Justia Constitutional Law Opinion Summaries

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

Three nonprofit organizations brought suit challenging an executive order that denies U.S. citizenship to children born in the United States whose fathers are neither citizens nor lawful permanent residents, and whose mothers are present in the country either unlawfully or only temporarily. The organizations alleged that they have members who are expecting children affected by the order, and sought declaratory and injunctive relief, arguing that the order violates the Citizenship Clause of the Fourteenth Amendment and the Immigration and Nationality Act.The United States District Court for the District of New Hampshire found that the plaintiffs had standing and a cause of action for injunctive relief. The court determined that the plaintiffs were likely to succeed on the merits of their constitutional and statutory claims, and that the equitable factors favored granting relief. It issued a preliminary injunction barring enforcement of the executive order against the plaintiffs and their members, but not against nonparties. The government appealed the scope and propriety of the injunction.The United States Court of Appeals for the First Circuit reviewed the preliminary injunction for abuse of discretion, with de novo review of legal issues and clear error review of factual findings. The court affirmed the district court’s determination that the plaintiffs had standing and were likely to succeed on the merits of their claims under the Citizenship Clause and 8 U.S.C. § 1401. However, the First Circuit vacated the injunction to the extent that it ran directly against the President and the agencies themselves, holding that injunctive relief should be limited to agency officials. The court affirmed the injunction as applied to the organizations’ members who are likely to be harmed, and remanded for further proceedings consistent with its opinion. View "New Hampshire Indonesian Community Support v. Trump" on Justia Law

The case concerns challenges to Executive Order No. 14160, issued in January 2025, which seeks to deny birthright citizenship to children born in the United States after its effective date if their fathers are not U.S. citizens or lawful permanent residents and their mothers are either unlawfully or temporarily present in the country. Plaintiffs include individual immigrants, nonprofit organizations, and a coalition of states and local governments. They allege that the Executive Order violates the Citizenship Clause of the Fourteenth Amendment, 8 U.S.C. § 1401(a), the equal protection component of the Fifth Amendment, the Separation of Powers doctrine, and the Administrative Procedure Act. The plaintiffs seek declaratory and injunctive relief to prevent enforcement of the Order.The United States District Court for the District of Massachusetts granted preliminary injunctions to both sets of plaintiffs, finding they were “exceedingly likely” to succeed on their claims under the Citizenship Clause and § 1401(a). The injunctions barred federal agencies and officials from enforcing the Executive Order against the plaintiffs and, in the case brought by the states, issued a nationwide injunction to provide complete relief. The government appealed, challenging the plaintiffs’ standing, the scope of the injunctions, and the merits of the constitutional and statutory claims.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s findings that the plaintiffs have Article III standing and are likely to succeed on the merits. The First Circuit held that the Executive Order’s denial of birthright citizenship to children born in the United States under the specified circumstances violates both the Citizenship Clause of the Fourteenth Amendment and 8 U.S.C. § 1401(a), as interpreted by United States v. Wong Kim Ark and subsequent precedent. The court affirmed the preliminary injunctions in part, vacated them in part as to agency defendants, and remanded for further proceedings consistent with its opinion. View "Doe v. Trump" on Justia Law

A group of out-of-state pig farmers and a pork processor challenged a Massachusetts law that prohibits the use of certain confinement methods for breeding pigs (specifically, gestation crates) and bans the sale in Massachusetts of pork products derived from pigs confined in such a manner. The plaintiffs, who operate outside Massachusetts and use these confinement methods, argued that the law discriminates against out-of-state producers and is preempted by federal statutes. The law was enacted by ballot initiative and became enforceable after the Supreme Court’s decision in National Pork Producers Council v. Ross.The United States District Court for the District of Massachusetts dismissed most of the plaintiffs’ claims, including those based on the Privileges and Immunities Clause, preemption by the Federal Meat Inspection Act (FMIA) and the Packers and Stockyards Act (PSA), the Full Faith and Credit Clause, the Due Process Clause, and the Import-Export Clause. The court allowed the dormant Commerce Clause claim to proceed, but ultimately granted summary judgment against the plaintiffs on that claim as well, after severing a provision of the law that it found discriminatory (the “slaughterhouse exemption”). The court found that the remaining provisions of the law did not discriminate against out-of-state interests and did not impose a substantial burden on interstate commerce.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The First Circuit held that the Massachusetts law does not discriminate against out-of-state producers in purpose or effect, does not impose a substantial burden on interstate commerce under the Pike balancing test, and is not preempted by the FMIA or PSA. The court also rejected the plaintiffs’ claims under the Privileges and Immunities Clause, Full Faith and Credit Clause, Due Process Clause, and Import-Export Clause. The court found no procedural error in the district court’s handling of the case. View "Triumph Foods, LLC v. Campbell" on Justia Law

