Justia Constitutional Law Opinion Summaries

In 2023, the Tennessee General Assembly enacted a statute imposing a cap of twenty voting members on metropolitan councils, affecting the Metropolitan Government of Nashville and Davidson County, which had a forty-member council. Metro Nashville and several individual plaintiffs challenged the statute, arguing it violated the Local Legislation Clause and the Exemption Clause of the Tennessee Constitution. They sought declaratory and injunctive relief to prevent implementation of the law.The Chancery Court for Davidson County, sitting as a three-judge panel, held that the cap violated both constitutional provisions and issued a permanent injunction against enforcement. The panel found some claims moot due to expired compliance deadlines but concluded that the main cap provision remained justiciable. The Court of Appeals reversed, holding that the cap did not violate either clause and that the claims were not moot, except as to certain implementation provisions.After granting permission to appeal, the Supreme Court of Tennessee reviewed the case. During the proceedings, the General Assembly amended the statute, removing the implementation provisions and the language linking the cap to those provisions. The Supreme Court determined that these amendments rendered the Local Legislation Clause claim moot, as the alleged defect no longer existed. The Court vacated the Court of Appeals’ judgment on this issue and instructed the trial court to dismiss the claim.The Court further held that the Exemption Clause claim remained justiciable but, on the merits, concluded that the Exemption Clause only exempts consolidated governments from constitutional requirements regarding legislative bodies, not from statutory requirements imposed by the legislature. Therefore, the twenty-member cap does not violate the Exemption Clause. The Supreme Court of Tennessee affirmed the Court of Appeals’ judgment on this issue and remanded the case for further proceedings consistent with its opinion. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law

A 2023 Tennessee law amended the structure and appointment process for the board of commissioners of the Metropolitan Nashville Airport Authority, reducing its board size and transferring most appointment powers to state officials. The changes applied only to the Nashville authority and not to any other airport authority in the state. The Metropolitan Government of Nashville and Davidson County filed suit, alleging that the new law violated specific provisions of the Tennessee Constitution, including the Local Legislation Clause and Anti-Ripper Clause.The Chancery Court for Davidson County, sitting as a three-judge panel, found that the law violated all three constitutional provisions alleged and enjoined its enforcement. The state defendants appealed and the Tennessee Court of Appeals affirmed the trial court in part, holding that the law violated the Local Legislation Clause, but reversed on the Law of the Land Clause. The Anti-Ripper Clause claim was not addressed by the appellate court. The state sought further review in the Supreme Court of Tennessee.While the case was pending before the Supreme Court of Tennessee, the General Assembly repealed and replaced the challenged provisions with new legislation that applied more broadly to multiple airport authorities. The Supreme Court of Tennessee held that these legislative changes rendered the case moot because the specific statutory provisions challenged were no longer in effect and could not reasonably be expected to recur. It found no basis to apply the voluntary cessation exception to mootness, as there was no evidence the legislature would reenact the specific challenged provisions. The Supreme Court vacated the lower courts’ judgments and remanded the case to the trial court with instructions to dismiss it as moot. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law

A man serving a life sentence for terrorism-related convictions at a federal prison in Colorado, who is severely disabled with both arms amputated above the elbow and vision loss in one eye, filed suit against several federal officials. He alleged violations of his federal constitutional and statutory rights stemming from his conditions of confinement and medical care while incarcerated. His claims included inadequate dental and medical care, denial of a medical diet, lack of proper prosthetics, and insufficient accommodation for his disabilities.The United States District Court for the District of Colorado dismissed most claims on the defendants’ motions to dismiss and for summary judgment. Some claims were dismissed as moot or for failure to exhaust administrative remedies, while others, including his Eighth Amendment deliberate indifference claim, were dismissed for failure to state a claim under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. The district court also found his Administrative Procedure Act (APA) claim challenging his placement at the prison was time-barred. The plaintiff voluntarily dismissed his remaining claims with prejudice and then appealed.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment. The appellate court held that the plaintiff could not pursue his Eighth Amendment deliberate indifference claim under the APA because he failed to allege a final agency action and sued individual officers rather than the agency or officials in their official capacities. The court also held that his Bivens claim for deliberate indifference arose in a new context and was foreclosed due to the existence of the Bureau of Prisons’ administrative remedies. The appellate court further found no abuse of discretion in denying leave to amend the complaint and ruled that the plaintiff had waived his challenge to deposition transcript fees by failing to object before the magistrate judge. View "Mostafa v. Blanche" on Justia Law

