Justia Constitutional Law Opinion Summaries

Florida enacted a statute (HB3) restricting minors’ access to social media platforms that employ certain “addictive features,” such as infinite scrolling, push notifications, and auto-play. Platforms meeting defined criteria—including algorithmic content selection and significant minor usage—must prohibit account creation by those under 14 and require parental consent for those aged 14–15. The Computer & Communications Industry Association and NetChoice, representing affected platforms, challenged the law on First Amendment grounds, asserting both facial and as-applied claims.The United States District Court for the Northern District of Florida initially denied a preliminary injunction for lack of associational standing, but after the plaintiffs amended their complaint and renewed their motion, the court granted a preliminary injunction. The district court found that the trade groups had standing, abstention under Younger v. Harris was unwarranted, and that although HB3 was a content-neutral regulation, it was insufficiently tailored to survive intermediate scrutiny, thus likely unconstitutional.On appeal, the United States Court of Appeals for the Eleventh Circuit first held that the plaintiffs had associational standing to challenge HB3 on behalf of their members. The court also determined that the district court properly declined to abstain under Younger because substantial proceedings had already occurred in federal court before the state enforcement action was initiated. Addressing the merits, the Eleventh Circuit concluded that HB3 is a content-neutral regulation implicating the First Amendment, but it likely survives intermediate scrutiny due to its age-based tailoring and focus on addictive features. The court rejected the facial challenge, holding that the plaintiffs had not demonstrated, as required by Moody v. NetChoice, LLC, that HB3’s unconstitutional applications substantially outweighed its constitutional ones. The disposition affirmed in part, reversed in part, vacated in part, and remanded for further proceedings. View "Computer & Communications Industry Association v. Attorney General, State of Florida" on Justia Law

Two nonprofit organizations dedicated to increasing voter participation, especially among underrepresented groups, sent mail ballot applications to Kansas voters during the 2020 election. These mailings included applications that had been partially prefilled with voter information obtained from public and commercial sources. Due to outdated or inaccurate data, many applications contained errors, leading to voter confusion and administrative burdens for local election officials who had to process erroneous or duplicate applications and respond to concerned voters.Following this experience, the Kansas legislature enacted a law prohibiting private entities from mailing partially prefilled advance ballot applications to registered voters. The nonprofits challenged the law in the United States District Court for the District of Kansas, arguing that it infringed on their First Amendment rights. The district court initially enjoined enforcement of the law, but the United States Court of Appeals for the Tenth Circuit reversed and remanded, instructing the district court to apply intermediate scrutiny unless it found the law was enacted with an improper purpose. On remand, the district court found that the Kansas legislature had acted with an improper purpose, concluded that strict scrutiny should apply, and again enjoined the law.On the second appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s findings de novo. The appellate court held that the district court erred in finding improper legislative intent, as there was no sufficient evidence in the law’s text, justifications, or legislative history to support that conclusion. Applying intermediate scrutiny, the Tenth Circuit found that the law served significant governmental interests—minimizing voter confusion, facilitating efficient election administration, and fostering confidence in elections—and was narrowly tailored to those interests without substantially burdening protected speech. Consequently, the Tenth Circuit reversed the district court’s judgment. View "VoteAmerica v. Schwab" on Justia Law

