Justia Constitutional Law Opinion Summaries

Three individuals filed a class action lawsuit against San Francisco, challenging new water rates adopted by the city’s Public Utility Commission in May 2023. The plaintiffs alleged that the new rates violated Proposition 218 of the California Constitution by including costs unrelated to the actual provision of water service, resulting in charges that exceeded the cost of service. Before adopting the new rates, the city provided required notice to ratepayers, including information about a 120-day period for legal challenges under the applicable validation statutes. The plaintiffs sought a refund, declaratory and equitable relief, and a writ of mandate.After the class action was filed, the City litigated the case for over a year. It participated in discovery, case management, and even moved for summary judgment, without initially arguing that the suit was procedurally improper. Eventually, the City moved for judgment on the pleadings, arguing that plaintiffs’ action was subject to the validation statutes, specifically Government Code section 53759 and Code of Civil Procedure sections 860 et seq., which require reverse validation actions attacking agency matters like water rates to be brought within 120 days and with specific notice by publication to all interested parties. The trial court (San Francisco County Superior Court) agreed with the City, finding the statutes mandatory and jurisdictional, and dismissed the case for failure to comply with the procedural requirements, including timely filing and appropriate notice.On appeal, the California Court of Appeal, First Appellate District, Division Two, reviewed the judgment de novo. The court held that compliance with the validation statutes was mandatory and jurisdictional. Plaintiffs’ failure to file a proper reverse validation action and to provide notice by publication deprived the court of jurisdiction. The court rejected arguments that the City had waived these requirements or that good cause existed for noncompliance. The judgment in favor of the City was affirmed. View "Toy v. City & County of S.F." on Justia Law

An inmate incarcerated at an Indiana prison was twice transported by correctional officers between the facility and a hospital in June 2019. During the first transport, after a medical appointment, the inmate was placed in a van in restraining gear that prevented him from buckling his seatbelt, and the officers refused to buckle it for him. One of the officers then drove the van in a manner the inmate described as reckless, resulting in a sudden stop that threw the inmate to the floor and caused a broken collarbone. The inmate alleged the officers made threatening remarks referencing his prior grievances against staff and later colluded to create consistent incident reports. On the second transport, after surgery, the inmate was buckled in but not placed in the more secure area he requested. Officers drove in a way that jostled his recent injuries, deliberately drove over rough terrain and railroad tracks, and laughed in response to his pain.The United States District Court for the Southern District of Indiana allowed the inmate’s Eighth Amendment claims against three officers to proceed, along with First Amendment retaliation claims. At summary judgment, the district court granted qualified immunity to all three officers on the Eighth Amendment claims, finding that the law was not clearly established for the conduct alleged, and entered judgment for the officers. The court analyzed the claims under both deliberate indifference and excessive force standards, depending on the officer’s role and the facts alleged.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed in part and vacated in part. The court held that the officer who failed to buckle the inmate’s seatbelt and did not intervene during reckless driving on the first transport was not entitled to qualified immunity, as it was clearly established that subjecting a restrained inmate to reckless driving without a seatbelt posed a substantial risk of serious harm. However, the court affirmed summary judgment for the officers involved in the second transport, finding the law was not clearly established that their conduct—though troubling—violated the Eighth Amendment under the specific facts presented. The case against the first officer was remanded for further proceedings. View "Smith v. Price" on Justia Law