During a protest at San Jose City Hall, the plaintiff attended as a peaceful participant. At one point in the evening, after some protestors threw bottles and objects at the police, an officer equipped with a 40mm projectile impact weapon responded by firing into the crowd. The plaintiff, who did not throw anything or engage with the police, was struck behind the knee by a foam baton round and subsequently developed a pulmonary embolism as a result of his injury.After these events, the plaintiff filed suit in the United States District Court for the Northern District of California against the officer and the City of San Jose, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and California’s Bane Act, as well as common law claims. The case proceeded to trial, where the plaintiff argued that the officer fired indiscriminately into the crowd rather than targeting a specific threat. The jury found in favor of the plaintiff on all claims against the officer, awarding damages, and specifically found that the officer fired indiscriminately. The district court denied the officer’s post-verdict motion for judgment as a matter of law on the Fourth Amendment and Bane Act claims.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court concluded that the officer’s actions constituted a seizure and that the use of force was excessive, thus violating the plaintiff’s Fourth Amendment rights. However, the court held that the law was not clearly established for purposes of qualified immunity because prior precedent, particularly Nelson v. City of Davis, was materially distinguishable from the circumstances present here. As a result, the Ninth Circuit reversed the district court’s denial of qualified immunity on the Fourth Amendment claim, vacated the award of attorneys’ fees, and remanded for recalculation pending resolution of the state law claim, which was certified to the California Supreme Court. View "JOHNSON V. ADGAR" on Justia Law

In this case, Indiana enacted legislation in 2021 that imposed new requirements on public school teachers who wished to have union dues automatically deducted from their paychecks. These requirements included submitting a written authorization containing a specific statement regarding their First Amendment rights, annual renewal of the authorization, confirmation via official work email, and annual notice of their right to resign from the union. These procedures applied only to teachers and not to other public employees in Indiana.Previously, the United States District Court for the Southern District of Indiana reviewed the case after teachers’ unions and individual members challenged the law, arguing it violated their First Amendment rights to free speech and association. The district court initially found that the mandated statement on the authorization form constituted compelled speech and issued a preliminary injunction. After Indiana amended the statute in response, the district court concluded that the revised law no longer violated the Free Speech Clause, but still found that the additional requirements on teachers constituted viewpoint discrimination against their freedom of association. The court permanently enjoined enforcement of the provisions and the State appealed.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s judgment. The Seventh Circuit held that the authorization form’s required statement was government speech, not compelled private speech, and did not violate the Free Speech Clause. However, the court agreed with the district court that the additional requirements imposed only on teachers and their unions amounted to unconstitutional viewpoint discrimination under the First Amendment’s Freedom of Association protections. The court applied strict scrutiny and found Indiana’s justifications insufficient. As a result, the Seventh Circuit affirmed the district court’s judgment permanently enjoining enforcement of the challenged provisions. View "Anderson Federation of Teachers v. Rokita" on Justia Law

A woman traveling through Raton, New Mexico, was approached twice by the defendant, who eventually led her into an abandoned motel. There, the defendant forcibly pulled her through a window, assaulted, strangled, and sexually assaulted her, causing physical and sexual injuries. The key facts are that the defendant's actions resulted in serious harm to the victim, including both physical and sexual violence, and these actions were largely undisputed at trial.The defendant was charged in district court with first-degree kidnapping, second-degree criminal sexual penetration (CSP II), and aggravated battery. The jury convicted him on all three counts, and he received an aggregate sentence of approximately thirty years. On appeal, the New Mexico Court of Appeals vacated both the CSP II and aggravated battery convictions on double jeopardy grounds, applying a novel analytical approach that compared the lesser offenses against each other, rather than against the most serious conviction, which was first-degree kidnapping. The State challenged this approach, arguing that the proper analysis should compare each lesser conviction with the most severe conviction that remained.The Supreme Court of the State of New Mexico held that double jeopardy barred the defendant’s conviction for CSP II because the State relied on that single sexual offense both to support the first-degree kidnapping charge and as an independent offense, without introducing another distinct sexual offense. Accordingly, the CSP II conviction was vacated. However, the Court found that aggravated battery and kidnapping were supported by sufficiently distinct factual bases, allowing both convictions to stand. The Court reversed the Court of Appeals’ decision vacating aggravated battery and affirmed its decision vacating CSP II, remanding for further proceedings. The Court also declined to change its established double jeopardy analysis. View "State v. Neal" on Justia Law

A fifteen-year-old defendant with an intellectual disability was arrested and charged with first-degree murder and tampering with evidence after the death of a younger child. Unable to post a high cash bond, the defendant remained incarcerated pretrial. At arraignment, defense counsel raised concerns about the defendant’s competency to stand trial. Over the next three years and three months, the case was repeatedly delayed due to defense counsel’s failure to schedule and facilitate a competency evaluation. The defendant was ultimately found competent to stand trial after several years in custody. Additional delays occurred, including a fourteen-month period during which the State pursued an interlocutory appeal. The first trial ended in a mistrial, while the second resulted in convictions for second-degree murder and tampering with evidence, leading to an adult prison sentence.After conviction, the defendant argued that his constitutional right to a speedy trial had been violated. The District Court for Santa Fe County rejected this claim, attributing much of the delay to defense counsel. The New Mexico Court of Appeals affirmed, holding that the delays caused by defense counsel’s neglect should be attributed to the defendant and that the State’s conduct did not warrant relief.The Supreme Court of the State of New Mexico reversed. Applying the Barker v. Wingo factors, the court held that the nearly six-year delay was extraordinary and presumptively prejudicial. It concluded that because the delays were caused by defense counsel’s neglect, and the defendant’s intellectual disability prevented him from meaningfully participating or acquiescing, the delays could not be weighed against the defendant. The State also failed to monitor and move the case forward. The court held that the defendant’s speedy trial rights were violated, vacated the convictions, and ordered dismissal of the indictment. View "State v. Villalobos" on Justia Law

