Justia Constitutional Law Opinion Summaries

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

The defendant was involved in a domestic violence incident with a former romantic partner with whom he continued to live as a roommate. On September 18, 2022, after drinking heavily, the defendant assaulted the victim by choking, hitting, and threatening her. The victim, fearing further violence, submitted to sexual acts. After the defendant fell asleep, the victim left, sought medical attention, and reported the incident to police. The defendant was arrested and, while detained pending trial, communicated with the victim numerous times, encouraging her to lie and withhold information from authorities, and discouraging her from testifying.The Hillsborough-northern judicial district Superior Court conducted a jury trial. The jury acquitted the defendant of some charges but convicted him of aggravated felonious sexual assault-domestic violence, stalking-domestic violence, indirect criminal contempt, witness tampering, criminal restraint, second degree assault-domestic violence, and simple assault-domestic violence. The defendant appealed these convictions.The Supreme Court of New Hampshire reviewed the case. It affirmed the aggravated felonious sexual assault convictions, holding that there was sufficient evidence to find the victim was confined and did not freely consent to the sexual acts due to fear provoked by prior assaults. The court reversed the stalking and indirect criminal contempt convictions, concluding that the bail statute in effect at the time did not authorize no-contact orders for detained defendants, rendering the evidence insufficient for those charges. The court found no double jeopardy violation regarding multiple witness tampering convictions, determining that each attempt to influence the victim constituted a separate offense. Other double jeopardy claims were rejected due to insufficient demonstration of plain error. The Supreme Court of New Hampshire affirmed the remaining convictions and reversed the stalking and contempt convictions. View "State v. Sales" on Justia Law

Several plaintiffs, including the founder of a religious group called Singularism, used psilocybin as part of their religious ceremonies in Utah, where the drug is classified as a controlled substance. Authorities seized a large quantity of psilocybin from them and notified Singularism’s landlord that the drug use constituted a nuisance. Shortly after, the plaintiffs initiated a state lawsuit, which was removed to the United States District Court for the District of Utah. The federal court issued a temporary restraining order requiring the return of seized items and, after state authorities filed criminal charges, enjoined state prosecution against the religious leader to prevent a potential First Amendment violation.On appeal, the state authorities argued that the federal district court should have abstained from interfering with ongoing state criminal proceedings under the Younger abstention doctrine, and that prosecution did not violate the First Amendment. The United States Court of Appeals for the Tenth Circuit reviewed the district court’s refusal to abstain de novo and found the requirements for abstention were satisfied. The court concluded that the state authorities had not waived the abstention argument through their litigation conduct. The plaintiffs failed to show that the prosecution was brought in bad faith, was harassing, or created a threat of irreparable injury, as required for exceptions to abstention.On the merits, the Tenth Circuit held the district court erred in finding a likely First Amendment violation. The court found Utah law’s regulatory scheme for secular, supervised medical use of psilocybin was not comparable to the unsupervised religious use, and thus did not treat secular activity more favorably than religious activity. The court vacated the injunction and the denial of the motion to dismiss as to preferential treatment for secular use, remanding the issue of individualized exemptions for further district court proceedings, and dismissed the appeal regarding the Fourth Amendment claim for lack of jurisdiction. View "Jensen v. Utah County" on Justia Law

A non-verbal adult male with Down syndrome and autism, residing in Philadelphia with his mother and sister, receives care funded under Pennsylvania’s Consolidated Waiver program for home and community-based services. After the Department of Human Services imposed a “40/60 Rule” limiting compensation for care provided by relatives to 40 hours per week for one caretaker or 60 hours for multiple caretakers, his mother sought a permanent exception, citing religious grounds. She argued that Islamic law prohibits unrelated males from providing personal care and restricts her own interactions with unrelated male aides. Without an exception, she and her daughter would continue to provide care beyond the capped hours without compensation.The Department initially denied the exception, and an Administrative Law Judge dismissed the appeal for lack of jurisdiction. After a remand and settlement for reassessment, the Department again denied the request. The Bureau of Hearings and Appeals upheld the denial, and the mother appealed to the Commonwealth Court. During the COVID-19 pandemic, temporary exceptions permitted full compensation, but after resumption, the request for a permanent religious exemption was again denied. The Commonwealth Court affirmed, finding no substantial burden on religious exercise under the Free Exercise Clause or Pennsylvania’s Religious Freedom Protection Act (RFPA), and concluded that the mother failed to meet her burden of proof.The Supreme Court of Pennsylvania reviewed whether a Free Exercise Clause claim requires evidence of a “substantial burden” on religious exercise. The Court held that only a “burden” is required, not a substantial burden, and that the Commonwealth Court erred by conflating RFPA’s statutory standard with the constitutional standard. The Court reversed the Commonwealth Court’s order and remanded for further proceedings consistent with this holding. View "Alsyrawan v. DHS" on Justia Law

A man convicted of murder in Texas and sentenced to death sought to halt his execution, scheduled for October 7, 2026. He argued that newly developed clinical standards for diagnosing intellectual disability, which became available after his first federal habeas petition, would now classify him as intellectually disabled and therefore constitutionally ineligible for execution. He maintained that these new clinical guidelines constituted either a new rule of constitutional law or a new factual predicate, justifying a second federal habeas petition under 28 U.S.C. § 2254. As an alternative, he requested a stay of execution pending a potential relevant decision by the United States Supreme Court.After his 2001 conviction, the Texas Court of Criminal Appeals rejected his Eighth Amendment claim that his mental illness barred execution. His first state and federal habeas petitions were denied, with the federal courts determining in 2017 that he was not intellectually disabled. He later abandoned his initial Atkins v. Virginia claim after the Supreme Court faulted Texas’s standards for such claims in Moore v. Texas. In 2019, the United States District Court for the Eastern District of Texas denied his remaining federal habeas claims, and the United States Court of Appeals for the Fifth Circuit denied a Certificate of Appealability in 2020.Reviewing the case, the United States Court of Appeals for the Fifth Circuit held that the petitioner’s second federal habeas application was barred by the one-year statute of limitations and that he was not entitled to equitable tolling. The court further found that his renewed claim of intellectual disability had already been presented in his prior habeas petition, barring reconsideration under § 2244(b)(1). The court also denied his request for a stay of execution, finding no likelihood of success on the merits and no justification for equitable relief. Both motions were denied. View "In re Howard" on Justia Law