Justia Constitutional Law Opinion Summaries

In this case, the petitioner was convicted of first-degree murder and robbery for an offense committed at age 17, resulting in a mandatory sentence of life imprisonment without parole under Massachusetts law. Decades later, following developments in constitutional law, the Massachusetts Supreme Judicial Court held that life-without-parole sentences for juveniles were unconstitutional and ordered that such sentences be modified to life with the possibility of parole. As a result, the petitioner’s sentence was changed; he became parole eligible, was granted parole, and was released.After this modification, the petitioner sought to file a second habeas corpus petition in federal court under 28 U.S.C. § 2254. The United States District Court for the District of Massachusetts ruled that this petition was “second or successive” under 28 U.S.C. § 2244(b) and thus subject to its “gatekeeping” requirements, concluding that the addition of parole eligibility did not constitute a new judgment for purposes of federal habeas law.On appeal, the United States Court of Appeals for the First Circuit reviewed de novo whether the sentence modification constituted a new judgment. The court held that the change from life without parole to life with parole eligibility was a material change, making the sentence a new judgment under federal law. The court reasoned that, because the petitioner’s current custody was authorized by this new judgment, his second-in-time habeas petition did not trigger the restrictions of § 2244(b).Therefore, the First Circuit reversed the district court’s decision, holding that the petitioner need not obtain pre-authorization to file his habeas petition, and remanded for further proceedings. View "Donovan v. Massachusetts Parole Board" on Justia Law

Two long-time residents of Nashua, New Hampshire, sought to fly various flags on a designated "Citizen Flag Pole" located at City Hall Plaza. The City had previously allowed private citizens and groups to fly flags representing diverse causes and cultural events on this pole, with minimal oversight and no substantive review of flag content. After one of the plaintiffs flew a "Save Women's Sports" flag, the City received complaints, revoked permission, and removed the flag, stating that it was discriminatory toward the transgender community. Subsequently, the City adopted a written policy in 2022 asserting that the flagpole’s use constituted government speech and reserving the right to deny flags not aligned with City policies.The plaintiffs filed suit in the United States District Court for the District of New Hampshire, alleging violations of the First and Fourteenth Amendments and seeking a preliminary injunction to prevent viewpoint-based denials of flag applications. Before the City filed its opposition, it enacted a new policy to exercise exclusive government control over the flagpoles. The magistrate judge recommended denying the injunction, finding the flag program to be government speech, and the district court adopted that recommendation and denied relief. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit reviewed the district court’s denial for abuse of discretion and legal conclusions de novo. Applying the government speech test from Shurtleff v. City of Boston, the court held that Nashua’s Citizen Flag Pole program was not government speech, but rather operated as a forum for private expression. Because Nashua conceded that, absent a government speech determination, its actions constituted impermissible viewpoint discrimination, the First Circuit reversed the district court. The case was remanded with instructions to enter interim declaratory relief in favor of the plaintiffs. View "Scaer v. City of Nashua" on Justia Law

In the spring of 2020, three veterans residing at the Soldiers’ Home in Chelsea, Massachusetts, died after contracting COVID-19. The personal representatives of the veterans’ estates filed suit against several Massachusetts state officials responsible for the facility, alleging violations of the veterans’ substantive due process rights under the Fourteenth Amendment. The complaint asserted that the officials failed to protect residents from COVID-19 by not implementing adequate safety protocols and maintaining inhumane living conditions, including lack of sanitation, improper restraint of residents, and exposure to illegal drugs.The United States District Court for the District of Massachusetts reviewed the complaint after the defendants moved to dismiss, arguing that the plaintiffs failed to state a claim for a substantive due process violation and that the officials were entitled to qualified immunity. The District Court granted the motion to dismiss. It held that the plaintiffs had not sufficiently alleged individual involvement by any defendant in the purported misconduct regarding COVID-19, and failed to provide details showing how the named veterans were specifically harmed by the living conditions. The court also found no clearly established legal authority placing the officials on notice that their conduct would violate the veterans’ rights, thus concluding qualified immunity applied.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s judgment. The First Circuit held that the complaint did not plausibly allege that the defendants directly caused the harm suffered by the veterans, nor did it sufficiently invoke exceptions to that requirement. The Court also found that the plaintiffs had not demonstrated a violation of clearly established law and thus, the defendants were entitled to qualified immunity. Consequently, the dismissal of the complaint was affirmed. View "Terenzio v. Urena" on Justia Law

