Justia Constitutional Law Opinion Summaries

A man convicted of capital murder and sentenced to death sought public records from various state agencies related to Florida’s lethal injection protocol and communications between government entities regarding his execution. He first filed a motion for these records before his death warrant was signed and then submitted an additional request after the warrant was issued. He argued that the records were necessary to support a potential claim that the method of execution would violate his constitutional rights, and that communications between agencies might reveal improper conduct or motives regarding the timing of his execution.The Circuit Court denied both his pre- and post-warrant public records motions, as well as a motion for rehearing and an in camera review of the requested records. The court also denied his motion for an extension of time to file a successive postconviction motion, though he was initially granted some additional time. Despite these denials, the man did not file a successive postconviction motion. He then petitioned the Supreme Court of Florida for relief, arguing that the denials infringed on his rights to due process, equal protection, and access to the courts.The Supreme Court of Florida treated his appeal as a petition for review of a nonfinal discovery order under Florida Rule of Appellate Procedure 9.142(c) and denied it. The Court held that the circuit court did not depart from the essential requirements of law because the requested records were not tied to a colorable claim for postconviction relief, but rather constituted a prohibited fishing expedition. The Court further denied his requests for habeas corpus and oral argument, and dismissed the appeal concerning the denied extension of time. The main holding is that public records requests in capital postconviction proceedings must be connected to a colorable claim for relief. View "Willacy v. State" on Justia Law

A sign operator installed two advertising signs near Interstate 85 in Atlanta in 1993, after obtaining permits under the city’s 1982 sign code. These permits were renewed several times. In 2015, after the Supreme Court’s decision in Reed v. Town of Gilbert, the city amended its sign code, removing several content-based provisions but allowing lawful, nonconforming signs to remain. When the sign operator later sought to upgrade the signs, the city approved the changes, but private parties challenged the decision. The Superior Court of Fulton County found that the original permits were unlawful under the 1982 code, making the signs illegal. The city then ordered removal of the signs and issued citations when the order was not followed.The sign operator, joined by the property owner and its president, sued the City of Atlanta in the United States District Court for the Northern District of Georgia, seeking a declaration that the 1982 sign code was unconstitutional under the First Amendment and seeking to enjoin its enforcement. The district court initially dismissed some claims for lack of jurisdiction, then reconsidered and ruled in favor of the plaintiffs, concluding that the code was content-based and subject to strict scrutiny, which the city had not attempted to satisfy.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs only had standing to challenge the provision of the 1982 code that applied to their signs—section 16-28.019(7)—rather than the entire code. The court further held that this provision, which distinguished between on-premises and off-premises signs, was content-neutral under the Supreme Court’s decision in City of Austin v. Reagan National Advertising of Austin, LLC. The Eleventh Circuit vacated the district court’s judgment and injunction and remanded for further proceedings to determine whether the provision meets the applicable intermediate scrutiny standard. View "Anderson v. City of Atlanta, Georgia" on Justia Law

In this case, four police officers in Puerto Rico pursued two young men suspected of engaging in a drug deal. One officer shot 17-year-old Calep Carvajal in the back as he fled on a bicycle. Defendant José Cartagena apprehended and handcuffed Carvajal, and was accused of pistol-whipping him while he was on the ground. Additional assaults allegedly occurred during and after transport to the police station. Cartagena later filed a false report about the incident and lied to a juvenile prosecutor about Carvajal’s injuries. Federal charges were brought under various statutes, including civil rights violations and obstruction of justice.After a grand jury indictment, three officers pleaded guilty. Cartagena initially entered a plea but withdrew it and went to trial in the United States District Court for the District of Puerto Rico. He was convicted by a jury on all counts and sentenced to concurrent prison terms. On appeal, he challenged the sufficiency of the evidence and asserted that his Sixth Amendment Confrontation Clause rights were violated when the prosecution introduced a hearsay statement from the victim, who was not available for cross-examination.The United States Court of Appeals for the First Circuit reviewed the case. It found the evidence sufficient to support convictions on most counts but determined that the admission of the victim’s testimonial hearsay statement, offered through a government medical expert, violated Cartagena’s Confrontation Clause rights as to the count involving the alleged pistol-whipping during the arrest. The court vacated the conviction on that count, affirmed the convictions on the other counts, and remanded the case for further proceedings consistent with its opinion. View "US v. Cartagena" on Justia Law