Brandon Velez was stopped by Manchester, New Hampshire police officers for vehicle equipment violations. After parking near his residence, Velez did not immediately comply with officers’ orders to exit his car. When he verbally refused and reached for his phone, officers attempted to physically remove him, leading to a struggle. During the altercation, one officer struck Velez multiple times and tased him twice. Velez was arrested and charged with misdemeanors and a traffic violation, ultimately pleading guilty only to the traffic violation. He later sued the officers and the City of Manchester, alleging wrongful arrest, false imprisonment, excessive force, assault and battery, and failure to train.The case was removed from state court to the United States District Court for the District of New Hampshire. The defendants moved for summary judgment, which the district court granted, finding that the officers had probable cause for the arrest and that the force used was not excessive. Velez appealed the decision.The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment order de novo. The appellate court held that the officers had probable cause to arrest Velez for resisting detention under New Hampshire law, defeating his wrongful arrest and false imprisonment claims. The court also found that, although one officer’s use of force was excessive under the Fourth Amendment, qualified immunity shielded the officer from liability because the law was not clearly established in the specific context. The court further held that Velez’s state-law assault and battery claim failed under the same immunity standard, and that his claims against the City for failure to train were unsupported by evidence of a municipal policy or deliberate indifference. The First Circuit affirmed the district court’s judgment in favor of the defendants on all counts. View "Velez v. Eutzy" on Justia Law

In March 2025, the President issued an executive order directing federal officials to eliminate non-statutory functions and reduce statutory functions of three federal agencies: the Institute of Museum and Library Services (IMLS), the Minority Business Development Agency (MBDA), and the Federal Mediation and Conciliation Service (FMCS). These agencies, established and funded by Congress, provide grants and services to states and other entities. Following the executive order, the agencies terminated, reassigned, or placed on leave nearly all employees and canceled numerous grants, which plaintiffs—twenty-one states—alleged caused immediate and ongoing harm, including loss of services, forced layoffs, and canceled programming.The United States District Court for the District of Rhode Island granted a preliminary injunction, finding that the plaintiffs had suffered and would continue to suffer concrete injuries due to the agencies’ actions. The court determined that the agencies’ actions likely violated the Administrative Procedure Act and constitutional provisions, including the Take Care Clause and separation of powers. The injunction barred implementation of the executive order as to the three agencies, required reversal of actions taken to implement the order, restoration of employees, and resumption of grant funding, while allowing for efficiency measures not motivated by the executive order. The district court denied the government’s request for a stay of the injunction pending appeal.The United States Court of Appeals for the First Circuit reviewed only the government’s motion for a stay pending appeal. The court denied the stay, holding that the government failed to make a strong showing of likely success on the merits, particularly because it did not adequately challenge the district court’s constitutional analysis and had not preserved certain arguments. The court also found that the balance of harms and public interest did not favor a stay. View "Rhode Island v. Trump" on Justia Law

Robert Miller died at his home in Cape Cod in 2019 following an encounter with Barnstable police officers Sean Roycroft and Spencer Jackson. The officers responded to a 911 call from Miller’s girlfriend, who requested a psychiatric evaluation but did not report any crime. Upon arrival, a struggle ensued as the officers attempted to handcuff Miller, who ended up face-down on the floor with Roycroft’s arm pinned beneath him. During the struggle, Jackson delivered two punches to Miller in an effort to facilitate handcuffing. Miller’s girlfriend witnessed one of the officers drive a knee into Miller’s back and heard Miller say, “I can’t breathe” and “Amy, help me.” After Miller was handcuffed, he became unresponsive and was later pronounced dead. The medical examiner attributed the death to cardiac dysrhythmia in the setting of excited delirium, while the plaintiff’s expert opined that Miller died from prone restraint cardiac arrest due to pressure on his back.The plaintiff, Miller’s son, brought a federal excessive force claim under 42 U.S.C. § 1983 against the officers in the United States District Court for the District of Massachusetts. After discovery, the officers moved for summary judgment on qualified immunity grounds. The district judge denied summary judgment, finding that there were genuine disputes of material fact regarding whether the officers used excessive force, particularly after Roycroft freed his arm and Miller was restrained. The judge concluded that clearly established law prohibited kneeling on a restrained person’s back and that a reasonable jury could find the officers’ conduct violated Miller’s constitutional rights.On appeal, the United States Court of Appeals for the First Circuit reversed the denial of qualified immunity for the officers’ conduct while Roycroft’s arm was pinned (Phase One), affirmed the denial for conduct after Miller was restrained and a knee was placed on his back (Phase Two), and dismissed the appeal in part for fact-based arguments not suitable for interlocutory review. The case was remanded for further proceedings. View "Miller v. Roycroft" on Justia Law

