Justia Constitutional Law Opinion Summaries

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

The defendant was arrested for suspicion of driving under the influence of alcohol after a breath test revealed a blood alcohol content of 0.113, above the legal limit. He was charged with Operating a Vehicle Under the Influence of an Intoxicant (OVUII) and his bench trial began before a district court judge, who heard testimony from the State’s first witness. Before the trial was completed, that judge was elevated to the circuit court and was no longer able to finish presiding over the trial.After the first judge's departure, a second district court judge was assigned to the case. The second judge reviewed the prior record and continued the trial, denying any objection from defense counsel, who after consulting with the defendant, did not object to the substitution. The second judge heard the remainder of the State’s evidence, conducted a colloquy, and found the defendant guilty. The defendant appealed to the Intermediate Court of Appeals (ICA), arguing that his double jeopardy rights were violated by being tried before a second judge without a proper mistrial or on-the-record consent. The ICA affirmed the conviction, finding no error in the substitution or in the lack of an on-the-record colloquy.The Supreme Court of the State of Hawai‘i reviewed the case and held that the district court plainly erred by continuing the bench trial before a new judge after jeopardy had attached, without declaring a mistrial or obtaining the defendant’s consent to terminate the first trial. The court determined that, after the first judge left, the defendant was effectively subjected to a second prosecution for the same offense, in violation of his constitutional protection against double jeopardy. The Supreme Court vacated the ICA’s judgment and the district court’s conviction, and remanded the case for dismissal of the charge with prejudice. View "State v. Ellway." on Justia Law

After two employees and a former resident at a Medicare-participating nursing home in Maryland were diagnosed with active tuberculosis in 2015, county health officials determined that the facility was at high risk for transmission. The officials directed the facility’s staff to take responsibility for testing and follow-up for residents. The facility carried out skin tests and chest x-rays, identifying several residents with latent tuberculosis, but did not proceed to evaluate or treat those residents for latent TB, nor did it document reasons for not treating them. Over a year later, a state health agency investigated and concluded that the facility failed to ensure proper follow-up and documentation, violating federal infection control regulations. The Department of Health and Human Services (HHS) agreed, found that the noncompliance created “immediate jeopardy,” and imposed a per-day civil monetary penalty.The facility challenged the findings and penalty before an administrative law judge, who rejected its arguments and upheld both the finding of noncompliance and the penalty. The Departmental Appeals Board affirmed the administrative law judge’s decision.On review, the United States Court of Appeals for the Fourth Circuit considered whether the Seventh Amendment entitled the facility to a jury trial in HHS’s administrative proceedings for monetary penalties. The court held that there is no Seventh Amendment right to a jury trial in this context because the enforcement action at issue involves “public rights,” not common law claims. The court reasoned that Congress created novel statutory obligations for Medicare-participating facilities, not merely reclassified common law causes of action, and that these obligations are enforced through an administrative scheme distinct from common law torts or contract actions. The court also found that HHS’s actions were neither arbitrary nor capricious and that its decision was supported by substantial evidence. The petition for review was denied. View "Sligo Creek Center v. Health and Human Services" on Justia Law

The defendant pleaded guilty in the United States District Court for the Eastern District of North Carolina to charges including conspiracy to distribute controlled substances and unlawful possession of a firearm by a felon. As part of his plea agreement, he waived his right to appeal his conviction or sentence except for claims of ineffective assistance of counsel or prosecutorial misconduct. At sentencing, the district court found that three prior North Carolina convictions—including second-degree murder—qualified as violent felonies under the Armed Career Criminal Act (ACCA), resulting in an enhanced sentence of 360 months’ imprisonment. The defendant withdrew all objections to the presentence report at sentencing and was sentenced accordingly.On appeal to the United States Court of Appeals for the Fourth Circuit, the defendant argued that his North Carolina second-degree murder conviction did not qualify as a violent felony under the ACCA, and also that his firearm conviction was unconstitutional under the Second Amendment. The government moved to dismiss only the Second Amendment challenge based on the appeal waiver, and argued the merits regarding the ACCA issue. The court dismissed the Second Amendment challenge, but deferred ruling on the ACCA claim. The government later attempted to invoke the appeal waiver against the ACCA challenge, but the court found this argument forfeited as the government had already argued the merits without raising the waiver.The United States Court of Appeals for the Fourth Circuit held that the government forfeited its right to enforce the appeal waiver by failing to timely assert it. On the merits, the court held that North Carolina’s second-degree murder statute categorically qualifies as a violent felony under the ACCA, as it requires malice amounting to extreme recklessness akin to knowledge and always involves the use of physical force. The judgment of the district court was affirmed. View "US v. Goode" on Justia Law

