Justia Constitutional Law Opinion Summaries

A legal resident of Florida, currently living in Illinois, applied for a Texas escrow-officer license. He is an attorney licensed in at least forty jurisdictions, including Texas, and holds title-producer licenses in twenty-four states. The Texas Department of Insurance denied his application solely because he did not reside in Texas or a state bordering Texas, despite admitting that he met all other licensure requirements. The plaintiff claimed that this residency requirement prevented him from serving existing Texas clients, securing new clients, and maintaining relationships with clients who needed title and escrow services in multiple jurisdictions.The United States District Court for the Southern District of Texas denied both the plaintiff’s motion for a preliminary injunction and the State’s motion to dismiss. The district court reasoned that it would be “precipitous” to overturn a long-standing statute on a preliminary basis, inferred little irreparable harm due to the plaintiff’s litigation choices in similar cases elsewhere, and found the merits “unclear” given the present record and lack of factual clarity. The plaintiff timely appealed the denial of preliminary relief.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial for abuse of discretion. The Fifth Circuit found the plaintiff likely to succeed on the merits of his claim under Article IV’s Privileges and Immunities Clause, determining escrow work is a protected common calling and that Texas had offered no substantial justification for its discriminatory residency requirement. The court also found that irreparable harm existed because sovereign immunity barred damages, and the equities and public interest favored preliminary relief. The Fifth Circuit reversed the district court’s denial and remanded with instructions to enter a preliminary injunction prohibiting enforcement of the residency requirement against the plaintiff. View "Polk v. Crawford" on Justia Law

After Puerto Rico experienced several states of emergency, including the COVID-19 pandemic, the government amended its public safety law, Law 20, specifically Article 5.14(a), to criminalize knowingly or recklessly disseminating false information about imminent catastrophes. The law applies during a governor-declared state of emergency or disaster and covers statements made through any medium, including social networks and mass media. Violation of the law can result in misdemeanor or felony charges, depending on the harm caused. Two independent journalists, who had published critical coverage of the government’s handling of emergencies, challenged the constitutionality of Article 5.14(a), arguing it violated their First Amendment rights.The United States District Court for the District of Puerto Rico reviewed the journalists’ claims. The court found Article 5.14(a) to be a content-based regulation, as it distinguished between true and false speech, and applied strict scrutiny. While the government’s interest in public safety was recognized as compelling, the court determined that the statute’s broad restrictions were not narrowly tailored, lacking meaningful limiting features and being both overinclusive and underinclusive. As a result, the district court issued a permanent injunction preventing enforcement of Article 5.14(a). The government’s motion for reconsideration was unsuccessful, leading to a timely appeal.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court’s decision, holding that Article 5.14(a) is a content-based regulation subject to strict scrutiny, and does not fall within any traditional exceptions to First Amendment protection. The First Circuit found that the statute was not narrowly tailored to serve the government’s compelling interest in public safety and failed to demonstrate necessity or a direct causal link between the restriction and the harm prevented. The injunction against enforcement of Article 5.14(a) was affirmed. View "Rodriguez-Cotto v. Gonzalez-Colon" on Justia Law

Halil Demir, a naturalized U.S. citizen and Executive Director of an international aid organization, frequently travels for work and has received security clearances for certain events. Since 2016, Demir experienced extended airport screening, leading him to suspect wrongful inclusion on the FBI’s Terrorist Watchlist and its Selectee List. After submitting five inquiries through the Department of Homeland Security’s Traveler Redress Inquiry Program (DHS TRIP), he received generic responses that neither confirmed nor denied his watchlist status. Demir then filed suit, alleging violations of his substantive and procedural due process rights and challenging the adequacy of DHS TRIP procedures under the Administrative Procedure Act.The United States District Court for the Northern District of Illinois dismissed Demir’s complaint for lack of subject matter jurisdiction. The court concluded that, under 49 U.S.C. § 46110, challenges to TSA orders—including those relating to DHS TRIP—must be brought directly in a federal court of appeals. It reasoned that Demir’s claims were essentially contesting a TSA decision, as reflected in the DHS TRIP determination letter, and thus should have originated in the Court of Appeals.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that § 46110 does not apply to Demir’s challenges to his inclusion on the Terrorist Watchlist and Selectee List, as the TSA does not control these lists—the FBI’s Threat Screening Center does. Thus, the district court has jurisdiction over those claims, and the appellate court reversed and remanded them for consideration on the merits. However, the appellate court affirmed the district court’s dismissal of Demir’s challenge to the DHS TRIP program itself, holding that the program constitutes an “order” under § 46110 and must be initially reviewed in a court of appeals. View "Demir v Mullin" on Justia Law

