Justia Constitutional Law Opinion Summaries

A high school social studies teacher with a history of disciplinary issues was terminated after posting inflammatory messages on her Facebook account, which was followed primarily by former students. The posts, made during nationwide protests following the killing of George Floyd, included comments and memes that were perceived as racially insensitive and vulgar. Although the teacher had set her account to private and did not accept friend requests from current students, the posts quickly circulated within the school community, prompting complaints from students, parents, staff, and widespread media attention. The school district cited her prior suspensions for similar conduct, the disruption caused by her posts, and her failure to appreciate the impact of her comments as reasons for her dismissal.After her termination, the teacher requested a review hearing before the Illinois State Board of Education, where she argued that her Facebook posts were protected by the First Amendment. The hearing officer applied the Pickering balancing test and found that her dismissal did not violate her constitutional rights. Subsequently, the teacher filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the school district and associated individuals under 42 U.S.C. § 1983, alleging a First Amendment violation. The district court granted summary judgment for the defendants, finding that she was collaterally estopped from bringing her claim and, alternatively, that her claim failed on the merits.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the teacher failed to present sufficient evidence for a reasonable juror to find in her favor on her First Amendment claim. Applying the Pickering balancing test, the court concluded that the school district’s interest in addressing actual and potential disruption outweighed the teacher’s interest in free expression, and her posts were not entitled to First Amendment protection. View "Hedgepeth v Britton" on Justia Law

The plaintiff, an Illinois prisoner, was involved in a physical altercation with several correctional officers at Stateville Correctional Center. Following the incident, he was transferred to Pontiac Correctional Center, where he received medical treatment. He was issued a disciplinary ticket for a major infraction, which led to an adjustment committee hearing at Pontiac. At the hearing, he was allowed to present his side but was not permitted to call witnesses or view video evidence. The committee recommended several disciplinary measures, including three months of solitary confinement in conditions the plaintiff later described as appalling, with unsanitary and unsafe features.The plaintiff filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the disciplinary committee members and the warden violated his Fourteenth Amendment rights by imposing solitary confinement without sufficient procedural protections. The defendants moved for summary judgment, arguing that the plaintiff had not established a protected liberty interest, had not shown inadequate procedures, and that they were entitled to qualified immunity. The district court granted summary judgment for the defendants, finding that three months in segregation, even with harsh conditions, did not amount to a deprivation of a liberty interest protected by due process.On appeal, the United States Court of Appeals for the Seventh Circuit disagreed with the district court’s conclusion regarding the liberty interest, holding that the plaintiff’s evidence of three months in unusually harsh and unsanitary solitary confinement raised a genuine issue of material fact about deprivation of a protected liberty interest. However, the Seventh Circuit affirmed the judgment for the defendants, holding that they were entitled to qualified immunity because the law was not clearly established at the time of the plaintiff’s confinement. The court clarified that, going forward, short terms of solitary confinement combined with comparably harsh conditions will suffice to show a protected liberty interest requiring procedural protections. View "Jackson v. Anastacio" on Justia Law

A high school student sought to establish a pro-life student club at her public high school. The school promptly approved the club after she followed the required procedures, including securing a faculty sponsor and submitting a club questionnaire. The student actively promoted the club at the school’s activities fair, wearing pro-life apparel and displaying related signs. The dispute arose when the student submitted flyers containing political slogans and images for posting on school walls. Administrators instructed her to revise the flyers to comply with the school’s neutral content policy, which limited flyers to the club’s name and meeting details and excluded political content. Instead of revising the flyers, the student and her mother approached another administrator to seek approval, which led the principal to suspend the club’s status for the semester, citing concerns that the club was no longer student-led and that established procedures had been violated. The student was allowed to reapply, and the club was later reinstated.The student and her parents filed suit in the United States District Court for the Southern District of Indiana, alleging violations of the First Amendment and the Equal Access Act, claiming that the rejection of the flyers and the club’s suspension were motivated by hostility to her pro-life views. The district court granted summary judgment to the school district and officials, finding no constitutional or statutory violations.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The Seventh Circuit held that the school’s restriction on political content in student club flyers was a reasonable, viewpoint-neutral policy related to legitimate pedagogical concerns under Hazelwood School District v. Kuhlmeier. The court also found that the temporary suspension of the club was based on neutral, conduct-related reasons and not on the student’s viewpoint. The court further held that there was no violation of the Equal Access Act and that the plaintiffs had not preserved a separate claim regarding the flyers under that statute. View "E.D. v Noblesville School District" on Justia Law