The case involved a traffic stop of Shawna Rae Pendleton in October 2021 due to expired vehicle registration. Officer Miller and his drug dog, Edo, were called to conduct a free-air sniff around Pendleton’s vehicle. During the sniff, Edo closely investigated the vehicle doors and briefly touched the exterior handle of at least one door with the tip of his nose before alerting to the presence of illegal drugs. A subsequent search of the vehicle revealed methamphetamine, marijuana, alprazolam, and drug paraphernalia, resulting in Pendleton’s arrest and charges for possession offenses.Pendleton moved to suppress the evidence, arguing that Edo’s brief contact with her vehicle constituted a trespass, transforming the sniff into an unlawful search under the Fourth Amendment. The District Court of the Fourth Judicial District in Ada County agreed with Pendleton, relying on State v. Dorff and finding that Edo’s contact amounted to intermeddling and a trespass for the purpose of obtaining information. The court granted the motion to suppress. The State appealed, and the Idaho Court of Appeals reversed, determining the contact was not trespassory and that Edo’s alert prior to contact provided probable cause for the search. Pendleton petitioned for review, which the Idaho Supreme Court granted.The Supreme Court of the State of Idaho held that Edo’s momentary and minimal contact with the vehicle did not rise to the level of intermeddling and therefore was not trespassory. The Court concluded that such brief contact did not meaningfully interfere with Pendleton’s possessory interest in the vehicle. Absent a trespass, the sniff did not constitute a search within the meaning of the Fourth Amendment. The district court’s order suppressing the evidence was reversed and the case remanded for further proceedings. View "State v. Pendleton " on Justia Law

A Milwaukee County Sheriff’s deputy, while on duty and driving his unmarked vehicle, caused a fatal collision after running a red light at a controlled intersection. The deputy failed to notice the light change because he was distracted—looking at either his cellphone or his dashboard computer—for over 15 seconds as he approached the intersection. He was traveling at or just below the speed limit at the time. The victim, Ceaser Stinson, was lawfully passing through the intersection when his vehicle was struck and he was killed. Investigations confirmed the deputy’s inattention as the cause of the accident.Following the crash, Stinson’s estate filed a lawsuit in state court against the deputy, Milwaukee County, and the county’s insurer, alleging, among other claims, a violation of Stinson’s substantive due process rights under 42 U.S.C. § 1983. After removal to the United States District Court for the Eastern District of Wisconsin, the court dismissed some claims but permitted the estate’s § 1983 claim against the deputy to proceed. The defendants moved for summary judgment, arguing that the deputy’s conduct did not meet the threshold for a constitutional violation and that he was entitled to qualified immunity. The district judge denied the motion, concluding that a jury should decide whether the conduct was egregious enough to violate due process and deferred ruling on qualified immunity until after a jury verdict.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the estate failed to show the deputy acted with deliberate indifference to a known and imminent harm, as required for a substantive due process violation. The court further held that it was not clearly established that distracted driving by a law enforcement officer violates due process. Accordingly, the court reversed the district court’s judgment and ordered entry of judgment in favor of the deputy, finding him entitled to qualified immunity. View "Estate of Stinson v. Streicher" on Justia Law

California enacted the No Vigilantes Act, which, among other things, requires any non-uniformed federal law enforcement officer operating in the state to visibly display identification showing their agency and either a name or badge number while performing enforcement duties. This requirement, codified at California Penal Code § 13654, applies broadly to federal officers, subject to narrow exceptions, and provides for criminal penalties for willful violations. The Act also allows agencies to avoid these requirements by publicly posting a written identification policy that complies with the statute.After the Act was passed, the United States filed a lawsuit in the United States District Court for the Central District of California, challenging the constitutionality of the identification requirement before it had been enforced. The United States argued that the law violated the Supremacy Clause by directly regulating federal law enforcement operations. The district court denied the United States’ request for a preliminary injunction against enforcement of the identification requirement, finding the government had not shown that California’s law interfered with or controlled federal operations to a degree that would render it unconstitutional. The district court did, however, grant partial relief under a different statute, and ruled that the United States lacked standing to challenge other provisions.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s denial of a preliminary injunction. The Ninth Circuit concluded that the United States was certain to succeed on its Supremacy Clause claim because the Act directly regulated federal operations without congressional authorization, in violation of intergovernmental immunity. The court held that no set of circumstances existed under which the challenged requirement would be valid, and that the other factors for preliminary injunctive relief also favored the United States. The Ninth Circuit ordered the district court to enter a preliminary injunction barring enforcement of the identification requirement against the United States, its agencies, and officers. View "USA V. STATE OF CALIFORNIA" on Justia Law

