Justia Constitutional Law Opinion Summaries

Two men were convicted in the Circuit Court for Baltimore City on charges related to the 2019 murder of Donnell Brockington, who was surrounded and fatally shot multiple times by a group of six individuals. After the suspects fled, four, including the two respondents, were apprehended when their vehicle crashed. Police recovered several firearms, and DNA evidence linked both respondents to a Desert Eagle 9mm pistol found in the vehicle. At trial, a State firearms examiner testified that certain ammunition components were fired from that pistol, but neither respondent challenged the reliability of the examiner’s methodology or requested a Daubert hearing.After trial, the Supreme Court of Maryland decided Abruquah v. State, clarifying the limits on firearms identification testimony. The Appellate Court of Maryland reversed the respondents’ convictions on plain-error review, concluding that the firearms examiner’s unqualified testimony was exactly the kind prohibited by Abruquah. Additionally, one respondent challenged the trial court’s decision to close the courtroom during jury deliberations and partially restrict attendance during the verdict, arguing it violated the Sixth Amendment. The Appellate Court found these closures de minimis and rejected the public trial claim.The Supreme Court of Maryland held that the admission of the firearms examiner’s unqualified opinion was not “clear or obvious” error for plain-error review purposes, since the law was unsettled both at trial and on appeal; Abruquah was a case-specific ruling, not a categorical ban on such testimony. The Court also concluded that the courtroom closures were not de minimis but were justified under Waller v. Georgia, given the trial court’s findings of escalating spectator misconduct and concern for juror safety. The Supreme Court reversed the Appellate Court’s judgment on the convictions, affirmed its ruling on the public trial issue, and remanded for further proceedings. View "State v. Thornton" on Justia Law

In 1995, a man was convicted by a jury in the Dauphin County Court of Common Pleas for first-degree murder following the shooting death of another individual related to a drug deal. Two key prosecution witnesses, both facing pending charges themselves, testified against him in exchange for plea agreements. The prosecution did not disclose all pending charges against these witnesses, though defense counsel was able to impeach their credibility based on other known charges. Despite this, the jury convicted the defendant, who was sentenced to life imprisonment. He unsuccessfully challenged his conviction on direct appeal and through multiple post-conviction proceedings in state court.After eventually discovering the full extent of the witnesses' pending charges, the petitioner filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Middle District of Pennsylvania, asserting a Brady violation. The District Court denied the petition as untimely under the statute of limitations, and subsequent requests for a certificate of appealability were also denied. Following a significant change in Third Circuit law announced in Dennis v. Secretary, Pennsylvania Department of Corrections, the petitioner sought to reopen his federal habeas case under Federal Rule of Civil Procedure 60(b)(6). After a remand for further analysis, the District Court again denied the Rule 60(b)(6) motion, finding that the factors for extraordinary relief were not met.The United States Court of Appeals for the Third Circuit reviewed the denial, applying an abuse-of-discretion standard and weighing the Cox factors. The Court held that, although the materiality and diligence factors favored the petitioner, the remaining factors—likelihood of success, finality and comity, lack of actual innocence, and non-capital sentence—strongly disfavored relief. The Third Circuit affirmed the District Court’s denial of the Rule 60(b)(6) motion. View "Bracey v. Superintendent Rockview SCI" on Justia Law

