Justia Constitutional Law Opinion Summaries

The defendant, Munson Hunter, was indicted on multiple counts of bank and wire fraud for his role in a scheme that caused significant financial losses. After raising concerns about his mental health and undergoing a competency evaluation, Hunter pleaded guilty to one count in exchange for the dismissal of the remaining charges. His plea agreement included a waiver of the right to appeal his conviction and sentence, except for claims of ineffective assistance of counsel. At sentencing, the United States District Court for the Southern District of Texas imposed a term of supervised release with a special condition requiring Hunter to participate in a mental health program and take any medication prescribed by his physician. Hunter objected to being compelled to take medication.Despite the appellate waiver, Hunter appealed the medication condition, arguing it infringed on his due process rights. The United States Court of Appeals for the Fifth Circuit initially dismissed his appeal, relying on circuit precedent that recognized only limited exceptions to appeal waivers. The Supreme Court of the United States subsequently granted certiorari and announced a new rule: appeal waivers are unenforceable if their enforcement would result in a "miscarriage of justice"—that is, if they would leave in place an obvious and egregious error undermining the integrity of the judicial system.On remand, the United States Court of Appeals for the Fifth Circuit applied the Supreme Court’s new standard. The court determined that the record supported the imposition of the medication condition, finding no "blatant" constitutional error or egregious statutory violation. The court concluded that requiring Hunter to take prescribed medication as part of supervised release did not constitute the kind of obvious judicial error that would render the waiver unenforceable. Accordingly, the Fifth Circuit held that Hunter’s appeal waiver remained effective and dismissed the appeal. View "USA v. Hunter" on Justia Law

A company that operated as a fixed-base operator at a municipal airport sued the city that owns and operates the airport. The company alleged that the city provided more favorable lease terms and selectively excused certain regulatory requirements for a competing operator, thereby disadvantaging the plaintiff. The city’s leases with the plaintiff and with its competitor differed in several respects, including rent abatement periods, required capital investments, and compliance with fuel storage and insurance requirements. The plaintiff argued that these differences, along with the city’s alleged failure to strictly enforce its own policies and federal grant assurances, constituted both an equal protection violation under a “class-of-one” theory and a breach of contract.The lawsuit was originally filed in Illinois state court, but the city removed it to the United States District Court for the Northern District of Illinois. The plaintiff amended its complaint to drop claims against the competitor and proceeded against the city for breach of contract and equal protection violations. After discovery, both sides moved for summary judgment. The district court granted summary judgment for the city on both claims, finding that the class-of-one theory did not apply in the context of government contracting and that the contractual documents did not incorporate the policies or grant assurances as enforceable obligations.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that a class-of-one claim under the Equal Protection Clause is not available where a company challenges the terms of its lease or its competitor’s treatment under a different lease, absent any class-based discrimination. The court also held that the city’s policy and grant assurances were not incorporated into the plaintiff’s lease as enforceable contract terms, nor did the law provide a private right to enforce them in this context. The court affirmed the district court’s summary judgment in favor of the city. View "Joliet Avionics, Inc. v City of Aurora" on Justia Law

A restaurant owner applied for a liquor license for a property in Providence, Rhode Island. Nearby property owners, including the appellant, filed an objection to the license under a state law that allows such objections to bar issuance of liquor licenses within 200 feet of their property. After the local licensing board could not issue the license due to this objection, the restaurant owner lobbied the General Assembly, which enacted a special law allowing the Providence Board of Licenses to exempt this specific address from the objection rule. This exemption applied only to the property at 225 Waterman Street and was enacted without a vote by local Providence voters.After the special law was passed, the restaurant owner reapplied, and the Board granted the license over objections. The appellant appealed to the Rhode Island Department of Business Regulation (DBR), which stayed the license but did not rule on the constitutional issue. The appellant then filed suit in the Rhode Island Superior Court, arguing that the special exemption was unconstitutional because Article 13, Section 4 of the Rhode Island Constitution requires local voter approval for legislation relating specifically to the property, affairs, or government of a particular city or town. The Superior Court granted summary judgment for the defendants, holding that liquor licensing is a matter of statewide concern and does not require local voter approval.On appeal, the Supreme Court of Rhode Island reviewed the constitutionality of the special law. The court held that the legislation, which singled out a specific property in Providence for exemption from a generally applicable law, related to the property, affairs, and government of a particular city. Because the law did not receive local voter approval as required by Article 13, Section 4, it was void. The Supreme Court vacated the judgment of the Superior Court and remanded for entry of judgment in favor of the appellant. View "Myles Standish Associates, LP v. The City of Providence" on Justia Law

