Justia Constitutional Law Opinion Summaries

A 59-year-old Navy employee began communicating with a 15-year-old boy, M.V., on an online dating site where M.V. falsely listed his age as 18, the minimum allowed by the site. Over several months in 2023, the two exchanged messages, met in person multiple times, and, according to M.V., engaged in sexual acts. The minor’s parents eventually discovered the relationship, notified law enforcement, and participated in a sting operation that resulted in the adult’s arrest. Police recovered evidence from the defendant’s belongings, including items suggesting sexual intent.A grand jury in the United States District Court for the Western District of Michigan indicted the defendant on one count of coercion and enticement of a minor under 18 U.S.C. § 2422(b), and two counts of interstate travel with intent to engage in illicit sexual conduct under 18 U.S.C. § 2423(b). Before trial, the district court excluded sexually explicit portions of the minor’s dating profile under Federal Rule of Evidence 412 and denied a proposed affirmative defense related to reasonable belief of the victim’s age for Counts 2 and 3. The jury convicted the defendant on all counts, and he was sentenced to 156 months in prison.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the conviction on Count 1, holding that the district court’s jury instructions accurately reflected the law and that sufficient evidence supported the conviction. The court found no abuse of discretion in excluding evidence under Rule 412. However, regarding Counts 2 and 3, the court held that the government must prove the defendant intended to engage in a sexual act with a person under 16, not merely under 18, when § 2243(a) is the predicate offense. The convictions on Counts 2 and 3 were vacated and remanded for a new trial with proper jury instructions. View "United States v. Stafford" on Justia Law

The case involves a challenge to Proposition M, a San Francisco measure approved by voters in 2022 that imposed an annual “Empty Homes Tax” on owners of certain residential units kept vacant for more than 182 days in buildings with more than two units. The stated aim was to discourage prolonged vacancies and increase available housing. Plaintiffs included individuals and associations representing property owners, who argued that Proposition M violated statutory and constitutional protections, including property rights and familial relations, and was preempted by the Ellis Act, which protects property owners’ right to withdraw accommodations from the rental market.The San Francisco City & County Superior Court reviewed cross-motions for summary judgment. Plaintiffs submitted declarations detailing how Proposition M would force them to either rent out units against their wishes or pay substantial taxes, potentially resulting in financial hardship or effective eviction. The City argued plaintiffs lacked standing and that their legal claims failed as a matter of law. After briefing and a hearing, the Superior Court granted summary judgment for plaintiffs, holding that Proposition M violated the Takings Clause, was preempted by the Ellis Act, burdened fundamental liberty interests in familial relations, violated equal protection, and infringed upon the constitutional right to privacy. The court entered judgment prohibiting the City from administering or enforcing Proposition M.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed the City’s appeal. The appellate court analyzed the measure’s conflict with the Ellis Act and concluded that Proposition M imposed a “prohibitive price” on owners’ right not to offer property for rent, directly contravening the Act’s protections. The court found that the Ellis Act preempts Proposition M and affirmed the trial court’s judgment, without reaching additional constitutional claims. The judgment prohibiting enforcement of Proposition M was thus upheld. View "Debbane v. City and County of San Francisco" on Justia Law

A parole commission issued an arrest warrant for an individual who had absconded. The warrant authorized various law enforcement officers to detain the individual. A Nampa City police officer located the individual in Caldwell, Idaho, and arrested him, despite being outside his jurisdiction and without satisfying any of the statutory exceptions for extraterritorial arrests. After the arrest, officers searched the individual’s vehicle and discovered narcotics and a stolen firearm, leading to charges including unlawful possession of a firearm and possession of drug paraphernalia.The matter was reviewed by the District Court of the Third Judicial District, Canyon County. The defendant moved to suppress evidence, arguing that his arrest was unconstitutional under both federal and Idaho constitutional provisions due to the officer’s violation of Idaho Code section 67-2337(2). The district court denied the motion, concluding that the officer’s violation of the statute did not amount to a constitutional violation. The defendant entered a conditional guilty plea, reserving his right to appeal. The Idaho Court of Appeals affirmed the district court’s decision.The Supreme Court of the State of Idaho granted review. The Court applied a bifurcated standard of review, examining factual findings for clear error and freely reviewing constitutional questions. The Court held that a violation of Idaho Code section 67-2337(2) by a peace officer does not constitute a constitutional violation requiring suppression of evidence, absent a showing that the Idaho Constitution, state precedent, or unique state interests demand a different analysis from federal law. The Court affirmed the district court’s denial of the suppression motion and the judgment of conviction. View "State v. Satterfield" on Justia Law

