Justia Constitutional Law Opinion Summaries

After Puerto Rico experienced several states of emergency, including the COVID-19 pandemic, the government amended its public safety law, Law 20, specifically Article 5.14(a), to criminalize knowingly or recklessly disseminating false information about imminent catastrophes. The law applies during a governor-declared state of emergency or disaster and covers statements made through any medium, including social networks and mass media. Violation of the law can result in misdemeanor or felony charges, depending on the harm caused. Two independent journalists, who had published critical coverage of the government’s handling of emergencies, challenged the constitutionality of Article 5.14(a), arguing it violated their First Amendment rights.The United States District Court for the District of Puerto Rico reviewed the journalists’ claims. The court found Article 5.14(a) to be a content-based regulation, as it distinguished between true and false speech, and applied strict scrutiny. While the government’s interest in public safety was recognized as compelling, the court determined that the statute’s broad restrictions were not narrowly tailored, lacking meaningful limiting features and being both overinclusive and underinclusive. As a result, the district court issued a permanent injunction preventing enforcement of Article 5.14(a). The government’s motion for reconsideration was unsuccessful, leading to a timely appeal.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court’s decision, holding that Article 5.14(a) is a content-based regulation subject to strict scrutiny, and does not fall within any traditional exceptions to First Amendment protection. The First Circuit found that the statute was not narrowly tailored to serve the government’s compelling interest in public safety and failed to demonstrate necessity or a direct causal link between the restriction and the harm prevented. The injunction against enforcement of Article 5.14(a) was affirmed. View "Rodriguez-Cotto v. Gonzalez-Colon" on Justia Law

During the COVID-19 pandemic, the City of Boston implemented a temporary outdoor dining program that allowed restaurants across the city to use outdoor spaces for dining under relaxed licensing rules. In 2022, the City adopted a special plan for the North End neighborhood, which included higher fees, a shorter outdoor dining season, and additional restrictions compared to other neighborhoods. The City cited quality-of-life concerns, such as congestion and sanitation, and ongoing complaints from residents as reasons for the North End-specific rules. In 2023 and 2024, the City went further and banned on-street dining in the North End, while permitting it elsewhere. These actions prompted a group of North End restaurants and the local Chamber of Commerce to sue the City, alleging constitutional and state law violations.The United States District Court for the District of Massachusetts dismissed the plaintiffs’ lengthy complaint, finding that it violated Rule 8 of the Federal Rules of Civil Procedure by being excessively long and repetitive, and also determined that the complaint failed on the merits. The court denied the plaintiffs leave to amend, citing their multiple prior complaints and the substantive deficiencies in their claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal of the federal constitutional claims (counts I–V) with prejudice, agreeing that the complaint was overly burdensome and failed to plausibly allege violations of equal protection, due process, or arbitrary action by the City. The Court held that disparate impact or political controversy alone does not suggest unconstitutional discrimination or retaliation, and the City’s actions had a rational basis. The First Circuit vacated the dismissal of the state law tax claim (count VI) and remanded with instructions to dismiss that claim without prejudice, as the federal court declined to reach its merits after disposing of the federal claims. View "North End Chamber of Commerce, Inc. v. City of Boston" on Justia Law

