Justia Constitutional Law Opinion Summaries

A police officer in Columbia, South Carolina, shot and killed a high school senior, J.R., during the COVID-19 curfew. The officer was responding to a report of teenagers looking into cars and saw J.R. walking alone. When the officer approached, J.R. ran away. The officer chased J.R. and, during the pursuit, observed that J.R. was armed. Despite repeatedly commanding J.R. to stop, get on the ground, and show his hands, J.R. did not comply. At one point, J.R. crouched near a fence, picked up his gun, and then ran again. The officer fired multiple shots, ultimately striking J.R. in the forehead and killing him.J.R.’s mother, acting as his personal representative, sued the officer under 42 U.S.C. § 1983, asserting that the use of deadly force violated J.R.’s Fourth Amendment rights. The United States District Court for the District of South Carolina denied the officer’s motion for summary judgment based on qualified immunity, finding that although J.R. was armed, ignored commands, and turned to face the officer, there was no undisputed evidence that J.R. made a threatening movement with his weapon. The court concluded that genuine disputes of material fact remained and that it was clearly established law that deadly force could not be used under these circumstances.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, at the time of the shooting, clearly established law prohibited a police officer from using deadly force against a fleeing, armed suspect who did not make a furtive or threatening movement with his weapon. The court concluded that the officer was not entitled to qualified immunity and allowed the case to proceed. View "Ruffin v. Davis" on Justia Law

A private company specializing in the disposal of wastewater from oil and gas fracking leased land in an urban area and constructed two saltwater-injection wells. After two earthquakes were recorded near the wells, the State of Ohio determined the company’s activities caused the seismic events and temporarily suspended operations at both wells. One well was later permitted to resume limited operations, but the suspension of the second well remained until 2021. The company had been aware of seismicity risks before acquiring its leasehold and warned investors of possible regulatory shutdowns.After the suspension, the company pursued administrative and judicial challenges, including an appeal to the Ohio Oil and Gas Commission and the Tenth District Court of Appeals, both of which upheld the State’s actions. The company then filed a petition for a writ of mandamus in the Eleventh District Court of Appeals, claiming a regulatory taking of its property. The Eleventh District initially denied relief, but following multiple remands from the Supreme Court of Ohio, it ultimately found no total taking but did find a compensable partial regulatory taking under the Penn Central analysis, ordering the State to initiate eminent-domain proceedings.On appeal, the Supreme Court of Ohio reviewed whether the suspension order constituted a total or partial regulatory taking. The court held that the company failed to prove it was deprived of all economically beneficial use, rejecting the total taking claim. The court further held that, under a proper balancing of the Penn Central factors, the State’s actions did not amount to a compensable partial taking. The Supreme Court of Ohio affirmed the Eleventh District’s denial of the total takings claim, reversed its partial takings finding, and denied the writ of mandamus. View "State ex rel. AWMS Water Solutions, L.L.C. v. Mertz" on Justia Law

The case involves a defendant who, in 2020, confronted individuals renting his neighbor’s house through Airbnb by approaching them with a shotgun, using racial slurs, and threatening them. He also left threatening voicemails for the property owner, making explicit references to race. The defendant was charged in two separate cases: one involving the renters (with charges including reckless endangerment and threatening) and another involving the neighbor (with charges including intimidation based on bigotry or bias and harassment). Ultimately, under a plea agreement, the defendant pleaded guilty to reckless endangerment in the second degree, threatening in the first degree (both under the Alford doctrine), and intimidation based on bigotry or bias in the third degree. The remaining charges were nolled.In the Superior Court for the judicial district of New Britain, the defendant entered his pleas. The trial court conducted a plea canvass, accepted the pleas, and later denied the defendant’s motion to withdraw them, in which he argued that the canvass was constitutionally deficient because the court did not specifically confirm that he was knowingly waiving his rights to a jury trial, to confront accusers, and against self-incrimination. On appeal, the Appellate Court affirmed the trial court’s judgment, holding that the plea canvass was sufficient under Boykin v. Alabama, as the record did not presume a waiver from silence and demonstrated the defendant’s understanding of the rights he was waiving.The Connecticut Supreme Court reviewed the case and affirmed the Appellate Court’s judgment. It held that Boykin does not require an express advisement or enumeration of each constitutional right during a plea canvass. Rather, the totality of the circumstances must show that the plea was made knowingly and voluntarily. Here, the defendant’s responses, counsel’s statements, and the overall canvass were constitutionally adequate, though barely so, and the plea was valid. View "State v. Roberts" on Justia Law

