Justia Constitutional Law Opinion Summaries

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

Dr. Ronald S. Hines, a retired and physically disabled veterinarian licensed in Texas, provided online pet-care advice without physically examining the animals. Texas law requires veterinarians to establish a veterinarian-client-patient relationship (VCPR) through an in-person examination or a visit to the premises where the animal is kept before offering veterinary advice. Dr. Hines was penalized for violating this requirement, receiving probation, a fine, and being forced to retake a licensing exam. He challenged the law on First Amendment grounds, arguing that it unconstitutionally restricted his speech.The United States District Court for the Southern District of Texas initially dismissed Dr. Hines's First Amendment claim, but the Fifth Circuit Court of Appeals reversed and remanded the case for further consideration in light of new Supreme Court precedent. On remand, the district court granted summary judgment for the State, concluding that the law regulated Dr. Hines's speech in a content-neutral way and survived intermediate scrutiny. Dr. Hines appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and determined that the physical-examination requirement primarily regulated Dr. Hines's speech rather than his conduct. The court found that the State failed to demonstrate that the harms it sought to address with the law were real and that the law alleviated these harms in a direct and material way. The court also concluded that the law was not narrowly tailored to serve the State's interests, as it burdened substantially more speech than necessary. Consequently, the Fifth Circuit reversed the district court's judgment and remanded the case with instructions to enter judgment for Dr. Hines, upholding his First Amendment rights. View "Hines v. Pardue" on Justia Law

The case involves the National Infusion Center Association (NICA) and other plaintiffs challenging the constitutionality of the Drug Price Negotiation Program established by the Inflation Reduction Act. This program requires the Department of Health and Human Services (HHS) to negotiate drug prices with manufacturers, setting a "maximum fair price" between 40% and 75% of the market price. Manufacturers who do not comply face significant fines or must withdraw from Medicare coverage entirely.The United States District Court for the Western District of Texas dismissed NICA's lawsuit for lack of subject-matter jurisdiction. The district court reasoned that NICA's claims had to be "channeled" through HHS as required by 42 U.S.C. § 405, which mandates that claims arising under the Medicare Act be decided by the relevant agency before being brought to federal court. The district court also dismissed the remaining plaintiffs due to improper venue without NICA.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that NICA had standing based on both economic and procedural injuries. The court determined that NICA's claims did not arise under the Medicare Act but rather under the Inflation Reduction Act, and thus did not require channeling through HHS. The court held that the district court had subject-matter jurisdiction over NICA's claims and reversed the lower court's dismissal, remanding the case for further proceedings. View "Natl Infusion Center v. Becerra" on Justia Law

On November 4, 2020, San Antonio police officers stopped a car driven by Ronnie Diaz, Jr. They detected a strong odor of marijuana and found empty baggies commonly used for narcotics. Diaz admitted to having ammunition in his pocket and being a convicted felon. A search of the vehicle revealed a .45 caliber pistol, methamphetamine, counterfeit Xanax, and heroin. Diaz had prior convictions, including theft of a vehicle and evading arrest in 2014, and possession of a firearm as a felon in 2018.Diaz was charged in the Western District of Texas with possession with intent to distribute methamphetamine, possessing firearms during a drug trafficking crime, and being a felon in possession of a firearm. He moved to dismiss the felon-in-possession charge, arguing it violated the Second Amendment. The district court denied the motion, and Diaz was convicted on all counts and sentenced to 120 months for counts one and three, to run concurrently, and 60 months for count two, to run consecutively.The United States Court of Appeals for the Fifth Circuit reviewed the case. Diaz raised two claims: that his conviction under 18 U.S.C. § 922(g)(1) was unconstitutional under the Second Amendment, both facially and as applied, and that the statute exceeded Congress’s power under the Commerce Clause. The court dismissed the Commerce Clause argument as foreclosed by precedent. Applying the historical analysis required by New York Rifle and Pistol Association, Inc. v. Bruen, the court found that the regulation of firearm possession by felons is consistent with the Nation’s historical tradition of firearm regulation. The court held that 18 U.S.C. § 922(g)(1) is constitutional as applied to Diaz and facially. Consequently, the Fifth Circuit affirmed Diaz’s conviction. View "United States v. Diaz" on Justia Law

Astrid Dariana Lopez Orellana, a noncitizen, entered the U.S. without inspection in 2019, fleeing gang threats in Honduras. In 2022, she was convicted of accessory after the fact to armed robbery under Louisiana law. Subsequently, she was taken into ICE custody and designated as an aggravated felon, leading to expedited removal proceedings.The Department of Homeland Security (DHS) issued a Final Administrative Removal Order (FARO) and a Notice of Intent (NOI) to remove her, alleging her conviction was an aggravated felony. Lopez requested withholding of removal, and an asylum officer found she had a reasonable fear of persecution if returned to Honduras. Her case was referred to an Immigration Judge (IJ). DHS later issued a new NOI and FARO on the same day, claiming her conviction was an aggravated felony related to obstruction of justice. Lopez challenged this, arguing the Louisiana statute did not match the federal definition of obstruction of justice, and that DHS violated procedural regulations.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the Louisiana accessory-after-the-fact statute requires only general intent, whereas the federal obstruction of justice offense requires specific intent. Therefore, the state statute is not a categorical match for the federal offense. The court also determined that DHS violated Lopez’s due process rights by not following proper procedures, such as issuing the FARO and NOI on the same day and failing to serve the FARO in a timely manner.The Fifth Circuit granted Lopez’s petition for review, vacated the order of removal, and remanded the case to DHS for further proceedings consistent with its opinion. The court directed the government to facilitate Lopez’s participation in these proceedings. View "Orellana v. Garland" on Justia Law

Independent candidates and minor political parties in Texas challenged several provisions of the Texas Election Code, arguing that these provisions, when combined, violate their First and Fourteenth Amendment rights by imposing severe and unequal burdens on non-wealthy Independents and Minor Parties. The provisions in question include requirements for obtaining ballot access through primary elections, party nominations, or nominating petitions, as well as restrictions on petitioning methods and timelines.The United States District Court for the Western District of Texas denied the plaintiffs' motion for a preliminary injunction and the defendants' motion to dismiss. The court granted in part and denied in part the parties' cross-motions for summary judgment. The district court found that the requirement for candidates to submit hardcopy signatures for ballot access petitions was unconstitutional, reasoning that it imposed an unequal burden on the plaintiffs compared to Major Parties, which could use electronic methods. The court enjoined the enforcement of the paper-petitioning process but stayed its injunction pending appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and applied the Anderson-Burdick framework to evaluate the constitutionality of the ballot-access laws. The court found that the plaintiffs failed to prove that the challenged provisions imposed severe burdens on them. The court upheld the numerical signature requirement, the costs associated with obtaining signatures, the time constraints on petitioning, and the restrictive petitioning procedures as justified by legitimate state interests. The court also upheld the filing fee or petition requirement for Minor Party candidates and rejected the claim that the provisions imposed more severe restrictions on presidential Independents.The Fifth Circuit reversed the district court's finding that the paper-petitioning requirement was unconstitutional, noting that all candidates, regardless of party affiliation, must obtain petition signatures through hardcopy methods. The court affirmed the constitutionality of the challenged provisions and rendered judgment in favor of the defendants. View "Miller v. Nelson" on Justia Law