In July 2024, police in Iowa investigated a report that Eric Schadl, a person prohibited from possessing firearms due to a prior conviction, had a gun in his home. Schadl admitted to owning a .22 caliber rifle and having a 2010 misdemeanor domestic abuse assault conviction, which barred him from firearm possession under Iowa law. He was charged under Iowa Code § 724.26(2)(a), which imposes a lifetime firearm ban on individuals convicted of a misdemeanor crime of domestic violence.Schadl moved to dismiss the charge in Iowa District Court for Dubuque County, arguing the statute violated his right to keep and bear arms under both the Iowa and Federal Constitutions. The district court denied his motion, finding the statute constitutional under intermediate scrutiny. Schadl then asked the court to reconsider, arguing that strict scrutiny applied under the Iowa Constitution’s Amendment 1A, and that recent United States Supreme Court decisions had changed the federal standard. The district court reaffirmed its prior ruling, this time stating the statute survived even under strict scrutiny. Schadl entered a conditional guilty plea, reserving the right to appeal the constitutional issue, and was sentenced to a suspended sentence with probation.On appeal, the Supreme Court of Iowa reviewed whether the lifetime firearm ban, as applied to Schadl, violated Amendment 1A of the Iowa Constitution, which requires all firearm restrictions to survive strict scrutiny. The court rejected Schadl’s facial challenge but found for him on his as-applied challenge, holding that the State failed to prove the indefinite ban was narrowly tailored to serve a compelling public safety interest, especially given Schadl’s fourteen years without reoffending. The court concluded the State had not met its burden under strict scrutiny and reversed Schadl’s conviction, remanding the case to the district court for dismissal. View "State of Iowa v. Schadl" on Justia Law

Several individuals incarcerated in Iowa correctional institutions challenged the constitutionality of Iowa Code section 904.310A, as amended in 2018, which prohibits the Iowa Department of Corrections from using funds to distribute or make available any commercially published material to inmates when such material is sexually explicit or features nudity. The plaintiffs, representing themselves and later joined by counsel, argued that this prohibition infringed on their rights to free speech under the United States and Iowa Constitutions. The amended statute and corresponding regulations resulted in the closure of reading rooms and a bar on materials with nudity, even when not sexually explicit. The challenged policy did not apply to personal photographs, only to commercially published materials.The Iowa District Court for Polk County initially granted a partial injunction, permitting the distribution of materials featuring mere, non-sexually explicit nudity, but ultimately denied most of the plaintiffs’ constitutional claims following a bench trial. The court applied the Turner v. Safley standard, requiring prison regulations that burden inmates’ constitutional rights to be reasonably related to legitimate penological interests. The court found that, while the regulation was more restrictive than prior policy, the State presented sufficient evidence—including expert testimony and examples of staff harassment and inmate safety issues—to support the connection between the ban and legitimate interests in institutional safety and order. As a result, the court denied the plaintiffs’ claims for declaratory and injunctive relief.On appeal, the Iowa Supreme Court conducted a de novo review and affirmed the district court’s judgment. The Supreme Court held that the Turner reasonableness standard, rather than strict scrutiny, applies to inmates’ free speech claims under both federal and state constitutions. The Court concluded that the regulation is justified by legitimate penological interests in staff and inmate safety, and that the ban is not an exaggerated response to those concerns. The judgment was affirmed. View "Gregory v. State of Iowa" on Justia Law

A woman, referred to as Naomi, was charged with felony battery by a prisoner after slapping a nurse while incarcerated in the Milwaukee County jail. At her initial court appearance, concerns were raised about her competency to stand trial, and the Milwaukee County Circuit Court ordered a competency evaluation. Upon finding Naomi incompetent but likely to regain competence with treatment, the court committed her to the Department of Health Services (DHS) for treatment. The court originally found her incompetent to refuse medication and, after applying the standards from Sell v. United States, ordered involuntary medication to restore competency. Naomi appealed, and the court stayed the order. Subsequently, after DHS raised concerns about Naomi’s dangerousness, the court vacated its earlier order and issued a new involuntary medication order based solely on Naomi’s dangerousness, relying on WIS. STAT. § 51.61(1)(g)3.Naomi challenged the legal authority for this order, arguing that someone committed only under WIS. STAT. § 971.14 for competency restoration could not be involuntarily medicated on dangerousness grounds under § 51.61(1)(g)3. The Wisconsin Court of Appeals agreed with Naomi, rejecting the State’s arguments that various statutory and case law authorities permitted the order.The Supreme Court of Wisconsin reviewed the matter and affirmed the Court of Appeals. The court held that WIS. STAT. § 51.61(1)(g)3. does not authorize a court to order involuntary medication for an individual committed exclusively under WIS. STAT. § 971.14. The court based its decision on statutory language, context, and history, finding that § 971.14 provides a separate, more stringent process for involuntary medication orders in the context of competency restoration, and that § 51.61(1)(g)3. cannot be used as an alternative basis for such orders. View "State v. N. K. B." on Justia Law