Congress enacted a law in 2025 that withholds Medicaid funding for one year from certain abortion providers that meet four criteria, which in effect covers most Planned Parenthood affiliates and two other organizations. The statute also withholds funding from subsidiaries, successors, clinics, and “affiliates” of such entities, even if those affiliates do not themselves meet all four criteria. Some Planned Parenthood entities qualified for defunding under the law (“Qualifying Members”), while others did not (“Non-Qualifying Members”), but the latter still risked losing funding due to the ambiguous “affiliate” provision. Concerned about the impact on their ability to provide healthcare, Planned Parenthood Federation of America, a Qualifying Member, and a Non-Qualifying Member sued to enjoin enforcement, alleging the law was an unconstitutional bill of attainder, imposed unconstitutional conditions on their right of association, and violated equal protection.The United States District Court for the District of Massachusetts granted a temporary restraining order and then preliminary injunctions, finding that the plaintiffs were likely to succeed on all three claims. The court reasoned that the law punished Planned Parenthood in violation of the Bill of Attainder Clause, impermissibly conditioned Medicaid funding on disassociation from other affiliates in violation of the First Amendment, and failed equal protection review because it targeted Planned Parenthood for its associations. The government appealed these orders.The United States Court of Appeals for the First Circuit vacated the district court’s orders. The court held that the statute did not inflict punishment as understood in bill of attainder case law, but instead established new conditions prospectively on Medicaid funding. The court also held that the “affiliate” provision is best read to cover only entities under common corporate control, avoiding constitutional problems, and thus does not burden associational rights. Finally, the court found that the law is subject only to rational basis review and is rationally related to Congress’s objectives. The preliminary injunctions were vacated and the case remanded. View "Planned Parenthood Federation of America, Inc. v. Kennedy" on Justia Law

In March 1997, James Garrey was involved in a fatal altercation at a bar in Franklin, Massachusetts, where he stabbed and killed Corey Skog following a dispute. Garrey, who is white, was later convicted of first-degree murder by a Massachusetts jury and sentenced to life imprisonment. During jury selection, the prosecution exercised a peremptory strike to remove a minority-race juror, Juror 6-7. Garrey objected, arguing the strike was improper and motivated by race, referencing Batson v. Kentucky and Powers v. Ohio. The trial judge allowed the strike after the prosecutor cited the juror’s occupation as a guidance counselor as the reason, not her race.Garrey appealed his conviction to the Massachusetts Supreme Judicial Court (SJC), asserting that the trial judge erred by accepting the prosecutor’s justification and by referencing the lack of minority participants in the trial. The SJC affirmed the conviction, finding the prosecutor’s explanation sufficient and not pretextual, and that the trial judge did not improperly rely on racial considerations. Garrey’s subsequent motions for a new trial in state court were denied.He then petitioned the United States District Court for the District of Massachusetts for habeas corpus relief under 28 U.S.C. § 2254, alleging Batson and Powers errors and unreasonable factual findings by the SJC. The District Court denied relief, concluding the SJC’s application of federal law and findings were not unreasonable.On appeal, the United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the District Court. The First Circuit held that the SJC did not unreasonably determine the facts or misapply clearly established federal law under Batson or Powers, and found the prosecutor’s rationale and the trial court’s process constitutionally sufficient. The judgment denying habeas relief was affirmed. View "Garrey v. Kelly" on Justia Law

