Justia Constitutional Law Opinion Summaries

A student with severe cognitive disabilities attended a public high school in Hawai‘i and was repeatedly sexually abused by male students, resulting in significant psychological harm, including a psychotic breakdown and persistent post-traumatic stress disorder. The student’s mother, acting for herself and her daughter, sued the State of Hawai‘i, the Department of Education, and school employees for negligence, alleging failure to protect her daughter despite the school’s awareness of her vulnerabilities and repeated warning signs. The evidence at trial showed that school staff recognized the student’s extraordinary vulnerability and received multiple reports of abuse but failed to take reasonable steps to prevent or address it.The Circuit Court of the First Circuit conducted a lengthy bench trial and found the State liable for negligently failing to protect the student, awarding over $14 million in damages to the plaintiffs. However, without a request from the State, the court sua sponte reduced the damages by 30%, attributing that portion of fault to the male students who committed the abuse, citing Hawai‘i Revised Statutes § 663-10.5. The State had not argued at trial that the male students should be apportioned fault; instead, its arguments for apportionment focused on the mother’s alleged negligence, which the court rejected. Plaintiffs moved to amend the judgment to reverse the apportionment, but the court denied the motion.On appeal, the Supreme Court of the State of Hawai‘i held that the circuit court’s sua sponte allocation of fault to the male students violated the plaintiffs’ constitutional due process rights because they lacked notice and an opportunity to be heard on the issue. The court further found insufficient evidence that the male students were “other tortfeasors” under the statute and held that apportionment under HRS § 663-10.5 is an affirmative defense, for which the State bears the burden of pleading and proof. The Supreme Court vacated the apportionment, affirmed the remainder of the circuit court’s judgment, and remanded for entry of an amended judgment awarding plaintiffs the full damages. The State’s cross-appeal regarding discovery and damages was rejected. View "R.H. v. Hayashi" on Justia Law

A former Michigan Department of Corrections prisoner with asthma and an alleged allergy to dogs experienced allergic reactions while incarcerated at multiple facilities that housed dogs for training purposes. He reported symptoms such as asthma attacks and respiratory infections to prison officials, who provided prescribed treatments but did not confirm a specific dog allergy. After pursuing the prison’s grievance process, he was moved within the facility but still encountered dogs during required programming. Subsequently, he requested an ADA accommodation to be housed away from dogs, but this was denied due to lack of medical documentation. He later filed suit, alleging violations of the Eighth Amendment, the ADA, the Rehabilitation Act, and state laws.The United States District Court for the Western District of Michigan granted summary judgment in favor of the defendants. The court found that prison officials were not deliberately indifferent to his medical needs under the Eighth Amendment, as they consulted medical staff who did not recommend a transfer based on his condition. For the ADA and Rehabilitation Act claims, the court determined that inadequate medical treatment was not actionable under those statutes and that the plaintiff had not demonstrated denial of prison services or programs due to his disability. The court also declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the grant of summary judgment, holding that the prison counselor was entitled to qualified immunity because no clearly established law required the transfer of prisoners with asthma to facilities without dog programs. The court also found that the plaintiff failed to provide sufficient medical documentation to support the necessity of the requested accommodation under the ADA and Rehabilitation Act and did not establish discriminatory animus. The district court’s refusal to exercise supplemental jurisdiction over state-law claims was also affirmed. View "Miles-El v. Michigan" on Justia Law

