Justia Constitutional Law Opinion Summaries

An inmate with a history of heart issues experienced unusually severe chest pain while incarcerated and took medication without relief. He promptly reported his symptoms to a corrections officer, expressing the need for immediate medical attention and warning of his medical vulnerability. The officer dismissed the complaint, ordering the inmate back to his cell, and allegedly threatened further discipline. Instead, the inmate sat in a nearby wheelchair. Another prison official later intervened and arranged for the inmate to be transported to the medical wing, resulting in an eight-minute delay from the initial complaint. After waiting about an hour in the medical wing without treatment, the inmate suffered a heart attack but ultimately recovered.The inmate initiated a lawsuit in the United States District Court for the Eastern District of Michigan, asserting that the officer’s conduct constituted deliberate indifference to his serious medical needs in violation of the Eighth Amendment and also violated his Fourteenth Amendment rights. The officer sought summary judgment on qualified immunity grounds. A magistrate judge recommended dismissing the Fourteenth Amendment claim but found that a reasonable jury could determine that the officer was deliberately indifferent and thus denied qualified immunity. The district court adopted this recommendation, concluding that there was sufficient evidence for the Eighth Amendment claim to proceed to trial.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the officer was entitled to qualified immunity as a matter of law. The Sixth Circuit held that the officer did not violate a clearly established constitutional right because existing precedent did not put a reasonable officer on notice that failing to immediately respond to a prisoner’s oral complaint of chest pain, absent visible signs of medical distress, violated the Eighth Amendment. The court reversed the district court’s denial of summary judgment and remanded the case for entry of judgment in favor of the officer. View "Richardson v. Falk" on Justia Law

Two businesses operating an industrial warehouse and distribution center in Bonner Springs, Kansas, were affected by an ordinance enacted by the neighboring City of Edwardsville. This ordinance prohibited vehicles weighing over six tons from traveling on 110th Street—the street dividing the two cities—unless the trucks were entering or exiting Edwardsville. As a result, heavy trucks serving the businesses could not access 110th Street to enter or exit their properties. In response, the businesses filed suit against Edwardsville and certain city officials, alleging violations of federal and state law and seeking a preliminary injunction to prevent enforcement of the ordinance.The United States District Court for the District of Kansas dismissed the plaintiffs’ federal claims, including those under the Surface Transportation Assistance Act, the Equal Protection Clause, and the Dormant Commerce Clause, and denied the request for a preliminary injunction. However, the district court declined to dismiss the remaining state-law claims, leaving them pending.While the appeal was pending before the United States Court of Appeals for the Tenth Circuit, Edwardsville repealed the challenged ordinance and replaced it with a new one. The new ordinance allowed southbound trucks to enter the businesses from 110th Street, though certain restrictions remained. The Tenth Circuit determined that the repeal and replacement of the ordinance rendered the appeal moot because the controversy over the original ordinance no longer existed. The court found no exception to mootness applied and declined to vacate the district court’s order or exercise pendent appellate jurisdiction over the dismissed claims. Accordingly, the Tenth Circuit dismissed the appeal for lack of jurisdiction. View "Scannell Properties #516 v. City of Edwardsville, Kansas" on Justia Law

