Justia Constitutional Law Opinion Summaries

The case involves the American Rescue Plan Act (ARPA), which allocated nearly $200 billion to states and the District of Columbia to assist with economic recovery following the COVID-19 pandemic. However, to accept the funds, states had to agree not to use them to "directly or indirectly offset" reductions in state tax revenue. The states of Texas, Louisiana, and Mississippi filed a lawsuit seeking to enjoin the enforcement of this provision, arguing that it was unconstitutionally ambiguous and violated the Spending Clause and the anticommandeering doctrine.The district court granted summary judgment in favor of the states, finding that the provision was unduly coercive and commandeered the states. It held that the amount of money at stake was too great to present the states with a real choice and that the provision unlawfully forced the states to adopt certain tax policies. The court permanently enjoined the enforcement of the provision, and the federal defendants appealed.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the provision was impermissibly ambiguous and fell short of Congress's constitutional obligation to clearly outline the conditions for states accepting federal funding. The court held that the provision violated the Spending Clause's requirement for clarity, as it left states unable to determine the terms of the deal they were agreeing to. The court also affirmed the district court's grant of a permanent injunction against the enforcement of the provision. View "State of Texas v. Yellen" on Justia Law

Three individuals and the State of Texas filed a lawsuit seeking to enjoin federal statutes that criminalize the creation of silencers for personal use without paying a $200 excise tax, applying for permission from the federal government, and, if permission is granted, registering the silencer in a federal database and labeling the silencer with a serial number. The plaintiffs argued that these federal regulations violated their Second Amendment rights. In 2021, Texas had enacted a law stating that a firearm suppressor manufactured in Texas and remaining in Texas is not subject to federal law or regulation.The United States District Court for the Northern District of Texas granted summary judgment in favor of the federal government, holding that the plaintiffs lacked standing to bring their claims. The court did not address the merits of the plaintiffs' Second Amendment claims.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the individual plaintiffs failed to demonstrate an injury in fact, a requirement for standing, because they did not express a serious intention to engage in conduct proscribed by law. The court also found that Texas did not have standing to bring the lawsuit. The state's claim that it had a quasi-sovereign interest in its citizens' health and well-being was found to be wholly derivative of the personal Second Amendment interests of its citizens. Furthermore, the court found that Texas's claim that it had a sovereign interest in the power to create and enforce a legal code was not implicated in this case. The court concluded that the plaintiffs lacked standing to challenge the federal statutes. View "Paxton v. Dettelbach" on Justia Law

A group of individuals and businesses challenged the Affordable Care Act's requirement for private insurers to cover certain types of preventive care, including contraception, HPV vaccines, and drugs preventing HIV transmission. The plaintiffs argued that the mandates were unlawful because the agencies issuing them violated Article II of the Constitution, as their members were principal officers of the United States who had not been validly appointed under the Appointments Clause. The district court mostly agreed, vacating all agency actions taken to enforce the mandates and issuing both party-specific and universal injunctive relief.The United States Court of Appeals for the Fifth Circuit agreed that the United States Preventive Services Task Force, one of the challenged administrative bodies, was composed of principal officers who had not been validly appointed. However, the court found that the district court erred in vacating all agency actions taken to enforce the preventive-care mandates and in universally enjoining the defendants from enforcing them. The court also held that the Secretary of the Department of Health and Human Services had not validly cured the Task Force’s constitutional problems.The court affirmed in part, reversed in part, and remanded the case for further proceedings. The court did not rule on the plaintiffs' challenges against the other two administrative bodies involved in the case, the Advisory Committee on Immunization Practices and the Health Resources and Services Administration, reserving judgment on whether the Secretary had effectively ratified their recommendations and guidelines. View "Braidwood Mgmt v. Becerra" on Justia Law

A group of patrons of the Llano County library system in Texas sued the county, its officials, and the library's director and board, alleging that their First Amendment rights were violated when seventeen books were removed from the library due to their content. The plaintiffs claimed that the books, which covered topics such as sexuality, homosexuality, gender identity, and the history of racism, were removed because the defendants disagreed with their messages. The district court granted a preliminary injunction, requiring the defendants to return the books and preventing them from removing any other books during the lawsuit.The defendants appealed the decision, arguing that the removal of the books was part of the library's standard process of reviewing and updating its collection, known as the "Continuous Review, Evaluation and Weeding" (CREW) process. They also claimed that the plaintiffs could still access the books through an "in-house checkout system."The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision, but modified the language of the injunction to ensure its proper scope. The court found that the plaintiffs were likely to succeed on the merits of their First Amendment claim, as the evidence suggested that the defendants' substantial motivation in removing the books was to limit access to certain viewpoints. The court also found that the plaintiffs would likely suffer irreparable harm if the injunction was not granted, as they would be unable to anonymously peruse the books in the library without asking a librarian for access. The court concluded that the balance of the equities and the public interest also favored granting the injunction. View "Little v. Llano County" on Justia Law

