Justia Constitutional Law Opinion Summaries
Articles Posted in U.S. Court of Appeals for the District of Columbia Circuit
Doe v. McKernan
Dr. John Doe, a federal public servant with a security clearance, was convicted of two felonies in Ohio in the early 1990s. He received a pardon from the Ohio governor in 2009, and his felony convictions were sealed by an Ohio court. In 2022, Dr. Doe applied for a position at the Federal Deposit Insurance Corporation (FDIC), but his application was denied due to a statutory bar against hiring individuals with felony convictions. Dr. Doe then filed a lawsuit challenging the constitutionality of this hiring prohibition and sought to proceed under a pseudonym to avoid public association with his sealed convictions.The United States District Court for the District of Columbia denied Dr. Doe's motion to proceed under a pseudonym. The court acknowledged Dr. Doe's privacy concerns and the lack of unfairness to the government but concluded that the privacy interest in felony convictions does not warrant pseudonymity. The court emphasized the importance of transparency in judicial proceedings, especially in cases involving constitutional challenges against the government.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Dr. Doe's privacy interest in his sealed felony convictions was insufficient to overcome the presumption against pseudonymous litigation. The court highlighted the public's significant interest in open judicial proceedings, particularly when the case involves a constitutional challenge to a federal statute. The court found that the district court did not abuse its discretion in applying the relevant factors and denying Dr. Doe's motion to proceed under a pseudonym. View "Doe v. McKernan" on Justia Law
Radio Communications Corporation v. FCC
Radio Communications Corporation (RCC), a telecommunications and media company, petitioned for review of a final order issued by the Federal Communications Commission (FCC) implementing the Low Power Protection Act (LPPA). The LPPA allows low power television (LPTV) stations to apply for an upgrade to a Class A license if they meet certain criteria, including operating in a Designated Market Area (DMA) with not more than 95,000 television households. The FCC's order adopted this limitation and used Nielsen’s Local TV Report to determine a station’s DMA.RCC operates an LPTV station, W24EZ-D, in Connecticut, which is licensed to serve Allingtown, a neighborhood of West Haven with fewer than 15,000 television households. However, the station is part of the Hartford-New Haven DMA, which has approximately one million television households. RCC challenged the FCC's order, arguing that the size limitation should apply to a station’s community of license, not its DMA. RCC also raised other statutory and constitutional arguments, including claims that the order contravenes section 307(b) of the Communications Act, violates the Commerce Clause, improperly delegates legislative authority to Nielsen, and restricts programming content in violation of the First Amendment.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the FCC's order adheres to the best reading of the LPPA, which clearly limits Class A license eligibility to LPTV stations operating in a DMA with not more than 95,000 television households. The court found that the FCC properly defined DMA according to Nielsen’s data, as authorized by Congress, and that the statute does not reference "community of license." The court also rejected RCC's constitutional arguments, finding that the FCC's interpretation did not violate the Commerce Clause or the nondelegation doctrine. Consequently, the court denied RCC's petition for review. View "Radio Communications Corporation v. FCC" on Justia Law
Doc Society v. Rubio
The case involves two organizations, Doc Society and International Documentary Association (IDA), which promote documentary filmmaking globally. They challenged a policy by the Secretary of State requiring visa applicants to disclose their social media information from the past five years. The plaintiffs argued that this policy violated the First Amendment and the Administrative Procedure Act, claiming it impeded their core activities and harmed their members.The United States District Court for the District of Columbia found that the plaintiffs had organizational standing but dismissed their claims on the merits, stating they failed to state a claim under the First Amendment or the Administrative Procedure Act. The district court dismissed the complaint with prejudice.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court concluded that the plaintiffs did not adequately allege that a favorable decision would redress their claimed injuries. The court found that the plaintiffs lacked standing because they did not provide specific allegations showing that their partners and members would return to their prior use of social media or reconsider their willingness to travel to the United States if the policy were vacated. The court reversed the district court's determination that the plaintiffs had standing, vacated the remainder of the district court's order, and remanded the case for further proceedings, including whether the plaintiffs should be granted leave to amend their complaint. View "Doc Society v. Rubio" on Justia Law
Hall v. District of Columbia Board of Elections
