Justia Constitutional Law Opinion Summaries

The defendant pled guilty to a single count of illegal reentry after removal from the United States. His presentence report detailed a criminal history that included prior convictions for driving under the influence, obstruction of justice, unlawful possession or consumption of alcohol by a minor, domestic battery, drug trafficking, and a previous illegal reentry. After being deported for his earlier illegal reentry, the defendant returned to the United States, purportedly to assist his wife, who was recovering from a significant injury and mental health issues. About ten months after his return, he was arrested for assaulting his wife, but the charges were later dismissed. The presentence report indicated the incident involved the defendant throwing water bottles at his wife, causing minor injuries, but made no mention of direct physical contact or biting.The United States District Court for the Western District of Texas conducted a brief sentencing hearing, during which it adopted the presentence report but made several factual errors. The court incorrectly referenced a 2020 illegal reentry conviction that did not exist and mistakenly asserted that the defendant had bitten his wife during the alleged assault. The district court treated these purported facts as aggravating factors and sentenced the defendant to 46 months, at the top of the Guidelines range, without stating whether the same sentence would have been imposed absent these errors. No contemporaneous objections were raised by the parties.The United States Court of Appeals for the Fifth Circuit reviewed the case under the plain error standard. The court found that the district court relied on clearly erroneous facts, that the errors were clear under established law, and that they affected the defendant’s substantial rights by likely increasing his sentence. The Fifth Circuit vacated the sentence and remanded for resentencing, holding that sentencing based on unfounded facts violates due process and undermines the fairness and integrity of judicial proceedings. View "USA v. Palencia-Berrum" on Justia Law

A group of associations representing infusion centers, cancer patients, and pharmaceutical manufacturers challenged the constitutionality of a program created by the Inflation Reduction Act of 2022, which directs the Secretary of Health and Human Services (HHS), through the Centers for Medicare and Medicaid Services (CMS), to negotiate prices for high-expenditure prescription drugs under Medicare Parts B and D. The program allows HHS to select drugs based on certain criteria, negotiate a “maximum fair price” with manufacturers, and impose an excise tax on manufacturers who refuse to negotiate. The tax is calculated as a high percentage of sales reimbursed by Medicare. Manufacturers may avoid the program by withdrawing from Medicare and Medicaid participation. The statutory scheme also limits administrative and judicial review of key program decisions and allows HHS to implement early cycles of the program through guidance rather than notice-and-comment rulemaking.The United States District Court for the Western District of Texas initially dismissed the case for lack of subject-matter jurisdiction and improper venue. On appeal, the United States Court of Appeals for the Fifth Circuit reversed and remanded, finding that at least one plaintiff had standing and venue was proper. On remand, the district court granted summary judgment for the government, holding that the program did not violate the nondelegation doctrine, that the Anti-Injunction Act barred the plaintiffs’ Eighth Amendment claim, and that the plaintiffs lacked a protected property interest to support their due process claim.Upon further appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The court held that the statute provided an “intelligible principle” sufficient to withstand a nondelegation challenge, that the Anti-Injunction Act did not bar the Eighth Amendment claim but the excise tax did not constitute a punitive fine, and that neither manufacturers, providers, nor patients possessed a protected property or liberty interest implicated by the program. The government’s summary judgment was affirmed in full. View "Natl Infusion Center v. Kennedy" on Justia Law

Several parents and a grandparent of two female high school athletes challenged actions taken by officials of a New Hampshire public school district. The dispute arose after the parents wore pink "XX" wristbands during a girls' soccer game as a passive protest against the participation of a transgender athlete, in light of recent litigation about transgender students’ eligibility for girls’ sports. School administrators, concerned about possible harassment and disruption, instructed the protestors to remove the wristbands and later issued sanctions, including no-trespass orders preventing them from attending future school events.The United States District Court for the District of New Hampshire reviewed the plaintiffs’ request for a preliminary injunction. It analyzed the school’s actions under First Amendment principles applicable to limited public fora and determined that the administrators’ interpretation and enforcement of school policy did not constitute impermissible viewpoint discrimination. The district court denied the request for injunctive relief, concluding that the school’s interests justified its response to the protest.The United States Court of Appeals for the First Circuit examined whether the school district’s actions amounted to viewpoint discrimination against the plaintiffs’ passive speech. The court found that the protest did not materially disrupt the event or amount to harassment, and that the sanctions appeared motivated by disagreement with the protest’s message. The First Circuit held that the plaintiffs demonstrated a likelihood of success on their viewpoint discrimination claim, specifically regarding the sanctions imposed at the soccer game’s sidelines and adjacent parking lot. The court remanded the case to the district court for further proceedings to determine whether any interim relief, such as a declaratory judgment, is warranted. No costs were awarded. View "Fellers v. Kelley" on Justia Law

