Justia Constitutional Law Opinion Summaries

Stephen and Deborah Gmeiner owned waterfront property in Michigan and sought a permit to construct a walking path through wetlands to the lake. The Michigan Department of Environment, Great Lakes, and Energy initially denied their permit application, citing environmental concerns and suggesting a boardwalk as a less damaging alternative. The Gmeiners appealed, and an administrative law judge found that township ordinances made a boardwalk infeasible without constructing a home, so the permit was granted. When the Department issued the permit, it included an indemnification clause requiring the Gmeiners to hold the State harmless for claims arising from their actions in connection with the permit. The Gmeiners objected, arguing that the clause was unauthorized under Michigan law and imposed an unconstitutional condition on their First Amendment right to petition by potentially barring lawsuits against the State for its own misconduct.The United States District Court for the Western District of Michigan denied the Gmeiners’ request for a preliminary injunction and dismissed their complaint. The court interpreted the indemnification clause narrowly, holding that it only required indemnification for claims resulting from the Gmeiners’ own actions, not for state misconduct. It concluded that the clause did not violate the First Amendment Petition Clause and that sovereign immunity barred the state-law claim in federal court.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The court held that, even assuming the unconstitutional-conditions doctrine under the Takings Clause applied to the Petition Clause, the indemnification clause was limited to claims arising from the Gmeiners’ own conduct and did not bar them from suing the State for its own misconduct. The court also held that Michigan’s sovereign immunity barred the Gmeiners from seeking state-law relief against state officials in federal court. The district court’s judgment was affirmed. View "Gmeiner v. Kent" on Justia Law

A residential subdivision in Black Hawk, South Dakota, known as Hideaway Hills, was constructed atop land with a history of both underground and surface gypsum mining. The State of South Dakota, through the South Dakota Cement Plant Commission, purchased the property, conducted surface mining, and reclaimed the land to pasture before selling it at public auction, while retaining subsurface mineral rights. Subsequent private owners and developers, aware of prior mining activity, developed the land into residential lots. Years later, residents began experiencing foundational problems and sinkholes, which culminated in a significant sinkhole event in 2020, leading to evacuation and property devaluation.After previous lawsuits against various parties were dismissed, a class action was brought in the Circuit Court of the Fourth Judicial Circuit, Meade County, against the State and related entities. The plaintiffs alleged inverse condemnation, asserting that the State’s reclamation and retention of subsurface rights amounted to a taking or damaging of private property for public use under the South Dakota Constitution. The circuit court granted summary judgment to the State, holding that the plaintiffs’ claims were, in essence, tort claims barred by sovereign immunity.On appeal, the Supreme Court of the State of South Dakota affirmed the circuit court’s decision. The Supreme Court held that the plaintiffs failed to establish a viable inverse condemnation claim because the alleged governmental actions occurred while the State owned the property, and thus did not implicate “private property.” The Court further found that the State’s activities were not for “public use” within the meaning of the state constitution, as the retained mineral rights did not confer a public right of use. The Supreme Court affirmed summary judgment for the State. View "Morse v. State" on Justia Law

Police investigating a fatal fentanyl overdose in Leavenworth, Kansas, suspected that a supplier was distributing drugs from a woman’s residence. Over several weeks, law enforcement surveilled the home and a related apartment, observing frequent short visits, repeated appearances by suspected dealers, and traffic consistent with narcotics sales. A trash pull at the residence yielded evidence of drug activity, including baggies with residue testing positive for controlled substances, a handwritten ledger, and mail addressed to the resident. Additional evidence included drug paraphernalia found in the resident’s car and information linking associates to drug distribution and overdoses. Based on these observations, an officer compiled an affidavit and obtained a search warrant, leading to a search that uncovered substantial drug evidence and resulted in criminal charges.In the Leavenworth District Court, the defendant moved to suppress the evidence, arguing that the affidavit failed to show probable cause. The district court agreed, finding the affidavit’s details—especially those about the trash pull and vehicle search—insufficient to connect the alleged criminal activity to the residence. The court also found that much of the supporting information was uncorroborated or indicative of innocent conduct. The State appealed, and the Kansas Court of Appeals agreed the affidavit was deficient, but held that the evidence was admissible under the good-faith exception.The Supreme Court of the State of Kansas reviewed the case and concluded that both the district court and the Court of Appeals used an incorrect legal standard by analyzing the affidavit’s facts in isolation rather than considering the totality of the circumstances. The Supreme Court held that the affidavit provided the issuing judge with a substantial basis for finding probable cause. The court affirmed the reversal of the suppression order but on different grounds, and remanded the case, vacating the Court of Appeals’ discussion of the good-faith exception. View "State v. Gardner " on Justia Law

