Justia Constitutional Law Opinion Summaries

During the COVID-19 pandemic, the City of Boston implemented a temporary outdoor dining program that allowed restaurants across the city to use outdoor spaces for dining under relaxed licensing rules. In 2022, the City adopted a special plan for the North End neighborhood, which included higher fees, a shorter outdoor dining season, and additional restrictions compared to other neighborhoods. The City cited quality-of-life concerns, such as congestion and sanitation, and ongoing complaints from residents as reasons for the North End-specific rules. In 2023 and 2024, the City went further and banned on-street dining in the North End, while permitting it elsewhere. These actions prompted a group of North End restaurants and the local Chamber of Commerce to sue the City, alleging constitutional and state law violations.The United States District Court for the District of Massachusetts dismissed the plaintiffs’ lengthy complaint, finding that it violated Rule 8 of the Federal Rules of Civil Procedure by being excessively long and repetitive, and also determined that the complaint failed on the merits. The court denied the plaintiffs leave to amend, citing their multiple prior complaints and the substantive deficiencies in their claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal of the federal constitutional claims (counts I–V) with prejudice, agreeing that the complaint was overly burdensome and failed to plausibly allege violations of equal protection, due process, or arbitrary action by the City. The Court held that disparate impact or political controversy alone does not suggest unconstitutional discrimination or retaliation, and the City’s actions had a rational basis. The First Circuit vacated the dismissal of the state law tax claim (count VI) and remanded with instructions to dismiss that claim without prejudice, as the federal court declined to reach its merits after disposing of the federal claims. View "North End Chamber of Commerce, Inc. v. City of Boston" on Justia Law

Three children, through their representatives, brought claims against a religious organization, individual clergy, and others after their father, Paul Adams, sexually abused them over several years. During the abuse, Paul disclosed his actions to two bishops of his church—first in private meetings and then in a formal disciplinary council where other church members were present. The bishops considered these disclosures confidential under church doctrine and did not report Paul’s admissions to authorities. Years later, law enforcement discovered evidence of the abuse, leading to criminal charges against Paul and his wife. After learning about Paul’s prior disclosures to church officials, the children sued the church and the clergy for, among other things, failing to report the abuse as required by Arizona law.The Cochise County Superior Court granted summary judgment to the church defendants, holding that the bishops’ knowledge of the abuse came exclusively from confidential religious communications. The court found that, under Arizona’s reporting statute and the so-called “clergy exemption,” the bishops were not required to report the abuse because they determined withholding the information was “reasonable and necessary” under the concepts of their religion. The court also ruled that it was not the role of the court or a jury to second-guess the clergy’s interpretation of their religious doctrine.The Arizona Court of Appeals vacated the lower court’s decision, finding that genuine issues of material fact remained as to whether the communications were truly confidential, whether the clergy-penitent privilege was waived by the presence of non-clergy, and whether church doctrine actually required non-reporting.The Supreme Court of the State of Arizona reversed the court of appeals and reinstated summary judgment for the church defendants. The court held that the First Amendment prohibits courts and juries from examining whether clergy properly applied religious doctrine in deciding not to report abuse under the reporting statute. It further ruled that, absent fraud or collusion for secular purposes, factfinders must defer to a religious institution’s definitions of “confession,” “confidential communication,” and “clergy.” The court concluded that all statutory requirements for the clergy exemption were met and affirmed the trial court’s judgment. View "DOE v THE CORPORATION" on Justia Law

