Justia Constitutional Law Opinion Summaries

A group of individuals required to register as sex offenders under Missouri’s Sex Offender Registration Act (Mo. SORA), along with their spouses and children, filed suit against Missouri State Highway Patrol officials responsible for enforcing the law. The plaintiffs challenged various aspects of Mo. SORA, including its registration requirements, the lack of individualized risk assessments, the tiered system of registration durations, and reporting obligations for online identifiers. They asserted that these provisions violated their constitutional rights and also caused harm to their family members, who experienced social stigma and other indirect consequences.The United States District Court for the Western District of Missouri dismissed the claims of the family members, finding they were not directly subject to Mo. SORA and that incidental effects on them were irrelevant to the constitutional analysis. The court also rejected the plaintiffs’ Eighth Amendment and Ex Post Facto Clause challenges, concluding that Mo. SORA was not punitive. It found the statute’s requirements regarding online identifiers were not unconstitutionally vague because the registration form specified the information to be provided. The court dismissed the due process and equal protection claims, finding no fundamental rights or suspect classifications were implicated and that the statute was rationally related to legitimate state interests. Regarding the First Amendment, the court held that the prior restraint on use of online identifiers was unconstitutional, and the parties agreed to modify the registration form to remove that requirement.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that (1) Mo. SORA is not punitive for Eighth Amendment or Ex Post Facto purposes, (2) the statute is not unconstitutionally vague regarding online identifiers, (3) no cognizable due process or equal protection claims were stated, (4) the family members lacked standing, and (5) the First Amendment claim was properly resolved by modifying the reporting requirement. View "Does v. Flannigan" on Justia Law

During the COVID-19 pandemic, Dr. Scott Jensen, a physician and former Minnesota state senator, publicly voiced opposition to vaccine mandates and business closures. As a Republican candidate for governor in 2022, he became the subject of 18 complaints alleging he spread misinformation and endangered public health. The Minnesota Board of Medical Practice initiated four investigations, each requiring Jensen to respond and cooperate fully, including providing documents and hiring legal counsel. One investigation lasted over a year and demanded an in-person conference. Jensen claims these investigations caused him to spend substantial time and money, self-censor his public statements, and decline speaking engagements due to fear of professional repercussions.The United States District Court for the District of Minnesota dismissed Jensen’s amended complaint for lack of standing, finding his allegations “too conclusory” and lacking specific instances of chilled speech or imminent enforcement threats. The court determined he did not demonstrate injury sufficient to invoke federal jurisdiction, thus preventing further review of his constitutional claims seeking damages and injunctive relief.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal. It found that Jensen’s general factual allegations of time, money spent, and self-censorship—the chilling effect—were sufficient to establish standing at the pleading stage. The court concluded that both monetary harms and reasonable self-censorship due to credible threats of enforcement constituted concrete and particularized injuries. The appellate court held that Jensen had standing to pursue his claims for damages and injunctive relief. The judgment of the district court was reversed and the case remanded for further proceedings on the merits. View "Jensen v. Minn. Bd. of Medical Practice" on Justia Law

A former applicant for the position of police commissioner in St. Louis alleged that after a competitive selection process, he and another white male candidate were certified as the only eligible finalists. The mayor publicly stated she did not want to select either finalist because both were white males, emphasizing the city’s diversity. The city then abandoned the original selection process, reopened the search with lower minimum qualifications, and ultimately hired a different white male candidate after two Black finalists withdrew. The plaintiff, who was ranked first and asserted he was entitled to the position under civil service rules, claimed the process was reopened solely due to the race of the finalists.The United States District Court for the Eastern District of Missouri denied the defendants’ motion to dismiss on the grounds of failure to state a claim and qualified immunity. The court found that the plaintiff had plausibly alleged an adverse employment action and a violation of clearly established equal protection rights, relying on the Supreme Court’s decision in Ricci v. DeStefano, which prohibits invalidating a selection process based on race. The defendants argued that the plaintiff suffered no adverse employment action since a white male was ultimately selected and asserted that the plaintiff had no entitlement to the promotion.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed only the denial of qualified immunity. The appellate court held that, accepting the allegations as true, the complaint sufficiently alleged that the defendants’ actions violated the plaintiff’s clearly established right to equal protection by reopening the hiring process for racial reasons and denying him promotion. The court also found the complaint adequately alleged personal involvement by each defendant. The Eighth Circuit affirmed the district court’s order denying qualified immunity and left the underlying claims to be resolved in further proceedings. View "Sack v. City of St. Louis" on Justia Law

