Justia Constitutional Law Opinion Summaries

Four individuals aged 18 to 20 sought to purchase handguns but were prohibited by 18 U.S.C. § 922(b)(1), which restricts the commercial sale of handguns to those under 21. They filed a lawsuit against the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), claiming that the statute violated their Second Amendment rights.The United States District Court for the Eastern District of Virginia granted summary judgment in favor of the plaintiffs. The court applied the text, history, and tradition test from New York State Rifle & Pistol Ass’n v. Bruen, determining that the Second Amendment protections apply to 18- to 20-year-olds and that the right to purchase a gun falls within the Amendment’s plain text. The court found that the government failed to demonstrate a historical tradition of firearm regulation supporting the constitutionality of § 922(b)(1).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that § 922(b)(1) does not violate the Second Amendment. The court reasoned that historical traditions, including the common law infancy doctrine, supported restrictions on the sale of firearms to individuals under 21. The court found that both the infancy doctrine and § 922(b)(1) imposed similar burdens on minors' ability to purchase firearms and were motivated by concerns about the judgment and maturity of individuals under 21. The court concluded that § 922(b)(1) is consistent with the nation's historical tradition of firearm regulation and is therefore constitutional. The case was remanded with instructions to dismiss it. View "McCoy v. Bureau of Alcohol, Tobacco, Firearms and Explosives" on Justia Law

Martin Misjuns, a Fire Captain and paramedic with the Lynchburg Fire Department, was terminated after posting offensive social media content targeting transgender individuals. Misjuns alleged that his termination was due to his political and religious views, which he expressed on his Facebook pages. He claimed that the City of Lynchburg and its officials conspired to violate his constitutional rights, leading to his firing.The United States District Court for the Western District of Virginia dismissed all of Misjuns' claims. The court found that the claims against the individual defendants in their official capacities were duplicative and dismissed them. The court also dismissed Misjuns' breach of contract, equal protection, conspiracy, and wrongful termination claims. The court partially dismissed his First Amendment claims but later dismissed them entirely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Misjuns' claims. The court held that Misjuns failed to establish Monell liability against the City of Lynchburg, as he did not adequately plead that a policy or custom caused the alleged constitutional violations. The court also found that the City's Employment Policies & Procedures handbook did not constitute a binding contract, thus dismissing the breach of contract claim. Additionally, the court upheld the dismissal of the conspiracy and wrongful termination claims against the individual defendants, as those claims were not asserted against the City and had been dismissed by agreement.The Fourth Circuit concluded that Misjuns did not sufficiently plead facts to state a claim for relief on any of his six claims, affirming the district court's decision. View "Misjuns v. City of Lynchburg" on Justia Law

T.M. has a medical condition that causes psychosis when she ingests gluten. After an episode in 2023, she was involuntarily committed to Baltimore Washington Medical Center. Despite her and her father's request for voluntary admission, an administrative hearing led to her involuntary commitment. A clinical review panel approved forcibly injecting T.M. with antipsychotic medication, a decision affirmed by a Maryland administrative law judge. T.M. and the medical center later reached an oral agreement for her release, which was formalized in a consent order by a state court. The consent order required T.M. to follow certain conditions, including taking prescribed medications and dismissing other lawsuits.The United States District Court for the District of Maryland dismissed T.M.'s claims, citing the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court found it lacked subject matter jurisdiction over T.M.'s claims and dismissed the parents' claims for failure to state a claim. T.M.'s claims were dismissed with prejudice, while the parents' claims were dismissed without prejudice.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of T.M.'s claims for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The court held that T.M. was a state court loser seeking to overturn a state court judgment, which is barred by the doctrine. The court vacated the dismissal with prejudice and remanded with instructions to modify the judgment to dismiss T.M.'s claims without prejudice. The court also affirmed the dismissal of the parents' claims for failure to state a claim, noting that the complaint did not allege a violation of their First Amendment rights. View "T.M. v. University of Maryland Medical System Corporation" on Justia Law

In October 2022, NCIS investigators obtained a military warrant to seize but not search Joshua Lee Ray's cell phone. Despite this, they searched the phone and found evidence of child sexual abuse material. Ray moved to suppress the evidence, arguing the search violated the Fourth Amendment as the warrant did not authorize it. The district court granted the motion.The Government appealed, conceding the warrant did not authorize the search, there was no verbal authorization, and the warrant did not incorporate an affidavit requesting authorization. The Government argued the search was justified under the good faith exception.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the Government could not rely on the good faith exception because the warrant was not deficient; it simply did not authorize the search. The court emphasized that the NCIS exceeded the scope of the valid warrant, and the good faith exception did not apply to such conduct. The court affirmed the district court's decision to suppress the evidence. View "US v. Ray" on Justia Law