The case involves Mid Valley Pipeline Company, an interstate pipeline company, and the Board of Mississippi Levee Commissioners. In 1949, the Levee Board granted Mid Valley a permit to construct and maintain two pipelines across a levee in Mississippi. The permit was not limited to a term of years and could be revoked by the Levee Board if Mid Valley failed to comply with any of the permit's conditions. In 2005, Mid Valley was instructed to relocate its pipelines, which it did at a cost of over $700,000. In 2020, the Levee Board informed Mid Valley that it would be charging an annual pipeline crossing fee and would revoke all existing permits for pipelines not currently paying the fee. Mid Valley did not respond to these notices.The United States District Court for the Northern District of Mississippi granted summary judgment in favor of the Levee Board, dismissing Mid Valley's claim that the imposition of the annual fee and the revocation of the permit violated the Contract Clause of the United States Constitution. The court reasoned that the 1949 permit was not a contract.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The appellate court agreed with the district court that the 1949 permit was not a contract. The court noted that under Mississippi law, a contract requires mutual assent, among other elements. The court found that the permit was a unilateral grant of permission by the Levee Board, and there was no evidence of mutual assent to form a contract. Therefore, the Levee Board's actions did not violate the Contract Clause. View "Mid Valley Pipeline v. Rodgers" on Justia Law

DC Operating, a strip club in El Paso, Texas, and two of its employees, Nuvia Medina and Michelle Corral, challenged the constitutionality of S.B. 315, a Texas law that raised the minimum age of employment at sexually-oriented businesses from 18 to 21. The law was enacted to curb human trafficking. The plaintiffs argued that the law infringed on the employees' constitutional rights to expressive interest in nude dancing and occupational freedom. They also raised a claim of sex discrimination under the Equal Protection Clause for the first time on appeal.The United States District Court for the Western District of Texas upheld the constitutionality of S.B. 315, following similar rulings in other cases. The plaintiffs then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit dismissed the appeal for lack of jurisdiction. The court found that DC Operating lacked standing to bring the appeal because it did not assert any legal interests of its own, only those of its employees. The court noted that a plaintiff must assert its own legal rights and interests and cannot rest its claim to relief on the legal rights or interests of third parties. The court also found that the overbreadth claim brought by DC Operating did not alter the standing analysis because the plaintiff still needed to satisfy Article III requirements.Furthermore, the court found that the appeal was moot as to the two employees, Medina and Corral, because they had turned 21 and were no longer subject to the law they were challenging. The plaintiffs did not argue that the employees' claims remained justiciable or that an exception to mootness applied. Therefore, the court dismissed the appeal for lack of jurisdiction. View "DC Operating v. Paxton" on Justia Law

The case involves a dispute arising from the financial fallout of Winter Storm Uri, which severely impacted Texas's electrical grid in 2021. The Electric Reliability Council of Texas (ERCOT), responsible for managing the grid, took measures including manipulating energy prices to incentivize production. This resulted in Entrust Energy, Inc., receiving an electricity bill from ERCOT of nearly $300 million, leading to Entrust's insolvency and subsequent bankruptcy filing. ERCOT filed a claim seeking payment of the invoice, which was challenged by Anna Phillips, the trustee of the Entrust Liquidating Trust. The trustee argued that ERCOT's price manipulation violated Texas law, that ERCOT was grossly negligent in its handling of the grid during the storm, and that ERCOT's transitioning of Entrust’s customers to another utility was an uncompensated taking in violation of the Fifth Amendment.The bankruptcy court declined to abstain from the case and denied ERCOT’s motion to dismiss all claims except for the takings claim. ERCOT appealed to the United States Court of Appeals for the Fifth Circuit, arguing that the bankruptcy court should have abstained under the Burford doctrine, which allows federal courts to abstain from complex state law issues to avoid disrupting state policies.The Fifth Circuit found that the bankruptcy court erred in refusing to abstain under the Burford doctrine. The court reversed the bankruptcy court's denial of ERCOT’s motion to abstain and its denial of ERCOT’s motion to dismiss the trustee’s complaint. The court also vacated the bankruptcy court’s order dismissing the takings claim with prejudice. The court remanded the case with instructions to dismiss certain counts and stay others pending the resolution of related state proceedings. View "Electric Reliability Council of Texas v. Phillips" on Justia Law

