Justia Constitutional Law Opinion Summaries

The appellants, Andrew Hanson and others, challenged the District of Columbia's law that limits firearm magazine capacity to 10 rounds. They argued that this restriction violates their Second Amendment rights, particularly in light of the Supreme Court's decision in N.Y. State Rifle & Pistol Ass’n v. Bruen, which emphasized historical traditions of firearm regulation over means-end scrutiny.The United States District Court for the District of Columbia denied the appellants' motion for a preliminary injunction. The court conducted a renewed analysis under the Bruen framework, which involves determining whether the Second Amendment covers the conduct in question and, if so, whether the regulation is consistent with historical traditions. The district court found that while extra-large capacity magazines (ELCMs) are "arms" under the Second Amendment, their possession is not protected because they are not typically used for lawful purposes. Additionally, the court held that the District's magazine cap is consistent with historical firearm regulations aimed at reducing violence.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that ELCMs are "arms" under the Second Amendment and are in common use for self-defense. However, it found that the District's magazine cap is consistent with historical regulations of weapons that posed unprecedented lethality, such as Bowie knives and machine guns. The court also noted that the regulation addresses the modern societal concern of mass shootings, which did not exist at the time of the Founding.The court concluded that the appellants failed to demonstrate a likelihood of success on the merits or irreparable harm. It emphasized the importance of maintaining the status quo and the potential public safety risks of enjoining the magazine cap. Therefore, the court affirmed the district court's denial of the preliminary injunction. View "Hanson v. District of Columbia" on Justia Law

Jason Lee, an American citizen of Chinese ancestry, was employed by the FBI and held a Top Secret security clearance. After failing three polygraph examinations, the FBI revoked his security clearance and subsequently terminated his employment, as his job required such clearance. Lee contended that the revocation was based on race, national origin, and protected speech, and he brought claims under the First Amendment, the Fifth Amendment, and Title VII.The United States District Court for the District of Columbia dismissed Lee's claims. It held that his Title VII claims were not timely exhausted, that Title VII preempted his Fifth Amendment claims against the Department of Justice (DOJ), and that Lee lacked a cause of action to press constitutional claims for damages against individual DOJ officials. The court also denied Lee's motion for leave to amend his complaint to include additional claims.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Department of Navy v. Egan, 484 U.S. 518 (1988), barred judicial review of Lee's statutory and constitutional claims. The court reasoned that the decision to grant or revoke a security clearance is a sensitive and inherently discretionary judgment committed by law to the appropriate agency of the Executive Branch. The court also found that Lee's constitutional claims were nonjusticiable under the political question doctrine, as they involved national security matters committed to the political branches and lacked judicially manageable standards for resolution. View "Lee v. Garland" on Justia Law

A non-profit organization, Citizens for Constitutional Integrity, sued the Census Bureau, the Department of Commerce, and related officials, alleging that the Bureau failed to proportionately reduce the basis of representation for states in the 2020 Census as required by the Fourteenth Amendment's Reduction Clause. Citizens claimed this failure diluted the voting power of its members in New York, Pennsylvania, and Virginia. The organization sought relief under the Administrative Procedure Act (APA) and a writ of mandamus.The United States District Court for the District of Columbia dismissed the case for lack of standing. The court found that Citizens could not demonstrate that its alleged vote dilution injury was traceable to the Bureau's actions. Specifically, the court noted that Citizens failed to show how the Bureau's failure to apply the Reduction Clause directly caused the loss of congressional representation for the states in question. The court also found the data scientist's declaration provided by Citizens unpersuasive, as it did not adequately account for the number of disenfranchised voters in the relevant states.The United States Court of Appeals for the District of Columbia Circuit affirmed the District Court's dismissal. The appellate court held that Citizens did not establish traceability under Article III standards. The court found that Citizens failed to present a feasible alternative methodology for apportionment that would have resulted in a different allocation of seats for New York, Pennsylvania, and Virginia. The court also rejected Citizens's argument that it was entitled to a relaxed standing requirement for procedural-rights cases, concluding that the challenge was substantive rather than procedural. Consequently, the court affirmed the District Court's ruling that Citizens lacked standing to pursue its claims. View "Citizens for Constitutional Integrity v. Census Bureau" on Justia Law

