Justia Constitutional Law Opinion Summaries

The Montana legislature enacted a law, HB 937, and associated administrative rules that imposed new licensure and regulatory requirements specifically on abortion clinics, which were defined as facilities providing abortion-inducing drugs or performing surgical abortions to at least five patients per year. These requirements did not apply to clinics that provided identical medications and procedures exclusively for miscarriage management. Plaintiffs, including two clinics and a nurse practitioner, challenged the law and rules, arguing that they violated the equal protection and privacy rights guaranteed by the Montana Constitution. They asserted that these new requirements could force them to cease providing abortion care, thereby restricting their patients’ access to such services.After the plaintiffs filed their complaint, the First Judicial District Court, Lewis and Clark County, initially granted a temporary restraining order and later a preliminary injunction, preventing enforcement of HB 937 and the associated rules. The District Court found that the plaintiffs were likely to succeed on their equal protection claim, that irreparable harm was likely absent an injunction, that the balance of equities favored the plaintiffs, and that an injunction was in the public interest. The court determined that the law treated similarly situated providers—those giving identical care for either miscarriage or abortion—differently solely based on the purpose of the treatment. The court applied strict scrutiny, finding that the state had not demonstrated a compelling interest or that the law was narrowly tailored.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s preliminary injunction. The Supreme Court held that HB 937 and the rules likely violate the Montana Constitution’s guarantee of equal protection by subjecting abortion providers to unique, burdensome licensing requirements not imposed on providers of identical miscarriage care, thus likely infringing on the fundamental right to privacy. The Court concluded that the plaintiffs met all four elements required for a preliminary injunction and affirmed the lower court’s order in its entirety. View "All Families v. State" on Justia Law

A group of business and industry associations challenged the Montana Attorney General’s March 6, 2026 determination that Proposed Ballot Measure No. 10 was legally sufficient to proceed in the initiative process. Ballot Measure No. 10 sought to amend state law by defining “artificial persons” and excluding “political spending power” from the rights granted to such entities. The challengers argued that the measure was facially unconstitutional because it restricted political speech, was vague, and improperly conditioned benefits on the waiver of constitutional rights.The challenge was brought directly to the Supreme Court of the State of Montana under its original jurisdiction. The Attorney General had performed only a procedural review, declining to address the measure’s substantive constitutionality due to a prior order by the First Judicial District Court in Ellingson v. State, which had enjoined the statutory provision that would have allowed such substantive review. The petitioners requested the Supreme Court to require the Attorney General to review the measure’s constitutionality and to reverse his finding of legal sufficiency.The Supreme Court of the State of Montana held that the Attorney General does not have authority to consider the substantive constitutionality of proposed ballot initiatives during legal sufficiency review under current law and precedent. The Court reaffirmed that pre-election constitutional challenges to initiatives are generally disfavored, as the people have a constitutional right to use the initiative process. Because Ballot Measure No. 10 had not yet qualified for the ballot, the Court declined to address the merits of the constitutional arguments, finding such review would be advisory. The Court denied and dismissed the petition, and also denied as moot motions to intervene and to file amicus briefs. View "Montana Mining Assn. v. Knudsen" on Justia Law