The plaintiff was an employee of the Puerto Rico Aqueduct and Sewer Authority and a former member of the relevant labor union. In 2016, he attempted to resign from the union and objected to the continued deduction of union dues from his wages, arguing that compelled dues for non-bargaining activities violated his First Amendment rights. The employer and union, acting under Puerto Rican law and the terms of a collective bargaining agreement, denied his requests, continued to deduct dues, and the plaintiff filed suit seeking declaratory, injunctive, and monetary relief.The United States District Court for the District of Puerto Rico presided over the initial proceedings. After the Supreme Court’s decision in Janus v. American Federation of State, County, and Municipal Employees overruled Abood v. Detroit Board of Education and invalidated mandatory union payments by nonmembers in the public sector, the employer and union ceased deducting dues from the plaintiff. The union then sought to deposit the amount withheld after his resignation, plus interest and nominal damages, with the court. The District Court ultimately granted the union’s request to deposit funds and dismissed the plaintiff’s claims as moot, reasoning that he had received all requested relief. The plaintiff’s subsequent motion to alter or amend the judgment was denied, with the court stating he was entitled to the deposited funds.The United States Court of Appeals for the First Circuit reviewed the appeal. The First Circuit found that the plaintiff was entitled to the funds deposited by the union, rejecting the argument that there was no judgment awarding him monetary relief. However, the court determined that the issue of whether the plaintiff could seek prevailing party attorneys’ fees—potentially affecting mootness—had not been fully addressed below. The First Circuit remanded the case to the District Court for further proceedings on that issue, while retaining jurisdiction over the appeal. View "Cruz v. UIA" on Justia Law

John Kenney, a resident of Florida, sought to obtain a retail cannabis license in Rhode Island as a social equity applicant. He argued that, as a recipient of a social equity cannabis license in the District of Columbia and someone with nonviolent marijuana convictions in Maryland and Nevada, he would otherwise qualify under Rhode Island’s Cannabis Act. Kenney challenged two provisions of the Act: the requirement that all license applicants must be Rhode Island residents or entities controlled by Rhode Island residents, and the definition of “social equity applicant,” which, according to Kenney, only recognizes nonviolent marijuana offenses eligible for expungement under Rhode Island law.After Kenney filed an amended complaint in the United States District Court for the District of Rhode Island, the defendants moved to dismiss for failure to state a claim and lack of subject matter jurisdiction. On February 6, 2025, the district court dismissed the case on ripeness grounds, reasoning that the Cannabis Control Commission had not yet promulgated final rules for retail cannabis licenses, and thus the court could not adjudicate the claims. The case was dismissed without prejudice, and Kenney appealed.The United States Court of Appeals for the First Circuit reviewed the appeal. Following the Commission’s issuance of final rules for retail cannabis licenses, effective May 1, 2025, the appellate court determined that the district court erred in dismissing the case for lack of ripeness. The First Circuit held that Kenney’s claims were not moot and that he had standing to pursue them. The court reversed the district court’s dismissal order and remanded the case for prompt consideration of the merits of Kenney’s constitutional challenges, instructing the district court to rule at least forty-five days before the Commission issues retail licenses. View "Kenney v. Rhode Island Cannabis Control Commission" on Justia Law

