Justia Constitutional Law Opinion Summaries

An attorney, Daniel Crowe, challenged the requirement to join the Oregon State Bar (OSB), arguing it infringed on his First Amendment right to freedom of association. Crowe objected to statements published by OSB in its magazine, which he felt misrepresented his views. OSB refunded Crowe a portion of his dues used for the publication but did not satisfy his concerns, leading him to file a lawsuit seeking declaratory and injunctive relief, as well as damages.The United States District Court for the District of Oregon initially dismissed Crowe's claims, but the Ninth Circuit Court of Appeals partially reversed this decision, allowing the freedom of association claim to proceed. On remand, the district court granted summary judgment for OSB, holding that the bar's activities were germane to its regulatory purpose and did not violate Crowe's rights. Crowe appealed again.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that OSB is an arm of the state entitled to sovereign immunity, dismissing claims against OSB and for retrospective relief against its officers. However, the court found that Crowe demonstrated an infringement on his freedom of association because OSB's statements in its magazine could reasonably be imputed to its members, including Crowe, and were not related to the bar's regulatory purpose. The court concluded that this infringement did not survive exacting scrutiny.The Ninth Circuit reversed the district court's judgment regarding Crowe's freedom of association claim for prospective equitable relief against individual OSB officers and remanded the case for further proceedings. View "CROWE V. OREGON STATE BAR" on Justia Law

The case involves a challenge to the Hawai‘i Court Records Rules, which mandate that all medical and health records filed in any court proceeding be filed under seal without further judicial order. The plaintiff, Civil Beat Law Center for the Public Interest, argued that this rule is unconstitutionally overbroad under the First Amendment, which grants the public a presumptive right to access court records.The United States District Court for the District of Hawai‘i granted summary judgment in favor of the defendants, the Chief Court Administrators of the Hawai‘i state courts. The district court held that the public does not have a presumptive First Amendment right to access medical and health records, and even if such a right existed, requiring case-by-case litigation to unseal these records did not violate the First Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s judgment. The Ninth Circuit held that the First Amendment grants the public a presumptive right to access a substantial portion of the records sealed under Hawai‘i’s mandatory sealing provision. The court found that the state’s interest in protecting individual privacy rights does not justify the categorical sealing of all medical and health records without any case-by-case consideration. The court concluded that the mandatory sealing rule is not the least restrictive means of protecting privacy interests and that case-by-case judicial review would better balance privacy concerns with the public’s right to access.The Ninth Circuit held that the Hawai‘i Court Records Rules are unconstitutionally overbroad because they encroach on the public’s right of access to court records. The court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "CIVIL BEAT LAW CENTER FOR THE PUBLIC INTEREST, INC V. MAILE" on Justia Law

A resident of the Commonwealth of the Northern Mariana Islands (CNMI) filed a lawsuit seeking a declaratory judgment that the Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States precludes the application of a federal cockfighting prohibition. The plaintiff also sought an injunction to prevent the enforcement of this prohibition. The federal cockfighting prohibition, codified in 7 U.S.C. § 2156 and amended in 2018, made cockfighting illegal in all U.S. jurisdictions, including the CNMI.The U.S. District Court for the Northern Mariana Islands dismissed the complaint with prejudice, finding that the federal cockfighting prohibition applied to the CNMI under the Covenant. The district court determined that 7 U.S.C. § 2156 was applicable to Guam and the several states as required by Covenant § 502, and thus also applicable to the CNMI. The court also found that Covenant § 105, which governs laws enacted after January 9, 1978, did not apply to amendments of laws that existed on that date.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that Covenant § 502 governs the applicability of 7 U.S.C. § 2156 and its 2018 Amendment to the CNMI. The court found that § 2156 was applicable to Guam and the several states as of January 9, 1978, and thus applicable to the CNMI. The court also held that even if Covenant § 105 were to govern, the federal cockfighting prohibition would still apply to the CNMI because it is applicable to the several states and does not impermissibly intrude upon the internal affairs of the CNMI. The court concluded that the federal interests in regulating interstate commerce, ensuring the humane treatment of animals, and preventing the spread of avian flu outweighed any intrusion into the CNMI’s internal affairs. The judgment was affirmed. View "SALAS V. USA" on Justia Law