An individual Nebraska resident, voter, and taxpayer sought declaratory and injunctive relief challenging the constitutionality of two medical cannabis laws enacted by voter-approved initiatives in the November 2024 general election. He named as defendants the Governor, other state officials, members of the Nebraska Medical Cannabis Commission, and the sponsors of the initiatives. The plaintiff alleged the laws violated the federal Supremacy Clause, improperly delegated regulatory authority in violation of Nebraska’s separation of powers, and were otherwise unconstitutional. He further claimed public officials and agencies would expend state funds and resources to implement these laws, and that this expenditure was unlawful.Previously, before the laws passed, the same individual brought a preelection challenge to the legal sufficiency of the initiative petitions in the District Court for Lancaster County. That challenge was rejected, and the Nebraska Supreme Court affirmed. After the election, he filed a new action in the same district court, seeking to enjoin the Governor from certifying the measures. The district court denied his request for a temporary restraining order. Once the laws were certified and enacted, he amended his complaint several times, ultimately alleging taxpayer standing, standing for a matter of great public concern, and standing under a Nebraska statute governing initiative challenges. The defendants moved to dismiss, contending he lacked standing.The Nebraska Supreme Court reviewed the district court’s dismissal de novo. The Supreme Court held that the plaintiff lacked standing to bring the suit. Specifically, it concluded he did not have taxpayer standing, as his allegations of incidental expenditures and government employee time spent implementing the laws did not amount to illegal expenditures sufficient to confer standing under Nebraska law. The Court also found he did not qualify for any exception for matters of great public concern. The order dismissing his complaint without prejudice was affirmed. View "Kuehn v. Pillen" on Justia Law

A woman brought a civil lawsuit against her uncle and godfather, alleging years of sexual abuse that began when she was a minor. The defendant was previously convicted in a criminal court for related offenses and was incarcerated. After his conviction, the plaintiff filed the civil suit seeking compensatory and punitive damages for personal injuries resulting from the abuse. The defendant initially had legal representation using personal funds, but those funds became inaccessible due to a blocked account ordered by a family court during concurrent divorce proceedings. When his accessible funds were depleted, the defendant began representing himself. He sought access to the blocked funds to retain new counsel but experienced significant delays in obtaining a family court order to release the money.The Superior Court of Alameda County presided over the civil trial, during which the defendant appeared remotely from prison. Despite repeated requests for continuances to secure counsel after finally gaining access to some funds, the trial court denied these requests. The trial proceeded, and a jury found the defendant liable for several torts, awarding the plaintiff substantial compensatory and punitive damages.Upon appeal, the California Court of Appeal, First Appellate District, Division Four, determined that the trial court abused its discretion and violated the defendant’s constitutional rights by denying his continuance requests, given his indigency, incarceration, and the fundamental right to meaningful access to the courts. The appellate court reversed the judgment and remanded the case for a new trial on all issues, including punitive damages. The court clarified that the plaintiff is entitled to retry all issues. The court did not address other trial errors or the excessiveness of damages due to its disposition. The appellate court also explained that the trial court did not err in admitting school photographs of the plaintiff, which may be relevant upon retrial. View "Mary D. v. McCauley" on Justia Law