A restaurant in Florida that hosts drag performances challenged the constitutionality of a state law known as the Protection of Children Act. The Act makes it a misdemeanor to knowingly admit a child to an “adult live performance,” defined as shows depicting nudity, sexual conduct, or lewd conduct, and meeting additional criteria based on prurient appeal, offensiveness to community standards for the age of the child present, and lack of serious value for that age. The restaurant argued that the Act’s use of the word “lewd” and its age-variable standards rendered the law unconstitutionally vague and overbroad, alleging harm to its business and chilling of its performances.The United States District Court for the Middle District of Florida granted a preliminary injunction, finding the Act unlikely to survive strict scrutiny and to be unconstitutionally vague and overbroad. The injunction barred the Secretary of the Florida Department of Business and Professional Regulation from enforcing the Act against anyone in the state. This decision was affirmed by a divided panel of the United States Court of Appeals for the Eleventh Circuit, but the full court granted rehearing en banc, stayed the injunction as to nonparties, and requested briefing on the scope and merits of the case.The United States Court of Appeals for the Eleventh Circuit, on en banc review, vacated the preliminary injunction in its entirety. The court held that the district court lacked authority to issue a universal injunction barring enforcement of the Act statewide, as such relief exceeds a federal court’s equitable power. Furthermore, the court found the Act’s language, as construed by Florida precedent, did not render it unconstitutionally vague or overbroad, and Hamburger Mary’s was not substantially likely to succeed on the merits. The matter was remanded for further proceedings consistent with this opinion. View "HM Florida-ORL, LLC v. Secretary of the Florida Department of Business" on Justia Law

The case centers on a juvenile, John Doe, who was charged by the government with two counts of violating the Federal Juvenile Delinquency Act by possessing a handgun in violation of 18 U.S.C. § 922(x)(2) on two separate occasions. Section 922(x)(2) prohibits juveniles from knowingly possessing a handgun or handgun ammunition, with certain exceptions outlined in the statute. Doe challenged the charges, asserting that the statute exceeded Congress’s authority under the Commerce Clause and violated the Second Amendment, though he ultimately appealed only the Commerce Clause issue.The United States District Court denied Doe’s motion to dismiss the information, finding that Congress had the power to enact § 922(x)(2) under the Commerce Clause. Doe admitted delinquency to one count, was sentenced to juvenile probation until his 21st birthday, and subsequently appealed the district court’s Commerce Clause ruling to the United States Court of Appeals for the Tenth Circuit.The United States Court of Appeals for the Tenth Circuit reviewed the constitutionality of § 922(x)(2) de novo. The court held that Congress had a rational basis to conclude that regulating juvenile handgun possession was an essential part of a comprehensive regulatory scheme aimed at the interstate handgun market. The court determined that Congress could rationally conclude that the regulatory scheme would be substantially undercut if § 922(x)(2) were removed, and that such regulation directly and substantially affects interstate commerce. Accordingly, the Tenth Circuit affirmed the district court’s ruling, upholding Congress’s authority to enact § 922(x)(2) under the Commerce Clause. View "United States v. Doe" on Justia Law

