Justia Constitutional Law Opinion Summaries

Police investigating a fatal drive-by shooting in Philadelphia identified several suspects, including T.C., and obtained an arrest warrant for him. Detectives used multiple databases, including CLEAR and police records, to determine T.C.’s last known address, which pointed to 4838 Stenton Avenue. Believing T.C. resided there, detectives and a SWAT team executed the warrant early one morning. Instead of finding T.C., officers encountered Richard Miller and Tonya Crawley, who had lived at the residence for two years and were not connected to T.C. The officers detained Miller and Crawley briefly and then left after learning T.C. was not present. T.C. was later located and cleared of wrongdoing.Miller and Crawley sued the involved officers and the City of Philadelphia in the United States District Court for the Eastern District of Pennsylvania under 42 U.S.C. § 1983, alleging that the officers lacked probable cause and violated the Fourth Amendment, and that the City failed to train or supervise its officers. The District Court dismissed the municipal-liability claim for failure to state a claim and granted summary judgment to the officers on the unlawful-entry claim, holding that they had probable cause to enter the residence.On appeal, the United States Court of Appeals for the Third Circuit reviewed both the dismissal and summary judgment de novo. The court held that, although the District Court incorrectly invoked the good-faith exception, the error was harmless because the officers had probable cause to believe T.C. lived at the address and would likely be home at the early hour. The court also held that the plaintiffs failed to allege facts sufficient to establish municipal liability, as there was no pattern of similar constitutional violations or plausible basis for single-incident liability. The Third Circuit affirmed the District Court’s decisions. View "Miller v. City of Philadelphia" on Justia Law

A New Jersey physician wished to provide medical aid in dying to terminally ill patients, including nonresidents seeking this service under New Jersey’s law that permits doctor-assisted suicide. The relevant statute allows only New Jersey residents, with a prognosis of six months or fewer to live, to request and obtain a prescription for life-ending medication. Patients must demonstrate residency through various documents and satisfy several procedural safeguards. The plaintiff, a physician, challenged the law’s residency requirement after two terminally ill nonresidents who had joined the suit died during the course of litigation.The United States District Court for the District of New Jersey dismissed the complaint. The court reasoned that the right to receive medical aid in dying was neither a fundamental privilege nor a fundamental right requiring extension to nonresidents under the Privileges and Immunities Clause or the Equal Protection Clause. It further found the law was not economic protectionism and survived rational-basis review. The plaintiff appealed this decision.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. It held that New Jersey’s restriction of doctor-assisted suicide to its own residents does not violate the Privileges and Immunities Clause because there is no longstanding tradition making such access a fundamental privilege, nor does it violate the Equal Protection Clause, as there is no fundamental right to assisted suicide or to interstate travel for this purpose. The Third Circuit also determined that the law does not offend the dormant Commerce Clause since it is a moral rather than commercial regulation and does not discriminate against out-of-state economic interests. The court concluded that New Jersey’s residency requirement is constitutionally permissible, justified by the state’s interests in protecting doctors, avoiding interstate friction, and safeguarding patients. View "Bryman v. Murphy" on Justia Law

A woman with a lifelong hearing impairment obtained a commercial driver’s license (CDL) in New Jersey after receiving a federal exemption from the standard hearing requirement. This exemption allowed her to drive commercial vehicles in interstate commerce but specifically prohibited her from operating passenger vehicles or school buses. Despite this, she was mistakenly issued state endorsements permitting her to drive such vehicles and worked as a campus shuttle bus driver for about eight months. When the New Jersey Motor Vehicle Commission (NJMVC) realized the error, it revoked her passenger and school bus endorsements without providing a pre-revocation hearing.Instead of seeking review in New Jersey Superior Court, the woman filed suit in the United States District Court for the District of New Jersey. She alleged violations of Title II of the Americans with Disabilities Act, Section 504 of the Rehabilitation Act, and New Jersey’s Law Against Discrimination, as well as a procedural due process claim under 42 U.S.C. § 1983. The District Court dismissed some claims and ultimately granted summary judgment to the defendants on all remaining claims, finding she was not “qualified” for the endorsements and had no property interest in them.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The court held that the plaintiff was not a “qualified individual with a disability” under the relevant statutes because she could not meet the essential eligibility requirement of passing the hearing test for the endorsements. The court also held that, even assuming a property interest in the endorsements, due process did not require a pre-revocation hearing given the state’s strong safety interests and the availability of post-deprivation remedies. The court affirmed summary judgment for the defendants on all claims. View "Parker v. New Jersey Motor Vehicle Commission" on Justia Law

