Justia Constitutional Law Opinion Summaries

The petitioner challenged the renewal of an annual permit granted to a hotel operator for the use of state-owned, ceded lands fronting the Kahala Hotel. The permit, which allowed the hotel to use the land for recreational and maintenance purposes, was extended several times by the Board of Land and Natural Resources (BLNR). The petitioner requested a contested case hearing (CCH) during a public meeting about the most recent renewal, arguing that the practice of pre-setting lounge chairs on the land discouraged public use. The BLNR denied the request for a hearing and approved the permit renewal. The petitioner appealed this denial.The Circuit Court of the First Circuit affirmed the BLNR’s actions, rejecting the petitioner’s arguments. The petitioner then appealed to the Intermediate Court of Appeals (ICA), which found that the petitioner had a constitutionally protected property interest in a clean and healthful environment under the Hawai‘i Constitution. The ICA concluded that the petitioner was entitled to a CCH and that the denial of such a hearing violated procedural due process. However, since the permit had expired, the ICA remanded the case to the circuit court to determine what relief could be granted, and denied the petitioner’s request for attorney fees under the private attorney general (PAG) doctrine, finding that the requirements for the doctrine had not yet been satisfied.Upon certiorari, the Supreme Court of the State of Hawai‘i held that the PAG doctrine does not require a party to obtain further relief before recovering attorney fees, and that all requirements for the doctrine were met. The court ruled that the hotel operator is liable for all reasonable attorney fees incurred by the petitioner during the certiorari proceedings, including fees for seeking fees, and remanded to the ICA to determine the amount of reasonable fees for the appellate stage. View "Ralston v. Board of Land and Natural Resources." on Justia Law

In this case, the defendant was found asleep with a firearm in his possession at a restaurant in Indiana. He was charged with and pleaded guilty to being a felon in possession of a firearm. At sentencing, the calculation of his advisory sentencing range under the United States Sentencing Guidelines turned on whether his prior Indiana conviction for conspiracy to commit armed robbery qualified as a “crime of violence.” The parties agreed that Indiana law allows for conviction of conspiracy even if the only other participant is an undercover officer, a so-called “unilateral” conspiracy.The United States District Court for the Southern District of Indiana determined that the relevant definition of “conspiracy” under the Guidelines, as amended in 2023, included both bilateral (where more than one genuine participant agrees to commit a crime) and unilateral conspiracies. As a result, it found that the Indiana conviction was a “crime of violence,” applied a higher offense level, and sentenced the defendant to 96 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case. It applied the categorical approach, which looks to the elements of the generic offense as understood when the relevant Guideline provision was enacted. The court held that in 1989, when the Guideline first included conspiracies as “crimes of violence,” the prevailing view required bilateral conspiracies; most states and federal law at that time defined conspiracy as requiring two or more genuine participants. Because Indiana’s statute is broader, the prior conviction could not categorically qualify as a “crime of violence” under the Guidelines. Accordingly, the Seventh Circuit vacated the sentence and remanded for resentencing. View "USA v. Lloyd" on Justia Law

Frank William Bonan II served as chairman of the board and loan committee member at Grand Rivers Community Bank in Illinois while simultaneously holding positions at another local bank. In 2015, Bonan orchestrated a complex loan transaction involving the purchase and leaseback of a warehouse by 618 Holdings, LLC, whose principals were financially unstable and closely connected to Bonan. The transaction was structured so that Grand Rivers’s loan funded both the purchase of the warehouse and initial lease payments, with the bank ultimately suffering significant losses when the loan defaulted. Additionally, Bonan was involved in an incident where the bank mistakenly released its security interest in valuable collateral, resulting in further losses.Following these events, the Federal Deposit Insurance Corporation (FDIC) initiated an administrative enforcement action against Bonan in 2021, alleging unsafe or unsound banking practices and breaches of fiduciary duty. After a hearing before an FDIC administrative law judge, the judge found misconduct and recommended sanctions. The FDIC Board of Directors subsequently issued an order barring Bonan from working at any FDIC-insured institution under 12 U.S.C. § 1818(e) and imposed a $105,000 civil money penalty under 12 U.S.C. § 1818(i)(2)(B).Bonan petitioned the United States Court of Appeals for the Seventh Circuit for review, presenting constitutional and evidentiary challenges, including an argument that the FDIC’s administrative adjudication deprived him of his Seventh Amendment right to a jury trial. The Seventh Circuit found that, under current Supreme Court precedent, the FDIC’s enforcement action implicated “public rights” and was not subject to the jury trial requirement. The court rejected Bonan’s additional constitutional and evidentiary arguments, found substantial evidence supporting the FDIC’s findings, and denied the petition for review, thereby upholding the FDIC’s orders. View "Bonan v. FDIC" on Justia Law

