Justia Constitutional Law Opinion Summaries

After the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, which struck down New York’s “proper cause” requirement for public handgun carry, New Jersey enacted Chapter 131. This law removed its own “justifiable need” standard but imposed new licensing requirements, increased permit fees, mandated liability insurance for handgun carriers, and designated numerous “sensitive places” where firearms are prohibited, such as parks, entertainment venues, healthcare facilities, and private property without express consent. Two groups of plaintiffs, including individuals and gun rights organizations, challenged these provisions under 42 U.S.C. § 1983, arguing they violated the Second Amendment.The United States District Court for the District of New Jersey consolidated the cases and allowed legislative leaders to intervene as defendants. The District Court preliminarily enjoined enforcement of several “sensitive place” restrictions, the vehicle carry ban, the liability insurance requirement, and the private property default rule, finding these likely unconstitutional under Bruen’s historical tradition test. The State and some plaintiffs appealed, and the Third Circuit Court of Appeals granted a partial stay, allowing most of the law to take effect pending appeal.The United States Court of Appeals for the Third Circuit reviewed the District Court’s preliminary injunction, applying de novo review to the underlying Second Amendment questions. The Third Circuit held that most of New Jersey’s “sensitive place” restrictions—such as those covering parks, entertainment venues, healthcare facilities, libraries, museums, and places serving alcohol—are likely constitutional, finding them consistent with a historical tradition of regulating firearms in locations set aside for civic, educational, or recreational purposes. However, the court affirmed the injunction against the liability insurance mandate, the portion of the permit fee allocated to the Victims of Crime Compensation Office, the private property default rule as applied to places open to the public, and the ban on carrying operable firearms in private vehicles, holding these provisions likely violate the Second Amendment. The court vacated the injunction as to film sets and certain hunting regulations for lack of standing or mootness, and remanded for further proceedings consistent with its opinion. View "Koons v. Attorney General New Jersey" on Justia Law

A philosophy lecturer at a public university in New Jersey had his contract non-renewed after his private, off-campus comments and writings about race, politics, and immigration became public. These included controversial essays and recorded conversations, which were later featured in a New York Times article. The university received some complaints from students, faculty, and outside parties, and several faculty groups issued public statements condemning the lecturer’s views. The university placed him on paid leave, conducted an investigation into his outside activities and class attendance, and ultimately decided not to renew his contract, citing both the content of his speech and alleged policy violations.The United States District Court for the District of New Jersey granted summary judgment in favor of the university, holding that the lecturer’s speech was not protected by the First Amendment. The court found that the university’s interest in mitigating disruption outweighed the lecturer’s interest in expressing his views. The District Court did not address whether the speech was a substantial or motivating factor in the non-renewal, whether the same action would have occurred absent the speech, or whether university officials were entitled to qualified immunity.The United States Court of Appeals for the Third Circuit reviewed the case and reversed the District Court’s judgment. The Third Circuit held that the lecturer’s off-campus, extramural speech on matters of public concern was protected by the First Amendment, and that the university had not demonstrated sufficient disruption to outweigh the lecturer’s interest in his speech under the Pickering balancing test. The court found the evidence of disruption minimal and insufficient to justify the adverse employment action. The judgment was vacated and the case remanded for further proceedings. View "Jason Jorjani v. New Jersey Institute of Technology" on Justia Law

A company sought approval to construct electricity transmission lines in Pennsylvania as part of a larger project selected through a federally supervised regional planning process. The project was designed to alleviate regional congestion on the electricity grid, which would lower wholesale electricity costs in certain states but increase costs for some Pennsylvania consumers. The regional transmission organization (PJM), acting under Federal Energy Regulatory Commission (FERC) rules, selected the project using a benefit-cost methodology approved by FERC.The Pennsylvania Public Utility Commission (PUC) reviewed the company’s applications for siting and eminent domain authority. After an evidentiary hearing, an administrative law judge recommended denial, finding that the project was no longer needed due to decreased congestion and that the benefit-cost analysis used by PJM was deficient under Pennsylvania law. The PUC adopted this recommendation, denied the applications, and rescinded the company’s provisional certificate of public convenience. The company appealed to the Pennsylvania Commonwealth Court, which affirmed the PUC’s decision. The company then pursued federal constitutional claims in the United States District Court for the Middle District of Pennsylvania, reserving those issues in state court.The United States Court of Appeals for the Third Circuit reviewed the case. It held that the PUC’s order was preempted under the Supremacy Clause of the U.S. Constitution because it posed an obstacle to federal objectives established by Congress and implemented by FERC—specifically, the regional planning and congestion-reduction process. The court found that the PUC’s independent “need” determination, which second-guessed PJM’s FERC-approved methodology, impermissibly conflicted with federal law. The Third Circuit affirmed the District Court’s judgment for the company and did not reach the dormant Commerce Clause issues. View "Transource Pennsylvania LLC v. DeFrank" on Justia Law