Two men were apprehended by the United States Coast Guard in international waters south of Puerto Rico after being observed jettisoning bales of cocaine from a vessel that lacked any indication of nationality. The Coast Guard recovered approximately 306 kilograms of cocaine and eventually transported the men, including the appellant, to St. Thomas in the U.S. Virgin Islands. The government asserted that the men were never brought to Puerto Rico, though the appellant disputed this. A grand jury in the District of the Virgin Islands indicted the appellant on multiple drug trafficking charges under the Maritime Drug Law Enforcement Act (MDLEA), as well as related offenses.The appellant moved to dismiss the indictment for improper venue, arguing that the MDLEA’s “any district” venue provision was unconstitutional and that venue was proper in Puerto Rico, where he claimed he was first brought. He also sought a pretrial evidentiary hearing on venue and the issuance of subpoenas for Coast Guard witnesses. The United States District Court of the Virgin Islands denied these motions, holding that the MDLEA’s venue provision was constitutional and that the Virgin Islands was a proper venue. The court also found that mere passage through Puerto Rico’s territorial waters did not constitute being “first brought” there under 18 U.S.C. § 3238, and denied the request for an evidentiary hearing, finding no colorable factual dispute that would affect the outcome.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit held that the MDLEA’s “any district” venue provision is constitutional, both facially and as applied, for offenses committed on the high seas. The court also found that the District Court did not abuse its discretion in denying a pretrial evidentiary hearing on venue. Accordingly, the Third Circuit affirmed the District Court’s orders. View "USA v. Cuevas-Almonte" on Justia Law

A federal inmate serving a 210-month sentence challenged the method used by the Federal Bureau of Prisons (BOP) to calculate his good conduct time credits under 18 U.S.C. § 3624(b)(1), as amended by the First Step Act of 2018. The inmate argued that, following the amendments, he should receive a full 54 days of good conduct time credit for the last six months of his sentence, rather than a prorated amount. The BOP, however, interpreted the amended statute to require prorating the credit for any partial year, resulting in the inmate receiving 26 days of credit for the final six months instead of 54.The United States District Court for the District of New Jersey denied the inmate’s habeas petition. The court found that the plain language of the amended statute allowed for proration of good conduct time credits for partial years. As an alternative basis, the District Court also relied on Chevron deference to uphold the BOP’s interpretation. The court rejected the inmate’s additional claims under the Administrative Procedure Act (APA) and the Due Process Clause, finding them either precluded by statute or inapplicable to the rulemaking context.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory interpretation de novo. The Third Circuit affirmed the District Court’s judgment, holding that the First Step Act’s amendments, while deleting the word “prorated,” introduced language (“for each year”) that sets a rate of 54 days per year, thereby requiring proration for any partial year. The court concluded that the statute’s natural reading supports the BOP’s method of prorating credits for the last portion of a sentence. The Third Circuit also rejected the inmate’s constitutional and APA-based arguments, and found no basis for applying the rule of lenity. View "Thieme v. Warden Fort Dix FCI" on Justia Law