Officers observed Trevon Hatcherson-Ross walking on a sidewalk in the late afternoon when one officer noticed an “L-shaped” bulge in his waistband, suspecting it was a firearm. When the officers approached to investigate, Hatcherson-Ross fled, leading them on a short foot chase that ended with him climbing into the backyard of a private residence and hiding under a porch. After the officers found and detained him, they searched the backyard and discovered a gun in a storage bin under the porch, as well as ammunition in Hatcherson-Ross’s pocket.The Superior Court of the District of Columbia reviewed Hatcherson-Ross’s pretrial motion to suppress the gun and ammunition as the fruits of an unlawful seizure. The trial court denied the motion, reasoning that Hatcherson-Ross had abandoned the firearm in the backyard, thereby relinquishing any expectation of privacy in it. The court did not make specific findings as to whether or when the officers had reasonable suspicion to stop him, relying instead on the abandonment theory. After trial, a jury convicted Hatcherson-Ross of firearm-related offenses.The District of Columbia Court of Appeals considered whether Hatcherson-Ross had been unlawfully seized before he entered the backyard and whether the search of the backyard and storage bin implicated his Fourth Amendment rights. The court held that Hatcherson-Ross was not seized until officers physically detained him under the porch, at which point he did not contest that reasonable suspicion existed. The court further held that Hatcherson-Ross had no reasonable expectation of privacy in a stranger’s backyard or storage bin, making the abandonment issue irrelevant. The court affirmed both the denial of the suppression motion and Hatcherson-Ross’s convictions. View "Hatcherson-Ross v. United States" on Justia Law

A commercial property owner that operates a large shopping mall in Nassau County, New York, was fined approximately $4.8 million by county officials for failing to provide financial information as required under the county’s Annual Statement of Income and Expenses (ASIE) Law. This law mandates commercial property owners to report financial data to county assessors or face a fine calculated as a percentage of the property’s market value. The property owner did not submit the required statements for two consecutive years and was subsequently notified of the fine.After receiving notice of the penalty, the property owner filed suit in the United States District Court for the Eastern District of New York, rather than pursuing remedies under state law or contesting the fine through state administrative proceedings. The owner argued that the ASIE Law and the resulting penalty violated the Eighth Amendment’s Excessive Fines Clause, the Fourteenth Amendment’s Due Process Clause, and several state laws. The district court granted summary judgment in favor of Nassau County and its officials, finding that the fine was not excessive, that adequate procedural due process was available through an Article 78 state court proceeding, and that the ASIE Law did not violate substantive due process. The district court also denied the owner’s motion for sanctions against the county, finding no evidence of bad faith or egregious conduct.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that the Excessive Fines Clause applies to business entities, including trusts, and that the fine imposed was not grossly disproportional to the offense. The court further found that the available procedures satisfied due process requirements and that the ASIE Law was rationally related to a legitimate government interest. The denial of sanctions was also upheld. View "The Retail Property Trust v. Nassau Cnty. Dep't of Assessment" on Justia Law

Several residential property owners and a short-term rental platform challenged two ordinances enacted by the city. The first ordinance, adopted in 2023, restricts short-term rental licenses to one per residential block and distributes them by lottery. The second ordinance, adopted in 2024, requires short-term rental platforms to verify the license status of properties before facilitating transactions, and to periodically reverify this status. Plaintiffs alleged that these ordinances infringed upon their constitutional and statutory rights, including claims under the Takings Clause and Section 230 of the Communications Decency Act.The United States District Court for the Eastern District of Louisiana reviewed the plaintiffs’ claims. It dismissed all claims under Rule 12(b)(6), except for Airbnb’s Fourth Amendment challenge regarding a monthly reporting requirement in the 2024 Ordinance. The district court granted Airbnb summary judgment on that particular claim. Airbnb appealed the dismissal of its other claims.The United States Court of Appeals for the Fifth Circuit examined the case de novo. The court held that the 2023 Ordinance did not constitute a per se or regulatory taking under the Takings Clause, noting that the ordinance neither physically appropriated property nor severely impaired economic expectations. It also found the ordinance to be a reasonable zoning regulation that balanced public interests. Regarding Section 230, the Fifth Circuit ruled that neither the booking nor verification requirements of the 2024 Ordinance treated Airbnb as the publisher or speaker of third-party content, and thus were not preempted. The court affirmed the district court’s dismissal of the Takings Clause claim and the Section 230 claim, as well as the dismissal of other claims raised by the plaintiffs. View "Bodin v. New Orleans" on Justia Law

