Justia Constitutional Law Opinion Summaries

A woman was arrested in Randolph County, Alabama, under a system that required arrestees to pay a predetermined bail amount based on the charged offense for immediate release. Those unable to pay had to wait until an initial appearance, which could take up to three days, and frequently did not result in a release determination. Instead, release decisions were often deferred until a preliminary hearing up to four weeks later. The plaintiff, unable to afford bail, filed a class action alleging that the county’s bail practices discriminated against indigent individuals and violated their constitutional rights.The United States District Court for the Middle District of Alabama initially granted a temporary restraining order, releasing the plaintiff. While the case was pending, Randolph County adopted a new, more permissive bail policy. Defendants moved to dismiss the case as moot, arguing the new policy ended the challenged conduct. The district court certified a class of arrestees unable to pay secured bail, but after the Supreme Court denied certiorari in a similar case, Schultz v. Alabama, the district court dismissed most claims as moot, limiting plaintiffs to facial challenges against the new policy, and concluded those remaining claims failed to state a plausible claim for relief.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal. The court held that the voluntary cessation doctrine precludes defendants from mooting the case simply by changing the bail policy during litigation. The class may proceed with facial and as-applied challenges to the prior bail practices, as well as as-applied challenges to the current bail practices. However, the court affirmed the district court’s dismissal of facial challenges to the current bail policy. The case was remanded for further proceedings consistent with these holdings. View "Edwards v. Randolph County Sheriff" on Justia Law

TC Telephone participated as a provider in California’s LifeLine program, offering measured-rate telephone service to low-income customers. This service allowed subscribers 60 untimed local calls per month, for which TC Telephone incurred per-minute charges from other carriers. To recoup its costs, TC Telephone sought and received reimbursement from the California Public Utilities Commission (the Commission) based on the total minutes used, rather than per-call. Over several years, Commission staff approved these per-minute reimbursement claims and provided guidance that was ambiguous about the proper method for calculating reimbursements.The Commission began investigating TC Telephone’s reimbursement practices after concerns arose regarding claim amounts. In March 2020, the Commission issued a resolution clarifying that LifeLine providers should seek reimbursement on a per-call basis, not per-minute, and specified that this clarification applied prospectively. However, the Commission subsequently initiated proceedings to determine whether TC Telephone’s prior per-minute reimbursement claims violated program rules. In its initial decision, the Commission found that TC Telephone had improperly sought per-minute reimbursement and ordered it to repay over $8 million in funds received between January 2018 and March 2020, plus interest. TC Telephone’s petition for rehearing was denied.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the Commission’s decisions. The court held that prior to the Commission’s resolution, the reimbursement rules were unconstitutionally vague and failed to provide TC Telephone with fair notice that per-minute reimbursement was prohibited. Because even Commission staff did not know whether per-minute reimbursement was allowed, punishing TC Telephone for its claims violated due process. The court annulled the Commission’s decisions and remanded the matter for further proceedings. View "TC Telephone v. Pub. Utilities Com." on Justia Law

The plaintiff, a convicted inmate at Riverside Regional Jail, was placed in restrictive housing after being found with contraband, and later spent five months in the Restrictive Housing Unit (RHU) due to repeated infractions and misconduct. During this period, he experienced varying levels of confinement and privileges, including periods of isolation, limited access to recreation, and additional restrictions following disciplinary incidents. He was also shackled to a telephone on two occasions for several hours, during which he alleged suffering humiliation and physical discomfort.The United States District Court for the Eastern District of Virginia granted summary judgment to the jail officials, both before and after limited discovery. The court dismissed all but two defendants and ordered production of any surveillance video related to the incidents. After reviewing the available evidence, including video footage, the district court rejected the plaintiff’s claims regarding conditions of confinement and due process violations.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The panel held that the district court did not abuse its discretion in granting summary judgment before discovery, as the plaintiff failed to show that additional evidence would have affected the outcome. Reviewing de novo, the Fourth Circuit concluded that the plaintiff’s placement in restrictive housing did not implicate a protected liberty interest under the Fourteenth Amendment because the conditions, duration, and review process did not constitute atypical and significant hardship. The court also found that the conditions of confinement—including the telephone shackling incidents—did not rise to the level of “extreme deprivation” required for an Eighth Amendment violation, and even if they had, the officials would be entitled to qualified immunity because no clearly established right was violated. The judgment of the district court was affirmed. View "Mason v. Talley" on Justia Law

