Justia Constitutional Law Opinion Summaries

The plaintiffs in this case are homeowners and rental-property supervisors in New Orleans who challenged the City’s regulations governing short-term rentals (STRs), defined as lodging offered for less than thirty days. The City’s regulatory scheme requires permits for both owners and operators of STRs, restricts eligibility to “natural persons,” mandates that operators reside at the property, and imposes specific advertising requirements. The regulations were enacted in response to concerns about neighborhood disruption and loss of affordable housing attributed to the proliferation of STRs. Plaintiffs argued that these regulations violated various constitutional provisions, including the Due Process and Equal Protection Clauses, the First Amendment, and the dormant Commerce Clause.The United States District Court for the Eastern District of Louisiana granted summary judgment largely in favor of the City, upholding the constitutionality of most aspects of the STR regulations. The district court found that the City had authority under state law to regulate STRs and rejected the plaintiffs’ due process and equal protection claims, except for one provision not at issue on appeal. The court also upheld the advertising restrictions and the operator residency requirement, interpreting the latter as not requiring permanent residency.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed in part, reversed in part, and remanded. The Fifth Circuit held that the City’s prohibition on business entities obtaining owner or operator permits violated the Equal Protection Clause, as the distinction was arbitrary and not rationally related to a legitimate government interest. The court also found that the requirement that each STR advertisement list only one dwelling unit violated the First Amendment. However, the court upheld the City’s authority to regulate STRs, the due process analysis, most advertising restrictions, and interpreted the operator residency requirement as not violating the dormant Commerce Clause. View "Hignell-Stark v. City of New Orleans" on Justia Law

Juan Alaniz was convicted of possessing a firearm and ammunition as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). Alaniz had prior state felony convictions for illegally possessing a controlled substance and for burglary. He challenged his conviction on constitutional grounds, arguing that the statute exceeded Congress’s authority under the Commerce Clause, violated the Second Amendment on its face, and violated the Second Amendment as applied to him.The United States District Court for the Southern District of Texas reviewed the case and entered a conviction against Alaniz. On appeal, Alaniz raised the same constitutional arguments before the United States Court of Appeals for the Fifth Circuit. He specifically argued that only his controlled substance conviction should be considered as the predicate for his § 922(g)(1) conviction, and that his burglary conviction should not be relevant to the constitutional analysis.The United States Court of Appeals for the Fifth Circuit rejected Alaniz’s Commerce Clause and facial Second Amendment challenges, citing circuit precedent. The court reviewed his as-applied Second Amendment challenge de novo and held that the government may consider Alaniz’s entire criminal record, including his burglary conviction, when evaluating the constitutionality of § 922(g)(1) as applied to him. The court found that founding-era laws support the constitutionality of disarming individuals convicted of burglary. Therefore, Alaniz’s as-applied challenge was foreclosed by circuit precedent, and the Fifth Circuit affirmed the judgment of the district court. View "United States v. Alaniz" on Justia Law

An inmate at the Louisiana State Penitentiary participated in the Angola Prison Rodeo from 1996 to 2019, selling leather belts and earning approximately $80,000. He alleged that prison officials confiscated about $16,000 of his earnings, claiming the deductions were for taxes, commissions, and maintenance fees. The inmate filed a grievance through the prison’s administrative process, arguing that the deductions were unauthorized and that he was denied a due process hearing regarding the seizure of his property. The prison denied his grievance, explaining the deductions, and the inmate exhausted his administrative remedies. He then sought relief in Louisiana state court through a petition for writ of mandamus, which remained unresolved for over a year.Subsequently, the inmate filed a pro se complaint in the United States District Court for the Middle District of Louisiana under 42 U.S.C. § 1983, alleging that various prison officials conspired to deny him due process in connection with the confiscation of his property. The defendants moved to dismiss the complaint, asserting qualified immunity and failure to state a claim. A magistrate judge recommended dismissing any standalone claims regarding the denial of the prison grievance but allowed the conspiracy and due process claims to proceed. The district court adopted this recommendation, and the defendants appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the defendants were entitled to qualified immunity. The court found that the inmate’s complaint did not adequately allege a pre-deprivation due process claim and that, at the time of the alleged conduct, it was not clearly established that the inmate had a protected property interest in the proceeds from the sale of crafts made and sold under prison auspices. The Fifth Circuit reversed the district court’s denial of qualified immunity and remanded the case for further proceedings. View "Savage v. Westcott" on Justia Law