Law enforcement began investigating after a mother reported that an adult man had offered her sixteen-year-old daughter vape pens in exchange for sex. Officers identified the man as the appellant and corroborated the report through interviews, social media messages, and vehicle information. During an interview at the appellant’s home, officers observed behavior indicating he was deleting information from his phone when asked about his contact with the minor. Concluding that evidence was at risk of imminent destruction, officers seized his phone without a warrant. The appellant subsequently signed a consent form for the search but only after officers inaccurately stated they already had a warrant. Later, a warrant was obtained based on an affidavit summarizing the investigation. The search revealed child sexual abuse material involving a different minor.The United States District Court for the District of South Dakota reviewed the appellant’s motion to suppress evidence obtained from his phone, arguing the seizure was unconstitutional and the search warrant was invalid due to factual omissions and misrepresentations in the supporting affidavit. The magistrate judge recommended denying the motion, and the district court adopted that recommendation. The appellant then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the warrantless seizure of the phone was justified by probable cause and exigent circumstances because officers reasonably believed evidence was about to be destroyed. The court also found that, even after correcting for alleged errors and omissions in the warrant affidavit, there remained probable cause to support the warrant. The court rejected the appellant’s arguments for suppression and affirmed the district court’s denial of the motion to suppress. View "United States v. Mulamba" on Justia Law

A residential contractor in Iowa received warning notices from the Iowa Insurance Division, alleging that its business activities and advertising involved unlicensed public adjusting, which is regulated by two Iowa statutes. These statutes require public adjusters to be licensed and prohibit residential contractors from representing or negotiating insurance claims on behalf of property owners for the same project on which they perform work. Violations can lead to significant penalties. After the contractor was notified of alleged violations related to its advertising and communications with consumers, it challenged the constitutionality of the statutes, claiming they are void for vagueness and infringe upon First Amendment rights, both facially and as applied.The United States District Court for the Southern District of Iowa dismissed the contractor’s suit. The court found that the State of Iowa and its Insurance Division were immune under the Eleventh Amendment. It further held that the contractor failed to state a cognizable claim under the First or Fourteenth Amendments, concluding the statutes regulated conduct, not speech, and were not unconstitutionally vague.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed in part, reversed in part, and remanded. The appellate court held that the statutes are not facially unconstitutional and are not void for vagueness. However, the court found that the district court erred by not adequately analyzing the contractor’s as-applied First Amendment challenge. Specifically, when the statutes were applied to restrict the contractor from telling insureds that it would assist or advise them in navigating the insurance claims process, the law regulated speech. The court reversed the dismissal of the as-applied First Amendment claim and remanded for further proceedings, while affirming the rejection of the facial and vagueness challenges. View "Shamrock Hills, LLC v. State of Iowa" on Justia Law

The defendant was charged with repeatedly sexually abusing his 13-year-old daughter over the course of about a year, resulting in her pregnancy and the birth of a stillborn infant. DNA testing confirmed that the defendant was the father. After authorities learned of the abuse in 2014, the defendant fled and was apprehended years later. During pretrial proceedings, the defendant claimed that a witch named Perla had compelled him to commit the offenses, raising concerns about his mental competence to stand trial.The Superior Court of Los Angeles County conducted extensive pretrial competency proceedings spanning approximately 26 months. Multiple experts evaluated the defendant, with initial reports finding him incompetent, resulting in his commitment to a psychiatric facility. Over time, subsequent expert reports, including one by a psychologist selected by the defense, concluded that the defendant was malingering and was competent to stand trial. At various hearings, the defendant’s counsel waived his presence, and ultimately both sides stipulated to the expert findings. The court reinstated criminal proceedings and set the case for trial. During trial, the defendant did not reiterate his prior claims about the witch, and the jury found him guilty.The California Court of Appeal, Second Appellate District, Division Eight, reviewed whether the defendant’s constitutional rights were violated by his absence from a pretrial competency hearing. The court held that neither the Sixth Amendment nor due process required the defendant’s presence at that hearing because his absence did not interfere with the fairness of the proceedings or with any opportunity for effective cross-examination. The court also found that any error would have been harmless beyond a reasonable doubt. The judgment was affirmed. View "People v. Maldonado" on Justia Law

The plaintiff, a former New Mexico state senator, used leftover campaign funds to make charitable donations, including a $200 contribution to assist a high school student with attending a pre-law program. These donations were made to individuals and organizations that did not qualify as tax-exempt under Section 501(c)(3) of the Internal Revenue Code. New Mexico’s Campaign Reporting Act (CRA) prohibits most campaign expenditures, but lists certain permitted uses, including donations to 501(c)(3) organizations. After the Secretary of State discovered the $200 donation during a random audit, she determined it violated the CRA and requested the plaintiff to reimburse his campaign fund. The plaintiff refused, arguing that enforcing the CRA in this way violated his First Amendment rights, and the matter was referred to the State Ethics Commission and Attorney General.In the United States District Court for the District of New Mexico, the plaintiff sought a declaration that the restriction was facially unconstitutional, and injunctive relief. The district court initially granted a preliminary injunction barring enforcement of the CRA for such donations, viewing the plaintiff’s claim as a facial overbreadth challenge and finding it likely to succeed. However, after further proceedings and in light of an affidavit from the Secretary of State, the district court concluded the CRA did not prohibit protected speech, granted summary judgment for the defendant, and denied a permanent injunction. The district court allowed the plaintiff’s as-applied challenge to proceed separately; the plaintiff appealed only the denial of his facial challenge.The United States Court of Appeals for the Tenth Circuit reviewed the case and held that the CRA’s prohibition on donations to non-501(c)(3) organizations and individuals facially regulates activity protected by the First Amendment. The court vacated the district court’s order and remanded for further proceedings, directing the lower court to determine the appropriate constitutional test and apply it to the CRA’s challenged prohibitions. View "Ortiz y Pino v. Oliver" on Justia Law

