Justia Constitutional Law Opinion Summaries

A group of petitioners proposed a constitutional amendment, designated as Ballot Issue 8 (BI-8), which would add a new section to the Montana Constitution. This amendment would explicitly recognize a fundamental right to initiative and referendum and set forth procedural protections to ensure the timely, impartial, and unburdened exercise of those rights. BI-8 also contains limits on governmental interference, including a prohibition on the use of government resources to support or oppose ballot measures. The Attorney General determined that BI-8 was legally insufficient, arguing it violated the Montana Constitution’s separate-vote requirement by effecting multiple, unrelated constitutional changes. The Attorney General also appended a fiscal statement to BI-8, based on speculative litigation costs, despite the fiscal note indicating zero fiscal impact.The Montana Attorney General’s legal-sufficiency determination was challenged in the Supreme Court of the State of Montana under its original jurisdiction. The main arguments centered on whether BI-8 improperly combined multiple unrelated constitutional subjects and whether the Attorney General had statutory authority to append a fiscal statement when the fiscal note showed no fiscal impact.The Supreme Court of the State of Montana held that BI-8 constituted a single constitutional amendment because its provisions were closely related and collectively served to define and protect the right to initiative and referendum. The Court explained that procedural protections and government-resource limitations were integral components of the proposed right, not separate constitutional subjects. The Court further held that the Attorney General lacked authority to append a fiscal statement since the fiscal note did not indicate a fiscal impact. As a result, the Court reversed the Attorney General’s determination, struck the fiscal statement, and ordered the Attorney General to prepare ballot statements for submission to the Secretary of State. View "Kendrick v. Knudsen" on Justia Law

The plaintiff, a magistrate in the domestic-relations division of a county court, declared her candidacy for a judicial seat alongside a fellow magistrate, who was also a court administrator. During her campaign, the plaintiff distributed literature that criticized her opponent’s work schedule and duties, suggesting that the opponent performed trivial administrative tasks and questioning her competence based on personal circumstances. These campaign materials were perceived by the administrative judge as undermining the integrity of the court and casting both the court and its staff in an unfavorable light. After the plaintiff lost the primary election, the administrative judge terminated her employment as a magistrate.Prior to this appeal, the United States District Court for the Southern District of Ohio dismissed the plaintiff’s suit brought under 42 U.S.C. § 1983, which alleged a violation of her First Amendment free-speech rights. The district court ruled that the court itself was not a legally cognizable entity subject to suit, that sovereign immunity barred claims for money damages against the administrative judge in her official capacity, and that the plaintiff failed to state a plausible free-speech claim against the administrative judge. The plaintiff appealed only the dismissal of her free-speech claim.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. It held that, because the plaintiff occupied a confidential or policymaking position and her campaign speech addressed matters related to court policy and politics in a manner that undermined the loyalty and efficient functioning required by her employer, her termination did not violate the First Amendment. The court affirmed the district court’s judgment, finding that the balancing test usually applied to public employee speech was unnecessary under these circumstances. The court also rejected the plaintiff’s arguments regarding insubordination, the scope of judicial candidate speech protections, and the applicability of strict scrutiny. View "Gaines v. Cross" on Justia Law