Two pharmaceutical companies challenged a federal program created by the Inflation Reduction Act of 2022, which directs the Centers for Medicare and Medicaid Services (CMS) to negotiate prices for certain high-expenditure prescription drugs lacking generic competition. Under this program, manufacturers of selected drugs must either negotiate a price with CMS or face steep excise taxes on all sales of those drugs, unless they withdraw all their products from specific Medicare and Medicaid programs. Both companies had drugs selected for negotiation and, while litigation was pending, agreed to participate and reached negotiated prices.The United States District Court for the District of New Jersey resolved the cases on cross-motions for summary judgment, as the parties agreed there were no material factual disputes. The District Court ruled in favor of the government, holding that the program did not violate the Takings Clause, the First Amendment, or the unconstitutional conditions doctrine. The companies appealed, and the United States Court of Appeals for the Third Circuit consolidated the appeals.The Third Circuit affirmed the District Court’s orders. It held that participation in Medicare and the negotiation program is voluntary, so there is no physical taking under the Fifth Amendment. The court found that economic incentives to participate do not amount to legal compulsion. It also held that the program’s requirements do not compel speech in violation of the First Amendment, as any speech involved is incidental to the regulation of conduct and participation is voluntary. Finally, the court concluded that the program does not impose unconstitutional conditions, as any compelled speech is limited to the contracts necessary to effectuate the program and does not restrict speech outside those contracts. The court affirmed summary judgment for the government. View "Bristol Myers Squibb Co v. Secretary United States Department of HHS" on Justia Law

A Pennsylvania resident, along with several organizations, challenged the state’s requirement that mail-in ballots be discarded if the return envelope is missing a handwritten date or contains an incorrect date. The plaintiffs argued that this “date requirement” led to thousands of otherwise valid ballots being rejected in recent elections, often without notice to the affected voters or an opportunity to cure the error. The date field on the return envelope does not determine whether a ballot is timely or whether the voter is eligible, and the state’s election system already records the actual receipt date of each ballot.The United States District Court for the Western District of Pennsylvania reviewed the case after extensive discovery. Only two county election boards defended the date requirement, while most did not. The District Court found that the date requirement was not justified by the state’s interests in election efficiency, solemnity, or fraud prevention. The court noted that the requirement imposed a minimal but real burden on voters, as it led to the rejection of thousands of ballots, and that the state had not shown the requirement meaningfully advanced its asserted interests. The court granted summary judgment for the plaintiffs and enjoined enforcement of the date requirement, but did not prohibit the inclusion of a date field on return envelopes.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that, under the Anderson-Burdick framework, the date requirement imposed a minimal burden on the right to vote, but that burden was not justified by the state’s interests. The court found no meaningful connection between the date requirement and election administration, solemnity, or fraud prevention, and concluded that discarding ballots for minor date errors was unconstitutional. The judgment of the District Court was affirmed. View "Eakin v. Adams County Board of Elections" on Justia Law

Philadelphia police officers stopped a car driven by Raphael Ross for having illegally tinted windows in a high-crime area. During the stop, Ross appeared extremely nervous, displaying shaking hands, a stammering voice, and erratic movements with his jacket inside the car. After Ross produced expired insurance and registration and claimed to have left his license elsewhere, Officer Smart complimented Ross’s Rolex watch and asked where he worked. Ross replied that he owned a home health aide business. Officer Smart then returned to his patrol car to check Ross’s information, discovering a recent firearm arrest. Meanwhile, Officer Foreman observed continued nervous behavior and noncompliance with her instructions. After backup arrived, officers frisked Ross and searched his car, finding a gun and drugs.Ross was charged in the United States District Court for the Eastern District of Pennsylvania with firearm and drug offenses. He moved to suppress the evidence, arguing that the officer’s questions about his watch and employment unlawfully extended the stop under the Fourth Amendment, as interpreted by Rodriguez v. United States. The District Court denied the motion, finding the brief exchange to be permissible small talk aimed at calming Ross and not an unconstitutional extension of the stop. Ross pleaded guilty but reserved his right to appeal the suppression ruling.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that brief, safety-related small talk—such as complimenting a watch and asking about employment—does not violate the Fourth Amendment if it is intended to deescalate tension and does not measurably prolong the stop. The court found that the officers’ actions were reasonable given Ross’s nervous behavior and affirmed the District Court’s denial of the suppression motion and Ross’s conviction. View "USA v. Ross" on Justia Law