In this case, Montgomery County, Maryland, enacted amendments to its County Code in 2021 and 2022 regulating firearms. The amendments expanded the definition of “place of public assembly,” prohibited the possession of firearms (including “ghost guns”) in or within 100 yards of such places, and removed exceptions for state-issued handgun permit holders. The amendments also imposed new restrictions concerning minors’ access to firearms and regulated ghost guns and their components. The petitioners, two businesses and eight individuals, claimed these provisions were preempted by state law, not a valid local law, and amounted to an unconstitutional taking.After removal to federal court and a partial remand, the Circuit Court for Montgomery County ruled in favor of the challengers, finding the county’s provisions preempted by state law, not a local law, and an unconstitutional taking, and issued declaratory and injunctive relief. The Appellate Court of Maryland remanded for further analysis of preemption and takings issues, particularly concerning the expansion of “place of public assembly.”The Supreme Court of Maryland reviewed the case, holding that new issues may only be properly added by amending the complaint, not through summary judgment motions. The Court determined that Criminal Law § 4-209(b)(1) authorizes charter counties to regulate firearms in limited contexts (with respect to minors, law enforcement, and within 100 yards of certain public places), and that this authority was not abrogated by other state preemption statutes. The Court found Montgomery County’s regulation valid for parks, places of worship, schools, libraries, courthouses, legislative assemblies, recreational and multipurpose exhibition facilities, and polling places, but invalid for hospitals, health centers, long-term care, childcare facilities, government buildings as broadly defined, and generalized gatherings. The Court also clarified the scope of local regulation regarding minors and found no unconstitutional taking occurred. The judgment of the Appellate Court was vacated and remanded with instructions for further proceedings consistent with these holdings. View "Engage Armament v. Montgomery Cnty." on Justia Law

In December 2021, an individual with a lower leg amputation and a history of medical episodes broke into a car dealership in Chesterfield County, Virginia. After the alarm was triggered, police—including an officer and his police K-9—responded to the scene. The individual hid in a storage room, unarmed and passively waiting to be arrested. When the officer and his leashed K-9 located him lying in a submissive, fetal-like position, the officer allegedly gave no orders or warnings before directing the dog to attack. The K-9 inflicted severe injuries, including to sensitive areas of the individual’s body, resulting in significant blood loss and destruction of his prosthetic leg. Following the incident, the individual was charged with trespassing and vandalism, but no violent offenses.The individual filed suit in the United States District Court for the Eastern District of Virginia, asserting a Fourth Amendment excessive force claim under 42 U.S.C. § 1983, as well as related state law claims. The officer moved to dismiss, arguing that the use of force was objectively reasonable and that qualified immunity applied because the right in question was not clearly established. The district court ruled that the complaint plausibly alleged a Fourth Amendment violation but concluded that the specific right was not clearly established, granting the officer qualified immunity and dismissing the federal claim. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that, as of 2013, it was clearly established that a non-threatening, unarmed, and passively-resisting suspect had a right to be free from unnecessary, gratuitous, and disproportionate force by deployment of a police K-9. The court vacated the district court’s judgment and remanded for further proceedings. View "Harrold v. Hagen" on Justia Law

Two sixteen-year-old girls ran away from a treatment facility and were taken in by the petitioner, a forty-nine-year-old man, who let them stay at his residence for ten days. During this period, the petitioner provided the girls with drugs, made repeated sexual advances, and sexually assaulted one of them. He later pleaded guilty to attempted sexual assault and distributing a controlled substance to a minor. Based on an evaluation using Colorado's Sexually Violent Predator Assessment Screening Instrument, the district court found that the petitioner met the criteria for a sexually violent predator (SVP) designation and imposed that status at sentencing. The court also sentenced him to fifteen years in prison.The petitioner appealed his SVP designation to the Colorado Court of Appeals, arguing that it constituted cruel and unusual punishment under the Eighth Amendment. The appellate court rejected this argument, relying on precedent holding that the SVP designation was not punishment. The court found no conflict between that precedent and a more recent Colorado Supreme Court decision that found mandatory lifetime sex offender registration to be cruel and unusual punishment as applied to juveniles. The appellate court thus affirmed the district court’s order.The Supreme Court of Colorado granted review to decide whether the SVP designation constitutes criminal punishment under the Eighth Amendment and, if so, whether it is cruel and unusual as applied to the petitioner. The court concluded that the Colorado General Assembly did not intend the SVP designation to be punitive and that its effects did not override that intent by “the clearest proof.” Therefore, it held that the SVP designation and its attendant requirements do not constitute punishment under the Eighth Amendment. The Supreme Court of Colorado affirmed the judgment of the Colorado Court of Appeals. View "Beagle v. People" on Justia Law

A proposed initiative petition sought to amend existing Massachusetts law by altering legislative stipends for members of the General Court. This proposal would have tied a portion of stipend payments to compliance with specific procedural requirements and performance goals related to committee activity. The clerks of the Senate and House of Representatives would have been responsible for certifying whether these requirements were met. The initiative aimed to promote transparency and efficiency in legislative proceedings by making part of legislative compensation contingent on adherence to certain committee procedures and timelines.After the initiative was filed and certified in accordance with the Massachusetts constitutional process for initiative petitions, it was transmitted to the Senate. Members of the Senate expressed significant doubt about whether the petition actually proposed a law, as required by Article 48 of the Massachusetts Constitution, or instead impermissibly sought to regulate the Legislature’s internal procedures, which are exclusively within the power of each legislative chamber. The Senate requested an advisory opinion from the Supreme Judicial Court of Massachusetts on whether the petition could properly proceed.The Supreme Judicial Court of Massachusetts concluded that the initiative petition did not propose a law, but rather attempted to impose a rule by regulating the internal procedures of the Legislature. The Court reasoned that Article 48 only allows the initiative process for laws or constitutional amendments, and that managing internal legislative operations is a unicameral power reserved for each chamber. Because the petition’s main purpose was to control internal legislative procedures through compensation mechanisms and by assigning duties to legislative officers, it was deemed outside the scope of the initiative process. The Court held that the petition was not in proper form for submission to the people and declined to answer the Senate’s second question. View "Opinion of the Justices to the Senate" on Justia Law

