Justia Constitutional Law Opinion Summaries

After reports and investigations of sexual abuse allegations against a father, the State’s Department of Human Services (DHS) petitioned for foster custody of his children. The family court consolidated the cases, and in September 2024, it issued orders granting DHS foster custody and incorporating a Service Plan that required the father to participate in sex abuse treatment. Importantly, the plan mandated that he “acknowledge and take responsibility for the sexual abuse to his victims” as a condition of successful completion.The father appealed these orders to the Intermediate Court of Appeals of Hawai‘i (ICA), which affirmed the family court's decision. Due to complications with his legal representation, the father’s application for writ of certiorari to the Supreme Court of Hawai‘i was filed late, but the Supreme Court agreed to consider the merits, recognizing his constitutional right to counsel in parental rights termination proceedings.The Supreme Court of Hawai‘i reviewed whether the State can require a parent, as part of mandated rehabilitation therapy in child custody proceedings, to make incriminating disclosures. The court held that under Article I, Section 10 of the Hawai‘i Constitution, the State may not require a parent to admit to criminal misconduct as a condition of completing court-ordered therapy, as this violates the privilege against self-incrimination. However, the court clarified that if a parent’s silence or refusal to admit abuse hinders effective therapy, the court may consider that as a factor in custody determinations without violating the constitutional privilege. The court vacated the lower courts’ orders to the extent they required the father to admit to sexual abuse, and remanded for further proceedings consistent with its opinion. The lower courts’ orders were otherwise affirmed. View "In re: T.J." on Justia Law

Gateway Conservation Alliance challenged the Montana Department of Environmental Quality’s (DEQ) issuance of an opencut mining permit to TMC, Inc. for a site in Gallatin County. After DEQ approved the permit, Gateway filed an administrative appeal with the Board of Environmental Review, alleging violations of environmental statutes related specifically to the permit and site. While that administrative appeal was pending, Gateway also filed a complaint in the Gallatin County District Court, arguing that recent legislative amendments (HB 599) to the governing mining statute violated Montana’s constitutional right to a clean and healthful environment. Gateway sought a declaration of unconstitutionality, an injunction against enforcement, and vacatur of the permit.The District Court for the Eighteenth Judicial District dismissed Gateway’s complaint, holding that Gateway had failed to exhaust its administrative remedies before seeking judicial review, as required under the Montana Administrative Procedure Act (MAPA). The District Court reasoned that Gateway’s constitutional challenge was not a pure facial attack on the administrative scheme itself, but was instead tied to the specific permit at issue, and thus did not fall within any exception to the exhaustion requirement.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal. The Supreme Court held that a party challenging an agency decision governed by MAPA must first complete the administrative process and obtain a final agency decision before seeking judicial review, even if the challenge includes constitutional claims. The only exception recognized is for pure facial constitutional challenges to the administrative process itself, which was not present here. The Court concluded that Gateway’s claims could be raised on judicial review after exhausting administrative remedies, but not before. The order of dismissal was affirmed. View "Gateway Conservation Alliance v. State" on Justia Law

A Lebanese citizen who worked as a physician and educator in the United States traveled to Lebanon to visit family and, upon her return to Boston Logan International Airport, was detained by Customs and Border Protection (CBP) officers. During inspection, officers reviewed her phone and found photos and videos related to Hezbollah, which is designated as a foreign terrorist organization by the United States. She acknowledged deleting some of the photos before her arrival, explained her religious motivations and familial connections, and denied supporting Hezbollah’s political or military activities. After an interview, CBP officers determined she was inadmissible as an immigrant without valid documents because her intentions could not be verified due to derogatory information found during inspection. She was issued an expedited removal order, her H-1B visa was revoked, and she was returned to Lebanon, subject to a five-year bar on reentry.The United States District Court for the District of Massachusetts dismissed her amended habeas corpus petition for lack of jurisdiction, finding that the Immigration and Nationality Act (INA) strips federal courts of jurisdiction to review expedited removal orders except in narrow circumstances not present in her case. The district court also concluded that the Suspension Clause did not preserve jurisdiction for her claims and that her remaining arguments fell outside the scope of habeas review permitted under the INA.The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that it lacked jurisdiction to review the petitioner’s challenge to the expedited removal order and the revocation of her visa because her claims did not fall within the exceptions enumerated in 8 U.S.C. § 1252(e)(2). The court further concluded that the Suspension Clause did not require broader habeas review in these circumstances and rejected arguments that her case was distinguishable from binding Supreme Court precedent. View "Alawieh v. Mullin" on Justia Law

