Justia Constitutional Law Opinion Summaries

A childcare provider operating multiple daycare centers in Georgia participated in the state’s childcare voucher program, which is funded primarily by a federal grant and administered by the Georgia Department of Early Care and Learning. The provider agreement requires daycare centers to maintain arrival and departure records for each child and to make these records immediately available during on-site audits. In 2023, the Department conducted simultaneous audits at four of the provider’s locations. Only one location produced the required records during the audits, and the Department determined that the provider failed to comply with the investigation. The Department dismissed all of the provider’s centers from the voucher program, issuing notice that the dismissal was not appealable but allowing a grievance process. The provider attempted to contest the dismissal, but was repeatedly told it had no right to appeal.The provider brought suit in the United States District Court for the Northern District of Georgia against several Department officials, alleging a violation of due process and seeking a preliminary injunction for reinstatement in the program. The district court found that while the provider might suffer irreparable harm, it was unlikely to succeed on the merits of its due process claim because it lacked a property interest in continued participation in the program, and denied the motion for a preliminary injunction.The United States Court of Appeals for the Eleventh Circuit reviewed the denial of the preliminary injunction. Assuming without deciding that the provider had a property interest in continued participation, the court held that the provider was not entitled to a pre-deprivation hearing under the Due Process Clause. Applying the balancing test from Mathews v. Eldridge, the court concluded that additional procedural safeguards would not significantly reduce the risk of erroneous deprivation in this context. The court affirmed the denial of the preliminary injunction. View "iCare Child Development Center LLC v. Cicero-Brown" on Justia Law

Two individuals, each with multiple convictions for driving under the influence (DUI) within seven years in Washington State, challenged a state law that temporarily prohibits people with such convictions from possessing firearms. Their applications for concealed carry permits were denied based on this statute, and they subsequently filed a declaratory judgment action, arguing that the law violated their rights under the Second Amendment. The statute in question allows individuals disarmed under this provision to petition for restoration of firearm rights after five years of law-abiding conduct.The Spokane County Superior Court denied the State’s motion for judgment on the pleadings but granted its request for further factual development, ruling that there were material issues of fact—specifically, whether either petitioner posed a credible threat to public safety. The trial court allowed the as-applied constitutional challenge to proceed, focusing on whether an individualized assessment of dangerousness was required under recent Supreme Court precedent.The Supreme Court of the State of Washington granted direct interlocutory review. It held that, under the Second Amendment, the state may temporarily disarm individuals convicted of multiple DUI offenses without requiring an individualized determination of dangerousness. The court examined the nation’s historical tradition of firearm regulation, finding that longstanding analogs support disarmament of groups with a proven risk of dangerous conduct, such as repeated DUI convictions. The court reasoned that the law at issue is justified by the legislature’s determination that recidivist drunk drivers pose a special danger of firearm misuse, and that such temporary restrictions are consistent with historical tradition. The court reversed the superior court’s decision and remanded with instructions to enter judgment on the pleadings in favor of the State. View "McLellan v. Brown" on Justia Law

A police officer in Aberdeen, South Dakota, stopped a driver after observing him make a right turn at an intersection. The officer initiated the traffic stop because he believed the driver had violated a statute requiring a turn signal to be activated for at least 100 continuous feet before turning. The stop led to an arrest for driving under the influence, and a subsequent blood test showed a high blood alcohol concentration. The driver moved to suppress the evidence, arguing that the officer lacked legal justification for the stop because the relevant traffic law did not require a turn signal under the circumstances.The magistrate court held a suppression hearing and denied the motion, finding the statute required use of a turn signal for at least 100 feet before any turn. A court trial on stipulated facts followed, resulting in a conviction for DUI. The driver appealed to the Circuit Court for the Fifth Judicial Circuit, which affirmed the magistrate’s decision. The Circuit Court determined the officer had reasonable suspicion to stop the vehicle based on his observation of what he believed to be a traffic violation, and concluded that the statutory language encompassed the circumstances of the stop.Upon review, the Supreme Court of the State of South Dakota reversed. The Supreme Court held that the statutes governing turn signals require a signal only when another vehicle may be affected by the turn, and that the officer’s belief that a signal was always required was an objectively unreasonable mistake of law. Because the officer did not have reasonable suspicion based on a valid interpretation of the law, the stop was unconstitutional. The Supreme Court reversed the lower courts’ rulings and remanded the case for further proceedings. View "State v. Hawley" on Justia Law