A man who had recently been released on parole was stopped by police in San Pablo, California, while driving with his young niece and nephew. After a brief delay in pulling over, the officer learned of his parole status and asked the occupants to exit the car. The officer found a loaded, modified Glock pistol on the nephew, and text messages showed the man had instructed his mother to retrieve the child because he was carrying the gun. The gun and ammunition were manufactured outside California, and the gun was modified to fire automatically.A federal grand jury indicted the defendant for being a felon in possession of a firearm and ammunition. He sought to dismiss the indictment on constitutional grounds and to suppress the evidence, but while the United States District Court for the Northern District of California granted the suppression motion, the Ninth Circuit summarily reversed and remanded after a related case clarified that asking about parole status during a stop was permissible. The defendant then requested a stipulated-facts bench trial, after his request for a conditional plea was refused by the government. The district court found him guilty following the bench trial.At sentencing, the district court applied a two-level reduction for acceptance of responsibility but, over its stated disagreement, did not apply a third point because the government declined to move for it, citing resources expended preparing for trial. The court also applied an enhancement for possessing the firearm in connection with child endangerment, a “wobbler” offense under California law, finding the conduct was felonious. The United States Court of Appeals for the Ninth Circuit affirmed, holding that the government has broad discretion to withhold the motion for the third acceptance point under U.S.S.G. § 3E1.1(b), and the district court properly exercised its discretion in treating the child endangerment offense as a felony for sentencing purposes. View "USA V. YATES" on Justia Law

A noncitizen from the Democratic Republic of the Congo was detained in New York pending removal proceedings and was ordered released on bond, which he could not pay. He then brought a class action and habeas petition on behalf of similarly situated noncitizens, challenging government bond-hearing procedures as violating due process. Specifically, he argued that the procedures wrongly placed the burden of proof on detainees, failed to consider ability to pay, and did not require consideration of alternatives to detention.The United States District Court for the Western District of New York initially certified the class and issued a preliminary injunction requiring changes to bond-hearing procedures, with the government complying for nearly two years. After the Supreme Court decided Garland v. Aleman Gonzalez, which held that lower courts lack jurisdiction to issue class-wide injunctive relief under certain immigration statutes, the district court vacated the injunction. It then decertified the class entirely, concluding that neither class-wide injunctive nor declaratory relief was appropriate, and dismissed the case.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not abuse its discretion in decertifying the class for injunctive relief, as lower courts lack authority for such relief post-Aleman Gonzalez. However, it found that the district court erred by decertifying the class for declaratory relief based on factors irrelevant to the Rule 23(b)(2) class-certification analysis. The Second Circuit clarified that while injunctive relief is unavailable, district courts retain authority to grant class-wide declaratory relief in these cases. Accordingly, the Second Circuit vacated the district court’s judgment and remanded for further proceedings. View "Onosamba-Ohindo v. Ball" on Justia Law

A group of plaintiffs, including Civil Rights Corps and several law professors, filed twenty-one grievance complaints against New York state prosecutors with the Attorney Grievance Committee of the Second Judicial Department. The complaints alleged unethical conduct based on public information and judicial findings. After the Committee informed the plaintiffs that any resulting proceedings against the prosecutors would remain confidential under Section 90(10) of the New York Judiciary Law, the plaintiffs brought suit under 42 U.S.C. § 1983, contending that the statute violated their First Amendment right of access as applied to their complaints.The United States District Court for the Southern District of New York reviewed the case at summary judgment. It held that a First Amendment presumption of access attaches to formal disciplinary hearings in the Second Department, to records necessary to understand those hearings, and to final dispositions by the Grievance Committee. The court found Section 90(10) unconstitutional as applied to the plaintiffs’ complaints, concluding it impermissibly interfered with their right of access.On appeal, the United States Court of Appeals for the Second Circuit considered whether the plaintiffs’ claims were ripe and whether abstention was warranted under O’Shea v. Littleton. Applying de novo review, the Second Circuit found the claims ripe and abstention unnecessary. The court applied the experience-and-logic test and determined that a qualified, presumptive First Amendment right of access exists for formal disciplinary hearings in the Second Department, pertinent records, and select Committee dispositions. The State may restrict access only if it makes specific, on-the-record findings justifying confidentiality. The Second Circuit affirmed the district court’s judgment. View "Civil Rights Corps v. LaSalle" on Justia Law

The defendant was convicted of the murder of Lannie Silver, Jr., based primarily on the testimony of Ruby Waller, who identified the defendant as the shooter and recounted the events leading up to Silver’s death. Waller, who had a history of drug convictions, initially provided her statement to police before she faced any pending charges, but by the time of trial, she had an unresolved shoplifting charge. During trial, she testified she was not expecting any benefit for her testimony. Years after conviction, the defendant alleged that the prosecution failed to disclose Waller’s 1991 plea agreement, in which she had received a reduced sentence in exchange for testifying against a co-defendant in an unrelated case, arguing that this could have been used to impeach her credibility.Following his conviction and unsuccessful direct appeal in the Superior Court, Appellate Division, and after a failed habeas petition in federal court, the defendant filed a motion in state court for a new trial based on the newly discovered plea agreement. The trial court denied the motion, concluding the evidence was not material. On appeal, the Appellate Division agreed with the trial court’s result but found it had used the wrong legal standard, ultimately holding that the standards for materiality under Brady v. Maryland and State v. Carter were essentially the same, and that the error was harmless.The Supreme Court of New Jersey clarified that the Brady standard for materiality—whether there is a reasonable probability that the result would have been different—is less demanding than Carter’s requirement that new evidence would probably change the verdict. The Court held these standards are not the same. Nonetheless, the Court affirmed the Appellate Division’s result, finding that the undisclosed plea agreement did not create a reasonable probability of a different outcome, and thus the defendant did not meet the Brady materiality standard. View "State v. Allen" on Justia Law