A member of the Pennsylvania House of Representatives used public funds and the resources of the House Democratic Caucus to send five pre-recorded, automated phone calls to constituents. These calls provided information about public health resources, employment opportunities, and community events. The calls were approved and administered by House staff, who determined that each served a clear legislative purpose and public benefit. The recipient of these calls, Andrew Perrong, filed suit, alleging that the calls violated the Telephone Consumer Protection Act (TCPA), which generally prohibits automated or pre-recorded calls made by “any person.”The United States District Court for the Eastern District of Pennsylvania denied the legislator’s motion for summary judgment. The court held that the legislator was a “person” under the TCPA and could be sued in his individual capacity, even though the calls were made as part of his official duties. The District Court also found that the suit was not barred by Eleventh Amendment sovereign immunity, reasoning that the Commonwealth of Pennsylvania was not the real party in interest, and that qualified immunity did not apply because the statutory prohibition was clear.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory question and the immunity defenses. The Third Circuit held that the TCPA’s use of the term “person” does not clearly and unmistakably include state legislators acting in their official capacity when performing legitimate government functions. The court reasoned that longstanding interpretive presumptions, constitutional federalism principles, and statutory context all support excluding such official acts from the statute’s reach. As a result, the court reversed the District Court’s denial of summary judgment, holding that the TCPA’s robocall restriction does not apply to calls made by state legislators in connection with their legitimate government functions. View "Perrong v. Bradford" on Justia Law

Novo Nordisk, a pharmaceutical manufacturer, challenged the implementation of the Drug Price Negotiation Program established by the Inflation Reduction Act of 2022. The Program requires the Department of Health and Human Services, through the Centers for Medicare and Medicaid Services (CMS), to negotiate prices for certain high-expenditure drugs covered by Medicare. In the first round of selections, CMS grouped six of Novo Nordisk’s insulin aspart products as a single “negotiation-eligible drug” and selected them for price negotiation. Novo Nordisk signed the required agreements to participate but subsequently filed suit, arguing that CMS’s grouping of its products and the procedures used to implement the Program violated statutory and constitutional provisions.The United States District Court for the District of New Jersey granted summary judgment in favor of the government. The court found it lacked subject matter jurisdiction to review CMS’s decision to treat the six products as one drug due to a statutory bar on judicial review. It also held that Novo Nordisk lacked standing to challenge the identification of more than ten drugs for the initial pricing period. The court rejected Novo Nordisk’s claims under the unconstitutional conditions doctrine, the Due Process Clause, the nondelegation doctrine, and the First Amendment, concluding that the Program did not deprive the company of a protected property interest, that Congress provided an intelligible principle to guide CMS, and that the Program primarily regulated conduct rather than speech.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that the statutory bar on judicial review precluded consideration of Novo Nordisk’s challenge to the grouping of its products. The court also held that CMS was authorized to implement the Program through guidance for the initial years without notice and comment rulemaking, that the Act did not violate the nondelegation doctrine or the Due Process Clause, and that Novo Nordisk’s First Amendment claim was foreclosed by precedent. View "Novo Nordisk Inc. v. Secretary US Dept & Health and Human Services" on Justia Law

A Nigerian citizen who became a lawful permanent resident of the United States in 2005 was placed in removal proceedings after being convicted of conspiracy to commit passport fraud. He had lived in the U.S. for many years, had a long-term partner, and was the father of four U.S. citizen children. His conviction stemmed from a scheme to obtain fraudulent U.S. passports for noncitizens, for which he was sentenced to 27 months in prison. After serving his sentence and briefly fleeing to Canada, he was returned to the U.S. and charged as inadmissible for committing a crime involving moral turpitude. In removal proceedings, he applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), claiming past persecution and fear of future harm in Nigeria due to his former union activities and threats from a militia group.An Immigration Judge (IJ) found him inadmissible, denied all forms of relief, and determined that his conviction constituted a particularly serious crime, barring asylum and withholding. The IJ also found his and his partner’s testimony not credible and denied CAT relief, concluding he had not shown a likelihood of torture with government acquiescence. The Board of Immigration Appeals (BIA) affirmed, agreeing with the IJ’s findings and further holding that the absence of an interpreter did not violate due process, that the conviction was a particularly serious crime, and that he was not eligible for a waiver of inadmissibility.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the BIA misapplied the legal standard for determining a particularly serious crime by failing to consider the elements of the underlying substantive offense in the conspiracy conviction. The court also found that the BIA did not properly analyze the CAT claim under the required legal framework and failed to consider eligibility for a waiver of inadmissibility. The court denied the due process claim but vacated the BIA’s decision and remanded for further proceedings, ordering a stay of removal pending the outcome. View "Amos v. Attorney General United States of America" on Justia Law