A man living with his partner and her two young children in Indiana was convicted of murdering the children and setting fire to their home. Prior to the incident, he exhibited suspicious behavior, including quitting his job, withdrawing his savings, and making threatening statements. On the night of the crime, he bound one child, gathered belongings, and fled the state. The children’s bodies were found after the house fire, and he was apprehended in Kentucky following a police chase. After being read his rights in the hospital, he gave a brief, largely uninformative statement to police.He was charged with two counts of murder and arson. At trial, the jury found him guilty and recommended the death penalty, which the judge imposed. During the trial, a juror brought a note and cookies from his wife, referencing the victims, but the court found this did not prejudice the jury after questioning them and dismissed the juror. The Indiana Supreme Court affirmed the convictions and sentence. The defendant then sought postconviction relief in Indiana state court, arguing ineffective assistance of counsel, but the trial court denied relief, and the Indiana Supreme Court affirmed, with some justices partially dissenting on the prejudice issue.The defendant filed a federal habeas petition in the United States District Court for the Southern District of Indiana, raising over 30 claims, including ineffective assistance of counsel, juror bias, and evidentiary issues. The district court denied most claims as procedurally defaulted and found the rest without merit, also denying requests for stays and additional funding. On appeal, the United States Court of Appeals for the Seventh Circuit held that most claims were procedurally defaulted, the district court did not abuse its discretion in denying stays or funding, and the Indiana Supreme Court’s decisions were neither unreasonable applications of federal law nor based on unreasonable factual determinations. The Seventh Circuit affirmed the district court’s denial of habeas relief and related motions. View "Weisheit v Neal" on Justia Law

Edward Flynn was killed when a fleeing suspect, James Shirley, crashed into his car during a high-speed police pursuit. The incident began when Indianapolis police officers attempted to investigate a potentially stolen truck. Shirley, the suspect, backed into a patrol car and nearly struck two officers before fleeing. Multiple officers engaged in a pursuit that lasted about five and a half minutes, during which Shirley drove recklessly, including turning off his lights, running stop signs and red lights, and reaching high speeds. The chase ended when Shirley ran a red light and collided with Edward Flynn’s vehicle, resulting in Flynn’s death.Gayl Flynn, representing Edward’s estate, filed suit in the United States District Court for the Southern District of Indiana against the City and five officers. She alleged violations of Edward’s Fourteenth Amendment substantive due process rights and claimed the City failed to properly train its officers, invoking Monell v. Department of Social Service of New York. The district court granted summary judgment for the defendants, applying the “intent to harm” standard for Fourteenth Amendment liability in emergency situations and finding no such intent by the officers.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed that the facts presented an emergency situation, making the “intent to harm” standard appropriate. The court found that the officers did not act with intent to harm and that the circumstances did not support a claim under a deliberate indifference standard. Because there was no underlying constitutional violation, the Monell claim against the City also failed. The Seventh Circuit affirmed the district court’s grant of summary judgment to all defendants. View "Flynn v Consolidated City of Indianapolis and Marion County" on Justia Law

Israel Isbell pleaded guilty in 2010 to receipt of child pornography and was sentenced to 180 months in prison followed by a lifetime of supervised release. As his prison term ended, Isbell violated several conditions of his supervised release, including unauthorized internet use and unsuccessful participation in sex offender and substance abuse treatment programs. These violations led to the revocation of his supervised release, an additional prison term, and a new term of supervised release with specific conditions.After a prior appeal resulted in a remand for resentencing on an unrelated issue, the United States District Court for the Central District of Illinois resentenced Isbell to 16 months’ imprisonment and 8 years of supervised release. Isbell objected to three conditions: a requirement to participate in a computer and internet monitoring program, a provision regarding medical marijuana use during treatment, and a mandate for substance abuse treatment. The district court overruled his objections and imposed the conditions as proposed.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Isbell’s challenges de novo. The court held that the computer monitoring condition was neither unconstitutionally vague nor overbroad, as its language and purpose provided sufficient notice and guidance. The court also found that the medical marijuana provision did not improperly delegate judicial authority to treatment providers, as it required Isbell to follow generally applicable program rules rather than allowing providers to determine the existence of the condition. Finally, the court determined that the written judgment requiring substance abuse treatment was consistent with the oral pronouncement and did not violate the non-delegation rule. The Seventh Circuit affirmed the judgment of the district court. View "USA v Isbell" on Justia Law

