Justia Constitutional Law Opinion Summaries

Dario Giambro was convicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm. The conviction stemmed from evidence found by police officers who forcibly entered his home in Hebron, Maine, without a warrant. The officers entered the home based on information from Giambro's son, Antonio, who reported that his mother, Arline, had died and was not in the house. Giambro argued that the warrantless entry violated his Fourth Amendment rights and that the evidence should be suppressed. He also challenged the charge on Second Amendment grounds.The United States District Court for the District of Maine denied Giambro's motion to suppress, ruling that the entry fell within the emergency aid exception to the Fourth Amendment's warrant requirement. The court found that the officers had an objectively reasonable basis to believe that Arline might be in need of immediate aid, despite Antonio's report that she had died and was not in the house. The court also denied Giambro's motion to dismiss the charge on Second Amendment grounds.The United States Court of Appeals for the First Circuit reviewed the case and disagreed with the district court's application of the emergency aid exception. The appellate court held that the officers did not have an objectively reasonable basis to believe that Arline was alive and in need of immediate aid, given that Antonio had been in the house that morning and reported that she was not there. The court emphasized that the officers should have spoken to Antonio and Giambro, who were available for questioning, before forcibly entering the home. Consequently, the First Circuit reversed the district court's denial of the motion to suppress, vacated Giambro's conviction and sentence, and remanded the case for further proceedings. The court did not address the Second Amendment claim due to its ruling on the Fourth Amendment issue. View "United States v. Giambro" on Justia Law

Marcus Todd, a state employee in Minnesota, alleged that a union violated his First and Fourteenth Amendment rights by deducting union dues from his paycheck without his consent. Todd joined the American Federation of State, County, and Municipal Employees in 2014 and authorized dues deductions. In 2018, a new authorization card was allegedly signed electronically with Todd's name, which he claims was forged. After the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, Todd attempted to resign from the union and stop dues deductions, but the union continued until May 2021, citing an annual opt-out period.The United States District Court for the District of Minnesota dismissed Todd's federal claims, stating that he voluntarily agreed to the dues deductions before Janus and was contractually bound to the opt-out period. The court also found that the union did not act under color of state law regarding the alleged forgery and dismissed Todd's claims for prospective relief as moot. The court declined to exercise jurisdiction over Todd's state law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Todd's claims failed due to the lack of state action, as the union's actions were based on private agreements, not state statutes. The court referenced Hoekman v. Education Minnesota and Burns v. School Service Employees Union Local 284, which established that private agreements for dues deductions do not constitute state action. The court also found that the alleged forgery did not establish state action, as it was a private misuse of state law. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Todd v. AFSCME" on Justia Law

David Shanton, Sr. was involved in two armed bank robberies in Hagerstown, Maryland, shortly after completing a 20-year sentence for a previous bank robbery. During the first robbery, Shanton threatened to kill anyone who called the police and pointed a shotgun at a deputy sheriff while fleeing with nearly $34,000. He was apprehended during the second attempted robbery. Shanton was indicted and convicted on multiple counts, including armed bank robbery, discharging and brandishing a firearm during a crime of violence, and possessing a firearm as a felon.The United States District Court for the District of Maryland sentenced Shanton to 188 months for each armed bank robbery and firearm possession conviction, to be served concurrently, plus consecutive terms for the firearm offenses, totaling 608 months. Shanton's sentence was enhanced under the Armed Career Criminal Act (ACCA) due to his prior convictions, including Maryland robbery. Shanton did not initially object to the enhancement. On direct appeal, the Fourth Circuit affirmed his convictions and sentence.Shanton later filed a motion under 28 U.S.C. § 2255, challenging the constitutionality of his ACCA-enhanced sentences based on the Supreme Court's decision in Samuel Johnson v. United States, which invalidated the ACCA's residual clause. The district court allowed Shanton to supplement his motion, arguing that his Maryland robbery convictions no longer qualified as violent felonies under ACCA's elements clause. The district court rejected this argument, relying on Fourth Circuit precedent, and denied the motion but issued a certificate of appealability.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The court held that Maryland robbery qualifies as a violent felony under ACCA's elements clause, consistent with prior Fourth Circuit decisions and the Supreme Court's ruling in Stokeling v. United States. The court concluded that Maryland robbery involves the use of force against a person, meeting the ACCA's definition of a violent felony. View "United States v. Shanton" on Justia Law