In 2025, the Delaware General Assembly amended the Delaware General Corporation Law to add new “safe harbor” provisions for transactions involving a corporation and its controlling stockholder. These amendments, enacted as Senate Bill 21, allowed certain transactions to avoid equitable relief or damages if approved either by a committee of disinterested directors or by a majority of disinterested stockholders, and applied these changes retroactively to acts and transactions occurring before their adoption. Shortly after enactment, a stockholder of a Delaware corporation brought a derivative action alleging that the corporation’s CEO and majority stockholder breached their fiduciary duties by causing the company to overpay for an asset. The plaintiff also challenged the constitutionality of SB 21, arguing that it impermissibly deprived the Delaware Court of Chancery of its equity jurisdiction and retroactively extinguished accrued or vested causes of action.The Court of Chancery, recognizing the importance and novelty of the constitutional issues, certified two questions of law to the Delaware Supreme Court: whether the safe harbor provisions unconstitutionally divested the Court of Chancery of its equity jurisdiction, and whether applying them to past transactions violated due process by eliminating vested claims.The Supreme Court of Delaware reviewed the certified questions de novo. It held that the statutory amendments did not violate Article IV, § 10 of the Delaware Constitution because they did not remove the Court of Chancery’s ability to hear equitable claims, but instead established substantive standards for when relief may be granted. The Court also ruled that retroactive application of the safe harbor provisions under Section 3 of SB 21 did not violate Article I, § 9, since the changes did not extinguish a vested property right or accrued cause of action, but merely altered the applicable standard of review. The Court answered both certified questions in the negative, upholding the constitutionality of the challenged amendments. View "Rutledge v. Clearway Energy Group LLC" on Justia Law

A pilot employed by a cargo airline was on a personal trip abroad when his employer, Amerijet International, selected him for a random drug test and requested that he appear for testing in Seattle on the same day. The pilot was unable to comply due to his location and a medical issue. The airline determined that he had refused the test, reported this to the Federal Aviation Administration (FAA), and subsequently terminated his employment. The FAA corresponded with the pilot, initially investigating the matter and ultimately informing him that, while it was not taking enforcement action against his certificates, he would be subject to return-to-duty requirements because of the refusal determination, and the test refusal would be reported to the Pilot Records Database.The pilot challenged these consequences, arguing that the FAA had not independently reviewed the employer’s determination that he refused the test. The FAA responded that test-refusal determinations were made solely by the employer, not by the agency, and that the FAA did not review such determinations. The case came before the United States Court of Appeals for the District of Columbia Circuit on the pilot’s petition for review of the FAA’s actions.The Court of Appeals held that the FAA’s internal guidance, specifically its Drug and Alcohol Compliance and Enforcement Surveillance Handbook, plausibly requires the FAA to independently review an employer’s test-refusal determination. The court interpreted the Handbook to require such review, partly to avoid serious constitutional concerns that would arise if the FAA entirely delegated this authority to private employers without oversight. Because the FAA conceded that it did not conduct any review, the court found the agency’s actions to be arbitrary and capricious for departing from its own procedures. The court granted the petition in part, remanding the case to the FAA for further review consistent with its opinion. View "Paul v. FAA" on Justia Law

An inmate at an Illinois women’s prison was repeatedly sexually assaulted by her assigned counselor, who used his authority over her access to her daughter as leverage. After the inmate’s cellmate reported the abuse to a prison investigator, the investigator and the prison warden, instead of moving to protect the victim, devised a plan to use her as unwitting “bait” to catch the counselor in the act. This plan failed, and the abuse continued. The prison’s toxic culture, where staff-on-inmate sexual abuse was widespread and often ignored, provided the backdrop for these events.In the United States District Court for the Central District of Illinois, the inmate filed a civil rights lawsuit under 42 U.S.C. § 1983 against the counselor (who defaulted), the investigator, and the warden, alleging Eighth Amendment violations for cruel and unusual punishment. The district court denied summary judgment for the investigator and warden on qualified immunity and liability, and a jury found all three defendants liable, awarding the plaintiff $19.3 million in compensatory and punitive damages. The district court also excluded evidence suggesting the plaintiff might have consented to the abuse, and denied the investigator and warden’s post-trial motions for judgment as a matter of law or a new trial.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s denial of judgment as a matter of law and denial of qualified immunity for the investigator and warden, holding that no reasonable official could have thought their response was appropriate. However, the appellate court reversed in part, ordering a new trial on compensatory and punitive damages (but not liability) against the investigator and warden, due to insufficient evidence supporting liability before they learned of the abuse, exclusion of relevant evidence affecting punitive damages, and failure to use a special verdict form to distinguish between theories of liability. The attorney fee award was also vacated and remanded for reconsideration. View "Doe v Macleod" on Justia Law

