Justia Constitutional Law Opinion Summaries

In 2016, the Mississippi legislature passed S.B. 2162, which abolished the Jackson Municipal Airport Authority (JMAA) and created the Jackson Metropolitan Area Airport Authority (Authority). The new Authority would be governed by nine commissioners, with only two selected by the Jackson city government. The JMAA commissioners, along with Jackson’s Mayor and City Council, intervened in a suit to enjoin enforcement of the law, alleging violations of the Equal Protection Clause of the Fourteenth Amendment and the Due Process Clause of the Mississippi Constitution. They claimed S.B. 2162 diluted the voting rights of Jackson citizens and altered the airport’s management for race-based reasons.The United States District Court for the Southern District of Mississippi initially upheld the plaintiffs' standing and ordered discovery, which the legislators resisted, citing legislative privilege. On the first appeal, the Fifth Circuit held that the plaintiffs lacked standing, as they failed to demonstrate injury to a legally protected interest. The case was remanded with instructions to dismiss without prejudice. Plaintiffs amended their complaint to address the standing issue, and the district court again ordered discovery. The Fifth Circuit reversed the district court’s privilege ruling but later dismissed the appeal as moot when none of the plaintiff-commissioners held their positions.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the plaintiffs lacked Article III standing to sue. The court held that the plaintiffs' alleged injuries were institutional rather than personal, as the injury affected the JMAA as an entity. The court also found that the plaintiffs did not have a protected property interest in their positions or the associated per diem and travel reimbursements. Consequently, the Fifth Circuit vacated the district court's order and remanded the case with instructions to dismiss. View "Jones v. Reeves" on Justia Law

The case involves a First Amendment challenge to a policy in Caldwell County, Texas, which categorically excludes the press and the public from observing criminal pretrial proceedings known as magistrations. The plaintiffs, two nonprofit news organizations and an advocacy organization, argued that this policy violates their First Amendment right of access to judicial proceedings. The district court agreed, finding the policy unconstitutional and granting a preliminary injunction to prevent its enforcement.The United States District Court for the Western District of Texas initially reviewed the case. The district court found that the plaintiffs had standing to challenge the policy and demonstrated a substantial likelihood of success on the merits of their First Amendment claim. The court issued a preliminary injunction, enjoining the County from enforcing its policy of closing magistrations to the press and public, except in extraordinary circumstances and as constitutionally permitted.The United States Court of Appeals for the Fifth Circuit reviewed the case on appeal. The County argued that the district court erred in finding that the plaintiffs had standing and in determining that they were likely to succeed on the merits of their First Amendment claim. The Fifth Circuit affirmed the district court's ruling, agreeing that the plaintiffs had standing and that there is a presumptive First Amendment right of access to magistrations. The court applied the "experience and logic" test, finding that both historical practice and the positive role of public access in the functioning of bail hearings supported the plaintiffs' claim. The court concluded that the district court did not err in its determinations and upheld the preliminary injunction. View "Texas Tribune v. Caldwell County" on Justia Law

The case involves a challenge to Texas House Bill 20 (H.B. 20) by NetChoice, L.L.C. and the Computer & Communications Industry Association (CCIA). The plaintiffs argue that H.B. 20, which regulates content moderation by social media platforms, violates the First Amendment. The Supreme Court previously emphasized that facial challenges to state laws, especially under the First Amendment, require a thorough exploration of both the law's unconstitutional and constitutional applications. The Supreme Court found the record in this case to be underdeveloped, necessitating further factual discovery to determine who and what activities are covered by H.B. 20 and how these activities burden expression.The United States District Court for the Western District of Texas initially reviewed the case. The district court largely agreed with the plaintiffs that the issues were purely legal questions and required the State of Texas to complete discovery in a short period to avoid burdening the plaintiffs. The district court blocked extensive discovery, which the Supreme Court later indicated was necessary for a proper evaluation of the case.The United States Court of Appeals for the Fifth Circuit is currently reviewing the case. The court remanded the case to the district court for further proceedings consistent with the Supreme Court's instructions. The district court must now determine the full range of activities covered by H.B. 20, identify the actors involved, and assess how content moderation decisions burden expression. The district court must also separately consider the individualized-explanation provisions of H.B. 20 and evaluate whether these provisions unduly burden expressive activity. The Fifth Circuit emphasized that plaintiffs bear the burden of developing a factual record to support their facial challenge to H.B. 20. The case is remanded for further factual development and analysis. View "NetChoice v. Paxton" on Justia Law

