Justia Constitutional Law Opinion Summaries

Several property owners in New Braunfels, Texas, challenged a city zoning ordinance that prohibits short-term rentals in residential districts. The ordinance, originally enacted in 2006 and amended in 2011, was in place prior to the appellants’ purchase of their properties. Despite knowing about the restrictions, the appellants either engaged in or sought to engage in short-term rental activities and, after being denied zoning changes to permit such use, filed suit against the city. Their claims alleged the ordinance violated the Due Process and Equal Protection Clauses of both the United States and Texas Constitutions.The United States District Court for the Western District of Texas initially dismissed the appellants’ claims under Rule 12(b)(6). The United States Court of Appeals for the Fifth Circuit, in a prior decision, vacated and remanded, allowing the appellants to proceed to discovery. After discovery, both parties moved for summary judgment. The district court again ruled in favor of the city, granting summary judgment on all claims. The appellants then sought review of this decision.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The court held that Texas law does not recognize a protected property interest in the right to lease one’s home on a short-term basis, which is required for a due process claim. It further found that the ordinance’s restrictions on short-term rentals survive rational-basis review under the Equal Protection Clause, as the city’s goal of preserving the residential character of neighborhoods is a legitimate government interest, and the line drawn between short-term and longer-term rentals was not arbitrary. Accordingly, the court found no constitutional violation and affirmed the summary judgment in favor of the city. View "Marfil v. City of New Braunfels" on Justia Law

After law enforcement arrested the defendant for unlawfully discharging a firearm, they executed a search warrant at his home. During the search, officers seized multiple firearms, suspected silencers, and other related paraphernalia. The Bureau of Alcohol, Tobacco, Firearms, and Explosives evaluated the items and determined the suspected silencers met the statutory definition of devices designed for silencing, muffling, or diminishing the report of a firearm. The defendant admitted to manufacturing and possessing the silencers.A federal grand jury charged the defendant with possession of unregistered firearms, specifically silencers, in violation of 26 U.S.C. § 5861(d), and possession of a firearm without a serial number under 26 U.S.C. § 5861(i). He moved to dismiss the indictment, arguing that both statutes violated the Second Amendment facially and as applied to him. The United States District Court for the Western District of Louisiana denied the motion, finding silencers to be “dangerous and unusual weapons” not protected by the Second Amendment. The defendant then entered a conditional guilty plea, reserving his right to appeal the constitutional issue, and was sentenced to twenty-four months in prison and three years of supervised release.Reviewing the appeal, the United States Court of Appeals for the Fifth Circuit applied de novo review to the preserved constitutional questions. The court acknowledged that, per Supreme Court precedent, silencers qualify as Second Amendment “Arms.” However, in light of United States v. Peterson, 161 F.4th 331 (5th Cir. 2025), the Fifth Circuit held that the National Firearms Act’s shall-issue regime for silencer registration is presumptively lawful unless a challenger shows it has been put toward abusive ends, such as through exorbitant fees or lengthy delays. Because the defendant did not allege such abuse, the court held that § 5861(d) did not violate his Second Amendment rights and affirmed the conviction. View "USA v. Comeaux" on Justia Law

The case concerns a challenge to Ohio’s Parental Notification by Social Media Operators Act, which requires operators of certain social media platforms to obtain verifiable parental consent before unemancipated children under sixteen can enter into contracts to use their services. The Act defines covered operators based on features such as enabling social interaction, profile creation, and content sharing, and details factors to determine whether a site targets or is likely to be accessed by minors. The law imposes civil penalties for non-compliance and grants enforcement authority to the Ohio Attorney General.When the Act was set to take effect, NetChoice, LLC—a trade association representing major online platforms—sued the Ohio Attorney General in the United States District Court for the Southern District of Ohio. NetChoice argued the Act was unconstitutional on First Amendment and vagueness grounds, asserting that it would chill protected speech and was impermissibly vague about which platforms were covered. The district court agreed, finding that NetChoice had standing, that the Act was a facially unconstitutional content-based restriction on speech that failed strict scrutiny, and that it was unconstitutionally vague. The court permanently enjoined enforcement of the Act.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s judgment. The appellate court held that NetChoice lacked third-party standing to assert the First Amendment rights of its members’ minor users due to a conflict of interest between the trade group and the affected minors. The court further found that, even considering NetChoice’s own First Amendment and vagueness claims, NetChoice failed to show the Act was facially unconstitutional. The Sixth Circuit held that the Act, while content-based and subject to strict scrutiny, was narrowly tailored to compelling state interests in protecting children and was not impermissibly vague in all its applications. The case was remanded for entry of judgment in favor of the Attorney General. View "NetChoice, LLC v. Yost" on Justia Law

