Justia Constitutional Law Opinion Summaries

Arizona voters adopted a statute requiring organizations engaging in independent election-related media spending to disclose the identities of major donors and the original sources of funds used for such communications. The law includes an opt-out provision allowing donors to prevent their contributions from being used for campaign media spending, and imposes thresholds for disclosure and reporting. Plaintiffs, consisting of two nonprofit organizations and two anonymous individuals who donate to such organizations, challenged the law’s constitutionality, alleging it violated their rights to free speech and privacy under the Arizona Constitution.The Superior Court for Maricopa County dismissed the plaintiffs’ complaint for failure to state a legally valid claim, but permitted an amended complaint to add an as-applied challenge. After defendants again moved to dismiss, the court granted the motion, and the Arizona Court of Appeals affirmed the dismissal, finding plaintiffs had not sufficiently alleged that the statute was unconstitutional on its face or as applied.Upon review, the Supreme Court of Arizona held that the plaintiffs failed to sufficiently allege that the statute is facially unconstitutional under either the Speak Freely Clause or the Private Affairs Clause of the Arizona Constitution. The court developed an Arizona-specific standard for evaluating compelled disclosure laws, requiring that such laws meaningfully further election integrity or transparency and not unreasonably burden protected expression. The court found that the plaintiffs did not plausibly allege that the statute burdens protected expression in a substantial number of its applications.However, the Supreme Court of Arizona determined that the plaintiffs sufficiently alleged an as-applied challenge under the Speak Freely Clause, based on specific allegations of threats and harassment related to campaign media spending. The court affirmed the lower courts’ dismissal of all facial and privacy claims, reversed the dismissal of the as-applied free speech claim, and remanded that claim for further proceedings. View "CENTER FOR AZ v AZ SECRETARY OF STATE" on Justia Law

In August 2025, the President attempted to remove a sitting member of the Board of Governors of the Federal Reserve System, Lisa Cook, citing allegations of mortgage fraud that predated her tenure. This was the first time in the Federal Reserve’s history that a Governor was purportedly fired. Cook, whose term was scheduled to run until 2038, received a letter from the President stating that her integrity was in question due to potential misconduct, and that her immediate removal was necessary. Cook filed suit, arguing both that the alleged misconduct did not constitute “cause” for removal under the governing statute, and that she had not been given the required process—namely, notice and an opportunity to respond—before her termination.The United States District Court for the District of Columbia issued a preliminary injunction preventing Cook’s removal, finding she was likely to succeed on her claims that the purported “cause” did not satisfy the statutory standard, and that she had not received constitutionally or statutorily required pre-termination process. The United States Court of Appeals for the District of Columbia Circuit declined to stay the injunction, with a concurrence emphasizing the due process issue. The Government then sought a stay from the Supreme Court.The Supreme Court of the United States denied the Government’s application for a stay. The Court held that the President’s power to remove Federal Reserve Governors is subject to judicial review and that “cause” for removal must be substantial and related to the Governor’s official duties, reflecting the Federal Reserve’s need for independence. Most importantly, the Court ruled that Governors are entitled by statute to notice and an opportunity to respond before removal. Because Cook was not afforded these protections, her removal could not stand pending further litigation. The Court declined to address broader constitutional questions, deciding the case on statutory grounds. View "Trump v. Cook" on Justia Law