Two individuals who had lived in the United States for many years after entering without inspection were detained by Immigration and Customs Enforcement in October 2025. Both were apprehended while living and working in the Washington, D.C. area, and had established significant ties to the community. Removal proceedings were initiated against them on the basis that they had entered the country without authorization. Following their detention, neither was given an opportunity for a bond hearing, a process that, prior to July 2025, would have typically been available to noncitizens in their circumstances unless they posed certain risks or had committed specific crimes—none of which applied to these individuals.After the Department of Justice adopted a new interpretation of the relevant immigration statute in July 2025, mandating detention for all noncitizens who entered without inspection under 8 U.S.C. § 1225(b)(2)(A), the individuals filed habeas petitions in the United States District Court for the Eastern District of Virginia. They argued that they were entitled to bond hearings under 8 U.S.C. § 1226(a) and that their continued detention violated due process. The district court agreed, granting habeas relief and ordering bond hearings under § 1226(a). During these hearings, immigration judges found neither individual posed a danger or flight risk, and both were released on bond. The government appealed, and the cases were consolidated.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of habeas relief de novo. The Fourth Circuit held that § 1226, not § 1225, governs the detention of noncitizens who have been present in the United States for years, regardless of their manner of entry. The court concluded that the statutory text, structure, history, and longstanding interpretation all supported this reading, and that detaining such individuals without bond hearings raised significant constitutional concerns. The court affirmed the district court’s grant of habeas relief, requiring bond hearings for the petitioners. View "Lopez Garcia v. Guadian" on Justia Law

While incarcerated at a North Carolina women’s correctional facility, the plaintiff learned she was pregnant and, due to her history of opioid use disorder, was prescribed medication for opioid withdrawal (MOUD) under a prison policy that restricted such treatment to pregnant inmates. When she went into labor, she was transported to the hospital and was shackled at various stages during labor, delivery, and her return to prison. After giving birth, the facility denied her further MOUD because she was no longer pregnant, instead providing a short course of alternative pain medication. She experienced significant withdrawal symptoms as a result. The plaintiff brought claims against various prison officials, alleging violations of the Eighth Amendment for the shackling and for denial of MOUD, as well as disability discrimination under the Americans with Disabilities Act and the Rehabilitation Act.The United States District Court for the Eastern District of North Carolina granted summary judgment to all defendants, finding no constitutional violations and that qualified immunity protected the officials. It also concluded that the plaintiff was not discriminated against under federal disability law because the MOUD program was limited to pregnant inmates.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed in part, vacated in part, and remanded. The Fourth Circuit held that, as to certain officials, there was a genuine dispute of fact regarding whether shackling the plaintiff during labor and postpartum, without evidence of a security or flight risk, violated the Eighth Amendment. The court also held that the denial of MOUD following pregnancy, pursuant to a categorical policy, could constitute deliberate indifference to serious medical needs under the Eighth Amendment, and that summary judgment was inappropriate for the medical officials involved. The court further vacated the lower court’s disposition of the plaintiff’s ADA and Rehabilitation Act claims, remanding for further proceedings. Summary judgment for other defendants was affirmed. View "Edwards v. Witherspoon" on Justia Law

