Justia Constitutional Law Opinion Summaries

In 1995, a woman was murdered in Houston, and Carlos Ayestas was convicted of capital murder and sentenced to death. Years later, Ayestas’s counsel discovered an internal memorandum from the prosecution recommending the death penalty in part because Ayestas was not a U.S. citizen. This memorandum had not been disclosed during Ayestas’s trial. Ayestas then sought to amend his federal habeas petition to add Eighth and Fourteenth Amendment selective-prosecution claims, arguing that the prosecution’s decision was improperly influenced by his non-citizen status.The United States District Court for the Southern District of Texas denied Ayestas’s motion to amend, finding it constituted a “second or successive habeas corpus application” barred by 28 U.S.C. § 2244(b) because the claims could have been discovered earlier with due diligence. Subsequent Supreme Court decisions clarified the law on what constitutes a “second or successive” application, prompting Ayestas to seek relief under Rule 60(b). The district court granted this motion, allowed discovery on Ayestas’s selective-prosecution claims, and ordered the Harris County District Attorney’s Office (HCDA) to produce decades of charging memoranda and the full prosecutorial file.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that the discovery order was immediately appealable by the HCDA under the collateral-order doctrine. The Fifth Circuit determined the district court lacked jurisdiction over Ayestas’s selective-prosecution claims because both his 2015 motion to amend and his later Rule 60(b) motion constituted successive habeas applications barred by § 2244(b). The court concluded that Ayestas had not shown the claims were based on a new rule of constitutional law or that the underlying facts could not have been discovered earlier with due diligence. The Fifth Circuit vacated the discovery order and dismissed the selective-prosecution claims. View "Ayestas v. Harris County" on Justia Law

A teacher at a Texas junior high school, who is a practicing Christian, regularly engaged in prayer and Bible study with other teachers before the school day. In September 2023, she invited staff to join her in prayer at the school flagpole prior to a student-led prayer event. The school principal responded by stating that district policy prohibited employees from praying “with or in the presence of students” and clarified that even if students were not directly involved, teachers could not pray where students might see them, even before official school hours. When the teacher and colleagues prayed near the flagpole, the principal stopped them, reiterating the prohibition on visible religious conduct.The teacher filed suit in the United States District Court for the Southern District of Texas, alleging violations of her First Amendment free speech and free exercise rights, as well as Fourteenth Amendment equal protection and due process claims, and state law claims. The district court denied the principal’s motion to dismiss on the grounds of qualified immunity regarding the First Amendment and equal protection claims, but granted dismissal of the due process claim. The court held that the complaint plausibly alleged a categorical, visibility-based restriction on teacher prayer, and that Kennedy v. Bremerton School District had clearly established the unconstitutionality of such conduct.On interlocutory appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The appellate court affirmed the district court’s denial of qualified immunity for the free speech and free exercise claims, holding that a categorical ban on visible private prayer by teachers, merely because students might observe, violated clearly established First Amendment rights. However, the appellate court reversed as to the equal protection claim, finding that the teacher had not alleged facts showing the principal individually treated her differently than similarly situated employees. The disposition was affirmed in part and reversed in part. View "Barber v. Rounds" on Justia Law

A city-owned zoo in Alameda County is managed through a contract with a nonprofit corporation. In 2022, local voters approved an initiative, Measure Y, which imposed a parcel tax to fund zoo operations. The measure specified that tax revenue would be placed in a city fund and distributed to the “Zoo Operator” for certain uses. Measure Y identified the Conservation Society of California, the current nonprofit operator, by name and assigned it specific duties and powers related to the new tax revenue. The measure stated it would take effect if approved by a simple majority of voters and received 63.1% support.Following the election, the Alameda County Taxpayers’ Association and an individual filed a reverse validation action in the Superior Court of Alameda County, seeking to invalidate Measure Y. They argued that the measure violated article II, section 12 of the California Constitution by naming a private corporation to perform functions or have duties, and that the measure required a two-thirds supermajority to pass. The trial court sustained demurrers to the supermajority claims, finding only a simple majority was needed, and granted judgment on the pleadings as to the constitutional claims. The court concluded that any reference to the Conservation Society was either not a violation or, if so, was severable, leaving the rest of the measure valid. Judgment was entered for the city and the Conservation Society.On appeal, the California Court of Appeal, First Appellate District, Division Four, found that Measure Y’s references to the Conservation Society as the “Zoo Operator” violated article II, section 12 because they assigned specific functions and duties to a named private corporation. However, the court held these references could be severed without affecting the remainder of the measure, which would remain valid. The court further held that only a simple majority vote was required for passage. The trial court’s judgment was affirmed as modified to reflect severance. View "Alameda County Taxpayers' Assn., Inc. v. City of Oakland" on Justia Law