Elizabeth Schulte, a co-owner of property in Cedar Lake, Wisconsin, challenged actions by Kenneth J. Leners, chairman of the Town’s Board of Supervisors. The Town maintained a website open to public comments, which Schulte used to criticize a post advocating stricter regulation of recreational vehicles. In response, Leners deleted Schulte’s and other critical comments, banned them from further commenting, and ultimately removed all comments from the post. After threats of legal action, the Board decided to eliminate comment sections from the website entirely, later restoring deleted comments in a separate thread unconnected to the original post.Schulte filed suit under 42 U.S.C. §1983 in the United States District Court for the Western District of Wisconsin, alleging violation of her First and Fourteenth Amendment rights due to viewpoint discrimination and vague criteria for regulating the comment section. She also claimed unlawful retaliation when the comment sections were shut down. Leners moved to dismiss, asserting qualified immunity. The district court denied the motion regarding the counts related to selective deletion of comments, finding Schulte had pleaded viewpoint discrimination and rejecting Leners’s qualified-immunity defense. The court dismissed other unrelated counts and allowed Leners and the Town to appeal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of qualified immunity for Leners’s selective deletion of comments. The appellate court held that it was clearly established in September 2022 that viewpoint discrimination in a public forum, such as a website comment section open to the public without content restrictions, violates the First Amendment. The lack of any policy regulating comment content made the speech private, not government speech. The Seventh Circuit affirmed the district court's denial of qualified immunity to Leners and dismissed the Town’s appeal. View "Schulte v Leners" on Justia Law

Several homeowners lost their properties through foreclosure after failing to pay property taxes to Oakland County, Michigan. Although the properties’ values exceeded the tax debts, the County retained all surplus equity rather than refunding the difference to the owners. The affected individuals, represented by attorney Scott Smith and later the McAlpine PC firm, brought suit alleging that this retention violated the Takings Clause of the U.S. Constitution.Both cases were initially dismissed by the United States District Court for the Eastern District of Michigan for failure to state a claim. The plaintiffs appealed. In the Hall case, the Pacific Legal Foundation represented the plaintiffs pro bono. The United States Court of Appeals for the Sixth Circuit reversed, holding that the County’s actions constituted a violation of the Takings Clause. The district court subsequently denied motions for class certification and the parties settled for $500,000. Plaintiffs then sought attorney fees totaling over $4.2 million, including hours spent on failed class certification and appeals largely handled by other counsel. The district court reduced the fee request by 40% and applied a 1.1 multiplier, awarding $1,361,476.51.The United States Court of Appeals for the Sixth Circuit reviewed the fee award for abuse of discretion and determined that the district court erred in several respects. The appellate court held that hours spent on failed class certification, litigation against other defendants, and certain other tasks were not properly billable and should have been categorically excluded. The court also found that the hours claimed for appellate work and by Mark McAlpine were grossly excessive, and that the district court failed to address the reasonableness of the hourly rates. The Sixth Circuit vacated the fee award and remanded, instructing the district court to recalculate fees with specific exclusions, a blended $325 hourly rate, and a 1.1 multiplier. No fees were awarded for the present appeal. View "Sinclair v. Meisner" on Justia Law

A South Carolina lender originates loans only within South Carolina but has extended credit to individuals with Pennsylvania addresses. Although the lender does not operate in Pennsylvania, it has engaged in activities connected to Pennsylvania, such as perfecting liens, collecting payments, and repossessing vehicles located in Pennsylvania. The Pennsylvania Department of Banking and Securities investigated the lender’s practices involving Pennsylvania residents, issuing subpoenas and ultimately initiating a formal administrative enforcement proceeding for alleged violations of Pennsylvania’s usury laws.Previously, the United States District Court for the District of Delaware granted summary judgment for the lender, finding Pennsylvania’s subpoena violated the Dormant Commerce Clause. The United States Court of Appeals for the Third Circuit reversed, holding that Pennsylvania could investigate and apply its usury laws to conduct connected to Pennsylvania. Afterward, Pennsylvania enforced its subpoena and initiated the administrative enforcement proceeding. The lender responded by filing suit in the United States District Court for the District of South Carolina, seeking to enjoin both the enforcement proceeding and a new subpoena, raising constitutional claims including those under the Dormant Commerce Clause.The United States District Court for the District of South Carolina dismissed the lender’s complaint, holding that claims related to the enforcement proceeding were barred by issue preclusion or, alternatively, by Younger abstention. Claims challenging the second subpoena were dismissed as unripe due to lack of present injury.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of claims challenging the administrative enforcement proceeding under Younger abstention, finding it was a quasi-criminal civil enforcement proceeding and that state interests and procedures were sufficient. The court also affirmed dismissal of claims challenging the second subpoena on ripeness grounds, but vacated the judgment insofar as those claims were dismissed with prejudice, remanding with instructions to dismiss them without prejudice. View "TitleMax of South Carolina, Inc. v. Spicher" on Justia Law