Dennis O’Connor had two non-interest-bearing financial accounts with private companies. After O’Connor lost contact with these companies, they transferred his accounts to the State of Michigan under the state’s Uniform Unclaimed Property Act, which governs the handling of unclaimed property. Michigan took custody of O’Connor’s accounts and deposited the funds into its general fund, where the money could generate interest for the state. When O’Connor learned of this, he contended that the state’s failure to pay him the interest earned while holding his money violated his constitutional rights.Previously, the United States District Court for the Eastern District of Michigan dismissed all of O’Connor’s claims, finding that the state took ownership of his accounts and thus owed him no interest. On an earlier appeal, the United States Court of Appeals for the Sixth Circuit affirmed the dismissal of his takings claims but vacated the dismissal of his due process claims and remanded for further proceedings. On remand, the district court again dismissed O’Connor’s due process claims, reasoning that Michigan’s ownership of the accounts meant O’Connor had no right to the interest and that the procedures provided were constitutionally sufficient.The United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that under Michigan law, the state only assumes custody—not ownership—of unclaimed property, and the original owner retains title to both the principal and any interest generated. The court found that the district court erred by following contrary state appellate precedent and by concluding that O’Connor had no property interest in the funds or the interest. The court vacated the district court’s judgment dismissing the due process claims and remanded for further proceedings, directing the lower court to analyze the due process claim based on the correct understanding that O’Connor retained ownership rights. View "O'Connor v. Eubanks" on Justia Law

The defendant was convicted of murder following a retrial in 1981 and sentenced to an indeterminate term of 25 years to life, with a mandatory minimum of 25 years. The underlying facts involved the killing of a friend’s mother during a burglary and a subsequent fatal car crash. The defendant’s conviction was affirmed on direct appeal and collateral review. While incarcerated, the defendant applied for parole in 2013 and 2019, and for a commutation of his sentence in 2021; all applications were denied. He then filed a motion for sentence modification, citing his intellectual disability, youth at the time of the offense, remorse, age, physical incapacity, and low risk of recidivism as grounds for good cause. The trial court denied the motion, finding the defendant had not established good cause.On appeal, the Connecticut Appellate Court affirmed the trial court’s decision, holding that it was proper to consider the Board of Pardons and Paroles’ prior denials of parole and commutation as part of the sentence modification inquiry. The Appellate Court also noted that the trial court had considered other relevant factors, such as the seriousness of the offense, the impact on the victims, and the defendant’s disciplinary record while incarcerated.The Supreme Court of Connecticut reviewed the case on certification. It held that a trial court may consider prior decisions of the Board of Pardons and Paroles in ruling on a motion for sentence modification, as such information falls within the broad scope of relevant sentencing information. The Court found no abuse of discretion or due process violation, as the trial court’s reliance on the board’s denials was not impermissibly speculative and was only one factor among several considered. The judgment of the Appellate Court was affirmed. View "State v. Toste" on Justia Law

A city’s Chief of Police was recruited for his reformist reputation and soon after his arrival, he observed and reported that several City Commissioners were improperly interfering in police investigations and using police resources to pursue personal vendettas. The Chief communicated his concerns to the Mayor and City Manager, and, believing himself unable to investigate the Commissioners due to a prior City resolution, he sent a whistleblowing memorandum detailing abuses of power to the Mayor, City Manager, the State Attorney’s Office, and the FBI. The memo was subsequently leaked to the media. Following this, the Chief faced public criticism from the Commissioners, had his job responsibilities undermined, was suspended with pay by the City Manager pending a termination hearing, and was ultimately terminated by the City Commission.The Chief filed suit in the United States District Court for the Southern District of Florida against three Commissioners and the City Manager, alleging retaliation for protected First Amendment activity under 42 U.S.C. § 1983. The individual defendants moved to dismiss, asserting legislative and qualified immunity. The district court denied their motions, finding that neither defense shielded the Commissioners or the City Manager at that stage.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of immunity de novo. The Eleventh Circuit held that the Commissioners were not entitled to legislative immunity because terminating an employee is administrative, not legislative, action. The court further held that the Commissioners were not entitled to qualified immunity at the pleading stage because, accepting the complaint’s allegations as true, the Chief’s whistleblower memo was constitutionally protected speech, and binding precedent clearly established that retaliating against such speech is unlawful. However, the court held that the City Manager was entitled to qualified immunity, as it was not clearly established that suspending the Chief with pay, pending further proceedings, constituted an adverse employment action. The panel affirmed the denial of immunity for the Commissioners, reversed as to the City Manager, and remanded for further proceedings. View "Acevedo v. de la Portilla" on Justia Law