A car leasing company leased a vehicle to an individual who defaulted on payments soon after the lease began. Despite having the right to repossess the car, the company did not do so. Two years later, the lessee was stopped by police in Butler, New Jersey, for driving with a suspended license, suspended registration, and no insurance. The police seized the car and had it towed by a contractor, Malanga’s Automotive. The lessee was informed of the tow but did not retrieve the vehicle. The towing company did not notify the leasing company that it possessed the car until nearly a year later, at which point it demanded payment of towing and storage fees before releasing the vehicle.The leasing company filed suit in the Superior Court of New Jersey against the towing company, later adding the Borough of Butler as a defendant and asserting claims under 42 U.S.C. § 1983 for violations of the Fourteenth Amendment’s Due Process Clause, the Fourth Amendment, and the Fifth Amendment. The case was removed to the United States District Court for the District of New Jersey, which granted summary judgment to Butler on all claims. The District Court found that the company had a property interest in the vehicle but concluded that Butler’s policies provided sufficient notice and opportunity to be heard, and that the seizure and retention of the vehicle were reasonable and did not constitute a taking.On appeal, the United States Court of Appeals for the Third Circuit held that Butler’s policies violated the Fourteenth Amendment’s Due Process Clause because they failed to require prompt notice to all holders of property rights in seized vehicles and did not provide an opportunity for a hearing to challenge the lawfulness of the tow or the fees. The court reversed and remanded the due process claim. However, it affirmed the District Court’s judgment on the Fourth and Fifth Amendment claims, finding no unreasonable seizure or unconstitutional taking. View "Honda Lease Trust v. Malanga's Automotive" on Justia Law

A pharmaceutical company challenged provisions of the Inflation Reduction Act of 2022, which established a program requiring the Department of Health and Human Services, through the Centers for Medicare and Medicaid Services (CMS), to negotiate maximum fair prices for certain high-cost prescription drugs covered by Medicare. The company’s drug was selected for the program, and it signed the required agreements to participate. The program imposes significant penalties and an excise tax on manufacturers who do not comply, but allows manufacturers to exit Medicare and Medicaid programs to avoid the tax, a process the company argued was not a realistic option.After its drug was selected, the company filed suit in the United States District Court for the District of New Jersey, alleging that the program violated the Eighth Amendment’s Excessive Fines Clause, the Fifth Amendment’s Takings Clause, and the First Amendment’s Free Speech Clause. The District Court granted summary judgment for the government, holding that participation in the program is voluntary and that the program primarily regulates conduct, not speech. The court also found it lacked jurisdiction over the Eighth Amendment claim due to the Tax Anti-Injunction Act and the Declaratory Judgment Act.On appeal, the United States Court of Appeals for the Third Circuit affirmed. The court held that the company’s Eighth Amendment claim was barred by the Tax Anti-Injunction Act and the Declaratory Judgment Act, as the relief sought would restrain the assessment or collection of a federal tax. The court further held that the program does not violate the Takings Clause or the First Amendment, relying on its recent precedent. The judgment of the District Court was affirmed. View "Novartis Pharmaceuticals Corp v. Secretary Department of Health" on Justia Law