Justia Constitutional Law Opinion Summaries

In 2022, two top officers of the Libertarian Party of Michigan resigned, leading to a power struggle within the party. Andrew Chadderdon became the acting Chair, but his leadership was contested by the defendants, who then voted to remove him and elected themselves to committee positions. The Libertarian Party Judicial Committee later voided these elections, reinstating Chadderdon. The defendants, however, continued to use the Libertarian National Committee’s (LNC) trademark, claiming to be the rightful leaders of the Michigan affiliate.The United States District Court for the Eastern District of Michigan granted the LNC’s request for a preliminary injunction, barring the defendants from using the LNC’s trademark. The defendants appealed, arguing that the district court’s application of the Lanham Act to their noncommercial speech violated the First Amendment and that their use of the trademark was authorized and not likely to cause confusion.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Lanham Act could apply to the defendants’ use of the LNC’s trademark because they used it as a source identifier for their political services, which falls within the scope of the Act. The court also determined that the defendants’ use of the trademark created a likelihood of confusion among potential voters, party members, and donors. However, the court found that the defendants’ use of the trademark for online solicitation, when accompanied by clear disclaimers, did not create a likelihood of confusion.The Sixth Circuit affirmed the preliminary injunction in part, except for the aspect concerning the defendants’ online solicitation with disclaimers, which it vacated. View "Libertarian National Committee, Inc. v. Saliba" on Justia Law

Nicholas Somberg, an attorney in Michigan, was representing a criminal defendant in the 52nd Judicial District. During a virtual courtroom conference, Somberg took a picture of the Zoom meeting without the judge's permission and posted it on Facebook. The Oakland County Prosecutor filed a motion to hold Somberg in contempt for violating Michigan court rules that prohibit recording or broadcasting judicial proceedings without permission. The court dismissed the motion on procedural grounds without addressing the rule's merits. Somberg, fearing future contempt actions, sued the prosecutor, seeking a declaration that the rule violates the First Amendment and an injunction to prevent its enforcement against him.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the prosecutor, concluding that the Electronics Rule satisfied First Amendment scrutiny. Somberg appealed the decision, arguing that the rule infringes on his constitutional rights.The United States Court of Appeals for the Sixth Circuit reviewed the case and focused on the issue of standing. The court held that Somberg lacked Article III standing to pursue his claim because he could not demonstrate causation and redressability. The court noted that even if the prosecutor were enjoined from seeking contempt sanctions, the court itself could still hold Somberg in contempt sua sponte. Additionally, third parties could refer Somberg for contempt proceedings. Therefore, the court concluded that the prosecutor was not the cause of Somberg's asserted future injury, and an injunction against her would not redress that injury. The court vacated the district court's order and remanded with instructions to dismiss the case for lack of jurisdiction. View "Somberg v. McDonald" on Justia Law

Two young African American boys died in a house fire after two City of Flint firefighters failed to properly search the home. The then-City Fire Chief, Raymond Barton, attempted to discharge the firefighters for gross misconduct. However, Flint’s Mayor, Sheldon Neeley, allegedly intervened to cover up the firefighters' actions to gain support from the firefighters’ union for his re-election. When Barton refused to comply with Neeley’s directives to alter official reports and make false public statements, Neeley fired him.In the United States District Court for the Eastern District of Michigan, Barton filed a lawsuit claiming that his termination was retaliation in violation of his First Amendment rights. The district court denied Neeley’s motion to dismiss based on qualified immunity, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Barton plausibly alleged a violation of his First Amendment rights, as public employees cannot be compelled to make false, politically motivated statements on matters of public concern in response to threats of retaliation. The court affirmed the district court’s denial of qualified immunity to Neeley, concluding that Barton’s refusal to alter reports and make false statements was protected speech, and that it was clearly established that such compelled speech and retaliation violated the First Amendment. View "Barton v. Neeley" on Justia Law

