Justia Constitutional Law Opinion Summaries

In 2016, the Mississippi legislature passed S.B. 2162, which abolished the Jackson Municipal Airport Authority (JMAA) and created the Jackson Metropolitan Area Airport Authority (Authority). The new Authority would be governed by nine commissioners, with only two selected by the Jackson city government. The JMAA commissioners, along with Jackson’s Mayor and City Council, intervened in a suit to enjoin enforcement of the law, alleging violations of the Equal Protection Clause of the Fourteenth Amendment and the Due Process Clause of the Mississippi Constitution. They claimed S.B. 2162 diluted the voting rights of Jackson citizens and altered the airport’s management for race-based reasons.The United States District Court for the Southern District of Mississippi initially upheld the plaintiffs' standing and ordered discovery, which the legislators resisted, citing legislative privilege. On the first appeal, the Fifth Circuit held that the plaintiffs lacked standing, as they failed to demonstrate injury to a legally protected interest. The case was remanded with instructions to dismiss without prejudice. Plaintiffs amended their complaint to address the standing issue, and the district court again ordered discovery. The Fifth Circuit reversed the district court’s privilege ruling but later dismissed the appeal as moot when none of the plaintiff-commissioners held their positions.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the plaintiffs lacked Article III standing to sue. The court held that the plaintiffs' alleged injuries were institutional rather than personal, as the injury affected the JMAA as an entity. The court also found that the plaintiffs did not have a protected property interest in their positions or the associated per diem and travel reimbursements. Consequently, the Fifth Circuit vacated the district court's order and remanded the case with instructions to dismiss. View "Jones v. Reeves" on Justia Law

Carey Dale Grayson, an Alabama prisoner, sought a preliminary injunction to halt his scheduled execution by nitrogen hypoxia, arguing that the method violated the Eighth Amendment due to the risk of conscious suffocation and other potential harms. Grayson proposed alternative methods of execution, including nitrogen gas with sedation and a sequential injection of ketamine followed by fentanyl.The United States District Court for the Middle District of Alabama denied Grayson's motion, finding that he did not demonstrate a substantial likelihood of success on the merits of his Eighth Amendment claim. The court held an evidentiary hearing where expert testimonies were presented. The court found that Grayson's evidence was speculative and did not show that the nitrogen hypoxia protocol created an unacceptable risk of pain. The court also found that the proposed alternatives were not feasible or readily implemented.The United States Court of Appeals for the Eleventh Circuit reviewed the district court's decision for abuse of discretion. The appellate court affirmed the district court's denial of the preliminary injunction, agreeing that Grayson failed to show a substantial likelihood of success on the merits. The court noted that the district court's factual findings were not clearly erroneous and that the nitrogen hypoxia protocol had been successfully used in previous executions without evidence of conscious suffocation or other significant issues. The appellate court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Grayson v. Commissioner, Alabama Department of Corrections" on Justia Law

The case involves a First Amendment challenge to a policy in Caldwell County, Texas, which categorically excludes the press and the public from observing criminal pretrial proceedings known as magistrations. The plaintiffs, two nonprofit news organizations and an advocacy organization, argued that this policy violates their First Amendment right of access to judicial proceedings. The district court agreed, finding the policy unconstitutional and granting a preliminary injunction to prevent its enforcement.The United States District Court for the Western District of Texas initially reviewed the case. The district court found that the plaintiffs had standing to challenge the policy and demonstrated a substantial likelihood of success on the merits of their First Amendment claim. The court issued a preliminary injunction, enjoining the County from enforcing its policy of closing magistrations to the press and public, except in extraordinary circumstances and as constitutionally permitted.The United States Court of Appeals for the Fifth Circuit reviewed the case on appeal. The County argued that the district court erred in finding that the plaintiffs had standing and in determining that they were likely to succeed on the merits of their First Amendment claim. The Fifth Circuit affirmed the district court's ruling, agreeing that the plaintiffs had standing and that there is a presumptive First Amendment right of access to magistrations. The court applied the "experience and logic" test, finding that both historical practice and the positive role of public access in the functioning of bail hearings supported the plaintiffs' claim. The court concluded that the district court did not err in its determinations and upheld the preliminary injunction. View "Texas Tribune v. Caldwell County" on Justia Law

