Justia Constitutional Law Opinion Summaries

Texas Tobacco Barn operated a laboratory and retail shop in Lubbock, Texas, manufacturing and selling e-liquids and vape products. After applying for authorization to sell over 2,200 vape products, including Barn Brewed Beetle Juice e-liquids, the FDA denied approval and warned that these products were considered “adulterated” and “misbranded.” Despite assurances from Texas Tobacco Barn that it would cease sales, a subsequent FDA inspection revealed continued sale of unauthorized products. The FDA initiated proceedings seeking a civil penalty of $19,192 for violations.The enforcement action began with an administrative hearing before an HHS administrative law judge (ALJ), who reviewed evidence including inspection photos and testimony from an FDA inspector. Texas Tobacco Barn admitted that the e-liquids lacked FDA authorization but disputed the inspector’s findings and challenged the FDA’s regulatory authority. The ALJ concluded that the FDA proved its case by a preponderance of the evidence and imposed the civil penalty. On appeal, the HHS Departmental Appeals Board affirmed the ALJ’s ruling, agreeing the ALJ lacked jurisdiction to address constitutional challenges but offering advisory comments on those defenses.Reviewing the agency’s final decision, the United States Court of Appeals for the Fifth Circuit considered Texas Tobacco Barn’s statutory and constitutional arguments. The court rejected the nondelegation challenge, citing its own precedent and Supreme Court guidance clarifying FDA’s explicit authority to regulate vape products. However, the Fifth Circuit held that the administrative process violated Texas Tobacco Barn’s Seventh Amendment right to a jury trial. The court determined that civil penalties for FDCA violations are legal in nature and do not fall under the public-rights exception that would permit agency adjudication without a jury. As a result, the Fifth Circuit granted the petition and vacated the agency’s decision. View "Texas Tobacco Barn v. HHS" on Justia Law

The defendant, a seventy-year-old man with a long history of alcohol use, was stopped by law enforcement after driving erratically and making multiple traffic violations. He was observed to be impaired, failed a field sobriety test, and later refused breath and blood tests, leading to a warrant for a blood draw that revealed a blood alcohol content over three times the legal limit. Investigation revealed he was driving with a suspended license and had three prior DUI convictions. He was charged with felony DUI (fourth or subsequent offense) and driving while suspended, but the latter charge was dismissed in exchange for his guilty plea to the DUI charge.The Montana Sixteenth Judicial District Court sentenced him to thirteen months with the Department of Corrections, recommended placement in an alcohol treatment program, and imposed a consecutive four-year suspended sentence. The court also imposed the statutory minimum fine of $5,000 but suspended half of it due to the defendant’s financial circumstances. The defendant appealed the imposition of the fine, arguing that the statute mandating the fine was unconstitutional based on recent case law. He maintained that the fine should not have been imposed without proper consideration of his ability to pay.The Supreme Court of the State of Montana held that the defendant did not waive his right to appellate review of the fine by agreeing to it in the plea agreement, as subsequent case law developments questioned the constitutionality of the statute. The Court reaffirmed that the sentencing court must impose the mandatory fine under the statute, then determine the defendant’s ability to pay, and may suspend any portion of the fine accordingly. The Supreme Court affirmed the imposition of the $5,000 fine but vacated the portion of the judgment relating to the fine and remanded to the District Court for explicit findings on the defendant’s ability to pay before determining how much of the fine should be suspended. View "State v. Hagberg" on Justia Law

