Justia Constitutional Law Opinion Summaries

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

The case concerns an individual who, after causing a car accident while driving under the influence, fled the scene on foot. When a uniformed Texas Department of Public Safety trooper attempted to apprehend him, the individual drew a pistol and shot the officer in the head and shoulder at close range. The resulting injury left the officer comatose and severely disabled, requiring multiple brain surgeries. Several months later, after additional medical complications and procedures, the officer died. The individual was also involved in related subsequent shootings at police officers during the ensuing manhunt but ultimately surrendered and was arrested.The 389th Judicial District Court in Hidalgo County tried the case. A jury found the individual guilty of capital murder for intentionally killing a peace officer performing his lawful duty. The jury also answered special sentencing issues, leading the court to impose a death sentence. The defendant raised several issues on direct appeal to the Texas Court of Criminal Appeals, including challenges to the sufficiency of the evidence on causation, alleged errors in the jury charge, and claims regarding the prosecutor’s access to his jail communications.The Texas Court of Criminal Appeals reviewed the case as required in death penalty appeals. The court found that the evidence supported the jury’s finding that the defendant’s actions were the but-for and proximate cause of the officer’s death. It held that the trial court did not err by omitting a concurrent causation jury instruction or by including a general instruction regarding the consideration of facts and circumstances, as neither resulted in egregious harm. The court also determined there was no violation of the defendant’s due process or equal protection rights regarding access to jail communications. The court affirmed the conviction and the sentence of death. View "GODINEZ v. STATE OF TEXAS" on Justia Law

The defendant was arrested following allegations of sexual assault against a minor, G.L., which reportedly began when the family lived in Wyoming and continued after relocating to Montana. After the arrest, law enforcement seized electronic devices from the defendant’s residence, and forensic analysis of these devices became central to the pretrial proceedings. The defendant was unable to post bail and remained incarcerated for an extended period, during which he consistently objected to trial delays and asserted his right to a speedy trial.The Eighth Judicial District Court in Cascade County presided over the case. The State requested multiple trial continuances due to ongoing forensic analysis and other administrative issues, including staff absences and problems with jury pool formation. Defense counsel did not object to most continuances but requested additional time for preparation after new counsel was appointed. The District Court found that a total of 630 days elapsed between arrest and trial, attributing most of the delay to the State but classifying all as institutional delay. The District Court denied the defendant’s motion to dismiss for violation of his speedy trial right, finding no oppressive pretrial conditions beyond the baseline prejudice of detention and no impairment of the defense.The Supreme Court of the State of Montana reviewed the case de novo. It held that the District Court erred by misapplying the relevant speedy trial factors, particularly by failing to recognize periods of State negligence and by using an excessively demanding standard for oppressive incarceration. The Supreme Court found that the State was responsible for most of the delay, that the defendant had persistently asserted his right, and that the prolonged, burdensome pretrial detention constituted prejudice. The Court reversed the District Court’s denial of the motion to dismiss, reversed the conviction, and remanded with instructions to dismiss the charge. View "State v. Yuste" on Justia Law

The plaintiffs, citizen sponsors of three ballot initiatives for the 2024 Montana election cycle, challenged several provisions of Senate Bill 93, enacted by the 2023 Montana Legislature, which revised laws governing the statewide initiative process. Among the challenged provisions were: a $3,700 filing fee for submitting initiative proposals (with a possible hardship waiver), a prohibition on resubmitting substantially similar measures for four years after defeat, authorization for legislative interim committees to vote on proposed measures and place the result on the petition, and granting the Attorney General authority to review the substantive legality of initiatives. When the plaintiffs submitted their initiatives, the Secretary of State’s office required payment of the filing fee or proof of hardship; the plaintiffs withheld payment, and their proposals were rejected.The case was filed in the District Court of the First Judicial District, Lewis and Clark County, seeking declaratory and injunctive relief against eleven provisions of SB 93. The District Court granted summary judgment for the plaintiffs on four claims, declaring the four challenged provisions unconstitutional, and denied relief on seven others. The parties then stipulated to dismiss all remaining claims not resolved in the plaintiffs’ favor. The District Court also denied the plaintiffs’ motion for attorney fees under the private attorney general doctrine.On appeal, the Supreme Court of the State of Montana reviewed the constitutionality of the challenged provisions and the denial of attorney fees. The Court held that the Legislature may not impose requirements for ballot measures exceeding the conditions set forth in the Montana Constitution. Specifically, the Court affirmed that the four-year resubmission ban, the legislative committee vote on petitions, the $3,700 filing fee, and the Attorney General’s substantive review authority all unconstitutionally impaired the people’s reserved initiative power and were facially invalid. The Court also affirmed the District Court’s denial of attorney fees, finding no abuse of discretion. View "Ellingson v. State" on Justia Law