An inmate at an Arkansas state prison injured his right pinky finger while playing basketball, resulting in a dislocation. He was treated initially by infirmary staff with a splint and pain medication, and an x-ray was ordered. The x-ray showed no fracture but confirmed the dislocation. After a week, a doctor and a nurse attempted to realign the finger but were unsuccessful, so they provided additional pain management and referred him to an orthopedic surgeon. The finger was reset by a specialist over a month after the original injury. The inmate followed the prison grievance process, complaining about pain, the delay in seeing a provider, and subsequent delays in receiving further care.The United States District Court for the Eastern District of Arkansas reviewed the inmate’s claims. The court dismissed the claims related to delay in care for failure to exhaust administrative remedies, as the inmate did not specifically name the doctor and nurse responsible for the alleged delay in his grievances. The district court granted summary judgment to the doctor and nurse on the remaining claim regarding their care on May 19, finding no deliberate indifference.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the inmate did not properly exhaust his administrative remedies against the doctor and nurse for claims of delayed care, since he failed to name them as required by prison policy. Further, the appellate court agreed with the district court that the care provided on May 19 did not constitute deliberate indifference under the Eighth Amendment. The court concluded that no reasonable jury could find that the medical staff acted with deliberate indifference, and thus affirmed the district court’s dismissal and grant of summary judgment. View "Nuuh Na'im v. Beck" on Justia Law

Two individuals who are transgender women, one living in Montana and the other in Alaska, challenged recent Montana laws and administrative policies that restrict the ability to amend the sex designation on birth certificates and driver's licenses. These state actions, enacted in response to legislative changes, allow amendments to these documents only in limited circumstances such as clerical errors, not to reflect a person’s gender identity. The plaintiffs argued that these restrictions forced them to carry identification that does not match their gender identity, resulting in concrete harms such as disclosure of their transgender status during routine activities and difficulties in verifying their identity.The case was filed in the First Judicial District Court of Lewis and Clark County. The plaintiffs sought declaratory and injunctive relief, alleging violations of equal protection, right to privacy, and prohibition against compelled speech under the Montana Constitution, as well as violations of the Montana Administrative Procedure Act. The District Court found that the plaintiffs had standing, demonstrated concrete and particularized injuries, and satisfied all four factors required for a preliminary injunction. The court concluded that the policies likely violated Montana’s Equal Protection Clause by discriminating against transgender individuals on the basis of sex, and that the plaintiffs were likely to suffer irreparable harm without relief. The District Court preliminarily enjoined enforcement of the challenged state policies as applied to amending birth certificates and driver’s licenses.The Supreme Court of the State of Montana reviewed whether the plaintiffs had standing and whether the District Court manifestly abused its discretion in granting the preliminary injunction. The Supreme Court affirmed the District Court’s order. It held that the plaintiffs had standing and that the District Court did not abuse its discretion in concluding that the state policies likely constitute unconstitutional sex discrimination under Article II, Section 4 of the Montana Constitution, warranting preliminary injunctive relief. View "Kalarchik v. State" on Justia Law

A U.S. citizen of Pakistani descent was denied boarding an international flight in 2019 and subsequently learned, after following the Department of Homeland Security’s redress process, that he was listed on the federal government’s No Fly List. He then sought to challenge his inclusion both on the No Fly List and the broader Terrorist Watchlist, which contains the names of individuals reasonably suspected of terrorism. Placement on the No Fly List is dependent on inclusion in the Terrorist Watchlist. The individual alleged ongoing travel and immigration-related harms due to his watchlist designations.He filed suit in the United States District Court for the District of Columbia, raising constitutional and statutory claims and seeking removal from both lists. The district court concluded it lacked jurisdiction over the No Fly List claims due to the statutory requirement that such challenges proceed in the circuit court under 49 U.S.C. § 46110, and transferred those claims accordingly. The district court retained the Terrorist Watchlist claims under general federal question jurisdiction. After further briefing, the district court dismissed the remaining Terrorist Watchlist claims for lack of Article III standing, finding it could not redress the alleged injuries because removing the plaintiff from the Terrorist Watchlist would necessarily set aside the TSA Administrator’s order keeping him on the No Fly List—an action reserved for the circuit court.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed. The court held that while the plaintiff suffered concrete injuries from his inclusion on the Terrorist Watchlist, the district court lacked authority to redress those injuries because any effective remedy would encroach on the circuit court’s exclusive jurisdiction to review and set aside TSA No Fly List orders under § 46110. Thus, the district court properly dismissed the case for lack of standing. View "Khalid v. Blanche" on Justia Law

A United States citizen of Pakistani descent challenged his continued placement on the federal No Fly List, which prohibits individuals from boarding flights in U.S. airspace. After enhanced screening and questioning by the FBI in 2012 and being prevented from boarding a flight in 2019, he sought redress through the Department of Homeland Security Traveler Redress Inquiry Program (DHS TRIP). He received an unclassified summary stating that his listing was based on concerns about his associations and candor regarding activities in Pakistan. He contested these grounds, denied any terrorist associations, and argued that his inclusion was erroneous.While his DHS TRIP redress was pending, he filed suit in the United States District Court, which ultimately concluded it lacked jurisdiction, as exclusive review of the Transportation Security Administration (TSA) Administrator’s order rested with the United States Court of Appeals for the District of Columbia Circuit. The district court transferred his claims to the appellate court.The United States Court of Appeals for the District of Columbia Circuit reviewed the TSA Administrator’s order, applying a “substantial evidence” and “arbitrary and capricious” standard, and reviewed constitutional claims de novo. The court dismissed the petitioner’s Religious Freedom Restoration Act claim for lack of standing, finding insufficient concrete plans to travel for religious purposes. It denied his other claims, holding that there is no fundamental right to air travel under substantive due process, and that the DHS TRIP process provides constitutionally adequate procedural protections. The court found that the Administrator’s order was supported by substantial evidence and not arbitrary or capricious. The court also rejected the argument that the major questions doctrine applied, finding TSA’s statutory authority adequate. The petition was dismissed in part and otherwise denied. View "Khalid v. TSA" on Justia Law

