Justia Constitutional Law Opinion Summaries

Three organizations, Inclusive Louisiana, Mount Triumph Baptist Church, and RISE St. James, sued St. James Parish, the Parish Council, and the Parish Planning Commission, alleging violations of their constitutional and statutory civil rights. They claimed that the Parish discriminated against them by directing hazardous industrial development towards majority-Black districts and Black churches, where their members and congregants live. They also argued that the Parish's actions desecrated and restricted access to cemeteries of their enslaved ancestors.The United States District Court for the Eastern District of Louisiana dismissed all claims. It held that the plaintiffs lacked standing for some claims and that other claims were time-barred, as they were based on the Parish's 2014 Land Use Plan. The court also dismissed claims related to religious injuries, stating that the injuries were not traceable to the Parish's actions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court erred in dismissing the claims as time-barred, noting that the plaintiffs alleged ongoing discriminatory practices, not just a single incident. The court also found that the plaintiffs had standing to sue for property injuries and health-related injuries. Additionally, the court held that the plaintiffs had standing to pursue claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Louisiana Constitution, as their alleged injuries were traceable to the Parish's conduct.The Fifth Circuit reversed the district court's dismissal of the claims and remanded the case for further proceedings. The court emphasized that the plaintiffs had sufficiently alleged ongoing discriminatory practices and injuries that were fairly traceable to the Parish's actions. View "Inclusive Louisiana v. St. James Parish" on Justia Law

A Texas county judge, Brian Umphress, challenged the State Commission on Judicial Conduct's application of Canon 4A(1) of the Texas Code of Judicial Conduct, which requires judges to conduct their extra-judicial activities in a manner that does not call into question their impartiality. Umphress, who refuses to perform same-sex marriages for religious reasons while continuing to perform opposite-sex marriages, argued that applying the Canon to his refusal is unconstitutional. This challenge arose after a similar situation involving Justice of the Peace Dianne Hensley, who was publicly warned by the Commission for her refusal to perform same-sex weddings.The United States District Court for the Northern District of Texas dismissed Umphress's case for lack of subject matter jurisdiction, holding that he lacked standing and that his claims were not ripe. The court also noted that even if it had jurisdiction, it would have abstained under the Pullman doctrine, which allows federal courts to defer to state courts on issues of unclear state law.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that Umphress had standing and that his claims were ripe for review. The court held that Umphress had demonstrated an imminent injury in fact, as his intended conduct was arguably proscribed by Canon 4A(1) and there was a substantial threat of future enforcement by the Commission. The court also determined that the case was not moot despite the Commission's rescission of its warning against Hensley, as the Commission had not disavowed future enforcement against Umphress.The Fifth Circuit reversed the district court's dismissal and declined to abstain under Pullman, noting that state court litigation was unlikely to resolve the crucial threshold question of Texas law. Instead, the court certified the question to the Supreme Court of Texas, asking whether Canon 4A(1) prohibits judges from publicly refusing to perform same-sex weddings for moral or religious reasons while continuing to perform opposite-sex weddings. View "Umphress v. Hall" on Justia Law

In 2010, Thomas Steven Sanders kidnapped and murdered a twelve-year-old girl, L.R., after killing her mother, Suellen Roberts. Sanders was apprehended and confessed to the crimes. He was prosecuted under federal law and, in 2014, a jury in the Western District of Louisiana convicted him of kidnapping and murder, sentencing him to death on both counts.Sanders appealed, raising numerous challenges to his convictions and sentences. The United States Court of Appeals for the Fifth Circuit reviewed the case. Sanders argued that the district court erred by not ordering a competency hearing, denying his motion to suppress statements made during interrogation, and violating the Double Jeopardy Clause by imposing two sentences for one act. He also challenged the jury selection process, the death-qualification of the jury, the sufficiency of the evidence, the admission of victim impact testimony, prosecutorial misconduct, and the constitutionality of the Federal Death Penalty Act (FDPA).The Fifth Circuit found that the district court did not abuse its discretion in failing to order a competency hearing or in denying the motion to suppress. However, the court agreed with Sanders that his conviction and sentence under 18 U.S.C. § 924(c) and (j) violated the Double Jeopardy Clause, as Congress did not authorize cumulative punishment for violations of § 1201(a) and § 924(j). Consequently, the court vacated Sanders’s conviction and sentence under Count Two of the indictment.The court rejected Sanders’s other arguments, including those related to jury selection, death-qualification, sufficiency of the evidence, victim impact testimony, prosecutorial misconduct, and the constitutionality of the FDPA. The court concluded that Sanders’s sentences were not imposed under the influence of passion, prejudice, or any other arbitrary factor and that the cumulative-error doctrine did not apply. The Fifth Circuit affirmed the district court’s judgment in all other respects. View "United States v. Sanders" on Justia Law