Brian Blunt, a long-term employee of the Town of Gilbert, was promoted to Commander in 2021 and signed an at-will employment agreement as a condition of his promotion and pay raise. This agreement allowed either party to terminate the relationship at any time, with or without cause, and was consistent with the then-existing Peace Officers’ Bill of Rights (POBR), which permitted such contractual deviations. In 2023, following employee complaints and an external investigation, Blunt was terminated without a pre-termination hearing or appeal process. He requested these procedural protections but was denied.After his termination, Blunt brought an action in Arizona Superior Court seeking a writ of mandamus compelling the Town to provide him procedural protections under POBR and due process. The Town removed the case to the United States District Court for the District of Arizona and moved to dismiss. The District Court granted the motion, holding that Blunt had no constitutionally protected employment interest because his contract was at-will and the 2022 amendment to POBR did not apply retroactively to his agreement. Blunt appealed to the United States Court of Appeals for the Ninth Circuit, which certified three questions to the Supreme Court of Arizona regarding the retroactive application of the 2022 POBR amendment.The Supreme Court of Arizona held that the presumption against retroactivity, codified in Arizona law, prohibits applying the 2022 amendment to at-will employment agreements executed before its effective date. The court found that the at-will employment term constituted a vested substantive right at the time of contract formation, and absent express legislative intent for retroactivity, the amendment cannot alter those pre-existing rights. The court answered only the first certified question, as its resolution was dispositive, and returned the matter to the Ninth Circuit. View "BLUNT v TOWN OF GILBERT" on Justia Law

The appellant, a father of six Indian children, challenged the termination of his parental rights under the Indian Child Welfare Act (ICWA). The Office of Children’s Services (OCS) took emergency custody of the children after receiving reports of neglect, including unsanitary living conditions and food insecurity. The father tested positive for multiple substances, and an initial out-of-home safety plan with a relative failed. OCS placed the children with their aunt, a preferred ICWA placement, and initiated proceedings for temporary custody, adjudication, disposition, and ultimately, termination of parental rights. Throughout the case, the father was represented by counsel at various stages, sometimes proceeding pro se, and repeatedly claimed he did not receive discovery materials.The Superior Court of the State of Alaska, Third Judicial District, Palmer, held hearings at each stage. Temporary custody was granted after expedited hearings, with findings that removal was necessary to prevent imminent harm. The father stipulated to probable cause for the children being in need of aid, reserving the right to contest at adjudication. Subsequent hearings resulted in approval of OCS’s permanency plan. The father failed to comply with his case plan, and OCS filed for termination. Multiple motions by the father, alleging ICWA and constitutional violations, were rejected by the superior court, which found OCS had complied with ICWA at all stages.On appeal, the Supreme Court of the State of Alaska reviewed three procedural arguments: denial of discovery, improper emergency removal, and alleged ICWA violations in earlier foster care proceedings. The court held that the superior court did not abuse its discretion regarding discovery, that OCS’s emergency removal complied with ICWA and Alaska law, and that alleged errors in earlier foster care actions did not invalidate the later, separate termination action. The court affirmed the termination order, finding no reversible error. View "Dash D. v. State" on Justia Law

Two attorneys, licensed in New Jersey and Michigan, sought admission to the Florida Bar and challenged a Florida rule requiring applicants admitted to another bar for more than twelve months to pay a higher application fee. They argued that this "experienced-applicant" rule violated the dormant Commerce Clause by burdening out-of-state applicants both on its face and in practical effect. One attorney paid the fee and then sued, seeking a refund and an injunction; the other attorney did not pay and joined the suit to seek prospective relief.The United States District Court for the Northern District of Florida initially dismissed most claims for lack of standing or based on Eleventh Amendment immunity, but allowed a limited practical-effect claim against the executive director of the Florida Board of Bar Examiners. After further amendments and discovery, the district court denied summary judgment to the plaintiffs and granted summary judgment to the executive director, finding that the rule did not discriminate against out-of-state applicants in practice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the Board of Bar Examiners is an arm of the state and therefore immune from suit under the Eleventh Amendment. As to the claim against the executive director, the court found that the experienced-applicant rule did not facially discriminate against out-of-state applicants, as it was based solely on years of admission, not geographic origin. The court further concluded that undisputed evidence showed the rule imposed similar burdens on both in-state and out-of-state applicants and was adopted for legitimate, non-protectionist reasons. The Eleventh Circuit affirmed the district court’s dismissal and summary judgment, holding that neither facial nor practical-effect dormant Commerce Clause claims could succeed. View "Hernandez v. Florida Board of Bar Examiners" on Justia Law