Several development groups entered into a public improvement contract with a Texas city, purchasing over 60 acres of land, much of it in a flood zone. The developers received a variance from the city, exempting them from obtaining a federal floodplain permit (CLOMR), and invested significant funds in developing the property, including constructing a bridge. In 2018, the parties executed updated agreements, including a Master Development Agreement (MDA), which required certain conditions to be met within five years or the contract would automatically terminate, ending the city’s reimbursement obligations. As the deadline approached, the city informed the developers that they would now need to obtain the previously waived CLOMR, citing a later-enacted ordinance. Unable to comply in time, the developers sought an extension, which the city council denied, resulting in termination of the MDA.The developers sued in Texas state court, alleging the city’s actions constituted an unconstitutional taking under federal and state law, and also brought claims for breach of contract and violations of the Texas Vested Rights Statute. The city removed the case to the United States District Court for the Northern District of Texas and moved to dismiss. The district court dismissed the federal takings and declaratory judgment claims, finding the developers had not sufficiently alleged that the city acted in its sovereign rather than commercial capacity, and remanded the remaining state-law claims to state court.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed. The court held that the developers’ allegations arose from a contractual dispute, not a sovereign act by the city, and thus did not state a plausible takings claim under the Fifth Amendment. The court also found no abuse of discretion in the district court’s decision to dismiss the declaratory judgment claim, as the core issues would be resolved in the remanded state court action. View "Mesquite Asset Recovery Grp v. City of Mesquite" on Justia Law

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

A man incarcerated in Texas state prison was classified as a member of a security threat group and placed in administrative segregation, a form of solitary confinement, for sixteen years. The only way for him to return to the general prison population was to complete a gang renunciation program, which required him to renounce his gang affiliation and participate in an interview. During the interview, he was questioned by prison and law enforcement officials about criminal activities that occurred during his incarceration. He refused to answer questions that could incriminate him, after which his application to the renunciation program was terminated for failure to cooperate. He filed grievances challenging the process, but they were denied or dismissed.He then filed suit in the United States District Court for the Western District of Texas against several prison officials, alleging violations of his Fifth, First, and Fourteenth Amendment rights. The district court initially dismissed his claims, but the United States Court of Appeals for the Fifth Circuit vacated and remanded for further proceedings. After further litigation, including the appointment of counsel and discovery, the district court again granted summary judgment for the defendants, finding no constitutional violations and holding that the officials were entitled to qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s summary judgment. The court held that the officials were entitled to qualified immunity on the Fifth Amendment self-incrimination and First Amendment compelled speech claims because there was no clearly established law making their conduct unlawful in this context. Regarding the Fourteenth Amendment procedural due process claim, the court assumed a liberty interest but found that the periodic classification reviews provided by the prison satisfied due process requirements. The court affirmed summary judgment in favor of the defendants. View "Ballentine v. Broxton" on Justia Law

A group of drug manufacturers that participate in the federal Section 340B program challenged a Mississippi law, H.B. 728, which prohibits manufacturers from interfering with healthcare providers’ use of contract pharmacies to distribute discounted drugs to low-income and uninsured patients. The manufacturers argued that the law compels them to transfer drugs at a discount to private, for-profit pharmacies and expands their obligations under federal law, potentially enabling improper resale of discounted drugs. They sought a preliminary injunction to prevent the law from taking effect, claiming it constituted an unconstitutional taking and was preempted by federal law.The United States District Court for the Southern District of Mississippi denied the manufacturers’ motion for a preliminary injunction. The court found that the manufacturers had not demonstrated a substantial likelihood of success on the merits of their takings or preemption claims, and thus were not entitled to preliminary injunctive relief. The manufacturers appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of a preliminary injunction for abuse of discretion, applying clear error review to factual findings and de novo review to legal conclusions. The Fifth Circuit affirmed the district court’s decision, holding that the manufacturers had not shown a substantial likelihood of success on their claims. The court concluded that H.B. 728 did not effectuate a physical or regulatory taking, nor was it preempted by federal law under either field or conflict preemption theories. The court emphasized that, on the record presented, the manufacturers had not met their burden to justify the extraordinary remedy of a preliminary injunction. The district court’s denial of injunctive relief was therefore affirmed. View "AbbVie v. Fitch" on Justia Law