A police officer in Washington, D.C., recovered a loaded handgun from the waistband of an individual during a patrol in a high-crime area. The officer initiated a pat-down after observing an unexplained L-shaped bulge in the individual's groin area, which he suspected to be a firearm based on his training, experience, and prior knowledge of the individual’s history with firearm-related arrests. The officer’s interaction began as a casual conversation, and several people present walked away freely. The officer noted the bulge after the individual sat, and subsequent questioning led to evasive responses before the officer conducted the frisk and discovered the firearm.The Superior Court of the District of Columbia reviewed the individual’s motion to suppress the evidence, which argued that the pat-down violated Fourth Amendment protections. After an evidentiary hearing, the trial court found the officer credible and concluded that the L-shaped bulge observed and the individual’s evasive behavior provided reasonable articulable suspicion to justify the frisk. The court also determined that there was no seizure prior to the officer’s observation of the bulge, as the individual was not physically restrained, blocked, or subjected to threatening or accusatory questioning. Following denial of the suppression motion, a second Superior Court judge convicted the individual on three firearm-related charges.The District of Columbia Court of Appeals reviewed the case, applying de novo review to the Fourth Amendment issues while deferring to the trial court’s factual findings unless clearly erroneous. The court held that the officer’s observation of an L-shaped bulge, its concealed location, the individual’s evasive responses, and contextual factors including prior arrests and recent criminal activity supported reasonable articulable suspicion for a frisk. The appellate court affirmed the trial court’s denial of the suppression motion and the convictions. View "Frazier v. United States" on Justia Law

Several teachers, students, parents, and their organizations challenged Oklahoma’s H.B. 1775, specifically subsection B, which restricts public school employees from making certain “discriminatory concepts” a required part of courses. These concepts include assertions about inherent superiority, moral character, responsibility, and psychological distress based on race or sex, among others. If violated, educators could face suspension or revocation of their teaching credentials. Plaintiffs argued that subsection B was unconstitutionally vague under the Fourteenth Amendment and violated students’ First Amendment right to receive information.The United States District Court for the Western District of Oklahoma reviewed the case. It granted judgment on the pleadings against the plaintiffs on their First Amendment claims, finding no protected right in curricular speech and no plausible right-to-receive-information claim. The court partially granted a preliminary injunction, finding that the use of “require” and two of the prohibited concepts (those using “treatment” and “treat”) were likely unconstitutionally vague, and enjoined enforcement of those parts. The court denied injunctive relief for the remaining language, and both parties appealed. The Oklahoma Supreme Court later declined to answer certified questions regarding the statute’s interpretation.The United States Court of Appeals for the Tenth Circuit reviewed the injunction. The court held that the District Court abused its discretion in finding vagueness in subsection B. It interpreted the statute as prohibiting teaching or requiring teaching of the listed discriminatory concepts as correct principles, not banning abstract discussion or instruction about related history or figures. The court determined that the statute’s language was sufficiently clear and not likely vague. It vacated the preliminary injunction, affirmed in part, reversed in part, and remanded for further proceedings. The court declined to address the First Amendment right-to-receive-information claims due to lack of appellate jurisdiction. View "Black Emergency Response Team v. Drummond" on Justia Law

Kevin Lackey was convicted in 1993 by a Michigan jury of criminal sexual conduct and breaking and entering after he was accused of sexually assaulting an eleven-year-old girl in her home. The incident involved an assailant who allegedly entered through a window, abducted the victim from her bedroom, and assaulted her on the back porch before fleeing. Police quickly responded, gathered statements, and relied on a police dog that tracked from the crime scene to Lackey’s nearby residence. Lackey matched the physical description given by the victim and her mother. After serving 22 years in prison, his convictions were vacated due to significant issues with the dog-tracking evidence, and the prosecutor chose not to retry the case.Following the vacatur of his convictions, Lackey filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan. He alleged that several investigating officers fabricated evidence, maliciously prosecuted him, and suppressed exculpatory material, thereby violating his constitutional rights. The district court granted summary judgment in favor of the officers, finding them entitled to qualified immunity, and Lackey settled his remaining claims against another defendant before final judgment was entered.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that Lackey failed to show the officers violated clearly established constitutional rights. The court found no genuine dispute as to material fact that would defeat qualified immunity on claims of fabrication of evidence, malicious prosecution, or suppression of exculpatory evidence. Specifically, the court concluded there was probable cause supporting Lackey’s arrest and prosecution, and no evidence that the officers withheld material information or fabricated evidence in a way that affected the outcome of the trial. The judgment in favor of the officers was therefore affirmed. View "Lackey v. Hurley" on Justia Law