A man was found shot and killed on a snow-covered trail in Saint Louis County, Minnesota. The investigation quickly focused on three individuals: the appellant, his girlfriend, and another accomplice. Key evidence included the murder weapon, Facebook messages discussing plans to harm the victim, and DNA on the weapon matching the appellant. The girlfriend, who was an eyewitness, testified to having seen the appellant shoot the victim. Law enforcement obtained a warrant to search multiple Facebook accounts—those of the appellant, his girlfriend, and the other accomplice—uncovering messages implicating the appellant.After initially pleading guilty to first-degree murder, the appellant challenged the conviction in postconviction proceedings. The Minnesota Supreme Court in Bonnell v. State vacated the guilty plea, remanding the case for trial. Before trial, the appellant moved to suppress evidence from the Facebook searches, arguing that the warrant lacked specificity. The Saint Louis County District Court denied the motion and admitted the evidence at trial, over defense objection. The jury convicted the appellant of first-degree premeditated murder.On direct appeal, the Supreme Court of Minnesota held, as a matter of first impression, that a sender of an electronic message does not retain a reasonable expectation of privacy in a copy of the message stored in the recipient’s separate and independent account or device. Thus, the appellant’s Fourth Amendment protections were not triggered by searches of his accomplices’ Facebook accounts. However, the appellant did have a reasonable expectation of privacy in his own Facebook accounts, and the warrant authorizing those searches was invalid for lack of particularity. Despite this error, the court concluded it was harmless beyond a reasonable doubt because the remaining evidence was overwhelming. The court also found that any errors in admitting certain prior bad acts evidence were harmless. The conviction was affirmed. View "State of Minnesota vs. Bonnell" on Justia Law

A city councilmember in Stevenson, Washington, participated in a protest outside the Skamania County Courthouse on International Transgender Day of Visibility. During the demonstration, she exposed her breasts with the phrase “MY BODY IS NOT A SIN” written on her chest as a form of protest. Police officers approached her regarding potential violation of Washington’s indecent exposure law (RCW 9A.88.010), but she asserted her actions were protected by the First Amendment and was neither arrested nor charged.A local resident filed a recall petition in Skamania County Superior Court, alleging that the councilmember committed malfeasance and violated her oath of office by engaging in indecent exposure, which the petitioner argued justified her removal from office. The Skamania County Superior Court found the recall charge factually and legally sufficient, determining that malfeasance simply required the commission of an unlawful act, and certified the ballot synopsis. The court reasoned that it was ultimately up to voters to decide if the conduct amounted to a violation of the law.The Supreme Court of the State of Washington reviewed the case. The court held that the recall petition was neither factually nor legally sufficient. It found that there was no evidence the councilmember intended to violate the law, as indecent exposure under RCW 9A.88.010 requires intentional open and obscene exposure, and the facts indicated she believed her conduct was lawful protest. Furthermore, the court concluded her actions were constitutionally protected expressive conduct. The court also determined that there was no factual or legal basis for a violation of the oath of office, as her conduct was not related to her official duties. The Supreme Court of the State of Washington reversed the superior court’s ruling and dismissed the recall petition. View "In re Recall of Lauser" on Justia Law

