Justia Constitutional Law Opinion Summaries

Several individuals attended a Loudoun County School Board meeting intending to speak during the public-comment period about recent news involving the Board’s reinstatement of a student who had previously been arrested and allegedly threatened another student. They wished to express concerns regarding the Board’s handling of school safety, particularly in relation to this specific student. During the meeting, the School Board Chair interrupted several of these individuals, invoking a Board policy that prohibits speakers from targeting, criticizing, or attacking individual students during public comments, and advised that such concerns should instead be directed privately to school officials.After these interruptions, the affected individuals filed suit in the United States District Court for the Eastern District of Virginia. Their complaint alleged that, as applied to them, the Board’s policy constituted impermissible viewpoint discrimination under the First Amendment, and that the policy was unconstitutionally vague. They sought a temporary restraining order and a preliminary injunction to prevent enforcement of the policy against them. The district court denied both requests, finding that the plaintiffs had not demonstrated a sufficient likelihood of success on the merits of their claims.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of the preliminary injunction. The Fourth Circuit affirmed the lower court’s decision, holding that the plaintiffs were unlikely to succeed on either claim. The court found that the policy was a reasonable, viewpoint-neutral restriction appropriate to the limited public forum of the school board’s meetings, and that the interruptions were consistent with the policy’s facial requirements, not discriminatory based on viewpoint. Furthermore, the court determined that the policy language—prohibiting comments that “target, criticize, or attack individual students”—was not unconstitutionally vague, providing sufficient notice and guidance for enforcement. The judgment of the district court was affirmed. View "Platt v. Mansfield" on Justia Law

A dual citizen of the United States and Pakistan, the defendant traveled from the U.S. to Pakistan in 2009, along with four others, with the intent to join jihad in Afghanistan. Upon arrival, the group attempted to make contact with terrorist organizations and made efforts to cross into Afghanistan. Pakistani authorities arrested them in Sargodha, Pakistan, and subsequently tried and convicted them on terrorism-related offenses. The defendant served approximately ten years in a Pakistani prison. After completing his sentence, he was extradited to the United States, where he faced federal charges arising from the same underlying conduct.The United States District Court for the Eastern District of Virginia arraigned the defendant and, after he waived his Speedy Trial Act rights, considered his motion to dismiss the indictment on Sixth Amendment speedy trial grounds. The motion argued that the government’s delay in seeking his extradition and prosecution in the U.S. violated his constitutional rights. The district court denied the motion, finding that, although the length of the delay was significant, the government made reasonably diligent and good-faith efforts to secure his return, and the remaining factors weighed against finding a violation. The defendant entered a conditional guilty plea, reserving his right to appeal the speedy trial ruling.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying the four-factor balancing test from Barker v. Wingo. The appellate court agreed that only the length of the delay favored the defendant, but reasoned that the government’s efforts, the defendant’s own conduct in resisting extradition, and the absence of actual prejudice outweighed that factor. The court held there was no Sixth Amendment speedy trial violation and affirmed the conviction. View "US v. Chaudhry" on Justia Law

Drug task force officers in West Virginia observed a car with expired registration, dark window tint, and a malfunctioning taillight, driven by Cornelious Johnson—an individual known to them from a prior drug conviction and currently on federal supervised release. The officers watched as Johnson and his passenger interacted with a man, Jackie Byrd, at an apartment complex previously associated with drug investigations. Although the officers suspected a drug transaction, they did not witness any exchange of items. Shortly after, Tremayne Hawkins entered the back seat, and the car left the complex. Officer Stanley, informed by the task force, stopped the car for the observed traffic violations and, suspecting drug activity, separated and questioned the occupants about their interaction with Byrd. Citing minor inconsistencies in their answers, Stanley called for a K9 unit, which alerted to drugs. A subsequent search yielded a firearm on Hawkins, who admitted to being prohibited from possessing one due to a prior conviction.The United States District Court for the Northern District of West Virginia denied Hawkins’ motion to suppress the firearm, holding that the officers had reasonable suspicion to extend the stop based on the area’s reputation, Johnson’s prior conviction, the observed interaction with Byrd, and the inconsistent statements from the occupants.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The Fourth Circuit held that none of the cited factors—alone or in combination—provided reasonable suspicion to extend the stop. The court emphasized that presence in an area associated with prior investigations, a dated conviction, innocuous interactions, and minor, reconcilable inconsistencies in statements did not collectively amount to reasonable suspicion of criminal activity. Accordingly, the Fourth Circuit reversed the district court’s denial of the suppression motion and remanded the case for further proceedings. View "US v. Hawkins" on Justia Law

