Justia Constitutional Law Opinion Summaries

An eight-year-old child, N.R., alleged that her father, Gerald Roberson, had sexually abused her over several years, with the most recent incident occurring two months before she was taken by her mother to a hospital for a sexual assault examination. While the examination found no physical evidence of abuse, N.R. gave a detailed statement about repeated abuse and indicated that Roberson threatened her to keep her silent. Roberson was charged with multiple serious offenses relating to sexual abuse of a child.The State moved before trial to allow N.R. to testify remotely using closed-circuit television (CCTV), citing a Delaware statute permitting such testimony for children under certain conditions. After a hearing that included expert testimony from N.R.’s counselor about the child’s fear and likely inability to communicate in her father’s presence, the Superior Court found that remote testimony was warranted and that the statute permitting it did not violate the Delaware Constitution. The court also denied Roberson’s request for a limiting instruction after the prosecutor, during closing arguments, asked the jury to consider why a child would endure the ordeal of reporting and testifying if her claims were untrue. The jury convicted Roberson on all counts, and he was sentenced to 125 years in prison.The Supreme Court of the State of Delaware reviewed whether the statutory procedure allowing child witnesses to testify by CCTV violated the state constitutional right to confront witnesses “face to face,” and whether the prosecutor’s closing argument constituted impermissible vouching for the witness’s credibility. The Court held that the statute does not violate the Delaware Constitution, relying on precedent that interprets the confrontation right to allow such procedures in the interest of protecting child victims while preserving the defendant’s right to cross-examination. The Court also found that the prosecutor’s comments did not amount to misconduct. The judgment of the Superior Court was affirmed. View "Roberson v. State" on Justia Law

A 13-year-old male student at a Virginia Beach middle school received a sexually explicit photo from a female classmate and, several months later, showed the image to other students during the school day. After teachers reported the incident, the assistant principal removed the student from class, questioned him, and searched his phone’s photo gallery. The school resource police officer was notified and began a criminal investigation. The student ultimately showed the explicit photo to the officer, was read his Miranda rights, arrested, and charged in juvenile court with possession of child pornography. The juvenile court found sufficient evidence for guilt but deferred disposition; the charge was dismissed after the student completed court-imposed conditions.The student, through his mother and later counsel, sued the assistant principal, the school resource officer, the Virginia Beach School Board, and the City of Virginia Beach in the United States District Court for the Eastern District of Virginia. He alleged violations of his Fourth, Fifth, and Fourteenth Amendment rights, as well as conspiracy and Monell claims. The district court granted summary judgment to all defendants, finding the phone search reasonable under New Jersey v. T.L.O., the confession voluntary, no evidence of unlawful conspiracy, and no underlying constitutional violations to support Monell liability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that the assistant principal’s search of the student’s phone was justified at its inception and reasonable in scope under T.L.O., and that Riley v. California did not displace this standard in the school context. The court also held the student’s confession was voluntary under the Fifth and Fourteenth Amendments, found no evidence of a conspiracy to violate constitutional rights, and determined Monell liability could not attach absent an underlying constitutional violation. The court therefore affirmed summary judgment for all defendants. View "O.W. v. Carr" on Justia Law

The case concerns a man convicted of the 1989 murders of his girlfriend and her daughter in Arizona. He was found guilty by a jury and subsequently sentenced to death by a judge. The sentencing judge identified multiple aggravating factors, including the especially cruel nature of the crimes, multiple victims, and prior violent felonies. The judge also found statutory and non-statutory mitigating factors, such as the defendant’s impaired capacity, troubled childhood, and psychological issues. After his conviction and sentencing were affirmed on direct appeal by the Arizona Supreme Court, the defendant sought postconviction relief in state court through three separate petitions. His first petition did not raise an ineffective assistance of counsel (IAC) claim and was handled by counsel later conceded to be ineffective. A second petition, raising the IAC claim, was denied as untimely. A third petition argued he was intellectually disabled and therefore ineligible for execution, but that claim was rejected after an evidentiary hearing.In federal court, the petitioner’s IAC claim was initially deemed procedurally defaulted by the United States District Court for the District of Arizona. Subsequent Supreme Court and Ninth Circuit decisions, including Martinez v. Ryan, allowed for the possibility that ineffective postconviction counsel could excuse such defaults. The Ninth Circuit originally remanded for an evidentiary hearing, but the United States Supreme Court reversed, holding that federal courts may not expand the state court record based on ineffective state postconviction counsel.On remand, the United States Court of Appeals for the Ninth Circuit considered only evidence properly submitted in state court under procedural rules. The Ninth Circuit found the petitioner demonstrated “cause” to excuse the procedural default but failed to show “prejudice,” as his underlying IAC claim was not “substantial.” Although counsel’s performance was deficient, the new mitigating evidence was unlikely to have changed the sentencing outcome, given the weight of aggravating factors and Arizona precedent. The Ninth Circuit affirmed the district court’s denial of habeas relief. View "RAMIREZ V. THORNELL" on Justia Law

