Justia Constitutional Law Opinion Summaries

A correctional officer with almost nineteen years of service was terminated by the state corrections department after he disclosed information about an upcoming search (“shakedown”) to his son, who was incarcerated at a different facility. The department conducted an investigation following a recorded phone call and statements gathered from both the officer and his son. The officer’s son allegedly boasted about receiving advance notice of the search, while the officer admitted in the investigation that he inadvertently shared information. After the investigation, the officer was fired for violating departmental policy. The officer attempted to appeal his termination, but filed his grievance with the wrong agency and did not follow up for over two years.The United States District Court for the Eastern District of Wisconsin dismissed the son’s First Amendment retaliation claim at the screening stage and later granted summary judgment in favor of the corrections department on the officer’s First Amendment retaliation and Fourteenth Amendment procedural due process claims. The district court determined that the officer’s speech was not protected because it did not address a matter of public concern, and that adequate pre- and post-termination procedures were available to the officer, despite his procedural missteps.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decisions. The appellate court held that the officer’s statement about the shakedown was not protected speech under the First Amendment, as it was private and not of public concern. It also found that the officer received sufficient notice and opportunity to respond before termination, and that adequate avenues for post-termination review were available, even if he failed to properly use them. The court further concluded that the son’s claim did not state a constitutional violation. The district court’s dismissal and summary judgment orders were affirmed. View "Felton v Johnson" on Justia Law

The defendant was convicted by a jury of multiple drug-trafficking and firearm offenses following a three-day trial, during which he was represented by court-appointed counsel. After the trial and before sentencing, the defendant filed a notice expressing his desire to remove his counsel and represent himself at sentencing. At a subsequent hearing, despite being advised against self-representation, the defendant maintained his wish to proceed pro se for sentencing. The sentencing hearing had not yet been scheduled at the time of his request.The United States District Court for the District of South Carolina denied the defendant’s request to represent himself at sentencing, finding it untimely because it was made several months after the jury verdict and after objections to the presentence report had been filed. The court relied on precedent that allows for denial of self-representation requests made after the commencement of trial and appointed new counsel to represent the defendant at sentencing. The defendant was ultimately sentenced with an enhancement under the Armed Career Criminal Act, and he appealed, arguing that his Sixth Amendment right to self-representation was violated.The United States Court of Appeals for the Fourth Circuit held that the district court erred in denying the defendant’s request to represent himself at sentencing on the basis of untimeliness. The appellate court clarified that a request to proceed pro se at sentencing, made after trial but before sentencing, is not untimely if sentencing has not yet been scheduled and the request does not disrupt proceedings. The court vacated the judgment and remanded the case for resentencing, instructing the district court to conduct a proper Faretta hearing to determine whether the waiver of counsel is knowing, intelligent, and voluntary. The court did not address arguments related to the Armed Career Criminal Act enhancement. View "US v. Jaqu" on Justia Law

The plaintiff, who operated boarding schools and programs for troubled teens, was featured in a three-part documentary series that examined the troubled-teen industry and included depictions and commentary about his role in industry organizations and specific schools. The filmmaker, herself a former student at an affiliated program, created the series based on her personal experience and broader investigative reporting. The series, produced and distributed by a major streaming service, included segments which the plaintiff claimed falsely implied his responsibility for a teen’s death, omitted the ultimate dismissal of criminal charges against him following a facility raid in Costa Rica, and accused him of abusing children and committing crimes.The United States District Court for the District of Utah dismissed the plaintiff's complaint, which included claims for defamation, defamation per se, false light invasion of privacy, intentional infliction of emotional distress, and civil conspiracy. The court concluded that the challenged statements were either non-actionable opinions protected by law and the First Amendment, true, or not defamatory. The court also granted the defendants’ special motion to strike under anti-SLAPP statutes, awarding attorneys’ fees and costs, and declined to decide between Utah or California law because the outcome was the same under either.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The Tenth Circuit held that none of the challenged documentary segments were capable of defamatory meaning under Utah law or the First Amendment. The court found the statements to be either protected opinion, not materially false, or not objectively verifiable. The court also found the anti-SLAPP fee award appropriate and rejected the plaintiff’s arguments regarding amendment and anti-SLAPP procedure, holding that any errors on those points were invited by the plaintiff’s own positions below. View "Lichfield v. Kubler" on Justia Law

The case concerns a defendant who pleaded guilty to being a felon in possession of a firearm, after police discovered a loaded pistol on his person during a traffic stop. The prosecution sought an enhanced sentence under the Armed Career Criminal Act (ACCA), based on the defendant’s prior Oregon state felony convictions: two for third-degree assault and one for strangulation. The defendant challenged the use of these convictions as ACCA predicate offenses, arguing they did not meet the definition of “violent felonies.” He also argued that his constitutional rights were violated because the judge, rather than a jury, determined that his prior offenses occurred on different occasions, a necessary finding to trigger the ACCA enhancement.The United States District Court for the District of Oregon found that the prior convictions were for violent felonies and had been committed on different occasions, and imposed the ACCA’s mandatory minimum sentence of 15 years. The defendant appealed, raising the same constitutional and statutory objections.The United States Court of Appeals for the Ninth Circuit reviewed the case. It concluded that, in light of the Supreme Court’s ruling in Erlinger v. United States, the district court had erred under Apprendi v. New Jersey by making the separate-occasions finding itself, rather than submitting it to a jury. However, the Ninth Circuit held that this error was harmless beyond a reasonable doubt, because the record contained overwhelming and uncontroverted evidence that the offenses occurred on different occasions. The court also held that the defendant’s Oregon convictions for third-degree assault and strangulation qualified as violent felonies under the ACCA. The court therefore affirmed the sentence imposed by the district court. View "USA V. PATTERSON" on Justia Law

