Justia Constitutional Law Opinion Summaries

Two state forensic chemists in Massachusetts tampered with drug evidence and falsified test results, affecting tens of thousands of drug cases. The Massachusetts Supreme Judicial Court (SJC) vacated over 30,000 criminal cases due to this misconduct. The SJC ruled that under the Fourteenth Amendment, affected individuals were entitled to the repayment of most funds collected due to their vacated convictions but not the automatic return of forfeited property. Instead, individuals had to file motions for relief from judgment under Rule 60(b) of the Massachusetts Rules of Civil Procedure.The plaintiffs, whose criminal convictions were vacated, sought a federal court order for the automatic return of their forfeited property and related relief. The Commonwealth defendants moved to dismiss the complaint, arguing that the claims were barred by the Eleventh Amendment, which prohibits suits in federal court against a state by its own citizens. The United States District Court for the District of Massachusetts dismissed the complaint in part, ruling that it could not order the automatic return of forfeited property but allowed other claims to proceed under the Ex parte Young exception to the Eleventh Amendment.The United States Court of Appeals for the First Circuit reviewed the case and concluded that the Eleventh Amendment bars all the relief sought by the plaintiffs. The court held that the plaintiffs' claims focused on a past wrong, and the Ex parte Young exception applies only to prospective relief against ongoing violations of federal law. Additionally, the state officials sued lacked the authority to enforce or change the state court procedures. The court reversed the district court's partial denial of the motion to dismiss and remanded with instructions to dismiss the case in full. View "Cotto v. Campbell" on Justia Law

In October 2019, Edward Magruder pleaded guilty to possession with intent to distribute more than a kilogram of heroin. He later sought to withdraw his plea, arguing that the district court erred by requiring him to assert his innocence to withdraw the plea and that his plea was tainted due to ineffective assistance of counsel. The investigation leading to his arrest involved the FBI and Colombian National Police, who identified Magruder through wiretaps and geolocation data as part of a drug-trafficking conspiracy. Magruder was arrested in June 2019 after being observed traveling between D.C. and New York with heroin in his backpack.The United States District Court for the District of Columbia denied Magruder's motions to withdraw his plea. The court found that Magruder failed to assert a viable claim of innocence and that his plea was not tainted by ineffective assistance of counsel. Magruder's new counsel filed multiple motions to withdraw the plea, all of which were denied. The district court sentenced Magruder to 180 months of imprisonment followed by 60 months of supervised release.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying Magruder's motion to withdraw his guilty plea. The appellate court found that even if the district court erred in requiring an assertion of innocence, the error was harmless because Magruder's Fourth Amendment claims were meritless. The court concluded that Magruder's counsel was not ineffective for failing to raise these claims, as the search of Magruder's backpack was lawful and the evidence obtained from the Louisiana search warrant was admissible under the good-faith exception. The judgment of the district court was affirmed. View "USA v. Magruder" on Justia Law

The case involves Maine healthcare workers who were terminated from their employment for refusing to comply with a COVID-19 vaccine mandate based on their religious beliefs. The mandate, initially promulgated by emergency rule on August 12, 2021, was no longer enforced as of July 12, 2023, and was repealed effective September 5, 2023. The plaintiffs filed suit in the United States District Court for the District of Maine, asserting that the mandate's lack of religious exemptions violated the First and Fourteenth Amendments. Their motion for a temporary restraining order and preliminary injunction was denied, and the denial was affirmed by the First Circuit. The Supreme Court also denied their application for emergency injunctive relief.The defendants moved to dismiss the complaint for failure to state a claim, which was granted. The First Circuit affirmed in part and reversed in part, reinstating the First Amendment Free Exercise and Fourteenth Amendment Equal Protection Clause claims for declaratory and injunctive relief against state health officials. Following the repeal of the mandate, the defendants moved to dismiss the remaining claims as moot, and the district court granted the motion, also denying the plaintiffs leave to amend the complaint.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's determinations. The court held that the challenge was moot because the COVID-19 vaccine mandate had been repealed and was no longer in effect. The court also found that no exceptions to mootness, such as voluntary cessation or capable of repetition yet evading review, applied. The court further affirmed the denial of the plaintiffs' request to amend their complaint, concluding that justice did not require permitting further amendments to broaden the scope of their claims. View "Lowe v. Gagne-Holmes" on Justia Law