A cannabis entrepreneur based in California sought to challenge specific provisions of Rhode Island’s Cannabis Act, which governs the licensing of retail cannabis businesses. The Act requires applicants for all retail cannabis business licenses to be Rhode Island residents or entities with a principal place of business in Rhode Island and majority ownership by Rhode Island residents. It also establishes criteria for “social equity applicants,” reserving certain licenses for individuals with past marijuana-related convictions eligible for expungement or for those who have resided in disproportionately impacted areas. The plaintiff, not a Rhode Island resident, intended to apply for a license but alleged that these requirements violated the dormant Commerce Clause and the Equal Protection Clause.The United States District Court for the District of Rhode Island dismissed the plaintiff’s action without prejudice, concluding that her claims were not ripe for judicial review. The court cited several cases but provided no substantive analysis, noting that the Commission had yet to promulgate final rules and regulations for licensing and declining to speculate on the timeline for their adoption. This order was issued just before the public comment period on the proposed regulations closed.On appeal, the United States Court of Appeals for the First Circuit held that the district court erred in dismissing on ripeness grounds. The appellate court determined that the claims were ripe, not moot, and that the plaintiff had standing to bring the suit. The court found that the plaintiff faced imminent harm under the statutory requirements and that judicial intervention was warranted. The First Circuit reversed the district court’s dismissal and remanded the case for prompt consideration of the plaintiff’s constitutional claims, instructing the lower court to issue its rulings before the planned issuance of retail cannabis licenses. View "Jensen v. Rhode Island Cannabis Control Commission" on Justia Law

A group of Maine lobstermen challenged a state rule requiring all federally permitted lobster fishers to install electronic tracking devices on their vessels, which transmit GPS location data whenever the vessels are in the water. This rule was adopted by the Maine Department of Marine Resources (MDMR) to comply with an addendum to the Atlantic States Marine Fisheries Commission’s American Lobster Fishery Management Plan. The addendum aimed to reduce risks to North Atlantic right whales, improve fishery data, and support regulatory enforcement. The tracking devices must remain powered and transmit data at all times, including when vessels are docked or used for personal purposes.The plaintiffs filed suit in the United States District Court for the District of Maine, arguing that the MDMR Rule violated their rights under the Fourth Amendment, as well as equal protection and state administrative law. The district court granted the state’s motion to dismiss, holding that the plaintiffs failed to state a claim under the Fourth Amendment because the lobster fishery is a closely regulated industry and the rule was not unreasonably invasive. The court noted several concessions by the parties, including that the GPS tracking constituted a search, that the lobster industry is closely regulated, and that the search was administrative in nature.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court held that the lobster industry is a closely regulated industry and that the administrative search exception, as articulated in New York v. Burger, 482 U.S. 691 (1987), applied. The court found that the MDMR Rule satisfied the Burger test: it served a substantial government interest, warrantless searches were necessary to the regulatory scheme, and the rule provided a constitutionally adequate substitute for a warrant. The First Circuit affirmed the district court’s dismissal. View "Thompson v. Wilson" on Justia Law

During the 2023–2024 academic year, students at a private university in Massachusetts engaged in a series of pro-Palestinian protests following violence in the Middle East. The protests included rallies, walkouts, chalk messages, and an encampment near the campus Hillel center. Some Jewish and Israeli students reported feeling unsafe or unwelcome, and a few specific incidents were alleged, such as being blocked from campus areas or subjected to hostile remarks. The university responded by revising protest policies, suspending student groups, and eventually clearing the encampment, but did not discipline all protestors or end the demonstrations immediately.The United States District Court for the District of Massachusetts dismissed the plaintiffs’ suit, which alleged violations of Title VI of the Civil Rights Act, the Ku Klux Klan Act, and state law, for failure to state a claim. The court found that the plaintiffs had not plausibly alleged actionable harassment or that the university was deliberately indifferent to any such harassment. The court also declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that most of the protestors’ conduct constituted protected speech under the First Amendment and did not amount to actionable harassment under Title VI. The court further found that the university was not deliberately indifferent, as it took a series of escalating actions in response to the protests. The court also concluded that the plaintiffs failed to state a claim under the Ku Klux Klan Act because they did not plausibly allege a conspiracy with the purpose of depriving Jewish or Israeli students of their rights. The dismissal of the state-law claims was affirmed, and the court found no abuse of discretion in denying further leave to amend the complaint. View "StandWithUs Center for Legal Justice v. MIT" on Justia Law