A petitioner challenged actions taken by a county justice court in Montana, claiming his First Amendment rights were violated when the presiding judge ordered the arrest of his friend for recording a pre-jury selection proceeding. The petitioner argued he had authorized his friend to make the recording, noting that similar recordings had occurred in prior hearings without incident. The petitioner asserted that the judge’s background as a retired police officer and current role in the courthouse created a conflict of interest. He also sought to protect what he viewed as his free speech rights in the courtroom.The Fergus County Justice Court, presided over by Judge Kelly Mantooth, imposed penalties on the friend for recording the proceeding. The petitioner requested the Montana Supreme Court to exercise supervisory control under M. R. App. P. 14(3), arguing that constitutional rights were at stake and that the normal appeal process was inadequate. He alleged the Justice Court was proceeding under a mistake of law and causing a gross injustice.The Supreme Court of the State of Montana reviewed the petition for writ of supervisory control. The Court held that while there is a constitutional right for the public to observe court proceedings, there is no constitutional entitlement to record them. A court may impose reasonable, content-neutral time, place, and manner restrictions within its courtroom. The Justice Court’s actions did not violate the petitioner’s First Amendment rights, and the record of the proceeding was available through official channels. The Court found no conflict of interest and concluded supervisory control was not warranted. The petition was denied and dismissed, and the matter was closed. View "Miller v. Fergus Co. Justice Court" on Justia Law

The case involves challenges to a 2024 order issued by the Federal Communications Commission (FCC) regulating communications services provided to incarcerated individuals, following statutory amendments in 2022. The FCC's order imposed rate caps for intrastate, interstate, and international prison communications, regulated the reimbursement of facility costs, excluded site commission payments from rate calculations, prohibited service providers from paying site commissions, preempted state and local laws requiring such payments, allowed alternate pricing plans, and required clearer consumer disclosures. These actions prompted petitions for review from nonprofit organizations, service providers, and state governments, consolidated by the United States Multidistrict Judicial Panel on Litigation and transferred to the United States Court of Appeals for the First Circuit.In the lower proceedings, the FCC's imposition of rate caps and prohibition of site commissions were challenged, and the parties disputed whether the First Circuit was the proper venue. The FCC then issued a new order in late 2025, modifying certain aspects of the 2024 order, notably by increasing rate caps to include more safety and security costs. This led to supplemental briefing on mootness. Service providers requested voluntary dismissal of their petitions, state governments argued portions of their petitions were moot, and nonprofit organizations maintained some challenges remained live.The United States Court of Appeals for the First Circuit granted the voluntary dismissal of service providers' petitions, dismissed portions of state governments' petitions as moot or for lack of jurisdiction (including constitutional challenges not raised before the FCC), and denied other state challenges to the FCC's authority and rulemaking. The court denied most nonprofit organizations’ challenges except for those related to the FCC’s treatment of certain costs in rate caps, which it held in abeyance pending review of the 2025 order. The court’s disposition was to dismiss, deny, or hold in abeyance the various petitions as appropriate. View "Direct Action for Rights and Equality v. FCC" on Justia Law

A man was subject to a one-year protective order issued by a family court. He was later charged with two counts of violating this order, based on allegations that he approached the petitioner’s workplace and contacted her in prohibited ways. The man had attended the hearing at which the protective order was issued. At trial, after the State presented its case, the defense argued that personal service of the order was required for a violation, even though the man was present when the order was issued. The State argued that his presence at the hearing provided sufficient notice.The Family Court of the Second Circuit agreed with the defense, concluding that personal service was an element of the offense and that the State had not established this element. The family court acquitted the defendant, entering a judgment of acquittal and dismissing the case. The State appealed, contending that the judgment of acquittal was actually an order sustaining a motion to dismiss and was therefore appealable. The Intermediate Court of Appeals (ICA) disagreed, holding that the ruling was an acquittal based on the court’s determination that the State failed to prove an element of the charge, making the appeal unreviewable.The Supreme Court of the State of Hawai‘i reviewed the case on certiorari. It held that service is not an element of the offense of violating an order for protection under HRS § 586-11. The court found that the family court erred in interpreting the statute but that the acquittal, even if based on legal error, barred retrial under Article I, Section 10 of the Hawai‘i Constitution. The Supreme Court affirmed the ICA’s dismissal of the State’s appeal. View "State v. Chau" on Justia Law

Three transgender children in Arizona, representing a class of all transgender individuals born in Arizona who wish to amend the sex marker on their birth certificates without undergoing a sex change operation, challenged the requirements for amending birth certificates. Arizona law, specifically A.R.S. § 36-337(A)(3), requires the registrar to amend a person’s birth certificate upon receiving a written request and a physician’s statement verifying a sex change operation. The plaintiffs argued that this “surgical requirement” violates the Equal Protection and Due Process Clauses of the U.S. Constitution.The United States District Court for the District of Arizona granted summary judgment for the plaintiffs, finding that the statute discriminated based on transgender status and burdened fundamental rights, thus applying heightened and strict scrutiny. The district court concluded the statute failed these standards and entered a permanent injunction, striking the word “operation” from the statute and its implementing regulation to allow amendments without proof of surgery.Upon review, the United States Court of Appeals for the Ninth Circuit clarified that Arizona’s statute provides two avenues for amending the sex marker on a birth certificate: through a physician’s verification of a sex change operation or by obtaining a court order. The court found that the law does not classify based on transgender status, but rather on whether an individual has undergone surgery, and that all individuals—including transgender people who have not had surgery—can seek a court order for amendment. Applying rational basis review, the court concluded the statute is rationally related to a legitimate state interest in ensuring adequate evidentiary support for amendments. The court also held that the statute does not violate due process, as it does not burden fundamental rights in all its applications. The Ninth Circuit reversed the district court’s summary judgment for the plaintiffs, vacated the permanent injunction, and remanded for further proceedings. View "ROE V. PETERSEN" on Justia Law