Charles Porter, a Yosemite National Park employee, was charged with various sexual assault offenses after attempting to anally rape T.D., another male park employee, in April 2020. T.D. testified that Porter, heavily intoxicated, forced himself on T.D. in his cabin. Neighbors corroborated T.D.'s account. Porter claimed T.D. was the aggressor. The district court allowed testimony from Porter’s ex-girlfriend, A.H., under Federal Rule of Evidence 413, which permits evidence of prior sexual assaults. A.H. testified that Porter had previously engaged in nonconsensual sex with her.The United States District Court for the Eastern District of California admitted A.H.'s testimony after evaluating its probative value against potential prejudice under Rule 403. The jury found Porter guilty on all counts, and he was sentenced to 148 months in prison. Porter appealed, arguing that Rule 413 violates the Fifth Amendment’s Due Process Clause by allowing propensity evidence.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Rule 413 is constitutional, referencing its decision in United States v. Lemay, which upheld the analogous Rule 414 for child molestation cases. The court emphasized that Rule 413, like Rule 414, is subject to Rule 403, which allows district courts to exclude unduly prejudicial evidence. The court found that the district court had properly applied Rule 403 and provided appropriate limiting instructions to the jury regarding A.H.'s testimony.The Ninth Circuit affirmed Porter’s conviction, concluding that the admission of A.H.'s testimony under Rule 413 did not violate due process. View "U.S. v. Porter" on Justia Law

Robert Roberson, a death-row inmate, was scheduled for execution on October 17, 2024. On October 16, 2024, the Texas House Committee on Criminal Jurisprudence issued a subpoena requiring Roberson to testify on October 21, 2024, creating a conflict between the legislative, judicial, and executive branches. The judicial branch had affirmed Roberson's sentence, and the executive branch had declined clemency. The committee sought to delay the execution to obtain Roberson's testimony, claiming legislative authority to compel testimony superseded the scheduled execution.The committee filed a lawsuit in a state district court, which granted a temporary restraining order to delay the execution. The Texas Department of Criminal Justice (the department) sought relief from the Texas Court of Criminal Appeals, which set aside the restraining order. The committee then petitioned the Supreme Court of Texas for a writ of mandamus to enforce the subpoena and delay the execution.The Supreme Court of Texas reviewed the case and concluded that the legislative committee's authority to compel testimony does not override the scheduled legal process leading to an execution. The court emphasized the separation of powers, noting that the legislature's investigatory power must be balanced against the judiciary's authority to render judgments and the executive's authority to enforce them. The court held that the committee could have obtained Roberson's testimony earlier and that the legislative subpoena could not disrupt the execution process. Consequently, the court denied the committee's petition for writ of mandamus, allowing the execution to proceed as scheduled. View "IN RE TEXAS HOUSE OF REPRESENTATIVES" on Justia Law

N.S. was involuntarily committed at age sixteen in 2006, which disqualified him from possessing firearms under federal law. In August 2022, he filed a petition under Iowa Code section 724.31 for the restoration of his firearm rights. The State and the county attorney opposed his petition. The district court conducted an evidentiary hearing and denied his petition, finding that N.S. failed to prove he would not likely act in a manner dangerous to public safety. The court also rejected N.S.'s state constitutional challenge, ruling that Amendment 1A did not apply retrospectively to his 2006 disqualification and that section 724.31 survives strict scrutiny.The Iowa Supreme Court reviewed the case de novo and agreed with the district court's factual findings and determination that N.S. failed to meet his burden to satisfy the statutory criteria for restoration of his right to possess firearms. The court held that Amendment 1A applies prospectively to N.S.'s restoration proceeding in 2023. The court further held that section 724.31 survives strict scrutiny under Amendment 1A, as the State has a compelling interest in preventing gun violence and suicide, and the statute is narrowly tailored to serve that interest by keeping firearms from dangerous persons while allowing restoration of firearm rights upon a petitioner’s showing they are no longer a threat to public safety.The court declined to shift the burden of proof under section 724.31 from the petitioner to the State. Consequently, the Iowa Supreme Court affirmed the district court's judgment denying N.S.'s petition for the restoration of his firearm rights. View "In re N.S." on Justia Law

A clerk-magistrate decided to allow public access to show cause hearings for individuals accused of being clients of a prostitution ring but denied media requests for the underlying complaint applications before the hearings. The accused individuals, referred to as John Does, intervened to oppose the public access decision and sought to keep the hearings private. The media outlets filed a petition in the Supreme Judicial Court for Suffolk County to challenge the clerk-magistrate's decision to withhold the complaint applications.The single justice of the Supreme Judicial Court remanded the matter to the clerk-magistrate for written findings on specific questions related to the public interest and privacy concerns. After reviewing the clerk-magistrate's responses, the single justice denied the petition, concluding that the clerk-magistrate did not commit an error of law or abuse her discretion in allowing public access to the hearings and denying access to the complaint applications.The Supreme Judicial Court affirmed the single justice's decision, holding that the clerk-magistrate acted within her discretion. The court found that the public interest in transparency and accountability outweighed the privacy interests of the accused, especially given the significant public attention and the potential for favoritism if the hearings were held privately. The court also agreed that denying access to the complaint applications was appropriate to prevent the dissemination of potentially erroneous or extraneous information before the accused had an opportunity to respond at the hearings.The court further directed the Trial Court to provide notice to the accused when a request for public access to a show cause hearing is made and to offer the accused an opportunity to respond before deciding on the request. View "Trustees of Boston University v. Clerk-Magistrate of the Cambridge Division of the District Court Department" on Justia Law

