Justia Constitutional Law Opinion Summaries

A retired public employee who was a participant in the Oklahoma Public Employees Retirement System (OPERS) filed suit against the State Treasurer, challenging the constitutionality of the Energy Discrimination Elimination Act of 2022 (EDEA). The EDEA required companies doing business with the state to certify they do not boycott energy companies, and it compelled state entities, including OPERS, to divest from financial companies that used ESG (environmental, social, and governance) principles if those companies were deemed to boycott energy companies. The plaintiff claimed the Act violated several provisions of the Oklahoma Constitution, particularly the requirement that public retirement system funds be used solely for exclusive purposes related to the retirement system.The District Court for Oklahoma County granted summary judgment for the plaintiff, issuing a permanent injunction preventing the Treasurer from enforcing the EDEA with respect to OPERS. The court found the Act violated multiple constitutional provisions, including the exclusive purpose clause of Article XXIII, §12 of the Oklahoma Constitution. The Treasurer appealed directly to the Supreme Court of the State of Oklahoma, and the Supreme Court retained the appeal.The Supreme Court of the State of Oklahoma held that the plaintiff’s death after the case was submitted did not deprive the Court of jurisdiction. The Court concluded the plaintiff had standing as a retiree with a direct interest in OPERS. Most significantly, the Court determined that the EDEA is unconstitutional in its entirety when applied to OPERS, because it creates a dual purpose for retirement system funds, contrary to the exclusive purpose mandated by Article XXIII, §12 of the Oklahoma Constitution. The Supreme Court affirmed in part the District Court’s judgment, upholding the permanent injunction against enforcement of the EDEA as applied to OPERS. View "KEENAN v. RUSS" on Justia Law

This case involves several dialysis providers, a nonprofit organization, and individual patients challenging a California law (AB 290) aimed at regulating relationships between dialysis providers and nonprofits that assist patients with health insurance premiums. The law was enacted due to concerns that providers were donating to nonprofits to help keep patients on private insurance, which led to higher reimbursements for providers compared to public insurance. Key provisions of the law included capping provider reimbursements if they had a financial relationship with a nonprofit offering patient assistance, requiring disclosure of patients receiving such assistance, restricting nonprofits from conditioning assistance on patient treatment choices, mandating disclosure to patients of all insurance options, and a safe harbor for seeking federal advisory opinions.The United States District Court for the Central District of California granted in part and denied in part motions for summary judgment. It upheld the constitutionality of the reimbursement cap, coverage disclosure requirement, and safe harbor provision, but found the anti-steering, patient disclosure, and financial assistance restriction provisions unconstitutional. The district court also ruled that the unconstitutional parts were severable from the remainder of the statute and rejected claims that federal law preempted the state law.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the reimbursement cap, patient disclosure requirement, and financial assistance restriction violated the First Amendment because they burdened the rights of expressive association and were not narrowly tailored to serve the state’s interests. The court found the coverage disclosure requirement constitutional under the standard for compelled commercial speech, as it required only factual, uncontroversial information reasonably related to a state interest. However, it concluded that the unconstitutional provisions were not severable from the coverage disclosure requirement. The court also held challenges to the safe harbor provision moot. The court affirmed in part, reversed in part, and each party was ordered to bear its own costs. View "DOE V. BONTA" on Justia Law