An American citizen married to a Chinese national with valid H-1B status sought to have his spouse classified as an immediate relative under immigration law, the first step for her to obtain permanent residency. The citizen had a prior conviction for aggravated criminal sexual abuse involving a minor, which triggered application of the Adam Walsh Child Protection and Safety Act. Under this Act, a U.S. citizen with such a conviction can only sponsor an immediate-relative petition if the Secretary of Homeland Security, in “sole and unreviewable discretion,” determines the citizen poses no risk to the beneficiary. The United States Citizenship and Immigration Services (USCIS) denied both of the citizen’s petitions, finding he failed to show he posed no risk to his spouse.The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, raising statutory and constitutional challenges to the USCIS decisions. The district court dismissed all but one statutory claim for lack of jurisdiction, relying on the Act’s jurisdiction-stripping provisions and the “sole and unreviewable discretion” language. The remaining statutory claim was dismissed for failure to state a claim, with the district court finding that the Adam Walsh Act applies to beneficiaries of any age, not just minors.On appeal, the United States Court of Appeals for the Seventh Circuit agreed with the district court. The court held that it lacked jurisdiction to review statutory and constitutional claims attacking the USCIS’s denial and the processes used, as Congress clearly barred judicial review of both the decision and the methods for reaching it. The court further held that the one statutory claim they could review failed because the Act unambiguously applies to beneficiaries of any age. The court affirmed dismissal of all claims, either for lack of jurisdiction or for failure to state a claim. View "Liu v Mullin" on Justia Law

In 1985, Gerald Ross Pizzuto, Jr. was convicted by a jury in Idaho state court of murdering Berta and Del Herndon during a robbery, and he was sentenced to death. Over the following decades, Pizzuto challenged his conviction and death sentence through numerous state and federal post-conviction proceedings, but those efforts were unsuccessful. In 2021, Pizzuto sought clemency from the Idaho Commission of Pardons and Parole, which recommended that his death sentences be commuted to life without parole. However, the Governor of Idaho rejected this recommendation in accordance with an Idaho statute requiring gubernatorial approval for commutation in capital cases.Following the Governor’s denial, Pizzuto argued in Idaho state court that the Governor lacked authority under the Idaho Constitution to overrule the Commission’s recommendation. The Idaho Supreme Court upheld the statute granting the Governor final authority in capital commutation cases, concluding that a 1986 amendment to the Idaho Constitution permitted the legislature to establish the procedures for granting clemency. Pizzuto filed a petition for rehearing, asserting that the Idaho Supreme Court’s decision was so arbitrary as to violate his federal due process rights, but the Idaho Supreme Court summarily denied rehearing.Pizzuto then brought a habeas corpus petition in the United States District Court for the District of Idaho, raising the due process claim. The district court denied relief, finding that the claim was not cognizable in federal habeas and would fail on the merits. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed. The court held that Pizzuto’s claim essentially challenged the Idaho Supreme Court’s interpretation of state law, which is not a cognizable federal habeas claim. Even if the claim were cognizable, the court determined that Pizzuto did not demonstrate a due process violation under clearly established federal law, and the Idaho Supreme Court’s decision was not so arbitrary as to support habeas relief. View "PIZZUTO V. VALLEY" on Justia Law