A nonprofit organization dedicated to election integrity requested a copy of Wisconsin’s voter registration list, seeking access under the National Voter Registration Act (NVRA). Wisconsin, however, is exempt from the NVRA because it has permitted same-day polling-place registration since before August 1, 1994. The state processed the request under its public-records law, which required redaction of birth dates and imposed a fee of $12,500 due to the size of the list. The organization objected to both the fee and the redactions, arguing that Wisconsin’s exemption from the NVRA was unconstitutional.The United States District Court for the Western District of Wisconsin dismissed the case. The district judge held that the plaintiff’s claims—asserting violations of the “equal state sovereignty” principle from Shelby County v. Holder and the “congruence and proportionality” requirement from City of Boerne v. Flores—were not supported by law. While the judge found that the plaintiff had Article III standing due to the alleged financial injury, he expressed doubt about prudential standing but decided the case on the merits, concluding that neither cited Supreme Court decision undermined the validity of Wisconsin’s exemption.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The court agreed that the plaintiff had Article III standing but questioned prudential standing, as the legal theories invoked state, rather than individual, rights. Nonetheless, the court bypassed this issue, holding that the NVRA’s exemption for states like Wisconsin does not violate equal state sovereignty or the congruence and proportionality standard. The court emphasized that the exemption relieves, rather than imposes, federal regulatory burdens and that Congress acted under its Elections Clause authority, making City of Boerne inapplicable. The Seventh Circuit affirmed the district court’s dismissal. View "Public Interest Legal Foundation, Inc. v. Wolfe" on Justia Law

A deputy sheriff in Gwinnett County, Georgia, was terminated from his position following allegations that he engaged in extramarital affairs during work hours and while using county resources. An anonymous letter triggered an internal investigation, which included a polygraph examination. After being confronted with the charges, the deputy was issued a pre-termination notice and ultimately fired. He appealed his termination but later entered into a settlement in which the Sheriff's Office agreed to treat his departure as a resignation. Subsequently, a local news outlet obtained and reported on his personnel file, and the deputy learned the identity of the person behind the anonymous letter.The former deputy and his wife filed a lawsuit in the United States District Court for the Northern District of Georgia, asserting claims for procedural due process and equal protection violations under the Fourteenth Amendment, as well as state law defamation. The district court granted summary judgment to the Gwinnett County officials on all claims, finding insufficient evidence to proceed.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s grant of summary judgment on the procedural due process and defamation claims. The court held that the plaintiff could not maintain a procedural due process claim because he failed to exhaust available state remedies before pursuing federal relief. The defamation claim failed due to a lack of evidence connecting the defendants to the alleged leak. However, the court vacated the summary judgment on the equal protection claim and remanded with instructions to dismiss that claim for lack of standing, because private citizens generally have no judicially cognizable interest in whether another individual is prosecuted. The officials’ cross-appeal was dismissed as moot. View "Peden v. Stephens" on Justia Law

The petitioner was convicted of murder after a jury trial in which a key witness, who had been involved in the crime and was separately charged, testified for the state. Before trial, the petitioner’s counsel inquired whether any deal or understanding of leniency existed between the state and the witness, but the prosecutor denied there were any assurances. During cross-examination, the witness denied having been promised any benefit in exchange for his testimony but indicated he was hoping his cooperation would help him at sentencing. Shortly after the petitioner’s conviction, the witness received a notably lenient sentence in his own criminal case, pursuant to a plea agreement.The petitioner subsequently filed for habeas corpus, alleging that the state had failed to disclose an informal cooperation agreement with the witness and had allowed the witness to deny such an agreement under oath, thus violating his due process rights under Napue v. Illinois. At the habeas trial in the Connecticut Superior Court, the witness, his defense counsel, and three prosecutors all testified that there was no cooperation agreement. The habeas court found no such agreement existed and denied the petition. The Connecticut Appellate Court affirmed this judgment.On appeal, the Supreme Court of Connecticut clarified that prosecutors have a duty to correct false or substantially misleading testimony about both formal and informal cooperation agreements, including those that are implied, unwritten, or tacit. The court held that, while lenient treatment alone does not prove an agreement, courts must consider whether prosecutors’ conduct created an expectation of leniency and whether the witness acted on that expectation. Because the record was insufficient to determine whether all parties understood what constitutes an informal agreement in this context, the Supreme Court remanded the case to the habeas court for further factual findings, while retaining jurisdiction for a final decision on the appeal. View "Moore v. Commissioner of Correction" on Justia Law