The case involves an early-morning stop of Juan Jose Ponce at a border checkpoint in Sarita, Texas, where a Border Patrol agent, Carlos Garcia, questioned him and observed unusual features in his vehicle. Ponce was driving an SUV with a roof rack but was transporting a ladder inside the car, which Garcia found atypical. Ponce appeared nervous and wore a surgical mask despite traveling alone. Upon request, Ponce consented to unlocking and opening the back hatch of his SUV for Garcia to look inside. During this inspection, Garcia noticed a speaker box with loose screws, which—based on his experience—suggested it might conceal contraband or a person. Garcia opened the speaker box and found a woman unlawfully in the United States. Ponce was indicted for transporting an undocumented person.Proceedings began in the United States District Court for the Southern District of Texas, where Ponce moved to suppress the evidence, arguing the search of the speaker box exceeded his consent and lacked probable cause. The district court held a hearing where both Ponce and Garcia testified. The court found Ponce’s consent to be valid, voluntary, and extending to containers within the vehicle. Even if consent did not reach the speaker box, the court determined Garcia obtained probable cause during his inspection. The district court denied the suppression motion, and Ponce entered a conditional guilty plea while preserving his right to appeal.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the lower court’s findings for clear error and legal conclusions de novo. The Fifth Circuit held that, based on the totality of the circumstances, Garcia obtained probable cause to search the speaker box during the consensual inspection. The court affirmed that Garcia’s actions were consistent with the Fourth Amendment, and upheld the denial of Ponce’s motion to suppress. View "USA v. Ponce" on Justia Law

After a road-rage incident in which a firearm was allegedly discharged, law enforcement investigated and tied the suspect to a residence using law enforcement databases, vehicle registration information, and visual surveillance. The police observed a vehicle matching the description from the incident parked at a house on West Iliff Lane, saw the suspect washing the car in the driveway, and watched him enter and exit the house. These observations occurred several weeks after the incident. Officers obtained a search warrant for the house and vehicle based on an affidavit summarizing the investigation and linking the suspect to the location. Execution of the warrant resulted in the discovery of firearms, ammunition, and controlled substances, leading to charges for drug offenses and possession of a firearm by a felon.The United States District Court for the District of Colorado denied the defendant’s motion to suppress the evidence, finding that the search warrant was supported by probable cause. The defendant pleaded guilty but preserved his right to appeal the suppression ruling. On appeal to the United States Court of Appeals for the Tenth Circuit, the defendant argued that the affidavit supporting the warrant failed to establish a sufficient nexus between the alleged offense and the residence and challenged the constitutionality of 18 U.S.C. § 922(g)(1) under the Second Amendment.The United States Court of Appeals for the Tenth Circuit concluded that the affidavit provided a substantial basis for finding probable cause, as law enforcement’s observations and the suspect’s connection to the residence justified the search. The court also held that the Second Amendment challenge to § 922(g)(1) was foreclosed by binding Tenth Circuit precedent. The judgment of the district court was affirmed. View "United States v. Becker" on Justia Law

A university student faced disciplinary action after three fellow students reported separate incidents in which, while intoxicated, he allegedly engaged in nonconsensual and increasingly violent sexual conduct. Following these reports, the student was placed on interim suspension and criminally charged with multiple felonies. The criminal proceedings included a preliminary hearing where two complainants testified under oath and were rigorously cross-examined by the student’s attorney. The criminal case concluded with a plea agreement.While the criminal case was ongoing, the university initiated its own disciplinary process. This included a multi-stage investigation and hearing pursuant to university policy. At the fact-finding hearing, the complainants chose not to testify or participate. The hearing officer relied on the prior sworn testimony from the criminal proceeding and other evidence, ultimately finding the student responsible for violating university policies with respect to two complainants. The student was expelled, and his university appeal was denied.The student then sought review in Alameda County Superior Court, arguing that he was denied due process because he could not cross-examine the complainants at the university hearing and that the university’s delay prejudiced his defense. The superior court denied his petition, finding that due process was satisfied by the opportunity for cross-examination at the criminal proceeding and that the delay was justified and not prejudicial.On appeal, the California Court of Appeal, First Appellate District, Division Two, affirmed the superior court’s judgment. The court held that due process does not require live cross-examination of complainants at a university disciplinary hearing when such an opportunity was provided during prior criminal proceedings, and that any procedural delay was supported by good cause and did not result in prejudice to the student. The judgment for the university was affirmed. View "Doe v. Regents of the Univ. of California" on Justia Law

James Williams, at midnight on New Year’s Day in Canton, Ohio, fired numerous shots into the air from a patio enclosed by a wooden privacy fence as part of a celebratory tradition. Officer Robert Huber, responding to the gunfire, arrived at the scene and witnessed Williams begin a second round of shooting. Without announcing his presence or issuing a warning, Huber shot Williams through the fence, resulting in Williams’s death. Williams’s wife sued Huber and the City of Canton, alleging excessive force under the Fourth Amendment and municipal liability.The United States District Court for the Northern District of Ohio reviewed Huber’s motion for summary judgment based on qualified immunity. The court determined that there was a genuine dispute of material fact regarding whether Williams had turned his rifle toward Huber or continued firing into the air, and whether celebratory gunfire was common in Canton at that time. Based on these unresolved factual questions, the district court denied Huber’s motion for summary judgment, finding that a reasonable jury could conclude Huber lacked probable cause to believe Williams posed a threat sufficient to justify deadly force.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of summary judgment. The Sixth Circuit held that, construing the facts in the light most favorable to Williams’s wife, Huber violated the Fourth Amendment by using deadly force without probable cause to believe Williams posed a threat of serious physical harm. The court further concluded that this violation was clearly established law in an “obvious” case, as no reasonable officer would have believed it permissible to shoot a person committing a misdemeanor—discharging a gun into the air in celebration—without warning or evidence of a threat. View "Williams v. City of Canton" on Justia Law