A Pennsylvania state prisoner with a history of opioid addiction participated in a prison Medication Assisted Treatment program, receiving Suboxone to help control his cravings. After prison officials twice accused him of possessing contraband and diverting his medication to other prisoners, he was removed from the treatment program. Instead of abruptly ending his medication, a prison doctor tapered his doses over a week to reduce withdrawal symptoms. The prisoner later suffered withdrawal effects and mental health challenges but was not reinstated in the program despite his requests. He claimed the diversion finding was unfair but did not allege personal animus or pretext by the officials involved.He filed a pro se lawsuit in the U.S. District Court for the Middle District of Pennsylvania against various prison officials and a doctor, alleging violations of the Eighth Amendment (cruel and unusual punishment), the Americans with Disabilities Act (ADA), and a state-law negligence claim. The District Court dismissed all claims, finding the federal claims inadequately pleaded and the state-law claim procedurally improper for lack of a certificate of merit under Pennsylvania law.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court affirmed the dismissal of the Eighth Amendment claim, holding that the complaint failed to allege deliberate indifference to medical needs as required by precedent; the officials’ actions were judged to be good-faith medical decisions, not constitutionally blameworthy conduct. The court also affirmed dismissal of the ADA claim, finding no plausible allegation that the prisoner was excluded from treatment “by reason of” his disability, but rather for diversion of medication. However, the court vacated the dismissal of the state-law negligence claim, as recent Supreme Court precedent abrogated the procedural requirement relied upon by the District Court, and remanded for further proceedings on that claim. View "DiFraia v. Ransom" on Justia Law

A group of parolees who had been detained challenged the procedures used by the Missouri Department of Corrections for revoking parole, arguing that these procedures violated their due process rights. The plaintiffs brought a class action suit under 42 U.S.C. § 1983 on behalf of all adult parolees in Missouri who currently face or will face parole revocation proceedings. The district court issued an order in 2020 requiring the Department to implement certain changes. After further proceedings, the plaintiffs sought and were awarded attorneys’ fees for their partial success and for monitoring the Department’s compliance.The Missouri Department of Corrections appealed the district court’s fee awards, arguing that the Prison Litigation Reform Act (PLRA) limited the attorneys’ fees that could be awarded. The district court had repeatedly rejected the Department’s argument, finding that the PLRA’s fee cap did not apply because the certified class included parolees who were not detained and because some of the relief benefited non-detained parolees. The district court issued its final judgment in January 2025 and permanently enjoined the Department while awarding additional attorneys’ fees.The United States Court of Appeals for the Eighth Circuit considered whether the PLRA’s attorneys’ fee cap under 42 U.S.C. § 1997e(d) applied to the class action. The Eighth Circuit held that the fee cap does apply because the certified class consisted of individuals who are, or will be, detained during parole revocation proceedings and thus fall under the statutory definition of “prisoner.” The court also found that the PLRA’s fee cap section is not limited to actions challenging prison conditions. The Eighth Circuit vacated the fee awards and remanded the case for the district court to recalculate the fee awards in accordance with the PLRA’s limitations. View "Gasca v. Precythe" on Justia Law

A licensed mental health counselor in Colorado, who provides talk therapy to clients—including minors—challenged a state law that prohibits licensed counselors from engaging in “conversion therapy” with minors. The law defines conversion therapy broadly to include any practice or treatment that attempts to change an individual’s sexual orientation or gender identity, including efforts to alter behaviors, expressions, or attractions. However, the law permits counselors to support clients exploring their identity or undergoing gender transition. The counselor’s practice involves helping clients pursue their own stated goals, which may include support for changes in sexual orientation or gender identity, but she only utilizes talk therapy and does not engage in any physical interventions.The United States District Court for the District of Colorado first reviewed the case. That court, and later the United States Court of Appeals for the Tenth Circuit, concluded that the counselor had standing to bring a pre-enforcement, as-applied First Amendment challenge to the law. Both courts interpreted the law as prohibiting her from using speech to help clients change their sexual orientation or gender identity. Nevertheless, both courts denied her request for a preliminary injunction, reasoning that the law regulates professional conduct, not speech, and any effect on speech is merely incidental. Applying rational-basis review, they found the law constitutionally permissible.The Supreme Court of the United States granted review to resolve a circuit split. The Supreme Court held that, as applied to the counselor’s talk therapy, the Colorado law regulates speech based on viewpoint, not merely conduct, and that the lower courts erred by applying only rational-basis scrutiny. The Supreme Court ruled that the law is subject to strict scrutiny under the First Amendment and reversed the Tenth Circuit’s decision, remanding the case for further proceedings consistent with its opinion. View "Chiles v. Salazar" on Justia Law

