Justia Constitutional Law Opinion Summaries

The defendant was arrested for driving under the influence of drugs and bribing an executive officer. During the arrest, the officer observed signs of intoxication and conducted field sobriety tests, which the defendant failed. A preliminary alcohol screening test showed no alcohol, leading the officer to suspect drug use. The defendant admitted to using cannabis and Alprazolam. At the police station, the defendant initially agreed to a blood test but later refused without a warrant. The officer obtained a warrant, and the blood test confirmed the presence of drugs. The defendant was charged and convicted of DUI and bribery.The Superior Court of California, County of Marin, handled the initial trial. The court instructed the jury with CALCRIM No. 2130, allowing them to infer consciousness of guilt from the defendant's refusal to submit to a blood test. The defendant was found guilty on both counts and sentenced to three years of probation and 180 days in jail. The defendant appealed, arguing that the jury instruction was improper because he had a constitutional right to refuse the blood test without a warrant.The California Court of Appeal, First Appellate District, reviewed the case. The court held that the instruction was proper, stating that while the Fourth Amendment prohibits criminal penalties for refusing a blood test without a warrant, it does not prohibit all consequences. The court emphasized that implied consent laws can impose civil penalties and evidentiary consequences for refusal. The court affirmed the lower court's judgment, concluding that the instruction did not violate the defendant's constitutional rights. View "People v. Bolourchi" on Justia Law

The case involves Business and Professions Code section 7451, enacted through Proposition 22, which classifies app-based drivers for companies like Uber, Lyft, and DoorDash as independent contractors rather than employees, provided certain conditions are met. This classification exempts these drivers from California workers’ compensation laws, which typically apply to employees. Plaintiffs, including several individuals and unions, argue that section 7451 conflicts with article XIV, section 4 of the California Constitution, which grants the Legislature plenary power to create and enforce a complete system of workers’ compensation.The Alameda County Superior Court found Proposition 22 unconstitutional, reasoning that it improperly limited the Legislature’s power to govern workers’ compensation, a power deemed "unlimited" by the state Constitution. The court held that the people must amend the Constitution through an initiative constitutional amendment, not an initiative statute, to impose such limitations. Consequently, the court invalidated Proposition 22 in its entirety.The California Court of Appeal reversed the lower court’s decision, holding that article XIV, section 4 does not preclude the electorate from using its initiative power to legislate on workers’ compensation matters. The court reasoned that the Legislature’s power under article XIV, section 4 is not exclusive and that Proposition 22 does not conflict with this constitutional provision. The court did, however, affirm the invalidation of certain severable provisions of Proposition 22 not at issue in this appeal.The California Supreme Court affirmed the Court of Appeal’s judgment, agreeing that section 7451 does not conflict with article XIV, section 4. The court held that the Legislature’s plenary power under article XIV, section 4 is not exclusive and does not preclude the electorate from enacting legislation through the initiative process. The court did not address whether other provisions of Proposition 22 improperly constrain the Legislature’s authority, as those issues were not presented in this case. View "Castellanos v. State of California" on Justia Law

In 2020, a student organization at the University of Minnesota-Twin Cities, along with two students, sued the University for alleged First and Fourteenth Amendment violations. The case centered on the University's allocation of lounge space in the Coffman Memorial Union to certain student organizations, particularly nine cultural centers. The plaintiffs argued that this allocation constituted viewpoint discrimination and gave unbridled discretion to University officials.The United States District Court for the District of Minnesota dismissed three of the five claims and later granted summary judgment in favor of the University on the remaining claims. The court found no evidence of viewpoint discrimination and deemed the unbridled discretion doctrine inapplicable to the University's past allocation decision. The plaintiffs appealed the summary judgment on one claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court agreed that the lounge space was a limited public forum and found that the University's allocation process was viewpoint neutral and reasonable. The court noted that the plaintiffs failed to provide evidence of viewpoint discrimination and that the University's decision was based on status-based distinctions, not viewpoint-based ones. The court also upheld the district court's finding that the unbridled discretion doctrine did not apply, as the challenge was to a past decision rather than an ongoing policy.The Eighth Circuit affirmed the district court's summary judgment, concluding that the University's allocation of lounge space did not violate the First Amendment. View "Viewpoint Neutrality Now! v. Regents of the University of Minnesota" on Justia Law