A group of individuals who wished to protest outside a high-profile murder trial in Massachusetts were prohibited from doing so by a Superior Court judge’s order establishing a 200-foot buffer zone around the courthouse, including nearby sidewalks and streets. After the buffer zone was imposed, the plaintiffs—demonstrators—filed suit in federal court against various public officials and entities, alleging violations of their First Amendment and due process rights.The United States District Court for the District of Massachusetts initially denied a preliminary injunction against the buffer zone, but the United States Court of Appeals for the First Circuit vacated that denial and remanded, suggesting that a restriction more closely tailored to demonstrations intended to interfere with justice might be permissible. In response, the Superior Court judge amended the order to include a requirement of intent to interfere with the administration of justice or influence trial participants. The district court then partially granted and partially denied a renewed motion for a preliminary injunction: it found the revised order survived a facial First Amendment challenge but agreed with plaintiffs that there had been unconstitutional as-applied enforcement, granting limited relief.After the murder trial concluded and the buffer zone order expired by its own terms, the plaintiffs continued to appeal the denial of broader injunctive relief. The United States Court of Appeals for the First Circuit held that the case was moot because the order was no longer in effect and there was no reasonable expectation the same plaintiffs would again face a similar restriction. The court determined that neither injunctive nor declaratory relief was available and that the “capable of repetition, yet evading review” exception did not apply. As a result, the First Circuit vacated the district court’s partial denial of the preliminary injunction and ordered dismissal of that portion of the case, leaving the remainder to the district court. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law

In this case, the owner of a Massachusetts gun store and the store itself challenged recent amendments to state law that prohibit the sale, transfer, or possession of certain "assault-style firearms" and related magazines. The plaintiffs argued that these provisions, enacted in 2024, violated their rights under the Second Amendment, the dormant Commerce Clause, and the Equal Protection Clause of the Fourteenth Amendment. They asserted that the law infringed on their ability to keep and bear arms, imposed unconstitutional burdens on interstate commerce by affecting out-of-state manufacturers and their own business, and discriminated against them compared to individuals and businesses in other states.The United States District Court for the District of Massachusetts granted the state defendants’ motion to dismiss for failure to state a claim. The district court concluded that the plaintiffs’ Second Amendment claim was foreclosed by the First Circuit’s earlier decision in Capen v. Campbell, which upheld a similar Massachusetts firearms ban. The court also found the plaintiffs’ dormant Commerce Clause and Equal Protection Clause claims inadequately pleaded, noting that the complaint did not plausibly allege discrimination against interstate commerce or that similarly situated persons were treated differently.The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that its prior decision in Capen v. Campbell controlled and that the challenged restrictions on assault-style firearms were consistent with the Nation’s historical tradition of firearm regulation and thus did not violate the Second Amendment. The court further held that the law did not discriminate against or impose an undue burden on interstate commerce, nor did it violate equal protection, as the right to make a living is not a fundamental right and the law had a rational basis. The district court’s judgment was affirmed. View "Recchia v. Campbell" on Justia Law

A state prisoner challenged the denial of his federal habeas corpus petition after being convicted of several charges, including aggravated rape, in Massachusetts. The prosecution’s case was based on the victim’s testimony, physical evidence, and expert and witness accounts, while the defendant claimed the sexual encounter was consensual. During jury deliberations, seven not-guilty verdicts were returned on some charges, but deliberations continued on the remaining counts. After the weekend recess, a Facebook post by a former police officer urged community members to attend the next court session to support the victim, and a small demonstration took place at the courthouse with attendees wearing teal ribbons. The defense raised concerns about potential juror exposure to these influences, but the judge declined an individual juror inquiry, instead asking general questions about their ability to continue serving.Following conviction, the defense contacted jurors, and one juror reported seeing the Facebook post, being aware of the demonstration, and claimed that these factors led to greater weight being given to the victim’s testimony on the last day of deliberations. The trial court held an evidentiary hearing, found that some jurors were aware of the post and demonstration, but concluded that exposure was brief, not discussed during deliberations, and not prejudicial. The trial court specifically discredited the juror’s account of actual prejudice. The Massachusetts Appeals Court affirmed, and the Supreme Judicial Court declined review.In federal habeas proceedings, the U.S. District Court for the District of Massachusetts denied relief, holding that the state court’s examination of extraneous influence claims met federal constitutional standards and that its factual findings were owed deference. The United States Court of Appeals for the First Circuit affirmed, holding that the state court’s decision was neither contrary to nor an unreasonable application of clearly established Supreme Court precedent, and that its factual determinations were reasonable. The denial of habeas relief was affirmed. View "Adames-Garcia v. Divris" on Justia Law