The case concerns a fatal shooting that took place on a MARTA train in April 2017. The defendant and the victim had previously lived together with the defendant’s girlfriend, after which the defendant accused the victim of stealing their money, personal items, and drugs. Several months later, after an earlier confrontation at a mall, the defendant encountered the victim and others on a train. Surveillance video and eyewitnesses established that the defendant boarded after the victim, lay in wait, then ambushed and fatally shot the victim, also wounding several passengers. The defendant was apprehended at the station and identified by eyewitnesses, and ballistic evidence connected the firearm he possessed to the shooting.Following indictment in the Superior Court of Fulton County, the defendant was tried by jury and found guilty of malice murder, armed robbery, aggravated assault, and firearms offenses. He received a life sentence without parole plus additional years. After trial, the defendant filed a motion for new trial, which was denied. He then appealed to the Supreme Court of Georgia.On appeal, the Supreme Court of Georgia reviewed the defendant’s claims that the trial court erred by refusing to instruct the jury on voluntary manslaughter and that trial counsel was constitutionally ineffective. The Supreme Court held that any error in failing to give the voluntary manslaughter instruction did not affect the outcome due to the strength of the evidence supporting malice murder and the lack of sufficient evidence of provocation. The Court also found that trial counsel’s performance was not deficient for not objecting to the omitted instruction, given the strategic decision to pursue a misidentification defense. The ineffective assistance claim regarding stipulation to felony status was deemed waived because it was not timely raised. The Supreme Court of Georgia affirmed the judgment. View "DANIELS v. THE STATE" on Justia Law

An individual who was convicted in Arizona for several sexual offenses moved to Georgia after completing his sentence and registration period in New Mexico. Upon arrival in Georgia, he was advised by law enforcement that he would need to register as a sex offender under Georgia law. After several years, he sought removal from the registry, arguing that he had fulfilled his obligations elsewhere, that the crimes for which he was convicted did not require registration in Georgia, and that continued enforcement of the registry against him violated his constitutional rights.The Superior Court of DeKalb County initially dismissed his petition for declaratory relief, finding it time-barred under the two-year statute of limitations for personal injury actions. The Court of Appeals affirmed this dismissal. The Supreme Court of Georgia later reversed, holding that his claims for prospective relief had not accrued and thus were not time-barred, and remanded the case. On remand, after further amendments and substitution of parties, the trial court dismissed the petition again, this time as moot, citing recent revisions to Georgia’s Registry Act which provided a statutory mechanism for requesting removal from registration requirements. The Court of Appeals affirmed the dismissal, but on the alternative ground that any decision would be an impermissible advisory opinion since only prospective relief was sought.The Supreme Court of Georgia reviewed the case and held that seeking prospective relief in a declaratory judgment action is not grounds for dismissal as an impermissible advisory opinion. The Court vacated the Court of Appeals' judgment and remanded the case for further proceedings consistent with its opinion, directing the Court of Appeals to address whether the trial court’s dismissal on mootness grounds was proper and, if not, to instruct the trial court to adjudicate the merits of the declaratory judgment claim. View "GARDEI v. TAYLOR" on Justia Law