A class of inmates at the Louisiana State Penitentiary alleged that the prison’s medical care was constitutionally inadequate and that the facility failed to comply with the Americans with Disabilities Act and the Rehabilitation Act. The lawsuit began in 2015, and evidence was introduced at trial in 2018. In 2021, the United States District Court for the Middle District of Louisiana issued a lengthy opinion finding systemic Eighth Amendment violations and ADA/RA noncompliance. While prison officials began making improvements ahead of a scheduled remedial trial, the district court later issued a Remedial Opinion and Order, prescribing detailed institutional changes and appointing special masters to oversee compliance.The district court’s Remedial Order required the state to bear the costs of three special masters, directed broad institutional reforms, and did not expressly adhere to the limitations imposed by the Prison Litigation Reform Act (PLRA). The court entered final judgment in favor of the plaintiffs, retaining jurisdiction only for compliance procedures. After entry of judgment, the defendants appealed. During the appeal, a panel of the United States Court of Appeals for the Fifth Circuit stayed the Remedial Order. The Fifth Circuit, sitting en banc, subsequently reviewed whether it had appellate jurisdiction and the validity of the district court’s orders.The United States Court of Appeals for the Fifth Circuit held that it had appellate jurisdiction under 28 U.S.C. § 1291 or, alternatively, § 1292(a)(1). The Fifth Circuit found that the district court’s Remedial Order violated the PLRA by failing to apply the statutory needs-narrowness-intrusiveness standard, improperly appointing multiple special masters, and requiring the state to pay their fees. The Fifth Circuit also concluded that the district court erred by disregarding ongoing improvements to prison medical care and by misapplying the standards for injunctive relief under the Eighth Amendment and the ADA/RA. The court vacated the district court’s judgment and remanded for further proceedings. View "Parker v. Hooper" on Justia Law

The defendant was found driving a car in which police discovered an assault rifle with a large-capacity magazine on the front seat. He attempted to evade a traffic stop and subsequently fled the vehicle. The prosecution charged him with felony “receiving” a large-capacity magazine under California Penal Code section 32310, subdivision (a). The only evidence presented was that the defendant possessed the magazine, with no additional evidence about how or when he acquired it.The Contra Costa County Superior Court convicted the defendant of felony receiving a large-capacity magazine. The defendant appealed, contending there was insufficient evidence to support the conviction for receiving, as opposed to mere possession, and that the jury was incorrectly instructed on the distinction between the two offenses. He also argued the statute was unconstitutional. The prosecution argued that the evidence was sufficient to support the felony conviction and that the defendant’s actions supported a finding of receiving rather than just possessing.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed the case. The court concluded that Penal Code section 32310 distinguishes between “receiving” and “possessing” a large-capacity magazine, with “receiving” punishable as a felony or misdemeanor and “possessing” punishable as a misdemeanor or infraction. The appellate court found that mere possession is insufficient to support a conviction for receiving; additional evidence is required to show how or when the defendant acquired the magazine. Because the record contained no such evidence, the court reversed the defendant’s felony conviction for receiving a large-capacity magazine. The rest of the judgment was affirmed. The appellate court did not reach the issues of instructional error or the statute’s constitutionality. View "P. v. Newt" on Justia Law

