Justia Constitutional Law Opinion Summaries

In July 2023, law enforcement responded to an incident in which James Jacobs allegedly discharged a firearm during a dispute with his girlfriend at his home. During a subsequent search, officers discovered two firearms. Jacobs, who has a prior felony conviction and a previous misdemeanor conviction for domestic battery in West Virginia, admitted to knowing he was prohibited from possessing firearms. As a result, a grand jury in the Northern District of West Virginia indicted him for possessing firearms after a felony conviction under 18 U.S.C. § 922(g)(1) and after a misdemeanor crime of domestic violence under § 922(g)(9).The United States District Court for the Northern District of West Virginia granted Jacobs’ motion to dismiss both counts of the indictment. The district court, employing the framework from New York State Rifle & Pistol Association v. Bruen, found that the government failed to demonstrate a historical tradition of disarming individuals like Jacobs—nonviolent felons and domestic violence offenders. The court concluded that both statutes were unconstitutional as applied to Jacobs and dismissed the charges without reaching the facial challenges.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s rulings de novo. The Fourth Circuit held that recent decisions—including United States v. Rahimi, United States v. Canada, United States v. Hunt, and United States v. Nutter—foreclose Jacobs’ facial and as-applied challenges to § 922(g)(1) and his facial challenge to § 922(g)(9). Accordingly, the court reversed the district court’s dismissal of the § 922(g)(1) charge and barred Jacobs from reviving those challenges. However, the Fourth Circuit determined that further proceedings were necessary regarding Jacobs’ as-applied challenge to § 922(g)(9), vacated the district court’s ruling on that count, and remanded for additional factfinding and analysis. View "United States v. Jacobs" on Justia Law

Plaintiffs, consisting of individuals and gun rights organizations, challenged multiple Maryland statutes and regulations that prohibit the carrying of firearms in a range of locations, including government buildings, mass transit, school grounds, public demonstrations, state parks and forests, healthcare facilities, places of amusement, locations selling alcohol, and private property. The plaintiffs claimed these laws violated their Second Amendment rights, arguing that the restrictions could not be justified under the Supreme Court’s “sensitive places” exception to the right to bear arms.The United States District Court for the District of Maryland consolidated the cases and ruled on cross-motions for preliminary injunction and summary judgment. It denied injunctive relief for most challenges, including those relating to museums, healthcare facilities, mass transit, state parks and forests, places of amusement, school grounds, and government buildings. However, it granted injunctive relief to plaintiffs for the restrictions on carrying guns on private property held open to the public, at public demonstrations, and at locations selling alcohol for on-site consumption. All summary judgment motions were initially denied without prejudice; on renewal, the district court granted summary judgment in part and denied it in part. Both sides appealed.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and issued a comprehensive decision applying Supreme Court precedent, particularly District of Columbia v. Heller and New York State Rifle & Pistol Association, Inc. v. Bruen. The Fourth Circuit affirmed the constitutionality of Maryland’s restrictions on carrying firearms in government buildings, mass transit, school grounds, state parks and forests, museums, healthcare facilities, stadiums, racetracks, amusement parks, and casinos. It also reversed the district court and upheld Maryland’s restrictions at public demonstrations and locations selling alcohol. However, the Fourth Circuit affirmed the district court’s ruling that Maryland’s ban on carrying firearms on private property held open to the public without express permission is unconstitutional, and found plaintiffs lacked standing to challenge the restriction on property not held open to the public. The judgment was affirmed in part and reversed in part. View "Kipke v. Moore" on Justia Law