Indiana enacted a statute making it a misdemeanor for a person to knowingly or intentionally approach within 25 feet of a law enforcement officer who is lawfully engaged in official duties, after being ordered by the officer to stop approaching. Several media organizations and news outlets challenged this law, arguing that it is unconstitutionally vague under the Fourteenth Amendment because it allows police officers too much discretion in deciding when to issue a do-not-approach order, potentially leading to arbitrary or discriminatory enforcement. The plaintiffs asserted that the law chills their newsgathering activities, as journalists often need to approach police officers in public spaces to report on events.The United States District Court for the Southern District of Indiana denied the State’s motion to dismiss for lack of standing, finding that the plaintiffs had sufficiently alleged injury in fact. The district court then granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on their Fourteenth Amendment vagueness claim, would suffer irreparable harm without relief, and that the balance of harms and public interest favored an injunction. The court did not address the plaintiffs’ First Amendment claims. The State appealed the preliminary injunction to the United States Court of Appeals for the Seventh Circuit, arguing that the law was not unconstitutionally vague and that the plaintiffs lacked standing.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s preliminary injunction. The appellate court held that the plaintiffs had standing and that the case was not moot, even though a second, narrower buffer law had been enacted. The court found that the original buffer law was unconstitutionally vague because it gave law enforcement officers unfettered discretion to decide when to issue a do-not-approach order, thus encouraging arbitrary or discriminatory enforcement. The court remanded the case for the district court to reconsider the appropriate scope of the injunction in light of recent Supreme Court precedent limiting universal injunctions. View "Reporters Committee for Freedom of the Press v. Rokita" on Justia Law

Nathan Nissenbaum was convicted in Illinois state court of aggravated criminal sexual assault, home invasion, aggravated kidnapping, and aggravated domestic battery after an incident involving his former girlfriend, D.K. The evidence at trial included testimony from D.K., physical evidence, and Nissenbaum’s own admissions. Nissenbaum’s defense was that the encounter was consensual, based on their prior relationship and history of “rape play.” He was sentenced to 14 years’ imprisonment.After his conviction, Nissenbaum filed a post-trial motion in the Illinois state court, alleging ineffective assistance of counsel. He claimed his attorney failed to properly advise him about the risk of mandatory consecutive sentences and his realistic chances at trial, which he argued led him to reject a plea deal that would have resulted in a lesser sentence. The trial court held an evidentiary hearing and found that Nissenbaum had not demonstrated ineffective assistance, concluding he was adequately informed and would not have accepted a plea regardless. The Illinois Appellate Court affirmed, finding no prejudice from any alleged deficiencies, and the Illinois Supreme Court denied further review.Nissenbaum then sought federal habeas relief in the United States District Court for the Northern District of Illinois under 28 U.S.C. § 2254, renewing his ineffective assistance claim. The district court denied the petition, holding that the Illinois Appellate Court had not unreasonably applied federal law in finding no prejudice. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed, holding that the state court’s decision was not contrary to or an unreasonable application of clearly established Supreme Court precedent. The Seventh Circuit found that Nissenbaum failed to show a reasonable probability he would have accepted a plea offer but for counsel’s alleged errors, and thus habeas relief was barred. View "Nissenbaum v. Jennings" on Justia Law

Madeline Krasno sued the University of Wisconsin–Madison after her comments on the University's social media posts were hidden and her Instagram account was restricted. Krasno alleged that these actions violated her First Amendment rights, as she was advocating against animal abuse in the University's primate testing facilities. The University defended its actions by claiming that it was hiding "off-topic" comments.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the University, finding that the University's social media comment threads were nonpublic forums and that the University's moderation decisions were reasonable and viewpoint neutral. The district court also held that Krasno lacked standing to seek an injunction against the University's use of keyword filters.The United States Court of Appeals for the Seventh Circuit disagreed with the district court's findings. The appellate court determined that Krasno had standing to bring her as-applied challenge and concluded that the University's social media comment threads were limited public forums. The court held that the University's off-topic comment rule was neither reasonable nor viewpoint neutral, making it unconstitutional under the First Amendment. The court reversed the district court's summary judgment in favor of the University and remanded the case with instructions to enter judgment for Krasno. View "Krasno v. Mnookin" on Justia Law

Mitchell Green was charged with trafficking a child and related offenses in Milwaukee County Circuit Court. During his trial, Green called his cousin, Jonathan Cousin, as a witness, who testified that he, not Green, had driven the minor to a hotel. The state did not initially object to Cousin's testimony but later argued that Green failed to provide pretrial notice as required for a "Denny witness," leading the judge to declare a mistrial. Green, out on bond, argued that a retrial would violate his constitutional right against double jeopardy.The trial court denied Green's motion to dismiss, and the Court of Appeals of Wisconsin held that the mistrial was erroneous. However, the Supreme Court of Wisconsin sided with the trial judge, finding that he exercised sound discretion in declaring a mistrial. Green then filed a collateral attack, and the district court denied relief, leading to this appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the trial judge's decision to declare a mistrial was based on a mistaken belief that pretrial notice for Denny evidence was required. The court noted that no such requirement existed in Wisconsin law. The trial judge failed to exercise sound discretion by not considering alternatives to a mistrial, such as a continuance. The Seventh Circuit held that there was no manifest necessity for the mistrial, and thus, a retrial would violate the Double Jeopardy Clause. The judgment of the district court was reversed, and the case was remanded with instructions to issue an unconditional writ. View "Green v. Milwaukee County Circuit Court" on Justia Law