While incarcerated at Augusta Correctional Center in Virginia, Daniel Jackson, proceeding without an attorney, filed a complaint using a standard prisoner form. He named the prison’s medical department and two healthcare providers as defendants, describing his medical condition and alleging a series of events: the confiscation of his prescribed ankle sleeve, the denial of a lower bunk assignment despite his medical needs, and pain caused by required work footwear. Jackson also claimed he was denied proper physical therapy and pain medication, and asserted that one nurse suggested he acquire drugs illicitly. His complaint sought compensation for lost wages, treatment for his pain, and damages for suffering.The United States District Court for the Western District of Virginia screened the complaint under 28 U.S.C. § 1915A. It construed the action as asserting Eighth Amendment deliberate indifference claims against the individual healthcare providers, dismissing the prison medical department as an improper defendant under § 1983. After allowing Jackson to supplement his complaint with additional allegations—such as retaliation by one nurse—the district court recognized both deliberate indifference and First Amendment retaliation claims. The retaliation claim was dismissed for lack of plausible causation. Ultimately, the district court granted summary judgment for the defendants on the deliberate indifference claims, finding no genuine disputes of material fact regarding the adequacy of medical care provided.Jackson, now represented by counsel, appealed to the United States Court of Appeals for the Fourth Circuit. He argued that the district court should have construed his complaint to assert a claim under the Americans with Disabilities Act (ADA). The Fourth Circuit held that the district court did not err in construing Jackson’s complaint as presenting only an Eighth Amendment claim, emphasizing that courts must liberally construe pro se pleadings but are not required to identify every conceivable claim. The judgment in favor of the defendants was affirmed. View "Jackson v. Dameron" on Justia Law

The case concerns a petitioner who was convicted in West Virginia state court in 2004 of sexually abusing his son. After the trial, it was discovered that, during jury deliberations, one juror told others that he knew the petitioner’s family and feared for his own family’s safety if the petitioner was acquitted. Four jurors later confirmed that the comments had been made, though the juror in question denied them. The petitioner argued this introduced an impermissible external influence into the deliberations, violating his right to an impartial jury.The trial court in West Virginia denied the petitioner’s request for a new trial, finding insufficient evidence of juror impartiality and concluding that the statements related only to the jury’s deliberative process, not to any external influence. The Supreme Court of Appeals of West Virginia affirmed this decision, holding that the comments were intrinsic to the deliberations and thus not grounds to set aside the verdict. The petitioner then sought federal habeas relief under 28 U.S.C. § 2254 in the United States District Court for the Southern District of West Virginia, which denied his petition, concluding the state court had not unreasonably applied Supreme Court precedent.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of habeas relief de novo but applied the deferential standard required by § 2254. The Fourth Circuit held that the state court did not unreasonably apply clearly established Supreme Court law in finding that the juror’s comments were intrinsic, not external, to the deliberation process. The court concluded that, under existing Supreme Court precedent, the statements did not rise to the level of external influence necessary to violate the petitioner’s Sixth Amendment rights. Accordingly, the Fourth Circuit affirmed the district court’s judgment denying habeas relief. View "Daugherty v. Dingus" on Justia Law

Darion Baker and Gregory Dees were driving a stolen car from California with plans to reach Tennessee. In Stratford, Texas, police officers Richard Coborn and Michael McHugh became suspicious of their vehicle, followed them to a gas station, and confirmed the car was stolen. As Baker and Dees returned to their car, the officers approached with weapons drawn and gave commands. Baker put the car in drive, and the officers fired shots—first before the car moved, then as Baker drove away. Baker was fatally shot from behind, while Dees was unharmed.The plaintiffs, including Baker’s estate and family, sued the officers in the United States District Court for the Northern District of Texas, alleging excessive force under 42 U.S.C. § 1983 and violations of the Fourth and Fourteenth Amendments. The officers asserted qualified immunity and moved for summary judgment. The district court granted qualified immunity for the shots fired before the car moved and ruled the second round of shots was reasonable under the Fourth Amendment. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit agreed with the district court regarding the first round of shots but disagreed about the second round, finding that a jury could decide whether the second round was objectively unreasonable. The panel remanded for the district court to decide whether the right was clearly established.On remand, the district court denied qualified immunity for the second round of shots, finding that the violation was clearly established. The officers appealed. The United States Court of Appeals for the Fifth Circuit affirmed, holding that, when the facts are viewed in the light most favorable to the plaintiffs, Coborn’s conduct during the second round of shots constituted a clearly established violation of the Fourth Amendment. Thus, Coborn was not entitled to qualified immunity for the second round of shots. View "Baker v. Coborn" on Justia Law