Texas law allows certain students, including those who are not lawfully present in the United States, to qualify for in-state tuition rates at public colleges if they meet residency requirements. The Texas Education Code provisions in question—sections 54.051(m) and 54.052(a)—permit illegal aliens who establish residency in Texas to pay discounted tuition, while out-of-state U.S. citizens must pay higher rates. The United States brought suit against Texas, alleging that these provisions violate federal law, specifically 8 U.S.C. § 1623(a), which bars states from granting postsecondary education benefits to illegal aliens based on residency unless all U.S. citizens and nationals are eligible for the same benefit regardless of residency.The United States District Court for the Northern District of Texas approved a consent judgment permanently enjoining Texas from enforcing the challenged provisions. After judgment, advocacy groups, a community college, and a student moved to intervene and sought to vacate or alter the judgment, arguing the provisions were not preempted by federal law. The district court denied intervention, reasoning it was legally futile because 8 U.S.C. § 1623(a) expressly preempts the Texas statutes.The United States Court of Appeals for the Fifth Circuit reviewed the denial de novo and affirmed. The court held that intervention was futile because federal law expressly preempts the Texas provisions, barring states from conferring in-state tuition benefits to illegal aliens based on residency unless all U.S. citizens and nationals may receive the same benefit without regard to residency. The court also dismissed the remaining claims for lack of appellate jurisdiction, as the movants were not parties to the case and therefore had no right to appeal the consent judgment. View "USA v. Texas" on Justia Law

A man was investigated after Google and Yahoo flagged several of his email accounts for sending and storing what appeared to be child pornography. Both companies identified the user through information like a shared recovery phone number, birthdate, and selfies associated with the accounts. Yahoo manually reviewed and confirmed the images as child pornography before reporting them to the National Center for Missing and Exploited Children (NCMEC). Google used both human review and a hash-value matching protocol, whereby a file’s unique digital fingerprint was compared against a database of previously identified illegal images. One of the files in the defendant’s account matched the hash of a known child pornography image. Law enforcement, after receiving tips from NCMEC, conducted warrantless searches and confirmed the illicit nature of the files, leading to search warrants for the defendant’s residence and devices, which yielded more incriminating evidence.The United States District Court for the Middle District of Florida denied the defendant’s motions to suppress the evidence (arguing a Fourth Amendment violation), to dismiss one of the charges on double jeopardy grounds, and to exclude certain evidence. The court also rejected his arguments concerning the admissibility of defense evidence, the sufficiency of the evidence, and the jury instructions. The defendant was convicted by a jury on both distribution and possession charges and given an enhanced sentence based on a finding of a pattern of activity involving abuse or exploitation. His subsequent motions for psychological evaluation and sentencing continuance were also denied.On appeal, the United States Court of Appeals for the Eleventh Circuit held that Google’s use of hash-value matching constituted a valid private search under the Fourth Amendment, so the government’s warrantless review did not violate the defendant’s rights. The court also held that possession and distribution of child pornography are separate offenses for double jeopardy purposes. The appellate court affirmed all district court decisions except for the application of a pattern-of-activity sentencing enhancement, which it found improper; it vacated the sentence and remanded for resentencing. View "USA v. Brillhart" on Justia Law

In response to a mass shooting in Illinois, the state enacted the Protect Illinois Communities Act, which criminalized the manufacture, sale, and possession of assault weapons and large-capacity magazines, with a grandfather clause allowing current legal owners to retain these items if they completed a registration process. Plaintiffs, including individuals and organizations, challenged the Act in federal court, arguing it violated the Second Amendment. The district court for the Southern District of Illinois consolidated four related cases and, after a bench trial, found that much of the Act violated the Second Amendment, concluding that its main provisions were not severable and enjoining the enforcement of the entire Act.Prior to this, at the preliminary injunction stage, the plaintiffs had received relief, but similar challenges in the Northern District of Illinois had been denied. The Seventh Circuit consolidated appeals from all these cases and previously held in Bevis v. City of Naperville that the plaintiffs were unlikely to prevail on the merits under the Supreme Court’s framework from New York State Rifle & Pistol Association v. Bruen. After further factual development and trial, the district court entered a permanent injunction against the Act, which the defendants appealed.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo on constitutional grounds. The court held that the Act’s restrictions on AR-15 rifles and thirty-round magazines are consistent with the nation’s historical tradition of firearms regulation. The court reasoned that legislatures have long imposed restrictions on particularly dangerous weapons, and Illinois’s law fits within this tradition. The court also held that the registration requirement was constitutional. The Seventh Circuit reversed the district court’s judgment and ordered the entry of judgment for the defendants, upholding the Act’s central restrictions. View "Barnett v Raoul" on Justia Law

In this case, federal drug enforcement agents received information suggesting that the defendant was involved in the distribution of large quantities of narcotics in Indiana. Following surveillance and a traffic stop that yielded evidence of drug activity, officers became concerned that the defendant was aware of their investigation. They installed a camera on a utility pole across the street from the defendant’s leased auto-repair shop without first obtaining a warrant. The property was surrounded by a six-foot fence, but it had significant gaps, including a thirty-foot-wide opening allowing vehicle and pedestrian access. The pole camera recorded activities on the property for approximately two weeks, capturing movements consistent with drug trafficking. Subsequent searches, supported by warrants, resulted in significant seizures of narcotics, firearms, and cash.The United States District Court for the Southern District of Indiana denied the defendant’s motion to suppress evidence obtained from the pole camera. The court held that the fence did not create a reasonable expectation of privacy in the observed activities because the gaps allowed visibility from the street. The court also found that the pole camera’s use was not a search requiring a warrant under prevailing precedent, and concluded that even without the camera footage, there was probable cause to support the search warrants. The court determined that, if necessary, the good-faith exception to the exclusionary rule would apply.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the use of the pole camera did not violate the Fourth Amendment. The court reasoned that the camera captured activities observable to passersby through the substantial gap in the fence, the technology was in common public use, and the officers were lawfully present. The court also emphasized that commercial properties receive less Fourth Amendment protection than residences. View "USA v Kendrick" on Justia Law