In this case, the defendant was convicted of two counts of capital murder and three counts of terroristic threatening, with firearm enhancements, following the deadly shooting of a woman, Sade Turner, and her unborn child. The prosecution’s evidence included testimony that the defendant, along with his brother, drove to a location in Little Rock and fired multiple shots into a car driven by Turner. After the incident, the brothers returned home, and a burned vehicle matching their Jeep was later found. A key piece of evidence involved a phone conversation overheard by Mykell McFee, who later recounted this conversation to law enforcement during an investigation into a separate murder.During the trial in the Pulaski County Circuit Court, McFee was called as a witness but claimed not to recall the details of his statements made during his interview with police. The prosecution played a recording of McFee’s interview over the defendant’s objection, which was based on the argument that McFee’s lack of memory rendered him unavailable for effective cross-examination, thus violating the defendant’s Sixth Amendment confrontation rights. The Pulaski County Circuit Court overruled the objection, determining that because McFee was present and subject to questioning, there was no confrontation violation.On appeal, the defendant argued to the Supreme Court of Arkansas that the introduction of statements made by another individual, now deceased, within the recorded interview further violated his confrontation rights. The Supreme Court of Arkansas held that this particular argument was not preserved for appellate review because it had not been specifically raised at trial. The court affirmed the conviction, concluding that only the objection presented to the trial court was preserved and that the new confrontation argument could not be considered. View "HOLLOWAY v. STATE OF ARKANSAS" on Justia Law

At a school board meeting in Xenia, Ohio, a member of the public sought to use her allotted time during the public comment period to criticize the school district’s handling of alleged critical race theory instruction, as well as the conduct of the superintendent and board. Although her remarks were calmly delivered, board president Mary Grech interrupted her, threatened to cut her microphone, and eventually did so, recessing the meeting amid disruptions from the audience. The speaker was not permitted to complete her five-minute comment, nor was she allowed additional time after the meeting resumed.The individual who was silenced brought a lawsuit against the school board and its president under 42 U.S.C. § 1983, arguing that her First Amendment rights were violated. She sought a preliminary injunction to prevent enforcement of the board’s public comment policy against her in the future. The United States District Court for the Southern District of Ohio conducted a hearing and denied the request for a preliminary injunction. The court concluded that the plaintiff had not demonstrated a strong likelihood of success on the merits or irreparable harm, and found the facts and motives for the board president’s actions to be equivocal.The United States Court of Appeals for the Sixth Circuit reviewed the matter and reversed the district court’s denial of the preliminary injunction. The appellate court held that the plaintiff’s speech—critical of school officials—was protected by the First Amendment and did not fall into any unprotected category. The court found that the board president engaged in impermissible viewpoint discrimination by curtailing speech because of its critical content, and also ratified a heckler’s veto by silencing the speaker rather than the disruptive audience. The Sixth Circuit concluded that the plaintiff demonstrated a strong likelihood of success on the merits and that irreparable harm to constitutional rights was presumed. The case was remanded with instructions to grant the preliminary injunction. View "Boddy v. Grech" on Justia Law

Jewel Sanitary Napkins, a Georgia-based company, sells feminine hygiene products that it claims provide health benefits, including products containing graphene. The company developed a market among the Amish community and advertised its products through Busy Beaver Publications, which circulates regional advertising papers to that community. In August 2022, Busy Beaver published an ad submitted by a reader, Betty Lantz, that questioned the safety of Jewel's products, suggesting that graphene could attract electrical waves or radiation and pose health risks. The ad was published anonymously at Lantz’s request. Jewel asserted that the ad contained false statements and damaged its reputation.After the ad’s publication, Jewel contacted Busy Beaver to request a retraction, but Busy Beaver instead offered free advertising, consistent with its policy of not issuing retractions. Jewel declined and sued in the United States District Court for the Western District of Wisconsin for libel and trade libel. During discovery, Jewel sought the original ad submission. Busy Beaver initially believed the form had been destroyed per company practice, but later obtained it from Lantz and provided it to Jewel. Jewel withdrew a related spoliation motion but then sought sanctions over the delay. The district court denied Jewel’s motions, including a request to reopen summary judgment briefing, and granted summary judgment to Busy Beaver.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. It held that, under Wisconsin law and the First Amendment standard for public figures, Jewel failed to present evidence that Busy Beaver acted with actual malice when publishing the ad. The appellate court also found no abuse of discretion in denying sanctions against Busy Beaver. The court affirmed the district court’s judgment in favor of Busy Beaver. View "Jewel Sanitary Napkins, LLC v Busy Beaver Publications, LLC" on Justia Law

A 15-year-old girl, E.R., stayed overnight at her friend G.T.’s home, where G.T.'s uncle, Rayford Evans, also lived. The morning after the sleepover, E.R. saw a cell phone through a bathroom transom window while she was bathing, which was quickly withdrawn. She believed Evans had tried to record her and reported this to G.T., who, with E.R., informed G.T.'s father, Ancel Teal. Teal coordinated with E.R.'s parents, one of whom was a sheriff’s deputy. Law enforcement was notified, and Officer Smith from the Doniphan Police Department responded. He confronted Evans at the home, requested Evans’s phones, and ultimately seized one phone after Evans initially objected but then acquiesced. Evans then consented in writing to a search of the phone, which led to the discovery of videos of E.R. nude in the bathroom.In the United States District Court for the Eastern District of Missouri, Evans was charged with attempted sexual exploitation of a minor. He moved to suppress the evidence from the warrantless seizure and search of his cell phone, arguing his consent was involuntary and that neither exigent circumstances nor the inevitable discovery doctrine applied. The district court denied the motion, found Evans guilty after a bench trial, and sentenced him to 252 months’ imprisonment. Evans renewed his suppression motion and sought a new trial, both of which were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that exigent circumstances justified the warrantless seizure of Evans’s phone because there was a reasonable belief Evans could imminently destroy evidence, and probable cause existed. The subsequent written consent to search the phone was voluntary. The court also held that sufficient evidence supported the conviction for attempted sexual exploitation of a minor. The judgment was affirmed. View "United States v. Evans" on Justia Law