A Michigan-based real estate developer and related parties sought to redevelop a commercial property in the City of Pontiac to include medical marijuana cultivation and processing facilities. After purchasing the property in 2019, the developer obtained rezoning approval from the city, but the process of securing required permits and special exceptions for tenants became protracted. The city clerk cited deficiencies in tenant applications and, at one point, argued that the project violated city ordinances regarding overlay districts for marijuana businesses. Despite eventual approvals—including a court order requiring the city to issue permits—the tenants withdrew due to the delays, and the project collapsed. Subsequently, the developer’s affiliate lost another business opportunity, which plaintiffs attributed to city officials’ retaliation.The plaintiffs filed suit in Oakland County Circuit Court, seeking injunctive, declaratory, and monetary relief, and later brought civil rights claims under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan. The district court granted summary judgment for the city and the city clerk, finding insufficient evidence of constitutional violations and concluding that the delays and alleged retaliation did not violate the plaintiffs’ rights.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The court held that the plaintiffs lacked a cognizable property interest under the Due Process Clause because city approval for marijuana facilities was discretionary, not a matter of right. The court also found that the delays did not constitute a “taking” under the Fifth Amendment, as the length and nature of the delays were not extraordinary. The equal protection claim failed for lack of evidence that similarly situated applicants were treated more favorably. Finally, the court determined that the plaintiffs’ First Amendment retaliation claim could not proceed against the city because the mayor lacked final policymaking authority over zoning and no municipal policy or custom was established. View "Rubicon Real Estate Holdings v. City of Pontiac" on Justia Law

Dusty Ray Spencer was convicted of murdering his wife, Karen Spencer, in 1992. The incident involved a series of violent altercations in the weeks preceding the murder, culminating in Spencer attacking Karen in their backyard, inflicting fatal stab wounds and blunt force trauma. Karen’s teenage son, Timothy Johnson, witnessed and attempted to intervene during both the January 4 and January 18 attacks. Spencer was apprehended and tried, with the jury recommending the death penalty by a seven-to-five vote.Following conviction, the trial court sentenced Spencer to death. On direct appeal, the Supreme Court of Florida affirmed the conviction but vacated the death sentence due to improper consideration of aggravating and mitigating factors, remanding for reconsideration. After further proceedings, the trial court again imposed the death penalty, which the Supreme Court of Florida affirmed. Spencer’s subsequent collateral attacks on his conviction and sentence in both state and federal courts were unsuccessful. In May 2026, nearly three decades after his sentence became final, Governor DeSantis signed Spencer’s death warrant, prompting Spencer to file a third successive motion for post-conviction relief and a request for a stay of execution.The Supreme Court of Florida reviewed the trial court’s summary denial of Spencer’s latest motion. The Court held that Spencer’s claims—challenging the lethal injection protocol based on alleged deviations and his cirrhosis, and asserting a categorical exemption from execution due to his advanced age—were untimely and without legal merit. The Court found that Spencer failed to demonstrate any exception to the one-year filing requirement, did not meet the legal standard for a method-of-execution claim, and was foreclosed from relief based on age. The Supreme Court of Florida affirmed the trial court’s denial of post-conviction relief and declined to stay the execution. View "Spencer v. State" on Justia Law