A white male employee of Seattle’s Human Services Department alleged that the City’s Race and Social Justice Initiative (RSJI) classified employees according to race, and that a series of workplace incidents—including racially aligned affinity groups, race-specific trainings, and racially offensive remarks from coworkers and supervisors—created a hostile work environment. He asserted that the RSJI and workplace conduct led to discrimination, retaliation, constructive discharge, and violation of his equal protection rights. After resigning in September 2021, he filed suit alleging claims under Title VII, the Washington Law Against Discrimination (WLAD), and the Equal Protection Clause.The United States District Court for the Western District of Washington dismissed as time-barred certain Title VII and WLAD claims based on acts predating statutory limitations periods. It granted summary judgment to the City on the remaining claims, finding insufficient evidence of actionable discrimination, retaliation, hostile work environment, constructive discharge, or equal protection violations. The court partially granted the City’s evidentiary objections to exhibits offered by the plaintiff.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s summary judgment de novo. The appellate court affirmed summary judgment for the City on the constructive discharge, disparate treatment, and retaliation claims, and also affirmed summary judgment on the Equal Protection Clause claim for lack of Article III standing. However, viewing the evidence in the light most favorable to the plaintiff, the Ninth Circuit reversed summary judgment on the hostile work environment claims under Title VII and WLAD, holding that there was a genuine issue of material fact as to whether the plaintiff was subjected to a racially hostile work environment. The case was remanded for further proceedings consistent with this determination. View "DIEMERT V. CITY OF SEATTLE" on Justia Law

Missouri enacted a congressional redistricting map in 2022 and then adopted a new map in 2025. Under the Missouri Constitution, a newly enacted law like the 2025 map does not become effective until approved by voters in a referendum, provided enough signatures are collected for such a petition. The Missouri Supreme Court held in September 2026 that the 2025 map “is not the law and has never been the law” and would not take effect unless approved in the 2026 election referendum, so the 2022 map remained in force for the upcoming election.After the Missouri Supreme Court’s ruling, a group of voters and candidates filed suit in federal court, arguing that the U.S. Constitution required Missouri to use the 2025 map in the 2026 election. The U.S. District Court for the Eastern District of Missouri issued a temporary restraining order on September 8, effectively requiring the use of the 2025 map. However, this order was stayed by the Supreme Court of the United States on September 10. Despite this, the U.S. Court of Appeals for the Eighth Circuit subsequently ordered the District Court to enter a permanent injunction requiring use of the 2025 map, prompting further review.The Supreme Court of the United States granted a stay of the District Court’s September 21 and 22 injunctions and the Eighth Circuit’s mandate and order, maintaining the prior stay, and prohibiting any federal court orders requiring use of the 2025 map in the 2026 election. The Court held that the 2022 map must be used in the ongoing election, given Missouri law and the Purcell principle, which discourages altering election rules during an ongoing election. The Supreme Court’s stay will remain unless further order is issued. View "People Not Politicians v. Onder" on Justia Law

Walker was involved in a scheme with two others to distribute cocaine. He arranged for cocaine to be mailed from a supplier near the U.S.-Mexico border, using one co-conspirator to send the packages and a postal worker whom he paid to deliver them along his mail routes. Law enforcement intercepted two cocaine packages, observed Walker conducting drug sales from his girlfriend’s home, and later searched that residence, finding drugs, paraphernalia, and Walker’s phone. Walker confessed to drug activities after the search.The United States District Court for the Western District of Michigan denied Walker’s motion to suppress evidence from the residence, finding probable cause for the search warrant and, alternatively, that the good-faith exception applied. At trial, the jury convicted Walker on all counts related to the drug conspiracy, and he was sentenced to 360 months’ imprisonment.Walker appealed to the United States Court of Appeals for the Sixth Circuit, raising three main issues. First, he argued that the evidence from the search should have been suppressed. The Sixth Circuit found the warrant affidavit was sufficient to establish probable cause and, even if not, that the officers' reliance on the warrant was objectively reasonable under the good-faith exception. Second, Walker challenged the admission of statements he made during a proffer session, asserting protection under Federal Rule of Evidence 410. The appellate court held that Walker, through counsel, had waived this argument by conceding that certain statements were admissible due to their inconsistency with his trial defense. Third, Walker argued a violation of his Confrontation Clause rights regarding a co-defendant’s testimony. The court found this right was also waived when Walker and his counsel agreed to a curative instruction for the jury to disregard the testimony. The Sixth Circuit affirmed the convictions. View "United States v. Walker" on Justia Law

A financial services company operating a designated contract market began offering sports-event contracts, which allowed users to buy and sell positions based on the outcome of various sporting events. These offerings attracted the attention of Ohio and Tennessee state gambling regulators, who asserted that the company was violating state gambling laws by operating without appropriate licenses and by allowing underage users to participate. Both states sent cease-and-desist letters to the company, demanding it stop offering sports-event contracts to their residents. The company, which claimed to be federally authorized under the Commodity Exchange Act (CEA), argued that federal law preempted state regulation of its activities.In Ohio, the company filed suit in the United States District Court for the Southern District of Ohio, seeking a preliminary injunction to prevent enforcement of state gambling laws against it. The district court denied the injunction, finding the company had not demonstrated that its sports-event contracts were “swaps” subject to exclusive jurisdiction of the Commodity Futures Trading Commission (CFTC) and, even if they were, had not established federal preemption. The company appealed. In Tennessee, a similar suit was filed in the United States District Court for the Middle District of Tennessee, which granted a preliminary injunction, holding the company was likely to succeed because the contracts constituted “swaps” and conflict preemption applied. Tennessee officials appealed.The United States Court of Appeals for the Sixth Circuit reviewed both cases together. It held that the company’s sports-event contracts did not satisfy the statutory definition of a “swap” under the CEA and thus did not fall within CFTC exclusive jurisdiction. The court further held that, even assuming the contracts were swaps, the CEA neither expressly nor impliedly preempted Ohio’s or Tennessee’s gambling laws. The Sixth Circuit affirmed the denial of the preliminary injunction in Ohio, vacated the grant of the injunction in Tennessee, and remanded for further proceedings. View "KalshiEX LLC v. Schuler" on Justia Law