Several vape industry businesses and a vape user challenged a North Carolina law that restricts the sale of vape products lacking approval from the Food and Drug Administration (FDA). North Carolina’s statute, enacted in 2024, requires manufacturers to certify annually to the North Carolina Department of Revenue that their vape products either have FDA approval, were on the market by August 8, 2016 with a timely FDA application, or are exempt due to superficial changes. Products not listed in the resulting state directory cannot be sold in North Carolina, and violations can result in fines, product seizure, or lawsuits for deceptive trade practices.Before reaching the United States Court of Appeals for the Fourth Circuit, the plaintiffs sued North Carolina officials in the United States District Court for the Eastern District of North Carolina, arguing that the state law was preempted by federal law and violated the Equal Protection Clause. They sought a preliminary injunction to block enforcement of the law, relying only on the preemption argument. The district court denied the motion, finding that the plaintiffs had standing due to the threat of economic harm but were unlikely to succeed on the merits because the federal Tobacco Control Act did not preempt North Carolina’s regulation of vape product sales.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that the commercial plaintiffs had standing due to the risk of substantial economic harm from enforcement of the law. On the merits, the court concluded that North Carolina’s law was not preempted by the relevant federal statutes. The state law was found to regulate sales, an area expressly preserved for state regulation by the federal Tobacco Control Act’s savings clause, and did not amount to impermissible enforcement of the FDA’s exclusive authority under federal law. The denial of a preliminary injunction was therefore affirmed. View "Vapor Technology Association v. Wooten" on Justia Law

After a divorce in September 2024, one party engaged in a series of acts directed at the other, including making a sexually suggestive and violent Facebook post, slamming a metal mailbox while delivering a child support payment despite requests for direct deposit, and posting a “warning poster” in the other party’s neighborhood implying she was a “black widow.” The recipient of these actions, who had previously experienced the other party’s alcohol misuse, anger, suicidal statements, and gun ownership, filed for a protection from abuse order.The District Court in Rockland issued a temporary protection order and then, after a final hearing, found by a preponderance of the evidence that the actions constituted abuse under Maine law, specifically 19-A M.R.S. § 4102(1)(B) as amended in 2024. The court determined that the conduct placed the plaintiff in fear of bodily injury, and that the defendant consciously disregarded a substantial risk that his speech would cause such fear. The court issued a final protection order prohibiting contact. The defendant appealed, arguing that his conduct constituted protected speech under the First Amendment, referencing Counterman v. Colorado, 600 U.S. 66 (2023), and challenging the sufficiency of the evidence regarding recklessness and “true threats.”The Maine Supreme Judicial Court reviewed the case, applying clear error review to the trial court’s factual findings and de novo review to the First Amendment challenge. The court held that the trial court properly considered the context and history between the parties, and that sufficient evidence supported the finding that the defendant’s actions and communications amounted to a course of conduct that placed the plaintiff in reasonable fear of bodily injury, and that he acted recklessly. The judgment of the District Court was affirmed. View "Doe v. Weymouth" on Justia Law

The case concerns a defendant who was convicted in two separate matters in Hancock County, Maine. In the first, he was found guilty by a jury of several offenses, including domestic violence aggravated assault with a dangerous weapon, after an incident in June 2020 in which he assaulted his romantic partner in his home, engaged in multiple acts of violence, and threatened both her and her child. In the second, he entered a conditional guilty plea to tampering with a witness. The court sentenced him to concurrent terms totaling twenty-four years, with all but twenty-two years suspended, and six years of probation.After the trial, the defendant argued that the trial court erred in three main ways: (1) by denying him an evidentiary hearing regarding funds seized in an unrelated drug case, which he claimed violated his rights to counsel and due process; (2) by failing to provide a specific-unanimity jury instruction and denying his post-judgment request for a mental-condition examination; and (3) by increasing his sentence based on findings about firearms, his age, and his lack of acceptance of responsibility.The Maine Supreme Judicial Court found it lacked jurisdiction to review the issues related to the seized funds, as they were tied to a separate case. The Court held that no specific-unanimity instruction was required for the counts at issue, the trial court did not err in denying the request for a mental-condition examination, and the sentencing court properly considered the presence of firearms, the defendant’s age, and his lack of acceptance of responsibility. However, the Court concluded that certain counts should have been merged to avoid double jeopardy. The judgment was affirmed, but the sentence was vacated in part and the matter remanded for resentencing consistent with the required mergers. View "State of Maine v. Witham" on Justia Law

