Justia Constitutional Law Opinion Summaries

A native and citizen of Honduras entered the United States without admission or parole and was taken into custody. Shortly after her release, the Department of Homeland Security (DHS) served her with a Notice to Appear, written in English, which informed her of the obligation to notify the immigration court of any change of address. She provided an address in Hanford, California, which was used for subsequent correspondence. After moving to a new address without notifying the immigration court, she missed a scheduled removal hearing, and was ordered removed in absentia.The Immigration Judge (IJ) denied her motion to reopen the removal proceedings, finding that she had received proper notice by mail to her last known address. Her subsequent motion to reconsider was also denied; the IJ found she had constructive notice because the Notice to Appear was sent to her last provided address, and that she had been properly informed of her obligation to update her address. On appeal, the Board of Immigration Appeals (BIA) upheld the IJ’s decisions, concluding that jurisdiction was not impacted by the allegedly defective Notice to Appear, and that mailing the Notice of Hearing to her last provided address was sufficient under the applicable statutory and Supreme Court precedent.On review, the United States Court of Appeals for the Ninth Circuit held that DHS is not constitutionally required to provide a translation of the entirety of a Notice to Appear—including the obligation to update an address—in an alien’s native language. The court found that English-language notices are generally sufficient to satisfy due process because they are reasonably calculated to inform recipients of their obligations. The petition for review was denied. View "URQUIA-YANEZ V. BLANCHE" on Justia Law

The case concerns the process by which a proposed constitutional amendment, authorizing partisan gerrymandering of congressional districts in Virginia, was submitted to the voters. The General Assembly approved the proposed amendment during a disputed special session in October 2025, after voting in the general election for the House of Delegates had already begun. Approximately 1.3 million votes had been cast before the General Assembly’s first vote on the amendment. The General Assembly then approved the proposal again in the 2026 regular session, and the amendment was put to a popular vote, ultimately passing by a narrow margin. The new map, contingent on the amendment’s approval, would have significantly shifted the partisan balance of Virginia’s congressional delegation.The Circuit Court of Tazewell County reviewed challenges to the constitutional amendment process, focusing on whether the requirements of Article XII, Section 1 of the Virginia Constitution, which governs the procedure for amending the state constitution, were properly followed. The central issue was whether the intervening general election required by the Constitution occurred after the General Assembly’s first vote on the amendment but before the second, thus giving voters the intended opportunity to influence the process.The Supreme Court of Virginia held that the legislative process used to advance the proposed amendment violated Article XII, Section 1 of the Virginia Constitution because the first legislative vote occurred after voting in the general election had already begun. The court concluded that the “general election” includes the entire period when votes are cast, not just Election Day, and strict compliance with the constitutionally mandated procedure is required. As a result, the referendum and the amendment were declared null and void. The court affirmed that the existing, nonpartisan congressional maps remain in effect for the upcoming elections. View "Scott v. McDougle" on Justia Law

The case centers on an economic development agreement between a city and county in Texas and a private foundation, aimed at fostering the construction of a retail shopping center anchored by a Gander Mountain store. The city and county pledged portions of future sales-tax revenues to the foundation, which used the funds to secure a construction loan for the facility. The agreements required that the tax proceeds be used solely to repay the construction debt. Gander Mountain operated for eleven years before closing its store, but the shopping center continued to generate significant economic activity and tax revenue, with the former anchor tenant’s space later occupied by another retailer.After Gander Mountain’s closure in 2015, the city and county ceased payments, claiming the public purpose of the grants had ended. They sought declaratory relief in the District Court of Navarro County, arguing that continued payments would be unconstitutional under the Texas Constitution’s Gift Clauses. The district court granted summary judgment to the city and county, ruling that the closure ended the public purpose and that the agreements lacked sufficient controls to ensure public purposes were met. The Court of Appeals for the Tenth District of Texas affirmed, holding that the economic development grants remained subject to the Gift Clauses and that the agreements failed to satisfy their requirements.The Supreme Court of Texas reviewed the case and held that economic-development grants authorized by article III, section 52-a of the Texas Constitution remain subject to the Gift Clauses. The Court determined that the lower courts erred by focusing narrowly on the operation of a specific store rather than the broader public purpose of economic development. It held that the agreements likely satisfied the constitutional requirements of public purpose, consideration, and adequate controls, and that summary judgment was improper. The Supreme Court of Texas reversed the lower courts’ judgments and remanded the case for further proceedings. View "JPMORGAN CHASE BANK, N.A. v. CITY OF CORSICANA AND NAVARRO COUNTY" on Justia Law