Christopher Arthur was investigated after founding a business that sold military gear and later provided training and manuals on tactics including the use of explosives. The FBI became involved after a customer, Joshua Blessed, died in a shootout and was found to possess pipe bombs and Arthur’s manuals. Subsequently, an undercover informant, “Buckshot,” sought training from Arthur, who instructed him on fortifying his home and making explosive devices, knowing Buckshot claimed he wanted to use such tactics against federal agents. Arthur was arrested in January 2022 and a search of his home revealed illegal firearms and improvised explosives.A grand jury in the United States District Court for the Eastern District of North Carolina indicted Arthur under 18 U.S.C. § 842(p)(2)(B) for teaching explosives use with knowledge of criminal intent, and on additional firearms and explosives charges. Arthur moved to dismiss the primary count, arguing the statute was facially overbroad under the First Amendment. The district court denied the motion, finding the statute’s knowledge requirement limited its scope to conduct integral to criminal acts, not protected speech. After a three-day trial, the jury found Arthur guilty on all counts. At sentencing, the court applied the U.S.S.G. § 3A1.4 terrorism enhancement, increasing his guidelines range, and sentenced Arthur to a total of 300 months’ imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that 18 U.S.C. § 842(p)(2)(B) is not unconstitutionally overbroad, concluding that the statute targets speech integral to criminal conduct and does not criminalize a substantial amount of protected expressive activity. The Fourth Circuit also found no reversible error in applying the terrorism enhancement, and determined any alleged guidelines error was harmless given the district court’s alternative sentencing rationale. The judgment of the district court was affirmed. View "US v. Arthur" on Justia Law

An Indian professor employed at a public university in North Carolina applied for tenure after a probationary period, but his initial application was denied following negative evaluations from colleagues concerning his teaching, mentorship, and administrative performance. Several years later, the same professor reapplied and was granted tenure. After receiving tenure, he sued various university officials, alleging that the original denial was the result of racial discrimination in violation of the Equal Protection Clause and 42 U.S.C. § 1981, as well as retaliation for his non-traditional teaching methods in violation of the First Amendment. His complaint focused on negative statements and actions by two specific colleagues, while also asserting that other officials enabled or failed to remedy alleged bias.The United States District Court for the Eastern District of North Carolina dismissed the complaint for failure to state a claim under Rule 12(b)(6). The court found that the plaintiff’s allegations of racial discrimination were unsupported by facts connecting any defendant’s actions to race, and that his First Amendment retaliation claim failed to identify protected speech or a causal link between such speech and the tenure decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal. The Fourth Circuit held that the plaintiff’s allegations did not plausibly suggest he was treated differently than similarly situated colleagues because of his race, as required for Equal Protection and § 1981 claims. The court also concluded that the complaint failed to plausibly allege protected speech or retaliation under the First Amendment. The Fourth Circuit emphasized the limited judicial role in reviewing academic tenure decisions and declined to address qualified immunity, as no plausible claim was stated. Thus, the district court’s judgment was affirmed. View "Katti v. Arden" on Justia Law

The case centers on Jessie Glass, whose estranged wife, April, reported to law enforcement that she witnessed a significant quantity of child sexual abuse material on Glass’s phone. April provided specific details about the alleged material, the devices Glass owned, and information for accessing his online accounts. Detective Jason Lowrance investigated April’s claims, which included reviewing her prior allegations against Glass as well as Glass’s history of previous investigations for similar offenses. Some of these earlier investigations had been closed without charges or with findings labeled “[u]nfounded.” Lowrance then prepared affidavits for search warrants to search Glass’s home and electronics, securing evidence of child sexual abuse material.The United States District Court for the Western District of North Carolina denied Glass’s motion to suppress, which argued that Lowrance recklessly omitted information in his warrant affidavits that would have undermined April’s credibility and thus probable cause. The district court found that any omissions were not made with intent to mislead or recklessness, and that the omitted facts would not have altered the probable cause determination. A jury later found Glass guilty on all counts, and the district court sentenced him to fifteen years’ imprisonment and imposed financial penalties.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that Lowrance’s affidavits contained sufficient detail to support probable cause, and that the omitted information about April’s credibility would not have defeated probable cause. The appellate court also rejected Glass’s double jeopardy argument, finding the convictions and sentences were based on distinct conduct. Finally, the court affirmed the district court’s imposition of a $5,000 special assessment, concluding the required statutory considerations were adequately addressed. The judgment was affirmed in all respects. View "US v. Glass" on Justia Law

