Justia Constitutional Law Opinion Summaries

Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

The case involves Michigan's electricity market regulations, specifically the Individual Local Clearing Requirement (ILCR), which mandates that electricity retailers in Michigan's lower peninsula procure a certain percentage of their capacity from within that region. Plaintiffs, including Energy Michigan and the Association of Businesses Advocating Tariff Equity (ABATE), challenged the ILCR on the grounds that it violates the dormant Commerce Clause by discriminating against interstate commerce.The United States District Court for the Eastern District of Michigan initially dismissed the Michigan Public Service Commission (MPSC) on Eleventh Amendment grounds but allowed the case to proceed against individual commissioners. The court denied summary judgment motions from both sides, finding that there were factual disputes regarding whether the ILCR discriminated against interstate commerce. After a three-day bench trial, the district court concluded that the ILCR did not violate the Commerce Clause.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the ILCR is facially discriminatory because it requires electricity to be generated within a specific geographic region, effectively favoring in-state over out-of-state electricity. The court held that this discrimination necessitates strict scrutiny, which the district court did not properly apply. The Sixth Circuit reversed the district court's judgment and remanded the case for further proceedings to determine if the ILCR can survive strict scrutiny by proving it is the only means to achieve the state's goal of ensuring a reliable energy supply. View "Energy Michigan, Inc. v. Public Service Commission" on Justia Law

Zillow, Inc., a for-profit corporation, requested property tax data from several Kentucky property valuation administrators (PVAs) under Kentucky’s Open Records Act (KORA). The PVAs classified Zillow’s requests as having a commercial purpose and quoted fees amounting to thousands of dollars. Zillow sued, arguing that KORA’s fee structure, which distinguishes between commercial and non-commercial purposes and includes exceptions for newspapers, radio, and television stations, violated the First and Fourteenth Amendments.The United States District Court for the Eastern District of Kentucky held that the commercial/non-commercial distinction did not violate the First or Fourteenth Amendments but found the newspaper exception unconstitutional. The court severed the newspaper exception from the statute, resulting in both Zillow and newspapers being subject to enhanced fees. The Kentucky Press Association and American City Business Journals intervened and, along with Zillow, appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the commercial-fee statute did not violate the First Amendment as applied to Zillow. It determined that the distinction between commercial and non-commercial purposes was content-neutral and did not impermissibly discriminate based on the content of Zillow’s speech. The court reversed the district court’s order declaring the newspaper exception unconstitutional, vacated the permanent injunction, and remanded with instructions to grant summary judgment to the PVAs. View "Zillow, Inc. v. Miller" on Justia Law

Danny Fox, an active-duty servicemember, purchased a property in Norfolk, Virginia, in 2015. The City of Norfolk determined the property was unsafe and uninhabitable, repeatedly notifying Fox of building code violations. Despite these notices, Fox did not make the necessary repairs. In December 2018, the city demolished the house, deeming it a public nuisance. Fox subsequently sued the city, claiming inverse condemnation, among other things, arguing the property was not a nuisance and that the city's actions were pretextual to increase its tax base.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the city. The court held that Fox's federal constitutional claims were barred by the statute of limitations. It also ruled that Fox's inverse condemnation claim failed because, whether or not the property was a nuisance, he could not demonstrate the city's public use requirement. The court found no evidence to support Fox's claim that the city's actions were pretextual.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court agreed that Fox's inverse condemnation claim failed regardless of whether the property was a nuisance. If the property was a nuisance, the city had the authority to abate it without compensation. If it was not a nuisance, Fox could not show a public use, a necessary element for an inverse condemnation claim. The court also found that Fox provided no evidence to support his pretext argument. Thus, the court affirmed the district court's grant of summary judgment for the city. View "D.A. Realestate Investment, LLC v. City of Norfolk" on Justia Law

