Justia Constitutional Law Opinion Summaries

In 1977, a 14-year-old was questioned by police in Peoria, Illinois, about the murder of two teenagers. Over roughly two days, police and a polygraph examiner interrogated him, at times using harsh tactics. He eventually confessed and was convicted of first-degree murder. The state appellate court later overturned the conviction, finding the confession involuntary. He was retried, convicted again, and served decades in prison before being released on parole in 2006. In 2014, he was pardoned by the governor. Years later, he filed a civil suit under 42 U.S.C. § 1983 against 16 former police officers, the City of Peoria, and the polygrapher, alleging unlawful detention, coercion of his confession, and destruction and fabrication of evidence.The United States District Court for the Central District of Illinois denied summary judgment to the defendants, concluding that material factual disputes precluded resolution of the unlawful detention claim, that clearly established law would have put the officers and the polygrapher on notice their interrogation tactics were unconstitutional, and that a reasonable jury could find evidence destruction and fabrication in violation of established law.On appeal, the United States Court of Appeals for the Seventh Circuit reversed. The court held the officers were entitled to qualified immunity for the unlawful detention claim, finding they had arguable probable cause based on the totality of the circumstances. The court also found no evidence the officers destroyed evidence in bad faith or at a time when its exculpatory value was apparent, and held there was no clearly established law making their actions unconstitutional at the relevant times. Additionally, the court concluded that the coercion claim failed because no then-existing precedent put the unconstitutionality of the officers’ interrogation methods “beyond debate.” Finally, the court held the officers were entitled to absolute immunity for testimony at trial, even if it was consistent with allegedly fabricated evidence not introduced at trial. Accordingly, the district court’s denial of immunity was reversed. View "Savory v Andrews" on Justia Law

A public interest law firm known for its advocacy on religious liberty and free speech was included on a list of "hate groups" published by the Southern Poverty Law Center (SPLC) in 2015, and has remained on the list since. In February 2019, Michigan’s Attorney General and the then-Director of the Michigan Department of Civil Rights issued a press release responding to the SPLC’s latest "Hate Map," noting an increase in such groups and announcing new state initiatives. Although the press release did not name the law firm, it linked to the SPLC report. The law firm alleged that it suffered reputational, economic, and organizational harm as a result, claiming a chilling effect on its First Amendment rights and seeking declaratory and injunctive relief against the officials.The United States District Court for the Western District of Michigan initially found that the law firm had adequately pleaded standing, as the press release arguably conferred the state’s “imprimatur” on the SPLC’s list, potentially harming the law firm’s reputation. The court denied the officials’ motion to dismiss at the pleading stage. However, following discovery and summary judgment motions, the district court concluded that the law firm failed to present sufficient evidence of a cognizable injury in fact traceable to the defendants’ actions or likely to be redressed by the requested relief, and granted summary judgment for the officials on standing grounds.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment ruling de novo. The Sixth Circuit held that the law firm had not demonstrated that the officials’ press release caused it any incremental reputational or economic injury beyond that resulting from the SPLC’s designation, nor that any such injury was ongoing or likely to recur. The court further found the law firm’s diversion-of-resources theory forfeited and unsupported. The judgment for the defendants was affirmed. View "Am. Freedom Law Center v. Nessel" on Justia Law

The dispute centers on a property owner that purchased a vacant and dilapidated parcel in Nashville’s East Bank district, intending to redevelop it into a multi-family residential project in accordance with local zoning rules. The owner submitted a building permit application that, according to its allegations, fully complied with all applicable zoning requirements. However, in mid-2022, the local government placed an indefinite “development hold” on the property, effectively barring any consideration or approval of the permit. The stated reason was that authorities were assessing possible routes for a planned major roadway that might require acquisition of part of the property. As a result, the owner claims the property has become undevelopable and unsellable, resulting in millions of dollars in carrying costs.After unsuccessful efforts to have the hold lifted, the owner filed suit in state court, alleging violations of the Takings and Due Process Clauses of the U.S. Constitution and the Tennessee Constitution. The case was removed to the United States District Court for the Middle District of Tennessee, where the defendants moved to dismiss on several grounds, including untimeliness and qualified immunity. The district court, on its own initiative, dismissed the complaint for lack of “jurisdictional” ripeness, reasoning that there had been no final decision on the permit application.On appeal, the United States Court of Appeals for the Sixth Circuit considered only the ripeness issue. The court held that the owner’s claims were both constitutionally and prudentially ripe because the local government’s development hold constituted a definitive, final decision barring any development of the property. The appellate court reversed the district court’s dismissal and remanded the case for further proceedings on the remaining issues. View "SW Nashville EB Owner, LLC v. Metro. Gov't of Nashville & Davidson Cnty." on Justia Law