A woman was the primary caregiver for her friend, residing in her friend’s condominium for several years. After the friend passed away, ownership of the condo transferred to a living trust, and the caregiver became trustee. She continued living in the condo for a month to recover from illness and remove her belongings. The friend’s nephew contacted local police, claiming the right to evict her, and presented officers with a superseded will listing him as a beneficiary but not mentioning the condo. The officers accompanied the nephew to the condo, told the caregiver she had ten minutes to leave, threatened her with arrest, pushed her out, and took her key.The United States District Court for the Southern District of Ohio reviewed the case after the caregiver sued various parties, alleging Fourth Amendment violations. The court granted summary judgment to some defendants but denied it for the officers, reasoning that the caregiver, as trustee, held a possessory interest in the condo, and the officers’ actions constituted active participation in an eviction without proper legal authority. The court relied on Sixth Circuit precedent to find the seizure unreasonable and the right clearly established.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that the caregiver had a possessory interest in the condo at the time of the eviction, the officers actively participated in the eviction, and their conduct was unreasonable under the Fourth Amendment because there was no court order or exigent circumstances justifying the seizure. The court further held that existing precedent clearly established the unlawfulness of the officers’ actions. The Sixth Circuit affirmed the district court’s denial of summary judgment, leaving the officers subject to further proceedings. View "Bender v. Village of Mariemont" on Justia Law

After the 2020 mayoral election in Maricao, Puerto Rico, the Popular Democratic Party candidate, Wilfredo Ruiz-Feliciano, assumed office, replacing the New Progressive Party incumbent. Odette López Collazo, a longstanding NPP member who had served as Internal Auditor since 1994, was not reappointed by the new mayor. López Collazo alleged that her non-reappointment was due solely to her political affiliation and constituted political discrimination in violation of her First and Fourteenth Amendment rights. She also asserted related claims against other municipal officials regarding the failure to pay out her accrued leave, but only the claim against Ruiz-Feliciano for political discrimination remained at issue in this appeal.The United States District Court for the District of Puerto Rico granted summary judgment in favor of Ruiz-Feliciano. The court concluded that First Amendment protections against political discrimination did not apply to a decision not to hire or reappoint, and further reasoned that because the Internal Auditor position was a “trust” position under Puerto Rico law, the mayor could hire and fire at will, including for political reasons. López Collazo moved for reconsideration, which was denied, and then sought partial final judgment under Rule 54(b) to appeal. After resolving procedural questions regarding finality, all claims but the political discrimination claim against Ruiz-Feliciano were dismissed with prejudice, and the appeal proceeded.The United States Court of Appeals for the First Circuit reviewed the district court’s grant of summary judgment de novo. The Court of Appeals held that First Amendment protections do apply to a failure to hire or reappoint a public employee, and that legislative classification of a position as a “trust” position is not dispositive in determining whether political affiliation is an appropriate requirement. The appellate court vacated the district court’s summary judgment and remanded for further proceedings. View "Lopez Collazo v. Ruiz-Feliciano" on Justia Law

A journalist with over twenty-five years of experience covering the Utah Legislature previously received media credentials while working for established news organizations. After founding an independent news outlet, he applied for a media credential under a new policy that categorically excluded bloggers, independent media, and freelance journalists from receiving credentials. This exclusion prevented him from accessing restricted areas and events within the Capitol that were available only to credentialed journalists, limiting his ability to gather news directly from legislative press conferences and availabilities.The plaintiff filed suit in the United States District Court for the District of Utah against legislative officials, alleging that the credentialing policy was unconstitutional as both facial and as-applied viewpoint discrimination under the First Amendment, along with claims of retaliation, prior restraint, and vagueness. The district court dismissed all claims, including denying a preliminary injunction as moot. The court reasoned, in part, that there was no protected speech implicated by the policy and that the plaintiff’s continued reporting without a credential undercut the retaliation claim.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the district court erred in dismissing both the facial and as-applied viewpoint discrimination claims. The appellate court found that the plaintiff plausibly alleged denial of access based on his viewpoint and that the exclusion from a government-created forum for journalists implicated protected speech. The court remanded those claims for further proceedings. The Tenth Circuit affirmed the district court’s dismissal of the retaliation, prior restraint, and vagueness claims, finding no plausible allegation of chilling effect and determining the policy did not regulate expression sufficiently to support a prior restraint or vagueness challenge. View "Utah Political Watch v. Musselman" on Justia Law