The owner of a long-standing hamburger restaurant in Salina, Kansas hired an artist to paint a large, UFO-themed display on the exterior wall of the business. The display included playful imagery related to the restaurant and a slogan. Shortly after painting began, city officials determined the display was a "sign" under Salina's sign code, not an unregulated mural, because it referenced the restaurant's products. They concluded the display was too large to qualify for a permit, informed the owner to pause work, and instructed him to submit a permit application. The city later placed the application on indefinite hold, citing a review of the sign regulations. The owner disputed consenting to this hold and subsequently filed suit challenging the sign code and the city's enforcement.The United States District Court for the District of Kansas granted summary judgment to the plaintiffs on their First Amendment claims. The court found Salina's sign code failed intermediate scrutiny because there was insufficient evidence connecting the city’s distinction between signs and murals to its stated interests of safety, aesthetics, and property values. Declaratory relief was granted, but a permanent injunction was denied. Salina appealed.Reviewing the case, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment. The appellate court held that Salina did not produce evidence demonstrating that regulated signs—as defined by the city—posed greater risks to its interests than unregulated murals. Therefore, the sign code failed intermediate scrutiny. The court further held that placing the permit application on indefinite hold constituted an impermissible prior restraint on speech, as the city did not show the applicant consented to the hold or that it complied with required time limits. The district court’s judgment was affirmed. View "Cozy Inn, Incorporated v. City of Salina, Kansas" on Justia Law

The defendant was stopped by police in Kentucky while driving erratically. He was found wearing body armor and carrying eight firearms, knives, ammunition, drugs, and a gasoline can. He claimed he was headed to Fort Knox to discuss a security clearance. Investigation revealed that he was prohibited from possessing firearms due to a prior Missouri court adjudication of mental illness, which had resulted from an incident in St. Louis where he exhibited erratic behavior and his girlfriend reported suicidal tendencies. The Missouri court had committed him for treatment and barred him from firearm possession, and he never petitioned to restore his rights.The United States District Court for the Eastern District of Kentucky reviewed the case after Laykovich was indicted for violating 18 U.S.C. § 922(g)(4) (prohibiting firearm possession by persons adjudicated as mentally defective). Laykovich moved to dismiss the charge on Second Amendment grounds, but the district court denied the motion, reasoning that the government could disarm individuals whose mental illness posed a risk of harm. Laykovich then entered a plea agreement, reserving his right to appeal both the constitutional issue and sentencing. At sentencing, the district court found, based on circumstantial evidence, that Laykovich had induced his girlfriend to act as a straw purchaser for some firearms, and applied a sentencing enhancement.The United States Court of Appeals for the Sixth Circuit reviewed the appeal de novo. It held that § 922(g)(4) is constitutional as applied to persons adjudicated as mentally defective and dangerous, because it is “relevantly similar” to longstanding laws allowing civil detention of dangerous mentally ill persons and serves the same public safety purpose. The court affirmed the district court’s application of the sentencing enhancement and its within-guidelines sentence, finding no procedural or substantive error. The judgment was affirmed. View "United States v. Laykovich" on Justia Law

After the petitioner’s adult son was terminated from a local fire department, shots were fired at the fire station, leading to an investigation by the Cabell County Sheriff's Department. Officers suspected the son due to recent statements and visited the petitioner’s property, where the son exited holding a 9mm pistol. The officers handled and photographed the firearm for safety reasons. Later, a mistaken report led officers to believe the pistol was stolen, prompting a search warrant and an arrest warrant for the son. When officers returned to execute the warrants, a confrontation ensued, resulting in injuries to officers and the petitioner, and the son’s death. It was later determined the firearm was lawfully owned by the petitioner.The Cabell County grand jury indicted the petitioner on several charges, including attempted murder and obstructing an officer. During the grand jury proceedings, officers referred to the 9mm Beretta as “stolen,” but did not disclose its lawful ownership, which had been discovered weeks after the incident. The petitioner moved to suppress evidence relating to the firearm, to dismiss the indictment due to alleged misleading grand jury testimony, and to strike two jurors for cause. The Circuit Court of Cabell County denied these motions, finding that any mistakes regarding the firearm’s status were innocent, that no prima facie showing of willful fraud by officers was made, and that the challenged jurors affirmed their impartiality.The Supreme Court of Appeals of West Virginia reviewed the appeal and affirmed the circuit court’s order. The Court held that any error regarding the search and seizure of the firearm was harmless beyond a reasonable doubt, as the conviction for obstructing an officer was based on the petitioner’s own conduct. The Court also concluded there was no basis to go behind the indictment, as no willful fraud was shown, and found no prejudice in jury selection since the petitioner removed the challenged jurors using peremptory strikes. View "State v. Pinkerman" on Justia Law