Justia Constitutional Law Opinion Summaries

After a mass shooting in Lewiston, Maine in October 2023, which resulted in significant loss of life, the state enacted a law requiring a seventy-two-hour waiting period before a firearm seller may deliver a purchased firearm to the buyer. The law’s purpose was to reduce suicides and homicides associated with impulsive gun purchases. The statute contains exceptions for law enforcement officers, certain security personnel, family transactions, collectors, antiques, and cases where background checks are not required. Several individuals and firearms businesses challenged the law in federal court, alleging it violated their Second Amendment rights, both facially and as applied.The United States District Court for the District of Maine granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on the merits of their facial Second Amendment claim. The court applied the two-step framework from New York State Rifle & Pistol Ass’n, Inc. v. Bruen, first finding that the law implicated conduct covered by the plain text of the Second Amendment, and then determining that the state had not shown that the law was consistent with the nation’s historical tradition of firearms regulation. The district court also found that the other factors for granting a preliminary injunction were present.On appeal, the United States Court of Appeals for the First Circuit reviewed the matter de novo. The appellate court concluded that the seventy-two-hour waiting period regulates conduct antecedent to “keeping” or “bearing” arms, and thus does not directly implicate the plain text of the Second Amendment. The court found that the law imposes, at most, a presumptively lawful condition on the commercial sale of firearms, akin to “shall-issue” licensing regimes, and is constitutional unless shown to be abusive. The court determined that the plaintiffs had not shown the law was abusive toward Second Amendment rights. Accordingly, the First Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Beckwith v. Frey" on Justia Law

Law enforcement officers in Albuquerque arrested the defendant in February 2022 after observing him exit the driver's seat of a truck reported stolen. The truck contained two passengers, one of whom fled. A search uncovered an unopened vacuum-sealed bundle of methamphetamine weighing 445 grams and an unloaded revolver beneath the driver's seat. An assault rifle with a loaded magazine was found in the passenger seat, and a Ziploc bag containing 84 grams of methamphetamine was located in the back-seat area. The defendant later admitted to moving from the back seat. Evidence at trial included expert testimony regarding the function of the firearms, the value and distribution quantity of the drugs, and the common practice of drug traffickers possessing firearms for protection. Text messages demonstrated the defendant sought firearms after being robbed of drugs and a gun.The United States District Court for the District of New Mexico convicted the defendant of multiple offenses, but only the conviction for possessing firearms in furtherance of a drug-trafficking crime under 18 U.S.C. § 924(c) was at issue in this appeal. The defendant argued that the evidence was insufficient to support the conviction and that the “in furtherance of” language in the statute was unconstitutionally vague as applied to him.The United States Court of Appeals for the Tenth Circuit reviewed the appeal. The court held that, under its precedent, there was sufficient evidence for a rational jury to find that the defendant possessed firearms in furtherance of his drug-trafficking offense. The court also concluded that the statutory language was not unconstitutionally vague as applied. The Tenth Circuit affirmed the conviction, rejecting both the sufficiency and vagueness challenges. View "United States v. Jimenez-Marquez" on Justia Law

A law firm and one of its clients challenged Maine’s Interest on Lawyers’ Trust Accounts (IOLTA) program, which requires attorneys to deposit certain client funds into pooled, interest-bearing accounts. The interest generated is collected by a nonprofit, the Maine Justice Foundation, and distributed to organizations supporting access to justice in Maine. The plaintiffs argued that being compelled to participate in the program forced them to subsidize advocacy with which they disagreed, violating their First and Fourteenth Amendment rights.The United States District Court for the District of Maine dismissed the claims against the Chief Justice of the Maine Supreme Judicial Court and the State Court Administrator on the merits, concluding that the plaintiffs failed to state a claim. Specifically, the District Court found that, under Maine’s rules, only client funds that could not generate net interest for the client (due to the amount or duration) are required to be deposited in IOLTA accounts, and the plaintiffs did not plausibly allege otherwise. The claim against the Maine Justice Foundation was dismissed for lack of jurisdiction, as the Foundation neither promulgates nor enforces the challenged rule.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rulings. The appellate court held that the plaintiffs failed to plausibly allege they were compelled to deposit funds that would have generated net interest for the client, as required to make out a compelled-speech claim under controlling precedent. The court also found that any appeal of the dismissal against the Maine Justice Foundation was moot, since the complaint was fatally deficient regardless of the defendant. Thus, the First Circuit affirmed the judgment of the District Court. View "Wescott v. Stanfill" on Justia Law