Several parents, some acting on behalf of their children, challenged a presidential executive order issued in January 2025. The order declared that children born in the United States to parents who were unlawfully or temporarily present would not be considered “subject to the jurisdiction” of the United States, and therefore would not be entitled to citizenship under the Fourteenth Amendment or the Immigration and Nationality Act. The plaintiffs argued that this order violated both the Constitution and the INA, as it denied citizenship to children based solely on the immigration status of their parents at the time of birth.The United States District Court for the District of New Hampshire reviewed the case and agreed with the plaintiffs. It provisionally certified a nationwide class of children affected by the order and issued a preliminary injunction, blocking enforcement of the executive order. The government appealed, and the Supreme Court of the United States granted certiorari before judgment from the United States Court of Appeals for the First Circuit.The Supreme Court held that children born in the United States to parents who are unlawfully or temporarily present are “subject to the jurisdiction” of the United States, and are entitled to citizenship at birth under the Fourteenth Amendment’s Citizenship Clause. The Court based its holding on the historical understanding of citizenship rooted in the English common law, the repudiation of Dred Scott v. Sandford, and the precedent established in United States v. Wong Kim Ark. The Court affirmed the judgment of the District Court, upholding birthright citizenship for these children. View "Trump v. Barbara" on Justia Law

A group of candidates and political party committees, including then-Senate candidate JD Vance and various Republican campaign committees, challenged federal limits on coordinated campaign expenditures by political parties under the Federal Election Campaign Act (FECA). These limits restrict the amount a party can spend in direct coordination with a candidate’s campaign. Plaintiffs argued that the restrictions violate the First Amendment, especially given modern developments in campaign finance law and enforcement tools such as earmarking and disclosure requirements. JD Vance maintained standing to challenge the law, as he had an active Statement of Candidacy and a campaign committee, despite later becoming Vice President.The case was first reviewed by the en banc United States Court of Appeals for the Sixth Circuit, which upheld FECA’s coordinated-expenditure limits. The Sixth Circuit relied primarily on the Supreme Court’s 2001 precedent, Federal Election Commission v. Colorado Republican Federal Campaign Committee (Colorado II), which had previously sustained these limits against First Amendment challenges. However, several Sixth Circuit judges questioned whether Colorado II remained good law in light of more recent Supreme Court decisions, including McCutcheon v. Federal Election Commission and Federal Election Commission v. Ted Cruz for Senate.The Supreme Court of the United States granted certiorari and ultimately reversed the Sixth Circuit. The Court held that FECA’s limits on political-party coordinated expenditures violate the First Amendment. Applying rigorous scrutiny, the Court determined that the limits are not necessary, narrowly tailored, or proportionate to the government’s interest in preventing circumvention of candidate contribution limits, especially given the effectiveness of existing earmarking rules and disclosure laws. The Court explicitly overruled Colorado II, concluding that subsequent precedents have rendered it obsolete. The judgment of the Sixth Circuit was reversed and the case remanded for further proceedings. View "National Republican Senatorial Committee v. Federal Election Commission" on Justia Law