Three equestrian trainers, each subjected to sanctions by the United States Center for SafeSport (SafeSport) for past misconduct, sought to challenge those sanctions. Navarro and Giorgio were permanently banned after SafeSport learned of their prior guilty pleas to child sexual abuse, while Shaffer received a suspension and probation following SafeSport’s investigation of complaints against her. Navarro and Giorgio pursued arbitration and internal grievance procedures that ultimately confirmed SafeSport’s sanctions. Shaffer declined to arbitrate, citing the cost. All three alleged that SafeSport’s procedures violated their constitutional rights because they were barred from Olympic sports without a prior hearing, and further argued that SafeSport, a private body, unconstitutionally exercises governmental authority.After their grievances and appeals were rejected by the United States Equestrian Federation (USEF) and the United States Olympic & Paralympic Committee (USOC), the trainers filed suit in the United States District Court for the Western District of Virginia. The district court dismissed their claims, holding that the trainers lacked standing to sue the USOC, that Shaffer failed to exhaust administrative remedies, that Appellees were not state actors and thus not subject to the Fifth Amendment, and that SafeSport’s powers did not violate the private non-delegation doctrine.The United States Court of Appeals for the Fourth Circuit reviewed the case. It affirmed the district court’s rulings that the trainers lacked standing to sue the USOC, that the Appellees were not state actors subject to the Due Process Clause, and that the court lacked jurisdiction over the private non-delegation claim. However, it reversed the district court’s finding on administrative exhaustion, holding that Shaffer was not obligated to arbitrate her constitutional claims before seeking relief in federal court. Thus, the judgment was affirmed in part and reversed in part. View "Navarro v. United States Center for SafeSport" on Justia Law

In August 2023, an adult defendant began communicating over the Whisper social media app with an individual he believed to be an adult, but who was actually thirteen years old. The two exchanged frequent communications, including explicit text, audio, and video messages, and spoke regularly over the course of several weeks. The defendant claimed he thought the other party was an adult, based on her representations, and that any mention of a younger age was part of a roleplay scenario. The communications were discovered when the minor’s classmates alerted school officials, leading to law enforcement intervention and the defendant’s indictment for coercion or enticement of a minor.The case proceeded to trial in the United States District Court for the Northern District of Oklahoma. A jury found the defendant guilty after less than forty minutes of deliberation, and he was sentenced to 140 months in prison. During closing arguments, the prosecutor made remarks suggesting the defendant’s presumption of innocence had been removed by the evidence, and reinforced this with a visual presentation, but the defense did not object at the time. The jury was instructed on the presumption of innocence only at the start of trial, and no specific curative instructions were given after the prosecutor’s statements.The United States Court of Appeals for the Tenth Circuit reviewed the case under plain error analysis, given the lack of objection at trial. The court held that the prosecutor’s statements during closing argument constituted a clear and obvious error that infringed the defendant's constitutional right to the presumption of innocence. The court found the error affected the defendant’s substantial rights, given the context and timing of the remarks, the absence of overwhelming evidence, and insufficient curative instructions. The conviction was vacated and the case remanded for further proceedings. View "United States v. Petro" on Justia Law

A high school student reposted on his public TikTok account an image depicting a man in a school hallway aiming an assault rifle, with the phrase “Me at School” across it. The image was seen by another student, the juvenile’s former girlfriend, who reported it to school officials because she found it frightening. This led to an investigation, a search of the juvenile’s home (with parental consent), and subsequent charges against the juvenile for communicating a threat against a place, in violation of Massachusetts General Laws chapter 269, section 14(b).The Middlesex County Division of the Juvenile Court Department heard the case. A jury found the juvenile delinquent. After the verdict, the judge vacated the finding, continued the case without a finding, and imposed probation conditions until the juvenile’s nineteenth birthday. The case was dismissed upon completion of probation, but the Supreme Judicial Court of Massachusetts allowed direct appellate review due to the possible collateral consequences of the delinquency complaint.The Supreme Judicial Court of Massachusetts held that, following the United States Supreme Court’s decision in Counterman v. Colorado, 600 U.S. 66 (2023), the Commonwealth must prove as an element of G. L. c. 269, § 14(b) that the defendant “consciously disregarded a substantial risk that his communications would be viewed as threatening violence.” The Court found that the jury had not been properly instructed on this requirement, constituting a substantial risk of a miscarriage of justice, even though the evidence was sufficient to support the adjudication. The Court remanded the case for further proceedings consistent with its opinion, clarifying the mens rea required for convictions under the statute. View "Commonwealth v. Ushon U." on Justia Law