The defendant was investigated after law enforcement used a specialized tool called Freenet Roundup, which is a modified version of a peer-to-peer software called Freenet. Freenet allows users to share files anonymously, but its Opennet mode warns users that their identity could be discovered and their IP address is visible to strangers. Freenet Roundup, available only to law enforcement, logs requests for known child sexual abuse material (CSAM) and uses a formula to help identify whether a request came from an original source or was simply relayed. After Freenet Roundup flagged requests associated with the defendant’s IP address for CSAM, the FBI obtained a search warrant for his residence, finding devices containing child pornography.The defendant was charged in the United States District Court for the District of Massachusetts with possession of child pornography. Before trial, he moved to suppress the evidence, arguing that law enforcement’s use of Freenet Roundup constituted an unlawful Fourth Amendment search, as he claimed a reasonable expectation of privacy in his Freenet transmissions. The district court denied the motion, reasoning that because the defendant voluntarily used Freenet’s Opennet mode, which warns of identity risks and connections with strangers, he lacked a reasonable expectation of privacy in the relevant activity. The court distinguished this case from Carpenter v. United States, finding that law enforcement’s actions did not amount to wholesale surveillance or use of technology not in general public use. The defendant then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s findings for clear error and its legal conclusions de novo. The First Circuit held that a defendant lacks a reasonable expectation of privacy in activity voluntarily shared on publicly-available peer-to-peer networks like Freenet’s Opennet mode. The court affirmed the district court’s denial of the suppression motion. View "US v. Johnson" on Justia Law

A Maine Catholic school, the Roman Catholic Diocese that operates it, and parents seeking to send their children there challenged several antidiscrimination provisions in Maine’s Human Rights Act (MHRA). The MHRA applies to schools receiving public tuition assistance and prohibits discrimination based on religion, sexual orientation, and gender identity. St. Dominic Academy, not currently receiving tuition assistance but eligible to do so, argued that these rules would require them to change admissions and employment policies central to their religious mission, including prioritizing Catholic students and requiring conformity with Catholic teachings. The school also objected to policies on gender identity that would compel the school to use students’ preferred pronouns and permit dress consistent with gender identity, potentially over parental objections.The United States District Court for the District of Maine denied St. Dominic’s request for a preliminary injunction, finding the school’s employment practices protected by MHRA carveouts and determining St. Dominic had not shown a likelihood of success on its other claims. The court also denied similar relief in a companion case brought by another religious school, and entered final judgment for the state officials.Reviewing the appeal, the United States Court of Appeals for the First Circuit affirmed in part and reversed in part. The court affirmed that St. Dominic lacked standing to challenge the employment rule, and that the challenges to the religious nondiscrimination and sexual orientation/gender identity rules were unlikely to succeed: these rules are neutral, generally applicable, and rationally related to legitimate state interests. However, the court reversed as to the “Religious Expression Rule,” finding it facially nonneutral and likely unconstitutional under the Free Exercise Clause. The First Circuit ordered entry of a preliminary injunction against enforcement of this rule as applied to St. Dominic. The parental-rights claim was deemed moot and remanded for dismissal. View "St. Dominic Academy v. Makin" on Justia Law