Police discovered the bodies of two men, both shot in the head, in a burning car in Jackson County, Michigan. Barbara Mercer lived with her boyfriend, Richard Janish, and her friend, Jessica Campbell. Mercer had recently tricked one of the victims, Thomas, into giving her crack cocaine without payment, resulting in threatening messages from Thomas. The night of the killing, Mercer and Janish discussed the threats, and Janish ultimately shot and killed both victims. Mercer and Janish then attempted to destroy evidence by burning the bodies in the victims’ car. Both were arrested, and their statements to police, as well as Campbell’s testimony, formed the basis of the prosecution’s case. Mercer was convicted by a jury of two counts of second-degree murder, tampering with evidence, and arson.The Michigan Court of Appeals affirmed Mercer’s convictions, rejecting her claims that the trial court erred by denying a defense-of-others jury instruction, that her counsel was ineffective, and that the prosecutor committed misconduct during closing arguments. The Michigan Supreme Court denied further review. Mercer then filed a federal habeas petition in the United States District Court for the Eastern District of Michigan. The district court granted habeas relief on the ground that Mercer’s due process rights were violated when the trial court failed to give a defense-of-others instruction, but denied relief on her other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s grant of habeas relief on the jury-instruction claim, holding that Mercer’s claim did not satisfy the requirements for relief under the Antiterrorism and Effective Death Penalty Act. The Sixth Circuit affirmed the district court’s denial of relief on Mercer’s remaining claims regarding ineffective counsel and prosecutorial misconduct, finding that the state court’s decisions were not contrary to or unreasonable applications of clearly established federal law. View "Mercer v. Stewart" on Justia Law

The defendant was indicted under a federal statute that prohibits individuals convicted of crimes punishable by more than one year of imprisonment from possessing firearms. The defendant’s criminal history included prior convictions for armed robbery and aggravated battery, and the conduct leading to the present prosecution involved using a firearm to threaten passengers on public transportation and possessing a loaded semi-automatic weapon in a location where firearms were explicitly prohibited.The United States District Court for the Northern District of Illinois, Eastern Division, dismissed the indictment. The district court concluded that the statute in question, 18 U.S.C. §922(g)(1), was invalid on its face under the Second Amendment, meaning that it was unconstitutional in every possible application. The government appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court considered Supreme Court precedents regarding the Second Amendment, including District of Columbia v. Heller, McDonald v. Chicago, New York State Rifle & Pistol Association, Inc. v. Bruen, and United States v. Rahimi. The appellate court noted that, while there is disagreement among courts about the statute’s application in some circumstances, all courts of appeals have agreed that §922(g)(1) is valid in many applications and cannot be declared unconstitutional in all cases. The Seventh Circuit held that the statute cannot be found facially invalid and reserved judgment on whether it might be unconstitutional as applied to individuals whose prior convictions do not suggest they are dangerous. In this case, because the defendant’s convictions and conduct indicated a risk of dangerousness, the court reversed the district court’s dismissal and remanded the case for further proceedings. View "USA v Prince" on Justia Law