Raymond Richardson was indicted for first-degree robbery under West Virginia law, specifically charged with using the threat of deadly force against Denise Cool to steal money. However, at trial, the prosecution presented evidence that Richardson accomplished the robbery by physically assaulting Cool rather than by threatening her with a deadly weapon. Richardson admitted to hitting Cool but denied taking her money. The jury found him guilty of first-degree robbery, assault during the commission of a felony, and possession with intent to deliver cocaine. The central issue on appeal concerned the alleged variance between the indictment and the State’s theory at trial.Following his conviction, Richardson sought post-conviction relief in state court, arguing that his trial counsel was ineffective for failing to object to the variance between the indictment and the evidence presented at trial. At an evidentiary hearing, Richardson and his trial counsel testified. Counsel acknowledged missing the indictment’s specific language but stated that the variance did not affect the defense strategy, which was focused on denying any theft rather than disputing the manner in which the robbery was committed. The state court denied habeas relief, finding Richardson had sufficient notice of the charges and was not prejudiced by the variance. The West Virginia Supreme Court of Appeals affirmed, concluding the difference between the indictment and trial evidence did not mislead Richardson or prejudice his defense.On federal habeas review, the United States District Court for the Southern District of West Virginia denied Richardson’s petition, finding he received adequate notice under the Fourteenth Amendment. The United States Court of Appeals for the Fourth Circuit affirmed, holding that the variance did not violate due process because Richardson was convicted of the offense charged, had actual notice of the evidence to be presented, and failed to show that the variance hindered his defense. The court found no ineffective assistance of counsel or prejudice and affirmed the district court’s denial of habeas relief. View "Richardson v. Frame" on Justia Law

William White, a federal prisoner serving a lengthy sentence, was transferred from one federal correctional institution to another, spending three days at a federal transfer center in Oklahoma City, where he was held in a Special Housing Unit for security reasons. During this brief transit period, he was not offered, nor did he participate in, any evidence-based recidivism reduction programming required under the First Step Act of 2018 (FSA). White later sought to have his time at the transfer center count toward FSA time credits, which could reduce his period of incarceration.The United States District Court for the District of Maryland denied White’s habeas corpus petition under 28 U.S.C. § 2241. The court found that the Bureau of Prisons’ (BOP) refusal to award FSA time credits for the three-day transfer period was consistent with BOP regulations and policy statements, which generally do not consider prisoners in transit or in certain housing statuses to be “successfully participating” in qualifying programs. The court also rejected White’s claim that his due process rights were violated, holding that the FSA does not create a protected liberty interest in earning time credits during every day of incarceration.Reviewing the case, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, under the plain text of the FSA, a prisoner is entitled to time credits only for days in which he actually participates in qualifying programming or productive activities. Because White did not participate in any such programming during his three days in transit, he was not statutorily entitled to those time credits. The court further held that the FSA does not create a constitutionally protected liberty interest in earning time credits, so the BOP’s actions did not violate due process. View "White v. Warden of Fed Correctional Ins - Cumberland" on Justia Law

Ali Al-Timimi, a respected lecturer at an Islamic center in Virginia, became acquainted with a group of young Muslim men who engaged in activities including paintball, which some saw as preparation for “jihad in the form of combat.” While Al-Timimi did not directly participate in these preparations, he offered advice on discretion after FBI attention. Following the September 11, 2001 attacks, Al-Timimi attended a gathering where he urged attendees to repent, leave the United States, and join militant groups abroad, including Lashkar-e-Taiba (LET) in Pakistan. His statements inspired several individuals to make concrete plans to travel overseas for training, though he did not provide operational details or set timelines. Some group members subsequently traveled to Pakistan but did not engage in combat.The United States District Court for the Eastern District of Virginia indicted and convicted Al-Timimi on multiple counts, including conspiracy, solicitation, and aiding terrorist groups. He was sentenced to life imprisonment and other consecutive terms. Over two decades, his case saw numerous appeals and remands, including vacatur of certain counts based on changes in law regarding “crimes of violence” (as in Johnson v. United States and United States v. Davis). Ultimately, Al-Timimi appealed his remaining convictions (Counts 2–6, 9, and 10), asserting First Amendment protection for his speech.The United States Court of Appeals for the Fourth Circuit reviewed de novo whether Al-Timimi’s speech constituted unprotected incitement, solicitation, or facilitation of criminal acts. The court held that his speech, though inflammatory and disturbing, did not incite imminent lawless action nor did it intentionally solicit or assist a specific crime. As his advocacy did not meet the narrow exceptions to First Amendment protection, the court vacated Al-Timimi’s remaining convictions and remanded for judgments of acquittal. View "US v. Al-Timimi" on Justia Law