Law enforcement conducted a two-month investigation in New Orleans into two relatives, Terence Wilson and Travis Enclade, suspected of trafficking methamphetamine, fentanyl, and heroin. Surveillance techniques included pole cameras, physical observation, GPS tracking, and phone analysis at several residences linked to the defendants. Footage and investigative findings suggested hand-to-hand drug transactions, shared access to a stash house, and the presence of firearms. During a jailhouse call following Wilson’s arrest, coded language was used to direct Enclade to narcotics later found in a kitchen cabinet. Subsequent searches of three residences uncovered large quantities of drugs, distribution materials, and multiple firearms.The United States District Court for the Eastern District of Louisiana presided over the trial, where both defendants were convicted by a jury of conspiracy to distribute controlled substances. Wilson was also convicted of possession with intent to distribute and being a felon in possession of firearms, while Enclade was convicted of being a felon in possession of firearms. Both were acquitted on one count related to possessing firearms in furtherance of drug trafficking. The district court sentenced Enclade to 288 months and Wilson to 240 months, both below the Guidelines range. Defendants challenged the sufficiency of the evidence, evidentiary rulings, jury instructions, the conduct of the prosecutor, denial of a continuance, their sentences, and the constitutionality of 18 U.S.C. § 922(g)(1).The United States Court of Appeals for the Fifth Circuit reviewed the convictions and sentences. The court held that the evidence was sufficient for all convictions, that any evidentiary errors or improper prosecutorial remarks did not prejudice the defendants, and that the district court did not abuse its discretion in its rulings. The court further held that § 922(g)(1) was constitutional and that Enclade’s sentence was reasonable. The Fifth Circuit affirmed the district court’s judgment. View "USA v. Enclade" on Justia Law

A group of registered voters in South Carolina, all under the age of sixty-five, challenged a provision of state law that restricts “no excuse” absentee-by-mail voting to voters sixty-five years of age or older. These plaintiffs argued that the statute unconstitutionally discriminates against them on account of age, in violation of the Twenty-Sixth Amendment, and also violates the Equal Protection Clause of the Fourteenth Amendment. The law at issue allows voters sixty-five and older to vote absentee by mail for any reason, while voters under sixty-five can only do so if they meet specific, narrow criteria such as disability, military service, or certain employment conflicts.The case was initially heard in the United States District Court for the District of South Carolina, where the court granted summary judgment in favor of the defendants—the South Carolina State Election Commission and related officials—on both constitutional claims. The district court found that the plaintiffs did not demonstrate a violation of either the Twenty-Sixth Amendment or the Equal Protection Clause. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. This court held that the plaintiffs have standing and that South Carolina’s age-based absentee-by-mail voting scheme violates the Twenty-Sixth Amendment because it abridges the right to vote on account of age by providing greater ballot access to older voters. However, the court affirmed the district court’s decision to dismiss the Equal Protection claim, as age is not a suspect classification under the Equal Protection Clause and the plaintiffs did not challenge the law under rational basis or Anderson-Burdick scrutiny. The Fourth Circuit reversed the district court’s judgment on the Twenty-Sixth Amendment claim, affirmed the Equal Protection ruling, and remanded the case for appropriate remedy. View "Grant v. Belangia" on Justia Law

A kindergarten teacher in Mississippi was frustrated after being unable to use a remote entry service to unlock her car and, during a customer service call, told an agent that she was aggravated and might “kill some little kindergarteners.” She reiterated this after her issue was resolved, saying the agent had “saved 20 children from being killed.” The agent reported the statements to the police. The responding officers met with the teacher, who admitted to the remarks but said they were taken out of context. After consulting with an Assistant District Attorney, the teacher was charged with making terroristic threats, processed, and jailed. A grand jury declined to indict her.The teacher filed suit in the United States District Court for the Southern District of Mississippi against the city, the chief of police, and an officer, alleging false arrest, false imprisonment, malicious prosecution under state and federal law, and a Fourteenth Amendment violation. The defendants moved for summary judgment, asserting qualified immunity. The district court denied their motion, and the defendants appealed.The United States Court of Appeals for the Fifth Circuit held that the officers were entitled to qualified immunity, finding that the facts known to the officers at the time provided probable cause for arrest, defeating the constitutional claims. The court also found that, even if the officers erred, the right to be free from arrest under these circumstances was not clearly established. The appellate court reversed the district court’s denial of qualified immunity and declined to exercise pendent jurisdiction over the state law and municipal liability claims, remanding those for further proceedings. View "Bonds v. Woodall" on Justia Law