A state law in West Virginia prohibited male students, as determined by biological sex, from participating on female sports teams. A student who is a biological male but identifies as female and has taken puberty blockers and hormones sought to participate on the girls’ cross-country and track-and-field teams and brought suit against West Virginia officials, alleging violations of Title IX and the Equal Protection Clause. Similarly, Idaho passed a law barring male students from female sports teams; a transgender woman who is a biological male but identifies as female and had taken hormones challenged Idaho’s law after trying out for collegiate women’s sports. Both states justified their laws by referencing inherent physical differences between the sexes and concerns for safety and competitive fairness in women’s sports.The United States District Court for the Southern District of West Virginia granted summary judgment for the state, finding no violation of Title IX or the Equal Protection Clause. The United States Court of Appeals for the Fourth Circuit reversed the ruling on the Title IX claim and remanded for further factual findings on the Equal Protection claim. Meanwhile, in Idaho, the United States District Court for the District of Idaho issued a preliminary injunction against enforcement of the statute; the United States Court of Appeals for the Ninth Circuit affirmed that decision, finding a likely violation of the Equal Protection Clause.The Supreme Court of the United States reversed both appellate court decisions. It held that Title IX permits schools to maintain separate men’s and women’s sports teams determined by biological sex and does not require exceptions for transgender athletes, regardless of puberty blockers or hormone use. The Court further held that the Equal Protection Clause does not bar states from limiting female sports teams to biological females, finding the sex-based classification substantially related to important government interests in safety and competitive fairness. The cases were remanded for further proceedings consistent with this opinion. View "West Virginia v. B. P. J." on Justia Law

Three property owners in Oregon alleged that the federal government committed a taking of their property rights under the Fifth Amendment when the Surface Transportation Board (STB) issued a Notice of Interim Trail Use or Abandonment (NITU) involving a railroad corridor that crossed their properties. The corridor, previously used for freight trains by the Port of Tillamook Bay Railroad (POTB), was also leased to the Oregon Coast Scenic Railroad (OCSR), which operated a scenic passenger-excursion service both before and after the NITU was issued. After severe storm damage in 2007, POTB ceased freight operations, but OCSR continued using the corridor under its lease, which extended at least until 2026.The United States Court of Federal Claims previously found that a taking had occurred due to the issuance of the NITU. The case then proceeded to a valuation phase to determine just compensation. The Court of Federal Claims ruled that the property owners did not meet their burden to prove that the NITU caused a reduction in the fair market value of their land. The court found that the “before” condition for valuation properly included OCSR’s ongoing operations, and that the property owners failed to show an actual market value loss resulting from the NITU and the new trail-use easement.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Court of Federal Claims’ judgment. The Federal Circuit held that the “before” condition for compensation must reflect the ongoing encumbrance of the scenic railroad’s operations, as the lease and use by OCSR would have existed regardless of the NITU. The court also concluded that the property owners had not proven with reasonable certainty any diminution in market value attributable to the NITU or the trail easement, and thus were not entitled to compensation. The judgment was affirmed. View "LOVERIDGE v. US " on Justia Law

Several proposed initiatives regarding Colorado’s congressional redistricting were submitted for review by the state’s Title Board. Initiative #241 sought to replace the Colorado constitutional independent congressional redistricting commission with an identical commission established by statute, but made its effectiveness contingent on the passage of Initiative #242. Initiative #242, in turn, proposed to create a new temporary congressional district map for the 2028 and 2030 elections, and would only take effect if Initiative #241 was also adopted. Initiative #328, which was similar in structure to #242 but provided a different map, was likewise conditioned on the passage of Initiative #241.The Title Board, after initial hearings, determined by unanimous vote that both Initiative #241 and #242 each contained a single subject and set their respective titles. Motions for rehearing were denied by a two-to-one vote. Petitioner Robert Balink challenged these decisions before the Colorado Supreme Court, arguing that conditioning the effectiveness of each measure on the passage of the other violated the constitutional single subject rule. For Initiative #328, the Title Board declined to set a title, finding that it did not constitute a single subject because it was expressly contingent on the passage of a separate measure, and denied a rehearing.On review, the Supreme Court of Colorado held that an initiative violates the single subject requirement of article V, section 1(5.5) of the Colorado Constitution and section 1-40-106.5, C.R.S., when its effectiveness is conditioned on the passage of a separate initiative. The court reasoned that such interdependence creates multiple subjects, as each measure’s effect is not properly and necessarily connected to the other. As a result, the court reversed the Title Board’s decision to set titles for Initiatives #241 and #242 and affirmed the Board’s refusal to set a title for Initiative #328. View "Balink v. Nathan" on Justia Law