A nonprofit organization in Florida, serving the Black community in St. Petersburg, applied twice for COVID-19 relief grants from funds distributed by Pinellas County. The group’s first grant application was initially approved, but after a newly seated Board member raised concerns about the group’s association with the “Uhuru Movement” and its perceived ties to Black empowerment and alleged antisemitic organizations, the Board revoked the grant. The group’s second application, for a backup generator, was later denied despite being highly ranked by an independent review foundation. The nonprofit alleged that similar grants were awarded to other organizations serving predominantly white communities for comparable purposes.After the denial, the nonprofit sued Pinellas County in the United States District Court for the Middle District of Florida, alleging violations of the First Amendment (retaliation for expressive association), the Equal Protection Clause (racial discrimination), and the Due Process Clause (lack of notice and opportunity to be heard). The district court dismissed all claims with prejudice, concluding there was no actionable First Amendment or equal protection violation and that the nonprofit did not have a property interest protected by due process.The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. It held that the nonprofit plausibly alleged First Amendment retaliation, as the facts showed the county may have revoked and denied grants based on the group’s expressive association, and that the organization was entitled to full First Amendment protection as a grant applicant. The court also held that the nonprofit stated a plausible claim for intentional racial discrimination under the Equal Protection Clause. However, the panel affirmed dismissal of the due process claim, finding the nonprofit lacked a constitutionally protected property interest in the grants. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "African People's Education and Defense Fund, Inc. v. Pinellas County" on Justia Law

In 1976, the defendant was convicted by a jury of first-degree felony murder for aiding and abetting an armed robbery in which another individual committed a fatal shooting at a grocery store. The defendant was not present during the actual shooting but had provided information about the store’s occupants to the principal. He was sentenced to life imprisonment without the possibility of parole. The trial court’s instructions to the jury did not require a finding of malice as later defined by Michigan law.On direct appeal, the Michigan Court of Appeals reversed the conviction due to improper jury instructions regarding the mens rea for felony murder. However, the Michigan Supreme Court reinstated the conviction after its decision in People v Aaron, which redefined malice for felony murder but applied only to trials in progress or later. The case returned to the Court of Appeals, which affirmed the conviction, and the Michigan Supreme Court denied further review.In 2020, the defendant filed for post-judgment relief, arguing that his sentence was unconstitutional because the jury did not make a finding of malice as required by Aaron, and that mandatory life without parole was cruel or unusual punishment. The trial court denied his motion, stating it was bound by precedent, and the Court of Appeals denied leave to appeal.The Michigan Supreme Court held that mandatory life without parole for pre-Aaron felony murder constitutes cruel or unusual punishment under the Michigan Constitution if the jury was not instructed on malice as defined by Aaron, unless the prosecution can prove beyond a reasonable doubt that a jury would have found malice based on the trial evidence. If the prosecution fails to meet this burden, the no-parole aspect of the sentence must be struck, making the defendant eligible for parole. The trial court’s order was vacated in part, and the case was remanded for further proceedings. View "People Of Michigan v. Langston" on Justia Law

The case involved a fatal shooting that took place during a nighttime street vigil in Hartford, where the defendant was identified as the shooter through surveillance video footage and subsequent police investigation. The police obtained and compiled footage from multiple street cameras using a software program called Milestone, which synchronized the various video feeds. During a police interview, the defendant identified himself in the video footage and admitted to being in the vicinity of the shooting. At trial, both the video compilation and the recording of the defendant’s interview were admitted into evidence.The case was tried before the Superior Court in the judicial district of Hartford, where the jury found the defendant guilty of murder and criminal possession of a firearm. During the trial, the defense did not object to the admission of either the video compilation or the recorded police interview and related waiver forms. The trial court rendered judgment in accordance with the jury’s verdict and sentenced the defendant to fifty-five years of imprisonment.On appeal, the defendant argued before the Connecticut Supreme Court that his confrontation rights were violated by the admission of the video compilation, claiming he was entitled to cross-examine the developer of the Milestone software. He also contended that his right to counsel was violated during the police interview. The Supreme Court held that the defendant’s confrontation clause claim was affirmatively waived because his counsel expressly stated “[n]o objection” to the admission of the evidence at trial. The court further found the record inadequate to review the confrontation claim and determined that the right-to-counsel claim was unreviewable under established standards due to waiver. The court declined to exercise its supervisory authority to adopt new rules or reverse the conviction. Accordingly, the conviction was affirmed. View "State v. Keaton" on Justia Law