Justia Constitutional Law Opinion Summaries

GenBioPro, Inc., a manufacturer of generic mifepristone, filed a complaint against West Virginia officials, arguing that the state's law prohibiting most abortions was preempted by federal law. The company claimed that the FDA Amendments Act of 2007 (FDAAA), which regulates the distribution of high-risk drugs like mifepristone, preempted the state law. GenBioPro contended that the FDAAA established a comprehensive scheme for regulating REMS drugs with safe-use elements, leaving no room for state regulation.The U.S. District Court for the Southern District of West Virginia dismissed GenBioPro's complaint, finding no preemption. The court held that abortion regulation is a matter of health and safety traditionally occupied by the states. It determined that Congress had not expressed an intent to occupy the field of drugs subject to a REMS in a manner that would preempt West Virginia's abortion restrictions. The court also found that the FDAAA's requirement to consider patient access was a limitation on the FDA's own restrictions, not a command to ensure access for all patients.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The Fourth Circuit held that the FDAAA did not preempt West Virginia's abortion law. The court emphasized the presumption against preemption in areas of traditional state regulation, such as health and safety. It found that the FDAAA did not demonstrate a clear intention to displace the state's historic and sovereign right to regulate abortion. The court concluded that the FDAAA's focus on drug safety did not create a right to access specific high-risk drugs, and the statute did not preempt state laws regulating the incidence of abortion. View "GenBioPro, Inc. v. Raynes" on Justia Law

Axalta Coating Systems LLC ("Axalta") provided a can of flammable paint to FedEx for air shipment. The paint spilled during transit due to a loose lid. The Federal Aviation Administration (FAA) filed an administrative complaint alleging Axalta failed to package the paint according to the Hazardous Materials Regulations (HMR). An Administrative Law Judge (ALJ) found Axalta in violation and imposed a $1,900 penalty, which the FAA Administrator affirmed. Axalta petitioned for review, arguing the administrative adjudication violated the Seventh Amendment's jury trial guarantee, referencing the Supreme Court's decision in SEC v. Jarkesy.The ALJ denied Axalta's motion to dismiss the complaint and a motion to disqualify the ALJ. After a hearing, the ALJ concluded Axalta violated 49 C.F.R. § 171.2(e) and 49 C.F.R. § 173.24(b)(1), assessing a $1,900 penalty. Axalta appealed, and the FAA cross-appealed for a higher penalty. The Administrator affirmed the ALJ's decision. Axalta then petitioned the United States Court of Appeals for the Third Circuit for review.The Third Circuit held that the administrative adjudication did not violate the Seventh Amendment. The court distinguished the case from Jarkesy, noting that the HMR's technical standards were not derived from common law, unlike the securities fraud provisions in Jarkesy. The court concluded that the FAA's enforcement action was a public right that could be adjudicated administratively without a jury. The court also rejected Axalta's additional arguments, including claims of unconstitutional delegation of legislative power, improper ALJ appointment, statute of limitations issues, and due process violations. The petition for review was denied. View "Axalta Coating Systems LLC v. Federal Aviation Administration" on Justia Law

Tobias Jones, a self-described citizen journalist, was filming a Secret Service building in Washington, D.C. when two officers ordered him to stop. When he refused, they detained, handcuffed, and searched him. A third officer later informed Jones that he had the right to film, and he was released. Jones sued the officers for damages, claiming violations of his First and Fourth Amendment rights, and sought prospective relief against the Secret Service.The United States District Court for the District of Columbia dismissed Jones' case. The court held that Jones did not have a valid cause of action for damages under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics and lacked standing to seek injunctive or declaratory relief.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that Jones' Fourth Amendment claims presented a new context under Bivens, as the Secret Service officers were performing protective duties, which differ from the law enforcement activities in Bivens. The court found that extending Bivens to this new context was inappropriate due to the potential for judicial intrusion into executive functions and the availability of alternative remedies through the Department of Homeland Security. The court also declined to extend Bivens to Jones' First Amendment claim, noting that the Supreme Court has never done so and has foreclosed Bivens remedies for First Amendment retaliation claims.Regarding prospective relief, the court held that Jones lacked standing because he did not plausibly allege a substantial risk of future harm. The court noted that Jones' allegations of potential future encounters with Secret Service officers were speculative and insufficient to establish standing.The court affirmed the district court's dismissal of Jones' case. View "Jones v. Secret Service" on Justia Law

