Justia Constitutional Law Opinion Summaries

Jennifer Virden, a small business owner in Austin, Texas, ran for city council in 2020 and for mayor in 2022. The City of Austin has a regulation that prohibits candidates from fundraising outside a one-year period before the general election. Virden announced her candidacy for the 2022 election in March 2021, which was seven months before she could start fundraising under the ordinance. She filed a lawsuit challenging the one-year fundraising window as unconstitutional under the First Amendment.The United States District Court for the Western District of Texas initially denied Virden's request for a preliminary injunction, finding no irreparable harm. Virden's interlocutory appeal was dismissed as moot after the fundraising window opened. The district court later granted summary judgment in part, ruling that the one-year fundraising window was unconstitutional and awarding nominal damages to Virden and her donor, William Clark. The court found that the claims for declaratory and injunctive relief were moot since the 2022 election had ended and there were no concrete plans for future campaigns. The court also refused to consider evidence regarding Virden's desire to contribute to another candidate in the 2024 election, deeming the submission untimely.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that the one-year fundraising window was unconstitutional, agreeing that it violated the First Amendment. The court also upheld the award of nominal damages to Virden and Clark. Additionally, the court found that the district court did not abuse its discretion in refusing to consider the late evidence regarding the 2024 election. The Fifth Circuit concluded that the suit was timely, Virden had standing, and the city's arguments were without merit. The court affirmed the district court's decision in its entirety. View "Virden v. City of Austin" on Justia Law

George Pitsilides, a successful restaurateur and professional poker player, was convicted in 1998 in Pennsylvania for criminal conspiracy to commit pool selling and bookmaking, and two counts of pool selling and bookmaking. These offenses are classified as first-degree misdemeanors in Pennsylvania, punishable by up to five years’ imprisonment. Consequently, under 18 U.S.C. § 922(g)(1), Pitsilides is barred from possessing a firearm. Despite these convictions, Pitsilides continued to engage in illegal gambling activities, leading to further convictions in Virginia in 2011 for operating an illegal gambling enterprise.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the Government, applying the two-step framework from Binderup v. Attorney General. The court concluded that Pitsilides failed to show his convictions were not serious and rejected his argument that his offenses fell within the carveout for business-related offenses under 18 U.S.C. § 921(a)(20)(A).The United States Court of Appeals for the Third Circuit reviewed the case. The court noted that the legal landscape had changed significantly since the District Court's decision, particularly with the Supreme Court's rulings in New York State Rifle & Pistol Ass’n v. Bruen and United States v. Rahimi, and the Third Circuit's en banc decision in Range v. Attorney General. These cases emphasized the need for individualized assessments of whether a felon poses a danger to public safety when challenging firearm prohibitions under the Second Amendment.The Third Circuit concluded that the record was insufficient to determine whether § 922(g)(1) is unconstitutional as applied to Pitsilides. The court affirmed in part, vacated in part, and remanded the case to the District Court for further factual development to assess whether Pitsilides poses a special danger of misusing firearms. View "Pitsilides v. Barr" on Justia Law

Haley Olson was arrested in Idaho for marijuana possession and consented to a search of her phone by Idaho police, who created a copy of its contents. Glenn Palmer, then-Sheriff of Grant County, Oregon, learned of the arrest and, curious about Olson's relationship with Grant County Deputy Tyler Smith, asked County Attorney Jim Carpenter to request the phone extraction from the Idaho prosecutor. Carpenter obtained and reviewed the extraction, allegedly deleting it afterward. However, Olson later heard gossip about the contents of her phone, including nude photos, seemingly originating from the sheriff’s office. Olson sued Palmer, Carpenter, and Grant County, alleging Fourth Amendment violations.The United States District Court for the District of Oregon granted summary judgment for Palmer, finding no supervisory liability, and for Carpenter, granting him qualified immunity as his actions did not violate clearly established law. Olson appealed these decisions.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court agreed that Palmer was not liable due to lack of supervisory authority over Carpenter. The court also held that Carpenter was entitled to qualified immunity because Olson’s right to be free from Carpenter’s search was not clearly established at the time. However, the court concluded that Carpenter’s search did violate Olson’s Fourth Amendment rights, as it was conducted without a warrant, consent, or suspicion of criminal activity. The court emphasized the importance of developing constitutional precedent in this area, despite affirming the grant of qualified immunity to Carpenter. View "OLSON V. COUNTY OF GRANT" on Justia Law