Several media organizations challenged an Indiana policy that restricts attendance at state executions to a limited set of individuals, including prison officials, spiritual advisors, a small number of people invited by the inmate, and immediate family members of the victim. The policy does not allow members of the press or the general public to attend executions unless they are specifically invited by the inmate. While the guidelines permit media representatives to be present outside the execution chamber and to report freely on the event, they cannot witness the execution itself unless included on the inmate’s guest list.After filing suit under 42 U.S.C. § 1983 in the United States District Court for the Southern District of Indiana, the plaintiffs alleged that Indiana’s policy violated their First Amendment rights—specifically, the qualified right of access to certain government proceedings and the Press Clause. They sought declaratory and injunctive relief and soon requested a preliminary injunction to prevent enforcement of the state’s attendance restrictions for upcoming executions. The district court denied their motion, finding that the plaintiffs were unlikely to succeed on the merits. The court concluded that Supreme Court precedent on public access to criminal proceedings did not extend to executions and that Indiana’s rules did not discriminate against the press because they were treated the same as the public.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that executions have not historically been open to the press or the general public, so no qualified First Amendment right of access attaches. The court also determined that Indiana’s policy is generally applicable and does not target the press for unfavorable treatment in violation of the Press Clause. Accordingly, the denial of the preliminary injunction was affirmed. View "Associated Press v Neal" on Justia Law

A man was charged with aggravated kidnapping and rape after holding a woman hostage and abusing her over several months. After his arrest, the State filed charges, and during pretrial proceedings, questions arose regarding his competency to stand trial and his desire to represent himself rather than be represented by counsel. The district court found him competent and, upon his request, allowed him to proceed pro se, appointing standby counsel. He represented himself during several pretrial hearings, including a competency hearing in March 2018 and a motions hearing in May 2018, before ultimately requesting counsel during trial, at which point standby counsel took over. He was found guilty on all counts and sentenced to 331 months in prison.The Kansas District Court conducted the initial proceedings, including the hearings at issue. On appeal, a panel of the Kansas Court of Appeals concluded that the March and May 2018 hearings were critical stages at which the defendant did not have counsel and had not validly waived his right to counsel. The panel determined that these errors were structural and not subject to harmless error analysis, reversing his convictions and remanding for a new trial.The Supreme Court of the State of Kansas reviewed the case. It agreed that the March 2018 competency hearing and the portion of the May 2018 hearing regarding the State’s motion were critical stages and that the defendant had not validly waived his right to counsel at those stages. However, the court held that such errors are not categorically structural and may be subject to harmless error analysis, depending on the extent and circumstances of the deprivation. In this instance, the court found the errors harmless beyond a reasonable doubt because they did not affect the trial’s outcome. The court affirmed the district court’s judgment and partially affirmed and partially reversed the Court of Appeals’ decision. View "State v. Allen " on Justia Law

A woman convicted of attempted murder and sentenced to twenty-five years in the custody of the Mississippi Department of Corrections (MDOC) participated in various educational and rehabilitative programs during her incarceration. Despite her reclassification to minimum security and her involvement in these programs, MDOC did not grant her trusty earned time, which could reduce her sentence. She challenged this denial through MDOC’s Administrative Remedy Program, arguing that the legislature had not excluded those convicted of attempted murder from eligibility for trusty time and that MDOC lacked the authority to expand the list of ineligible offenses. She further asserted that, if such authority were delegated, it would violate the Mississippi Constitution’s separation of powers.After MDOC denied her request, citing internal policy and recent legislative changes, she sought judicial review in the Circuit Court of Rankin County. The circuit court upheld MDOC’s decision, concluding that the department had the statutory discretion to deny trusty earned time to her. She then appealed to the Supreme Court of Mississippi.The Supreme Court of Mississippi reviewed whether MDOC’s policy violated Mississippi Code Section 47-5-138.1 and whether the statute, as applied, was unconstitutional. The court determined that MDOC has authority to define trusty status and that the statutory requirements for trusty time eligibility only apply to inmates whom MDOC has already granted trusty status. Because the appellant was never given trusty status under MDOC’s classification, the statute did not entitle her to trusty time. The court also concluded that denying trusty time did not increase her sentence or violate the separation of powers, as inmates are not entitled to such reductions. Accordingly, the Supreme Court of Mississippi affirmed the decisions of MDOC and the circuit court. View "Hudson v. Department of Corrections" on Justia Law