During Winter Storm Uri in February 2021, Black Hills Colorado Electric LLC incurred extraordinary natural gas costs to ensure continuous electric service to its customers. Holcim U.S. Inc., a large retail electric customer, argued that the Colorado Public Utilities Commission (PUC) set an unjust and unreasonable charge for electricity over a five-day period, disproportionately allocating utility costs to Holcim. Holcim also claimed that the PUC's charge constituted a taking in violation of the Fifth Amendment.The District Court for the City and County of Denver upheld the PUC's decision, finding that the rate was just and reasonable and did not violate Holcim's constitutional rights. The court noted that the PUC's rate structure was based on total customer usage forecasts and was applied uniformly to all customers.The Supreme Court of Colorado reviewed the case and affirmed the district court's judgment. The court held that the PUC's rate was just and reasonable, as it accurately reflected the cost of service, distributed costs among customers fairly, and maintained the utility's financial integrity. The court also found that Holcim's actual electricity usage during the storm did not impact the costs incurred by Black Hills, which were based on forecasted needs.Additionally, the court rejected Holcim's constitutional claims. It concluded that Holcim did not adequately develop its takings claim and that the PUC's decision did not violate Holcim's due process rights, as the PUC provided a fair hearing, considered competent evidence, and made its determination based on evidence rather than arbitrarily. View "Holcim U.S. Inc. v. Colo. Pub. Utils. Comm'n" on Justia Law

Taegan Ray Contreras was charged with possessing a firearm as a felon, violating 18 U.S.C. § 922(g)(1). He moved to dismiss the charge, arguing that the statute violated the Second Amendment both facially and as applied to him. The district court denied the motion, and Contreras was convicted and sentenced. He appealed, raising the same constitutional challenges.The District Court for the Western District of Texas initially sentenced Contreras to 24 months’ imprisonment and three years of supervised release for being a user in possession of a firearm. While on supervised release, detectives found Contreras in possession of a firearm and marijuana. He was arrested and indicted for possession of a firearm by a convicted felon. Contreras moved to dismiss the indictment, but the district court denied the motion, finding § 922(g)(1) constitutional. Contreras entered a conditional guilty plea, reserving his right to appeal the denial of his motion to dismiss. He was sentenced to 21 months’ imprisonment, three years of supervised release, and forfeiture of the firearm.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reiterated that § 922(g)(1) is facially constitutional and concluded that it is constitutional as applied to Contreras. The court found that the Second Amendment extends to convicted felons but upheld the statute, noting historical traditions of disarming felons and those under the influence of substances. The court held that § 922(g)(1) is consistent with historical regulations and principles, affirming Contreras' conviction. View "United States v. Contreras" on Justia Law

Jose Gomez Quiroz was charged under 18 U.S.C. § 922(a)(6) for making a false statement while purchasing a firearm, as he allegedly denied being under indictment for a felony. He was also charged under 18 U.S.C. § 922(n) for receiving a firearm while under indictment. A jury found him guilty on both counts. However, on the same day, the Supreme Court decided New York State Rifle & Pistol Association, Inc. v. Bruen. Quiroz then moved to dismiss the indictment, and the district court granted the motion, ruling that § 922(n) is facially unconstitutional under the Second Amendment. Consequently, the court also dismissed the § 922(a)(6) charge, stating that the false statement was immaterial.The United States District Court for the Western District of Texas initially denied Quiroz's motion to dismiss the indictment. After the jury's guilty verdict, the district court reconsidered its decision in light of the Bruen ruling and dismissed the indictment, declaring § 922(n) unconstitutional and the false statement under § 922(a)(6) immaterial.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court concluded that § 922(n) is consistent with the nation's historical tradition of firearms regulation. The court noted that historically, individuals indicted for serious crimes were often detained pretrial, which effectively disarmed them. The court held that § 922(n) imposes a comparable burden on the right to armed self-defense as historical pretrial detention practices. Consequently, the court reversed the district court's judgment and remanded the case, reinstating the charges under both § 922(n) and § 922(a)(6). View "United States v. Quiroz" on Justia Law

Paul Curry, Jr. pleaded guilty to possession of a firearm by a felon under 18 U.S.C. § 922(g)(1). The presentence report (PSR) classified him as an armed career criminal under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), due to four prior Texas burglary convictions. Consequently, the district court sentenced him to 262 months of imprisonment, within the guidelines range of 210 to 262 months. Curry did not object to the PSR at the district court level.Curry appealed to the United States Court of Appeals for the Fifth Circuit, arguing for the first time that § 922(g)(1) is unconstitutional and that the district court erred in sentencing him as an armed career criminal. He contended that § 922(g)(1) exceeds Congress's power under the Commerce Clause and violates the Second Amendment. Additionally, he argued that the district court should have submitted the question of whether his prior crimes occurred on separate occasions to a jury, and that it erred by relying solely on the PSR for the ACCA enhancement.The Fifth Circuit reviewed Curry's constitutional challenges for plain error, as they were not raised in the district court. The court found that Curry's arguments regarding the constitutionality of § 922(g)(1) were foreclosed by precedent. The court also held that Curry's facial challenge to § 922(g)(1) under the Second Amendment failed, as the statute was not unconstitutional in all its applications.Regarding the ACCA enhancement, the Fifth Circuit determined that the district court clearly erred by not submitting the separate-occasions inquiry to a jury, as required by the Supreme Court's decision in Erlinger v. United States. However, the court concluded that Curry failed to demonstrate that this error affected his substantial rights, given the substantial gaps in time and different victims involved in his prior convictions. Consequently, the Fifth Circuit affirmed the district court's judgment. View "United States v. Curry" on Justia Law