Two individuals—a student enrolled in a nursing program and a prospective paramedic student—challenged a community college’s policy requiring proof of COVID-19 vaccination for participation in certain clinical programs. The student alleged she was removed from the nursing program after failing to provide proof of vaccination and not receiving a clear response to her request for a medical exemption. She also claimed that the college placed her in clinical rotations at facilities with strict vaccination requirements, while other students were placed at locations accommodating the unvaccinated. The prospective paramedic student did not complete the vaccination requirement, did not seek an exemption, and was told that proof of vaccination or a successful exemption was necessary for acceptance.The District Court for Lancaster County allowed amendment of the initial complaint, but ultimately dismissed the amended complaint for lack of subject matter jurisdiction and failure to state a claim. The court found that the contract and negligence claims were barred by sovereign immunity, that the due process and equal protection claims lacked sufficient factual allegations to proceed, and that the “ultra vires” claim was not cognizable. The court denied further leave to amend, finding amendment would be futile. A timely postjudgment motion to alter or amend was denied, and the plaintiffs appealed.The Nebraska Supreme Court, after reviewing for plain error due to briefing deficiencies, found no plain error in the lower court’s dismissal of the case. The Court concluded that the district court properly dismissed all claims and that the appeal was timely. The Supreme Court affirmed the judgment of the district court. View "Fischer v. Southeast Community College" on Justia Law

An online journalist residing in Bossier Parish, Louisiana, attended several Bossier City Council meetings in 2023 to speak on a petition for term limits for city officials. At these meetings, the City Council enforced a policy governing public comment, which barred “personal, impertinent or slanderous remarks” and prohibited “boisterous” conduct. The policy was repeatedly invoked to interrupt the journalist’s remarks, and after a contentious meeting, several councilmembers met privately to discuss further restricting public comment. The journalist later filed an open meetings complaint and sued the city and individual councilmembers under federal and state law, alleging violations of the First Amendment and Louisiana’s Open Meetings Law.The United States District Court for the Western District of Louisiana granted the defendants’ motion to dismiss, rejecting all of the journalist’s claims under Rule 12(b)(6). The court found that the policy did not violate constitutional or statutory rights and that the conduct described did not support actionable claims.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The court held that the City Council’s policy was facially overbroad and unconstitutionally vague under the First and Fourteenth Amendments, as its prohibitions on “personal, impertinent or slanderous remarks” and “boisterous” conduct lacked clear definitions and chilled protected speech. The court also found that the policy constituted viewpoint and content discrimination, except as to the prohibition on “boisterous” conduct, which was deemed viewpoint neutral. The court determined that the journalist had plausibly alleged First Amendment retaliation and an Open Meetings Law violation against certain councilmembers, but not against one councilmember or for civil penalties. Accordingly, the Fifth Circuit affirmed the district court’s dismissal in part and reversed in part, remanding for further proceedings. View "Merriott v. City of Bossier City" on Justia Law