The defendant, a patient at a community mental health center, was informed by his career counselor that he had been dismissed from classes at UNH Manchester and would be removed by security if he returned to campus. Distressed by this news, he insisted he would still attend his evening class. In communications with his counselor and later his therapist, he reiterated his plan to attend, culminating in a statement asking if “doing a mass shooting” would be required for him to get what he wanted. When told his statement would be reported, he claimed it was a figure of speech. The counselor reported his comments to the treatment team and local police, in accordance with center policy. Law enforcement notified UNH Manchester, which took security precautions, and later apprehended the defendant. He was indicted for criminal threatening based on his statements.Prior to trial in the Superior Court, the defendant sought to exclude the testimony of his counselor and therapist regarding his statements, asserting the therapist-patient privilege, and also moved to dismiss for insufficiency of the evidence. The Superior Court denied both motions, finding an “essential need” for the privileged communications and concluding that a reasonable jury could find the defendant guilty. The jury convicted the defendant of criminal threatening.On appeal, the Supreme Court of New Hampshire reviewed whether the trial court properly allowed admission of the privileged communications and whether the evidence was sufficient for conviction. The court held that the State demonstrated an “essential need” to pierce the therapist-patient privilege due to the centrality of the communications to the charged offense and the compelling public safety interest in investigating threats of mass violence. The court also found the evidence sufficient for a rational jury to conclude beyond a reasonable doubt that the defendant acted in reckless disregard for causing fear, terror, or public inconvenience. The conviction was affirmed. View "State v. Stewart" on Justia Law

A police officer stopped a vehicle after observing what appeared to be a nonfunctional headlight. During the stop, the officer asked the driver for his license, but the driver stated he did not have it and instead provided his name, date of birth, and Social Security number. Soon after, the officers realized the headlight was actually working, but the stop continued so the officer could verify the driver’s information. Dispatch reported that the driver had failed to reinstate his license and had an outstanding warrant. The driver was then arrested, and a search of the vehicle uncovered drugs and a scale, leading to felony charges.In the Cuyahoga County Court of Common Pleas, the defendant’s motion to suppress the evidence was denied. The defendant then entered a no-contest plea and was convicted. On appeal, the Eighth District Court of Appeals reversed the convictions, finding that the officer should have ended the stop once it became clear the headlight was operational. The appellate court held that continuing to detain the defendant after the original reason for the stop was dispelled rendered the subsequent search and evidence unlawful.The Supreme Court of Ohio reviewed the case. It held that, under the Fourth Amendment, an officer may verify a driver’s license status as part of the mission of a lawfully initiated traffic stop, even if the suspicion that justified the stop is later dispelled. The court further held that the driver’s failure to produce a license provided new reasonable suspicion to extend the stop and investigate whether he was unlicensed. Therefore, the Supreme Court of Ohio reversed the judgment of the Eighth District Court of Appeals and remanded the case for further proceedings. View "State v. Fips" on Justia Law

William Walls was found by an Illinois state court to be a sexually violent person in 2015, leading to his civil commitment under Illinois law. The commitment was based, in part, on statements he made or that were made by his treatment providers while he was incarcerated for a prior sexual assault conviction. Walls has argued that these statements were obtained in violation of his constitutional rights. After his commitment, his case involved extensive delays, including a twelve-year period before the initial commitment decision and seven years before the state appellate court resolved the appeal filed by his counsel.After the 2015 commitment order, Walls—sometimes proceeding pro se despite being represented—filed a series of appeals and petitions. The Illinois Appellate Court eventually affirmed both the 2015 and a subsequent 2018 recommitment decision in a consolidated opinion. Walls’s first federal habeas petition under 28 U.S.C. §2254 was dismissed by the United States District Court for the Central District of Illinois on procedural default grounds. He did not appeal that dismissal. After the 2018 recommitment proceeding, Walls filed a second federal habeas petition, which was dismissed as an unauthorized successive petition under 28 U.S.C. §2244(b) because it challenged the same 2015 order or did not raise new claims as required.The United States Court of Appeals for the Seventh Circuit reviewed Walls’s appeal of the district court’s dismissal. The court held that, to the extent Walls was once again contesting the 2015 commitment order, his petition was barred as a successive habeas application. Alternatively, if he was challenging later decisions, he had failed to raise or exhaust federal claims relating to those decisions. The Seventh Circuit affirmed the district court’s dismissal of Walls’s petition. View "Walls v Posey" on Justia Law