RJR Vapor, a company selling oral nicotine products in Texas, including VELO nicotine pouches, sought a tax refund after paying the Texas Cigars and Tobacco Products Tax under protest. VELO pouches consist of a porous material filled with a dry mixture of microcrystalline cellulose (a plant-based substance) and nicotine isolate, along with flavorings and preservatives. Unlike traditional tobacco pouches, which use ground tobacco leaf, VELO uses non-tobacco plant matter combined with nicotine extracted from tobacco leaves. The key legal question was whether these pouches qualify as “tobacco products” under Texas Tax Code, specifically as products “made of tobacco or a tobacco substitute.”After RJR paid the tax and filed suit, the trial court ruled in RJR’s favor, finding that VELO pouches are not taxable tobacco products and granting a refund. The trial court also found the statutory phrase “made of tobacco or a tobacco substitute” unconstitutional, both facially and as applied. The Court of Appeals for the Third District of Texas affirmed, agreeing that VELO pouches are neither “made of tobacco” nor “made of . . . a tobacco substitute,” and declined to reach RJR’s constitutional challenges, considering them moot because the products were not taxable.The Supreme Court of Texas reviewed the case and reversed the decision of the court of appeals. The Supreme Court held that VELO pouches are “made of . . . a tobacco substitute” because their primary ingredients—plant matter and nicotine—take the place and function of tobacco in products expressly taxed by the statute, such as snus or moist snuff. The Court rendered judgment that VELO pouches are taxable tobacco products under Texas law and remanded the case to the court of appeals to consider RJR’s equal-and-uniform constitutional challenge to the tax. View "HANCOCK v. RJR VAPOR CO., LLC" on Justia Law

A catastrophic storm in March 2016 caused unprecedented rainfall in the Sabine River basin, leading the operators of the Toledo Bend Dam—jointly managed by the Sabine River Authority of Texas and the Sabine River Authority, State of Louisiana—to open nine spillway gates. This action released significant amounts of water into the Sabine River over several weeks. Downriver landowners experienced extensive flooding and property damage. More than 700 landowners brought suit, alleging that the dam operators’ actions constituted a compensable taking of their property under the Fifth Amendment.The case began in the United States District Court for the Eastern District of Texas, where the defendants raised several defenses, including sovereign immunity, which was litigated and ultimately denied. Discovery disputes arose over the admissibility and timeliness of the plaintiffs’ expert affidavits and reports, which were found to rely heavily on an untested graduate thesis. The magistrate judge struck the challenged affidavits as untimely, and the plaintiffs did not object. Later, the district court granted summary judgment for the defendants, finding the plaintiffs had not produced sufficient admissible evidence to create a genuine dispute of material fact as to whether the dam’s operation caused the flooding, nor that a taking had occurred. The court also found the necessity doctrine might shield the defendants but did not decide the case on that ground.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the lower court’s decisions. It held that the district court did not abuse its discretion in excluding the untimely expert affidavits. Affirming summary judgment, the Fifth Circuit found that the plaintiffs had failed to present sufficient evidence of causation—specifically, that the dam’s operation, rather than the unprecedented storm itself, caused additional flooding beyond what would have occurred without the dam. The judgment of the district court was affirmed. View "Bonin v. Sabine River Authority" on Justia Law

The case concerns a police shooting in Seattle involving an officer and an individual named Shaun Fuhr. Fuhr threatened the mother of his infant daughter, fired a handgun in a public park, and then fled on foot with the child. Despite police commands to stop and a search involving a helicopter and SWAT officers, Fuhr continued to evade authorities for over thirty minutes while still holding his daughter. Eventually, SWAT officers, including Noah Zech, encountered Fuhr in a residential alley. As Fuhr appeared from behind bushes, advancing with the infant in his arms, Zech fired a single shot, killing Fuhr. The baby was unharmed, and Fuhr’s gun was later found nearby.Prior to this appeal, the United States District Court for the Western District of Washington granted summary judgment in favor of Zech and the City of Seattle. The district court held that Zech was entitled to qualified immunity on the excessive force claim under 42 U.S.C. § 1983 and dismissed the plaintiffs’ other claims, including negligence, wrongful death, and claims under state law. The plaintiffs appealed these rulings.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The Ninth Circuit held that, even when viewing the facts in the light most favorable to the plaintiffs, Zech did not violate clearly established law by shooting Fuhr under these circumstances. The court found no precedent clearly establishing a Fourth Amendment violation in a case involving a fleeing, possibly armed suspect holding a child after firing a gun and ignoring police commands. Accordingly, Zech was entitled to qualified immunity. The court also affirmed the dismissal of the plaintiffs’ remaining claims. View "FUHR V. CITY OF SEATTLE" on Justia Law

Three defendants, including the petitioner, were convicted in California state court for the robbery, kidnapping, and murder of a victim who was forced into a car trunk and subsequently killed. The petitioner, who was 18 at the time, confessed to police after being advised of his Miranda rights. At trial, the judge made several offhand, jocular, and at times insensitive comments, including remarks touching on race, gender, and capital punishment. The petitioner did not testify and raised claims at various points about judicial bias and misconduct, an involuntary confession, invalid Miranda waiver, and the improper admission of codefendants’ statements.After conviction and a death sentence, the petitioner’s direct appeal and two state habeas petitions were denied by the California Supreme Court, which rejected his claims both on the merits and on procedural grounds. The petitioner then filed a federal habeas petition in the United States District Court for the Central District of California, which denied relief. The district court also denied a request to expand the certificate of appealability to include claims regarding his confession and the admission of codefendants’ statements.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of habeas relief. The court held that the petitioner’s claims of judicial bias and misconduct failed because the trial judge’s comments, while inappropriate, did not demonstrate actual bias or render the trial fundamentally unfair under the Due Process Clause. The Ninth Circuit also declined to expand the certificate of appealability, finding that the petitioner’s claims regarding the voluntariness of his confession, the validity of his Miranda waiver, and any Bruton violation were not debatable among reasonable jurists and that any error was harmless in light of overwhelming evidence of guilt. The denial of habeas relief was affirmed. View "BURNEY V. BROOMFIELD" on Justia Law