Employees of a nonprofit animal sanctuary took possession of six injured sheep following a highway accident in Missouri, after being authorized to do so by a law enforcement officer. The sanctuary’s director transported the sheep to a university veterinary hospital and paid a deposit for care. With the director’s consent, two sheep were euthanized due to critical injuries. Subsequently, the hospital denied the sanctuary further information about the remaining sheep, citing the arrival of the owner. The sanctuary was also denied access to the sheep and their medical records. Shortly thereafter, the sanctuary learned that, at the owner’s direction, the four remaining sheep had been euthanized. The sanctuary’s state court action for recovery of the sheep became moot when it was discovered the sheep were deceased.The Iowa Farm Sanctuary and its director then filed a federal lawsuit in the United States District Court for the Western District of Missouri against the university, its veterinary hospital, and certain personnel, alleging violations of procedural and substantive due process under the Fourteenth Amendment, and an unreasonable seizure under the Fourth Amendment. The district court dismissed the complaint, ruling that Missouri’s lien laws provided an adequate remedy for the loss, and that the complaint otherwise failed to state a claim.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court held that the plaintiffs lacked standing to seek injunctive relief, as the alleged future injury was too speculative. On the merits, the court found that the existence of an adequate post-deprivation remedy under Missouri law precluded the procedural due process claim. The court further held that the complaint did not plausibly allege a substantive due process violation, nor was there an unreasonable seizure under the Fourth Amendment, as the euthanasia was performed with the owner’s consent. The district court’s judgment was affirmed, except that the injunctive relief claim was dismissed without prejudice. View "The Iowa Farm Sanctuary v. Univ. of MO Vet Health Center" on Justia Law

Dale Gourneau worked as a carman for BNSF Railway Company, inspecting railroad cars to ensure compliance with safety regulations. In January 2020, BNSF terminated Gourneau following a disciplinary proceeding. Gourneau subsequently filed a whistleblower complaint with the Occupational Safety and Health Administration of the Department of Labor, alleging that BNSF unlawfully retaliated against him for reporting hazardous safety conditions in good faith.After administrative proceedings, an Administrative Law Judge found in favor of Gourneau, ordering reinstatement, backpay, compensatory damages, punitive damages, and attorneys’ fees. The Administrative Review Board affirmed the ALJ’s decision and order. BNSF petitioned the United States Court of Appeals for the Eighth Circuit for review, arguing that the Department’s process violated the company’s Seventh Amendment right to a jury trial.The United States Court of Appeals for the Eighth Circuit examined whether the administrative adjudication of Gourneau’s claims for legal remedies—liability, backpay, compensatory damages, and punitive damages—implicated the Seventh Amendment. The court determined that Gourneau’s claim was analogous to a common-law wrongful discharge action and sounded basically in tort, entitling BNSF to a jury trial. The court rejected arguments that the “public rights” exception allowed agency adjudication without a jury trial, finding that Gourneau’s claim was a standalone suit between private parties and not so integrated into a regulatory scheme as to justify agency resolution without a jury. The court concluded that Congress may not avoid a jury trial by assigning such disputes to an agency.The Eighth Circuit granted the petition for review, vacated the order of the Administrative Review Board, and remanded the case for further proceedings consistent with its opinion, holding that BNSF is entitled to a jury trial on Gourneau’s claims for legal remedies before any equitable claims are adjudicated. View "BNSF Railway Co. v. Dept. of Labor" on Justia Law

During the aftermath of George Floyd’s death, Tosun Fitil participated in a protest in Omaha, Nebraska, holding a sign to honor Floyd and Zachary Bear Heels. The Omaha Police Department deployed numerous officers, including SWAT member Justyn Riley. When unrest escalated, officers responded to thrown water bottles with pepper balls, which further intensified the confrontation. Amidst this, Fitil stepped forward to confront the officers. As rocks were thrown toward Officer Riley, he threw a flashbang device that detonated near Fitil’s head, causing serious injuries including burns, ruptured eardrums, concussion, and lasting hearing and balance problems.Fitil filed suit in the United States District Court for the District of Nebraska, asserting claims under 42 U.S.C. § 1983 for violations of his First Amendment rights (free speech and assembly) and the Fourth Amendment (excessive force). At summary judgment, the district court denied qualified immunity for both claims, finding that factual disputes remained and a reasonable jury could conclude Riley had effectuated a seizure by deploying the flashbang.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court determined that it had jurisdiction only to address the denial of qualified immunity on the Fourth Amendment claim, not the First Amendment claim, because the district court had not explicitly ruled on qualified immunity for the latter. The Eighth Circuit held that the law was not clearly established regarding whether the use of a flashbang in an open area to disperse protestors amounted to a seizure under the Fourth Amendment. Therefore, it reversed the district court’s denial of qualified immunity on the excessive force claim, dismissed the remainder of the appeal for lack of jurisdiction, and remanded for further proceedings. View "Fitil v. Riley" on Justia Law