After his wife disappeared in May 2020, the plaintiff became the primary suspect in her case. Significant evidence was collected, and law enforcement focused on the possibility that he had staged the scene to make it appear as an abduction. Despite his consistent claims of innocence and multiple meetings with investigators, prosecutors charged him with first-degree murder in May 2021, even though his wife's body had not been found. Before trial, the defense discovered that prosecutors had withheld exculpatory evidence, leading the State to dismiss charges without prejudice. The plaintiff then filed a federal civil rights lawsuit against various officials involved in his arrest and prosecution, alleging fabrication of evidence, conspiracy, malicious prosecution, and related claims.The United States District Court for the District of Colorado reviewed the complaint, the lengthy arrest affidavit, and the parties' arguments. It granted the defendants' motions to dismiss under Rule 12(b)(6), finding that the plaintiff’s allegations failed to plausibly allege an absence of probable cause for his arrest and prosecution. The court noted the presence of extensive inculpatory facts and determined that the complaint did not sufficiently link individual defendants to the alleged misconduct. Certain claims were also dismissed as conclusory, and some defendants were found to have immunity. The court declined to exercise supplemental jurisdiction over the remaining state law claims.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s dismissal. The Tenth Circuit held that the plaintiff’s federal claims for malicious prosecution, fabrication of evidence under the Fourth Amendment, Franks violations, conspiracy, failure to intervene, and municipal liability all required plausible allegations that probable cause was lacking, which the complaint did not provide. The court also found the Fourteenth Amendment claims for fabrication of evidence and reckless investigation deficient due to lack of causal allegations. The judgment of dismissal was affirmed. View "Morphew v. Chaffee County" on Justia Law

DEA agents recruited a drug trafficker, Michael Allen, as a confidential source and discovered Allen was obtaining heroin and cocaine from Joseph McNoriell. Working with agents, Allen arranged a purchase of two kilograms of cocaine from McNoriell in a controlled operation. Shortly before the planned arrest, Allen, without law enforcement’s knowledge, purchased heroin from McNoriell to avoid suspicion. Agents recorded Allen’s subsequent calls with McNoriell arranging the cocaine transaction. On the day of the planned purchase, law enforcement surveilled McNoriell and two co-conspirators, stopped their vehicles, and recovered two kilograms of cocaine.A grand jury indicted McNoriell for conspiracy to distribute heroin and cocaine and possession with intent to distribute cocaine. Throughout proceedings in the United States District Court for the Western District of Michigan, McNoriell changed attorneys multiple times and eventually elected to represent himself, with standby counsel appointed. Pretrial, the court conducted Faretta hearings to ensure McNoriell’s waiver of counsel was knowing and voluntary and allowed him to determine the division of trial responsibilities with standby counsel, including decisions about participation in sidebar conferences. At trial, McNoriell and his standby counsel shared duties such as cross-examination and objections. The jury convicted McNoriell on both counts, finding each involved at least 500 grams of cocaine. The court imposed a 110-month sentence, including a leadership enhancement over McNoriell’s objection.On appeal, the United States Court of Appeals for the Sixth Circuit addressed McNoriell’s claims regarding exclusion from sidebar conferences, duplicity of the indictment, admission of certain testimony and text messages, interpretation of recorded calls, and the leadership enhancement at sentencing. The court held there was no violation of McNoriell’s constitutional rights due to his acquiescence to hybrid representation, no prejudicial duplicity in the indictment, no plain error in admitting testimony or text messages, and no error in interpreting communications or applying the sentencing enhancement. The Sixth Circuit affirmed the district court’s judgment. View "United States v. McNoriell" on Justia Law