A group of prisoners in Illinois sued the state’s Department of Corrections, alleging that they were provided with inadequate medical and dental care, which they claimed violated the Eighth Amendment. The class was certified, and the parties reached a settlement that led to the entry of a consent decree. This decree required the Department to prepare an implementation plan, with oversight and recommendations from an independent monitor, to address the systemic deficiencies identified. Over time, disagreements arose regarding the adequacy and specificity of the Department’s proposals, and the monitor’s recommendations were largely adopted by the court after finding the Department in contempt for noncompliance.The United States District Court for the Northern District of Illinois, Eastern Division, approved and amended the consent decree, eventually adopting the implementation plan as part of it. The Department then filed several motions under Rule 60(b) to modify the consent decree, including requests to remove stipulations about compliance with the Prison Litigation Reform Act (PLRA) and to excise or terminate the implementation plan. The court denied these requests, but did acknowledge changed circumstances and amended the decree to clarify that the implementation plan would only be enforceable if the court made findings required by the PLRA. The court also extended the term of the consent decree due to the Department’s lack of substantial compliance.On appeal, the United States Court of Appeals for the Seventh Circuit found it lacked jurisdiction to review some orders, such as the denial of the motion to strike the stipulation and the extension of the decree, as these did not substantially alter the parties’ legal relationship. The court affirmed the lower court’s decisions regarding the implementation plan, holding that its terms are not enforceable unless and until the district court makes the factual findings required by 18 U.S.C. § 3626(a)(1)(A) of the PLRA. The case was remanded for further proceedings. View "Lippert v Hughes" on Justia Law

In this case, the defendant was indicted under federal law for possessing firearms after having been previously convicted of felony offenses, including possession of cocaine with intent to distribute and being a firearm user while using controlled substances. The case arose when police, investigating a shooting, traced evidence to the defendant through witness statements, storage unit searches, and DNA samples. The defendant challenged both the admissibility of DNA evidence and the constitutionality of the federal statute prohibiting felons from possessing firearms as applied to him.The United States District Court for the Eastern District of Wisconsin denied the defendant’s motions to dismiss the indictment and to suppress the DNA evidence. The court found that the DNA collected by federal authorities was obtained independently of any potentially unlawful prior collection by state authorities, and that there was a sufficient evidentiary basis for the federal warrant. The defendant subsequently pleaded guilty but preserved his right to appeal the denial of his motions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the legal conclusions de novo and factual findings for clear error. The Seventh Circuit affirmed the district court’s rulings. It held that the DNA evidence was admissible under the independent-source doctrine, as the federal warrant was based on evidence untainted by any prior illegality. The court also held that 18 U.S.C. § 922(g)(1), as applied to the defendant’s conviction for a dangerous felony (possession of cocaine with intent to distribute), did not violate the Second Amendment. The court reasoned that disarmament of individuals convicted of dangerous felonies is consistent with the nation’s historical tradition and supported by both categorical disarmament of dangerous groups and the historical imposition of severe penalties for such offenses. The judgment was affirmed. View "USA v Watson" on Justia Law

Kenneth Karwacki was convicted by a special court martial of delivering peyote to fellow soldiers and received a bad-conduct discharge from military service. Later, he applied for a permit to carry a concealed firearm in Wisconsin. The state denied his application under Wis. Stat. §941.29(1m)(b), which bars firearm possession by anyone convicted of a crime elsewhere that would be a felony if committed in Wisconsin. Although the military court labeled his offense a misdemeanor, Wisconsin classified his conduct as a felony under its own laws.Karwacki brought a federal lawsuit, arguing that Wisconsin’s decision to treat his military misdemeanor conviction as a state-law felony violated the Full Faith and Credit Clause of the U.S. Constitution and his Second Amendment rights. The United States District Court for the Eastern District of Wisconsin entered judgment in favor of the state, rejecting Karwacki’s claims.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that the Full Faith and Credit Clause does not apply to federal court martial convictions because such proceedings are not “judicial Proceedings of any other State,” nor has Congress prescribed any effect for court martial judgments in the states. The court also concluded that Wisconsin did not fail to give effect to the court martial’s judgment, as it imposed only collateral consequences under state law. Addressing the Second Amendment, the Seventh Circuit reasoned that neither the federal nor Wisconsin’s statutory scheme is facially invalid, and that individuals convicted of distributing illegal drugs are not entitled to as-applied relief from firearms disabilities. Therefore, the judgment was affirmed. View "Karwacki v Kaul" on Justia Law