Four individuals who regularly engage in panhandling in Daytona Beach, Florida, challenged the city’s 2019 ordinance that imposed wide-ranging restrictions on panhandling. They argued that the law, which defined panhandling as in-person requests for immediate donations, and which banned or restricted this conduct in various locations and circumstances, violated their First Amendment rights. Each plaintiff relied on panhandling for basic needs and had faced threats, arrests, or other enforcement actions as a result of the ordinance.The United States District Court for the Middle District of Florida reviewed the case and granted summary judgment in favor of the plaintiffs. The court found that the ordinance’s challenged provisions were content-based, failed strict scrutiny, and thus violated the First Amendment. It issued a declaratory judgment, a universal injunction against enforcement of the challenged provisions, and awarded damages as agreed by the parties. The City of Daytona Beach appealed these decisions.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the ordinance imposed content-based restrictions on speech by targeting only in-person requests for immediate donations, distinguishing them from other types of solicitation. The court found that several provisions could not withstand strict scrutiny, as the city had less speech-restrictive means to achieve its public health and safety goals. However, the Eleventh Circuit determined that the plaintiffs had standing to challenge only some, not all, of the ordinance’s provisions and that the district court’s remedy was overbroad. The appellate court affirmed the district court’s ruling as to the provisions where at least one plaintiff had standing, vacated it in other respects, and remanded for further proceedings consistent with its opinion. The damages award was affirmed because at least one provision was found unconstitutional. View "Scott v. City of Daytona Beach" on Justia Law

James Morgan was investigated by law enforcement for several years due to his online activity, which included posting instructions for making dangerous homemade weapons and advocating for violence against government officials and minority groups. His posts, while often protected speech, were accompanied by demonstrations of weapons such as pipe bombs, acid sprayers, and flamethrowers. In late 2023, federal agents sought and obtained a search warrant from a magistrate judge in the Eastern District of Wisconsin to search Morgan’s property, including a trailer parked in the Western District, based on an affidavit detailing his conduct and apparent intent to commit acts dangerous to human life.After executing the warrant, agents found pipe bombs in Morgan’s trailer. He was indicted by a grand jury in the Western District of Wisconsin for possession of unregistered destructive devices under 26 U.S.C. § 5861(d). Morgan moved in the United States District Court for the Western District of Wisconsin to suppress the evidence, arguing the magistrate lacked authority to issue an extra-district warrant under Federal Rule of Criminal Procedure 41(b), and to dismiss the indictment, claiming the statute exceeded Congress’s taxing power. The district court denied both motions, finding the affidavit provided probable cause that Morgan’s activities constituted domestic terrorism under Rule 41(b)(3) and that established precedent foreclosed his constitutional challenge. Morgan entered a conditional guilty plea, reserving his right to appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The court held the affidavit supplied probable cause that Morgan’s activities met the statutory definition of domestic terrorism, authorizing the magistrate’s extra-district warrant under Rule 41(b)(3). It also concluded that Morgan’s constitutional challenge to 26 U.S.C. § 5861(d) was foreclosed by Supreme Court and Seventh Circuit precedent, upholding the statute as a valid exercise of Congress’s taxing power. View "USA v Morgan" on Justia Law

An elected official in a Tennessee city, after selling her home and residing outside city limits for an extended period, faced a legal challenge to her eligibility to serve based on the city’s residency requirement. The challenge was initiated after a citizen petition, supported by over two hundred signatures, prompted the district attorney to file a quo warranto petition seeking her removal from office. Although she later purchased an unimproved lot in the city and began construction of a new home, questions remained about her intent to return and her actual residency during the contested period.The Tennessee state court found her claims of living on the undeveloped property unconvincing but ultimately determined that her efforts to build a residence demonstrated just enough intent to return, allowing her to retain her office. Following this outcome, the official sued two citizens, the city, the mayor, and the city administrator in the United States District Court for the Eastern District of Tennessee, alleging First Amendment retaliation and conspiracy for their roles in initiating the removal proceedings, along with a state law malicious prosecution claim. The district court granted summary judgment to the defendants on the federal claims, holding that she failed to show a conspiracy or retaliation connected to her protected speech, and declined to exercise jurisdiction over the state law claim.On appeal, the United States Court of Appeals for the Sixth Circuit held that, when a claim of First Amendment retaliation is based on the initiation of a civil action such as a quo warranto petition, the plaintiff must show a lack of probable cause for that action. The court concluded that probable cause existed to support the quo warranto petition, as there were reasonable grounds to doubt the official’s residency. Therefore, the court affirmed summary judgment for the defendants and found no abuse of discretion in the district court’s handling of discovery deadlines. View "Amacher v. City of Tullahoma" on Justia Law