Victor S. Couzens, the senior pastor of Inspirational Bible Church (IBC), faced a significant decline in church membership and financial troubles following public accusations of an adulterous relationship. In response, church leaders organized a vote to remove him from his position. To enforce this decision, they hired off-duty police officers for the next Sunday service. When Couzens attempted to address the congregation, the officers threatened him with arrest, leading him to leave the church. Couzens subsequently sued the officers, their police chief, and the City of Forest Park, alleging a conspiracy to deny him his constitutional rights.The United States District Court for the Southern District of Ohio granted summary judgment in favor of the defendants. The court found that while the officers' actions could be seen as a seizure under the Fourth Amendment, their actions were not unreasonable. The court also determined that the free exercise claim failed because the police department's policy did not target religious conduct. Without constitutional violations from individual defendants, the court found no merit in the municipal liability and civil conspiracy claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the officers' actions were objectively reasonable given the circumstances and the evidence they had, including a letter indicating Couzens' removal as pastor. The court also found that Couzens failed to establish a violation of his First Amendment rights, as the officers' actions did not reflect state interference in church governance. Consequently, the court upheld the summary judgment on the constitutional, civil conspiracy, and municipal liability claims. View "Couzens v. City of Forest Park, Ohio" on Justia Law

Erick Williams was stopped by Memphis police for speeding and erratic driving. Officers smelled marijuana and saw an open beer can, leading them to search the car after a canine alert. They found a loaded pistol in the trunk. Williams, a convicted felon for aggravated robbery, was indicted for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The district court denied his motion, and Williams pled guilty while reserving the right to appeal.The United States District Court for the Western District of Tennessee denied Williams's motion to dismiss the indictment. Williams then appealed to the United States Court of Appeals for the Sixth Circuit, arguing that § 922(g)(1) was unconstitutional both on its face and as applied to him.The United States Court of Appeals for the Sixth Circuit reviewed the case and upheld the district court's decision. The court held that § 922(g)(1) does not violate the Second Amendment. The court reasoned that historical precedent supports the disarmament of individuals deemed dangerous, and Williams's criminal record, including convictions for aggravated robbery and attempted murder, demonstrated that he was dangerous. Therefore, the statute was constitutional as applied to him. The court also noted that while individuals must have an opportunity to show they are not dangerous, Williams failed to do so. The court affirmed the district court's decision, maintaining Williams's conviction under § 922(g)(1). View "United States v. Williams" on Justia Law

In this case, DEA agents, acting on an anonymous tip, conducted a four-month investigation into Robert Cortez Burrell's alleged drug trafficking activities. They surveilled Burrell, observed suspicious behavior consistent with drug transactions, and corroborated the tip with additional evidence, including Burrell's criminal history and interactions with known drug dealers. Based on this information, they obtained and executed search warrants for four residences associated with Burrell, recovering significant quantities of illegal narcotics, firearms, and drug-manufacturing equipment. Burrell was subsequently convicted by a jury of multiple drug-related offenses and being a felon in possession of firearms and ammunition, resulting in a 180-month prison sentence.The United States District Court for the Eastern District of Michigan denied Burrell's motion to suppress the evidence obtained from the searches, as well as his motion to dismiss the firearms and ammunition charges on Second Amendment grounds. The court found that the search warrants were supported by probable cause and that Burrell's motion to dismiss was untimely. Additionally, the court admitted testimony that Burrell argued violated the Confrontation Clause and the Federal Rules of Evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the search warrants were supported by probable cause, as the DEA agents had sufficiently corroborated the anonymous tip through extensive surveillance and other investigative methods. The court also found that the district court did not abuse its discretion in denying Burrell's motion to dismiss as untimely and that Burrell's constitutional challenges to the firearms and ammunition charges failed under the plain-error standard. Furthermore, the court ruled that the admission of the contested testimony did not violate the Confrontation Clause or the Federal Rules of Evidence, as the statements were not offered for their truth but to explain the DEA's actions. View "United States v. Burrell" on Justia Law

Joseph Fortin applied for disability insurance benefits, but his claim was denied by an Administrative Law Judge (ALJ) from the Social Security Administration (SSA). Fortin argued that the ALJ who denied his claim was improperly appointed because the then-Acting Commissioner of the SSA, Nancy Berryhill, lacked the authority to ratify the ALJ's appointment. Fortin did not challenge the merits of the ALJ's decision but focused on the validity of the ALJ's appointment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Commissioner of Social Security, rejecting Fortin's arguments. The court held that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ did not err in denying Fortin's application for benefits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Berryhill, as Acting Commissioner, had the authority to ratify the appointments of SSA ALJs in response to the Supreme Court's decision in Lucia v. Securities and Exchange Commission, which required ALJs to be appointed in accordance with the Appointments Clause. The court also concluded that Berryhill's actions were valid under the Federal Vacancies Reform Act and that she did not need to be reappointed by the sitting President to serve as Acting Commissioner. The court found that Berryhill's ratification of the ALJ's appointment was both constitutionally and statutorily valid, and therefore, Fortin was not entitled to a new hearing before a different ALJ. View "Fortin v. Commissioner of Social Security" on Justia Law