A federal inmate diagnosed with diabetes was initially prescribed medication and given certain accommodations while incarcerated. After being transferred to a new facility, his new medical provider discontinued his diabetes medication and accommodations based on a single blood test result, despite the inmate’s objections that the result was not representative of his condition. The inmate’s health deteriorated, leading to severe diabetic ulcers and ultimately the amputation of his toe. He alleged that medical staff repeatedly denied or delayed necessary care, and that his requests for treatment were falsely documented as refusals. The inmate later filed administrative claims with the Bureau of Prisons (BOP) and, after those were denied or not fully addressed, brought suit alleging deliberate indifference to his medical needs under the Eighth Amendment and also asserted a claim under the Rehabilitation Act.The United States District Court for the District of New Jersey screened the complaint and dismissed the Rehabilitation Act claim. The defendants moved to dismiss the Eighth Amendment claim brought under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics. The District Court granted the motion, reasoning that the case presented a new context from prior Supreme Court precedent because the injuries were not fatal and that the existence of the BOP’s administrative remedy program was a special factor counseling against extending Bivens. The inmate appealed.The United States Court of Appeals for the Third Circuit affirmed. The court held that the availability of the BOP’s administrative remedy program constituted a special factor not present in Carlson v. Green, and thus created a new context under the Bivens analysis. Because an alternative remedial structure existed and was available to the inmate, the court declined to extend a Bivens remedy. The court also affirmed dismissal of the Rehabilitation Act claim, as sovereign immunity barred damages claims against the federal government under that statute. View "Muniz v. United States" on Justia Law

Roger Esteban Real, a native and citizen of Colombia, participated in protests in his home country, leading to his arrest and mistreatment by police. Fearing for his safety, he fled to the United States with his family in March 2022. Upon arrival, he surrendered to immigration authorities, who did not issue him a Notice to Appear (NTA) or inquire about his fear of returning to Colombia. He was instructed to attend a court hearing in 2025 and to check in regularly using a cell phone provided by the authorities.Real was later arrested for crimes related to a domestic dispute, and two months after this arrest, the Department of Homeland Security (DHS) issued him an NTA. An Immigration Judge (IJ) found him removable and, in July 2023, Real applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The IJ granted him withholding of removal but denied his asylum application, citing his failure to meet the one-year filing deadline and lack of extraordinary circumstances to excuse the delay. The Board of Immigration Appeals (BIA) dismissed his appeal, agreeing with the IJ's findings.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the government's failure to notify Real of the one-year asylum application deadline did not constitute a due process violation. Additionally, the court determined that it lacked jurisdiction to review Real's claim of extraordinary circumstances excusing his late filing, as such determinations are discretionary and not subject to judicial review. Consequently, the court denied the petition in part and dismissed it in part. View "Real v. Attorney General" on Justia Law

Sun Valley Orchards, a New Jersey farm, was accused by the U.S. Department of Labor (DOL) of breaching an employment agreement under the H-2A nonimmigrant visa program. The DOL alleged that Sun Valley failed to provide adequate housing, meal plans, transportation, and guaranteed work hours to its workers, as stipulated in the job order. The DOL imposed civil penalties and back wages totaling hundreds of thousands of dollars through administrative proceedings.The case was first reviewed by an Administrative Law Judge (ALJ), who affirmed most of the DOL's findings but slightly modified the penalties and back wages. Sun Valley then appealed to the Administrative Review Board, which upheld the ALJ's decision. Subsequently, Sun Valley challenged the DOL's decision in the United States District Court for the District of New Jersey, arguing that the administrative proceedings violated Article III of the Constitution, among other claims. The District Court dismissed Sun Valley's claims, holding that the DOL's actions fit within the public-rights doctrine and that the agency had statutory authority to impose penalties and back wages.The United States Court of Appeals for the Third Circuit reviewed the case and held that Sun Valley was entitled to have its case decided by an Article III court. The court found that the DOL's enforcement action resembled a common law breach of contract suit, which traditionally would be heard in a court of law. The court also determined that the case did not fit within the public rights exception to Article III adjudication, as the H-2A labor certification regulations primarily concern domestic employment law rather than immigration control. Consequently, the Third Circuit reversed the District Court's decision and remanded the case with instructions to enter judgment in favor of Sun Valley. View "Sun Valley Orchards LLC v. United States Department of Labor" on Justia Law

Safehouse, a Pennsylvania nonprofit corporation, was established in 2018 to address opioid abuse in Philadelphia by providing overdose prevention services, including supervised illegal drug use. Safehouse argues that its activities are motivated by a religious belief in the value of human life and that government intervention substantially burdens its religious exercise.The United States District Court for the Eastern District of Pennsylvania initially determined that Safehouse’s proposed activities did not violate 21 U.S.C. § 856(a)(2). However, the Third Circuit Court of Appeals reversed this decision, holding that Safehouse’s activities would indeed violate the statute. On remand, the District Court dismissed Safehouse’s Religious Freedom Restoration Act (RFRA) and Free Exercise counterclaims, reasoning that non-religious entities are not protected by these provisions. Safehouse appealed this dismissal.The United States Court of Appeals for the Third Circuit reviewed the case and held that the District Court erred in its interpretation. The Third Circuit determined that RFRA and the Free Exercise Clause extend protections to non-natural persons, including non-religious entities like Safehouse. The court emphasized that RFRA’s plain text and Free Exercise doctrine protect any “person” exercising religion, which includes corporations and associations. The court reversed the District Court’s dismissal of Safehouse’s RFRA and Free Exercise counterclaims and remanded the case for further consideration of whether Safehouse has plausibly pleaded these claims. The appeal by José Benitez, President of Safehouse, was dismissed due to lack of appellate standing. View "United States v. Safehouse" on Justia Law