Justia Constitutional Law Opinion Summaries

Eric Poemoceah, an Oklahoma resident and member of the Comanche Nation, participated in a protest against the Dakota Access Pipeline at the Standing Rock Reservation in North Dakota. On February 22, 2017, while attempting to negotiate with law enforcement officers for the peaceful exit of elders from the protest site, Poemoceah was tackled and arrested by officers, including Benjamin Swenson. He sustained injuries, including a pelvic fracture, and was charged with obstruction of a government function, a charge that was later dismissed.The United States District Court for the District of North Dakota dismissed Poemoceah’s complaint with prejudice, granting the defendants' motions to dismiss. The court found that the defendants were entitled to qualified immunity on the First and Fourth Amendment claims and dismissed the remaining claims as inadequately pled. Poemoceah’s request for leave to amend his complaint was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Poemoceah plausibly alleged a Fourth Amendment excessive force claim against Swenson, as the facts suggested that Swenson's use of force was not objectively reasonable. However, the court affirmed the dismissal of Poemoceah’s deliberate indifference to medical needs claim, First Amendment retaliation claim, supervisory liability claims, Monell claim against Morton County, and the intentional infliction of emotional distress claim under North Dakota law. The court also found no abuse of discretion in the district court’s denial of Poemoceah’s motion to amend his complaint. The case was affirmed in part, reversed in part, and remanded for further proceedings on the Fourth Amendment claim against Swenson. View "Poemoceah v. Morton County" on Justia Law

The case involves the Horseracing Integrity and Safety Act, which establishes a framework to regulate horseracing through the Horseracing Integrity and Safety Authority, a private nonprofit corporation. The Authority is responsible for creating and enforcing rules related to horseracing, subject to oversight by the Federal Trade Commission (FTC). Bill Walmsley, Jon Moss, and the Iowa Horsemen’s Benevolent and Protective Association sought a preliminary injunction to prevent the enforcement of rules under the Act, arguing that the Act was unconstitutional.The United States District Court for the Eastern District of Arkansas denied the motion for a preliminary injunction, finding that the plaintiffs were unlikely to succeed on the merits of their constitutional challenges. The plaintiffs then appealed to the United States Court of Appeals for the Eighth Circuit.The Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Act's rulemaking structure does not violate the private nondelegation doctrine because the FTC has ultimate discretion over the rules governing the horseracing industry. The court also found that the Act does not unconstitutionally delegate executive power to the Authority, as the FTC has pervasive oversight and control over the Authority's enforcement activities. Additionally, the court concluded that the Act provides an intelligible principle for the FTC to follow, thus not violating the public nondelegation doctrine. Finally, the court determined that the Authority's board members are not officers of the United States and therefore not subject to the Appointments Clause.The Eighth Circuit concluded that Walmsley did not demonstrate a fair chance of success on the merits, and thus, the district court did not abuse its discretion in denying the preliminary injunction. The order of the district court was affirmed. View "Walmsley v. FTC" on Justia Law

Nyynkpao Banyee, a citizen of Ivory Coast and lawful permanent resident of the United States, was detained for a year while awaiting a decision on his deportation. His criminal history includes theft, lying to the police, and possession of marijuana and drug paraphernalia, culminating in a robbery with a dangerous weapon conviction. This led federal authorities to initiate deportation proceedings. Initially, an immigration judge ruled the robbery conviction as a "crime of violence," disqualifying Banyee from certain discretionary relief. However, after the Supreme Court's decision in Borden v. United States, the government argued the conviction was an attempted "theft offense." The immigration judge eventually canceled Banyee's removal, but the government successfully appealed, and Banyee's appeal is still pending.The United States District Court for the District of Minnesota granted Banyee's habeas petition, ruling that his year-long detention without individualized review violated due process. The court ordered a bond hearing, which resulted in Banyee's release after the government failed to prove he was a danger or flight risk. The government appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that detention during deportation proceedings is constitutionally valid, as established in Demore v. Kim. The court emphasized that the length of detention does not determine its legality as long as deportation remains a possibility and the detention serves its purpose. The court found no evidence of dilatory tactics by either side and noted that Banyee's detention was not punitive. Consequently, the Eighth Circuit remanded the case for the denial of Banyee's habeas petition. View "Banyee v. Garland" on Justia Law