The plaintiff, a community advocate, posted a lengthy video—obtained from internal office security footage of a local police department—on his Facebook page. Only a few department employees had access to this footage. In response, a special agent from the Virginia State Police investigated how the plaintiff obtained the video, suspecting possible computer trespass under Virginia law. The agent sought and obtained warrants to search the plaintiff’s Facebook and Gmail accounts, believing these accounts might contain evidence relevant to the investigation. Although the plaintiff moved to quash both warrants for lack of probable cause, a state court denied the motions, and the Supreme Court of Virginia refused his appeal. Ultimately, the local prosecutor determined there was insufficient evidence to charge anyone with computer trespass.Following these events, the plaintiff filed a federal lawsuit in the United States District Court for the Western District of Virginia, alleging that the searches violated his First and Fourth Amendment rights and were conducted in retaliation for his criticism of local government. After amending his complaint once, the plaintiff sought to amend it a second time. The district court dismissed his claims, concluding that his failure to plead the absence of probable cause was fatal, and denied leave to amend as futile.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The Fourth Circuit held that, in order to state a First Amendment retaliatory search claim, the plaintiff was required to plead the absence of probable cause or show he qualified for a narrow exception, and he had done neither. The court further held that the same requirement applied to his Fourth Amendment claim. The court also agreed that denying leave to amend was proper, as the proposed amendment would not have stated a valid claim. View "Stanley v. Bocock" on Justia Law

In this case, the defendant applied for U.S. citizenship in 2011 and, on his application and during an interview, denied ever having committed a crime for which he was not arrested. However, in 2013, he pleaded guilty in North Carolina state court to attempted statutory rape for conduct that occurred in 2008, admitting to engaging in a sexual act with a minor. He did not disclose this conduct on his naturalization application. Years later, a federal grand jury indicted him for naturalization fraud, alleging he knowingly concealed his criminal history to obtain citizenship.The United States District Court for the Western District of North Carolina denied the defendant’s motion to dismiss the indictment for unconstitutional preindictment delay, finding he had not shown actual prejudice from the delay. The court also denied his motion to suppress evidence of his state guilty plea, ruling that he could not collaterally attack the validity of his state conviction in federal court except for a deprivation of counsel, which did not apply here. At trial, the court limited the testimony of the defendant’s expert witness regarding his cognitive abilities, excluding certain opinions about his capacity to understand the application question. The jury convicted the defendant, finding he knowingly made a false statement, and the court sentenced him to six months in prison and revoked his citizenship.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the defendant failed to demonstrate substantial actual prejudice from the preindictment delay, that the district court properly refused to suppress the state guilty plea, and that while the limitation of the expert’s testimony was error under recent Supreme Court guidance, the error was harmless given the other evidence presented. The conviction and sentence were therefore affirmed. View "US v. Palmer" on Justia Law

Several individuals whose livelihoods depended on interacting with spinner dolphins challenged a federal regulation that restricted human proximity to these dolphins. The regulation, known as the Approach Rule, was issued by the National Marine Fisheries Service under the authority of the Marine Mammal Protection Act. The plaintiffs included a psychotherapist who used dolphin encounters in therapy, a boat captain who operated dolphin swim tours, and a dolphin guide and photographer. They argued that the regulation was unconstitutional because it was signed and promulgated by an official who, they claimed, was not properly appointed under the Appointments Clause of the U.S. Constitution.The United States District Court for the District of Maryland reviewed the case after the plaintiffs filed suit seeking to invalidate the regulation and enjoin its enforcement. During the litigation, Dr. Richard Spinrad, the Senate-confirmed NOAA Administrator and a principal officer, ratified the regulation, affirming that he independently evaluated and approved it. The district court found that this ratification cured any potential Appointments Clause defect and granted summary judgment in favor of the government. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court held that, under established principles of agency law, a principal officer’s ratification of a regulation can cure any constitutional defect arising from its initial promulgation by a non-principal officer. The court found that Dr. Spinrad’s ratification was valid and not impermissibly retroactive, as it did not impose new liabilities for past conduct but merely confirmed the regulation’s validity from the time of its original publication. Accordingly, the Fourth Circuit affirmed the district court’s dismissal of the suit. View "Wille v. Lutnik" on Justia Law

The defendant was indicted on three charges related to the production and possession of child pornography. He pleaded guilty to one count—production of child pornography—and was sentenced to 256 months in prison, followed by a lifetime of supervised release. The terms of his supervised release included both mandatory and special conditions. Of particular relevance was a special condition requiring him to submit to substance abuse testing and contribute to the cost of such testing, as determined by a sliding scale approved by the Probation Office.The United States District Court for the District of South Carolina imposed these conditions at sentencing. The defendant did not object to the special condition regarding substance abuse testing during the sentencing proceedings. On appeal, he argued that this special condition unconstitutionally delegated a core judicial function—specifically, the authority to determine the number of drug tests—to the Probation Office.The United States Court of Appeals for the Fourth Circuit reviewed the case for plain error, given the lack of objection below. The court found that the plain language of the special condition did not delegate authority to determine the number of drug tests to the Probation Office; rather, it addressed only the payment for drug testing ordered by the court. The court concluded that the discretion over the number of drug tests remained with the district court, and the special condition merely facilitated payment. As a result, the Fourth Circuit held that there was no error, let alone plain error, in imposing the special condition and affirmed the defendant’s sentence. The government’s motion to dismiss the appeal based on an appeal waiver was denied as moot. View "US v. Jones" on Justia Law