The defendant was convicted of voting in more than one state during the 2016 general election. He maintained residences in both New Hampshire and Massachusetts and was alleged to have voted in Holderness, New Hampshire by absentee ballot and in Belmont, Massachusetts in person. The State introduced evidence of his voting history in both states from 1996 to 2018 and sought to exclude statements by an acquaintance, William Botelho, who had previously admitted to voting in the defendant's name in Massachusetts.The Grafton County Superior Court allowed the State to admit the defendant’s prior voting records under New Hampshire Rule of Evidence 404(b) and excluded Botelho’s statements as inadmissible propensity evidence, also denying the defendant’s request for a Richards hearing regarding Botelho’s potential testimony. After a jury found the defendant guilty, the Superior Court denied his post-trial motions for dismissal based on territorial jurisdiction, judgment notwithstanding the verdict, and to set aside the verdict.The Supreme Court of New Hampshire found that the Superior Court erred in admitting the defendant’s prior voting history because the danger of unfair prejudice substantially outweighed its probative value, especially since the prior alleged acts were nearly identical to the charged crime. The court also held that evidence of Botelho’s confession to voting in the defendant’s name in the 2016 election was not evidence of other bad acts under Rule 404(b) and should not have been categorically excluded. The Supreme Court further ruled that, if Botelho asserts his Fifth Amendment rights on remand, the trial court must hold a Richards hearing.The Supreme Court affirmed the lower court’s denial of the defendant’s motions regarding territorial jurisdiction, sufficiency, and weight of the evidence, but reversed the conviction due to the evidentiary errors and remanded for further proceedings. View "State v. Rosen" on Justia Law

A married couple, acting on behalf of their minor child, challenged West Virginia’s compulsory vaccination law after their daughter was disenrolled from a public virtual school because she was not fully vaccinated. The parents sought a religious exemption from the vaccination requirement, but were informed that only medical exemptions—based on specific medical contraindications or precautions certified by a physician—are permitted under state law. After being denied a religious exemption, the parents filed suit, claiming that the absence of a religious exemption violated their First Amendment right to freely exercise their Christian faith. They requested a preliminary injunction to allow their daughter’s re-enrollment in the virtual academy during the litigation.The United States District Court for the Northern District of West Virginia granted the preliminary injunction, finding that the parents were likely to succeed on their free exercise claim. The district court applied the test from Employment Division, Department of Human Resources of Oregon v. Smith, concluding that the vaccination law was not generally applicable, and thus subject to strict scrutiny, which it found the law did not survive.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of preliminary relief. The Fourth Circuit held that West Virginia’s compulsory vaccination law is a neutral and generally applicable measure enacted under the state’s police power to protect public health, as recognized in longstanding Supreme Court precedent including Jacobson v. Massachusetts and Prince v. Massachusetts. The court found that the medical exemption process does not constitute a “mechanism for individualized exemptions” that would undermine general applicability under cases such as Fulton v. City of Philadelphia. The Fourth Circuit concluded that the law is subject to rational basis review, which it easily satisfies, and that the Free Exercise Clause does not require religious exemptions simply because medical exemptions exist. The court reversed the district court’s preliminary injunction and remanded the case. View "Perry v. Marteney" on Justia Law