Seven District of Columbia citizen-voters filed a complaint challenging the constitutionality of the Local Resident Voting Rights Amendment Act of 2022, which allows noncitizens to vote in municipal elections. The plaintiffs argued that this law dilutes their votes, discriminates against U.S. citizens, and violates the constitutional right to citizen self-government. The District of Columbia Board of Elections, responsible for implementing the law, was named as the defendant.The case was initially brought in D.C. Superior Court, but the Board removed it to the United States District Court for the District of Columbia. The Board then moved to dismiss the case, arguing that the plaintiffs lacked standing and failed to state a claim. The district court agreed with the Board, holding that the plaintiffs did not demonstrate any individual disadvantage and thus lacked standing. The court dismissed the complaint, characterizing the plaintiffs' grievances as generalized and insufficient to confer standing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the plaintiffs had standing to sue because they alleged a concrete and particularized injury: the dilution of their votes due to the expansion of the electorate to include noncitizens. The court distinguished this case from others where plaintiffs failed to show individualized harm. The court found that the plaintiffs' claims were specific to their voting power in D.C. local elections and not merely a generalized grievance. Consequently, the court reversed the district court's dismissal and remanded the case for further proceedings. The Board's cross-appeal was dismissed as moot. View "Hall v. District of Columbia Board of Elections" on Justia Law
Al-Baluchi v. Hegseth
Ammar al-Baluchi, a Pakistani national, has been detained at the U.S. naval base in Guantánamo Bay since 2006. He is accused of supporting the September 11, 2001, attacks as a senior member of al-Qaeda. In 2008, al-Baluchi filed a habeas corpus petition in federal district court. In 2022, he moved to compel the government to convene a Mixed Medical Commission to assess his eligibility for repatriation due to alleged torture and resulting serious health issues. The district court denied his request, ruling that detainees captured during non-international armed conflicts are not entitled to such examinations under the Third Geneva Convention or Army Regulation 190-8.The United States District Court for the District of Columbia initially stayed al-Baluchi’s habeas case pending the outcome of his military commission trial. After temporarily lifting the stay to consider his motion for a Mixed Medical Commission, the court denied the motion, leading al-Baluchi to appeal the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court determined that it lacked jurisdiction to review the district court’s nonfinal order. The court found that al-Baluchi did not demonstrate that the denial of his motion had the practical effect of denying injunctive relief or that it caused serious or irreparable harm requiring immediate review. The court noted that even if a Mixed Medical Commission found al-Baluchi eligible for repatriation, the government retained discretion to delay repatriation until the completion of his military commission proceedings. Consequently, the appeal was dismissed for lack of jurisdiction. View "Al-Baluchi v. Hegseth" on Justia Law
Media Matters for America v. Paxton.
Media Matters for America and Eric Hananoki, a senior investigative reporter, filed a lawsuit against Warren Kenneth Paxton, Jr., in his official capacity as the Attorney General of Texas. The plaintiffs alleged that the Texas Office of the Attorney General launched a retaliatory campaign against them after they published an unfavorable article about X.com, a social media platform owned by Elon Musk. The article reported that corporate advertisements on X appeared next to antisemitic posts and that Musk endorsed an antisemitic conspiracy theory. Following the publication, the Texas Attorney General's office issued a civil investigative demand (CID) to Media Matters, requiring them to produce extensive records.The United States District Court for the District of Columbia granted the plaintiffs' motion for a preliminary injunction and denied Paxton's motion to dismiss for improper venue and lack of personal jurisdiction and subject matter jurisdiction. The court found that the investigation and CID constituted cognizable injuries sufficient to establish the plaintiffs' standing. The court concluded that the plaintiffs satisfied the requisite factors for a preliminary injunction, including a likelihood of success on the merits of their First Amendment retaliation claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the District Court's judgment. The appellate court held that Paxton was subject to personal jurisdiction in the District of Columbia because he purposefully directed actions at the plaintiffs in the District. The court also found that the plaintiffs' complaint raised a justiciable claim of First Amendment retaliation, as they alleged concrete and ongoing harms resulting from the retaliatory investigation. The court concluded that the District of Columbia was a proper venue for the action and that the District Court did not err in issuing the preliminary injunction. View "Media Matters for America v. Paxton." on Justia Law
Castaneira v. Noem
Ryan Castaneira, a U.S. citizen, filed a Form I-130 petition to obtain permanent residency for his spouse, a Mexican national. USCIS issued a Notice of Intent to Deny the petition due to Castaneira's prior convictions in Georgia for crimes that appeared to qualify as "specified offenses against a minor" under the Adam Walsh Act. Castaneira argued that his convictions involved an undercover officer, not a minor, and thus should not be considered offenses against a minor. He also challenged the agency's use of the "beyond any reasonable doubt" standard to prove he posed no risk to his spouse.The United States District Court for the District of Columbia dismissed Castaneira's claims. The court held that his prior convictions fell within the statutory definition of "specified offense against a minor" and that the Adam Walsh Act's grant of "sole and unreviewable discretion" to USCIS precluded judicial review of the evidentiary standard applied by the agency. The court concluded that it lacked jurisdiction to review the standard of proof used by USCIS in making the no-risk determination.The United States Court of Appeals for the District of Columbia Circuit affirmed the District Court's ruling in part, agreeing that Castaneira's prior convictions were covered by the Adam Walsh Act. However, the appellate court vacated the District Court's jurisdictional ruling regarding the evidentiary standard. The court held that while USCIS's ultimate no-risk determinations are unreviewable, challenges to the agency's departure from its own binding precedent, such as the standard of proof, are reviewable under the Administrative Procedure Act. The case was remanded for further proceedings to determine whether USCIS violated its own precedent by applying the "beyond any reasonable doubt" standard. View "Castaneira v. Noem" on Justia Law