Fifth Generation, Inc., a Texas-based liquor manufacturer and subchapter S corporation known for producing Tito’s Vodka, supplied increasing quantities of vodka to Maine between 2011 and 2017 without filing Maine pass-through-entity withholding or income tax returns. The company did not own real estate or hold itself out as doing business in Maine but shipped its products to a Maine state-operated bailment warehouse, as required by state law. Fifth Generation retained title to the goods in the warehouse until they were sold to the Maine Bureau of Alcoholic Beverage and Lottery Operations, and its out-of-state employees and broker occasionally accessed the warehouse.Maine Revenue Services conducted an audit and assessed over $748,000 in withholding, interest, and penalties against Fifth Generation. The company appealed to the Maine Board of Tax Appeals, which found no income tax nexus and canceled the assessment. The State Tax Assessor then sought de novo review in the Maine Superior Court (Kennebec County), which granted summary judgment for the Assessor, reinstating the assessment. Fifth Generation subsequently appealed to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court held that Fifth Generation was not exempt from state income tax during the audit period. The Court found that, under Maine law, Fifth Generation had a sufficient nexus with Maine because it owned tangible property in the state and sold it there. The Court also concluded that neither federal law (15 U.S.C. § 381(a)), the Commerce Clause, nor any constitutional provision barred the tax, as Maine’s regulatory scheme served a legitimate state purpose and was applied equally to in-state and out-of-state businesses. The Court further held that Fifth Generation did not have “substantial authority” to justify waiving penalties. The Superior Court’s judgment was affirmed. View "State Tax Assessor v. Fifth Generation, Inc." on Justia Law

A group of students, their parents or guardians, and local school boards from several low-wealth and urban school districts in North Carolina brought suit against the State and the State Board of Education in 1994. They claimed that the State’s method of funding education deprived students in their districts of their constitutional right to the opportunity for a sound basic education, focusing on perceived inadequacies in the implementation and funding of the Basic Education Program (BEP) as it then existed. The plaintiffs did not allege that the statewide education system was unconstitutional on its face, but rather that it was unconstitutional as applied to their specific districts due to disparities in resource allocation.After various procedural developments, including intervention by additional parties and the dismissal of some claims, the case reached the Supreme Court of North Carolina, which previously clarified that the right at issue belonged only to students, not school boards. The Supreme Court held in Leandro v. State that the constitution guarantees every child the opportunity for a sound basic education, and remanded the case for as-applied determinations regarding whether that right was denied in the named districts. In Hoke County Board of Education v. State, the Supreme Court affirmed a trial court finding that at-risk students in Hoke County had been deprived of their right, but otherwise found the statewide education system generally constitutional as then structured. The Supreme Court remanded for further as-applied proceedings in the other named districts, but no further trials occurred.Over time, the case’s subject matter shifted, and the trial court, with the parties’ acquiescence, began addressing a statewide, facial challenge to the current education system, including ordering the implementation of a statewide remedial plan without a new or amended complaint raising such a claim. The Supreme Court of North Carolina, reviewing an order entered on 17 April 2023, held that the trial court lacked subject matter jurisdiction to adjudicate a facial challenge to the statewide education system, since no party had properly invoked jurisdiction over such a claim by amending the pleadings or following the statutory procedure. The Court vacated the trial court’s order and dismissed the action with prejudice, concluding that any orders entered after 24 July 2017, when the litigation’s nature changed, were void for lack of subject matter jurisdiction. View "Hoke Cnty. Bd. of Educ. v. State" on Justia Law