Cedric Allen Ricks was convicted of capital murder in Texas state court for killing his girlfriend and her eight-year-old son and was sentenced to death. After his direct appeal and state habeas petition were denied, Ricks filed a federal habeas petition, which the district court also denied, including a certificate of appealability (COA).Ricks sought a COA from the United States Court of Appeals for the Fifth Circuit on several claims. The district court had denied his Batson claim, which alleged racial discrimination in jury selection, finding no prima facie case of discrimination and accepting the prosecution's race-neutral justifications. The district court also found no pattern of racially disparate questioning. The Fifth Circuit agreed, noting that reasonable jurists would not find the district court's assessment debatable or wrong, and thus denied the COA on this claim.Ricks also claimed ineffective assistance of appellate counsel for not raising the Batson claim on appeal. The state court had denied this claim on the merits. The Fifth Circuit found that since the Batson claim was meritless, the appellate counsel's failure to raise it was neither unreasonable nor prejudicial, and denied the COA on this claim as well.Ricks argued that his due process rights were violated when the jury saw him in shackles. The district court rejected this claim, noting that Ricks exposed his shackles himself and failed to show any substantial influence on the jury's verdict. The Fifth Circuit found this claim procedurally defaulted because it was not raised on direct appeal and was barred by the Texas Court of Criminal Appeals. Consequently, no COA was issued for this claim.Lastly, Ricks claimed ineffective assistance of trial counsel for not objecting to the shackling and for not challenging the State's peremptory strikes against female venire members. The Fifth Circuit found the trial counsel's decisions reasonable and strategic, and thus denied the COA on these claims.The Fifth Circuit denied the motion for a COA on all claims. View "Ricks v. Lumpkin" on Justia Law

Alex Francois, a Haitian national, left Haiti in 1979 to reunite with his U.S. citizen father. He has lived in New York City, raised six U.S. citizen children, and suffers from severe mental illnesses, including schizophrenia and bipolar disorder. Francois has been hospitalized multiple times for his mental health and has had several encounters with law enforcement, often related to his mental illness. In 2017, he was arrested for trespassing in Texas, found incompetent to stand trial, and subsequently transferred to U.S. Immigration and Customs Enforcement custody. The Department of Homeland Security charged him with removability under 8 U.S.C. § 1182(a)(6)(A)(i).The Immigration Judge (IJ) initially granted Francois withholding of removal, finding that he would likely be persecuted in Haiti due to his mental illness. The IJ based this decision on expert testimony and country conditions evidence, which highlighted the dire conditions and violent treatment of mentally ill individuals in Haitian prisons. The government appealed, and the Board of Immigration Appeals (BIA) remanded the case for further factfinding, questioning whether Francois would be singled out for persecution and whether there was a pattern of persecution against similarly situated individuals.The IJ, on remand, reversed the initial decision, denying Francois's claims for withholding of removal and protection under the Convention Against Torture (CAT). The IJ found that Francois had not proven he would be targeted for persecution in Haiti based on his mental illness. The BIA affirmed this decision, finding no clear error in the IJ's findings. Francois then filed a petition for review with the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit held that the BIA deprived Francois of due process by violating its own regulations, specifically by remanding for further factfinding instead of reviewing the IJ's initial findings for clear error. The court granted Francois's petitions for review, vacated the BIA's orders, and remanded the case for the BIA to review the IJ's initial order under the proper standards of review. View "Francois v. Garland" on Justia Law

In November 2023, X Corp. filed a lawsuit against Media Matters, Inc., Eric Hananoki, and Angelo Carusone, alleging interference with X Corp.'s contracts, business disparagement, and interference with prospective economic advantage. X Corp. claimed that Media Matters manipulated images to portray X Corp. as a platform dominated by neo-Nazism and anti-Semitism, which alienated advertisers, publishers, and users. During discovery, X Corp. requested Media Matters to produce documents identifying its donors and communications with them. Media Matters resisted, citing First Amendment concerns.The United States District Court for the Northern District of Texas initially ordered Media Matters to log documents responsive to X Corp.'s requests as privileged. However, Media Matters did not comply, arguing that the requests overlapped with other discovery requests. The district court then granted X Corp.'s motion to compel production, ruling that Media Matters had waived any First Amendment privilege by not searching for or logging the documents. Media Matters appealed the order and sought a stay pending appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that it had jurisdiction under the collateral order doctrine, as the discovery order involved important First Amendment issues that were separate from the merits of the case and would be effectively unreviewable on appeal. The court determined that Media Matters was likely to succeed on the merits of its appeal because the discovery requests were not proportional to the needs of the case and posed a significant burden on Media Matters and its donors. Consequently, the court granted Media Matters's motion for a stay pending appeal, staying the district court's order compelling production. View "X Corp v. Media Matters" on Justia Law