In 2020, Eric Noble, a security guard at the Cincinnati and Hamilton County Public Library, shared an insensitive meme on his personal Facebook page during the Black Lives Matter (BLM) protests. The meme, which was visible only to his Facebook friends, was taken down within 24 hours after his mother advised him to do so. However, some of his colleagues at the Library saw the post and complained. Following an investigation, the Library terminated Noble's employment, citing a violation of its harassment policy and a loss of confidence in his ability to perform his duties impartially.The United States District Court for the Southern District of Ohio granted summary judgment in favor of the defendants, holding that the Library's actions did not violate Noble's First Amendment rights as a public employee. Noble appealed the decision, arguing that his termination was a result of exercising his right to free speech.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Noble's Facebook post was protected speech under the First Amendment. The court found that Noble spoke on a matter of public concern and that his interest in expressing his views outweighed the Library's interest in maintaining workplace efficiency. The court noted that there was no evidence of public disruption or that Noble's post had a significant impact on Library operations. Consequently, the court remanded the case with instructions to grant summary judgment in favor of Noble on his First Amendment retaliation claim. View "Noble v. Cincinnati & Hamilton County Public Library" on Justia Law

The plaintiffs, who regularly engage in cryptocurrency transactions, challenged amendments to 26 U.S.C. § 6050I, which now require reporting certain cryptocurrency transactions to the federal government. They argued that the law violates their constitutional rights under the Fourth, First, and Fifth Amendments, and exceeds Congress's enumerated powers. The plaintiffs claimed that the law's requirements would force them to disclose private information, incur compliance costs, and potentially expose them to criminal penalties.The United States District Court for the Eastern District of Kentucky dismissed the case, finding that it lacked jurisdiction to consider the merits of the plaintiffs' claims. The court ruled that the claims were either not ripe for adjudication or that the plaintiffs lacked standing. Specifically, the court found that the Fourth Amendment claim was not ripe because the law was not yet effective and the Department of Treasury was still developing rules. The First Amendment claim was dismissed for lack of standing, as the court deemed the plaintiffs' injuries too speculative. The court also found the Fifth Amendment vagueness claim unripe due to pending regulatory action, and the enumerated-powers claim unripe for similar reasons. The Fifth Amendment self-incrimination claim was dismissed as not ripe because the plaintiffs had not yet asserted the privilege.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court erred in dismissing the enumerated-powers, Fourth Amendment, and First Amendment claims. The appellate court held that these claims were ripe for review and that the plaintiffs had standing. The court noted that the plaintiffs, as direct objects of the law, would indeed be subject to the reporting requirements and incur compliance costs, thus suffering an injury in fact. The court affirmed the district court's dismissal of the Fifth Amendment vagueness and self-incrimination claims as not ripe. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Carman v. Yellen" on Justia Law

Nathaniel Jackson was convicted of a capital offense and sentenced to death. His sentencing was marred by judicial bias and misconduct, including ex parte communications between the judge and prosecutor and the prosecutor ghostwriting the judge’s sentencing opinion. When this misconduct was revealed, the Ohio appellate courts ordered new sentencing proceedings. However, the trial judge denied Jackson’s motion to present additional mitigating evidence and resentenced him based on the old record, issuing a nearly identical opinion to the original one.The Ohio appellate courts affirmed Jackson’s sentence despite the trial judge’s misconduct. Jackson then filed a habeas corpus petition in federal district court. The district court granted the petition on the grounds that Jackson was unconstitutionally denied the opportunity to present mitigating evidence but denied his other claims, including judicial bias.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Ohio’s standard for assessing judicial bias was contrary to clearly established federal law. On de novo review, the court found that the trial judge was unconstitutionally biased. The court also held that the exclusion of mitigating evidence at Jackson’s resentencing violated the Eighth Amendment, as capital defendants have the right to present all relevant mitigating evidence. Consequently, the court affirmed the district court’s issuance of a writ of habeas corpus on the mitigating-evidence claim, reversed the denial on the judicial-bias claim, and remanded for further proceedings. View "Jackson v. Cool" on Justia Law