The National Association of Immigration Judges (NAIJ) challenged an Executive Office for Immigration Review (EOIR) policy requiring immigration judges to obtain prior approval before speaking publicly on immigration-related issues. NAIJ argued that this policy violated the First and Fifth Amendment rights of its members. The district court dismissed the case for lack of subject matter jurisdiction, concluding that the Civil Service Reform Act (CSRA) provided the exclusive remedy for such claims, requiring them to be brought through the administrative procedures established by the CSRA.The United States District Court for the Eastern District of Virginia dismissed the case, determining that the CSRA's comprehensive scheme for reviewing personnel actions against federal employees precluded the district court from exercising jurisdiction. The district court held that NAIJ's members must pursue their claims through the CSRA's administrative process, which includes review by the Merit Systems Protection Board (MSPB) and potential judicial review by the Federal Circuit.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court's decision. The Fourth Circuit held that while the CSRA generally precludes district court jurisdiction over such claims, the current functionality and independence of the MSPB and the Office of Special Counsel (OSC) were in question. The court noted that recent events, including the removal of the Special Counsel and the lack of a quorum in the MSPB, raised concerns about whether the CSRA's adjudicatory scheme was functioning as Congress intended. The Fourth Circuit remanded the case to the district court to conduct a factual inquiry into whether the CSRA continues to provide a functional and independent review process, as required for the jurisdiction-stripping scheme to apply. View "Natl Assn of Immigration Judges v. Owen" on Justia Law

Samuel Joseph was convicted of drug and firearm offenses. He appealed the district court's denial of his motion to suppress evidence seized during two encounters with law enforcement. The first encounter occurred in Charleston, West Virginia, where an officer, after receiving a tip about possible drug activity, observed Joseph's suspicious behavior and items consistent with drug distribution in a motel room. Joseph was apprehended after fleeing from officers, and a search of his duffel bag, which he abandoned during the chase, revealed drugs and firearms.The United States District Court for the Southern District of West Virginia denied Joseph's motion to suppress the evidence obtained during the encounters. Joseph argued that the officers lacked reasonable suspicion to stop him and that the search and seizure violated his Fourth Amendment rights. The district court found that the officers had reasonable suspicion based on their observations and Joseph's behavior, and that the subsequent search and seizure were lawful.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that the officers had reasonable suspicion to stop Joseph based on their observations and his unprovoked flight. The court also found that the officers' actions following the stop, including the use of a drug-detection dog and obtaining a search warrant for the duffel bag, were permissible and did not violate the Fourth Amendment. Additionally, the court rejected Joseph's arguments regarding the lack of bodycam footage and the reliability of the initial tip, as well as his claim that the traffic stop in Parkersburg was impermissibly prolonged. The court concluded that the district court's factual findings were not clearly erroneous and upheld the denial of the motion to suppress. View "United States v. Joseph" on Justia Law

The plaintiffs in this case are parents of children with special needs attending public schools in Fairfax County, Virginia. They allege that the transition to remote learning during the COVID-19 pandemic constituted an unconstitutional "taking" of their children's Fifth Amendment property interest in public education. The plaintiffs argue that Virginia law establishes a fundamental right to public education, which they claim is a protected property interest under the Fourteenth Amendment's Due Process Clause and, by extension, should be considered private property under the Takings Clause.The United States District Court for the Eastern District of Virginia dismissed the plaintiffs' complaint for failure to state a claim under Rule 12(b)(6). The court reasoned that while the right to public education in Virginia may be a protected property interest under the Due Process Clause, it does not necessarily qualify as private property under the Takings Clause. The court noted that federal courts have long interpreted property interests protected by the Takings Clause as narrower than those protected by the Due Process Clause. The district court concluded that the right to public education is subject to regulation and revision by the Virginia government and cannot be bought or sold, distinguishing it from private property.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and affirmed the district court's judgment. The Fourth Circuit agreed that the plaintiffs' children may have a property interest in public education under the Due Process Clause but held that this does not extend to the Takings Clause. The court emphasized that the Takings Clause applies only to private property and that public education, being subject to government regulation and not possessing the characteristics of private property, does not qualify. The court concluded that the plaintiffs failed to state a plausible claim for compensation under the Takings Clause. View "Chollet v. Brabrand" on Justia Law