In 2020, the Springfield R-12 School District mandated "equity training" for its employees. Two employees, Brooke Henderson and Jennifer Lumley, attended the training and later sued the school district and several officials under 42 U.S.C. § 1983. They claimed that the training compelled them to speak on matters of public concern and engaged in viewpoint discrimination, violating their First and Fourteenth Amendment rights. The training included interactive sessions and online modules that required participants to discuss prompts and select "correct" answers to questions about equity and diversity.The United States District Court for the Western District of Missouri granted summary judgment in favor of the school district, ruling that the plaintiffs lacked standing because they did not suffer an injury in fact. The court also deemed the lawsuit frivolous and awarded attorney’s fees to the school district. The plaintiffs appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's dismissal, agreeing that the plaintiffs did not establish an injury in fact. The court found that the plaintiffs' fear of punishment for their speech during the training was speculative and not objectively reasonable. The court also concluded that the plaintiffs' completion of online modules did not constitute a First Amendment injury. However, the Eighth Circuit reversed the award of attorney’s fees, determining that the plaintiffs' claims were not frivolous given the nuanced and unsettled nature of the constitutional issues involved. View "Henderson v. Springfield R-12 School District" on Justia Law

Russell Hotchkiss, a resident of Linn County, Iowa, began sending emails to the Cedar Rapids Community School District officials in September 2021, criticizing their COVID-19 masking and vaccination policies. His communications included threats of criminal charges against board members, particularly targeting Jennifer Borcherding, a board member. Hotchkiss attended board meetings in November and December 2021, where he voiced his opposition aggressively. Following these incidents, the District issued a no-trespass notice to Hotchkiss on January 10, 2022, barring him from District premises due to his disruptive and threatening behavior.Hotchkiss filed a lawsuit on May 17, 2023, claiming First Amendment retaliation under 42 U.S.C. § 1983 and a violation of the Iowa Open Meetings Act. He sought a preliminary injunction to prevent the enforcement of the no-trespass order. The United States District Court for the Northern District of Iowa denied his motion, concluding that Hotchkiss failed to demonstrate irreparable harm. The court noted that Hotchkiss had not attempted to return to District premises, had moved his child to another school district, and had not communicated with the District since the notice was issued.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision. The appellate court affirmed the denial of the preliminary injunction, agreeing that Hotchkiss did not show a likelihood of irreparable harm. The court emphasized that speculative harm does not justify a preliminary injunction and noted Hotchkiss's delay in seeking relief and lack of recent attempts to exercise his First Amendment rights. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction based on the failure to demonstrate irreparable harm. View "Hotchkiss v. Cedar Rapids Community School District" on Justia Law

Darris Lamar Mull pleaded guilty to four counts of being a felon in possession of firearms, violating 18 U.S.C. § 922(g)(1). The presentence investigation report (PSR) assessed a base offense level of 20 due to the involvement of a semiautomatic firearm capable of accepting a large capacity magazine. Mull objected, arguing that his co-defendant was responsible for that firearm. The district court overruled the objection and sentenced Mull to 135 months’ imprisonment. Mull appealed, challenging the application of the sentencing enhancement and arguing that 18 U.S.C. § 922(g)(1) violated his Second Amendment rights.The United States District Court for the Western District of Missouri initially reviewed the case. Mull objected to the PSR's findings, particularly the base offense level enhancement under U.S.S.G. § 2K2.1(a)(4)(B). The district court found that Mull's offense involved a semiautomatic firearm with a large capacity magazine and overruled his objection. The court adopted the PSR's factual content and calculations, sentencing Mull to 135 months based on the 18 U.S.C. § 3553(a) factors.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not err in applying the § 2K2.1(a)(4)(B) enhancement. It found that Mull and his co-defendant engaged in jointly undertaken criminal activity, making Mull accountable for the co-defendant's possession and use of the firearm. The court also rejected Mull's Second Amendment challenge, citing Eighth Circuit precedent that upheld the constitutionality of 18 U.S.C. § 922(g)(1). The Eighth Circuit affirmed the district court's judgment, maintaining Mull's 135-month sentence. View "United States v. Mull" on Justia Law

In 2021, Missouri enacted the Second Amendment Preservation Act, which declared certain federal firearms regulations as infringements on the right to keep and bear arms and invalid within the state. The Act prohibited state officials from enforcing these federal laws and allowed private citizens to sue state entities that did so, imposing penalties for violations. The United States sued Missouri, arguing that the Act violated the Supremacy Clause of the U.S. Constitution.The United States District Court for the Western District of Missouri denied Missouri's motions to dismiss for lack of standing and failure to state a claim. The court granted summary judgment in favor of the United States, ruling that the Act violated the Supremacy Clause and enjoined its implementation and enforcement. Missouri appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the United States had standing to sue because the Act caused concrete and particularized injury by impairing federal law enforcement efforts. The court also ruled that the Act's attempt to invalidate federal law was unconstitutional under the Supremacy Clause. The court found that the Act was not severable, as its provisions were fundamentally interconnected with the invalidation of federal law. Consequently, the injunction against the Act's implementation and enforcement was upheld. View "United States v. State of Missouri" on Justia Law