The case concerns a search of Albert Alexander’s residence by Lafayette Police Department officers, who had a warrant to search for firearms. Upon executing the warrant, the officers found only pellet rifles, but also observed a large quantity of electronics and appliances—many in unopened boxes or wrapped—inside the house. These observations, combined with prior tips from Alexander’s granddaughter and her girlfriend that stolen goods were stored there, led the officers to seize the items on suspicion they were stolen. The seized property was not listed in the original search warrant.After being charged with possession of stolen property and later acquitted at trial, Alexander filed a civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Louisiana. He alleged that the officers violated his Fourth Amendment rights by seizing items not listed in the warrant during the first search. The defendants moved for summary judgment, asserting qualified immunity. The district court granted summary judgment, finding that the officers’ seizure of the electronics and appliances was justified under the plain view doctrine, as their incriminating nature was immediately apparent given the circumstances and information available to the officers.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the officers did not violate the Fourth Amendment because, under the totality of the circumstances—including the tips received, officers’ observations, and their experience—the officers had probable cause to believe the items were stolen, satisfying the plain view exception. The court affirmed the district court’s grant of summary judgment, holding that the officers were entitled to qualified immunity. View "Alexander v. Arceneaux" on Justia Law

The defendant was arrested and charged with multiple sexual assault offenses involving a 16-year-old girl. After being released on bail, he failed to appear at a scheduled arraignment, leading to a bench warrant and a delay of more than six years before he was returned to custody and the case moved forward. During jury selection for his trial, a prospective juror (PJ183) identified herself as a newly graduated nurse. The prosecutor used a peremptory challenge to excuse her, stating, “she is a nurse.” Defense counsel objected, referencing California Code of Civil Procedure section 231.7, but did not argue that the prosecutor’s stated reason was presumptively invalid under the statute. The trial court overruled the objection, focusing only on the reason provided.A jury in the Superior Court of Orange County found the defendant guilty of all charges, and the court found aggravating factors true. He was sentenced to 26 years in prison. On appeal, the defendant argued that the prosecutor’s reason for excusing PJ183—a nurse—was presumptively invalid under section 231.7, subdivision (e)(10), because nursing is a field disproportionately occupied by women, a protected group under the statute. The Attorney General contended that the defendant forfeited this argument by not raising the presumptive invalidity at trial.The California Court of Appeal, Fourth Appellate District, Division Three, held that the defendant did not forfeit his argument. The Court explained that section 231.7 requires the trial court, when ruling on a peremptory challenge objection, to meaningfully consider whether any stated reason is presumptively invalid—even if not explicitly identified by the objecting party. Because the trial court failed to make this inquiry or create a record of doing so, the Court reversed the judgment and remanded the case for a new trial. View "P. v. Espiritu" on Justia Law

Several individuals, all enthusiasts of distilling spirits, and a non-profit organization devoted to legalizing at-home hobby distilling, sought to challenge longstanding federal laws prohibiting the operation of home distilleries. The plaintiffs, who had experience with lawful alcohol production for fuel or other beverages, expressed clear intent to distill spirits for personal consumption at or near their residences. They faced explicit warnings from federal authorities that such activity was illegal and punishable by substantial penalties, and that no permits would be issued for home-based distillation of consumable spirits.After contacting the Alcohol and Tobacco Tax and Trade Bureau (TTB) and receiving confirmation that home distilling would not be permitted, the plaintiffs filed suit in the United States District Court for the Northern District of Texas against the TTB and the U.S. Department of Justice. The district court dismissed several individual plaintiffs for lack of standing but allowed the claims of one individual and the non-profit organization to proceed. On the merits, the district court determined that federal statutes barring home distilling for beverage purposes violated the Constitution’s Commerce, Taxation, and Necessary and Proper clauses. The government appealed, and the dismissed plaintiffs cross-appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that all individual plaintiffs and the non-profit organization had standing to sue. On the merits, the Fifth Circuit ruled that the statutory prohibition on home distilleries and associated criminal penalties exceeded Congress’s constitutional authority under both the Taxation Clause and the Necessary and Proper Clause, as the prohibitions were not “plainly adapted” to raising revenue and represented an improper federal intrusion into matters reserved to the states. The Fifth Circuit affirmed the district court’s judgment and injunction against enforcement of the statutes, as modified. View "McNutt v. Dept of Justice" on Justia Law