On December 26, 2019, Officers Rozeboom and Malone responded to a shoplifting report at Dick’s Sporting Goods in Papillion, Nebraska. The suspects were described as a black male and black female in a silver four-door sedan. Malone spotted a similar vehicle and conducted a traffic stop. Storrs, a black male, was driving, and Smith, a white female, was the passenger. Despite the discrepancy in the suspect description, the officers detained Storrs and Smith. During the encounter, Storrs and Smith were uncooperative, leading to their arrest and a search of their vehicle, which allegedly smelled of marijuana.The United States District Court for the District of Nebraska granted summary judgment in favor of the officers, finding they were entitled to qualified immunity on all claims. The court determined that the officers had reasonable suspicion for the initial stop and probable cause for the continued detention and search based on the alleged odor of marijuana. The court also found no evidence of excessive force or First Amendment retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision in part, agreeing that the officers had probable cause to arrest Storrs and Smith for obstructing a peace officer and that there was no evidence of excessive force or First Amendment retaliation. However, the court reversed the summary judgment on the claim of unlawful continued detention, finding that the officers lacked reasonable suspicion once they saw Smith was white. The court also found a genuine dispute of fact regarding the alleged odor of marijuana, precluding summary judgment on the illegal search claim. The case was remanded for further proceedings consistent with these findings. View "Storrs v. Rozeboom" on Justia Law

Laurie Weinlein was convicted of bank fraud and embezzlement from an employee benefit plan, resulting in a sentence of sixty-three months in prison, five years of supervised release, and over $2 million in restitution payments. The crimes were committed in 1994 and 1995. At that time, the Victim and Witness Protection Act (VWPA) stipulated that restitution obligations terminated twenty years from the date of judgment. In 1996, the Mandatory Victims Restitution Act (MVRA) extended the enforcement period for restitution orders. In 2021, Weinlein moved to terminate her restitution obligation, arguing that the VWPA’s enforcement period had expired and that applying the MVRA retroactively violated the Ex Post Facto Clause of the Constitution.The United States District Court for the Northern District of New York denied Weinlein’s motion to terminate her restitution obligation. The court held that retroactive application of the MVRA’s enforcement period did not violate the Ex Post Facto Clause. Weinlein then appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The court held that retroactively applying the MVRA’s longer enforcement period did not violate the Ex Post Facto Clause. The court reasoned that the MVRA did not increase the punishment for Weinlein’s crime but merely extended the time period over which the government could collect the restitution. The court concluded that the punishment imposed by the restitution order remained the same, and the extension of the enforcement period did not constitute a greater punishment than what was originally imposed. View "United States v. Weinlein" on Justia Law

Michael Jones was convicted by a jury of ten drug-trafficking and drug-possession charges. Before the trial, Jones filed a motion to suppress evidence seized from a safe in a house, arguing that the consent to search was invalid and the search warrant for the safe was insufficient. The trial court denied the motion and sentenced Jones to an aggregate prison term of 22 to 24.5 years.Jones appealed to the First District Court of Appeals, arguing ineffective assistance of counsel for not challenging the evidence as coerced and the protective sweep as unconstitutional. The appellate court agreed, finding that Jones's trial counsel had a reasonable basis to challenge the consent and the protective sweep. The court concluded that the failure to raise these arguments constituted deficient performance and prejudiced Jones. The appellate court ordered a limited remand for Jones to file a new motion to suppress and for the trial court to hold a suppression hearing, staying the consideration of Jones’s remaining assignments of error.The Supreme Court of Ohio reviewed the case and determined that it had jurisdiction under Article IV, Section 2(B)(2) of the Ohio Constitution and R.C. 2505.03(A). The court found that the First District did not comply with App.R. 12(A)(1)(a) and (c) because it did not affirm, modify, or reverse the trial court’s judgment and did not decide all assignments of error. The Supreme Court reversed the judgment of the First District, vacated its entry ordering limited remand, and remanded the case to the First District to enter a judgment that complies with App.R. 12. View "State v. Jones" on Justia Law

The New Jersey Staffing Alliance, the American Staffing Association, and the New Jersey Business and Industry Association sought to enjoin a New Jersey law designed to protect temporary workers. The law, known as the Temporary Workers’ Bill of Rights, mandates recordkeeping, disclosure requirements, and state certification procedures for staffing firms. It also imposes joint and several liability on clients hiring temporary workers and requires staffing firms to pay temporary workers wages equivalent to those of permanent employees performing similar work.The United States District Court for the District of New Jersey denied the preliminary injunction, concluding that the Staffing Associations were unlikely to succeed on the merits of their claims. The court found that the law did not discriminate against out-of-state businesses, as it imposed the same burdens on both in-state and out-of-state firms. The court also rejected the void-for-vagueness claim, reasoning that the law provided sufficient guidance on its requirements. Additionally, the court determined that the law was a reasonable exercise of New Jersey’s police power, as it was rationally related to the legitimate state interest of protecting temporary workers.The United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit agreed that the Staffing Associations failed to show a likelihood of success on their claims. The court held that the law did not violate the dormant Commerce Clause, as it did not favor in-state businesses over out-of-state competitors. The court also found that the law was not unconstitutionally vague, as it provided adequate notice of its requirements. Finally, the court upheld the law as a permissible exercise of state police power, as it was rationally related to the goal of protecting temporary workers. View "New Jersey Staffing Alliance v. Fais" on Justia Law