Two plainclothes detectives in Baltimore, acting on a tip about drug activity, observed Robert Gary Moore and another individual near a parked vehicle. When approached, Moore dropped a plastic bag and fled but was apprehended. The police recovered the bag, which was later analyzed in a laboratory report stating it contained cocaine. During Moore’s trial for possession and possession with intent to distribute, the State introduced two chain-of-custody reports: one disclosed before trial and another (the ECU report) disclosed only mid-trial. The latter did not mention the chemist who performed the analysis, raising questions about whether the correct bag was tested. Moore’s counsel did not object to the late disclosure or use the discrepancy in his defense. Moore was convicted by a jury.After his conviction was affirmed on appeal by Maryland’s intermediate appellate court, Moore sought postconviction relief in Maryland state court, arguing that the State’s belated disclosure of the ECU report violated his due process rights under Brady v. Maryland and that his counsel was ineffective. The Maryland trial court initially granted relief under Brady but, upon remand from the intermediate appellate court for further factfinding, ultimately denied both claims, finding that disclosure during trial did not constitute suppression under Brady. Moore’s application for leave to appeal this denial was rejected.Moore then filed a federal habeas petition in the United States District Court for the District of Maryland. The district court found a Brady violation and granted habeas relief, ordering Moore’s conviction vacated unless retried within sixty days. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the state court had unreasonably applied federal law and that a Brady violation warranted habeas relief. However, it held that federal district courts lack authority to vacate state convictions directly and thus vacated the district court’s order, remanding for a new order consistent with the proper bounds of federal habeas relief. View "Moore v. State of Maryland" on Justia Law

Adrian Roberts, a military veteran suffering from severe mental health issues, was the subject of an involuntary commitment order after his wife raised concerns about his safety and possession of weapons. Law enforcement officers, including a specially trained response team, attempted to execute the order, initially trying to persuade Adrian to leave his home peacefully. When he refused, the team forcibly entered his residence. Shortly after entry, Deputy Evans shot and killed Adrian. The circumstances surrounding the shooting were disputed: Evans claimed Adrian charged at officers with a machete, while Adrian’s wife alleged he was shot in the back while facing away.The United States District Court for the Eastern District of North Carolina reviewed the case after Adrian’s wife brought claims under 42 U.S.C. § 1983, alleging excessive force and unlawful entry. The district court granted Evans qualified immunity and summary judgment on the unlawful entry claim but denied both on the excessive force claim. The court found that genuine disputes of material fact existed, particularly regarding whether Adrian posed an immediate threat or was resisting arrest, and relied on the autopsy report suggesting Adrian may have been shot from behind. Because these factual disputes remained, the court concluded that a reasonable jury could find Evans violated Adrian’s clearly established rights.On appeal, the United States Court of Appeals for the Fourth Circuit considered whether it had jurisdiction to review the district court’s denial of qualified immunity and summary judgment on the excessive force claim. The Fourth Circuit held that it lacked jurisdiction because the district court’s decision was based on unresolved factual disputes rather than purely legal questions. The court emphasized it could not weigh evidence or resolve factual disputes at this stage, and dismissed the appeal for lack of jurisdiction. View "Roberts v. Evans" on Justia Law

The case concerns the fatal shooting of Kwamena Ocran by four Gaithersburg Police Department officers in January 2021. Ocran, who had recently been released from prison and was reported by a confidential informant to be armed, was surveilled by the officers after the informant indicated Ocran might attempt to sell a handgun. When Ocran left an apartment with the informant and was approached by the officers, he fled. The officers pursued him, and during the chase, multiple officers reported seeing a muzzle flash and believed Ocran fired a weapon in their direction. The officers collectively discharged 27 rounds, resulting in Ocran’s death. Forensic evidence revealed Ocran was shot multiple times in the back, and a handgun was found near his body, though no evidence indicated it had been fired.After discovery, Melody Cooper, Ocran’s mother and personal representative, brought a 42 U.S.C. § 1983 claim alleging excessive force in violation of the Fourth Amendment. The United States District Court for the District of Maryland denied the officers’ motion for summary judgment and rejected their claim of qualified immunity, finding genuine disputes of material fact existed—particularly regarding whether Ocran pointed or fired his weapon at the officers. The court also denied the officers’ motion for reconsideration.On appeal, the United States Court of Appeals for the Fourth Circuit dismissed the officers’ appeal to the extent it challenged the district court’s findings of disputed material facts, as such findings are not reviewable under the collateral order doctrine. The Fourth Circuit affirmed the district court’s ruling that, accepting the undisputed facts, the officers were not entitled to qualified immunity because the right to be free from deadly force when fleeing and not posing a significant threat was clearly established at the time of the incident. The case was remanded for further proceedings, including a jury trial. View "Cooper v. Doyle" on Justia Law

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