KalshiEX LLC operates a federally licensed designated contract market (DCM) that allows users to trade event contracts, including those based on sports outcomes. In late 2024, after Kalshi began offering sports-related event contracts similar to those offered by a competitor, New Jersey issued a cease-and-desist letter. The state asserted that Kalshi’s activities violated the New Jersey Constitution and state gambling laws, particularly regarding betting on collegiate sports, and threatened legal action with significant penalties if Kalshi continued its operations within New Jersey.In response, Kalshi initiated proceedings in the United States District Court for the District of New Jersey, seeking a preliminary injunction to prevent enforcement of New Jersey’s gambling laws against its federally regulated contracts. The District Court granted the injunction, finding that Kalshi had a reasonable likelihood of success on the merits, would suffer irreparable harm without relief, and that the public interest favored enjoining enforcement of potentially preempted state law. New Jersey appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error, legal conclusions de novo, and the decision to grant the preliminary injunction for abuse of discretion. The Third Circuit affirmed the District Court’s order. The appellate court held that the Commodity Exchange Act (CEA) grants the Commodity Futures Trading Commission (CFTC) exclusive jurisdiction over swaps, including sports-related event contracts traded on CFTC-licensed DCMs. Both field and conflict preemption principles bar New Jersey from enforcing its gambling laws against these contracts. The court concluded that Kalshi demonstrated a likelihood of success on the preemption claim, irreparable harm in the absence of an injunction, and that the equities and public interest favored injunctive relief. Accordingly, the court affirmed the preliminary injunction. View "Kalshiex LLC v. Flaherty" on Justia Law

Several educators, parents, students, and a nonprofit organization challenged two provisions of an Iowa law affecting public schools. The law restricts classroom instruction on gender identity and sexual orientation for students in kindergarten through sixth grade and requires school officials to notify parents if a student requests accommodations affirming their gender identity, such as using a different pronoun. The plaintiffs, asserting facial constitutional challenges, argued the provisions were overbroad and vague, infringing on First Amendment and due process rights.Previously, the United States District Court for the Southern District of Iowa granted a preliminary injunction against these provisions. The district court found that the terms “program” and “promotion” in the instruction restriction were overly broad and infringed on protected speech, and determined that the parental notification law was impermissibly vague due to the undefined use of “accommodation.” The district court severed what it considered unconstitutional portions of the statutes and enjoined their enforcement.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. It held that the statutes, when read with the canon of constitutional avoidance, could reasonably be interpreted in a way that avoided constitutional problems and that the statutory language was sufficiently clear. The appellate court found the plaintiffs did not demonstrate that unconstitutional applications of the laws substantially outweighed constitutional ones in their facial challenge. It further determined that the term “accommodation” was not unconstitutionally vague. The Eighth Circuit concluded that the district court abused its discretion in granting the preliminary injunction and vacated that injunction as to all challenged provisions, remanding the case for further proceedings on the merits. View "Iowa Safe Schools v. Reynolds" on Justia Law

A group of plaintiffs, including publishers, authors, educators, and a parent of a student, challenged provisions of an Iowa law (Senate File 496) requiring public school libraries to remove books containing “descriptions or visual depictions of a sex act.” The law also imposed penalties on educators who failed to comply. The plaintiffs argued that these provisions violated their First Amendment rights, both as to students’ access to information and as to the right of authors and publishers to communicate with their intended audience.The United States District Court for the Southern District of Iowa initially granted a preliminary injunction, preventing enforcement of the challenged provisions. The court concluded that the plaintiffs were likely to prevail, holding that the unconstitutional applications of the law substantially outweighed constitutional ones. It declined to apply the standard set out in Hazelwood School District v. Kuhlmeier, instead relying on the obscenity standard from Ginsberg v. State of New York and the “substantial and reasonable government interest” test from the plurality in Board of Education, Island Trees Union Free School District No. 26 v. Pico.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. The Eighth Circuit held that the Hazelwood standard—whether the restrictions are “reasonably related to legitimate pedagogical concerns”—applies to school library curation. The court determined that the Iowa law’s book restrictions addressed legitimate pedagogical concerns and were neither amorphous nor unreasonable. Because the plaintiffs could not show a likelihood of success on the merits under the correct standard, the Eighth Circuit vacated the preliminary injunction and remanded the case for further proceedings on the merits. View "Penguin Random House, LLC v. Robbins" on Justia Law