Joseph Terrell Goody, a documented gang member with a lengthy criminal history, was convicted of possession of a firearm by a felon. His criminal record includes convictions for cocaine possession, robbery, assault, deadly conduct, evading arrest, and burglary. On September 26, 2020, Goody was pulled over for traffic violations, and officers found cocaine, methamphetamine, and a suspicious guitar case in his car. The case contained a loaded rifle. Goody was arrested and later pleaded guilty to violations of 18 U.S.C. §§ 922(g)(1) and 924(a)(2).The United States District Court for the Southern District of Texas sentenced Goody to 57 months of imprisonment and two years of supervised release, with a special condition prohibiting him from associating with gang members. Goody appealed his conviction and the supervised-release condition.The United States Court of Appeals for the Fifth Circuit reviewed the case. Goody raised three arguments on appeal: the facial unconstitutionality of the felon-in-possession ban under the Second Amendment, a violation of the equal protection principle under the Fifth Amendment, and the vagueness of the supervised-release condition. The court rejected all three arguments. It upheld the constitutionality of the felon-in-possession ban, found no merit in the equal protection claim, and determined that the supervised-release condition was not plainly erroneous. The court noted that similar conditions have been routinely imposed and upheld by other courts. Consequently, the Fifth Circuit affirmed the district court's judgment. View "United States v. Goody" on Justia Law

A Texas statute, Senate Bill 315, prohibits individuals under 21 from working at sexually oriented businesses (SOBs) to prevent sex trafficking and sexual exploitation. Plaintiffs, including the Texas Entertainment Association and several adult cabarets and bookstores, challenged the constitutionality of S.B. 315 under the First Amendment, suing the Texas Attorney General and the Executive Director of the Texas Workforce Commission.The United States District Court for the Western District of Texas held a bench trial and upheld the statute as constitutional. The court found that Texas enacted S.B. 315 with the reasonable belief that it would curb sex trafficking and that the law was sufficiently tailored to that end. The court applied intermediate scrutiny, concluding that the statute furthered the state's interest in reducing sex trafficking and did not restrict substantially more speech than necessary.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's judgment, agreeing that intermediate scrutiny was appropriate. The court found that S.B. 315 was designed to serve a substantial governmental interest by providing evidence linking SOBs to sex trafficking and sex crimes. The court also determined that the statute allowed for reasonable alternative avenues of communication, as it did not significantly restrict the expressive conduct of SOBs or their employees. The court concluded that S.B. 315 was not overbroad, as the plaintiffs failed to demonstrate that the statute prohibited or chilled a substantial amount of protected speech. Thus, the Fifth Circuit held that S.B. 315 is constitutional under the First Amendment. View "Ass’n of Club Executives v. Paxton" on Justia Law

Brian and Susan Fernaays own a house on lot 31 in Brewers Creek Subdivision, Isle of Wight County, Virginia. A 20-foot drainage easement, shared with lot 32, contains an underground stormwater drainage pipe that has deteriorated over time, causing significant erosion. The Fernaayses estimate the repair cost at $150,000 and sued Isle of Wight County, claiming the County owns the easement and is responsible for maintaining the pipe. They argued that the County's failure to maintain the pipe resulted in an unconstitutional taking of their property under both the Virginia and U.S. Constitutions.The United States District Court for the Eastern District of Virginia reviewed the subdivision plat and the Declaration of Covenants and Restrictions. The court found that the easement was not dedicated to the County, meaning the County had no duty to maintain the drainage pipe. Consequently, the court granted summary judgment in favor of the County.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court concluded that the Brewers Creek Partnership did not unequivocally dedicate the drainage easement to the County. The court noted that the plat and the Declaration of Covenants and Restrictions did not manifest an intent to dedicate the easement or the pipe to the County. The language in the documents suggested that the easements were for the benefit of the lot owners and that the County was only permitted to use them, not obligated to maintain them. Therefore, the County was not responsible for the damage, and the Fernaayses, as property owners, would have to bear the maintenance costs. The judgment of the district court was affirmed. View "Fernaays v. Isle of Wight County" on Justia Law