Law enforcement officers sought and obtained a no-knock search warrant for a residence in an area known as Kent Bottom, Maryland, based on an affidavit describing the area's reputation for drug activity, criminal histories of individuals associated with the area, and surveillance of suspected drug transactions near the property. The affidavit included descriptions of drug-related incidents from as far back as 2006 involving the residence, as well as more recent but less direct observations of possible drug activity in the general vicinity of the house. The more recent surveillance involved suspected hand-to-hand transactions outside the residence and people entering and leaving the property, but did not directly connect current criminal activity to the interior of the home.After the search, officers recovered drugs and a firearm from a vehicle parked outside the residence. The defendant, who was found inside the house, was charged with several drug and firearm offenses. He moved to suppress the evidence, arguing that the warrant lacked probable cause because the affidavit failed to establish a meaningful connection between the alleged criminal activity and the specific residence. The United States District Court for the District of Maryland denied the motion, reasoning that the history and geography of drug activity in Kent Bottom, along with the observed conduct near the residence, provided a sufficient basis for probable cause.The United States Court of Appeals for the Fourth Circuit reversed. It held that the warrant affidavit did not provide a substantial basis for probable cause to search the residence because the facts were either too old, not specifically tied to the home, or both, and therefore failed to establish a fair probability that evidence of a crime would be found inside the house at the time of the search. The court also determined that the good-faith exception did not apply, as the affidavit was so lacking in indicia of probable cause that no reasonable officer could rely on it. The court reversed the district court’s denial of the motion to suppress, vacated the conviction, and remanded for further proceedings. View "US v. Griffin" on Justia Law

The defendant was indicted on multiple counts of statutory sexual offense with a child and indecent liberties with a child. Over a period of approximately fifty months, the defendant was represented by five different court-appointed attorneys, each of whom either withdrew due to conflicts, personal reasons, or at the defendant’s request. Dissatisfied with his representation, the defendant twice filed handwritten documents titled “Waiver of Counsel,” with the first explicitly requesting to proceed pro se with standby counsel. The trial court conducted a colloquy with the defendant to assess whether he knowingly, intelligently, and voluntarily wished to waive his right to counsel, ultimately finding that he did and assigning standby counsel. The defendant represented himself at trial, with standby counsel examining witnesses upon the State's motion. The jury convicted him on several counts, and he was sentenced to a minimum of seventy-five years.After conviction, the defendant appealed. The North Carolina Court of Appeals vacated the judgments and remanded for a new trial, holding that the defendant had neither knowingly nor voluntarily waived his right to counsel, and therefore, his convictions could not stand.Upon review, the Supreme Court of North Carolina reversed the decision of the Court of Appeals. The Supreme Court held that, under the totality of the circumstances—including the defendant’s two written waivers, his in-court statements, and his consistent course of conduct—the defendant clearly and unequivocally expressed his intent to proceed without counsel. The Court further held that the trial court’s colloquy, while not perfectly precise as to the full range of potential punishments, substantially complied with statutory requirements because both the misstated and actual sentences amounted to more than the defendant’s natural life. Accordingly, the Supreme Court determined that the waiver of counsel was valid and reinstated the trial court’s judgment. View "State v. McGirt" on Justia Law

A middle school student in the Alamance-Burlington School District alleged that her teacher violently assaulted her in the classroom. The teacher, who was not licensed at the time, reportedly grabbed the student, slammed her into a door, and then onto the ground, causing physical and emotional harm. After the incident, the Board of Education suspended the student, later reversed the suspension when media reported on the attack, but still transferred her to an alternative school without her consent. The student’s academic performance suffered as a result.The student, through her guardian, sued the teacher and the Board of Education in Superior Court, claiming assault, emotional distress, negligent hiring and supervision, and violations of the North Carolina constitutional right to a sound basic education. The Board moved to dismiss, arguing sovereign immunity on the tort claims and failure to state a constitutional claim. The Superior Court granted the Board’s motion, dismissing all claims against it. The North Carolina Court of Appeals affirmed, finding that the student had not adequately alleged waiver of sovereign immunity or a constitutional violation under relevant precedent.On appeal, the Supreme Court of North Carolina reviewed whether the student’s complaint stated a viable constitutional claim. The Supreme Court held that, accepting the allegations as true, the Board’s actions—suspending and transferring the student after she was assaulted by a teacher—could constitute deliberate indifference to her right to access a sound basic education under the state constitution. The Court found the student lacked any other adequate remedy due to sovereign immunity and that her complaint met the necessary elements for a direct constitutional claim. The Supreme Court reversed the Court of Appeals and remanded for further proceedings. View "K.H. v. Dixon" on Justia Law

The case concerns a defendant whose vehicle crossed the center line and collided with a motorcycle, resulting in the deaths of both riders. The defendant left the scene but later turned himself in. He was charged with several offenses, including driving while impaired, felony hit and run, attaining violent habitual felon status, and two counts of second-degree murder. Before trial, the defendant pled guilty to driving while license revoked and, through written stipulations and oral colloquies, admitted to several facts related to the charges, including being the driver, the collision, and his revoked license status.At trial in the Superior Court of Rowan County, the defendant’s counsel, with the defendant’s partial consent, conceded certain elements of the offenses. During closing argument, counsel asked the jury to find the defendant guilty of the lesser included offenses—misdemeanor death by vehicle and misdemeanor hit and run—without explicitly seeking a not guilty verdict. The jury convicted the defendant of two counts of second-degree murder and felony hit and run. The defendant appealed, arguing his counsel provided ineffective assistance by conceding guilt to the lesser charges without his knowing consent.The North Carolina Court of Appeals held that, under State v. Harbison, a defense counsel’s admission of guilt without the defendant’s consent is per se ineffective assistance, and remanded for an evidentiary hearing to determine if the defendant had consented. The State sought discretionary review.The Supreme Court of North Carolina clarified that, following Florida v. Nixon, the per se prejudice rule of Harbison is limited. The general standard for ineffective assistance of counsel is Strickland v. Washington’s two-prong test, unless the narrow United States v. Cronic exception applies (where the defendant is wholly surprised by the concession). Because the defendant was not wholly surprised and could not show prejudice, the Supreme Court of North Carolina reversed the decision of the Court of Appeals. View "State v. Farook" on Justia Law