Alton Cannon, previously adjudicated as a Tier III sex offender, was convicted in 1998 for unlawful sexual contact in the first degree and required to register as a Tier III sex offender for life. After completing his original probation, Cannon was later found guilty in the Superior Court of Delaware in 2025 for two counts of failure to report as a registered sex offender. As part of his sentence for those offenses, he was placed on Level II probation and required by the Department of Correction to wear a GPS-enabled ankle bracelet.Cannon moved for a modification of his sentence, specifically requesting the removal of the GPS monitoring condition. The Superior Court denied his motion, finding that under 11 Del. C. § 4121(u), the Department of Correction was mandated to impose GPS monitoring on any Tier III sex offender under supervision, regardless of whether the probation was for the original sex offense or a subsequent crime. Cannon appealed this ruling, arguing that the statutory GPS monitoring requirement should only apply to probation for the offense that triggered the registry requirement, not to later, unrelated offenses. He also raised a constitutional challenge, asserting that the application of GPS monitoring in his case constituted an unreasonable search under the Fourth Amendment.The Supreme Court of the State of Delaware reviewed the statutory language and found it unambiguous, determining that the requirement applies to any Tier III sex offender on probation, regardless of the underlying offense. The court also concluded that, as applied to Cannon, the statute did not violate the Fourth Amendment. The court affirmed the judgment of the Superior Court, upholding both the statutory interpretation and the constitutionality of the GPS monitoring requirement. View "Cannon v. State" on Justia Law

A man with a history of sexual offenses, including a 2017 conviction for sexual abuse in the third degree, was later incarcerated for violating the terms of a special sentence imposed due to that conviction. While serving time for this parole revocation, the State petitioned to civilly commit him as a sexually violent predator (SVP) under Iowa Code chapter 229A. The petition was filed shortly before his anticipated discharge from prison. The man had a long criminal record and numerous behavioral violations in prison, several involving sexual misconduct.The Iowa District Court for Polk County conducted a trial, during which the respondent moved to dismiss the petition. He argued that because he was only confined for a nonsexual violation of his special sentence at the time of the petition, he was not “presently confined” as required by statute, and that due process required the State to prove a recent overt act indicating a risk of future violence. The district court denied the motion, found that the State had proven the statutory elements beyond a reasonable doubt—including that the respondent was an SVP and was presently confined as defined in the statute—and ordered his commitment. The respondent appealed, reasserting his statutory and constitutional arguments.The Supreme Court of Iowa reviewed the appeal. The court held that the statutory definition of “presently confined” includes incarceration resulting from a special sentence for a sexually violent offense, and that the State was not required to prove a recent overt act under these circumstances. The court further concluded that this statutory scheme did not violate federal or state due process, as long as the respondent was presently confined due to a sexually violent offense and found to be an SVP under the statute. The judgment of the district court was affirmed. View "In Re Detention Of Harlow" on Justia Law

A man entered a gun shop in Las Vegas seeking to sell two firearms, including a Glock 30 handgun equipped with an auto-sear device, which converts the weapon into a fully automatic machine gun. The store employee recognized the illegal modification and alerted the store owner, who then reported the incident to law enforcement and provided video surveillance. As a result, the man was charged with several offenses, including carrying a concealed firearm, possession of a machine gun, and violating regulations regarding modified semiautomatic firearms. A jury convicted him on these counts, and he later pleaded guilty to being a prohibited person in possession of a firearm.The Eighth Judicial District Court in Clark County entered convictions on all counts and imposed a prison sentence for possession of a machine gun, with lesser concurrent terms for the other offenses. The defendant appealed, raising constitutional and procedural challenges, including arguments that Nevada’s firearm statutes were unconstitutional and that his convictions for both possession of a machine gun and a modified semiautomatic firearm violated the Double Jeopardy Clauses of the United States and Nevada Constitutions.The Supreme Court of Nevada reviewed the case. It held that Nevada’s prohibitions on machine guns and modified semiautomatic firearms do not violate either the federal or state constitutions, as these weapons are considered dangerous and unusual and thus unprotected by the Second Amendment or the analogous Nevada provision. However, the court found that convicting the defendant for both possession of a machine gun and possession of a modified semiautomatic firearm based on the same conduct constituted double jeopardy, as the elements of the latter are entirely subsumed within the former. The court reversed the conviction for violating regulations regarding modified semiautomatic firearms, affirmed the remaining convictions, and remanded the case for entry of an amended judgment. View "ARMSTRONG VS. STATE" on Justia Law

