Justia Constitutional Law Opinion Summaries

A university professor in Oxford, Mississippi sought to host a nighttime art exhibition on the grounds of the local courthouse, which is frequently used by the public for varied activities, including political protests and social gatherings. The county had implemented a Facility Use Policy requiring permits for use of courthouse grounds, including a ban on nighttime events, advance notice, security fees, insurance, and granting discretionary authority to deny permits based on the nature of the event. The professor’s permit request was denied due to the curfew provision, prompting him to file suit alleging violations of the First Amendment.The United States District Court for the Northern District of Mississippi held a bench trial and permanently enjoined enforcement of the curfew provision against the professor, finding it an unreasonable restriction on speech. However, the court dismissed the professor’s other claims for lack of standing, concluding he had not suffered sufficient injury to challenge the remaining policy provisions or to bring a vagueness challenge.The United States Court of Appeals for the Fifth Circuit reviewed the case. It affirmed the injunction against the curfew provision, holding that the ban was not narrowly tailored to serve a significant government interest and burdened more speech than necessary. The court rejected the county’s argument that subsequent policy amendments mooted the case, finding the amended curfew provision still posed the same fundamental issues. The Fifth Circuit reversed the district court’s dismissal of the professor’s facial challenges to the other policy provisions, holding he had standing to challenge them under the First Amendment, though not on vagueness grounds. The case was remanded for further proceedings, requiring the professor to demonstrate that unconstitutional applications of the policy substantially outweigh constitutional ones. View "Rash v. Lafayette County" on Justia Law

Two inmates who identify as transgender women brought a class action against the Oregon Department of Corrections and related officials, alleging Eighth Amendment violations for purportedly exposing transgender women inmates to substantial risk of harm by housing them in men’s prisons. The plaintiffs sought a preliminary mandatory injunction on behalf of a class of all current and future transgender women in Oregon prison facilities, requesting that they be presumptively assigned to the state’s women’s prison and given additional protections.A magistrate judge in the United States District Court for the District of Oregon granted the motion for a preliminary injunction and provisionally certified the class. The injunction required Oregon to presumptively assign transgender women inmates to the women’s prison unless a specific security justification was documented, along with other measures for safety and privacy. Defendants moved for reconsideration, and the district court amended but largely maintained the injunction. Defendants appealed and obtained a stay of the injunction pending appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s order, applying an abuse-of-discretion standard to the injunction and de novo review to underlying legal issues. The Ninth Circuit found the district court committed clear error by basing its injunction on an unsupported finding that the defendants employed a default presumption of housing transgender women in men’s prisons. The appellate court determined that the record showed individualized assessments for inmate placement and that the plaintiffs failed to demonstrate a likelihood of success on the merits, irreparable harm, or commonality for class certification. The Ninth Circuit vacated the preliminary injunction, ordered the class to be decertified, and remanded the case. The mandate was issued forthwith. View "S.D. V. REESE" on Justia Law

A software company managing cloud storage accounts detected that a user had uploaded material suspected to be child sexual abuse content. As required by federal law, the company reported this to the National Center for Missing and Exploited Children (NCMEC), which in turn forwarded a CyberTip containing the information, including the suspect’s phone number, to law enforcement. A detective from the Tallahassee Police Department reviewed the CyberTip and submitted an affidavit to a Florida state court judge to obtain a warrant to search the suspect’s cloud account. The affidavit referenced the reliability of NCMEC’s processes and the detective’s experience, but did not describe the alleged illicit images. The warrant was granted, and the subsequent search uncovered child sexual abuse images. Further investigation led to the identification of a victim and the arrest of the suspect, who was later charged federally.The defendant moved in the United States District Court for the Northern District of Florida to suppress the evidence, arguing that the search warrant affidavit lacked probable cause and that the good faith exception to the exclusionary rule did not apply. The district court agreed, finding that the affidavit was too vague and conclusory, lacking sufficient details to support probable cause or reasonable reliance. As a result, the court suppressed all evidence obtained from the searches.On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether the good faith exception to the exclusionary rule applied, assuming without deciding that the affidavit was deficient in establishing probable cause. The court held that the affidavit contained enough indicia of probable cause, particularly due to the general trustworthiness of NCMEC’s CyberTip program and the detective’s reasonable reliance on established procedures. Therefore, the court reversed the district court’s suppression order and remanded for further proceedings. View "USA v. Gibbs" on Justia Law