Trevon Bey was convicted by a jury of possession of a firearm by a felon and carrying a loaded firearm in public. The trial court dismissed a prior strike conviction and sentenced Bey to three years for each count, to be served concurrently. Bey appealed, arguing that the trial court improperly revoked his self-representation status, that his conviction for possession of a firearm by a felon violated his Second Amendment rights, and that California's concealed carry laws were unconstitutional under a recent Supreme Court decision.The Superior Court of Los Angeles County initially allowed Bey to represent himself but later revoked this status due to his disruptive behavior and failure to follow court rules. Bey repeatedly challenged the court's authority, disrespected the court, and disrupted proceedings, despite multiple warnings. The court appointed standby counsel to represent him, citing his inability to adhere to courtroom protocol.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the trial court did not abuse its discretion in revoking Bey's self-representation status due to his continuous disruptive conduct. The court also found that Bey's conviction for possession of a firearm by a felon did not violate his Second Amendment rights, referencing recent Supreme Court decisions that upheld prohibitions on firearm possession by felons. Additionally, the court rejected Bey's challenge to California's concealed carry laws, noting that the unconstitutional "good cause" requirement was severable from the rest of the licensing scheme.The Court of Appeal agreed with both parties that the sentence for carrying a loaded firearm in public should be stayed under Penal Code section 654, as it was based on the same act as the possession charge. The court modified the judgment to stay the sentence on count 2 and affirmed the judgment as modified. View "People v. Bey" on Justia Law

The case involves the defendant, who was charged with 46 sex crimes against the same person over an eight-year period. The counts in the indictment were identical and did not specify the incidents they were based on. During the first trial, the state did not link any specific incidents to the counts, and the jury found the defendant not guilty of 40 counts and guilty of six. The defendant appealed, arguing an evidentiary error, and the Court of Appeals reversed and remanded the case.On remand, the defendant filed a motion to dismiss the indictment, claiming that retrying him on the six counts of conviction would violate his constitutional rights against double jeopardy. The trial court denied the motion, and the case proceeded to a second jury trial, where the defendant was again convicted of the six counts. The defendant appealed, arguing that the trial court erred in denying his motion to dismiss.The Oregon Supreme Court reviewed the case and found that the Court of Appeals had erred in resolving the case on preservation grounds. The Supreme Court concluded that the defendant had consistently raised the same double jeopardy argument throughout the case: that due to the lack of specificity in the indictment and the first trial, it was impossible to determine the factual basis for any count, and there was a risk that he would be convicted based on incidents of which he had already been acquitted. The Supreme Court reversed the decision of the Court of Appeals and remanded the case for further proceedings to address the merits of the double jeopardy issue. View "State v. Dodge" on Justia Law

Dario Giambro was convicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm. The conviction stemmed from evidence found by police officers who forcibly entered his home in Hebron, Maine, without a warrant. The officers entered the home based on information from Giambro's son, Antonio, who reported that his mother, Arline, had died and was not in the house. Giambro argued that the warrantless entry violated his Fourth Amendment rights and that the evidence should be suppressed. He also challenged the charge on Second Amendment grounds.The United States District Court for the District of Maine denied Giambro's motion to suppress, ruling that the entry fell within the emergency aid exception to the Fourth Amendment's warrant requirement. The court found that the officers had an objectively reasonable basis to believe that Arline might be in need of immediate aid, despite Antonio's report that she had died and was not in the house. The court also denied Giambro's motion to dismiss the charge on Second Amendment grounds.The United States Court of Appeals for the First Circuit reviewed the case and disagreed with the district court's application of the emergency aid exception. The appellate court held that the officers did not have an objectively reasonable basis to believe that Arline was alive and in need of immediate aid, given that Antonio had been in the house that morning and reported that she was not there. The court emphasized that the officers should have spoken to Antonio and Giambro, who were available for questioning, before forcibly entering the home. Consequently, the First Circuit reversed the district court's denial of the motion to suppress, vacated Giambro's conviction and sentence, and remanded the case for further proceedings. The court did not address the Second Amendment claim due to its ruling on the Fourth Amendment issue. View "United States v. Giambro" on Justia Law