After reports and investigations of sexual abuse allegations against a father, the State’s Department of Human Services (DHS) petitioned for foster custody of his children. The family court consolidated the cases, and in September 2024, it issued orders granting DHS foster custody and incorporating a Service Plan that required the father to participate in sex abuse treatment. Importantly, the plan mandated that he “acknowledge and take responsibility for the sexual abuse to his victims” as a condition of successful completion.The father appealed these orders to the Intermediate Court of Appeals of Hawai‘i (ICA), which affirmed the family court's decision. Due to complications with his legal representation, the father’s application for writ of certiorari to the Supreme Court of Hawai‘i was filed late, but the Supreme Court agreed to consider the merits, recognizing his constitutional right to counsel in parental rights termination proceedings.The Supreme Court of Hawai‘i reviewed whether the State can require a parent, as part of mandated rehabilitation therapy in child custody proceedings, to make incriminating disclosures. The court held that under Article I, Section 10 of the Hawai‘i Constitution, the State may not require a parent to admit to criminal misconduct as a condition of completing court-ordered therapy, as this violates the privilege against self-incrimination. However, the court clarified that if a parent’s silence or refusal to admit abuse hinders effective therapy, the court may consider that as a factor in custody determinations without violating the constitutional privilege. The court vacated the lower courts’ orders to the extent they required the father to admit to sexual abuse, and remanded for further proceedings consistent with its opinion. The lower courts’ orders were otherwise affirmed. View "In re: T.J." on Justia Law

Gateway Conservation Alliance challenged the Montana Department of Environmental Quality’s (DEQ) issuance of an opencut mining permit to TMC, Inc. for a site in Gallatin County. After DEQ approved the permit, Gateway filed an administrative appeal with the Board of Environmental Review, alleging violations of environmental statutes related specifically to the permit and site. While that administrative appeal was pending, Gateway also filed a complaint in the Gallatin County District Court, arguing that recent legislative amendments (HB 599) to the governing mining statute violated Montana’s constitutional right to a clean and healthful environment. Gateway sought a declaration of unconstitutionality, an injunction against enforcement, and vacatur of the permit.The District Court for the Eighteenth Judicial District dismissed Gateway’s complaint, holding that Gateway had failed to exhaust its administrative remedies before seeking judicial review, as required under the Montana Administrative Procedure Act (MAPA). The District Court reasoned that Gateway’s constitutional challenge was not a pure facial attack on the administrative scheme itself, but was instead tied to the specific permit at issue, and thus did not fall within any exception to the exhaustion requirement.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal. The Supreme Court held that a party challenging an agency decision governed by MAPA must first complete the administrative process and obtain a final agency decision before seeking judicial review, even if the challenge includes constitutional claims. The only exception recognized is for pure facial constitutional challenges to the administrative process itself, which was not present here. The Court concluded that Gateway’s claims could be raised on judicial review after exhausting administrative remedies, but not before. The order of dismissal was affirmed. View "Gateway Conservation Alliance v. State" on Justia Law

A Lebanese citizen who worked as a physician and educator in the United States traveled to Lebanon to visit family and, upon her return to Boston Logan International Airport, was detained by Customs and Border Protection (CBP) officers. During inspection, officers reviewed her phone and found photos and videos related to Hezbollah, which is designated as a foreign terrorist organization by the United States. She acknowledged deleting some of the photos before her arrival, explained her religious motivations and familial connections, and denied supporting Hezbollah’s political or military activities. After an interview, CBP officers determined she was inadmissible as an immigrant without valid documents because her intentions could not be verified due to derogatory information found during inspection. She was issued an expedited removal order, her H-1B visa was revoked, and she was returned to Lebanon, subject to a five-year bar on reentry.The United States District Court for the District of Massachusetts dismissed her amended habeas corpus petition for lack of jurisdiction, finding that the Immigration and Nationality Act (INA) strips federal courts of jurisdiction to review expedited removal orders except in narrow circumstances not present in her case. The district court also concluded that the Suspension Clause did not preserve jurisdiction for her claims and that her remaining arguments fell outside the scope of habeas review permitted under the INA.The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that it lacked jurisdiction to review the petitioner’s challenge to the expedited removal order and the revocation of her visa because her claims did not fall within the exceptions enumerated in 8 U.S.C. § 1252(e)(2). The court further concluded that the Suspension Clause did not require broader habeas review in these circumstances and rejected arguments that her case was distinguishable from binding Supreme Court precedent. View "Alawieh v. Mullin" on Justia Law