Four female hockey players filed a lawsuit against the University of North Dakota, alleging that the university violated Title IX by eliminating the women’s ice hockey program after the 2016-17 season. None of the plaintiffs were enrolled at the university at the time of the program's termination. They sought to represent a class of current, prospective, and future female students and requested a declaratory judgment and an injunction to reinstate the women’s hockey program.The United States District Court for the District of North Dakota dismissed the case for lack of jurisdiction, finding that the plaintiffs did not demonstrate a "concrete" injury as required for standing under Article III.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that two plaintiffs, Calli Forsberg and Maya Tellmann, had standing. Forsberg was recruited to play for the university’s hockey team but chose another school after the program was cut. Tellmann, a two-time state hockey champion, was accepted as a student but had no opportunity to play due to the program's elimination. Both plaintiffs demonstrated a concrete injury by being denied the opportunity to compete for the team of their choice, and they expressed a definite intent to attend the university if the program were reinstated.The court found that the other two plaintiffs, Emily Becker and Morgan Stenseth, did not allege sufficient facts to establish standing. Becker did not provide details about her qualifications or acceptance to the university, and Stenseth did not express an intent to attend the university in the future.The Eighth Circuit reversed and remanded the case in part, allowing Forsberg and Tellmann’s claims to proceed, but affirmed the dismissal of Becker and Stenseth’s claims. View "Becker v. North Dakota University System" on Justia Law

The case involves several states suing the President of the United States, the Secretary of Education, and the U.S. Department of Education to prevent the implementation of a plan to forgive approximately $475 billion in federal student loan debt. The plan, known as SAVE, significantly alters the existing income-contingent repayment (ICR) plan by lowering payment amounts, often to $0 per month, and forgiving principal balances much sooner than previous plans.The United States District Court for the Eastern District of Missouri granted a preliminary injunction in part, finding that Missouri had standing through its state instrumentality, MOHELA, which faced certain irreparable harm. The court concluded that the states had a fair chance of success on the merits, particularly that loan forgiveness under SAVE was not statutorily authorized and violated the separation of powers under the major-questions doctrine. However, the court only enjoined the ultimate forgiveness of loans, not the payment-threshold provisions or the nonaccrual of interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the district court that Missouri had standing. The court found that the states demonstrated a fair chance of success on the merits, noting that the SAVE plan's scope was even larger than a previously contested loan-cancellation program. The court also found that the Government's actions had rendered the district court's injunction largely ineffective. Balancing the equities, the court decided to grant in part and deny in part the states' motion for an injunction pending appeal, prohibiting the use of the hybrid rule to circumvent the district court's injunction. The injunction will remain in effect until further order of the court or the Supreme Court of the United States. View "State of Missouri v. Biden" on Justia Law

In May 2023, Iowa's Governor signed Senate File 496 (SF496) into law, which introduced new regulations for public school libraries, classrooms, and curriculum, and required parental notification for certain gender identity accommodations. Two groups of plaintiffs, including students, authors, and educators, filed lawsuits to enjoin SF496, arguing it violated the First Amendment, the Fourteenth Amendment, and the Equal Access Act. The plaintiffs sought a preliminary injunction to prevent the law's enforcement.The United States District Court for the Southern District of Iowa granted the preliminary injunction, enjoining the enforcement of SF496's provisions related to the removal of books from school libraries and the prohibition of instruction on gender identity and sexual orientation for students in kindergarten through grade six. The court found that the plaintiffs had standing and that the law's enforcement would likely cause irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the district court's analysis was flawed. The appellate court held that the district court did not properly apply the legal standards for facial challenges and failed to consider the law's legitimate applications. The Eighth Circuit also noted that the district court did not adequately address the as-applied challenges raised by the plaintiffs. Consequently, the appellate court reversed the district court's decision, vacated the preliminary injunction, and remanded the case for further proceedings consistent with its opinion. The plaintiffs were allowed to pursue injunctive relief under the correct legal framework and address the unconsidered as-applied challenges. View "GLBT Youth in Iowa Schools Task Force v. Reynolds" on Justia Law