The case centers on a fatal shooting that occurred on March 29, 2023, involving a love triangle between Steven Beard (the defendant), Michael Ingram (the victim), and Ashton Meigs. Meigs had relationships with both men, leading to jealousy and confrontations. On the night of the incident, Meigs and Ingram went to Beard’s trailer to collect Meigs’ belongings after Beard told her to do so and claimed he would not be home. Beard parked his truck out of sight, obtained a shotgun, and shot Ingram as he entered the trailer. Surveillance footage showed Ingram with his hands raised before being shot, and Beard fired a second shot at point-blank range while Ingram lay motionless.The United States District Court for the Eastern District of Oklahoma presided over the trial. The government charged Beard with murder in Indian country, using and discharging a firearm in relation to a crime of violence, and causing death with a firearm. The jury convicted Beard on all counts. Before sentencing, the government requested dismissal of the § 924(j) count as multiplicitous with the § 924(c) count, which the district court granted. Beard was sentenced to life imprisonment for murder and a consecutive ten-year sentence for the firearm offense.The United States Court of Appeals for the Tenth Circuit reviewed Beard’s appeal challenging the sufficiency of evidence, admission of hearsay and prior bad acts, prosecutorial conduct, and the sentencing decision. The court held that the government presented sufficient evidence for premeditation and lack of self-defense, any hearsay error regarding tribal status was harmless, and the admission of prior bad acts and prosecutorial conduct did not amount to plain error or fundamental unfairness. The court also determined that dismissing the § 924(j) count in favor of sentencing under § 924(c) was proper under recent Supreme Court precedent. The convictions and sentence were affirmed. View "United States v. Beard" on Justia Law

In 2017, an investment entity loaned approximately 160 million Chinese yuan to an individual, who failed to repay the loan. The lender obtained an arbitral award against the borrower from the Beijing Arbitration Commission for around 150 million yuan. A Singaporean court later ordered the borrower to pay the award, but he still did not comply. The lender, knowing the borrower had been living in California for about two years, sought to enforce the foreign arbitral award in the United States under the Federal Arbitration Act by filing a petition in the U.S. District Court for the Southern District of California. Attempts to serve process directly on the borrower at his California residence were unsuccessful. Eventually, the petition was left with another adult at the residence, mailed, and emailed to the borrower, who later acknowledged receiving notice.The borrower moved to dismiss the case in the U.S. District Court for the Southern District of California, arguing under Federal Rule of Civil Procedure 12(b)(2) that the court lacked personal jurisdiction because his domicile was China and the underlying dispute had no connection to California. He did not raise a defense under Rule 12(b)(5) for insufficient service of process. The district court found that it had general personal jurisdiction over the borrower based on his physical presence in California and confirmed the arbitral award.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the Due Process Clause of the Fourteenth Amendment does not require that presence-based personal jurisdiction be conditioned on service of process on the defendant’s person; other means of service are sufficient if the defendant is physically present in the forum state. The court declined to address the sufficiency of service of process because the borrower had waived this argument by not raising it in district court. The Ninth Circuit affirmed the judgment. View "SHENZHEN ZEHUIJIN INVESTMENT CENTER V. YINGKUI" on Justia Law

The case involves two individuals, Michelle Przybocki and Ketan Vakil, and Vakil’s company, Gourmend Foods, LLC. Przybocki suffers from a digestive condition that requires her to follow a low-FODMAP diet, and Vakil, on medical advice, founded Gourmend Foods to produce and sell low-FODMAP food products. Both plaintiffs wish to see FODMAP levels disclosed on food labels. They allege that federal regulations enforced by the United States Department of Agriculture (USDA) and Food and Drug Administration (FDA) prohibit food companies from including FODMAP information on product labels, which they claim violates their First Amendment rights—Przybocki’s right to receive information and Vakil and Gourmend’s right to speak. Gourmend’s proposed beef broth label, regulated by the USDA, was rejected due to its inclusion of FODMAP information.The United States District Court for the District of Nevada dismissed the plaintiffs’ suit. It found that Vakil and Gourmend lacked standing against the FDA because they were already selling FODMAP-labeled products and had not received warnings from the agency. The court also concluded Przybocki lacked standing as a listener, finding she had not sufficiently alleged that other food producers would provide FODMAP information absent the regulations and that she was not injured by the chilling of Gourmend’s speech. Additionally, Vakil and Gourmend’s claims against the USDA were dismissed for failure to exhaust administrative remedies.The United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal for lack of standing with respect to the plaintiffs’ claims against the FDA and Przybocki’s claims against the USDA. The Ninth Circuit held that Przybocki adequately pleaded standing as a listener and that Vakil and Gourmend sufficiently pleaded standing as speakers for a pre-enforcement challenge against the FDA. In a separate memorandum disposition, the court affirmed the district court’s dismissal of Vakil and Gourmend’s claims against the USDA for failure to exhaust administrative remedies. View "PRZYBOCKI V. UNITED STATES DEPARTMENT OF AGRICULTURE" on Justia Law

