Justia Constitutional Law Opinion Summaries

Law enforcement officers arrested an individual in a public parking lot while he was carrying a backpack. The arrest was pursuant to a warrant based on allegations of arson. After detaining him, officers seized the backpack and searched it a few minutes later, discovering a loaded handgun and drugs inside. The individual was subsequently charged with federal offenses.The defendant filed a motion in the United States District Court for the Northern District of Illinois, Eastern Division, seeking to suppress the evidence found in the backpack. He argued that the search violated the Fourth Amendment. The district court denied the motion, holding that the search was permissible under the inventory search exception to the warrant requirement. The defendant then pleaded guilty, reserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the search of the backpack was lawful. The court held that law enforcement may take custody of an arrestee’s personal property when the arrest occurs in a public place, and that an inventory search conducted according to established procedures is lawful. The court found that, although there were minor deviations from departmental policy in the way the search was conducted and documented, these did not render the search unreasonable. The court also rejected the defendant’s argument that officers acted in bad faith, finding no evidence to support this claim. Additionally, the court declined to consider a Fourth Amendment challenge to law enforcement’s use of a license plate reader database because the defendant forfeited the issue by not raising it earlier. Accordingly, the Seventh Circuit affirmed the district court’s denial of the suppression motion. View "USA v Fillyaw" on Justia Law

An association representing immigration judges challenged a policy issued by the Executive Office for Immigration Review, which required judges to obtain supervisory approval before making public statements relating to their official duties. The association claimed this policy violated its members’ First and Fifth Amendment rights. The dispute centered on whether such claims must proceed through the administrative review process established by the Civil Service Reform Act of 1978 (CSRA), which channels most work-related federal employee grievances to the Merit Systems Protection Board and the Special Counsel rather than federal district courts.The United States District Court for the Eastern District of Virginia concluded that the CSRA did indeed cover the claims, and therefore dismissed the association’s case for lack of district court jurisdiction. The association appealed, maintaining that its constitutional claims fell outside the scope of the CSRA’s jurisdiction-stripping provisions, but did not dispute that the CSRA generally channels review of covered claims out of district court.On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the association’s claims were covered by the CSRA. Nonetheless, the appellate court vacated the District Court’s judgment and remanded the case for additional factfinding, raising on its own initiative concerns about the current operation of the CSRA’s administrative review scheme—specifically, issues arising from challenges to tenure protections and the lack of a quorum at the Merit Systems Protection Board.The Supreme Court of the United States found that the Fourth Circuit erred by addressing issues not raised or argued by the parties, thus violating the principle of party presentation. The Supreme Court reversed the judgment of the Fourth Circuit and remanded for further proceedings consistent with its opinion. The main holding is that appellate courts may not decide cases on grounds not presented or argued by the parties. View "Margolin v. National Association of Immigration Judges" on Justia Law

The appellant was convicted in 2001 of lewd or lascivious conduct with a child aged 14 or 15, where he was at least 10 years older than the child, under California Penal Code section 288(c)(1). He also sustained a misdemeanor conviction for contributing to the delinquency of a minor. The section 288(c)(1) conviction required him to register as a tier three sex offender, which mandates lifetime registration. In 2022, the trial court reduced his section 288(c)(1) conviction to a misdemeanor, but this did not affect his tier three registration status.Following the reduction, he petitioned the Santa Clara County Superior Court under section 290.5 to terminate his sex offender registration, arguing that the lifetime registration requirement violated his right to equal protection because it treated offenders under section 288(c)(1) more harshly than those under section 288(a), who register as tier two offenders for a minimum of 20 years. The trial court summarily denied his petition, finding him statutorily ineligible for termination as a tier three registrant. The court relied on the Third District Court of Appeal’s decision in Legg v. Department of Justice, which upheld lifetime registration for section 288(c)(1) convictions against an equal protection challenge. The appellant timely appealed the denial.The California Court of Appeal, Sixth Appellate District, reviewed the appeal and determined that rational basis review applied, as sex offender registration does not involve a suspect class or fundamental right. The court held that there is a rational basis for imposing lifetime registration on section 288(c)(1) offenders, due to the minimum age gap and heightened concern about exploitation by significantly older adults. The court concluded that the legislative classification is constitutionally valid and affirmed the trial court’s order denying the petition to terminate sex offender registration. View "People v. Molina" on Justia Law