A man who served as a confidential informant for the Department of Homeland Security became involved in criminal activity by continuing to deal drugs while cooperating with law enforcement. He developed a corrupt relationship with his handler, a special agent, who was later convicted of federal corruption charges. The informant’s unauthorized criminal conduct was uncovered when he became the target of two separate narcotics sting operations. Following his arrest, law enforcement searched his home and cell phone, and he was charged with multiple drug-related crimes.In proceedings before the United States District Court for the Northern District of Illinois, the defendant moved to suppress his post-arrest statements and evidence obtained from the warrantless searches of his home and cell phone. The district court suppressed his post-arrest statements as involuntary but denied suppression of the physical evidence, holding it admissible under the inevitable discovery doctrine. The court also denied his motions to dismiss for vindictive prosecution, sever various counts for trial, and quash a subpoena to his former handler, who invoked his Fifth Amendment right against self-incrimination. The case proceeded to a jury trial, where the defendant was convicted on three drug counts but acquitted on one. His post-trial motions for acquittal or a new trial were denied, and he was sentenced to 156 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not abuse its discretion in quashing the subpoena, that the inevitable discovery doctrine applied to the search evidence, and that the evidence was sufficient to support the convictions. The court also determined that the defendant’s other claims were either waived or without merit, and it found no abuse of discretion in the sentence imposed. View "USA v Howard" on Justia Law

Two police officers attempted to execute a felony arrest warrant for a man believed to be affiliated with a local gang. The officers were aware of a recent incident in which the man had fled a traffic stop and believed he was an active fugitive wanted for serious drug-related offenses. Although the warrant had been recalled days before, the police database had not been updated, and the officers were unaware of this development. They located the man in a backyard, approached from ten to twenty feet away with their guns drawn, and ordered him to climb a fence and submit to arrest. The man claims both officers aimed their guns at his head, causing him fear and shock, but he complied without incident.After the arrest, the man was detained and later released when it was confirmed the warrant was no longer active. He filed a lawsuit in the United States District Court for the Central District of California, alleging the officers used excessive force in violation of his Fourth Amendment rights. The district court denied the officers’ motion for summary judgment, finding that a reasonable juror could conclude they used excessive force by aiming their weapons at the man’s head, and that this conduct was a clear violation of an established constitutional right.Reviewing the case, the United States Court of Appeals for the Ninth Circuit reversed the district court’s decision. The appellate court held that, under the circumstances, the officers did not violate the Fourth Amendment by approaching with weapons drawn, given their reasonable belief that the man was a serious and potentially dangerous fugitive who might resist or flee. The court further found that, even if excessive force had been used, there was no clearly established law making the officers’ conduct unlawful in these circumstances. The case was remanded with instructions to enter judgment for the officers. View "MEDRANO V. ACOSTA" on Justia Law

A technology company developed an artificial intelligence system and imposed contractual and technical restrictions to prevent its use for fully autonomous lethal military operations and mass domestic surveillance. The company had previously adapted its product to meet some government needs but refused to remove these two key restrictions when the Department of War (formerly the Department of Defense) sought contractual terms allowing all lawful uses of the AI system. This disagreement coincided with a dispute over the product’s use in a sensitive military operation and previous incidents where the AI’s restrictions prevented it from fulfilling government requests. As a result, the Secretary of War determined that continued use of the AI posed a national security risk and ordered its removal from the Department’s supply chain under the Federal Acquisition Supply Chain Security Act of 2018.The Department promptly notified the company, offered an opportunity for reconsideration, and began implementing the exclusion. The company petitioned the United States Court of Appeals for the District of Columbia Circuit for review and raised statutory and constitutional challenges, arguing that the exclusion was arbitrary, beyond statutory authority, and violated due process and First Amendment rights. The company also sought a stay, which was denied, and later requested rescission, which was also denied by the Secretary.The United States Court of Appeals for the District of Columbia Circuit held that it had jurisdiction under the statute to review the procurement action. The court found the Department’s determination reasonable, concluding that the company’s ability and willingness to restrict the AI’s use posed a covered “supply chain risk” under the statute, even without evidence of malicious intent. The court also held that less intrusive measures were not reasonably available, and that any procedural deficiencies in notice did not prejudice the company. The court further held that the exclusion did not violate the Fifth or First Amendments. The petitions for review were denied. View "Anthropic PBC v. United States Department of War" on Justia Law