A pretrial detainee at Goose Creek Correctional Center was asked to provide a urine sample for random drug testing. Under the Department of Corrections (DOC) policy, inmates have two hours to provide a sample. The detainee attempted to comply but was unable to urinate within the required time. Consequently, he was charged with refusing to provide a urine sample, which is considered a high-moderate infraction, and was disciplined.The detainee pled not guilty at a disciplinary hearing, arguing that he tried to comply but could not urinate. The prison tribunal found him guilty using the preponderance of the evidence standard and imposed punitive segregation. The detainee appealed to the facility’s superintendent, who upheld the decision. He then appealed to the superior court, arguing that the preponderance of the evidence standard violated his due process rights and that he should have been offered a saliva test instead of a urine test.The superior court affirmed the administrative decision, concluding that the preponderance of the evidence standard is constitutional. The court also noted that the detainee did not raise the saliva test argument until his reply brief, thus it was not preserved for review.The Supreme Court of the State of Alaska reviewed the case. The court held that the Alaska Constitution permits the use of a preponderance of the evidence standard in prison disciplinary proceedings, balancing the inmate’s interest in avoiding harsher conditions against the prison’s interest in maintaining order. The court also declined to address the saliva test argument, as it was not properly preserved during the administrative proceedings or raised in a timely manner in the superior court. The decision of the superior court was affirmed. View "Valoaga v. State of Alaska" on Justia Law

Aqudre Quailes and Ayinda Harper were separately charged with being felons in possession of a firearm in violation of 18 U.S.C. § 922(g)(1). Harper was on Pennsylvania state probation and parole when his probation officer discovered photographs of him holding firearms on social media. During a home visit, officers found a semiautomatic pistol in his residence. Harper had thirteen prior felony convictions. Quailes, on parole for one of his six prior felony convictions, was arrested for absconding from parole. Authorities found firearms and ammunition in his girlfriend’s apartment, where he had been staying.The United States District Court for the Middle District of Pennsylvania dismissed both indictments, ruling that § 922(g)(1) was unconstitutional under the Second Amendment. The court reasoned that the defendants' status as parolees or probationers did not negate their Second Amendment rights. The Government appealed, arguing that § 922(g)(1) is constitutional as applied to state parolees and probationers.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that § 922(g)(1) is constitutional as applied to Quailes and Harper because neither had completed their criminal sentences. The court referenced its en banc decision in Range v. Attorney General, which held that § 922(g)(1) was unconstitutional for a felon who had completed his sentence, and United States v. Moore, which upheld the constitutionality of § 922(g)(1) for felons still serving their sentences. The court concluded that historical practices support disarming convicts who are still serving their sentences, including those on state parole or probation. Consequently, the Third Circuit reversed the District Court’s orders and remanded the cases for further proceedings. View "USA v. Quailes" on Justia Law

The case involves the Protecting Americans from Foreign Adversary Controlled Applications Act, which will make it unlawful for companies in the U.S. to provide services to distribute, maintain, or update TikTok unless its U.S. operations are severed from Chinese control. Petitioners, including TikTok Inc. and U.S. TikTok users, argue that the Act violates the First Amendment.The U.S. Court of Appeals for the District of Columbia Circuit consolidated and denied the petitions, holding that the Act does not violate the First Amendment. The court assumed strict scrutiny applied but found the Act satisfied this standard, citing compelling national security interests and narrow tailoring. Chief Judge Srinivasan concurred, suggesting intermediate scrutiny was appropriate and the Act was constitutional under that standard.The Supreme Court reviewed whether the Act, as applied to petitioners, violates the First Amendment. The Court assumed without deciding that the Act's provisions are subject to First Amendment scrutiny. It found the Act's prohibitions and divestiture requirement content-neutral, justified by the government's interest in preventing China from collecting sensitive data from U.S. TikTok users. The Court applied intermediate scrutiny, concluding the Act furthers an important government interest and does not burden substantially more speech than necessary.The Court affirmed the judgment of the U.S. Court of Appeals for the District of Columbia Circuit, holding that the Act does not violate petitioners' First Amendment rights. View "TikTok Inc. v. Garland" on Justia Law