The defendant was charged with several serious crimes, including second-degree murder and aggravated assault, following an incident in which he allegedly attacked his parents with a baseball bat, killing his father and injuring his mother, before fleeing in a vehicle and colliding with a game warden's truck. After his arrest, the court ordered a neutral psychiatric examiner to conduct a competency examination to determine whether the defendant was fit to stand trial. The examiner interviewed the defendant multiple times but concluded that further psychometric testing was necessary. The examiner stated that defense counsel must be excluded from the testing, citing copyright and professional ethics concerns, and warned that she would otherwise submit a report without a competency finding.The defendant objected, asserting that his attorney had a constitutional right to be present during the competency examination, referencing both the Sixth Amendment and Article 10 of the Vermont Constitution. The State argued that the competency examination was not a critical stage of the prosecution, and thus the right did not attach. The Superior Court, Franklin Unit, Criminal Division denied the defendant's motion, holding there was no constitutional right to counsel’s presence during the examination. The defendant sought and was granted an interlocutory appeal.The Vermont Supreme Court reviewed the trial court’s decision de novo for constitutional questions and for abuse of discretion on procedural rulings. The Court held that a competency examination is not a critical stage of criminal proceedings where the Sixth Amendment right to counsel attaches, citing United States Supreme Court precedent and the practices of numerous jurisdictions. The Court further held that Vermont law and the Fifth Amendment adequately protect defendants’ rights during such examinations. Finding no abuse of discretion in the trial court’s decision to exclude counsel, the Vermont Supreme Court affirmed the trial court’s ruling. View "State v. Lawyer" on Justia Law

An inmate serving a sentence for second-degree murder in Vermont challenged the constitutionality of a statutory amendment affecting earned-time credits. The original law allowed inmates to earn sentence reductions for good behavior, and this petitioner received such credits for several months in early 2021. However, a 2021 amendment excluded inmates convicted of second-degree murder and other serious offenses, if they were sentenced on or before January 1, 2021, from earning further reductions after April 26, 2021. The petitioner, who falls into this category, retained credits earned before the amendment but was prohibited from earning future credits.The petitioner initially filed a pro se complaint in the Superior Court, Washington Unit, Civil Division, seeking declaratory relief to continue earning sentence reductions. After a parallel federal case, Baird v. Deml, decided in favor of the Department of Corrections, the petitioner amended his complaint to assert violations of his due process rights and the Common Benefits Clause of the Vermont Constitution. Both parties sought summary judgment, and the civil division adopted the reasoning of Baird, granting summary judgment to the Department of Corrections.The Vermont Supreme Court reviewed the case de novo and affirmed the lower court’s decision. The Court held that procedural due process requirements do not apply to legislative actions such as statutory amendments, and the legislative process provided all the process that was due. Regarding substantive due process, the Court found that the law did not implicate a fundamental constitutional right and was rationally related to a legitimate government purpose—protecting victims’ expectations about offenders’ sentences. The Court also held that the statute did not violate the Common Benefits Clause, concluding that the exclusion of certain inmates from earned-time credits was reasonably and justly related to the legislative purpose. The judgment was affirmed. View "Murphy v. Deml" on Justia Law

The case involved a defendant who killed her two young daughters by asphyxiation, believing she was protecting them from imagined abuse and exploitation by family members. The defendant had a documented history of severe mental illness, including schizoaffective disorder with both schizophrenic and bipolar symptoms, and had experienced increasing paranoia and delusions in the months before the offenses. After the killings, she drove to the police station, called 911, and confessed. Prior to the incident, she had made several reports to police, which were investigated and determined to be unfounded, and she was involuntarily hospitalized months before the offenses. The children were returned to her care following her treatment, and the killings occurred two months later.Following her arrest, questions arose regarding her competency to stand trial and potential insanity at the time of the offense. A defense-retained expert initially found her incompetent, but after further evaluation, both the defense and a State-retained expert agreed she was competent. The trial court later appointed the State’s expert as a “disinterested” expert for the insanity evaluation. At trial, the defense challenged the admissibility of the State’s expert’s testimony, arguing that the expert violated the defendant’s Fifth Amendment rights during the competency exam by inquiring about her mental state at the time of the offense, and that the expert was not a disinterested party as required by statute. The trial court overruled the objection. The jury found the defendant guilty of capital murder, and she was sentenced to life without parole.The Fifth District Court of Appeals initially held the defendant had failed to preserve her complaints for review but alternatively found that, even if error occurred, there was no substantial harm. The Texas Court of Criminal Appeals found that the defendant had preserved her claims. However, it held that even if the appointment of the expert was error, it did not affect the defendant’s substantial rights because the expert’s testimony did not have a substantial and injurious effect on the verdict. The court also concluded there was no constitutional error under the Fifth Amendment, as none of the allegedly improper statements were introduced by the State at trial. The judgment of the court of appeals was affirmed. View "MCDONALD v. STATE OF TEXAS" on Justia Law

Wyoming’s Constitution requires the legislature to provide a thorough and efficient education for all students. Historically, public education was funded by local property taxes, resulting in significant disparities between districts. Decades of litigation and legislative reform led to a statewide, cost-based funding model for school operations and facilities. This model, known as the legislative model (LM), was intended to ensure equal educational opportunities by using a block grant system based on the estimated cost of an adequate education (the “basket of goods and services”). Periodic recalibrations and annual adjustments for inflation were required to keep the model current.The plaintiffs, including the Wyoming Education Association and several school districts, sued in 2022, alleging that the legislature’s funding model was no longer cost-based, wasn’t properly adjusted for inflation, and lacked funding for certain innovations such as elementary school counselors, nutrition services, and school resource officers. They also claimed the State’s facilities oversight was inadequate. The District Court of Laramie County, after a bench trial, found in favor of the plaintiffs on all issues, concluding that the legislature failed to fund actual costs, address inflation, and include necessary innovations, and that the State’s facilities process was constitutionally deficient.The Supreme Court of Wyoming reviewed the case. The Court affirmed the district court’s findings that the legislature violated students’ equal protection rights by failing to fund the true cost of teacher salaries and by not properly adjusting for inflation. However, it reversed the requirement to fund a one-to-one technology ratio, nutrition services, and school resource officers, finding insufficient evidence that these innovations required statewide funding. The Court also reversed the order requiring statewide assessment of educational suitability for facilities, holding the State’s administrative process was constitutionally adequate. The Court ended the lower court’s retention of jurisdiction, assuming the legislature would act in good faith to comply with constitutional requirements. View "The State of Wyoming v. Wyoming Education Association" on Justia Law