The case involves the City of Myrtle Beach's response to a surge in violent crime in an area known as "the Superblock." Between 2015 and 2016, eleven people were shot, and dozens more were sexually assaulted, battered, or robbed in the Superblock, primarily around a small cluster of bars. The City increased police presence and investigated these establishments for compliance with safety regulations. Despite these measures, crime persisted, leading the City to shut down two bars for repeated legal violations, while a third bar closed due to lack of business. Years later, the bars and the landlord sued the City and the City Manager, alleging violations of the Takings Clause, Due Process Clause, Equal Protection Clause, and 42 U.S.C. § 1985, claiming the City unlawfully targeted them because their owners and clientele were predominantly racial minorities.The United States District Court for the District of South Carolina granted directed verdicts for the City on all claims during a jury trial. The court held that the appellants did not have a constitutionally protected property interest in the right to conduct their business. It found that the City's enforcement actions were within the legitimate bounds of state police power and rejected the § 1985 civil conspiracy claims based on the intra corporate conspiracy doctrine, which states that corporate and government agents cannot conspire with themselves.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court held that the City acted within its lawful authority to address serious public safety threats and enforce compliance with state and local regulations. The appellants' claims were deemed speculative and unsupported by the evidence presented at trial. The court found no discriminatory intent or violation of due process, and it upheld the application of the intra corporate conspiracy doctrine, concluding that the City officials did not possess a personal stake independent of their relationship to the City. View "Brady v. City of Myrtle Beach" on Justia Law

David Nutter was indicted in August 2021 for violating 18 U.S.C. § 922(g)(9), which prohibits individuals with convictions for misdemeanor crimes of domestic violence from possessing firearms or ammunition. Nutter had three prior convictions in Ohio for domestic violence and child endangerment. He acknowledged possessing firearms and did not dispute his prior convictions but moved to dismiss the indictment, arguing that § 922(g)(9) violated the Second Amendment.The United States District Court for the Southern District of West Virginia denied Nutter's motion, applying the means-end analysis from District of Columbia v. Heller. Nutter entered a conditional guilty plea, reserving the right to appeal the denial of his motion. After the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen, which rejected the means-end analysis, Nutter filed a second motion to dismiss, arguing that § 922(g)(9) was unconstitutional under the new framework. The district court again denied the motion, concluding that § 922(g)(9) was consistent with the Nation's history and tradition of disarming individuals deemed a threat to public safety.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that § 922(g)(9) is facially constitutional, finding that it fits within the historical tradition of disarming individuals who pose a credible threat to the physical safety of others. The court noted that the statute's purpose and method align with historical analogues, such as surety and going armed laws, which were designed to mitigate demonstrated threats of physical violence. The court affirmed the district court's denial of Nutter's motion to dismiss the indictment and upheld his conviction. View "United States v. Nutter" on Justia Law

In 2019, Navient Solutions, LLC, a student loan servicer, filed a civil action alleging that a group of lawyers, marketers, and debt-relief businesses conspired to defraud Navient out of millions of dollars in unpaid student debt. Navient claimed that the defendants lured student borrowers into filing sham lawsuits against Navient under the Telephone Consumer Protection Act (TCPA), which regulates abusive telemarketing practices. The case proceeded to trial, and a jury found in favor of Navient. However, the district court later granted the defendants' renewed motions for judgment as a matter of law, ruling that the TCPA suits were not sham litigation and setting aside the jury's verdicts.The United States District Court for the Eastern District of Virginia initially rejected the defendants' argument that their litigation activities were protected under the Noerr–Pennington doctrine, which safeguards the First Amendment right to petition the government. After the jury returned verdicts against each defendant, the district court vacated the verdicts, concluding that the TCPA litigation was not sham litigation and that Navient's damages were directly related to the TCPA litigation.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that the TCPA actions were not sham litigation and were protected under the Noerr–Pennington doctrine. The court found that the defendants' actions were based on a legitimate question of statutory interpretation regarding the definition of an automatic telephone dialing system (ATDS) under the TCPA. The court also noted that Navient had conceded the merits of the TCPA cases and had only sought damages related to the litigation costs. As a result, the court concluded that the defendants' petitioning activity was protected by the First Amendment, and the district court's judgment as a matter of law was appropriate. View "Navient Solutions, LLC v. Lohman" on Justia Law