A Chinese drone manufacturer and its subsidiary challenged their designation by the U.S. Secretary of Defense as a “Chinese military company” under Section 1260H of the National Defense Authorization Act. The designation, which is published annually, restricts the company from contracting with certain government agencies and can damage its business reputation. DJI was added to the list in 2022 and again in 2024 and 2025 without prior notice. DJI petitioned for removal, which was denied, and subsequently received a report explaining the designation, though portions of the rationale were redacted.DJI filed suit in the United States District Court for the District of Columbia, alleging violations of the Fifth Amendment’s Due Process Clause and the Administrative Procedure Act. The company argued that it was denied due process, that there was insufficient evidence for the designation, that the agency failed to explain disparate treatment compared to other companies, and that the Secretary’s finding that DJI “contributes” to the Chinese defense industrial base was unsupported. The district court granted summary judgment against DJI, relying solely on the unclassified administrative record and declining to review the classified materials.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The appellate court affirmed the district court’s rejection of DJI’s due process, evidentiary, and disparate treatment claims, holding that DJI failed to show deprivation of a protected liberty or property interest, and that sufficient evidence supported the finding that DJI received government assistance. However, the appellate court reversed the district court’s conclusion regarding DJI’s “contribution” to the Chinese defense industrial base, finding that the lower court improperly relied on post hoc agency arguments and failed to review the classified record. The case was remanded for further proceedings on that issue. View "SZ DJI Technology Co., Ltd. v. DOD" on Justia Law

Three Venezuelan nationals, alleged by the government to be members of the Tren de Aragua gang, were detained in Texas following a presidential proclamation under the Alien Enemies Act (AEA). This proclamation, issued in March 2025, authorized immediate removal of Venezuelan citizens aged fourteen or older, residing in the United States, who were not naturalized or lawful permanent residents and were identified as members of the gang. The petitioners challenged the proclamation, arguing that it exceeded the President’s authority under the AEA and violated due process rights. They sought class certification and injunctive relief to prevent removal under the AEA.The United States District Court for the Northern District of Texas denied temporary restraining orders and class certification. On appeal, the Fifth Circuit initially dismissed the case for lack of jurisdiction. The Supreme Court, in A.A.R.P. v. Trump, vacated that dismissal and remanded, instructing the Fifth Circuit to address two issues: whether the petitioners were entitled to a preliminary injunction against removal under the AEA, and whether the notice provided for due process claims was sufficient for the putative class. The Supreme Court also allowed the government to remove the petitioners under other lawful authorities.After remand, the three named petitioners were removed from the United States under the Immigration and Nationality Act (INA), not the AEA. The United States Court of Appeals for the Fifth Circuit concluded that, because the petitioners were no longer in the country and no class had been certified, it was impossible to grant any effectual relief. The Fifth Circuit dismissed the appeal as moot for lack of jurisdiction, declining to substitute new class representatives on appeal but leaving open the possibility for future proceedings in the district court. View "W.M.M. v. Trump" on Justia Law

Four professors employed by Indiana’s public universities brought a facial constitutional challenge against a new state law, which mandates that university boards adopt and enforce policies promoting “free inquiry, free expression, and intellectual diversity.” The law conditions tenure and promotion decisions, as well as periodic reviews of tenured faculty, on compliance with these principles. The professors argued that these requirements, and related university policies, compelled them to alter their teaching and course materials, thereby chilling their First Amendment rights. They described changes they made to their syllabi and teaching practices out of concern for violating the law or university policies, but none had faced discipline or explicit threats as a result.Previously, the United States District Court for the Southern District of Indiana dismissed the professors’ initial suit for lack of standing, finding no credible threat of enforcement since the law regulated university boards rather than faculty directly. After the universities adopted “interim” policies to implement the law, the professors sued again, targeting both the statute and these new policies. The district court again dismissed the case, reasoning that the professors’ fears of enforcement were speculative because the policies were not final and no actions had been taken against them under the new regime.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal for lack of subject-matter jurisdiction. The Seventh Circuit held that the professors failed to establish Article III standing, as they did not demonstrate a credible threat that the law or university policies would actually be enforced against them, nor an objectively reasonable chilling effect on their speech. The court emphasized that neither the indirect application of the law nor the interim status of the policies categorically precluded standing, but found that the record did not support a sufficient injury-in-fact to proceed. View "McDonald v Trustees of Indiana University" on Justia Law