The case involves a defendant who shot and killed a 15-year-old during an attempted theft of his cell phone. The defendant, who was armed due to concerns over personal safety as a delivery driver, agreed to meet the buyer at a community center. When the victim grabbed the phone and fled, the defendant fired multiple shots, ultimately killing the victim. After the incident, the defendant cooperated with the police, turning himself in and providing his account of the events, asserting that he fired because he believed the victim was armed.The Superior Court of Los Angeles County charged the defendant with murder and a firearm enhancement. At trial, the jury acquitted the defendant of murder but convicted him of voluntary manslaughter and found the firearm enhancement true. After conviction, the defendant exercised his right to a jury trial on three aggravating sentencing factors. The trial court denied defense counsel’s request to argue these factors to the jury, instead instructing the jury directly and receiving findings that all three aggravating factors were true. The court imposed the middle term for manslaughter but the upper term for the firearm enhancement based on these findings.The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the case. The court held that a defendant has the right to have counsel argue to the jury regarding aggravating circumstances when those factors are submitted for a jury’s determination under Penal Code section 1170, subdivision (b)(2). The court found that denial of this right was not harmless error under the standard of Chapman v. California, as there was reasonable doubt that the jury would have reached the same findings absent the error. The appellate court reversed the jury’s findings on the aggravating circumstances and vacated the upper-term sentence for the firearm enhancement, affirming the judgment in all other respects and remanding for further proceedings. View "People v. Cardenas" on Justia Law

Renewable Redevelopment, LLC, a subsidiary of U.S. Wind, owns property in Sussex County, Delaware, and sought a conditional use permit from Sussex County to build an electrical substation supporting a major offshore wind project. The county’s Planning and Zoning Commission recommended approval, but after a public hearing, the Sussex County Council denied the permit. Renewable Redevelopment challenged the denial in the Superior Court. While that case was pending, the Delaware General Assembly enacted Senate Bills 159 and 199, which retroactively mandated approval of qualifying electrical substation permits and prohibited counties from actions that would undermine such applications. The Governor signed the bills the same day.Following this legislative action, Sussex County and the Town of Fenwick Island filed suit in the Court of Chancery, claiming the new statute violated the Delaware Constitution’s separation of powers, Article II, Section 25 (delegation of zoning authority), Article II, Section 16 (one-subject rule), and public due process rights. The Court of Chancery expedited the case, denied a temporary restraining order, and ultimately granted summary judgment for the defendants. The court found that Fenwick Island lacked standing, that separation of powers did not bar the General Assembly’s actions, that the Assembly retained ultimate zoning authority, that the statute’s title and subject matter complied with constitutional requirements, and that due process protections did not apply to the counties in this context.On appeal, the Supreme Court of Delaware reviewed the constitutional challenges de novo, affirmed the judgment, and held that: (1) separation of powers does not operate vertically within a branch and the General Assembly may override delegated zoning decisions; (2) Article II, Section 25 does not restrict the Assembly’s power to reclaim zoning authority; (3) the statute’s title and subject matter satisfied Article II, Section 16; and (4) no due process violation was shown. The Court affirmed the Court of Chancery’s summary judgment for the defendants. View "Town of Fenwick Island v. State" on Justia Law