The plaintiffs, parents of Idaho school children, sought reimbursement for fees associated with educational and extracurricular activities within Idaho public school districts. They argued that these fees were improperly assessed because the Idaho Constitution mandates "free common schools," and that the payment of such fees constituted a taking of property without due process, violating the Takings Clause of the Fifth Amendment.The United States District Court for the District of Idaho initially denied the school districts' motion for summary judgment, concluding that the plaintiffs had a property interest in a free education under the Idaho Constitution. However, the case was later reassigned to a different district judge, who revisited the issue. The second district judge granted summary judgment in favor of the school districts, concluding that the plaintiffs did not possess a property right protected by the Takings Clause because the right to a free public education in Idaho does not constitute a vested private property interest.The United States Court of Appeals for the Ninth Circuit affirmed the district court's summary judgment. The court held that the Idaho Constitution does not create a vested private property interest in specific educational benefits. It determined that public education in Idaho lacks the essential characteristics of private property, such as the right to possess, use, dispose of, or sell. Therefore, money paid to satisfy fees related to supplemental educational services is not subject to a Takings Clause claim. The court also clarified that a second district judge should not reconsider a prior judge's ruling unless specific conditions are met, but found any procedural error in this case to be harmless. View "Zeyen v. Bonneville Joint District" on Justia Law

Gail Manney was convicted for violating 18 U.S.C. § 922(a)(6), which criminalizes making false statements in connection with the acquisition of firearms. On April 21, 2021, Manney visited Hi-Cap Firearms in Reno, Nevada, and selected seven handguns to purchase. She filled out the required ATF Form 4473, certifying she was the actual purchaser. However, after her purchase, a Hi-Cap employee suspected her of being a straw purchaser and contacted the ATF. Upon investigation, ATF Special Agent Joshua Caron found incriminating messages on Manney’s phone indicating she was buying the firearms for her son, Razaaq, a convicted felon prohibited from possessing firearms.The United States District Court for the District of Nevada indicted Manney on May 27, 2021, for making false statements on ATF Form 4473. She was convicted after a jury trial. Manney appealed, arguing that 18 U.S.C. § 922(a)(6) violated her Second Amendment rights and that her false statement was not material under the statute.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court rejected Manney’s Second Amendment challenge, stating that the Second Amendment does not protect false statements. The court emphasized that § 922(a)(6) regulates false statements made during firearm acquisitions, not the possession of firearms. The court also dismissed Manney’s argument regarding the materiality of her false statement, citing Abramski v. United States, which held that a false statement about the actual purchaser of a firearm is material even if the actual purchaser could legally possess a firearm.The Ninth Circuit affirmed Manney’s conviction, concluding that § 922(a)(6) did not violate her Second Amendment rights and that her false statement was material under the statute. View "USA V. MANNEY" on Justia Law

The case involves a class action lawsuit against the Maricopa County Sheriff’s Office (MCSO) for racially profiling Latino drivers and passengers under the guise of immigration enforcement. Plaintiffs sought declaratory and injunctive relief for violations of their Fourth and Fourteenth Amendment rights. The district court issued a permanent injunction in 2013, followed by a supplemental injunction appointing an independent monitor to oversee MCSO’s compliance. In 2016, a second supplemental injunction required MCSO to reform its internal misconduct investigation procedures. In 2022, a third supplemental injunction found the Sheriff in contempt for non-compliance and set forth curative measures, including creating a Constitutional Policing Authority (CPA) and assigning its duties to the Monitor.The United States District Court for the District of Arizona initially issued the permanent injunction and subsequent supplemental injunctions. The court found MCSO in contempt for failing to comply with the injunctions and ordered additional remedial measures. The district court relied on its inherent equitable powers rather than Federal Rule of Civil Procedure 53 in issuing these orders.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court’s amended third supplemental permanent injunction. It held that the district court acted within its inherent equitable powers in assigning the CPA’s duties to the Monitor. The court rejected the Sheriff’s contention that this assignment violated Article III of the Constitution and separation of powers principles. It also found that the First Order provided adequate judicial review of the Monitor’s actions and that the Third Order did not contravene Federal Rule of Civil Procedure 65’s specificity requirement. The Ninth Circuit concluded that the district court’s actions were appropriate and affirmed the Third Order. View "MELENDRES V. SKINNER" on Justia Law

A national trade association of online businesses challenged the California Age-Appropriate Design Code Act (CAADCA), which aims to protect children's online privacy and ensure that online products accessed by children are designed with their needs in mind. The association argued that the CAADCA's requirements, particularly those mandating businesses to assess and mitigate risks of exposing children to harmful content, violated the First Amendment.The United States District Court for the Northern District of California granted a preliminary injunction, finding that the association was likely to succeed in its First Amendment challenge. The court held that the CAADCA's requirements compelled businesses to express opinions on controversial issues and act as censors, which constituted a violation of free speech. The court enjoined the entire law, concluding that the unconstitutional provisions were not severable from the rest of the statute.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed in part and vacated in part the district court's preliminary injunction. The Ninth Circuit agreed that the CAADCA's requirement for businesses to create Data Protection Impact Assessment (DPIA) reports, which included assessing and mitigating risks of exposing children to harmful content, likely violated the First Amendment. The court affirmed the injunction against these provisions and those not grammatically severable from them.However, the Ninth Circuit vacated the remainder of the preliminary injunction, finding that it was unclear whether other challenged provisions of the CAADCA facially violated the First Amendment. The court noted that further proceedings were necessary to determine the full scope and impact of these provisions. The case was remanded to the district court for further consideration. View "NETCHOICE, LLC V. BONTA" on Justia Law