Late at night, as Allison Beaver left work at a Taco Bell in Bristol, Tennessee, Charles Mixon confronted her in the parking lot with a handgun, forced her into her car, and ordered her to undress. When Mixon became distracted while driving, Beaver escaped and called the police. Mixon fled across the state line into Virginia, where he confessed to his stepfather, admitting he had stolen his stepfather’s gun for the carjacking. Upon refusing to return the firearm, Mixon was apprehended by police as he crossed back into Tennessee, in possession of the stolen gun.The United States District Court for the Eastern District of Tennessee heard the case against Mixon, who was indicted for carjacking, using and brandishing a firearm in furtherance of a crime, being a felon in possession of a firearm with at least three qualifying convictions under the Armed Career Criminal Act (ACCA), and possessing a stolen firearm. Mixon moved to dismiss the indictment, arguing the statutes exceeded Congress’s Commerce Clause power and that his Texas burglary convictions did not qualify as “violent felonies” under ACCA. The district court denied these motions and allowed evidence regarding his prior offenses, despite Mixon’s offer to stipulate to certain facts.On appeal, the United States Court of Appeals for the Sixth Circuit addressed Mixon’s Commerce Clause challenge, his argument that his Texas burglaries were not ACCA predicates, and his objection to the admission of prior crime evidence. The Sixth Circuit held that the statutes at issue were valid exercises of congressional power under prevailing precedent, that Texas burglary under Penal Code § 30.02(a) qualifies as generic burglary for ACCA purposes, and that the district court did not abuse its discretion in admitting evidence of Mixon’s prior robbery. Accordingly, the court affirmed Mixon’s convictions and sentence. View "United States v. Mixon" on Justia Law

Three individuals alleged that New Jersey child welfare caseworkers violated their constitutional rights during a series of investigations and child removals in 2017. The principal facts involved caseworkers entering the plaintiffs’ residence without a warrant and subsequently removing children from parental custody without court authorization. One plaintiff was the mother whose children were removed; another was the father of her youngest child and a resident of the home; the third was the grandfather. The plaintiffs argued that the warrantless entry and removals were not justified by imminent danger, and that their consent to certain “family plan agreements” was coerced.The United States District Court for the District of New Jersey initially dismissed the plaintiffs’ complaint for lack of jurisdiction, but the United States Court of Appeals for the Third Circuit vacated that dismissal in part and remanded. Upon remand, the District Court dismissed the claims again, this time based on qualified immunity—holding that the defendants were shielded from liability because the plaintiffs had not shown violation of clearly established constitutional rights. The District Court found the defendants’ actions reasonable given alleged concerns about child safety and home conditions. Subsequent motions to dismiss by sheriff defendants were also granted, and the plaintiffs appealed.Reviewing the appeal, the United States Court of Appeals for the Third Circuit affirmed most aspects of the District Court’s dismissal. However, it held that the plaintiffs had plausibly alleged a violation of clearly established Fourth Amendment law regarding the warrantless home entry, as no imminent danger was apparent from the complaint. The Third Circuit reversed the dismissal of this Fourth Amendment claim against the caseworker who entered the home and remanded for further proceedings. All other claims, including those based on substantive and procedural due process, were affirmed as dismissed due to qualified immunity. View "O''Bryant v. Division of Child Protection and Permanency" on Justia Law