Justin and Jared Brackett own and operate two restaurants in Harwich, Massachusetts: Ember Pizza, Inc. and The Port Restaurant and Bar, Inc. Both establishments held liquor and entertainment licenses issued by the town. Allegedly, they violated Harwich's noise ordinance and Massachusetts COVID-19 restrictions, leading to suspensions and restrictions on their permits. In response, they sued Harwich, several town officials, and other individuals in federal district court, asserting various federal and state claims.The United States District Court for the District of Massachusetts largely granted the defendants' dispositive motions, rejecting all of Ember and The Port's claims. The court also denied their request for leave to amend their complaint, finding that an amendment would be futile. Ember and The Port then appealed the district court's decisions.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that Ember and The Port failed to state a plausible claim for relief under federal law, including their First Amendment, Fourteenth Amendment, and procedural due process claims. The court also found that the Massachusetts Civil Rights Act claims and common law claims, including civil conspiracy and defamation, were inadequately pleaded. The court concluded that the district court did not abuse its discretion in denying the request for leave to amend the complaint, as the proposed amendments would not have cured the deficiencies in the original complaint. View "3137, LLC v. Town of Harwich" on Justia Law

Johnnie Franklin Wills, a state prisoner, filed a habeas petition challenging his life sentence under West Virginia’s recidivist statute. He argued that the judicially crafted test for determining whether a recidivist life sentence is proportional to the crime is unconstitutionally vague. Wills was convicted of grand larceny and conspiracy to commit grand larceny in 2016, and due to his prior eight felony convictions, he was sentenced to life imprisonment with parole eligibility after fifteen years under the recidivist statute.The West Virginia courts denied Wills relief, stating that the void-for-vagueness doctrine does not apply to their proportionality test. The Supreme Court of Appeals of West Virginia affirmed this decision, distinguishing Wills’s case from the U.S. Supreme Court’s decisions in Johnson v. United States and Sessions v. Dimaya, which invalidated certain statutory provisions as unconstitutionally vague. The state court maintained that the proportionality test was clear and did not fall under the same scrutiny as the statutes in Johnson and Dimaya.Wills then filed a federal habeas petition under 28 U.S.C. § 2254, which the United States District Court for the Northern District of West Virginia also denied. The district court found that the state court’s decision was not contrary to or an unreasonable application of clearly established federal law. The court noted that the proportionality test serves as a judicial limitation on the recidivist statute, unlike the statutory mandates in Johnson and Dimaya.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that the state court’s ruling was not an unreasonable application of clearly established federal law, as the U.S. Supreme Court has not extended the void-for-vagueness doctrine to judicially crafted proportionality tests. Therefore, Wills’s habeas petition was denied. View "Wills v. Pszczolkowski" on Justia Law

Charles Pittman pleaded guilty to violating a federal law that criminalizes burning or attempting to burn buildings owned by institutions that receive federal funding. He was charged with aiding and abetting others in maliciously damaging and destroying the Market House, a building owned by the City of Fayetteville, which receives federal financial assistance. During his plea hearing, Pittman confirmed his understanding of the charges and admitted to committing acts constituting the elements of the crime.The United States District Court for the Eastern District of North Carolina accepted Pittman's guilty plea and later sentenced him to 60 months of imprisonment. Before sentencing, Pittman moved to dismiss Count 1, arguing that the statute required a nexus between the federal financial assistance and the damaged property, and that the criminal information failed to allege such a nexus. He also argued that the City of Fayetteville is not an "institution or organization" under the statute. The district court denied the motion to dismiss.The United States Court of Appeals for the Fourth Circuit reviewed the case. Pittman argued that his conduct did not violate the statute and that the statute was unconstitutional as applied to him. The court held that Pittman waived his statutory construction arguments by pleading guilty, as a guilty plea admits that the conduct violated the statute. The court also found that Pittman's as-applied constitutional challenge was forfeited because he did not timely raise it before the district court, and he failed to show plain error.The Fourth Circuit affirmed the district court's judgment, holding that Pittman's guilty plea waived his statutory arguments and that his constitutional challenge was both forfeited and failed to meet the plain-error standard. View "United States v. Pittman" on Justia Law