Marcus Todd, a state employee in Minnesota, alleged that a union violated his First and Fourteenth Amendment rights by deducting union dues from his paycheck without his consent. Todd joined the American Federation of State, County, and Municipal Employees in 2014 and authorized dues deductions. In 2018, a new authorization card was allegedly signed electronically with Todd's name, which he claims was forged. After the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, Todd attempted to resign from the union and stop dues deductions, but the union continued until May 2021, citing an annual opt-out period.The United States District Court for the District of Minnesota dismissed Todd's federal claims, stating that he voluntarily agreed to the dues deductions before Janus and was contractually bound to the opt-out period. The court also found that the union did not act under color of state law regarding the alleged forgery and dismissed Todd's claims for prospective relief as moot. The court declined to exercise jurisdiction over Todd's state law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Todd's claims failed due to the lack of state action, as the union's actions were based on private agreements, not state statutes. The court referenced Hoekman v. Education Minnesota and Burns v. School Service Employees Union Local 284, which established that private agreements for dues deductions do not constitute state action. The court also found that the alleged forgery did not establish state action, as it was a private misuse of state law. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Todd v. AFSCME" on Justia Law

David Shanton, Sr. was involved in two armed bank robberies in Hagerstown, Maryland, shortly after completing a 20-year sentence for a previous bank robbery. During the first robbery, Shanton threatened to kill anyone who called the police and pointed a shotgun at a deputy sheriff while fleeing with nearly $34,000. He was apprehended during the second attempted robbery. Shanton was indicted and convicted on multiple counts, including armed bank robbery, discharging and brandishing a firearm during a crime of violence, and possessing a firearm as a felon.The United States District Court for the District of Maryland sentenced Shanton to 188 months for each armed bank robbery and firearm possession conviction, to be served concurrently, plus consecutive terms for the firearm offenses, totaling 608 months. Shanton's sentence was enhanced under the Armed Career Criminal Act (ACCA) due to his prior convictions, including Maryland robbery. Shanton did not initially object to the enhancement. On direct appeal, the Fourth Circuit affirmed his convictions and sentence.Shanton later filed a motion under 28 U.S.C. § 2255, challenging the constitutionality of his ACCA-enhanced sentences based on the Supreme Court's decision in Samuel Johnson v. United States, which invalidated the ACCA's residual clause. The district court allowed Shanton to supplement his motion, arguing that his Maryland robbery convictions no longer qualified as violent felonies under ACCA's elements clause. The district court rejected this argument, relying on Fourth Circuit precedent, and denied the motion but issued a certificate of appealability.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The court held that Maryland robbery qualifies as a violent felony under ACCA's elements clause, consistent with prior Fourth Circuit decisions and the Supreme Court's ruling in Stokeling v. United States. The court concluded that Maryland robbery involves the use of force against a person, meeting the ACCA's definition of a violent felony. View "United States v. Shanton" on Justia Law

During Winter Storm Uri in February 2021, Black Hills Colorado Electric LLC incurred extraordinary natural gas costs to ensure continuous electric service to its customers. Holcim U.S. Inc., a large retail electric customer, argued that the Colorado Public Utilities Commission (PUC) set an unjust and unreasonable charge for electricity over a five-day period, disproportionately allocating utility costs to Holcim. Holcim also claimed that the PUC's charge constituted a taking in violation of the Fifth Amendment.The District Court for the City and County of Denver upheld the PUC's decision, finding that the rate was just and reasonable and did not violate Holcim's constitutional rights. The court noted that the PUC's rate structure was based on total customer usage forecasts and was applied uniformly to all customers.The Supreme Court of Colorado reviewed the case and affirmed the district court's judgment. The court held that the PUC's rate was just and reasonable, as it accurately reflected the cost of service, distributed costs among customers fairly, and maintained the utility's financial integrity. The court also found that Holcim's actual electricity usage during the storm did not impact the costs incurred by Black Hills, which were based on forecasted needs.Additionally, the court rejected Holcim's constitutional claims. It concluded that Holcim did not adequately develop its takings claim and that the PUC's decision did not violate Holcim's due process rights, as the PUC provided a fair hearing, considered competent evidence, and made its determination based on evidence rather than arbitrarily. View "Holcim U.S. Inc. v. Colo. Pub. Utils. Comm'n" on Justia Law