Several members of the public submitted requests to a large social media company seeking information about political advertisements displayed on its platforms to users in Washington State. The company did not dispute that its responses to these requests failed to comply with Washington’s Fair Campaign Practices Act (FCPA) and the law’s implementing regulations, as it did not provide all the required information. The State of Washington, through the Attorney General’s Office, filed suit against the company, alleging multiple violations of the FCPA’s disclosure requirements.The case was heard in King County Superior Court, where both sides moved for summary judgment. The trial court granted summary judgment for the State, holding the company liable for violating the FCPA, and imposed maximum statutory penalties for each advertisement for which the required information was not disclosed. The court found the violations to be intentional, trebled both the civil penalties and attorney fees, and granted an injunction. On appeal, the Washington Court of Appeals affirmed the trial court’s rulings on liability, statutory interpretation regarding penalty calculation, and the constitutionality of the penalty assessed.Before the Supreme Court of the State of Washington, the company argued that the FCPA’s disclosure requirements violate the First Amendment as applied, that the penalty was improperly calculated, and that the penalty violated the Eighth Amendment’s excessive fines clause. The Supreme Court, with no single majority opinion, affirmed the company’s liability under the FCPA, holding that the law as applied does not violate the First Amendment. The court also let the penalty judgment stand, as no majority view existed to reverse or modify it, and further held by a majority that the penalty does not violate the Eighth Amendment. Thus, the judgment of the Court of Appeals was affirmed, upholding both the liability finding and the civil penalty. View "State v. Meta Platforms, Inc." on Justia Law

A group of former and sitting justices of New York State courts challenged the constitutionality of the mandatory judicial retirement age imposed by article VI, § 25 (b) of the New York State Constitution, which requires judges to retire at age 70, with a certification process allowing some to serve until age 76. Petitioners argued that this age limit was implicitly repealed by the 2024 Equal Rights Amendment (ERA), which amended article I, § 11 to prohibit discrimination based on age, among other characteristics, in civil rights.The proceeding was brought as a hybrid article 78 and declaratory judgment action against the State of New York and the Office of Court Administration. Supreme Court denied petitioners’ request for preliminary relief and dismissed the petition, granting the State’s cross-motion. The Appellate Division, First Department, affirmed the dismissal, holding that the ERA did not implicitly repeal the mandatory retirement provision. The Appellate Division found no reference in the ERA to judicial eligibility or retirement age and concluded that the ERA and article VI, § 25 (b) addressed different subject matters and could be harmonized. The court declined to address whether strict scrutiny applies to age-based classifications or whether the ERA made article I, § 11 self-executing.On appeal, the New York State Court of Appeals reviewed whether article VI, § 25 (b) was implicitly repealed by the ERA. The Court of Appeals held that repeal by implication is disfavored and that the two provisions are not antagonistic, operating independently. The Court concluded that article VI, § 25 (b) remains in effect and was not repealed or invalidated by the ERA. Accordingly, the Court of Appeals affirmed the Appellate Division’s order dismissing the petition. View "Miller v State" on Justia Law

The defendant was indicted for first-degree sexual assault following an incident in March 2021. The complainant testified that she was invited to a social gathering by the defendant, consumed alcohol throughout the night, and later awoke in an unfamiliar motel room unable to move, where she observed the defendant engaging in sexual acts against her will. The complainant denied consenting to sexual activity or going to the motel. A motel employee corroborated that the complainant appeared intoxicated, and forensic testing on her clothing and swabs revealed DNA consistent with the defendant. The defendant conceded to sexual intercourse but claimed it was consensual.The case was tried before the Kent County Superior Court, where a jury heard testimony from the complainant, witnesses, and forensic experts. The laboratory supervisor who reviewed and approved the DNA analysis, but did not perform the testing herself, testified regarding the DNA findings. The defendant moved to strike her testimony, arguing it violated his right to confront the analyst who performed the testing, relying on Supreme Court precedents. The trial justice denied the motion, referencing prior Rhode Island Supreme Court decisions permitting supervisory analysts to testify.On appeal, the Supreme Court of Rhode Island reviewed whether the defendant properly preserved his Confrontation Clause objection and whether an intervening Supreme Court decision, Smith v. Arizona, warranted a departure from the raise-or-waive rule. The Court held that the defendant’s objection was not based on a novel rule of law and was untimely, as prior precedent already addressed the issue. The Court concluded that the intervening decision did not alter existing controlling law and affirmed the Superior Court’s judgment of conviction. View "State v. Vasquez" on Justia Law