The case involves a challenge to the provisions of the Bipartisan Safer Communities Act of 2022, which expanded background checks for firearm purchases by individuals aged 18 to 20. The plaintiffs, Ethan McRorey, Kaylee Flores, Gun Owners of America, Inc., and Gun Owners Foundation, argued that the government failed to show a historical analogue for the Act's expanded background checks for this age group. They filed a lawsuit requesting a preliminary injunction after their attempts to purchase shotguns were delayed due to the National Instant Criminal Background Check System (NICS) protocols.The United States District Court for the Northern District of Texas denied the plaintiffs' request for a preliminary injunction. The court reasoned that while adults aged 18 to 20 are protected by the Second Amendment, laws barring the mentally ill and felons from possessing firearms are constitutional, and restrictions to further those ends are presumptively lawful. Therefore, the plaintiffs lacked a substantial likelihood of success on the merits and were not entitled to preliminary relief.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The appellate court held that background checks preceding firearm sales are presumptively constitutional, and the plaintiffs failed to rebut that presumption. The court also found that the plaintiffs had not shown that the challenged regulations had been put towards abusive ends or had otherwise rebutted the presumption of lawfulness. The court concluded that a period of 10 days for background checks does not qualify as being put towards abusive ends or as a de facto prohibition on possession. View "McRorey v. Garland" on Justia Law

Two members of the Lipan-Apache Native American Church, Gary Perez and Matilde Torres, sued the City of San Antonio over its development plan for Brackenridge Park. They claimed that the plan, which involved tree removal and bird deterrence measures, would prevent them from performing religious ceremonies in the park, violating their rights under the First Amendment, the Texas Religious Freedom Restoration Act, and the Texas Constitution. They sought an injunction requiring the city to grant them access to the park for worship, minimize tree removal, and allow cormorants to nest.The district court granted them access to the park for religious ceremonies but declined to enjoin the city's planned tree removal and bird deterrence measures. Both parties appealed this decision.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the city's development plan did not substantially burden the appellants' religious exercise. The court also found that the city's plan served two compelling interests: public health and safety, and compliance with federal law. The court concluded that the city's tree removal and bird deterrence plans were the least restrictive means to advance these interests. Therefore, the appellants failed to show a likelihood of success on the merits of their claims. The court also denied the appellants' emergency motion for an injunction pending appeal. View "Perez v. City of San Antonio" on Justia Law

Courtney D. Clayton was indicted on one count of possession with intent to distribute heroin, fentanyl, and cocaine. As part of a three-month drug trafficking investigation, officers conducted video surveillance of Clayton's home and placed GPS tracking devices on two vehicles associated with him. Based on the surveillance and information from a reliable confidential informant, officers obtained search warrants for Clayton's home and one of his vehicles. However, before the warrants could be executed, officers observed burglars break into Clayton's home. Believing that evidence of drug trafficking may have been stolen, officers continued their investigation for another two weeks before seeking a new warrant for Clayton's residence. The officers did not renew their search warrant for the vehicle.The district court denied Clayton's motion to suppress evidence found in his vehicle and his incriminating statement to law enforcement. Clayton contended that the search warrant of the vehicle had become stale, and that officers did not have probable cause to arrest him. He also argued that the Government failed to show that officers advised him of his constitutional rights pursuant to Miranda v. Arizona. After the denial of his motion to suppress, Clayton pleaded guilty but preserved his right to appeal the denial of his motion to suppress.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the search of Clayton's vehicle was proper under the automobile exception to the Fourth Amendment, which allows a warrantless search of a readily mobile vehicle when law enforcement has probable cause to believe the vehicle contains contraband or evidence of a crime. The court also found that Clayton failed to properly invoke his Fifth Amendment right to silence, as his indication through body language that he did not wish to speak to officers did not constitute a "simple, unambiguous statement" invoking his right to remain silent. View "United States v. Clayton" on Justia Law