The appellants in this case were arrested by the Metropolitan Police Department (MPD) during protests in August 2020. Upon arrest, their personal property, including cell phones, was seized. They were released without charges, but their property was not returned for months or even over a year, despite repeated requests. The appellants filed motions under D.C. Rule of Criminal Procedure 41(g) to recover their property, which led to the return of some items after significant delays. They then sued the District of Columbia in federal court, alleging violations of the Fourth and Fifth Amendments and common-law conversion, and sought damages and injunctive relief.The United States District Court for the District of Columbia dismissed the complaints. It held that the plaintiffs failed to state a Fourth Amendment claim because the initial seizure was reasonable and any challenge to continued retention was governed by the Fifth Amendment. The court also found that Rule 41(g) provided adequate process for the Fifth Amendment claim. Consequently, it declined to exercise supplemental jurisdiction over the conversion claim and denied class certification as moot.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Fourth Amendment requires that any continued retention of personal property seized incident to a lawful arrest must be reasonable. The court found that the prolonged retention of the appellants' property without a legitimate investigatory or protective purpose could constitute an unreasonable seizure under the Fourth Amendment. The court reversed the dismissal of the Fourth Amendment claims, vacated the dismissal of the D.C.-law claims and the denial of class certification, and remanded the case for further proceedings. View "Oyoma Asinor v. DC" on Justia Law

In 2017, Special Counsel Robert S. Mueller III began investigating Russian interference in the 2016 presidential election, during which Giorgi Rtskhiladze testified before a grand jury. When the Department of Justice (DOJ) released a redacted version of Mueller’s report, it included information that Rtskhiladze claimed was inaccurate and damaging to his reputation. Rtskhiladze sued for both equitable and monetary relief and sought a copy of his grand jury testimony transcript.The United States District Court for the District of Columbia ruled that Rtskhiladze lacked standing for his equitable claims, failed to state a claim for damages, and was not entitled to obtain a copy of the transcript. The court found that Rtskhiladze had abandoned his separate damages claim against DOJ and Mueller personally and forfeited arguments about this claim on appeal.The United States Court of Appeals for the District of Columbia Circuit held that Rtskhiladze has standing to bring all his claims and remanded the equitable claims for further consideration. The court agreed with the district court that Rtskhiladze failed to state a claim for damages under the Privacy Act, as he did not allege "intentional or willful" conduct by DOJ. The court also upheld the district court’s decision to deny Rtskhiladze’s request to obtain a copy of his grand jury testimony transcript, emphasizing the government’s interest in maintaining grand jury secrecy and preventing witness intimidation.In summary, the appellate court reversed the district court’s dismissal of Rtskhiladze’s equitable claims for lack of standing, affirmed the dismissal of his damages claim for failure to state a claim, and upheld the denial of his request to obtain a copy of his grand jury transcript. View "Rtskhiladze v. Mueller" on Justia Law

Five police officers from the Crime Suppression Team were patrolling Southeast Washington, D.C., when they encountered Antonio Malachi Bryant. Upon searching him, they found a firearm. Bryant, a previously convicted felon, was charged with possession of a firearm in violation of 18 U.S.C. § 922(g)(1). He moved to suppress the gun, arguing it was obtained through an unconstitutional seizure under the Fourth Amendment.The United States District Court for the District of Columbia denied Bryant’s motion to suppress. The court found that the officers had reasonable articulable suspicion to seize Bryant when they observed a bulge in his waistband, which they believed to be a weapon. The court concluded that the seizure was constitutional and did not need to determine the exact moment the encounter turned into a seizure, as the reasonable suspicion was established by the time the bulge was observed.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the District Court’s decision, holding that the officers had reasonable articulable suspicion to detain and search Bryant when they saw the bulge in his waistband. The court found that Bryant was not seized until after the officers observed the bulge, and thus the seizure was lawful under the Fourth Amendment. The court also noted that the officers’ approach and initial questioning did not constitute a seizure, as police officers are permitted to approach individuals in public places without it being considered a seizure. The court concluded that the District Court’s factual findings were not clearly erroneous and upheld the denial of the motion to suppress. View "USA v. Bryant" on Justia Law

A computer science professor and a tech inventor challenged the Digital Millennium Copyright Act (DMCA), arguing that its provisions against circumventing technological protections on copyrighted works and distributing circumvention tools violate the First Amendment. They claimed these provisions unduly stifle fair use of copyrighted works, which they argued is protected speech. The plaintiffs sought to invalidate these provisions as facially overbroad and a prior restraint on speech.The United States District Court for the District of Columbia dismissed the plaintiffs' facial First Amendment challenges and their Administrative Procedure Act claims but allowed their as-applied First Amendment claims to proceed. The court found that the plaintiffs failed to show that the DMCA's impact on third-party free speech interests was different from its impact on their own. The court also held that the triennial rulemaking process for exemptions did not constitute content-based censorship. The plaintiffs' as-applied claims were later dismissed after the Librarian of Congress granted an exemption for the professor's security research, and the court found that the tech inventor's proposed device would likely lead to widespread piracy.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's dismissal of the facial challenges. The court held that the DMCA's anticircumvention and antitrafficking provisions are not facially overbroad because they regulate conduct, not speech, and their legitimate applications, such as preventing digital piracy, far outweigh any potential unconstitutional applications. The court also rejected the argument that the triennial rulemaking process constitutes a prior restraint on speech, noting that the DMCA does not target expression and that alternative avenues for lawful access to copyrighted works remain available. View "Matthew Green v. DOJ" on Justia Law