Ali Hemani, a dual citizen of the United States and Pakistan, lived in Texas with his parents and maintained steady employment. In 2022, federal agents searched his home based on suspicions of terrorism-related activity. Hemani cooperated fully with law enforcement, surrendering a firearm and marijuana found on the property, and admitted during an interview that he used marijuana about every other day. Several months later, the government charged Hemani under 18 U.S.C. §922(g)(3) for possessing a gun while being an unlawful user of a controlled substance, relying solely on his admitted marijuana use.The United States District Court for the Northern District of Texas granted Hemani’s motion to dismiss the indictment, finding the prosecution violated his Second Amendment rights. The government appealed, but the United States Court of Appeals for the Fifth Circuit affirmed the dismissal, prompting the government to seek review from the Supreme Court.The Supreme Court of the United States reviewed whether the government’s prosecution of Hemani under §922(g)(3) was consistent with the Second Amendment. The Court held that the government’s automatic ban on firearm possession for anyone who regularly uses a controlled substance, without individualized proof of dangerousness or any pre-deprivation process, is inconsistent with the Second Amendment’s protections. The government failed to demonstrate that §922(g)(3), as applied, was sufficiently analogous to historical regulations targeting habitual drunkards, which operated for different reasons, targeted different groups, and provided procedural safeguards. The Court’s decision is narrow, addressing only the automatic application of the statute to regular drug users without further showing. The judgment of the Fifth Circuit was affirmed. View "United States v. Hemani" on Justia Law

Hunter was charged with ten counts of bank and wire fraud, involving a scheme that cost financial institutions approximately $500,000. He entered a written plea agreement with the government, pleading guilty to one count of aiding and abetting wire fraud. In exchange, the government dismissed the other nine charges and agreed not to prosecute Hunter for related conduct in the future. The plea agreement contained an appeal waiver, barring him from appealing his conviction and sentence, except for claims of ineffective assistance of counsel. The agreement stipulated that any modification must be in writing and signed by all parties. At sentencing, the District Court imposed 51 months’ imprisonment and three years of supervised release, including a requirement that Hunter participate in a mental-health treatment program and take any prescribed medications. Hunter objected to the medication condition, but the District Court stated he could address any disputes with the probation officer or the court. At the conclusion of sentencing, the court erroneously informed Hunter that he had a right to appeal, without objection from either party.Hunter appealed, challenging the mandatory-medication condition as violating his fundamental due process rights. The government moved to dismiss the appeal based on the plea agreement’s waiver. Hunter conceded he had knowingly and voluntarily signed the waiver, but argued it was unenforceable because the sentence allegedly infringed on a fundamental constitutional right and that the District Court’s statement at sentencing, coupled with the prosecutor’s silence, voided the waiver. The United States Court of Appeals for the Fifth Circuit dismissed the appeal, holding that the District Court’s misstatement did not invalidate the waiver and that Fifth Circuit precedent permitted appeals despite a waiver only in cases of ineffective assistance of counsel or sentences exceeding the statutory maximum.The Supreme Court of the United States held that an appeal waiver is unenforceable when its enforcement would result in a miscarriage of justice—specifically, when it would leave in place an egregious error undermining the judicial system’s integrity. The Court vacated the Fifth Circuit’s judgment and remanded the case for consideration under this miscarriage-of-justice standard. View "Hunter v. United States" on Justia Law