In 2017, Indiana enacted a statute known as the “aid-or-assist” law, which prohibits any person from knowingly or intentionally assisting an unemancipated pregnant minor in obtaining an abortion without fulfilling the state’s parental consent and notice requirements. Planned Parenthood, a nonprofit operating health centers in Indiana, regularly provides minors with factually accurate information and referrals about lawful abortion services in neighboring states, particularly after Indiana enacted more restrictive abortion laws following Dobbs v. Jackson Women’s Health Organization. Both parties agreed that, without adherence to Indiana’s parental consent law, providing such information would violate the aid-or-assist statute, exposing Planned Parenthood and its physicians to civil liability and professional discipline.After the law’s passage, Planned Parenthood filed suit in the United States District Court for the Southern District of Indiana, challenging the statute under the First Amendment as applied to its provision of information and referrals to minors about lawful out-of-state abortion services. The district court initially granted a preliminary injunction, and after changes in federal and state abortion law, ultimately issued a permanent injunction preventing enforcement of the aid-or-assist law as applied to Planned Parenthood’s speech and referrals about legal abortion practices in other states. The district court reasoned that the statute was a content-based restriction on protected speech and failed strict scrutiny.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the permanent injunction, with one modification: it removed the Commissioner of Health as a defendant because the Commissioner no longer had authority to provide relief. The Seventh Circuit held that Planned Parenthood’s provision of information and referrals about legal out-of-state abortion services was protected speech under the First Amendment. The court found that Indiana’s law, as applied, was a content- and viewpoint-based restriction that failed strict scrutiny, as it was not narrowly tailored to serve compelling state interests. The injunction was affirmed as modified. View "Planned Parenthood Great Northwest, Hawai'i v Commissioner of the Indiana State Department" on Justia Law

A pharmaceutical company that manufactures both branded and generic drugs challenged the federal agency rules implementing the Medicare Drug Price Negotiation Program created under the Inflation Reduction Act of 2022. Specifically, the company objected to two rules: first, the agency’s grouping of two drugs with the same active ingredient and manufacturer, but approved under separate applications, as one “qualifying single source drug” for price negotiation; and second, the agency’s requirement that a generic drug must be engaged in “bona fide marketing” to be considered as marketed, which affects when a branded drug exits the negotiation program. The company argued that these rules exceeded the agency’s statutory authority and that the program deprived it of protected property interests without due process.The United States District Court for the District of Columbia reviewed the case. It found that the statutory bar on judicial review did not prevent the company’s challenges to generally applicable agency guidance. On the merits, the district court upheld the agency’s definition of a qualifying single source drug, ruled that the challenge to the “bona fide marketing” standard was not yet ripe, and rejected the due process claim due to lack of a protected property interest. The company appealed.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The appellate court held that the statutory review bar precludes review only of drug-specific determinations, not generally applicable legal standards. On the merits, it concluded that the statute permits the agency to treat drugs with the same active ingredient and manufacturer as one statutory drug. The court found that the due process challenge failed because the company lacked a protected property interest. However, it determined that the challenge to the “bona fide marketing” requirement was ripe and remanded that issue to the district court for further proceedings. The court thus affirmed in part, reversed in part, and remanded. View "Teva Pharmaceuticals USA, Inc. v. Kennedy" on Justia Law