A young child, X.R., was left in the care of her maternal aunt, H.R., after her mother, J.R., struggled with substance abuse. The West Virginia Department of Human Services (DHS) initiated abuse and neglect proceedings that led to the termination of J.R.’s parental rights. During these proceedings, R.S. was identified as X.R.’s biological father. R.S. was adjudicated as an abusing parent due to lack of appropriate housing, but he successfully completed a court-ordered improvement period, demonstrating his ability to provide a stable environment. H.R. was recognized as X.R.’s psychological parent, having cared for her since birth.Following R.S.'s improvement period, the Circuit Court of Mason County ordered a parenting plan allocating equal custody and decision-making authority over X.R. to both R.S. and H.R., and dismissed the case. R.S. appealed, arguing that the plan violated his fundamental rights as a fit natural parent.The Supreme Court of Appeals of West Virginia reviewed the case and determined that, because R.S. had completed his improvement period and was not found to be unfit at the time of the final order, his parental rights were intact and paramount. The court found that the circuit court erred in granting H.R. equal custody and decision-making authority based solely on the child’s best interests, without a finding of parental unfitness or other justification that would overcome the natural parent’s rights.Accordingly, the Supreme Court of Appeals reversed the portion of the parenting plan granting equal custody and decision-making to H.R., vacated the remainder of the plan and the dismissal order, and remanded the case with instructions. The circuit court was directed to determine the scope of continued association between X.R. and H.R., giving special weight to the father’s preferences while also considering the child’s best interests. View "In re X.R." on Justia Law

Police officers in Calumet City, Illinois, responded to a 911 call in May 2015 reporting a man allegedly throwing a knife near a home. Upon arrival, officers spoke with the caller, who identified the suspect entering a residence. The officers knocked on the door, exchanged words with someone inside who told them to leave, and later decided to enter through an unlocked back door without a warrant, citing concerns for the safety of occupants due to a recent domestic violence report involving the address. Inside, officers found a woman who appeared unhurt and ultimately located Elias Villalobos hiding upstairs. The parties dispute whether Villalobos resisted or threatened the officers before he was tased and shot.Villalobos sued four officers in the United States District Court for the Northern District of Illinois, Eastern Division, alleging excessive force and unlawful entry under the Fourth Amendment. At summary judgment, the district court denied qualified immunity for most excessive force claims, finding factual disputes for trial. On the unlawful entry claim, however, the court granted partial summary judgment for Villalobos, concluding as a matter of law that the officers violated the Fourth Amendment by entering without a warrant and rejecting the officers’ exigent circumstances argument.The United States Court of Appeals for the Seventh Circuit reviewed only the denial of qualified immunity on the unlawful entry issue. The Seventh Circuit vacated the district court’s order, finding that the lower court did not address whether clearly established law put the officers on notice that their conduct was unlawful, as required for denying qualified immunity. The appellate court also noted unresolved factual disputes relevant to the exigent circumstances analysis. The case was remanded for further proceedings, instructing the district court to clarify the facts and address both prongs of the qualified immunity test. View "Villalobos v. Picicco" on Justia Law

A public port authority sought to acquire approximately twenty-nine acres of private, unimproved land owned by an individual in Plaquemines Parish, Louisiana. The expropriation was initiated as part of a larger project to develop a liquified natural gas (LNG) and container port complex. The authority intended to lease the acquired property to a private LNG company, Venture Global, for its exclusive development and use, including construction of LNG facilities and docks. The port authority asserted that the expropriation would serve public interests such as economic growth, job creation, energy security, and environmental stewardship, and advanced its mission of expanding port operations.After the port authority deposited the alleged just compensation in court, the landowner filed a motion to dismiss the expropriation, arguing that the taking lacked a public purpose under Louisiana law because its sole intent was to lease the land for private use. The Twenty-Fifth Judicial District Court for the Parish of Plaquemines held a contradictory hearing and granted the motion, finding the expropriation unconstitutional since the property would be used exclusively by Venture Global and not by the public port. The Louisiana Court of Appeal, Fourth Circuit, reviewed the decision and affirmed, concluding the port authority did not meet the public purpose requirement set by the Louisiana Constitution.The Supreme Court of Louisiana granted certiorari to address whether a public port authority may lawfully expropriate property for leasing to a private entity. The court held that such a taking, when the property is to be used predominantly by a private company, does not constitute a public purpose as defined in the Louisiana Constitution. The court affirmed the lower courts’ rulings, finding the expropriation prohibited and the motion to dismiss properly granted. View "PLAQUEMINES PORT HARBOR & TERMINAL DISTRICT VS. NGUYEN" on Justia Law