Page v. Comey
Carter W. Page filed a lawsuit against the United States, the Department of Justice (DOJ), the Federal Bureau of Investigation (FBI), and several current and former FBI officials. Page alleged that the FBI unlawfully obtained four warrants to electronically surveil him under the Foreign Intelligence Surveillance Act (FISA) and leaked information obtained from these warrants to the press, causing him reputational harm and lost business opportunities. The district court dismissed Page's claims, finding them either time-barred or insufficiently pleaded.The United States District Court for the District of Columbia dismissed Page's second amended complaint for failure to state a claim. The court found that Page's FISA claims were time-barred by the applicable three-year statute of limitations and that his claims were insufficiently pleaded. The court also dismissed Page's Patriot Act claim against the United States, with the majority concluding it was time-barred and the partial dissent finding it legally insufficient. Additionally, the court dismissed Page's Bivens claim and Privacy Act claims for lack of jurisdiction and failure to state a claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's dismissal of Page's FISA and Patriot Act claims as time-barred. The court held that Page had actual or inquiry notice of his FISA claims by April 2017, more than three years before he filed his complaint in November 2020. The court also found that Page's Patriot Act claim was barred because he failed to file his administrative claim with the FBI within two years of its accrual. The court concluded that Page had sufficient information by April 2017 to discover the basis for his claims, making them time-barred. View "Page v. Comey" on Justia Law
Hight v. DHS
Captain Matthew Hight trained with the Saint Lawrence Seaway Pilots Association from 2015 to 2018 to become a maritime pilot on Lake Ontario and the St. Lawrence River. The Great Lakes Pilotage Act of 1960 requires certain ships on these waters to have a registered pilot on board. The Coast Guard oversees the registration of American pilots and supervises private pilotage associations responsible for training new pilots. Hight applied for registration in 2018, but the Pilots Association recommended denial, citing incomplete training and concerns about his temperament. The Coast Guard denied his application after an independent review.Hight challenged the decision in the United States District Court for the District of Columbia, arguing that the Coast Guard acted arbitrarily and capriciously, unconstitutionally delegated authority to the Pilots Association, and violated the First Amendment by requiring him to train with and join the Pilots Association. The district court rejected all claims, finding that the Coast Guard's decision was supported by substantial evidence, including Hight's failure to complete the required training and concerns about his temperament.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Coast Guard's decision was reasonable and supported by the record, as Hight had not completed the required supervised trips on the St. Lawrence River. The court also found that the Coast Guard did not unconstitutionally delegate authority to the Pilots Association, as the association's role was limited to providing advice and gathering facts. Finally, the court determined that Hight's First Amendment claim regarding mandatory association membership was not ripe for review, as he was not yet eligible to join the Pilots Association. The court affirmed the district court's judgment. View "Hight v. DHS" on Justia Law
Ateba v. Leavitt
A journalist, Simon Ateba, sought preferred access to the White House Press Area through a special press credential known as a "hard pass." The White House issues hard passes only to reporters accredited by either the Supreme Court Press Gallery or a congressional press gallery. Ateba applied for membership in the Senate Daily Press Gallery as a prerequisite to securing a hard pass, but his application was still under consideration. In the meantime, he accessed the Press Area with a daily pass, which required him to wait for an escort. Ateba argued that the White House Hard Pass Policy violated the First Amendment because it burdened his access and conditioned fuller access on accreditation by the Senate Daily Press Gallery, which he claimed exercised unbridled discretion.The United States District Court for the District of Columbia granted summary judgment in favor of the White House. The court concluded that while Ateba had suffered a cognizable First Amendment injury, the White House acted reasonably under the First Amendment by outsourcing part of its press-credentialing process. The district court also ruled that the Senate Daily Press Gallery did not impermissibly exercise discretion in deciding who could become a member and that extraordinary procedural protections were not constitutionally required.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's judgment. The court held that the White House Hard Pass Policy was both reasonable and viewpoint neutral. It found that the policy's reliance on external credentialing bodies was reasonable given the White House's lack of its own vetting system. The court also determined that the Senate Daily Press Gallery's membership criteria, including the "of repute" standard, did not confer unbridled discretion because it was guided by concrete rules. Additionally, the court held that the First Amendment did not require the gallery to set a deadline for processing membership applications. View "Ateba v. Leavitt" on Justia Law