An organization based in Virginia requested access to Minnesota’s Registered Voter List under a federal statute, asserting it was entitled to the records despite Minnesota’s exemption from the law. Minnesota denied the request, citing its exemption as a state with continuous election-day registration since August 1, 1994. The organization also sought the information under a Minnesota statute, but was again denied because no Minnesota-registered voter joined the request. The organization acknowledged it could obtain the information by recruiting a Minnesota voter but did not do so. It then filed suit, claiming Minnesota’s exemption from the federal disclosure requirement was unconstitutional, alleging informational injury and other adverse consequences.The United States District Court for the District of Minnesota reviewed the case. Minnesota moved to dismiss, and the United States intervened to defend the statute’s constitutionality. The district court dismissed the organization’s claim on the merits, concluding that the “equal sovereignty” principle does not apply to Congress’s authority under the Elections Clause.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether the organization had Article III standing. The court reviewed standing de novo and focused on whether the plaintiff had suffered a concrete injury in fact. The court held that a purely informational injury does not satisfy Article III’s requirements and found the plaintiff’s alleged downstream consequences insufficient, as they lacked a nexus to the interests Congress sought to protect. The court concluded the plaintiff failed to allege a concrete injury and therefore lacked standing.The Eighth Circuit vacated the district court’s judgment and remanded with instructions to dismiss the complaint for lack of jurisdiction. View "Public Interest Legal Foundation, Inc. v. Simon" on Justia Law

A business specializing in adult products sought to open a store in downtown Fargo, North Dakota, in a zone designated for mixed-use development. The proposed store intended to sell items such as lingerie and sexual wellness products, but not sexually explicit media like books or DVDs. To proceed, the business’s landlord applied for a change-of-use permit to allow retail sales and service at the location. The City of Fargo, through its Director of Planning and Development, denied the application, concluding that the business constituted an "Adult Bookstore" as defined by the city’s municipal code, which prohibited such establishments in the downtown zone. The city’s decision was upheld by both the Fargo Board of Adjustment and the Board of City Commissioners.Following these administrative decisions, the business filed suit in the United States District Court for the District of North Dakota, raising constitutional claims including violations of the First Amendment, the imposition of a prior restraint, denial of procedural due process, and unconstitutional vagueness in the city’s code. The business also challenged the Commissioners’ decision under state law, arguing it was arbitrary and capricious. While the lawsuit was pending, Fargo amended its code to explicitly prohibit “Sexual Device Shops” in the relevant zone.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the dismissal of all federal claims, holding that the business’s planned activities were not protected expressive conduct under the First Amendment, the permit process was not a prior restraint, and the business received adequate procedural process. The court also found the city’s ordinance was not unconstitutionally vague. However, the court determined that denying the permit as an “Adult Bookstore” was arbitrary and capricious under state law, reversed the dismissal of the state-law claim, and remanded for further proceedings regarding possible relief. View "Romantix-Fargo, Inc. v. City of Fargo" on Justia Law

Law enforcement officers responded to a report of a possible drug overdose at a residence in Onamia, Minnesota. Upon arrival, they found Jeremy Burton unconscious with drug paraphernalia present. After being revived with Narcan, officers noticed a handgun magazine protruding from Burton’s shorts. During the encounter, another individual tried to prevent officers from retrieving the firearm, but it was ultimately secured. Burton was transported to a hospital and found to have multiple controlled substances in his system. He was charged as a felon in possession of a firearm, with a sentencing enhancement under the Armed Career Criminal Act due to prior convictions.The United States District Court for the District of Minnesota presided over Burton’s trial. The court granted the government’s motion in limine to exclude expert testimony from a pharmacologist regarding the effects of drugs on Burton’s mental state, finding voluntary intoxication was not a defense to the charge. At trial, Burton testified that someone had planted the gun on him while he was unconscious, but the jury found him guilty. The district court sentenced him to 240 months of imprisonment, which was a downward variance from the applicable guidelines range. Burton appealed, arguing error in excluding the expert testimony and that his sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary ruling for abuse of discretion and, where constitutional issues were implicated, de novo. The appellate court held that voluntary intoxication is not a defense to being a felon in possession of a firearm, and thus the exclusion of the expert testimony was proper. The court also found that the sentence was substantively reasonable, given the district court’s consideration of both aggravating and mitigating factors. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Burton" on Justia Law

A police officer in Jonesboro, Arkansas, encountered Jayden Prunty standing in the street holding a plastic bag late at night in an area known for high crime. The officer, identifying himself and stating he was conducting drug interdiction, approached Prunty, claimed to smell marijuana, and repeatedly told him to “come here.” Prunty denied the accusation, became visibly nervous, and walked away. When Prunty began to run, the officer caught him and pushed him to the ground. During the ensuing struggle, a firearm discharged, and the officer was shot in the leg. The officer then drew his own weapon and fatally shot Prunty. Prunty was later pronounced dead at the hospital.The administrators of Prunty’s estate brought a civil rights action in the United States District Court for the Eastern District of Arkansas under 42 U.S.C. § 1983, alleging violations of the Fourth and Fourteenth Amendments. The district court granted summary judgment in favor of the officer, finding that the officer’s actions did not violate clearly established rights and that he was entitled to qualified immunity. The court determined that the officer had reasonable suspicion to detain Prunty based on the odor of marijuana, Prunty’s nervous behavior, and attempted flight, and that his use of force was objectively reasonable under the circumstances.Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the officer did not seize Prunty until applying physical force, at which point reasonable suspicion existed. The court also found the officer’s use of force, including the takedown and subsequent use of deadly force after being shot, was objectively reasonable. Accordingly, the officer was entitled to qualified immunity, and the grant of summary judgment was affirmed. View "Prunty v. Obregon" on Justia Law