After President Trump began his second term in 2025, he dismissed two Democratic commissioners from the Federal Trade Commission (FTC), Rebecca Slaughter and Alvaro Bedoya, citing that their continued service conflicted with his administration’s priorities. He did not allege any statutory cause for their removal, instead asserting authority under Article II of the Constitution. Slaughter sued, arguing her removal was unlawful under the relevant statute, the Administrative Procedure Act, and the Constitution. Bedoya’s claims were dismissed as moot after he resigned, leaving only Slaughter’s case at issue.The United States District Court for the District of Columbia granted summary judgment in Slaughter’s favor, finding that President Trump’s action was ultra vires because the relevant statute allows removal of FTC commissioners only for “inefficiency, neglect of duty, or malfeasance in office.” The court relied on the Supreme Court’s prior decision in Humphrey’s Executor v. United States, which had recognized such statutory protections for FTC commissioners. The court issued a permanent injunction prohibiting interference with Slaughter’s ability to perform her duties. The United States Court of Appeals for the District of Columbia Circuit denied the government’s motion for a stay pending appeal, finding that Humphrey’s Executor controlled the issue.The Supreme Court of the United States reversed. It held that the FTC’s statutory provision limiting removal of commissioners to “for cause” is unconstitutional because it impermissibly restricts the President’s authority to remove executive officers. The Court overruled Humphrey’s Executor to the extent it permitted such statutory insulation for executive officers, reaffirming that officers exercising executive power must be removable by the President at will to preserve the Constitution’s separation of powers. The case was remanded for further proceedings consistent with this holding. View "Trump v. Slaughter" on Justia Law

A man robbed a credit union in Midlothian, Virginia in May 2019. Police learned from witnesses and surveillance that the robber appeared to use a cell phone but could not identify him. To find leads, the officers applied for a geofence warrant, compelling Google to provide anonymized location data for all cell phones within a 150-meter radius of the credit union around the time of the crime. The warrant described a three-step process: first, Google would produce anonymized data for all devices within the geofence for an hour; second, police would narrow the list and receive additional location data for those devices; third, police would further narrow the list and obtain identifying information. Ultimately, Google provided the identities of three users, including the petitioner, whose movements matched those of the robber.The United States District Court for the Eastern District of Virginia found the geofence warrant “plainly violates the rights enshrined in [the Fourth] Amendment” but denied the motion to suppress the evidence, applying the good-faith exception to the exclusionary rule. A divided panel of the United States Court of Appeals for the Fourth Circuit affirmed, but on the ground that no Fourth Amendment search had occurred because the petitioner had no reasonable expectation of privacy in the Location History data given to Google. On rehearing en banc, the Fourth Circuit affirmed in a one-sentence opinion, dividing evenly on the search question.The Supreme Court of the United States held that police conduct a Fourth Amendment search when they acquire an individual’s cell-phone Location History data from Google, because a person has a reasonable expectation of privacy in such information. The Court vacated the Fourth Circuit’s judgment and remanded the case for further proceedings to determine whether the warrant satisfied the Fourth Amendment’s requirements of particularity and probable cause at each stage of the search process. View "Chatrie v. United States" on Justia Law

Two men were convicted in the Circuit Court for Baltimore City on charges related to the 2019 murder of Donnell Brockington, who was surrounded and fatally shot multiple times by a group of six individuals. After the suspects fled, four, including the two respondents, were apprehended when their vehicle crashed. Police recovered several firearms, and DNA evidence linked both respondents to a Desert Eagle 9mm pistol found in the vehicle. At trial, a State firearms examiner testified that certain ammunition components were fired from that pistol, but neither respondent challenged the reliability of the examiner’s methodology or requested a Daubert hearing.After trial, the Supreme Court of Maryland decided Abruquah v. State, clarifying the limits on firearms identification testimony. The Appellate Court of Maryland reversed the respondents’ convictions on plain-error review, concluding that the firearms examiner’s unqualified testimony was exactly the kind prohibited by Abruquah. Additionally, one respondent challenged the trial court’s decision to close the courtroom during jury deliberations and partially restrict attendance during the verdict, arguing it violated the Sixth Amendment. The Appellate Court found these closures de minimis and rejected the public trial claim.The Supreme Court of Maryland held that the admission of the firearms examiner’s unqualified opinion was not “clear or obvious” error for plain-error review purposes, since the law was unsettled both at trial and on appeal; Abruquah was a case-specific ruling, not a categorical ban on such testimony. The Court also concluded that the courtroom closures were not de minimis but were justified under Waller v. Georgia, given the trial court’s findings of escalating spectator misconduct and concern for juror safety. The Supreme Court reversed the Appellate Court’s judgment on the convictions, affirmed its ruling on the public trial issue, and remanded for further proceedings. View "State v. Thornton" on Justia Law