Officers responding to a reported burglary encountered Maurice Mitchell near a storage facility, leading to his flight, capture, and discovery of a loaded revolver in a bag on his bicycle. Mitchell has a history of felony convictions, including drug possession and attempting to disarm a peace officer, the latter involving an attempt to grab pepper spray from an officer during an arrest. Based on the January 2023 incident, Mitchell was indicted for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1).The United States District Court for the Western District of Louisiana denied Mitchell’s pretrial motions to dismiss the indictment, which asserted Second Amendment protections against prosecution. The court focused on Mitchell’s drug convictions as predicates, not addressing the attempted disarmament conviction. At trial, the court issued a flight instruction over Mitchell’s objection, directing the jury to consider his flight as evidence of consciousness of guilt. The jury ultimately returned a guilty verdict, and Mitchell was sentenced to prison and supervised release. He timely appealed.The United States Court of Appeals for the Fifth Circuit reviewed Mitchell’s Second Amendment challenge de novo. The court held that Mitchell’s conviction for attempting to disarm a police officer is analogous to robbery, historically a crime for which individuals could be disarmed under firearm regulations. Thus, the application of § 922(g)(1) to Mitchell was constitutional. The court also found that the district court did not abuse its discretion in issuing the flight instruction, and the evidence was sufficient to support Mitchell’s conviction under the stringent “manifest miscarriage of justice” standard. Consequently, the Fifth Circuit affirmed the judgment of the district court. View "USA v. Mitchell" on Justia Law

An inmate at Airway Heights Corrections Center participated in a prison writing program sponsored by Eastern Washington University, which encouraged submissions to a university literary journal. The inmate wrote a short story containing a brief reference to sexual intimacy and submitted it for consideration. The prison’s Community Partnership Program Coordinator intercepted the submission, deeming it “inappropriate for publication” due to its “sexual content,” and returned it to the inmate. The inmate then mailed the story directly to the university and complained to the prison superintendent, who endorsed the decision to block the submission and warned that further unauthorized correspondence would result in removal from the program.The United States District Court for the Eastern District of Washington granted summary judgment for the prison officials, concluding that they had not violated the inmate’s First Amendment rights and, even if they had, their actions were protected by qualified immunity. The court applied the deferential standard from Turner v. Safley, which governs regulations of prisoner conduct, and found no retaliation. The court also denied the inmate’s motions for additional discovery and to vacate the judgment.Reviewing the case, the United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment, including its qualified immunity determination, and remanded for further proceedings. The Ninth Circuit held that the district court erred by applying the Turner standard instead of the standard from Procunier v. Martinez, which governs outgoing inmate correspondence. The panel determined that genuine disputes of fact existed and, if proven, could show that the prison officials’ refusal to transmit the inmate’s story constituted prohibited censorship under the First Amendment. The court also held that the district court erred in its analysis of the retaliation claim and instructed that it should be evaluated under Rhodes v. Robinson, which sets forth the elements for a First Amendment retaliation claim in the prison context. View "GRENNING V. KEY" on Justia Law

A member of Congress from New Jersey was charged with three counts of violating federal law after allegedly physically interfering with federal officials during an oversight visit to a federal immigration detention facility in Newark. During the visit, the Congresswoman and other Representatives encountered Newark’s Mayor, who was ordered to leave the premises by federal agents. When federal agents attempted to arrest the Mayor, the Congresswoman allegedly placed herself between the Mayor and an agent, forcibly made contact with the agent, and later pushed past another federal officer to reenter the facility. The charges stem from these physical altercations and the Congresswoman’s efforts to impede the Mayor’s arrest.The United States District Court for the District of New Jersey denied the Congresswoman’s motions to dismiss the indictment. The court found that her conduct was not protected by legislative immunity under the Speech or Debate Clause, concluding it was non-legislative in nature. The court also rejected her arguments based on the separation of powers doctrine, distinguishing between Presidential and legislative immunities. Additionally, the court ruled against her selective and vindictive prosecution claims, finding she failed to demonstrate discriminatory effect or personal animus by the prosecution.The United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit affirmed the denial of legislative immunity for Counts One and Two, holding that prosecution of those charges would not require the Congresswoman to answer for any legislative acts. The court vacated and remanded with respect to Count Three for further consideration as to whether legislative immunity might apply. The court dismissed the remainder of her appeal, including claims of selective and vindictive prosecution, for lack of jurisdiction. View "USA v. McIver" on Justia Law

Raymond Luna was indicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm. The only felony conviction supporting this indictment was Luna’s prior conviction for possession of a controlled substance. The district court found that applying § 922(g)(1) to Luna violated the Second Amendment as applied to him and dismissed the indictment. After the dismissal, the Government moved for reconsideration, providing new evidence from Luna’s prior conviction that suggested he was involved in drug trafficking, rather than mere possession. The district court denied the motion for reconsideration, reasoning that the Government could have, but did not, present this evidence earlier.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of the motion for reconsideration for abuse of discretion, as the district court declined to consider the new evidence presented by the Government after the original dismissal. The Fifth Circuit observed that the Government did not argue in its opening appellate brief that the district court abused its discretion in refusing to consider the late-submitted evidence, thereby forfeiting that argument. The appellate court further declined to revisit the district court’s ruling based on the late-submitted evidence.The Fifth Circuit held that, with only the fact of Luna’s conviction for simple possession before it, binding precedent established that such a conviction cannot support a § 922(g)(1) prosecution post-Hembree. The court also rejected the Government’s alternative arguments, including the assertion that historical regulations on illicit marketplaces justified disarmament, and found that Luna’s indictment status for a separate firearm offense was irrelevant under circuit precedent. As a result, the Fifth Circuit affirmed the district court’s dismissal of the indictment. View "USA v. Luna" on Justia Law