Dajuan Martin was arrested after being seen riding a stolen scooter in New Orleans. During the police pursuit, he discarded a Glock 26, 9mm semi-automatic handgun, which was later recovered with a magazine containing 16 rounds of ammunition. Martin pled guilty to being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The Presentence Investigation Report (PSR) calculated his offense level at 12, with a criminal history category of III, suggesting a sentencing range of 15 to 21 months. However, the government objected, arguing for a higher base offense level due to the firearm's large capacity magazine.The United States District Court for the Eastern District of Louisiana accepted the government's argument, raising Martin's base offense level to 20, resulting in a new sentencing range of 30 to 37 months. Martin was sentenced to 33 months of imprisonment and 3 years of supervised release. The court also imposed conditions for supervised release, including participation in a drug and alcohol treatment program and submission to searches under certain conditions. However, the written judgment included additional requirements not stated during the oral pronouncement.The United States Court of Appeals for the Fifth Circuit reviewed the case. Martin challenged the district court's application of the Sentencing Guidelines' commentary defining "large capacity magazine" and the discrepancies between the oral pronouncement and the written judgment regarding supervised release conditions. The Fifth Circuit upheld the district court's use of the commentary, finding it consistent with the Guidelines. However, it agreed with Martin that the written judgment improperly broadened the conditions of supervised release.The Fifth Circuit affirmed Martin's sentence in part, vacated it in part, and remanded the case for the district court to amend the written judgment to conform to the oral pronouncement. The court also rejected Martin's constitutional challenge to 18 U.S.C. § 922(g)(1), citing consistent precedent upholding the statute's constitutionality. View "USA v. Martin" on Justia Law

In response to challenges faced during the 2020 election, the Texas Legislature enacted S.B. 1 in 2021, which restricts paid "vote harvesting services." This law aims to protect the privacy of mail-in voters by prohibiting compensated interactions intended to influence votes. Plaintiffs, a coalition of organizations, challenged this provision on vagueness and First Amendment grounds, seeking injunctions against various Texas officials.The United States District Court for the Western District of Texas enjoined the enforcement of the vote harvesting provision of S.B. 1 on September 28, 2024, nearly three years after the law took effect and just three weeks before voting was to begin. The State of Texas then moved to stay the district court's order pending appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and granted the State's request for a stay. The court emphasized the Supreme Court's guidance in Purcell v. Gonzalez, which advises against altering election laws close to an election due to potential voter confusion and administrative burdens. The court found that the district court's injunction, issued after mail-in ballots had already been distributed, could lead to significant confusion and disruption.The Fifth Circuit held that the plaintiffs' constitutional challenge to S.B. 1 was not "entirely clearcut," failing to meet the criteria that might justify an exception to the Purcell principle. The court noted that the law's provisions were designed to protect voter privacy and security, similar to protections upheld by the Supreme Court for in-person voting. Consequently, the motion to stay the district court's injunction pending appeal was granted. View "La Union del Pueblo Entero v. Abbott" on Justia Law

Crusader Gun Group, L.L.C. applied for a Federal Firearms License (FFL) in November 2020, with Alan Aronstein identified as the president and responsible person. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) denied the application, citing Aronstein's history of willfully violating federal firearms laws through his previous roles in other firearms businesses. These violations included over 6,000 recordkeeping errors, failure to report the theft or loss of firearms, and possession of unlawful machine guns. Crusader requested a hearing, but the ATF upheld its decision, leading Crusader to seek judicial review.The United States District Court for the Southern District of Texas reviewed the case and granted summary judgment in favor of the ATF. The court found that the ATF was authorized to deny the application based on Aronstein's willful violations of federal firearms laws. Crusader's cross-motion for summary judgment was denied, prompting an appeal to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court's decision. The court held that the ATF was authorized to deny Crusader's FFL application under 18 U.S.C. § 923(d)(1)(C) because Aronstein, as the responsible person, had willfully violated federal firearms laws. The court also rejected Crusader's due process claims, noting that adequate procedural safeguards were in place, including notice, a hearing, and the opportunity for judicial review. Additionally, the court found no abuse of discretion in the district court's decision to stay discovery, as the administrative record was sufficient for summary judgment. The court concluded that the ATF's denial of the FFL application was lawful and supported by substantial evidence. View "Crusader Gun Group v. James" on Justia Law

Steve Winder became suicidal after discovering Facebook messages between his wife and her ex-husband. His wife, Latrisha, who was out of state, called her mother, Lou Anne, and the Young County Sheriff’s Department for a welfare check after Steve sent pictures of himself holding a gun to his head. Deputy Joshua Gallardo arrived at the scene, and after hearing Steve shout from within, opened the front door. Lou Anne indicated that Steve was armed. Deputy Gallardo then fatally shot Steve after ordering him to put the gun down.The United States District Court for the Northern District of Texas dismissed the case at the 12(b)(6) stage. The court found that Steve’s suicidality and possession of a gun created exigent circumstances excusing the need for a warrant. It also ruled that an objectively reasonable officer in Deputy Gallardo’s position would not need to wait for Steve to point the gun at him before using deadly force, thus defeating the excessive force claim. Additionally, the court found no underlying constitutional violation to support claims for supervisory or Monell liability and ruled that Title II of the ADA does not support claims where police officers face exigent circumstances.The United States Court of Appeals for the Fifth Circuit affirmed the District Court’s dismissal. The appellate court held that the exigent circumstances justified the warrantless entry and that Deputy Gallardo’s use of deadly force was reasonable under the circumstances. The court also found no basis for supervisory or Monell liability due to the absence of an underlying constitutional violation. Lastly, the court ruled that the ADA claims were foreclosed by the exigent circumstances and that there was no evidence that Steve was discriminated against by reason of his disability. View "Winder v. Gallardo" on Justia Law