Police received a call from a resident in a townhouse community who was personally acquainted with a local police officer, Sergeant Muollo. The caller, who contacted the officer directly on his cell phone rather than through the usual police line, reported that an unfamiliar black sedan with multiple occupants had been parked on her street for an extended period, with cell phones visibly in use inside the car, and expressed her suspicion that the occupants might be engaged in illegal activity, possibly breaking into vehicles. The officer, considering the caller credible due to their longstanding relationship, responded to the location, observed the described car, and, along with backup, blocked the vehicle’s exit. As the officer approached, the car moved slowly forward, which the officer interpreted as an attempt to turn around. He then activated his emergency lights, approached, and detected the odor of marijuana and observed contraband, leading to the arrest of the driver, who was also found in possession of a firearm.In the Circuit Court for Montgomery County, the defendant moved to suppress the evidence, arguing the stop was unsupported by reasonable suspicion. The circuit court denied the motion, finding the officer had reasonable suspicion based on the informant’s tip, the general level of crime in the area, and the movement of the vehicle when police approached. The defendant entered a conditional guilty plea and appealed. The Appellate Court of Maryland affirmed, concluding that, under the totality of the circumstances, the officer had reasonable suspicion, citing the tip from a known resident, the officer’s corroboration of the car’s presence, and testimony that the area experienced significant crime.The Supreme Court of Maryland reversed. The court held that, under the totality of the circumstances, the officer lacked reasonable suspicion to stop the car. The tip provided no basis for suspecting criminal activity beyond the car’s unfamiliarity and presence, and the officer’s corroboration only confirmed innocuous facts. The court further found the testimony about the area being high-crime was insufficiently particularized and not based on information known to the officer at the time of the stop. The judgment was reversed. View "Kopp v. State" on Justia Law

This case concerns two defendants, Paul Girard and Kareem Harry, who were tried and convicted in the U.S. Virgin Islands for multiple drug, firearm, and racketeering offenses connected to a violent criminal enterprise. Their trial took place in March 2022, shortly after COVID-19 restrictions on in-person court proceedings were partially lifted. On the first day of trial, public access to the courtroom was restricted, and spectators—including the defendants’ mothers—were directed to an overflow room with an audiovisual feed. Although the court later allowed some spectators into the courtroom, federal marshals continued to prevent the defendants’ mothers from entering for several days, even when seats were available.Following their convictions, Girard and Harry moved for a new trial in the District Court of the Virgin Islands, arguing that these restrictions violated their Sixth Amendment right to a public trial. The District Court held a hearing but ultimately found that public access was provided through the overflow room and that any interruptions in the audiovisual feed were brief. The court denied the motions for a new trial, concluding that the public was not excluded from the proceedings.On appeal, the United States Court of Appeals for the Third Circuit reviewed the case for plain error due to the lack of adequate contemporaneous objections during trial. The Third Circuit found that the defendants’ Sixth Amendment rights were violated when the courtroom was closed to all spectators on the first day and when their mothers were excluded on subsequent days without justification. However, the court held that these errors did not seriously affect the fairness, integrity, or public reputation of the proceedings. The court also rejected Harry’s claims regarding his rights to compulsory process and due process. Accordingly, the Third Circuit affirmed the judgments of conviction. View "USA v. Girard" on Justia Law

Law enforcement identified an individual using the eMule peer-to-peer file-sharing platform who was sharing files with hash values matching those of known child pornography. The account was traced to the defendant, who had a prior record of offenses involving minors. Despite being unable to directly download the flagged files from the defendant’s account, agents matched the hash values and observed filenames indicative of child pornography. The officers obtained a search warrant, searched the defendant’s residence, and seized numerous electronic devices. Forensic analysis uncovered tens of thousands of images and hundreds of videos containing child pornography.The United States District Court for the District of Arizona reviewed several pretrial motions. The defendant moved to suppress evidence, arguing the search warrant lacked probable cause since agents had not visually confirmed the files’ content and that the review of his publicly shared files violated his Fourth Amendment rights and the Wiretap Act. The defendant also moved to dismiss the indictment, claiming prejudice from forensic analysis conducted without counsel present, and argued selective prosecution due to his status as a registered sex offender. Following hearings, the district court denied all motions. After a jury convicted the defendant on all counts, the court also denied his Rule 29 motion for judgment of acquittal, and sentenced him to concurrent prison terms and supervised release.The United States Court of Appeals for the Ninth Circuit affirmed the conviction. The court held that hash value matches, even without visual confirmation, provided probable cause to support the search warrant, especially when reinforced by descriptive filenames and the defendant’s criminal history. The court found no Fourth Amendment or Wiretap Act violations because the files had been made publicly available. It ruled there was no right to counsel during the non-critical stage of forensic analysis and found no evidence supporting selective prosecution. The court declined to review the sufficiency of the evidence claim due to lack of argumentation. View "USA V. JOHNSEN" on Justia Law