Jeffrey Brown, Markus Maly, and Peter Schwartz were tried and convicted by a jury for assaulting police officers on the Capitol grounds on January 6, 2021. They traveled separately to Washington, D.C., and participated in the riot following then-President Trump’s rally. Evidence showed that Maly and Schwartz assaulted officers on the Lower West Terrace, with Schwartz throwing a chair and both using pepper spray. All three later entered the Tunnel, where they used pepper spray against officers and attempted to push through the police line.The United States District Court for the District of Columbia denied Schwartz’s motions to suppress evidence obtained from his cellphone and to sever the trials. The court found that the FBI had compelled Schwartz to unlock his phone but ruled that this act was not testimonial. The jury convicted all three defendants on all counts, and the district court sentenced Schwartz to 170 months, Maly to 72 months, and Brown to 54 months.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed Brown’s and Maly’s convictions and Brown’s sentence. It vacated Schwartz’s conviction on the 18 U.S.C. § 1512(c)(2) charge and remanded for resentencing. The court also held that compelling Schwartz to unlock his cellphone violated the Fifth Amendment and remanded to the district court to determine which, if any, of Schwartz’s counts of conviction must be vacated due to this error. The court found sufficient evidence to support the jury’s findings that the defendants used pepper spray and, in Schwartz’s case, a chair as deadly or dangerous weapons. The court also upheld the district court’s refusal to give a special unanimity instruction for Maly’s Section 111 counts and found no abuse of discretion in Brown’s sentencing. View "USA v. Brown" on Justia Law

Lukouxs Brown was charged with first-degree murder after allegedly killing a coworker. Before his arraignment, his counsel observed signs of mental illness, including hearing voices and a history of schizophrenia. The district court found probable cause to believe Brown was not competent to stand trial and ordered a psychiatric evaluation. Dr. Arnold Andersen diagnosed Brown with a schizophrenia-like disorder and substance abuse disorders, concluding he was not competent but could potentially be restored to competency. Brown was committed to the Iowa Medical and Classification Center (IMCC) for treatment.After eight months of treatment, Dr. Andersen reported that Brown remained incompetent and unlikely to be restored to competency within a reasonable time. The district court, however, allowed the State to obtain a separate psychiatric evaluation, which concluded that Brown was competent. The district court found Brown competent to stand trial and reinstated the criminal proceedings. Brown filed an interlocutory appeal, arguing the district court erred in its competency determination and in allowing the State to obtain a separate evaluation.The Iowa Court of Appeals reviewed the case de novo, found Brown was not competent, and remanded the case for further treatment. The State sought further review, challenging the standard of review and the district court's decision to allow a separate evaluation. The Iowa Supreme Court reaffirmed the de novo standard of review for competency determinations, emphasizing the protection of constitutional rights. The court also held that Iowa Code does not permit separate psychiatric evaluations at the dispositional phase of competency proceedings. The court vacated the Court of Appeals decision, reversed the district court order, and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Brown" on Justia Law

Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

The case involves Michigan's electricity market regulations, specifically the Individual Local Clearing Requirement (ILCR), which mandates that electricity retailers in Michigan's lower peninsula procure a certain percentage of their capacity from within that region. Plaintiffs, including Energy Michigan and the Association of Businesses Advocating Tariff Equity (ABATE), challenged the ILCR on the grounds that it violates the dormant Commerce Clause by discriminating against interstate commerce.The United States District Court for the Eastern District of Michigan initially dismissed the Michigan Public Service Commission (MPSC) on Eleventh Amendment grounds but allowed the case to proceed against individual commissioners. The court denied summary judgment motions from both sides, finding that there were factual disputes regarding whether the ILCR discriminated against interstate commerce. After a three-day bench trial, the district court concluded that the ILCR did not violate the Commerce Clause.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the ILCR is facially discriminatory because it requires electricity to be generated within a specific geographic region, effectively favoring in-state over out-of-state electricity. The court held that this discrimination necessitates strict scrutiny, which the district court did not properly apply. The Sixth Circuit reversed the district court's judgment and remanded the case for further proceedings to determine if the ILCR can survive strict scrutiny by proving it is the only means to achieve the state's goal of ensuring a reliable energy supply. View "Energy Michigan, Inc. v. Public Service Commission" on Justia Law