The defendant pleaded guilty in 2013 to possessing child pornography, after sharing videos of minors being sexually abused and attempting to arrange sex with a minor. He was sentenced to ten years in prison and 25 years of supervised release, with conditions restricting his access to internet-capable devices. After completing his prison term, he began supervised release in December 2019. His release was revoked three times for violations, including unauthorized internet access and failure to comply with monitoring requirements. The conditions at issue required him to use only devices with court-approved monitoring software and to contribute to the cost of monitoring based on his ability to pay.Following the first revocation, the United States District Court for the District of Puerto Rico imposed new, stricter internet monitoring conditions. After further violations, including possessing unauthorized devices and failing to report employment changes, the court again revoked his supervised release (the “Second Revocation”), sentencing him to time served and a renewed term of supervised release with the same conditions. The defendant objected, arguing that the court improperly relied on ex parte communications from his probation officer and that the internet monitoring conditions were unconstitutional and unlawfully delegated judicial authority to the Probation Office.The United States Court of Appeals for the First Circuit reviewed the appeal. The court held that, although the district court erred by relying on new, significant facts from ex parte communications regarding the defendant’s employment, the error was harmless because other uncontested violations supported the revocation and sentence. The court also held that the challenged internet monitoring conditions were not facially unconstitutional or an unlawful delegation of judicial authority. The court found the defendant’s as-applied constitutional challenges unripe, as they depended on future enforcement. The judgment and sentence from the Second Revocation were affirmed. View "United States v. Negron-Cruz" on Justia Law

A police officer with the Cambridge Police Department, who had served in both patrol and special investigations roles, posted a comment on his personal Facebook page criticizing the naming of a federal police reform bill after George Floyd. In his post, he referred to Floyd as a "career criminal, a thief and druggie," and expressed pessimism about the country's future. The post was made from home, visible only to his Facebook friends, but was quickly screenshotted and shared with community members, including the local NAACP. The police commissioner was alerted, and the department initiated an internal investigation. The officer was placed on administrative leave and, after the investigation concluded that his post violated department policies on courtesy and professionalism, he was suspended without pay for four days.The officer filed suit in the United States District Court for the District of Massachusetts, alleging that his suspension was unconstitutional retaliation for exercising his First Amendment rights. Both parties moved for summary judgment. The district court granted summary judgment in favor of the department, finding that the department’s interest in maintaining public trust and effective service outweighed the officer’s and the public’s interest in his speech, particularly given the context of heightened scrutiny and protest following George Floyd’s death.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s decision de novo. The First Circuit held that, while the officer’s speech addressed a matter of public concern, its mocking and disparaging nature diminished its First Amendment value. The court further held that the department’s prediction that the post could undermine public trust was reasonable, especially in the context of ongoing public unrest and the department’s need to maintain community confidence. The court found no evidence of impermissible viewpoint discrimination. The First Circuit affirmed the district court’s grant of summary judgment for the department. View "Hussey v. City of Cambridge" on Justia Law

A coastal town in Maine, known for its small population and proximity to a national park, experienced a significant increase in cruise ship tourism, with large vessels bringing thousands of passengers daily. In response to concerns about congestion, public safety, and the impact on local amenities, residents approved an ordinance capping the number of cruise ship passengers who could disembark in the town to 1,000 per day. The ordinance imposed fines for violations and was intended to address issues primarily at the waterfront and, to a lesser extent, in the downtown area.Several local businesses, a business association, and a pilots’ association challenged the ordinance in the United States District Court for the District of Maine. They argued that the ordinance was preempted by federal and state law, violated the Commerce Clause (including its dormant aspect), and infringed on due process rights. After a bench trial, the District Court largely ruled in favor of the town and an intervening resident, rejecting most claims but finding that the ordinance was preempted by federal regulations only to the extent it restricted crew members’ shore access. The court declined to enjoin the ordinance, noting the town’s intent to address this issue through further rulemaking.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rejection of the state law preemption, federal preemption (except for the now-moot crew access issue), and due process claims. The First Circuit also affirmed the dismissal of discrimination-based Dormant Commerce Clause claims, finding no similarly situated in-state and out-of-state competitors. However, the court vacated and remanded the District Court’s dismissal of the Pike balancing Dormant Commerce Clause claim, instructing further analysis of whether the ordinance’s burdens on interstate commerce are clearly excessive in relation to its local benefits. The court dismissed as moot the appeals related to the crew access issue. View "Ass'n to Preserve and Protect Local Livelihoods v. Town of Bar Harbor" on Justia Law