Jeremy Jason Schnur, previously convicted of multiple felonies including aggravated battery, burglary, and robbery, was indicted for unlawfully possessing a firearm as a convicted felon under 18 U.S.C. § 922(g)(1). Schnur was apprehended by law enforcement at the Hard Rock Casino in Biloxi, Mississippi, where he was found in possession of a loaded Canik 9mm semiautomatic pistol. Schnur moved to dismiss the indictment, arguing that § 922(g)(1) violated his Second Amendment rights as applied to him. The district court denied his motion, and after a bench trial, found him guilty.The United States District Court for the Southern District of Mississippi denied Schnur's motion to dismiss the indictment. Schnur waived his right to a jury trial and proceeded to a bench trial based on stipulations regarding his possession of the firearm and his felony convictions. The district court found Schnur guilty and sentenced him to seventy-eight months of imprisonment, three years of supervised release, and a $3,000 fine. Schnur appealed the decision, maintaining his as-applied Second Amendment challenge.The United States Court of Appeals for the Fifth Circuit reviewed the constitutionality of § 922(g)(1) de novo. The court held that the Second Amendment's plain text covers Schnur's conduct, but the government demonstrated that disarming Schnur is consistent with the Nation's historical tradition of firearm regulation. The court cited precedents indicating that individuals with violent criminal histories, like Schnur's aggravated battery conviction, can be constitutionally disarmed. The court also referenced Schnur's robbery and burglary convictions, which further supported the constitutionality of § 922(g)(1) as applied to him. The Fifth Circuit affirmed the district court's judgment and upheld the constitutionality of § 922(g)(1) in Schnur's case. View "United States v. Schnur" on Justia Law

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity. View "McClain v. Delgado" on Justia Law

Jessie Hoffman was convicted of first-degree murder for the kidnapping, rape, and murder of Mary "Molly" Elliot in 1998 and sentenced to death. After exhausting all state and federal post-conviction remedies, his execution was delayed due to the unavailability of lethal injection drugs. In 2024, Louisiana adopted nitrogen hypoxia as a method of execution. Hoffman challenged this new method, arguing it violated the Eighth Amendment.The United States District Court for the Middle District of Louisiana granted Hoffman's motion for a preliminary injunction, preventing his execution by nitrogen hypoxia. The court concluded that Hoffman had exhausted his administrative remedies under the Prison Litigation Reform Act (PLRA) and found that nitrogen hypoxia posed a substantial risk of superadding pain and suffering. The court suggested that execution by firing squad would be a reasonable alternative that would reduce the risk of severe pain.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that Hoffman had indeed exhausted his administrative remedies. However, it disagreed with the district court's conclusion regarding the Eighth Amendment. The Fifth Circuit held that nitrogen hypoxia is painless and that the district court erred in suggesting that the Eighth Amendment requires a more painful method of execution, such as a firing squad. The court emphasized that the Eighth Amendment does not guarantee a painless death and that Hoffman failed to show that nitrogen hypoxia presented a substantial risk of severe pain compared to other methods.The Fifth Circuit vacated the preliminary injunction, allowing Louisiana to proceed with Hoffman's execution by nitrogen hypoxia. View "Hoffman v. Westcott" on Justia Law