A group of environmental organizations, Native tribes, and individual plaintiffs sought to prevent a land exchange in Southeast Arizona’s Tonto National Forest, mandated by the Southeast Arizona Land Exchange and Conservation Act. This exchange would transfer nearly 2,500 acres of federal land, including Oak Flat—a site of religious significance to the Apache—and a large copper deposit to Resolution Copper Mining LLC. In return, the company would provide over 5,000 acres of equally appraised land to the federal government. Plaintiffs raised concerns under several statutes, including the Land Exchange Act, the National Environmental Policy Act (NEPA), the National Historic Preservation Act (NHPA), the Religious Freedom Restoration Act (RFRA), and the Free Exercise Clause, alleging procedural and substantive flaws in the exchange.The United States District Court for the District of Arizona denied motions for preliminary injunctions, finding that plaintiffs failed to show likely success or serious questions on the merits of their claims relating to appraisal, NEPA compliance, tribal consultation, and religious liberty. In a related case, Apache Stronghold v. United States, the district court’s denial of an injunction on religious liberty grounds was affirmed by the Ninth Circuit and not disturbed by the Supreme Court.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of a preliminary injunction. The court held that plaintiffs had Article III standing and that their NEPA claims were justiciable as “final agency action.” However, it concluded that plaintiffs were not likely to succeed on the merits of their appraisal, NEPA, consultation, or religious liberty claims. The court further determined that existing precedent foreclosed the RFRA and Free Exercise arguments. The court did not address other injunction factors and dissolved the administrative stay. View "BROWN LOPEZ V. USA" on Justia Law

A sitting circuit court judge was the subject of an impeachment petition submitted to the Kentucky House of Representatives by a former legislator who was not a party to any of the cases he cited. The petition alleged that the judge abused her discretion in six cases; five of these cases were still pending in the judicial system at the time. The petition did not include an affidavit, as required by Kentucky statute. The House referred the matter to its Impeachment Committee, which held a hearing and ultimately issued articles of impeachment against the judge. The Kentucky Senate scheduled a trial on these articles.The judge sought a temporary injunction in Franklin Circuit Court to stop the impeachment proceedings. The Franklin Circuit Court denied the injunction. She then sought emergency relief and review from the Kentucky Court of Appeals, which also denied relief. The judge subsequently filed emergency motions and a petition for a supervisory writ with the Supreme Court of Kentucky, seeking a declaration that the impeachment articles and proceedings violated the separation of powers and her due process rights, and requesting that they be declared void from the outset.The Supreme Court of Kentucky granted the petition for a supervisory writ. The Court held that the impeachment petition was invalid because it was not verified by affidavit, as required by statute. The Court further held that the allegations concerned discretionary judicial acts subject to correction through the appellate process or Judicial Conduct Commission proceedings, not impeachment, and that the Legislature’s actions violated the separation of powers. The Court also found that the impeachment process denied the judge due process, and that further proceedings would cause her irreparable harm. The Court enjoined the General Assembly from continuing the impeachment proceedings and ordered dismissal of the pending articles. View "GOODMAN V. NEMES" on Justia Law

A public hospital district in California established and recorded covenants, conditions, and restrictions (CC&Rs) in 1991 for a common interest development known as the Tulare Medical Center. These CC&Rs included a prohibition on abortion clinics within the development. In 2001, certain property subject to these CC&Rs was transferred to individual owners, who later sought to lease it to a family planning organization that provides a range of services, including abortion. The property owners association, comprised of all parcel owners and authorized to enforce the CC&Rs, objected to the lease and sought to enjoin the operation of the clinic, arguing that any abortion services would violate the CC&Rs.The Superior Court of Tulare County reviewed the association’s request for a preliminary injunction. After considering the parties’ submissions and arguments, the court denied the injunction. The court found there was a credible threat that abortion services would be provided but concluded the association had not shown a likelihood of prevailing on the merits. Specifically, the trial court noted unresolved legal questions regarding whether restrictions on abortion clinics in CC&Rs violated the Unruh Civil Rights Act or California constitutional protections, and found the association failed to demonstrate that the balance of harms favored an injunction.The California Court of Appeal, Fifth Appellate District, reviewed the case. It held that the prohibition on abortion clinics, adopted by a public entity, constituted government action that interfered with the fundamental constitutional right to reproductive choice under the California Constitution. The court applied the compelling interest test, found no compelling interest justifying the restriction, and concluded the prohibition violated fundamental public policy. Additionally, the court held that the prohibition was void under Civil Code section 53 because it indirectly limited property use based on a characteristic protected by the Unruh Act. The order denying the preliminary injunction was affirmed. View "Tulare Medical Center Property v. Valdivia" on Justia Law

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