In May 2022, Payton Gendron carried out a mass shooting at a supermarket in Buffalo, New York, killing ten Black individuals and injuring three others. He meticulously planned the attack to target Black victims, documenting his intentions and motives in a manifesto and online journal. Following the attack, a grand jury indicted Gendron on multiple federal charges, including hate crimes resulting in death and firearm offenses. The government sought the death penalty on certain counts and provided notice of both statutory and non-statutory aggravating factors, including the impact on surviving victims, Gendron’s racist motive, and his intent to incite further violence.The United States District Court for the Western District of New York struck the three contested non-statutory aggravating factors from the government’s notice. The court reasoned that the surviving victims’ injuries were irrelevant to the capital charges, that federal law precluded the government from presenting Gendron’s racist motive as an aggravator, and that citing his intent to incite further violence would violate his First Amendment rights by punishing protected speech.The United States Court of Appeals for the Second Circuit reviewed these rulings de novo. The Second Circuit held that all three non-statutory aggravating factors were permissible. It concluded that evidence of injury to surviving victims is relevant to the circumstances of the crime in a capital sentencing proceeding. The court determined that presenting Gendron’s racist motive does not violate statutory restrictions, as the motive itself, not the race of the victims, is at issue. Finally, the court held that referencing Gendron’s intent to incite further violence does not infringe upon his First Amendment rights when used to establish motive for the crime. The Second Circuit reversed the district court’s order and remanded for further proceedings. View "United States v. Gendron" on Justia Law

A man was stopped by police while driving a car matching the description of a vehicle seen leaving the scene of a shooting. Police found a loaded handgun in the glovebox. During questioning, the driver admitted to being at the scene and driving the car, but when asked for a DNA sample to compare with the handgun, he refused and ended the interview. At trial, the prosecutor argued that the defendant’s decision to stop cooperating was evidence of a “guilty conscience,” displaying a board with that phrase to the jury and contrasting his actions with those of other occupants who continued their interviews.After closing arguments, the Macomb Circuit Court judge raised concerns that the prosecutor’s comments improperly used the defendant’s invocation of his right to silence against him. Defense counsel moved for a mistrial, which the court granted. The defendant argued that a retrial would violate double jeopardy, but the trial court denied this, finding no evidence that the prosecutor specifically intended to provoke a mistrial. At the second trial, the prosecution shifted its theory, and the defendant was convicted. The Michigan Court of Appeals affirmed, holding that retrial was not barred under the standard from Oregon v Kennedy, 456 US 667 (1982), because the prosecutor’s misconduct was not intended to goad the defense into requesting a mistrial but was instead reckless or negligent.On further appeal, the Michigan Supreme Court held that the Kennedy standard does not properly protect the double-jeopardy rights guaranteed by the Michigan Constitution. The Court rejected Kennedy and adopted the broader standard from Pool v Superior Court, 139 Ariz 98 (1984), holding that retrial is barred if a mistrial is granted due to intentional, prejudicial prosecutorial misconduct pursued for an improper purpose with indifference to the risk of mistrial, and the resulting prejudice cannot be cured short of a mistrial. The Court vacated the judgment of the Court of Appeals and remanded for application of the new standard. View "People Of Michigan v. Jennings" on Justia Law

A group of individuals who wished to protest outside a high-profile murder trial in Massachusetts were prohibited from doing so by a Superior Court judge’s order establishing a 200-foot buffer zone around the courthouse, including nearby sidewalks and streets. After the buffer zone was imposed, the plaintiffs—demonstrators—filed suit in federal court against various public officials and entities, alleging violations of their First Amendment and due process rights.The United States District Court for the District of Massachusetts initially denied a preliminary injunction against the buffer zone, but the United States Court of Appeals for the First Circuit vacated that denial and remanded, suggesting that a restriction more closely tailored to demonstrations intended to interfere with justice might be permissible. In response, the Superior Court judge amended the order to include a requirement of intent to interfere with the administration of justice or influence trial participants. The district court then partially granted and partially denied a renewed motion for a preliminary injunction: it found the revised order survived a facial First Amendment challenge but agreed with plaintiffs that there had been unconstitutional as-applied enforcement, granting limited relief.After the murder trial concluded and the buffer zone order expired by its own terms, the plaintiffs continued to appeal the denial of broader injunctive relief. The United States Court of Appeals for the First Circuit held that the case was moot because the order was no longer in effect and there was no reasonable expectation the same plaintiffs would again face a similar restriction. The court determined that neither injunctive nor declaratory relief was available and that the “capable of repetition, yet evading review” exception did not apply. As a result, the First Circuit vacated the district court’s partial denial of the preliminary injunction and ordered dismissal of that portion of the case, leaving the remainder to the district court. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law