A violent series of confrontations between residents of two Southeast D.C. neighborhoods resulted in several shootings, including two murders and multiple assaults, during 2016 and 2017. One defendant, a resident of Wahler Place, was implicated in these violent acts and was connected to the crimes through witness identifications, forensic ballistics, cell phone location data, and his possession of the firearm used in the shootings. The second defendant, an employee of the Metropolitan Police Department and longtime acquaintance of the first defendant, used her access to police databases to search for information related to the shootings and communicated with the first defendant after each incident.Following an investigation, both individuals were indicted in the Superior Court of the District of Columbia and faced numerous charges. The first defendant moved to suppress evidence based on alleged Fourth Amendment violations related to the seizure and search of his vehicle and cell phones, but the trial court denied these motions. After an eleven-week jury trial, the first defendant was convicted of multiple counts, including murder, assault with intent to kill, firearm offenses, and obstruction of justice. The second defendant was acquitted of the most serious charges but convicted of being an accessory after the fact (AAF) and obstruction of justice. Both appealed.The District of Columbia Court of Appeals affirmed the first defendant’s convictions for murder, assault, and related firearm offenses, concluding that the evidence was sufficient and that the searches satisfied Fourth Amendment exceptions or were admissible under the good-faith exception. However, the court reversed the second defendant’s AAF convictions, holding that the government failed to prove she had actual knowledge of the principal’s crimes when she provided assistance. The court also vacated all obstruction of justice convictions for both defendants, finding the statute did not apply to the proceedings at issue. The case was remanded for further proceedings consistent with these rulings. View "Jennings & Turner v. United States" on Justia Law

On a December evening, a Metropolitan Police Department officer responded to reports of disorderly groups in Southeast Washington, D.C., an area associated with frequent gun-related incidents. The officer observed four men walking and overheard a comment he interpreted as referring to gun violence. He monitored the group and began interacting with them, including Allen Grant, who voluntarily stated he had no guns. Grant carried a satchel, which he moved behind his back when questioned, prompting repeated requests from the officer to see it. Grant denied having anything in the satchel, continued walking, and ultimately threw the satchel over a fence. Another officer found a gun inside the satchel, after which Grant fled and was arrested approximately thirty minutes later.The Superior Court of the District of Columbia presided over the suppression hearing on Grant's motion to exclude evidence from the satchel, arguing an unlawful seizure. The trial court found that Grant had not been seized before discarding the satchel, as he continued walking and ultimately ran, and there was no show of force by officers. The trial court characterized the interaction as an investigatory conversation and denied the motion to suppress. Grant was subsequently convicted by a jury on several firearm-related charges and sentenced to imprisonment and supervised release.The District of Columbia Court of Appeals reviewed the case and affirmed the trial court’s denial of the suppression motion. The Court held that Grant was not seized within the meaning of the Fourth Amendment prior to discarding the satchel, as he did not submit to the officer’s show of authority. The evidence found in the satchel was not the fruit of an illegal seizure. The Court applied a de novo review to legal issues and deferred to factual findings unless clearly erroneous. The order denying suppression was affirmed. View "Grant v. United States" on Justia Law

In this case, the defendant was convicted of first-degree murder and robbery with a firearm for the 1991 killing of a police officer during a traffic stop. After initial convictions and a direct appeal, a new penalty phase was ordered, and the defendant was again sentenced to death in 1996. The trial court found two aggravating factors, including that the murder was committed during a robbery and to hinder law enforcement, outweighing the mitigating circumstances related to the defendant’s age, confession, courtroom behavior, and difficult childhood. The Florida Supreme Court affirmed the convictions and death sentence, which became final in 2001. Over the following decades, the defendant pursued numerous unsuccessful challenges to the conviction and sentence in state and federal courts.Following the signing of a death warrant in January 2026, the defendant filed a sixth successive motion for postconviction relief in the Circuit Court for St. Lucie County. He raised three claims: newly discovered evidence of jury influence by uniformed officers, a claim of intellectual disability based on a recent IQ test, and a challenge to the constitutionality of Florida’s death warrant process. The circuit court summarily denied all claims, as well as related motions for a juror interview, to declare the intellectual disability standard unconstitutional, and for late-filed public records requests.On review, the Supreme Court of Florida affirmed the circuit court’s denial of postconviction relief, denied the habeas corpus petition, and denied the motions for a stay of execution. The Court held that the claims of improper jury influence and intellectual disability were untimely and procedurally barred, the request for a juror interview and public records were properly denied as untimely and speculative, and that the intellectual disability claim was also legally insufficient. The Court further declined to extend Eighth Amendment protections beyond current U.S. Supreme Court precedent. View "Kearse v. State" on Justia Law