Quincy Taylor was convicted by a jury of possession of a controlled substance with intent to distribute, possession of a firearm in furtherance of drug trafficking, and being a felon in possession of a firearm. The charges stemmed from an incident where Taylor was involved in a car accident, and a witness, William Howell, testified that Taylor had a bag containing drugs and a firearm. Howell's testimony was the only evidence linking Taylor to the contraband.The United States District Court for the Eastern District of Kentucky limited Taylor's ability to cross-examine Howell about his criminal history and potential bias. Specifically, the court allowed Taylor to ask if Howell had any felony convictions but prohibited questions about the nature of the conviction, Howell's pending felon-in-possession charge, and any benefits Howell might receive for his cooperation. Taylor argued that these limitations violated his Confrontation Clause rights under the Sixth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court's limitations on cross-examination violated Taylor's constitutional right to confront witnesses. The court determined that the jury did not have sufficient information to assess Howell's potential bias and motive for testifying. The court also found that the error was not harmless, as Howell's testimony was crucial to the prosecution's case, and there was no other evidence linking Taylor to the contraband.As a result, the Sixth Circuit reversed Taylor's convictions and remanded the case for a new trial, holding that the district court's limitations on cross-examination violated Taylor's Confrontation Clause rights and that the error was not harmless. View "United States v. Taylor" on Justia Law

In March 2020, Andrew Cooperrider, owner of Brewed, a coffee shop and bar in Lexington, Kentucky, criticized Governor Beshear’s COVID-19 policies on social media. In November 2020, the Kentucky Department of Alcoholic Beverage Control (DABC) suspended Brewed’s alcohol license, and officially revoked it in March 2022. Cooperrider filed a lawsuit against Governor Beshear, DABC officials, and other state officials, alleging First Amendment retaliation and due-process violations, claiming the license revocation was in retaliation for his critical speech.The United States District Court for the Eastern District of Kentucky dismissed the case, granting the defendants' motions to dismiss. The court found that most of Cooperrider’s claims were barred by absolute, qualified, and sovereign immunity. It also determined that Cooperrider’s remaining substantive-due-process claim did not meet the Rule 12(b)(6) pleading standard.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of most claims, agreeing that the defendants were protected by absolute, qualified, and sovereign immunity. However, the appellate court found that the district court improperly granted qualified immunity to Governor Beshear, Ray Perry, and Wesley Duke regarding Cooperrider’s First Amendment retaliation claim. The appellate court held that Cooperrider had plausibly alleged that the enforcement action against Brewed was motivated by his protected speech. Consequently, the court reversed the district court’s decision on this point and remanded the case for further proceedings on the First Amendment retaliation claim. View "Cooperrider v. Woods" on Justia Law

James D. Ford was convicted of the 1997 murders of Greg and Kimberly Malnory at a sod farm in South Florida. Ford, who worked with Greg, had planned to go fishing with the couple. Greg was shot in the head, beaten, and had his throat slit. Kimberly was raped, beaten, and shot. Their young daughter was found nearby, unharmed but exposed to the elements. Ford was convicted of two counts of first-degree murder, sexual battery with a firearm, and child abuse, and was sentenced to death.Ford's convictions and sentences were affirmed on direct appeal, and the U.S. Supreme Court denied certiorari in 2002. Ford has since filed multiple unsuccessful postconviction relief motions in state and federal courts. His third successive motion for postconviction relief, filed under Florida Rule of Criminal Procedure 3.851, was summarily denied by the circuit court. This motion raised claims that his death sentence was unconstitutional under Roper v. Simmons due to his mental and developmental age and that executing him would violate his rights under the Fifth, Sixth, Eighth, and Fourteenth Amendments in light of Erlinger v. United States.The Supreme Court of Florida reviewed the case and affirmed the circuit court's denial. The court held that Ford's claim regarding his mental and developmental age was untimely and without merit, as Roper does not extend to individuals over eighteen, regardless of mental age. The court also found that Erlinger, which involved the federal Armed Career Criminal Act, was not applicable to Ford's case. Additionally, the court rejected Ford's arguments related to Hurst v. Florida and Hurst v. State, noting that these decisions do not apply retroactively to Ford's case. The court concluded that Ford's claims were procedurally barred and meritless, and affirmed the denial of his third successive motion for postconviction relief. View "Ford v. State" on Justia Law

Joseph Rivera's driver's license was permanently revoked by New York authorities after he was convicted of three alcohol-related driving offenses between 2000 and 2010. Rivera moved to Alaska in 2011 but did not apply for an Alaska driver's license until 2021. His application was denied by the Alaska Department of Motor Vehicles (DMV) because his license was still revoked in New York. Rivera sought reinstatement of his driving privileges in New York, but his requests were denied. He then requested an administrative hearing with the Alaska DMV, which upheld the denial of his application.Rivera appealed to the Superior Court of the State of Alaska, Third Judicial District, arguing that the DMV misapplied Alaska's licensing statutes and that the statutes conflicted. The superior court affirmed the DMV's decision, rejecting Rivera's arguments.The Supreme Court of the State of Alaska reviewed the case and held that Alaska's driver’s license statutes do not conflict. The court found that the statutes operate in harmony, with the Compact providing a framework for considering out-of-state driving records and Alaska's statutes imposing additional requirements. Specifically, Alaska Statute 28.15.031(b)(1) prevents the DMV from issuing a license to anyone whose driving privileges are revoked in any jurisdiction, including out-of-state revocations. The court concluded that the DMV properly applied this statute in denying Rivera's application.The court also addressed Rivera's arguments regarding equal protection and manifest injustice, finding them unpersuasive. The court noted that Rivera had not exhausted all available appeals in New York and that the DMV's decision did not result in manifest injustice. Consequently, the Supreme Court of the State of Alaska affirmed the superior court's judgment and upheld the DMV's decision to deny Rivera's application for a driver's license. View "Rivera v. State" on Justia Law