The case involves People for the Ethical Treatment of Animals (PETA) and two animal rights advocates, Madeline Krasno and Ryan Hartkopf, who frequently commented on the National Institutes of Health (NIH) social media pages to criticize NIH’s funding of animal testing. NIH used keyword filters to automatically hide comments containing specific words like “animal,” “testing,” and “cruel,” which resulted in the appellants' comments being filtered out and not viewable to the public. The appellants argued that NIH’s policy violated the First Amendment.The United States District Court for the District of Columbia held that the comment threads on NIH’s social media pages were limited public forums and upheld NIH’s speech restrictions as reasonable. The court found that the restrictions were viewpoint-neutral and reasonable in light of the forum's purpose. The appellants then appealed this decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and agreed that NIH’s comment threads are limited public forums. However, the court held that NIH’s “off-topic” restriction, as implemented through its keyword filters, was not reasonable in light of the purpose of the forum and was therefore unconstitutional under the First Amendment. The court found that the restriction lacked objective, workable standards and was inflexible and unresponsive to context, which made it unreasonable. The judgment of the district court was reversed, and summary judgment was directed in favor of the appellants. View "People for the Ethical Treatment of Animals v. Tabak" on Justia Law

Exxon Mobil Corporation owned subsidiaries in Cuba that had various oil and gas assets. In 1960, the Cuban government expropriated these assets without compensating Exxon. In 1996, Congress enacted the Cuban Liberty and Democratic Solidarity Act, which allows U.S. nationals to sue those who traffic in property confiscated by the Cuban government. Exxon sued three state-owned defendants, alleging they trafficked in the confiscated property by participating in the oil industry and operating service stations.The United States District Court for the District of Columbia denied one defendant's motion to dismiss based on foreign sovereign immunity. The court held that the Cuban Liberty and Democratic Solidarity Act does not override the Foreign Sovereign Immunities Act (FSIA), and jurisdiction depends on an FSIA exception. The court found that the FSIA’s expropriation exception did not apply but that the commercial-activity exception did. The court allowed limited jurisdictional discovery for the other two defendants and later denied their motion for reconsideration.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court agreed with the district court that the Cuban Liberty and Democratic Solidarity Act does not confer jurisdiction and that the FSIA’s expropriation exception is inapplicable. However, the court concluded that the district court needed to undertake additional analysis before determining that jurisdiction exists under the FSIA’s commercial-activity exception. The court vacated the district court’s decision and remanded the case for further analysis on the applicability of the FSIA’s commercial-activity exception. View "Exxon Mobil Corporation v. Corporacion CIMEX, S.A. (Cuba)" on Justia Law

Aly Abdellatif, an Egyptian citizen, suspected he was placed on government watchlists after experiencing unwarranted airport security screenings. He sought correction through the Transportation Security Administration's (TSA) redress program, which responded without confirming or denying his watchlist status. Abdellatif and his wife, Nina Araujo, petitioned for review, challenging the administration of the traveler redress program and their treatment during travel.The petitioners initially filed their case in the United States Court of Appeals for the District of Columbia Circuit. They named multiple federal agencies and officials as respondents, alleging that Abdellatif's inclusion on the Selectee List and TSA watchlists led to enhanced security screenings and secondary inspections. They argued that TSA's redress process failed to correct erroneous information, violating statutory obligations and due process rights. The court dismissed the petition against all respondents except TSA, citing jurisdictional limitations.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court dismissed the petition in part for lack of standing, as TSA cannot remove names from the Selectee List, which is maintained by the Terrorist Screening Center (TSC). The court found that petitioners' injuries related to the Selectee List were not redressable in this lawsuit. However, the court denied the remaining claims on the merits, concluding that TSA's redress process complies with statutory requirements and does not violate due process. The court also rejected the Fourth Amendment claims, finding that the enhanced security screenings and secondary inspections described were reasonable and did not constitute unreasonable searches or seizures. The petition was dismissed in part and otherwise denied. View "Abdellatif v. DHS" on Justia Law