Erik Harris, a frequent marijuana user, purchased three pistols over a short period. Each time, he falsely stated on federal forms that he was not an unlawful user of marijuana. After losing one of the guns while intoxicated, Harris reported it stolen and bought a replacement. When the missing gun was found with a felon, Harris admitted to regular marijuana use during police questioning.The United States District Court for the Western District of Pennsylvania denied Harris's motion to dismiss the charges, which included three counts under 18 U.S.C. §922(g)(3) for possessing guns as an unlawful drug user and three counts under §922(a)(6) for lying to obtain the guns. The court concluded that §922(g)(3) was constitutional as applied to Harris, using means-end scrutiny. Harris then pleaded guilty to all counts but preserved his right to appeal the denial of his motion to dismiss.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that history and tradition justify §922(g)(3)’s restrictions on those who pose a special danger of misusing firearms due to frequent drug use. However, the court found insufficient facts to determine whether the law's restrictions are constitutional as applied to Harris. The court affirmed the statute's constitutionality in general but vacated Harris's conviction under §922(g)(3) and remanded the case for further fact-finding. The court also held that §922(g)(3) is not unconstitutionally vague as applied to Harris and upheld his convictions under §922(a)(6) for lying on the federal forms. View "United States v. Harris" on Justia Law

David Valle, an inmate at the California Men’s Colony, was found in possession of a 14-inch by 1-inch sharpened plastic fragment, metal fragments from a shower valve cover, and a folded metal sheet during a cell search. The plastic fragment was described as a weapon resembling a spear or knife. Valle admitted to having the items but claimed he could not remember why.Valle was convicted by a jury of possessing a sharp instrument in prison under Penal Code section 4502. The trial court sentenced him as a third-strike offender to 25 years to life in prison. Valle appealed, arguing that section 4502 is unconstitutionally vague because it does not define "sharp instrument."The California Court of Appeal, Second Appellate District, reviewed Valle's constitutional challenge de novo and rejected it. The court held that section 4502 is not unconstitutionally vague, either facially or as applied to Valle. The court reasoned that the statute's purpose is to protect inmates and prison officials from assaults by armed prisoners and that it provides a clear standard of conduct. The court cited previous California decisions that consistently upheld the statute's constitutionality.The court concluded that a 14-inch by 1-inch sharpened piece of hard, non-flexible plastic is a sharp instrument prohibited by section 4502. Valle's possession of such items, concealed in his cell, demonstrated his understanding that they were prohibited. The judgment was affirmed. View "People v. Valle" on Justia Law

A nonprofit organization, Students for Fair Admissions (SFFA), challenged the University of Texas at Austin (UT) for its admissions policies, alleging they violated the Equal Protection Clause and Title VI by considering race as a factor. After the Supreme Court's decision in Students for Fair Admissions, Inc., v. President & Fellows of Harvard College, UT revised its admissions policy to exclude race as a factor but allowed admissions officers access to applicants' racial data. SFFA claimed this access still constituted a violation and sought declaratory and injunctive relief.The United States District Court for the Western District of Texas dismissed all claims as moot, reasoning that UT's policy changes addressed the issues raised by SFFA. The district court concluded that the claims related to the old policy were moot and that the new policy did not violate the law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court agreed that claims related to UT's pre-Harvard policy were moot because the policy had been repealed and could not reasonably be expected to recur. However, the court found that claims related to UT's post-Harvard policy were not moot. The court noted that admissions officers' access to racial data could still potentially allow for racial discrimination, thus maintaining a live controversy.The Fifth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. The court held that SFFA's claims regarding the revised admissions policy remained live and required further examination to determine if the policy was a subterfuge for continued race discrimination. View "Students for Fair Admissions v. University of Texas Austin" on Justia Law

In 2023, Maine voters passed "An Act to Prohibit Campaign Spending by Foreign Governments" to prevent foreign governments and entities influenced by them from contributing to or influencing elections. The Act also requires media platforms to ensure they do not distribute communications that violate this prohibition, with violators facing civil and criminal penalties. Several companies and individuals, including Central Maine Power (CMP) and Versant Power, challenged the Act, claiming it violated the First Amendment. The district court granted a preliminary injunction against the Act, and Maine appealed.The United States District Court for the District of Maine granted the preliminary injunction, finding that the Act was likely unconstitutional under the First Amendment. The court held that the Act's prohibition on spending by entities with at least 5% foreign ownership was not narrowly tailored to a compelling state interest. It also found that the definition of "foreign government-influenced entity" was overly broad and likely to stifle domestic speech regardless of actual foreign influence. The court declined to sever the unconstitutional provisions from the rest of the Act, reserving the issue for later consideration.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that the Act's 5% foreign ownership threshold was not narrowly tailored and that the definition of "foreign government-influenced entity" was overly broad. The court also found that the Act's restrictions on contributions and expenditures were likely unconstitutional. The court did not address the issue of severability, leaving it for the district court to decide. The court also did not find it necessary to discuss the preemption determination in affirming the injunction. View "Central Maine Power Co. v. Commission on Governmental Ethics and Election Practices" on Justia Law