Malachi Handley was stopped by police officers in Cedar Rapids, Iowa, due to a broken brake light on his vehicle. During the stop, an officer detected the smell of marijuana but was uncertain if it originated from the vehicle or a nearby apartment. A K-9 unit was called to conduct a drug sniff, and during the sniff, the drug dog’s snout entered the open window of Handley’s vehicle for about one second before indicating the presence of narcotics. Based on this indication, officers searched the vehicle and discovered a firearm and marijuana.A grand jury indicted Handley for being a felon in possession of a firearm and possessing a stolen firearm. He moved to suppress the evidence, arguing that his Fourth Amendment rights were violated when the dog’s snout entered his car. The United States District Court for the Northern District of Iowa agreed that the dog’s entry constituted an unreasonable, warrantless search because probable cause was lacking before the intrusion. However, the court denied the suppression motion, concluding that the officers acted in objectively reasonable reliance on then-binding appellate precedent from the Eighth Circuit, specifically United States v. Lyons.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the district court erred in declining to apply the exclusionary rule. The Eighth Circuit held that the dog’s entry into Handley’s vehicle was a Fourth Amendment search under intervening Supreme Court precedent. However, the exclusionary rule did not apply because the officers reasonably relied on binding Eighth Circuit precedent at the time of the search. Therefore, the court affirmed the district court’s denial of the motion to suppress. View "United States v. Handley" on Justia Law

Between December 2017 and February 2018, Derby Clerfe purchased nine 9mm handguns from a Pennsylvania sporting goods store. Federal authorities, finding this purchasing pattern suspicious, interviewed Clerfe, who admitted arranging for the guns to be shipped to Haiti through a third party, without declaring them as required by law. He acknowledged the guns may have been concealed and had not yet arrived in Haiti. Clerfe was charged with conspiracy to violate U.S. laws prohibiting the export of firearms without proper filing, as well as transferring firearms to an unlicensed out-of-state resident.The U.S. District Court for the Western District of Pennsylvania reviewed the charges. Clerfe moved to dismiss the indictment on the grounds that the laws he was charged under violated the Second Amendment, constituted an unconstitutional delegation of legislative authority to the executive branch, and were unconstitutionally vague. The District Court denied his motion. Clerfe then pleaded guilty to one count of conspiracy but reserved the right to appeal the denial of his motion on Second Amendment and non-delegation grounds.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the laws prohibiting Clerfe from exporting handguns to Haiti did not violate the Second Amendment because the right to “keep and bear Arms” does not encompass sending firearms abroad in violation of export laws. The court further held that the Arms Export Control Act’s delegation to the President to designate “defense articles” for export control satisfies the constitutional “intelligible principle” standard, and thus does not violate the non-delegation doctrine. Accordingly, the Third Circuit affirmed the District Court’s denial of Clerfe’s motion to dismiss the indictment. View "USA v. Clerfe" on Justia Law

In this case, organizations that represent indigent and low-income litigants challenged the widespread unavailability of official court reporters in California’s superior courts for civil, family, and probate proceedings. These organizations documented that, despite prior assurances, many indigent litigants appear in court and find that no court reporter is present, even when properly requested. As a result, such litigants are often forced either to accept repeated continuances—delaying urgent matters like domestic violence restraining orders and child custody—or to proceed without a verbatim record, which severely impairs their ability to seek appellate review.Previously, the Supreme Court of California had ruled in *Jameson v. Desta* that when a superior court does not routinely provide court reporters in civil cases but allows parties who can afford it to hire private reporters, the court must ensure that indigent litigants receive access to an official verbatim record. Despite this, the petitioners alleged and the courts largely conceded that a chronic shortage of court reporters had rendered this guarantee largely ineffective. Some superior courts responded by issuing general orders allowing electronic recording in certain cases involving fundamental rights, but these policies were limited in scope and not uniformly adopted.The Supreme Court of California reviewed this original proceeding and held that, under the in forma pauperis doctrine articulated in *Jameson v. Desta*, superior courts have a ministerial duty to provide indigent litigants, upon request, with meaningful access to an official verbatim record of proceedings in all civil matters. This duty includes using electronic recording if neither an official nor a private court reporter is available, notwithstanding statutory restrictions. The court issued a writ of mandate directing the respondent superior courts to comply with this obligation. Each party was ordered to bear its own costs. View "Family Violence Appellate Project v. Super. Ct." on Justia Law