This case involves challenges to the ballot title certified by the Oregon Attorney General for Initiative Petition 64 (2026), which proposes to add a provision to the Oregon Constitution. Under current law, individuals charged with crimes who are found unfit to aid and assist in their defense cannot proceed to trial and may be committed for restoration of fitness, but such commitment is limited to a maximum period based on the seriousness of the charge. The proposed measure would require these individuals, if found to require a hospital level of care due to public safety concerns, to be committed to a secure state-funded facility until a court determines they are fit or no longer require such care—removing the current statutory limit on the duration of their commitment.After the Attorney General certified the ballot title, petitioners—both as Oregon electors and as the chief petitioner for IP 64—filed timely challenges. They argued that the caption and the “yes” result statement of the certified ballot title were inaccurate and misleading. Specifically, they contended that the language incorrectly stated that such defendants “cannot be prosecuted,” when, in reality, prosecution is merely paused during the restoration process, and that the ballot title failed to inform voters that the measure would eliminate statutory time limits on commitment, allowing for potentially indefinite detention.The Supreme Court of the State of Oregon agreed with the petitioners. The court found that the caption and the “yes” result statement did not substantially comply with the requirements of ORS 250.035(2), as they mischaracterized the status of prosecution and failed to identify a major effect of the measure. The court referred the ballot title back to the Attorney General for modification. View "Paden v. Rayfield" on Justia Law

The case involves an altercation in the lobby of an apartment building, where Darryl Brown, an off-duty corrections officer, shot and killed Vonde Cabbagestalk, his daughter’s boyfriend. During a heated argument, Brown drew his firearm. Witness testimony established that Cabbagestalk became physically aggressive and swung at Brown, after which Brown pulled out his gun and held it at his waist. Cabbagestalk made a threatening remark and attempted to swipe at the gun, at which point Brown fired, resulting in Cabbagestalk’s death.Brown was tried in the New York Supreme Court, Bronx County, and convicted of first-degree manslaughter. The trial judge declined to instruct the jury on the justification (self-defense) defense, finding the evidence insufficient to warrant the charge. On direct appeal, a divided Appellate Division, First Department, vacated the conviction, reasoning that the evidence could support Brown’s belief that he needed to use deadly force. However, the New York Court of Appeals unanimously reversed and reinstated the conviction, holding that Brown’s act of drawing his gun made him the initial aggressor under New York law, disqualifying him from the justification defense. The court found no evidence that Brown withdrew from the encounter or that Cabbagestalk threatened deadly force before Brown drew his weapon.Brown sought federal habeas relief in the United States District Court for the Southern District of New York, arguing that denial of a justification instruction violated his federal due process rights. The district court denied relief, agreeing with the New York Court of Appeals. The United States Court of Appeals for the Second Circuit affirmed, holding that Brown was not entitled to a justification instruction under New York law and, consequently, there was no constitutional violation justifying habeas relief. View "Brown v. James" on Justia Law

The case concerns a defendant indicted in two separate Superior Court proceedings for offenses including a violent home invasion and multiple firearm-related charges. The defendant was found incompetent to stand trial and unlikely to attain competency, based on several forensic psychological evaluations. While awaiting trial, the defendant was also charged with additional drug and firearm offenses in the Boston Municipal Court, which resulted in revocation of his bail in the Superior Court cases and the imposition of new cash bail. Following the expiration of the bail revocation, cash bail was set in the Superior Court cases, which the defendant could not post, resulting in his continued detention.After the Boston Municipal Court case was dismissed, the defendant remained detained solely due to his inability to post bail in the Superior Court cases. He petitioned a single justice of the Supreme Judicial Court for extraordinary relief, arguing that his continued detention, given his incompetency and unlikelihood of restoration, violated his substantive due process rights under the Massachusetts Declaration of Rights and the Fourteenth Amendment to the United States Constitution. The single justice denied relief, finding that the defendant’s detention had not yet exceeded a reasonable period necessary to determine the likelihood of competency restoration, and that the totality of circumstances—including the seriousness of the charges, time elapsed since prior evaluations, and the Commonwealth’s stated intention to seek a new evaluation—did not amount to a due process violation.On appeal, the Supreme Judicial Court of Massachusetts held that the framework articulated in Abbott A. v. Commonwealth, 458 Mass. 24 (2010), which limits the detention of incompetent defendants to the period necessary to assess the probability of restoring competency, applies regardless of whether detention arises from a finding of dangerousness or inability to post bail. The Court affirmed the judgment, concluding that no due process violation had occurred. View "In the Matter of an Impounded Case" on Justia Law