Justia Constitutional Law Opinion Summaries

Petitioners Jennifer McGill and Cherokee Nation Entertainment, LLC challenged the sufficiency of a proposed constitutional amendment regarding the Pope County casino license. They alleged that the Arkansas Secretary of State, John Thurston, improperly certified the amendment for the ballot. The petitioners claimed that the number of valid signatures was insufficient and that the popular name and ballot title were inadequate. Local Voters in Charge (LVC), the sponsor of the amendment, and Jim Knight intervened in the case.The Arkansas Supreme Court had previously granted expedited consideration and bifurcated the proceedings into two counts. For Count I, the court appointed a special master to resolve factual disputes about the number of valid signatures. The special master found that LVC had properly certified that no paid canvasser had disqualifying offenses and that LVC did not violate the pay-per-signature ban. The special master disqualified some signatures but concluded that LVC still had enough valid signatures to meet the requirement.The Arkansas Supreme Court reviewed the special master’s findings and determined that LVC complied with the statutory requirements for certifying paid canvassers. The court also found that the petitioners did not provide sufficient evidence to prove that LVC violated the pay-per-signature ban. As a result, the court denied the petition on Count I, allowing the proposed amendment to remain on the ballot. The court’s decision was based on the lack of clear error in the special master’s findings and the petitioners' failure to meet their burden of proof. View "McGill v. Thurston" on Justia Law

The case involves a dispute between a taxpayers' association and a water district over the imposition of groundwater replenishment charges. The taxpayers' association alleged that the water district's charges violated constitutional provisions and unfairly benefited large agricultural businesses. The association sought a writ of mandate to stop the collection of these charges and to vacate the resolutions imposing them. They also claimed conversion, civil conspiracy, aiding and abetting, and violations of the Unfair Competition Law (UCL) against the water district's board members, general manager, and consulting firms.The Superior Court of Riverside County denied the defendants' anti-SLAPP motion, which sought to strike several causes of action on the grounds that they arose from protected activities. The court found that the public interest exemption to the anti-SLAPP statute applied. Additionally, the court sustained the defendants' demurrer to the first amended petition and complaint, finding the claims time-barred under the validation statutes. The court also awarded over $180,000 in attorney's fees to the plaintiffs, deeming the anti-SLAPP motion frivolous.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the public interest exemption did not apply because the relief sought could only be provided by the water district, not the individual defendants. The court found that the anti-SLAPP motion should have been granted for most causes of action, except for conversion and the writ of mandate against the general manager. Consequently, the fee award was reversed. The court also affirmed the demurrer ruling, as the claims against the individual defendants were not legally sufficient. The case was remanded for further proceedings consistent with these findings. View "Howard Jarvis Taxpayers Assn. v. Powell" on Justia Law

Joe Baltas, a Connecticut state prisoner, was transferred to the Virginia Department of Corrections (VADOC) under the Interstate Corrections Compact. While at Red Onion State Prison (ROSP) in Virginia, Baltas alleges he was threatened by VADOC officials for filing a grievance and was later attacked by inmates, resulting in his placement in restrictive housing. He also claims that Connecticut Department of Corrections (CTDOC) officials failed to review his administrative segregation (Ad Seg) status as required, violating his due process rights under the Fourteenth Amendment. Additionally, he alleges violations of his First, Sixth, and Eighth Amendment rights due to his treatment at ROSP.The United States District Court for the District of Connecticut granted summary judgment in favor of the Defendants. The court found that CTDOC had adequately reviewed Baltas’s Ad Seg classification and dismissed his due process claim. It also dismissed his First, Sixth, and Eighth Amendment claims, concluding that Baltas failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the District Court’s ruling that CTDOC’s periodic reviews of Baltas’s Ad Seg classification satisfied due process requirements. However, it found that a genuine dispute of fact existed regarding whether VADOC’s administrative remedies were available to Baltas, making summary judgment inappropriate for his First, Sixth, and Eighth Amendment claims. The court vacated the summary judgment on these claims and remanded the case for further proceedings. The court also affirmed the dismissal of Baltas’s remaining claims in a concurrently issued summary order. View "Baltas v. Maiga" on Justia Law

A sixteen-year-old defendant, concerned that a poor Spanish grade might hinder his plans to study abroad, conspired with a friend to murder his Spanish teacher. They meticulously planned and executed the murder, later bragging about it to classmates. The defendant initially lied to the police but eventually pleaded guilty to first-degree murder, agreeing to challenge only his sentence. At sentencing, the State recommended life imprisonment with parole eligibility after thirty years, while the defendant argued against any minimum term. The district court sentenced him to life with parole eligibility after thirty-five years.The Iowa District Court for Jefferson County rejected the defendant's argument that a minimum sentence required expert testimony. The court considered various factors, including the impact on the victim's family and community, the defendant's role in the crime, and his potential for rehabilitation. The court found that the severity and premeditation of the crime warranted a minimum term of thirty-five years before parole eligibility.The Iowa Supreme Court reviewed the case, focusing on whether sentencing juvenile offenders to a minimum term before parole eligibility violates the Iowa Constitution and whether expert testimony is required to impose such a sentence. The court upheld the district court's decision, ruling that the Iowa Constitution does not categorically ban minimum sentences for juveniles and that expert testimony is not mandatory. The court found that the district court properly considered the relevant factors and did not abuse its discretion in sentencing the defendant to life with the possibility of parole after thirty-five years. The sentence was affirmed. View "State of Iowa v. Miller" on Justia Law