John Doe was found not guilty by reason of insanity (NGRI) for an offense in Arlington County, Virginia, in 2014 and was committed to a state hospital in 2015. After his first job offer was rescinded due to his arrest and commitment, he changed his legal name and moved to Texas in 2020. In 2022, he was arrested based on a Virginia bench warrant for failure to appear but was released when Virginia declined extradition. In 2023, Doe received a job offer from Charter Communications, pending a background check by HireRight. HireRight reported that Doe had a criminal record and an active warrant, leading Charter to rescind the job offer.Doe filed a pro se civil rights action under 42 U.S.C. § 1983 against Charter, HireRight, and Paul Ferguson, Clerk of the Circuit Court of Arlington County, Virginia, alleging violations of the Fair Credit Reporting Act (FCRA), the Americans with Disabilities Act (ADA), and the Fourteenth Amendment. The United States District Court for the Western District of Texas dismissed Doe’s claims, finding that his FCRA claim against Charter was barred as there is no private right of action against users of consumer reports, and his Fourteenth Amendment claim against Ferguson was duplicative of a previously litigated case in Virginia.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court agreed that Doe’s constitutional claims against Ferguson were duplicative and therefore frivolous. It also upheld the dismissal of Doe’s FCRA claim against Charter, interpreting 15 U.S.C. § 1681m(h)(8) to bar private enforcement of section 1681m in its entirety. The court found that Doe’s FCRA claim against HireRight and ADA claim against Charter were based on the allegation that the warrant was unlawful or inaccurate, which had already been addressed in the Virginia litigation. View "Doe v. Charter Communications" on Justia Law

In January 2023, law enforcement executed a search warrant at Juan David Cisneros's residence, resulting from a narcotics investigation. They found ammunition in his bedroom but no drugs or firearms attributable to him. Cisneros admitted to using the ammunition previously but claimed his mother-in-law purchased it. He was charged with possessing ammunition as a convicted felon under 18 U.S.C. § 922(g)(1).The United States District Court for the Southern District of Texas denied Cisneros's motion to dismiss the indictment, which argued that § 922(g)(1) was unconstitutional under the Second Amendment and exceeded Congress's power under the Commerce Clause. Cisneros pleaded guilty but reserved the right to appeal on Second Amendment grounds. The court adopted the Presentence Investigation Report, which included a four-level enhancement for possessing ammunition in connection with drug trafficking, and sentenced him to ninety-six months in prison.The United States Court of Appeals for the Fifth Circuit reviewed the case. Cisneros's facial challenge to § 922(g)(1) was foreclosed by precedent, and his as-applied challenge failed under plain error review. The court affirmed his conviction, finding no clear or obvious error in the application of § 922(g)(1) under the Second Amendment.However, the court found that the district court plainly erred in applying the sentencing enhancement under U.S.S.G. § 2K2.1(b)(6)(B) for possessing ammunition in connection with another felony offense. The court noted that there was no evidence the ammunition facilitated drug trafficking, as required by precedent. This error affected Cisneros's substantial rights, as it likely resulted in a longer sentence. Consequently, the Fifth Circuit vacated Cisneros's sentence and remanded for resentencing. View "United States v. Cisneros" on Justia Law

Space Exploration Technologies Corp. (SpaceX) operates a space launch business and a global satellite-based internet service called Starlink. In June 2022, a group of SpaceX employees sent an open letter demanding certain actions from the company and solicited support through a survey. SpaceX discharged four employees involved in the letter's distribution for violating company policies. Additional employees were later discharged for lying during a leak investigation and for unrelated performance issues. These employees filed charges with the National Labor Relations Board (NLRB) in November 2022, alleging violations of the National Labor Relations Act.The NLRB Regional Director found merit in the claims and issued an order consolidating the employees' cases with a hearing set for March 2024. SpaceX sued the NLRB in the Southern District of Texas (SDTX) in January 2024, challenging the NLRB's structure as unconstitutional and seeking declaratory and injunctive relief. The NLRB moved to transfer the case to the Central District of California (CDCA), arguing improper venue. The SDTX granted the transfer motion in February 2024. SpaceX petitioned for an emergency writ of mandamus to vacate the transfer order, which was initially stayed but later denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. SpaceX argued that the district court effectively denied its motion for a preliminary injunction by failing to rule on it by May 2, 2024. The Fifth Circuit found that SpaceX did not demonstrate the "serious, perhaps irreparable, consequence" required for an immediate appeal. The court noted that participating in the administrative proceeding did not constitute irreparable harm and that the district court did not act unreasonably in waiting to resolve procedural challenges. Consequently, the Fifth Circuit dismissed SpaceX's appeal for lack of subject-matter jurisdiction. View "Space Exploration Technologies Corp. v. National Labor Relations Board" on Justia Law

Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law