Edward Williams was convicted in Pennsylvania for driving under the influence of alcohol at the “highest rate,” a crime punishable by up to five years in prison due to a prior DUI offense. He was sentenced to home confinement for ninety days to two years, but his conviction triggered 18 U.S.C. § 922(g)(1), which prohibits firearm possession by anyone convicted of a crime punishable by more than one year of imprisonment. Williams continued to possess firearms until learning of the prohibition, after which he divested himself of firearms and refrained from further possession.The United States District Court for the Eastern District of Pennsylvania reviewed Williams’s claim that § 922(g)(1), as applied to him, violated the Second Amendment. Both parties moved for summary judgment. The District Court granted summary judgment in favor of Williams, holding that the statute’s application to his nonviolent DUI conviction was unconstitutional under the Second Amendment. The United States appealed this decision.The United States Court of Appeals for the Third Circuit, sitting en banc, affirmed the District Court’s judgment. The Court held that the permanent firearm prohibition imposed by § 922(g)(1) was not consistent with the Nation’s historical tradition of firearm regulation when applied to individuals convicted of nonviolent offenses, such as Williams’s DUI. The Court emphasized that longstanding restrictions targeted individuals who posed a risk of violence or misuse of arms, not felons in general or those convicted of nonviolent conduct. The government failed to show that Williams’s offense or current status justified permanent disarmament under historical analogues. The Court concluded that Williams, as a peaceable citizen who poses no present risk, is constitutionally protected in his right to possess firearms. The District Court’s decision was affirmed. View "Williams v. Attorney General" on Justia Law

An employee with a long tenure at a state agency suffered a heart attack and was subject to permanent medical restrictions preventing him from performing his original job duties at a coal-fired power plant. The agency accommodated him for two years with a temporary assignment and ultimately offered him a permanent position that met his medical restrictions, but at a lower hourly wage. The employee did not respond to the offer and was subsequently terminated.The employee sought review of his termination before the Civil Service Division of the Office of Management and Enterprise Services (OMES). An administrative law judge found he failed to meet his burden to prove that the agency had no reasonable basis for his termination, and OMES adopted that decision. The employee then sought judicial review in the District Court of Mayes County, which reversed OMES’s order. The district court found that the employee had a substantial interest in his employment and that the statutory and regulatory procedures for termination under 62 O.S. § 34.301 violated due process. The district court also concluded that the agency lacked a reasonable basis to terminate the employee and ordered further proceedings.The Supreme Court of the State of Oklahoma reviewed the case. It held that the Civil Service Modernization Act does not create a constitutionally protected property interest in continued public employment for state employees, so due process protections are not triggered by terminations under this statute. The Court further held that the district court erred in reweighing the evidence and misapplied the statutory burden of proof: the employee did not prove there was no reasonable basis for his termination. The Supreme Court reversed the district court’s judgment and affirmed OMES’s final agency order upholding the termination. View "TURNER v. OKLAHOMA GRAND RIVER DAM AUTHORITY" on Justia Law

James Bost previously pleaded guilty to several crimes in Pennsylvania, including terroristic threats, which involved threatening to commit a violent crime with intent to terrorize another. Years after his conviction, Bost was found by police with a stolen pistol while on bail for an unrelated charge. This led to federal charges for possessing a firearm as a felon under 18 U.S.C. § 922(g)(1), and for possessing a stolen firearm under § 922(j). Bost moved to dismiss the indictment, contending that the felon-in-possession law was unconstitutional both on its face and as applied to him, citing his Second Amendment rights.The U.S. District Court for the Western District of Pennsylvania denied Bost’s motion to dismiss. It reasoned that his conviction for terroristic threats sufficed to show he could not be trusted with a firearm and rejected his facial challenge to the statute, finding he could not demonstrate that the law was unconstitutional in every application. Bost then entered a conditional guilty plea, preserving his right to appeal the Second Amendment claims.The United States Court of Appeals for the Third Circuit, sitting en banc, reviewed the District Court’s denial de novo. The Third Circuit held that certain predicate crimes, such as Bost’s conviction for terroristic threats, establish a prima facie risk of physical violence from misuse of firearms and thus justify disarmament under § 922(g)(1). The court concluded that because Bost’s predicate crime involved a threat of physical violence, his disarmament was consistent with the historical tradition of firearm regulation. The court rejected his facial, vagueness, and Commerce Clause challenges, as well as his challenge to the stolen firearm statute. The Third Circuit affirmed the judgment of the District Court. View "USA v. Bost" on Justia Law

Dylan Youngblood was arrested in Kalispell, Montana, in September 2023 on an outstanding felony warrant. During the arrest, officers found fentanyl pills on his person and located two pistols, drug paraphernalia, and suspected methamphetamine in his car. Youngblood admitted ownership of one pistol and to having used fentanyl earlier that day. He was indicted for possessing a firearm while being an unlawful user of, and addicted to, a controlled substance, in violation of 18 U.S.C. § 922(g)(3).In the United States District Court for the District of Montana, Youngblood moved to dismiss the indictment, arguing that § 922(g)(3) was unconstitutional both on its face and as applied to him. The district court denied the motion, applying the Second Amendment framework from New York State Rifle & Pistol Ass’n v. Bruen, and found that while Youngblood’s conduct fell within the Second Amendment’s text, the statute’s application to frequent users of methamphetamine and fentanyl was consistent with a historical tradition of temporarily disarming intoxicated individuals. The district court concluded that the statute was both facially and as-applied constitutional. Youngblood then entered a conditional guilty plea, preserving his right to appeal the denial of his motion.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that its prior decision in United States v. Stennerson, which upheld the facial constitutionality of § 922(g)(3), remained binding even after the Supreme Court’s decision in United States v. Hemani, which addressed only an as-applied challenge. The Ninth Circuit also found that Youngblood waived his as-applied challenge by failing to argue it specifically and distinctly in his opening brief. The court affirmed Youngblood’s conviction. View "USA V. YOUNGBLOOD" on Justia Law