In 2024, Iowa enacted legislation (HF 2677) prohibiting the manufacture and sale of electronic nicotine delivery systems (ENDS) that had not received marketing authorization from the United States Food and Drug Administration (FDA). The law required manufacturers to certify their compliance with federal premarket approval requirements or demonstrate that their products were pending FDA review. Several manufacturers, retailers, and consumers challenged the law, contending it was preempted by federal law, specifically the Family Smoking Prevention and Tobacco Control Act, and that it violated constitutional equal protection guarantees.The United States District Court for the Southern District of Iowa granted a preliminary injunction, halting enforcement of the law. The district court found that at least one plaintiff had standing, was likely to succeed on the merits of the preemption claim, and was not required to post a security bond. It dismissed claims against the Iowa Department of Revenue based on Eleventh Amendment immunity but allowed the case to proceed against the Director in her official capacity. The Department voluntarily stayed enforcement while the litigation continued.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s order. The Eighth Circuit held that at least one retailer plaintiff had Article III standing, as they plausibly alleged injury from the credible threat of enforcement. However, the appellate court concluded the plaintiffs were not likely to succeed on the merits of their preemption claim. The court determined that HF 2677 was not preempted by federal law, as it fell within the scope of the Tobacco Control Act’s savings clause, which permits state requirements relating to the sale and distribution of tobacco products. The Eighth Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Iowans for Alternatives v. Mosiman" on Justia Law

Arkansas enacted Act 372 in 2023, which criminalizes furnishing materials deemed “harmful to minors” and requires public libraries to adopt written policies for curating their collections and responding to challenges about appropriateness. Plaintiffs, including libraries, bookstores, and patrons, filed suit against Arkansas officials, alleging that these provisions violated the First Amendment due to overbreadth and the Fourteenth Amendment due to vagueness, before the act took effect.The United States District Court for the Western District of Arkansas granted summary judgment for the plaintiffs. The court permanently enjoined enforcement of both challenged sections, finding them unconstitutional as overbroad and void for vagueness, and awarded nearly $450,000 in attorney fees and costs. Defendants, including prosecuting attorneys and the Attorney General, appealed.The United States Court of Appeals for the Eighth Circuit reviewed the appeal de novo. The court found that the librarian and bookstore plaintiffs had standing to challenge the criminal provision, but patrons lacked standing regarding the library policy requirement, as no concrete injury was shown. The court determined the challenges to the criminal provision were ripe. On the merits, the court held that the criminal section was not unconstitutionally overbroad, as plaintiffs failed to provide evidence of substantial unconstitutional applications among third parties, and the record did not establish a lopsided ratio of impermissible to permissible applications. The court also held the provision was not void for vagueness because its language was commonly understood and included scienter requirements. Ultimately, the court reversed the district court’s judgment, vacated its permanent injunction, and vacated the award of attorney fees and costs. View "Fayetteville Public Library v. Murray" on Justia Law

A man was cited and charged in the Salt Lake City Justice Court after allegedly causing a car accident while driving under the influence of alcohol. The charges included a class B misdemeanor for DUI, as well as other related offenses. Several months after the charges were filed, the defendant attempted to plead guilty, but the City refused to consent, invoking a state law requiring prosecutorial approval for guilty pleas in DUI cases. The justice court declined to accept his plea without the City’s consent.The defendant then moved the justice court to declare the prosecutorial consent law unconstitutional, arguing it violated Utah’s separation of powers doctrine and his due process rights. While this motion was pending, the Salt Lake County District Attorney filed enhanced, felony-level charges against him in the district court. The City moved to dismiss the justice court case without prejudice, and the justice court denied the defendant’s constitutional challenge, finding no violation of the separation of powers and concluding the due process argument was inadequately briefed. The case in the justice court was dismissed without prejudice.The Supreme Court of the State of Utah reviewed the defendant’s petition for extraordinary relief. The court found that the defendant had properly invoked its authority for relief under Utah Rule of Appellate Procedure 19 regarding the separation of powers claim, since no direct appeal was available. However, the court declined to reach the merits or grant relief, holding that the defendant had not shown he was likely to benefit from a favorable ruling because felony charges were already pending in district court and it was speculative that the justice court would accept his guilty plea. The court also rejected the due process challenge, finding the defendant had not addressed the justice court’s basis for rejection. The petition for extraordinary relief was denied. View "Adams v. Hon. Robison" on Justia Law

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