Northland Management & Construction, LLC developed four lots in a Missouri subdivision, including Lot 9. The City of Parkville had approved the subdivision’s Sixth Plat, which contemplated grading Lot 9 at a continuous slope to its southern property line. During construction, Northland filled in an existing swale, installed piers to stabilize the home, and created a new swale that diverted stormwater runoff to both Lot 9 and neighboring Lot 3. The City became concerned about erosion and water flow, ultimately requiring Northland to seek a grading permit under Section 520 of the municipal code. Northland refused, believing the permit was unnecessary due to the approved plat. The City denied a final Certificate of Occupancy (CO), prompting Northland to file suit for the CO and damages for the inability to sell Lot 9 at full value.The United States District Court for the Western District of Missouri held a bench trial, where it ruled in favor of Northland on its Missouri state law inverse condemnation and equal protection claims. The court ordered the City to issue a final CO and awarded damages based on the difference in the lot’s value with and without a CO. The City complied with the order but appealed, challenging both the legal and factual bases for the district court’s rulings and the calculation of damages.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s findings that Northland graded Lot 9 consistent with the approved plat and accepted practice, and that the City’s application of Section 520 was unreasonable. The appellate court also upheld the equal protection claim, finding Northland was treated differently from similarly situated property owners without rational basis. However, the court reversed the damages award, holding that compensation must reflect only the temporary diminution in value during the period the CO was withheld, and remanded for recalculation of damages. View "Northland Management & Construction, LLC v. City of Parkville" on Justia Law

A woman who was diagnosed with placenta previa during her pregnancy developed placenta accreta spectrum (PAS) during a cesarean section at a hospital, which led to a massive hemorrhage and an emergent hysterectomy. After extensive surgery, she was moved to the ICU for monitoring. The ICU physician and a medical staffing agency were responsible for her care there. Her condition deteriorated, resulting in respiratory and cardiac arrest, and she died the following morning. Her fiancé, acting as administrator of her estate, and a conservator for her children sued the ICU doctor and the staffing agency, alleging medical malpractice and wrongful death. The plaintiffs presented expert testimony regarding deviations from the standard of care by the ICU doctor.The Superior Court of Rockdale County presided over the trial. Most defendants settled before trial, leaving only the ICU physician and the staffing agency. The jury found both defendants liable, awarding $10 million to the estate for pain and suffering and $32 million to the children for wrongful death. After trial, the defendants moved for a new trial and, alternatively, to amend the judgment to apply a statutory cap on noneconomic damages. The court denied both motions, concluding the cap had been waived and, in the alternative, that the statutory cap was unconstitutional. The plaintiffs were awarded attorney fees under Georgia law after the defendants rejected a qualifying settlement offer.The Supreme Court of Georgia reviewed the appeal. It held that the trial court did not abuse its discretion by excluding portions of the defendants’ expert testimony, nor did it err in its jury instructions, as any alleged error was affirmatively waived by the defendants. The Court also held, consistent with its contemporaneous decision in Clark v. Leigh and Atlanta Oculoplastic Surgery, P.C. v. Nestlehutt, that the statutory cap on noneconomic damages in medical malpractice cases cannot constitutionally be applied to the jury’s verdict in this case. The award of attorney fees to the plaintiffs was affirmed. Judgment affirmed. View "CAYAMCELA v. ADVOCACY TRUST, LLC" on Justia Law