Several individuals affiliated with an organization headquartered in Florida, which advocates for the rights of African people worldwide, developed a close relationship with a Russian citizen who directed a Russian government-backed group. Over the course of several years, this Russian contact funded trips to Russia for organization leaders, sponsored events, and directed them to produce and disseminate pro-Russian statements and media. These individuals participated in activities at the direction of the Russian contact, including authoring petitions, organizing demonstrations, publishing statements, recording videos, and protesting at the request of their Russian counterpart. None of them notified the U.S. Attorney General as required by law for acting as agents of a foreign government.A federal grand jury indicted three organization members and one former member for acting as unregistered agents of a foreign government under 18 U.S.C. § 951(a), and for conspiracy to do so under 18 U.S.C. § 371. After a jury trial in the United States District Court for the Middle District of Florida, the defendants were found guilty of conspiracy but not of the substantive offense. The district court sentenced the former member to 60 months’ probation and the other three to 36 months’ probation. The defendants raised several arguments on appeal, including claims that the statute was unconstitutional as applied, that the evidence was insufficient, that evidentiary and jury instruction errors occurred, and that there was prosecutorial misconduct.The United States Court of Appeals for the Eleventh Circuit held that 18 U.S.C. §§ 951 and 371 are constitutional as applied, as they are content-neutral and survive intermediate scrutiny. The Court found sufficient evidence to support the conspiracy convictions, ruled that the district court did not abuse its discretion regarding jury instructions or evidentiary rulings, and found no prosecutorial misconduct. The convictions were affirmed. View "USA v. Romain" on Justia Law

Todd Sutton, Jr. was arrested in Iowa for driving with a suspended license, an aggravated misdemeanor. He was taken to the Cerro Gordo County Jail, where officials intended to place him in a communal intake dormitory with other detainees due to his cooperative behavior. Prior to being housed in the dormitory, jail policy required a visual strip search for detainees arrested for at least a serious misdemeanor. During this search, officials discovered a plastic bag containing methamphetamine concealed beneath Sutton’s genitals. Sutton was subsequently indicted for possession of methamphetamine with intent to distribute.Sutton moved to suppress the evidence found during the strip search, arguing it was an illegal search under the Fourth Amendment. The motion was first reviewed by a magistrate judge, who recommended denial. The United States District Court for the Northern District of Iowa adopted the magistrate’s recommendation over Sutton’s objection. Sutton then entered a conditional guilty plea, reserving his right to appeal the denial of his suppression motion.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to suppress, applying a clear error standard for factual findings and de novo review for legal conclusions. The Eighth Circuit held that, under the Supreme Court’s decision in Florence v. Board of Chosen Freeholders of County of Burlington, jail officials may conduct strip searches of detainees who will be housed with others, even absent reasonable suspicion or probable cause, unless substantial evidence shows the search was unnecessary or unjustified. The court found no such evidence in Sutton’s case and affirmed the district court’s denial of the motion to suppress, concluding the strip search did not violate Sutton’s Fourth Amendment rights. View "United States v. Sutton" on Justia Law