Several researchers at the University of California received multi-year federal grants from agencies including the Environmental Protection Agency, the National Science Foundation, and the National Endowment for the Humanities. In April 2025, these agencies terminated the research grants by issuing form letters, citing shifts in agency priorities and referencing multiple Executive Orders issued by the President, some of which explicitly aimed to eliminate diversity, equity, and inclusion (DEI) and related initiatives from the federal government. The affected researchers alleged these terminations resulted in lost funding, harm to their reputations, and disruption to their projects, with no ready alternative sources of support.The researchers filed a class action lawsuit in the United States District Court for the Northern District of California, asserting constitutional and statutory claims, including violations of the First Amendment and the Administrative Procedure Act (APA). The district court provisionally certified two classes: one consisting of researchers whose grants were terminated by form letter without grant-specific explanation (the Form Termination Class), and another whose grants were terminated specifically due to the DEI Executive Orders (the DEI Termination Class). The district court granted a preliminary injunction, ordering the reinstatement of the grants for both classes. The government appealed.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiffs had established Article III standing. It reversed the preliminary injunction for the Form Termination Class, concluding that the district court likely lacked jurisdiction over their APA claim because the claim was essentially contractual and thus barred by the Tucker Act. However, the Ninth Circuit affirmed the preliminary injunction for the DEI Termination Class, finding that the class was likely to succeed on its First Amendment claim because the grant terminations were based on viewpoint discrimination. The court remanded for further proceedings. View "THAKUR V. TRUMP" on Justia Law

After observing a traffic violation, a sheriff’s deputy attempted to stop a driver who did not immediately pull over, instead proceeding to an apartment complex known for high criminal activity. The deputy observed the driver, who had prior narcotics and weapons convictions, behaving evasively and refusing to answer questions. Both the initial deputy and another responding officer detected the odor of marijuana emanating from the vehicle. During a frisk for weapons, an officer found what was believed to be a marijuana blunt in the driver’s pocket; the driver did not claim it was legal hemp. A subsequent warrantless search of the vehicle uncovered a firearm. The driver was indicted for carrying a concealed weapon and possession of a stolen firearm.In the Superior Court of Forsyth County, the defendant moved to suppress evidence from the searches, arguing that the odor and sight of marijuana could not, in light of the legalization of industrial hemp, provide reasonable suspicion or probable cause. The trial court denied the motion, citing the driver’s failure to stop, the high-crime location, prior convictions, evasive conduct, and the odor of marijuana as sufficient under the totality of the circumstances. The jury found the defendant guilty of carrying a concealed weapon but not guilty of possessing a stolen firearm.The North Carolina Court of Appeals affirmed, holding that the trial court did not err in denying the motion to suppress and that the defendant received a fair trial. On discretionary review, the Supreme Court of North Carolina held that under the totality of the circumstances—including but not limited to the odor of marijuana—officers had reasonable suspicion to frisk the defendant and probable cause to search the car. The odor of marijuana remains a relevant factor despite the existence of legal hemp. The decision of the Court of Appeals was modified and affirmed. View "State v. Rowdy" on Justia Law