The defendant, Sylvester Gailes, has a history of domestic violence, including multiple incidents where he physically assaulted his partners. In 2012, he struck his girlfriend in the face, and in 2014, he dragged her by her hair and kicked her in the head. In 2018, he assaulted another ex-girlfriend, choking her and threatening her with a handgun. Gailes was convicted of domestic-violence misdemeanors for each of these incidents. Later, during a traffic accident investigation, police found Gailes in possession of two loaded pistols, leading to his indictment for violating 18 U.S.C. § 922(g)(9), which prohibits individuals convicted of domestic-violence misdemeanors from possessing firearms.The United States District Court for the Western District of Tennessee denied Gailes's motion to dismiss the indictment, in which he argued that 18 U.S.C. § 922(g)(9) is unconstitutional in light of the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen. Gailes then pleaded guilty to the charges and was sentenced to 50 months in prison. He appealed the district court's decision, challenging the constitutionality of the statute under the Second Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court applied the two-step framework from Bruen, first determining that the Second Amendment's plain text covers Gailes's conduct. The court then examined whether the statute is consistent with the Nation's historical tradition of firearm regulation. The court found that historical analogues, such as surety laws and "going armed" laws, support the constitutionality of disarming individuals who pose a clear threat of physical violence. Consequently, the court held that 18 U.S.C. § 922(g)(9) is facially constitutional and affirmed the district court's judgment. View "United States v. Gailes" on Justia Law

Adam Richardson, a citizen and taxpayer, petitioned the Supreme Court of Florida for writs of quo warranto and mandamus, alleging that the Governor, Attorney General, and Secretary of the Florida Agency for Health Care Administration (AHCA) violated section 104.31, Florida Statutes, by advocating against a proposed constitutional amendment (Amendment 4) related to abortion rights. Richardson claimed that their actions, including statements on an AHCA webpage and social media, as well as participation in a public call and opinion piece, unlawfully interfered with the vote on Amendment 4.The lower courts did not review this case as it was directly brought to the Supreme Court of Florida. Richardson argued that the respondents' actions violated a statute limiting political activities of state officers and employees, which he believed should be enforced through extraordinary writs.The Supreme Court of Florida denied the petition. The court held that the writ of quo warranto is traditionally used to test the right of a person to hold an office or exercise a state-derived power, not to compel criminal prosecution or enable private enforcement of a criminal statute. The court found that Richardson's grievances were more about the merits of the respondents' actions rather than their authority to act. Additionally, the court denied the writ of mandamus, stating that Richardson did not establish a clear legal right or an indisputable legal duty on the part of the respondents, nor did he show that there was no other adequate remedy available. The court concluded that no further relief was required to complete the exercise of its jurisdiction and denied the petition without permitting a rehearing. View "Richardson v. Secretary, Florida Agency for Health Care Administration" on Justia Law

Plain-clothes detectives from the Central Ohio Drug Enforcement Task Force observed Terrance Cunningham, a known suspected drug trafficker, driving a minivan. They relayed this information to Detective Benjamin Martens, who confirmed that Cunningham did not have a valid driver’s license. Detective Martens located the minivan in a convenience store parking lot, where Cunningham was standing next to the vehicle and Katrina Hale, the passenger, was exiting the store. When questioned, Cunningham claimed Hale was the driver. Hale, appearing nervous, was detained by Detective Martens, who subsequently searched her purses and found methamphetamines.The Licking County Common Pleas Court found that Hale was no longer a passenger when detained and granted her motion to suppress the evidence obtained during the stop, including her statements and the contents of her purses. The court reasoned that since Hale was not in the vehicle at the time of the stop, the detention was unjustified. However, the court did not address whether the search of Hale’s purses was justified independently of her detention.The Fifth District Court of Appeals reversed the trial court’s decision, concluding that Hale remained a passenger and could be detained for the duration of the stop. The appellate court found that the evolving circumstances justified extending the stop and that the search of Hale’s purses was valid under the automobile exception to the Fourth Amendment’s warrant requirement.The Supreme Court of Ohio affirmed the appellate court’s decision, holding that Detective Martens had a reasonable, articulable suspicion to detain Hale as part of the investigatory stop. The court found that Hale’s actions and admissions during the stop provided sufficient grounds for her detention. However, the court did not address the constitutionality of the search of Hale’s purses, as Hale did not develop this argument in her appeal. View "State v. Hale" on Justia Law