George Peterson was investigated by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) for illegal firearm transactions at his business, PDW Solutions, LLC, which he operated from his home. The ATF conducted undercover operations where Peterson sold firearms without reporting the transactions as required. Based on this, a magistrate judge issued a warrant to search Peterson's home and business. During the search, agents found an unregistered firearm suppressor in Peterson's bedroom-closet safe. Peterson was indicted for possession of an unregistered suppressor.The United States District Court for the Eastern District of Louisiana denied Peterson's pretrial motions to dismiss the indictment on Second Amendment grounds and to suppress the evidence on Fourth Amendment grounds. Peterson argued that the National Firearms Act's (NFA) registration requirement for suppressors violated his Second Amendment rights and that the search warrant lacked probable cause. The district court rejected these arguments, and Peterson entered a conditional guilty plea, reserving the right to appeal the denial of his motions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that suppressors are not "Arms" protected by the Second Amendment, as they are accessories and not weapons themselves. Therefore, the NFA's registration requirement does not violate the Second Amendment. Additionally, the court found that the good-faith exception to the exclusionary rule applied, as the officers reasonably relied on the warrant issued by the magistrate judge. The court affirmed the district court's denial of Peterson's motions to dismiss and suppress. View "USA v. Peterson" on Justia Law

Tim Daniels, a commercial fisherman in Florida, challenged the constitutionality of regulations by Florida’s Fish and Wildlife Conservation Commission (FWC) that restrict where and how Florida-registered vessels can harvest Florida pompano in federal waters. Daniels argued that federal law preempts state regulations affecting fishing in federal waters and that Florida’s regulations violate the Equal Protection Clause by only restricting Florida-registered vessels.The United States District Court for the Southern District of Florida granted summary judgment for the FWC, concluding that Florida’s regulations do not violate the Privileges and Immunities Clause, the Supremacy Clause, the Commerce Clause, or the Equal Protection Clause. The court also determined that Daniels lacked standing to sue.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that Daniels has standing to sue because he faces a credible threat of prosecution under Florida’s regulations, which affects his commercial fishing activities. The court found that Daniels’s injury is directly traceable to Florida’s regulations and can be redressed by a favorable judicial decision.On the merits, the Eleventh Circuit held that the Magnuson-Stevens Fishery Conservation and Management Act does not preempt Florida’s regulations. The court reasoned that the Act allows states to regulate fishing vessels registered under their laws in federal waters when there is no federal fishery management plan or regulations in place. The court also held that Florida’s regulations do not violate the Equal Protection Clause because they are rationally related to the legitimate governmental purpose of conserving and managing pompano stock, and the regulations only apply to Florida-registered vessels, which are within the state’s jurisdiction.The Eleventh Circuit affirmed the District Court’s decision, upholding Florida’s pompano regulations. View "Daniels v. Executive Director of the Florida Fish and Wildlife Conservation Commission" on Justia Law

The defendant was convicted of unlawful possession of a controlled substance after a stipulated bench trial. The conviction stemmed from evidence found in a locked kitchen cabinet during a warrantless search by police officers who were investigating a gas leak in the defendant's home. The defendant filed a motion to suppress the evidence, arguing that the search was unreasonable and violated the Fourth Amendment. The trial court denied the motion, and the defendant was subsequently convicted.The Second District Appellate Court affirmed the conviction, holding that the police officers' actions were permissible under the community caretaking or emergency aid exceptions to the warrant requirement. The appellate court found that the use of a flashlight to look into the cabinet did not constitute a search under the Fourth Amendment. One justice dissented, arguing that the use of the flashlight to peer into a locked cabinet was a search in violation of the Fourth Amendment.The Supreme Court of Illinois reviewed the case and reversed the lower courts' judgments. The court held that the contraband found in the locked cabinet was not in plain view and that the police officers' actions constituted an unreasonable search. The court concluded that the use of a flashlight to look into the cabinet, which was secured with a chain and padlock, amounted to a search that was not justified by the emergency aid or community caretaking exceptions. As a result, the trial court erred in denying the defendant's motion to suppress the evidence. The Supreme Court reversed the defendant's conviction and vacated his sentence. View "People v. Hagestedt" on Justia Law