The case involves individual falconers and the American Falconry Conservancy challenging state and federal regulations that require them to consent to unannounced, warrantless inspections as a condition for obtaining a falconry license. The plaintiffs argue that these regulations impose unconstitutional conditions on their right to obtain a license and violate the Fourth Amendment and the Administrative Procedures Act (APA).The United States District Court for the Eastern District of California dismissed the plaintiffs' claims for lack of standing. The court concluded that the plaintiffs failed to demonstrate injury in fact because they had not been subjected to a warrantless inspection under the challenged regulations and had not shown that future inspections were imminent. The district court also found that the American Falconry Conservancy lacked associational standing because it did not allege that its members faced immediate or threatened injury from unannounced inspections.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court’s dismissal of the plaintiffs' unconstitutional-conditions claim against the California Department of Fish and Wildlife (CDFW), holding that the plaintiffs had standing because they were forced to choose between retaining their Fourth Amendment rights and obtaining a falconry license. The court affirmed the dismissal of the remaining claims against CDFW and the U.S. Fish and Wildlife Service (FWS), finding that the plaintiffs' claims against FWS were unripe and that the plaintiffs failed to demonstrate a sufficient likelihood of future injury to support their Fourth Amendment claims. The court also concluded that the American Falconry Conservancy had standing for its unconstitutional-conditions claim but not for its unannounced-inspection claim.The Ninth Circuit's main holding was that the plaintiffs had standing to challenge the unconstitutional conditions imposed by CDFW but lacked standing for their other claims. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "PETER STAVRIANOUDAKIS V. USFWS" on Justia Law

A sixteen-year-old, Donnell Wilson, was convicted of two murders, armed robbery, and criminal gang activity in Gary, Indiana. Wilson and his accomplice, Jonte Crawford, harassed and robbed a teenager before encountering and fatally shooting two brothers affiliated with a rival gang. Wilson was sentenced to 183 years in prison, which was later reduced to 181 years on appeal due to a vacated gang activity conviction.Wilson sought post-conviction relief, arguing ineffective assistance of counsel and that his sentence violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life without parole for juveniles. The Indiana Supreme Court found his trial counsel effective but agreed his appellate counsel was ineffective for not challenging the sentence under Indiana Appellate Rule 7(B). The court then reduced Wilson’s sentence to 100 years, considering his youth as a mitigating factor.Wilson filed a federal habeas corpus petition, arguing his 100-year sentence was a de facto life sentence violating the Eighth Amendment. The United States District Court for the Northern District of Indiana found the petition timely but denied relief, stating no clearly established law extended Miller to de facto life sentences. The United States Court of Appeals for the Seventh Circuit affirmed, agreeing the petition was timely but holding that the Indiana Supreme Court’s decision was not contrary to or an unreasonable application of clearly established federal law. The Seventh Circuit concluded that Miller’s protections did not extend to Wilson’s 100-year sentence, thus affirming the denial of his habeas petition. View "Wilson v. Neal" on Justia Law

In this case, a Judaic Studies teacher employed by an Orthodox Jewish school was terminated following allegations of inappropriate conduct. The school conducted an investigation and consulted with religious authorities before deciding to terminate the teacher's employment. The school then communicated this decision to the school community, stating that the teacher's conduct was deemed unacceptable and inconsistent with the school's standards.The teacher filed a lawsuit asserting several claims, including defamation. The trial court dismissed all claims, citing the ministerial exception, which bars courts from intervening in employment disputes involving religious institutions and their ministers. The Appellate Division affirmed the dismissal, holding that the ministerial exception applied because the teacher was considered a minister and the defamation claims were related to the school's employment decision.The Supreme Court of New Jersey reviewed the case and reaffirmed the standard set forth in McKelvey v. Pierce, which requires courts to analyze each element of a claim to determine if adjudication would interfere with a religious institution's prerogatives. The Court concluded that adjudicating the defamation claims would require an inquiry into religious law and the school's decision-making process, thus violating the First Amendment. The Court held that the ministerial exception barred the defamation claims and affirmed the Appellate Division's judgment.The Court was equally divided on whether additional discovery was necessary, but ultimately decided that further discovery would not change the constitutional analysis. Therefore, the dismissal of the defamation claims was upheld. View "Hyman v. Rosenbaum Yeshiva of North Jersey" on Justia Law