Justia Constitutional Law Opinion Summaries

Bryan Burwell and Aaron Perkins were involved in a series of bank robberies and were convicted in the United States District Court for the District of Columbia. They were sentenced to lengthy prison terms, including mandatory minimum sentences for firearms-related convictions under 18 U.S.C. § 924(c), which mandates enhanced penalties for using a firearm during a crime of violence. Burwell and Perkins argued that their convictions under § 924(c) were erroneous because federal bank robbery under 18 U.S.C. § 2113(a) is not categorically a crime of violence.The District Court denied their post-conviction motions, which challenged the application of § 924(c) based on the Supreme Court's decision in United States v. Davis, which invalidated the residual clause of § 924(c) as unconstitutionally vague. Burwell and Perkins appealed, arguing that bank robbery by extortion does not involve the use or threat of force and thus cannot be considered a crime of violence under the elements clause of § 924(c).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that 18 U.S.C. § 2113(a) is indivisible regarding the means of committing bank robbery—by force and violence, intimidation, or extortion. The court concluded that extortion, as a means of committing bank robbery, does not necessarily involve the use or threat of force. Therefore, bank robbery under § 2113(a) does not qualify as a crime of violence under § 924(c). Consequently, the court vacated Burwell's and Perkins's § 924(c) convictions and remanded the case to the District Court to determine whether to release them immediately. View "United States v. Burwell" on Justia Law

The case involves the Protecting Americans from Foreign Adversary Controlled Applications Act, which was signed into law on April 24, 2024. The Act identifies certain countries, including China, as foreign adversaries and prohibits the distribution or maintenance of applications controlled by these adversaries, specifically targeting the TikTok platform. TikTok Inc. and ByteDance Ltd., along with other petitioners, challenged the constitutionality of the Act, arguing that it violates the First Amendment, the Fifth Amendment's equal protection and takings clauses, and the Bill of Attainder Clause.The lower courts had not previously reviewed this case, as it was brought directly to the United States Court of Appeals for the District of Columbia Circuit. The petitioners sought a declaratory judgment and an injunction to prevent the Attorney General from enforcing the Act. The court had to determine whether the petitioners had standing and whether their claims were ripe for judicial review.The United States Court of Appeals for the District of Columbia Circuit concluded that TikTok had standing to challenge the Act and that its claims were ripe. The court assumed without deciding that strict scrutiny applied to the First Amendment claims and upheld the Act, finding that it served compelling governmental interests in national security and was narrowly tailored to achieve those interests. The court also rejected the equal protection, bill of attainder, and takings clause claims, concluding that the Act did not constitute a punishment, was not overinclusive or underinclusive, and did not result in a complete deprivation of economic value. The petitions were denied. View "TikTok Inc. v. Garland" on Justia Law

Alpine Securities Corporation, a securities broker-dealer and member of the Financial Industry Regulatory Authority (FINRA), faced sanctions from FINRA in 2022 for violating its rules. FINRA imposed a cease-and-desist order and sought to expel Alpine from membership. Alpine challenged the constitutionality of FINRA in federal court, arguing that FINRA's expedited expulsion process violated the private nondelegation doctrine and the Appointments Clause.The United States District Court for the District of Columbia denied Alpine's request for a preliminary injunction to halt FINRA's expedited proceeding. The court held that FINRA is a private entity, not subject to the Appointments Clause, and that the SEC's ability to review FINRA's decisions satisfied the private nondelegation doctrine.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that Alpine demonstrated a likelihood of success on its private nondelegation claim, as FINRA's expulsion orders take effect immediately without prior SEC review, effectively barring Alpine from the securities industry. The court held that this lack of governmental oversight likely violates the private nondelegation doctrine. The court also found that Alpine faced irreparable harm if expelled before SEC review, as it would be forced out of business.The court reversed the district court's denial of a preliminary injunction, instructing it to enjoin FINRA from expelling Alpine until the SEC reviews any expulsion order or the time for Alpine to seek SEC review lapses. However, the court did not grant a preliminary injunction on Alpine's Appointments Clause claims, as Alpine did not demonstrate irreparable harm from participating in FINRA's expedited proceeding itself. The case was remanded for further proceedings consistent with the appellate court's findings. View "Alpine Securities Corporation v. Financial Industry Regulatory Authority, Inc." on Justia Law

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