The case involves a challenge to two Montana laws, HB 544 and HB 862, and a rule adopted by the Montana Department of Public Health and Human Services (DPHHS) regarding Medicaid funding for abortions. The plaintiffs, including Planned Parenthood of Montana and other healthcare providers, argue that these provisions infringe on the constitutional rights of their patients by imposing restrictions on Medicaid coverage for abortions. Specifically, the laws and rule bar Medicaid from covering abortions provided by non-physicians, require prior authorization for abortion services, and limit Medicaid coverage to abortions deemed "medically necessary" under a restrictive definition.The First Judicial District Court of Lewis and Clark County issued a preliminary injunction to halt the enforcement of HB 544, HB 862, and the DPHHS rule. The court found that the plaintiffs were likely to succeed on the merits of their claims, which included violations of the right to privacy and equal protection under the Montana Constitution. The court applied strict scrutiny, determining that the laws and rule were not narrowly tailored to serve a compelling state interest. The court also found that the plaintiffs would suffer irreparable harm without the injunction and that the balance of equities and public interest favored granting the injunction.The Montana Supreme Court reviewed the case and affirmed the District Court's decision to grant the preliminary injunction. The Supreme Court agreed that the plaintiffs were likely to succeed on the merits, as the challenged provisions infringed on the fundamental right to privacy and equal protection. The court held that the state failed to demonstrate that the laws and rule were narrowly tailored to address a medically acknowledged, bona fide health risk. The Supreme Court also found that the plaintiffs would suffer irreparable harm without the injunction and that the balance of equities and public interest supported maintaining the injunction. View "Planned Parenthood v. State" on Justia Law

Robert E. Lee Flade filed a lawsuit against several defendants, including Stephanie Isaacs and the Bedford County Listening Project (BCLP), over disparaging remarks made on social media. Isaacs and the BCLP filed motions to dismiss under Rule 12.02(6) of the Tennessee Rules of Civil Procedure and petitions to dismiss under the Tennessee Public Participation Act (TPPA), seeking dismissal with prejudice, attorney’s fees, and sanctions. Before the trial court could hear these motions, Flade voluntarily dismissed his complaint without prejudice. Isaacs and the BCLP requested the court to adjudicate their TPPA petitions despite the dismissal, but the trial court declined, stating the nonsuit concluded the matter.The Court of Appeals affirmed the trial court’s decision, holding that the TPPA petitions did not limit Flade’s right to a voluntary nonsuit under Rule 41.01(1). The court reasoned that the TPPA did not specifically limit the right to a nonsuit and that the mere filing of a TPPA petition did not create a vested right that would prevent a voluntary dismissal.The Supreme Court of Tennessee reviewed the case and affirmed the Court of Appeals' judgment. The court held that the right to take a voluntary nonsuit is not subject to the provisions of the TPPA under Rule 41.01(1). It also concluded that there is no vested right to adjudication of a TPPA petition pending at the time of a voluntary nonsuit and that a TPPA petition does not constitute a counterclaim for purposes of Rule 41.01(1). Therefore, the trial court correctly declined to adjudicate the TPPA petitions after Flade voluntarily dismissed his complaint. View "Flade v. City of Shelbyville, Tennessee" on Justia Law

The case involves a challenge to Montana House Bill 702 (HB 702), which prohibits discrimination based on vaccination status. Plaintiffs, including health care providers and individuals with compromised immune systems, argued that HB 702 is preempted by the Americans with Disabilities Act (ADA) and the Occupational Health and Safety Act (OSH Act) and violates the Equal Protection Clause of the Fourteenth Amendment. They sought to invalidate HB 702 in all health care settings, claiming it prevents employers from knowing employees' vaccination status, thus hindering ADA-required accommodations and OSH Act compliance.The United States District Court for the District of Montana ruled in favor of the plaintiffs, holding that HB 702 is preempted by the ADA and the OSH Act and violates the Equal Protection Clause. The court issued a permanent injunction against the enforcement of HB 702 in health care settings, reasoning that the law conflicts with federal requirements for reasonable accommodations and workplace safety.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision and vacated the injunction. The Ninth Circuit held that neither the ADA nor the OSH Act facially preempts HB 702 in health care settings. The court found that the plaintiffs did not demonstrate a genuine conflict between HB 702 and the ADA or OSH Act in any specific case, much less in all health care settings. The court also held that HB 702 does not violate the Equal Protection Clause, as the classification and differential treatment of facilities could rationally reflect Montana's interest in balancing personal privacy and public health.The Ninth Circuit reserved judgment on whether the ADA and the OSH Act could preempt HB 702 on a narrower, as-applied basis in future cases. The court deemed moot the portion of the district court's order related to interim CMS regulations, as those regulations have been rescinded. The court concluded that HB 702 is not facially invalid under the ADA, OSH Act, or Equal Protection Clause and vacated the district court's injunction in full. View "MONTANA MEDICAL ASSOCIATION V. KNUDSEN" on Justia Law