Claude Stephen Bent, a lawful permanent resident from Jamaica, pleaded no contest to two felony charges in California in 2006. The judge did not inform him of the immigration consequences of his plea. After serving his sentence, Bent was detained by the Department of Homeland Security (DHS) in 2016 and charged with removability based on his felony conviction. Bent applied for asylum and other relief, but an immigration judge (IJ) denied his application and ordered his removal. The Board of Immigration Appeals (BIA) affirmed the IJ's decision. Bent appealed to the Ninth Circuit, which remanded the case to the BIA. The BIA again dismissed his appeal, and Bent petitioned for review.Bent moved to vacate his 2006 conviction in California state court, which was granted in 2022 on the grounds that his plea was involuntary and violated his Fifth Amendment rights. Bent then moved to reopen his removal proceedings before the BIA, arguing that his vacated conviction invalidated the basis for his removal. The BIA denied the motion, stating it was untimely and not subject to equitable tolling, and mischaracterized the California statute as allowing vacatur solely to mitigate immigration consequences.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court found that the BIA erred in its interpretation of California Penal Code § 1473.7(a)(1) and the state court's order, which vacated Bent's conviction due to a constitutional defect, not to alleviate immigration consequences. The Ninth Circuit also held that the BIA misapplied equitable tolling precedent by not properly assessing whether Bent diligently pursued his rights. The court granted Bent's petition for review in part and remanded the case to the BIA to adjudicate his motion to reopen under the correct legal standards. View "BENT V. GARLAND" on Justia Law

In this case, the plaintiffs, Election Integrity Project California, Inc., and ten former political candidates, challenged the California Secretary of State’s certification of the November 2020 general election results and sought to declare California’s vote-by-mail election system unconstitutional. They alleged that state and county officials diluted the voting power of in-person voters and voters in certain counties by inadvertently counting some invalid vote-by-mail ballots.The United States District Court for the Central District of California dismissed the plaintiffs’ claims for failure to state a claim. The district court concluded that even if all the plaintiffs’ allegations were true, they failed to state plausible claims of constitutional violations in the administration of California’s elections. The plaintiffs appealed the dismissal.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal. The Ninth Circuit held that the plaintiffs’ vote dilution claim failed as a matter of law because they did not show disproportionate voting power for some voters over others. The court found that any effect of counting invalid vote-by-mail ballots was the same for all votes, regardless of voting method or geography. The court also rejected the plaintiffs’ claim that California’s election laws and county practices violated the Equal Protection Clause, finding that the state’s election rules and practices satisfied the requirements of equal treatment and fundamental fairness. Additionally, the court found that the plaintiffs’ allegations of election irregularities did not plausibly demonstrate the scale of disenfranchisement or lack of integrity necessary to state a due process claim.Finally, the Ninth Circuit held that the district court did not abuse its discretion by denying the plaintiffs a further opportunity to amend their complaint, as any further amendment would likely prove futile. The court affirmed the district court’s order dismissing the plaintiffs’ claims without leave to amend. View "ELECTION INTEGRITY PROJECT CALIFORNIA, INC. V. WEBER" on Justia Law

In 1984, Roger Scott Helm, Jr., then 14 years old, murdered his adoptive parents and stepsister. He was arrested and charged with multiple counts, including first-degree murder. Helm pleaded guilty to one count of first-degree murder, two counts of second-degree murder, and one count of armed robbery. The trial court sentenced him to life imprisonment for the first-degree murder with eligibility for parole after 25 years, followed by consecutive sentences totaling an additional 42 years for the other counts.Helm's case was transferred from juvenile to adult court, and he was sentenced after a detailed hearing where the court considered mitigating factors such as his age and drug influence, as well as aggravating factors like his lack of remorse and dangerousness. The Arizona Supreme Court upheld the consecutive sentences on direct appeal.Helm later filed for post-conviction relief, arguing that his sentence violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life without parole for juveniles. The Arizona trial court and the Arizona Court of Appeals rejected his claim, stating that Miller does not apply to consecutive sentences for multiple crimes. The Arizona Supreme Court denied review.The United States Court of Appeals for the Ninth Circuit reviewed Helm's habeas corpus petition. The court assumed, for argument's sake, that Helm's sentence was the functional equivalent of life without parole. However, it concluded that Helm's sentence complied with Miller because the trial judge had discretion and considered Helm's youth before imposing the sentence. The Ninth Circuit affirmed the district court's denial of Helm's habeas corpus petition, holding that Helm's sentence did not violate the Eighth Amendment as interpreted in Miller and clarified in Jones v. Mississippi. View "Helm v. Thornell" on Justia Law