In early 2023, police responded to a disturbance at a residence in Odessa, Texas, where Deimon Nolan Simpson, who had recently been evicted, attempted to enter the house he believed was still his. After being blocked by the new tenant, Simpson retrieved a firearm from his car, entered through a window, and shot the tenant’s dog. Simpson, a convicted felon with prior convictions including possession of a controlled substance, evading arrest or detention with a vehicle, and being a felon in possession of a firearm, was charged with violating 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms.The United States District Court for the Western District of Texas denied Simpson’s motion to dismiss the indictment. Simpson then pleaded guilty, admitting to the relevant prior felony convictions. On appeal, Simpson challenged the constitutionality of § 922(g)(1) as applied to him under the Second Amendment, and also raised facial and Commerce Clause challenges, which he acknowledged were foreclosed by existing Fifth Circuit precedent.The United States Court of Appeals for the Fifth Circuit reviewed the constitutional challenge de novo. The court held that the felon-in-possession statute is constitutional as applied to Simpson because his predicate felony—evading arrest or detention with a vehicle—involved violent conduct, and there is a historical tradition of disarming individuals who pose a credible threat of violence. The court found that both historical and contemporary laws support permanent disarmament in such circumstances, and that the statute does not broadly restrict firearm rights but targets those with demonstrated threats to public safety. Accordingly, the Fifth Circuit affirmed the district court’s denial of the motion to dismiss. View "USA v. Simpson" on Justia Law

An ordained minister served as Executive Director of a regional Baptist convention, where he was responsible for implementing a joint ministry agreement with a national Baptist mission board. Disagreements arose between the minister and the mission board regarding the execution of their shared evangelical objectives, particularly concerning missionary selection, funding, and work requirements. The mission board expressed dissatisfaction with the minister’s leadership and gave notice to terminate the partnership agreement. Subsequently, the regional convention’s board unanimously voted to terminate the minister’s employment, citing concerns about his leadership and spiritual disposition. After his termination, the minister publicly criticized the mission board and its president, which led to further actions by the board, including security measures and the posting of a no-entry photograph of the minister at its headquarters.The minister filed suit in Mississippi state court against the mission board, alleging tortious interference with business relationships, defamation, and intentional infliction of emotional distress. The mission board removed the case to the United States District Court for the Northern District of Mississippi and moved to dismiss, arguing that the church autonomy doctrine barred the claims. The district court initially denied the motion to dismiss but later granted summary judgment for the mission board, concluding that the First Amendment’s church autonomy doctrine precluded adjudication of the minister’s claims. On appeal, the United States Court of Appeals for the Fifth Circuit previously reversed and remanded, finding it premature to apply the doctrine at an early stage. After further discovery, the district court again granted summary judgment for the mission board on church autonomy grounds.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s summary judgment. The court held that the church autonomy doctrine, rooted in the First Amendment, bars civil courts from adjudicating employment-related claims that would require inquiry into religious doctrine, internal management, or ministerial decisions. The court concluded that all of the minister’s claims were precluded by this doctrine, regardless of the organizational structure of the Baptist entities involved. View "McRaney v. N Amer Mission Bd" on Justia Law

The defendant pleaded guilty to possessing a firearm after a felony conviction, in violation of 18 U.S.C. § 922(g)(1). The presentence investigation report determined that the defendant’s offense level was increased due to two prior Louisiana felony convictions: aggravated battery and distribution of cocaine. The report also applied enhancements for a stolen firearm and use of the firearm in connection with another felony. The defendant objected to these enhancements and the classification of his prior aggravated battery conviction as a “crime of violence.” The district court overruled the objections, adopted the report’s findings, and sentenced the defendant to 120 months in prison, the statutory maximum.On appeal to the United States Court of Appeals for the Fifth Circuit, the defendant argued that § 922(g)(1) is unconstitutional under the Second Amendment, relying on New York State Rifle & Pistol Ass’n, Inc. v. Bruen, and that the district court erred in treating his prior aggravated battery conviction as a crime of violence for sentencing purposes. The defendant had not raised these arguments in the district court, so the Fifth Circuit reviewed for plain error.The Fifth Circuit held that, under existing precedent, a conviction under § 922(g)(1) does not constitute plain error, and there has been no development in the law to suggest otherwise. Regarding the sentencing enhancement, the court found that the defendant failed to show a “realistic probability” that Louisiana courts would uphold an aggravated battery conviction based on reckless or negligent conduct, as required to demonstrate clear or obvious error under the categorical approach. The court concluded that neither the conviction nor the sentence was reversible under plain error review and affirmed the judgment of the district court. View "USA v. Sereal" on Justia Law