Two children, whose parents divorced in Missouri, were involved in a custody dispute. After the parents agreed to a custody arrangement, the children refused to leave the courthouse with their mother. Judge Eric Eighmy intervened, escorting the children to a conference room and later to the juvenile division, where repeated threats of foster care failed to persuade them. Ultimately, Judge Eighmy ordered a juvenile officer to lock the children in holding cells for twenty to forty minutes, after which they agreed to leave with their mother.The children’s father brought suit in the United States District Court for the Western District of Missouri, alleging violations of their Fourth Amendment rights under 42 U.S.C. § 1983. Judge Eighmy’s claim for judicial immunity was denied both at the motion-to-dismiss and summary-judgment stages, and the Eighth Circuit previously affirmed that denial in Rockett ex rel. K.R. v. Eighmy, 71 F.4th 665 (8th Cir. 2023). After a trial, the jury found for the children, awarding $5,000 each in damages. The district court resubmitted the damages issue for clarification and ultimately upheld the jury’s award, also granting $326,637.22 in attorney fees.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo and affirmed the district court’s judgment. The court held that Judge Eighmy’s actions constituted an unreasonable seizure in violation of clearly established Fourth Amendment rights. The court also dismissed the appeal regarding judicial immunity, finding it unreviewable due to procedural forfeiture. The Eighth Circuit affirmed the damages and attorney fees awards, finding no abuse of discretion by the district court. The disposition was to dismiss the appeal in part and affirm the district court’s judgments. View "Rockett v. Eighmy" on Justia Law

The defendant, after serving a prison sentence for a Florida felony drug offense, was released into the state's conditional release program. Three days post-release, he signed a certificate agreeing to various conditions, including submission to searches by his release supervisor. Shortly before his conditional release was scheduled to end, he tested positive for cocaine. The supervisor recommended a warrant for his arrest, which was issued by the Florida Commission on Offender Review. When officers executed the warrant at his residence, the supervisor conducted a warrantless search, finding drugs and a firearm. This led to federal charges including possession of a firearm by a convicted felon and possession with intent to distribute a controlled substance.The United States District Court for the Southern District of Florida denied the defendant’s motion to suppress evidence from the warrantless search, concluding he was still on conditional release at the time and that reasonable suspicion justified the search. The defendant then pleaded guilty to the firearm possession charge. During sentencing, the presentence investigation report recommended a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), listing several prior Florida convictions as possible predicate offenses. The defendant objected, arguing both legally and factually that the convictions did not qualify and that the government had not proven their existence by a preponderance of the evidence.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of the motion to suppress, holding that the defendant was still subject to conditional release and that the search was supported by reasonable suspicion. However, the appellate court vacated the sentence, finding the district court erred by imposing the ACCA enhancement without requiring the government to prove the necessary predicate convictions. The case was remanded for resentencing without the ACCA enhancement. View "USA v. Louis" on Justia Law

A high school principal was terminated by his school district’s board after an internal investigation into allegations that he mistreated a female student over several years and attempted to dissuade staff from making a mandatory report of child abuse. The investigation included interviews with the student, a school counselor, the principal, and other witnesses. The board provided the principal with written notice of the allegations and an opportunity to respond, after which it held a multi-day hearing where both sides presented evidence and witnesses. The board found, by a preponderance of the evidence, that the principal had engaged in inappropriate conduct toward the student and interfered with mandatory reporting obligations, and concluded that there was just and sufficient cause for termination.The principal appealed the dismissal to the Windham Southeast School District Board and, following the board’s decision, filed suit in the Vermont Superior Court, Bennington Unit, Civil Division. He challenged the sufficiency of the evidence, argued that the pre-termination and post-termination processes violated his constitutional rights, and asserted claims of breach of contract, wrongful termination, denial of due process, intentional infliction of emotional distress, and defamation. The civil division dismissed some claims, granted summary judgment to the defendants on the remaining claims, and found that the board’s decision was supported by the record, that the principal was afforded adequate due process, and that no evidence supported claims of bias or other wrongdoing.The Vermont Supreme Court reviewed the case and affirmed the civil division’s decision. The Court held that the principal received constitutionally adequate pre- and post-termination process, that the trial court did not abuse its discretion in denying discovery related to alleged bias, and that sufficient evidence supported the board’s findings and conclusion that just cause existed for dismissal. The Court also found that structural or actual bias claims were either unpreserved or unsupported. View "Perrin v. Windham Southeast Supervisory Union" on Justia Law