A Christian church in Maine operates a private K–12 school that adheres closely to its religious beliefs, including requiring students and staff to conform to a statement of faith and specific codes of conduct and dress. The school is willing to admit students of any background if their families support its religious philosophy, but it maintains policies that exclude students who are openly gay or transgender and requires employees to be co-religionists. The school sought to participate in Maine’s tuition-assistance program, which allows public funds for private education in certain circumstances, but did not apply because of state nondiscrimination laws it believed would conflict with its religious practices.The United States District Court for the District of Maine denied the school’s motion for a permanent injunction against several provisions of the Maine Human Rights Act (MHRA), finding either no case or controversy or no constitutional violation. The case reached the United States Court of Appeals for the First Circuit after the parties stipulated to final judgment based on the preliminary injunction record, reserving all appellate rights.The United States Court of Appeals for the First Circuit reviewed whether the MHRA’s rules on employment, religious expression, religious nondiscrimination, and sexual orientation/gender identity nondiscrimination violate the First Amendment as applied to the school. The court held there was no case or controversy regarding the employment rule due to existing carveouts. It affirmed the district court’s rejection of the school’s challenges to the religious nondiscrimination and sexual orientation/gender identity rules, finding no constitutional violation. However, the court determined that the religious expression rule violates the school’s free-exercise rights and must be enjoined as applied to the school. The judgment was affirmed in part and reversed in part, and the case was remanded for entry of a permanent injunction against enforcement of the religious expression rule. View "Crosspoint Church v. Makin" on Justia Law

A religious nonprofit organization sought to purchase a former university campus property after being selected as the winning bidder in a competitive process conducted by a state university system. Following the public announcement of the award, there was significant public opposition to the sale, particularly due to the religious nature of the winning bidder. Two unsuccessful bidders filed administrative protests, raising both procedural and substantive objections, including criticism of the university's decision to sell to a religious organization. The university's designated official initially denied these protests, but upon further internal review, a higher-level administrator determined that a flaw in the bid evaluation process—specifically, the failure to consider cost-saving proposals for existing infrastructure—warranted rescinding the award and restarting the process. In the new round, the property was awarded to a different bidder who scored higher under revised criteria.The original winning bidder, the religious organization, challenged the university's decision in the United States District Court for the District of Maine, alleging violations of the Equal Protection and Free Exercise Clauses of the U.S. Constitution. The district court denied the plaintiff’s motions for a temporary restraining order and a preliminary injunction, finding that the plaintiff failed to show a likelihood of success on the merits of either claim. The court credited testimony that the university’s decision was motivated by cost-saving considerations rather than religious bias, and found no clear evidence of procedural irregularity or pretext.On appeal, the United States Court of Appeals for the First Circuit reviewed the denial of the preliminary injunction for abuse of discretion. The Court affirmed the district court’s decision, holding that the lower court applied the correct legal standards and did not clearly err in its factual findings. The Court concluded that the plaintiff failed to demonstrate a likelihood of success on the merits of its constitutional claims. View "Calvary Chapel Belfast v. University of Maine System" on Justia Law

Plaintiffs had their property taken by the Commonwealth of Puerto Rico through eminent domain. They received over two million dollars in compensation, including interest accrued up to the time of payment. However, they alleged a second violation occurred when the court-administered disbursement process failed to notify them of further accrued interest and deducted a 15% administrative fee from that interest. They challenged these practices as unconstitutional takings and violations of due process, seeking declaratory and equitable relief against the Administrator of the Administration of Tribunals.The United States District Court for the District of Puerto Rico initially dismissed most claims, finding plaintiffs lacked standing because they had not alleged an attempt to withdraw the accrued interest, making their injury speculative. After reconsideration, the court revived the claim challenging the deduction of administrative fees, but limited relief to prospective injunctive relief due to Eleventh Amendment constraints. The court ultimately granted summary judgment to the defendant, finding the administrative fee reasonable and not an unconstitutional taking, as plaintiffs provided no evidence to the contrary.The United States Court of Appeals for the First Circuit reviewed the case and confronted jurisdictional issues arising from Puerto Rico’s Title III bankruptcy under PROMESA. The court held that the administrative fee claim was void for violating the automatic stay provisions, as it amounted to a demand for property of the debtor (the Commonwealth), and dismissed that portion of the appeal. Regarding the interest claim, the court affirmed the district court’s dismissal, ruling plaintiffs lacked standing because they failed to allege they sought disbursement or challenged existing procedures. The First Circuit thus dismissed the appeal from summary judgment and affirmed the district court's dismissal. View "Hernandez-Castrodad v. Steidel-Figueroa" on Justia Law