The case involves Russell Lucius Laffitte, who was convicted of bank and wire fraud in the United States District Court for the District of South Carolina. The government alleged that between 2006 and 2021, Laffitte, as CEO of Palmetto State Bank, conspired with Alex Murdaugh, a disbarred attorney, to defraud Murdaugh’s clients. Laffitte was accused of using his position to access settlement accounts, collecting fees, and extending unsecured loans to Murdaugh, resulting in nearly two million dollars being stolen from the accounts. Laffitte was charged with conspiracy to commit wire and bank fraud, bank fraud, wire fraud, and misapplication of bank funds.During the trial, the government presented fifteen witnesses, and Laffitte called eight witnesses and testified in his own defense. After the jury began deliberations, the court received notes from jurors indicating issues, including one juror needing medication and another feeling pressured. The district court decided to remove two jurors, Juror No. 88 and Juror No. 93, and replaced them with alternates. The jury then returned a guilty verdict on all counts.Laffitte appealed, arguing that the removal of the jurors violated his Fifth Amendment right to be present and his Sixth Amendment right to an impartial jury. The Fourth Circuit Court of Appeals reviewed the case and found that the removal of Juror No. 88 violated Laffitte’s Sixth Amendment right because there was a reasonable and substantial possibility that her removal was related to her views on the case. The court also found that the removal violated Laffitte’s Fifth Amendment right to be present, as he was not present during the in camera interview when the decision to remove Juror No. 88 was made. The court concluded that these errors were not harmless and vacated Laffitte’s convictions and sentence, remanding the case for a new trial. View "US v. Russell Laffitte" on Justia Law

The plaintiff, Siddhanth Sharma, a convicted felon, challenged North Carolina's felony-disclosure requirement for candidates running for federal office. This state law mandates that candidates disclose any felony convictions and provide additional information about the convictions and the restoration of citizenship rights. Sharma, who announced his candidacy for North Carolina’s Thirteenth Congressional District seat, argued that this requirement violated the Qualifications Clause and the First Amendment.The United States District Court for the Eastern District of North Carolina dismissed Sharma's claims. The court found that Sharma had standing to challenge the felony-disclosure requirement but concluded that it did not constitute an additional qualification for office. The court also held that the requirement did not violate the First Amendment, as it served a substantial interest in promoting an informed electorate and posed only a modest burden. Sharma's challenge to the address-disclosure requirement was dismissed for lack of standing, as the court found his injury insufficiently particularized.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's decision, holding that the felony-disclosure requirement is constitutional. The court reasoned that the requirement does not exclude candidates from the ballot or disadvantage political viewpoints, and it falls within the state's authority to regulate elections. The court also found that the requirement imposes only a light burden on First Amendment rights and serves the state's interest in fostering an informed electorate. However, the court vacated the judgment on the address-disclosure challenge and remanded it to the district court with instructions to dismiss it as moot, as Sharma's address was already publicly available in the voter-search database. View "Siddhanth Sharma v. Alan Hirsch" on Justia Law

Indiana enacted a law prohibiting physicians from altering a child's sex characteristics through medication or surgery as treatment for gender dysphoria. Plaintiffs, including transgender children, their parents, and a physician, argued that the law violated their rights under the Equal Protection Clause, substantive due process, and the First Amendment. The district court found these arguments likely to succeed and issued a preliminary injunction against the law. Indiana appealed the decision.The United States District Court for the Southern District of Indiana granted a preliminary injunction, finding that the plaintiffs were likely to succeed on their claims that the law violated the Equal Protection Clause and the First Amendment. The court concluded that the law discriminated based on sex and transgender status and that the aiding and abetting provision regulated speech based on its content. The court also found that the balance of harms favored the plaintiffs and that they would suffer irreparable harm without the injunction.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the district court's decision. The Seventh Circuit held that the law did not classify based on sex or transgender status in a way that warranted heightened scrutiny. The court applied rational basis review and found that the law was rationally related to the state's legitimate interest in protecting children from uncertain and potentially harmful medical treatments. The court also held that the law's aiding and abetting provision did not violate the First Amendment, as it regulated speech integral to unlawful conduct. The court vacated the preliminary injunction and remanded the case for further proceedings. View "K.C. v. Individual Members of the Medical Licensing Board" on Justia Law