A minor child, who had been in her grandmother’s custody due to her mother’s intellectual disabilities, became the subject of a child in need of assistance (CINA) case after concerns arose about missed medical appointments and poor academic performance. The Department of Social Services petitioned for CINA status, but the juvenile court initially allowed the child to remain with her grandmother under protective supervision. Over time, further review hearings were held, and eventually a magistrate recommended removing the child from her grandmother’s custody. The child and her grandmother objected, leading to a de novo exceptions hearing.At the exceptions hearing, the Circuit Court for Worcester County, sitting as a juvenile court, excluded the child from the hearing over the objection of her counsel, reasoning generally that it was inappropriate for children under 15, especially those with developmental delays, to attend such contested proceedings. The court later removed the child from her grandmother’s custody and placed her with the Department. The Appellate Court of Maryland affirmed the juvenile court, finding no abuse of discretion, and distinguished this case from prior precedent by concluding the juvenile court had considered the child’s due process rights.The Supreme Court of Maryland reviewed the case and held that, although the appeal was moot because the CINA proceedings had been terminated and custody restored to the grandmother, the case presented an issue of public importance warranting review. The Court held the juvenile court violated the child’s procedural due process rights by excluding her from her own CINA hearing without making individualized findings or balancing her due process interests against any potential harm from her presence. The Court articulated a new test requiring courts to make specific findings and narrowly tailor any exclusion of a child party. The judgment of the Appellate Court of Maryland was reversed. View "In re: K.B." on Justia Law

Two naturalized U.S. citizens, who previously obtained lawful status through the Special Immigrant Juvenile (SIJ) program after state courts found parental abuse, neglect, or abandonment, sought to confer immigration benefits to their noncitizen mothers. Both mothers’ applications were denied by United States Citizenship and Immigration Services (USCIS), invoking an exclusion clause in the SIJ statute, 8 U.S.C. § 1101(a)(27)(J)(iii)(II), and an implementing regulation prohibiting parents of SIJ recipients from receiving immigration benefits based on parentage. The plaintiffs challenged both USCIS’s interpretation of the exclusion clause and the constitutionality of the clause, arguing it violated equal protection.The United States District Court for the Eastern District of Virginia, reviewing cross-motions for summary judgment, ruled in favor of USCIS. The court held that the regulation was consistent with the plain text of the exclusion clause and rejected the equal protection claim, concluding that plaintiffs lacked a direct constitutional injury and, in the alternative, that the exclusion survived rational basis review. Plaintiffs appealed, maintaining their APA and equal protection challenges.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the exclusion clause’s plain text establishes a permanent bar, preventing any parent of an SIJ recipient from receiving immigration benefits based solely on parentage, regardless of whether the parent was abusive or not. The court also held that USCIS’s regulation is consistent with the statute. On the equal protection claim, the Fourth Circuit found differential treatment but determined that the exclusion clause survives rational basis review, as it is rationally related to protecting children from harm. The judgment of the district court was affirmed. View "Fuentes v. Citizenship and Immigration Services" on Justia Law

Texas enacted a law imposing new requirements on certain social media platforms, termed "digital service providers" (DSPs), to restrict minors’ access to specific categories of content. These requirements included monitoring and filtering content deemed harmful, prohibiting targeted ads to minors, preventing unlawful ads, verifying user age for access to certain material, and requiring age registration for account creation. Two groups challenged the law: one group, including technology industry organizations, contested the monitoring and filtering requirement; another group, comprised of a student coalition, individuals, and an ad agency, challenged several provisions, including the monitoring and filtering, targeted ads, unlawful ads, and age-verification requirements.In the United States District Court for the Western District of Texas, both plaintiffs sought preliminary injunctions against enforcement of the law. The district court granted injunctions in part, enjoining the monitoring and filtering requirements for both groups, and enjoining the targeted ads, unlawful ads, and age-verification requirements for the student coalition group. The court found these provisions likely unconstitutional or vague, and held that the plaintiffs had standing based on the chilling effect on their speech and listening rights. The Attorney General of Texas appealed, and the United States Court of Appeals for the Fifth Circuit consolidated the cases.The United States Court of Appeals for the Fifth Circuit held that the student coalition plaintiffs lacked standing to challenge the monitoring and filtering, targeted ads, and unlawful ads requirements, as they were not directly regulated and failed to show a substantial risk of imminent harm. Their challenge to the age-verification requirement was foreclosed by Supreme Court precedent. However, the court held that the monitoring and filtering requirement, as challenged by the industry groups, is preempted by Section 230 of the Communications Decency Act. The Fifth Circuit affirmed the district court’s injunction as to the industry group, but vacated and remanded the injunction as to the student coalition plaintiffs. View "Computer & Communications Industry Association v. Paxton" on Justia Law