A group of correctional officers was terminated by the Illinois Department of Corrections after an incident involving a wheelchair-dependent inmate who refused to comply with orders to place his hands through a cuffing port for removal of handcuffs. Instead of following certain established protocols, the lead officer decided not to activate the tactical team or notify a supervisor, but instead assembled additional officers to enter the inmate’s cell. The officers attempted to remove the handcuffs, leading to a physical altercation in which the inmate resisted, was dragged out of his cell, sprayed with pepper spray, and then left tethered in a shower area for two hours. Incident reports filed by the officers failed to accurately describe the use of force, omitting details such as dragging the inmate.Following an internal investigation, administrative hearings, and review by the Illinois Civil Service Commission, the officers were discharged for violating rules that require force to be used only as a last resort and for submitting false reports. The Commission found that the officers had other options available, had sufficient time to consider alternatives, and that the use of force was not justified as a first response. The Commission also concluded that the failure to report the incident accurately was egregious.The officers filed suit in the United States District Court for the Central District of Illinois, contending that the Department’s use-of-force rules were unconstitutionally vague and thus their termination violated their Fourteenth Amendment due process rights. The district court granted summary judgment to the defendants, finding the rules were sufficiently clear.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. It held that the “force as a last resort” rule was not unconstitutionally vague as applied to the officers, providing fair warning of prohibited conduct, and that the truthful reporting requirements were also sufficiently clear. The grant of summary judgment for the defendants was affirmed. View "Hundley v. Brookhart" on Justia Law

Several non-profit organizations focused on trappers’ rights challenged a New Mexico statute that broadly prohibits the use of traps, snares, or wildlife poison to capture, injure, or kill animals on public land. The statute includes an exception allowing enrolled members of federally recognized Indian nations, tribes, or pueblos to trap for religious or ceremonial purposes under rules that have not yet been promulgated. The plaintiffs did not contest the general prohibition on trapping, but argued that the exception violates constitutional and statutory rights, specifically invoking the Equal Protection and Establishment Clauses of both the U.S. and New Mexico Constitutions, as well as the New Mexico Civil Rights Act.The United States District Court for the District of New Mexico dismissed the plaintiffs’ federal and state constitutional claims without prejudice, holding that the plaintiffs lacked standing. The court found their economic, recreational, aesthetic, and psychological injuries were not redressable because striking the exception would not lift the general ban on trapping. It also determined that their alleged stigmatic injury was not judicially cognizable and, in any event, their claims were not ripe because the rules implementing the exception had not been issued. The court declined to exercise supplemental jurisdiction over the remaining state statutory claim.The United States Court of Appeals for the Tenth Circuit affirmed. The court held that the plaintiffs failed to establish standing. First, their alleged injuries from not being allowed to trap were not redressable, as invalidating the exception would not affect the underlying prohibition. Second, their claims of psychological and stigmatic injury were not ripe for review, as the exception had not been implemented, and any harm was too abstract and generalized to support standing. The appellate court also found no error in the district court’s decision to decline supplemental jurisdiction over the state law claim. View "New Mexico Trappers Association v. Torrez" on Justia Law

Several cities challenged recent Texas legislative changes that reduced the fees cities could charge telecommunications companies for using public property alongside city streets. The cities argued that requiring them to charge less than market rates for this use amounted to an unconstitutional gift to the telecom companies, contrary to the Texas Constitution’s Gift Clauses. Seeking a judicial declaration to this effect, the cities sued the State of Texas as the sole defendant, asserting that the statutory rate reductions were unconstitutional.At the trial level, the district court partially granted the cities’ request for a declaratory judgment. The Court of Appeals for the Third District of Texas went further, largely siding with the cities and holding that the statutory reductions violated the Gift Clauses. The State then sought review by the Supreme Court of Texas.The Supreme Court of Texas determined that the lower courts lacked jurisdiction over the case because the cities had sued the wrong defendant. The court explained that in constitutional challenges to state statutes, the proper defendant must be the officer or agency with authority to enforce the challenged law, not the State of Texas in the abstract. The court noted that the cities failed to identify any such officer or agency, and there was no indication that any state official had enforced or threatened to enforce the challenged statutes against the cities. Because a judgment against the “State of Texas” would not redress the cities’ alleged injuries nor bind the telecommunications companies, the dispute lacked the concrete adversarial parties necessary for a justiciable controversy. The Supreme Court of Texas vacated the judgments of the lower courts and dismissed the case for lack of jurisdiction. View "STATE v. CITY OF MCALLEN" on Justia Law