In 1995, a man was convicted by a jury in the Dauphin County Court of Common Pleas for first-degree murder following the shooting death of another individual related to a drug deal. Two key prosecution witnesses, both facing pending charges themselves, testified against him in exchange for plea agreements. The prosecution did not disclose all pending charges against these witnesses, though defense counsel was able to impeach their credibility based on other known charges. Despite this, the jury convicted the defendant, who was sentenced to life imprisonment. He unsuccessfully challenged his conviction on direct appeal and through multiple post-conviction proceedings in state court.After eventually discovering the full extent of the witnesses' pending charges, the petitioner filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Middle District of Pennsylvania, asserting a Brady violation. The District Court denied the petition as untimely under the statute of limitations, and subsequent requests for a certificate of appealability were also denied. Following a significant change in Third Circuit law announced in Dennis v. Secretary, Pennsylvania Department of Corrections, the petitioner sought to reopen his federal habeas case under Federal Rule of Civil Procedure 60(b)(6). After a remand for further analysis, the District Court again denied the Rule 60(b)(6) motion, finding that the factors for extraordinary relief were not met.The United States Court of Appeals for the Third Circuit reviewed the denial, applying an abuse-of-discretion standard and weighing the Cox factors. The Court held that, although the materiality and diligence factors favored the petitioner, the remaining factors—likelihood of success, finality and comity, lack of actual innocence, and non-capital sentence—strongly disfavored relief. The Third Circuit affirmed the District Court’s denial of the Rule 60(b)(6) motion. View "Bracey v. Superintendent Rockview SCI" on Justia Law

In July 2024, police in Iowa investigated a report that Eric Schadl, a person prohibited from possessing firearms due to a prior conviction, had a gun in his home. Schadl admitted to owning a .22 caliber rifle and having a 2010 misdemeanor domestic abuse assault conviction, which barred him from firearm possession under Iowa law. He was charged under Iowa Code § 724.26(2)(a), which imposes a lifetime firearm ban on individuals convicted of a misdemeanor crime of domestic violence.Schadl moved to dismiss the charge in Iowa District Court for Dubuque County, arguing the statute violated his right to keep and bear arms under both the Iowa and Federal Constitutions. The district court denied his motion, finding the statute constitutional under intermediate scrutiny. Schadl then asked the court to reconsider, arguing that strict scrutiny applied under the Iowa Constitution’s Amendment 1A, and that recent United States Supreme Court decisions had changed the federal standard. The district court reaffirmed its prior ruling, this time stating the statute survived even under strict scrutiny. Schadl entered a conditional guilty plea, reserving the right to appeal the constitutional issue, and was sentenced to a suspended sentence with probation.On appeal, the Supreme Court of Iowa reviewed whether the lifetime firearm ban, as applied to Schadl, violated Amendment 1A of the Iowa Constitution, which requires all firearm restrictions to survive strict scrutiny. The court rejected Schadl’s facial challenge but found for him on his as-applied challenge, holding that the State failed to prove the indefinite ban was narrowly tailored to serve a compelling public safety interest, especially given Schadl’s fourteen years without reoffending. The court concluded the State had not met its burden under strict scrutiny and reversed Schadl’s conviction, remanding the case to the district court for dismissal. View "State of Iowa v. Schadl" on Justia Law