Jason Thomson was transported to a hospital in Green Bay, Wisconsin after suffering a seizure, where he later became agitated and aggressive toward hospital staff. Officers from the Green Bay Police Department responded, restrained Thomson—who repeatedly complained that he could not breathe—and placed him in a WRAP restraint device. Officers monitored his breathing and obtained a medical clearance from hospital staff before transporting him to jail. During transport and upon arrival at the jail, Thomson continued to state he could not breathe. At the jail, medical staff determined he could not be admitted and needed further hospital evaluation. Shortly after, Thomson suffered a cardiac arrhythmia and died.The Estate of Jason Thomson filed suit in the United States District Court for the Eastern District of Wisconsin, alleging that the officers used excessive force and failed to provide adequate medical care in violation of the Fourth Amendment, and asserting a failure-to-train claim against the City of Green Bay under Monell v. Department of Social Services of the City of New York. The district court granted summary judgment to the officers, the city, and Brown County, finding that the officers’ actions were objectively reasonable, that they did not violate Thomson’s rights, and that they were entitled to qualified immunity. The claims against Brown County and its officers, as well as a claim against a nurse, were subsequently resolved or dismissed.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The court held that no reasonable jury could find that the officers violated Thomson’s constitutional rights regarding medical care or excessive force. The court further held that the officers were entitled to qualified immunity, and, because no underlying constitutional violation was established, the Monell claim against the city also failed. The Seventh Circuit affirmed the judgment of the district court. View "Estate of Thomson v. Behn" on Justia Law

The case centers on the fatal shooting of a seventeen-year-old during a street altercation in Providence, Rhode Island. The defendant was accused of firing a gun at the victim as she approached a fight between her sister and the defendant’s sister. Witnesses saw the defendant shoot in the victim’s direction, after which she collapsed and later died at the hospital. The defendant was apprehended and charged with second-degree murder and two firearms offenses.At the initial trial in the Rhode Island Superior Court, the prosecution exercised a peremptory strike against the only African-American prospective juror. The trial court allowed the strike, accepting the prosecutor’s asserted concern about potential workplace repercussions for the juror. The jury, which had no African-American members, convicted the defendant on the main charges. On appeal, the Rhode Island Supreme Court upheld the conviction, finding the peremptory strike was based on race-neutral grounds. After a habeas petition was denied by the federal district court, the United States Court of Appeals for the First Circuit reversed, holding that the strike was not race-neutral and ordered the state courts to vacate the conviction unless a new trial was held.At the retrial, again only one African-American venireperson was present. The prosecution sought to remove this juror for cause and, when that was denied, exercised a peremptory challenge, citing the juror’s pending criminal cases and lack of candor. The trial justice ultimately allowed the peremptory challenge, and a jury again lacking African-Americans convicted the defendant. The defendant’s motion for a new trial was denied.On appeal, the Supreme Court of Rhode Island held that the trial court failed to properly conduct the third step of the Batson analysis, which requires a probing inquiry into whether the prosecutor’s race-neutral explanation was genuine or pretextual. The court concluded this failure constituted structural error and vacated the conviction, remanding the case for a new trial. View "State v. Porter" on Justia Law

After threatening his ex-wife and her nephew with what appeared to be a firearm while intoxicated, an individual left his home and fell asleep at a neighbor’s house. Police were alerted, and, believing him to be inside and armed, surrounded the residence with S.W.A.T. teams and other tactical units. Negotiators eventually reached him by phone, during which he threatened self-harm and was reported to have threatened the officers, though he denied threatening the officers directly. When he exited the house, police fired non-lethal projectiles after he refused commands to come off the porch, seriously injuring his arm. After briefly retreating indoors, he reemerged and was shot three more times with similar ammunition when he acted aggressively and shouted threats at the officers.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the officers and the City, holding that the plaintiff failed to show the police violated clearly established constitutional rights under the Fourth Amendment. The district court distinguished the facts of this case from prior circuit precedent, including Phillips v. Community Insurance Corp., and found that the officers’ actions did not clearly contravene established law.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment ruling de novo. The appellate court held that qualified immunity shielded the officers because no binding precedent placed the unconstitutionality of their specific actions beyond debate, given the circumstances—namely, threats involving firearms and knives and the plaintiff’s aggressive behavior. The court also noted that the plaintiff failed to articulate a viable claim against the City of Elgin. The Seventh Circuit therefore affirmed the district court’s grant of summary judgment for all defendants. View "Davis v. City of Elgin, Illinois" on Justia Law