A group of organizations and individuals challenged the constitutionality of a statewide initiative approved by Washington voters in November 2024. The initiative, known as I-2066, enacted broad changes to energy regulation, including requirements for utilities and local governments to ensure natural gas access, restrictions on local air quality regulators, removal of zero-emission goals from state law, amendments to the Decarbonization Act, and limitations on the state building code council’s authority regarding gas usage and transitions away from fossil fuels.The King County Superior Court reviewed the case following cross-motions for summary judgment by the parties. The court declared I-2066 unconstitutional in its entirety, finding that it violated three constitutional requirements: it impermissibly encompassed more than one subject, failed to include its subjects in the title, and failed to set forth the laws it amended. This judgment was appealed directly to the Supreme Court of the State of Washington.The Supreme Court of the State of Washington reviewed the superior court’s ruling de novo. The court held that I-2066 violated the single-subject requirement of article II, section 19 of the Washington Constitution. It found that the initiative combined several distinct subjects with separate regulatory effects, lacking the necessary rational unity among its provisions. The court concluded that the provisions introducing distinct subjects were not severable and thus rendered the entire initiative unconstitutional. The Supreme Court affirmed the superior court’s judgment on the narrower ground of the single-subject violation and did not address the other constitutional arguments raised. View "Climate Sols. v. State" on Justia Law

On October 1, 2021, Heather Marichal was involved in a car accident in Auburn, Maine, after driving on the wrong side of the road and crashing into another vehicle, then striking a snowplow. Marichal admitted to an officer that she had consumed alcohol at a brew fest and was the sole driver. She submitted to an Intoxilyzer test that showed a blood-alcohol content of .21 grams per 210 liters of breath. Marichal was charged with criminal operating under the influence (OUI), a Class D offense.The Androscoggin County Unified Criminal Docket handled the case, with multiple continuances throughout 2022, 2023, and 2024. Marichal sought to secure the appearance of a defense witness who allegedly would testify that someone else was driving. She served a subpoena and moved for a writ of capias ad respondendum when the witness ignored the subpoena. The court issued a civil warrant for the witness, but he did not appear for the December 2024 trial. Marichal filed motions in limine to admit hearsay statements from the witness and requested another arrest warrant. The trial court denied both the motion to continue and the motion in limine, finding Marichal had not demonstrated due diligence or likelihood of securing the witness, and that the hearsay exception was not met.The Maine Supreme Judicial Court reviewed the appeal following Marichal’s conditional guilty plea. The Court held that the trial court did not abuse its discretion in denying the motion to continue, as Marichal had not shown due diligence in securing the witness nor a likelihood that a continuance would procure the witness’s attendance. The Court also determined that Marichal’s constitutional rights to compulsory process and due process were not violated, as the witness’s absence was not attributable to State action or omission. The judgment of conviction was affirmed. View "State of Maine v. Marichal" on Justia Law

Chinwendu Alisigwe, a lawful permanent resident, was suspected by international law enforcement agencies of using fraudulent passports and identification documents to open bank accounts in the names of real individuals. Between 2017 and 2020, he opened thirty-six accounts, deposited millions from fraudulent schemes, transferred money to disguise its origins, and sent funds abroad. In 2019 and again in 2021, officers at John F. Kennedy International Airport stopped Alisigwe, manually searched his cellphone, and found evidence of identity theft and communications with co-conspirators.The United States District Court for the Southern District of New York denied Alisigwe’s motion to suppress evidence from the cellphone searches, reasoning that such searches require reasonable suspicion, and finding that law enforcement had reasonable suspicion both times due to ongoing investigations and evidence linking Alisigwe to fraudulent documents. The district court also imposed sentencing enhancements: an eighteen-point enhancement for intended loss under U.S.S.G. § 2B1.1(b)(1)(J), and a two-point enhancement for obstruction of justice under § 3C1.1 based on Alisigwe’s testimony at a duress hearing, which the court found to be fabricated.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The main holding is that no suspicion is required before the government searches a traveler’s cellphone at the border; routine border searches of property, including cellphones, are reasonable under the Fourth Amendment. The court further held that the First Amendment does not impose an independent warrant requirement for border searches of cellphones. The court also upheld the district court’s application of sentencing enhancements for both intended loss and obstruction of justice. View "United States v. Alisigwe" on Justia Law