Several individuals incarcerated in Iowa correctional institutions challenged the constitutionality of Iowa Code section 904.310A, as amended in 2018, which prohibits the Iowa Department of Corrections from using funds to distribute or make available any commercially published material to inmates when such material is sexually explicit or features nudity. The plaintiffs, representing themselves and later joined by counsel, argued that this prohibition infringed on their rights to free speech under the United States and Iowa Constitutions. The amended statute and corresponding regulations resulted in the closure of reading rooms and a bar on materials with nudity, even when not sexually explicit. The challenged policy did not apply to personal photographs, only to commercially published materials.The Iowa District Court for Polk County initially granted a partial injunction, permitting the distribution of materials featuring mere, non-sexually explicit nudity, but ultimately denied most of the plaintiffs’ constitutional claims following a bench trial. The court applied the Turner v. Safley standard, requiring prison regulations that burden inmates’ constitutional rights to be reasonably related to legitimate penological interests. The court found that, while the regulation was more restrictive than prior policy, the State presented sufficient evidence—including expert testimony and examples of staff harassment and inmate safety issues—to support the connection between the ban and legitimate interests in institutional safety and order. As a result, the court denied the plaintiffs’ claims for declaratory and injunctive relief.On appeal, the Iowa Supreme Court conducted a de novo review and affirmed the district court’s judgment. The Supreme Court held that the Turner reasonableness standard, rather than strict scrutiny, applies to inmates’ free speech claims under both federal and state constitutions. The Court concluded that the regulation is justified by legitimate penological interests in staff and inmate safety, and that the ban is not an exaggerated response to those concerns. The judgment was affirmed. View "Gregory v. State of Iowa" on Justia Law

A woman, referred to as Naomi, was charged with felony battery by a prisoner after slapping a nurse while incarcerated in the Milwaukee County jail. At her initial court appearance, concerns were raised about her competency to stand trial, and the Milwaukee County Circuit Court ordered a competency evaluation. Upon finding Naomi incompetent but likely to regain competence with treatment, the court committed her to the Department of Health Services (DHS) for treatment. The court originally found her incompetent to refuse medication and, after applying the standards from Sell v. United States, ordered involuntary medication to restore competency. Naomi appealed, and the court stayed the order. Subsequently, after DHS raised concerns about Naomi’s dangerousness, the court vacated its earlier order and issued a new involuntary medication order based solely on Naomi’s dangerousness, relying on WIS. STAT. § 51.61(1)(g)3.Naomi challenged the legal authority for this order, arguing that someone committed only under WIS. STAT. § 971.14 for competency restoration could not be involuntarily medicated on dangerousness grounds under § 51.61(1)(g)3. The Wisconsin Court of Appeals agreed with Naomi, rejecting the State’s arguments that various statutory and case law authorities permitted the order.The Supreme Court of Wisconsin reviewed the matter and affirmed the Court of Appeals. The court held that WIS. STAT. § 51.61(1)(g)3. does not authorize a court to order involuntary medication for an individual committed exclusively under WIS. STAT. § 971.14. The court based its decision on statutory language, context, and history, finding that § 971.14 provides a separate, more stringent process for involuntary medication orders in the context of competency restoration, and that § 51.61(1)(g)3. cannot be used as an alternative basis for such orders. View "State v. N. K. B." on Justia Law

Two individuals—a student enrolled in a nursing program and a prospective paramedic student—challenged a community college’s policy requiring proof of COVID-19 vaccination for participation in certain clinical programs. The student alleged she was removed from the nursing program after failing to provide proof of vaccination and not receiving a clear response to her request for a medical exemption. She also claimed that the college placed her in clinical rotations at facilities with strict vaccination requirements, while other students were placed at locations accommodating the unvaccinated. The prospective paramedic student did not complete the vaccination requirement, did not seek an exemption, and was told that proof of vaccination or a successful exemption was necessary for acceptance.The District Court for Lancaster County allowed amendment of the initial complaint, but ultimately dismissed the amended complaint for lack of subject matter jurisdiction and failure to state a claim. The court found that the contract and negligence claims were barred by sovereign immunity, that the due process and equal protection claims lacked sufficient factual allegations to proceed, and that the “ultra vires” claim was not cognizable. The court denied further leave to amend, finding amendment would be futile. A timely postjudgment motion to alter or amend was denied, and the plaintiffs appealed.The Nebraska Supreme Court, after reviewing for plain error due to briefing deficiencies, found no plain error in the lower court’s dismissal of the case. The Court concluded that the district court properly dismissed all claims and that the appeal was timely. The Supreme Court affirmed the judgment of the district court. View "Fischer v. Southeast Community College" on Justia Law