Justia Constitutional Law Opinion Summaries

A twelve-year-old boy named Maxwell was abused and killed by his father and stepmother. His mother, Sara Coon, sued Lebanon County and several county officials, alleging that the county knew about the abuse and had a state-law duty to protect Maxwell. The complaint stated that the county's Children and Youth Services agency failed to act despite multiple warnings about the abuse.The United States District Court for the Middle District of Pennsylvania dismissed the federal claims brought under 42 U.S.C. § 1983, concluding that Pennsylvania’s Child Protective Services Law did not create a property interest in having the county agency protect Maxwell from child abuse. The court also remanded the state-law claims to state court.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that due process protects interests in life, liberty, or property, and to state a claim for violating procedural due process, a plaintiff must show a legitimate claim of entitlement to a protected property interest. The court found that Pennsylvania law did not create such a property interest in having a county agency protect a child from abuse. The court compared this case to Town of Castle Rock v. Gonzales and Burella v. City of Philadelphia, where similar statutory language did not create a property interest. Consequently, the Third Circuit affirmed the District Court’s order dismissing the federal claims and remanding the state claims to state court. View "Coon v. County of Lebanon" on Justia Law

Jamal Morton was convicted in 2012 in the Virgin Islands Superior Court of second-degree murder and various firearm offenses, receiving a fifty-year sentence. After his conviction was affirmed on direct appeal, Morton filed a territorial habeas petition in 2014, raising twenty claims, including violations of his Fifth and Sixth Amendment rights. Despite his numerous attempts to move the case forward, including motions for default judgment, discovery requests, and status conference requests, the Superior Court took no substantive action for nearly six years.Frustrated by the inaction, Morton filed a federal habeas petition in the U.S. District Court of the Virgin Islands in April 2020, raising the same claims. The District Court dismissed his petition without prejudice, citing his failure to exhaust territorial court remedies. The court reasoned that Morton had not taken sufficient steps, such as seeking a writ of mandamus from the Virgin Islands Supreme Court, to address the delay in the territorial court.The United States Court of Appeals for the Third Circuit reviewed the case and found that the nearly six-year delay in the territorial court, coupled with the lack of progress and Morton’s reasonable efforts to advance his case, constituted inordinate delay. The Third Circuit held that the District Court erred by not requiring the Government to justify the delay before dismissing Morton’s petition. The court vacated the District Court’s dismissal and remanded the case, instructing the lower court to allow the Government to provide any justifications for the delay and proceed accordingly. View "Morton v. Director Virgin Islands Bureau of Corrections" on Justia Law

In 2008, Diontai Moore was investigated for drug crimes, leading to his arrest and a guilty plea for distributing cocaine base. He was sentenced to 72 months in prison followed by three years of supervised release. In 2013, while on supervised release, Moore was found with a handgun and subsequently pleaded guilty to being a felon in possession of a firearm, resulting in a 60-month prison sentence and another three years of supervised release. In 2021, during his supervised release, Moore used a firearm to confront intruders at his fiancée’s home, leading to his arrest and charges for violating 18 U.S.C. § 922(g)(1).The United States District Court for the Western District of Pennsylvania sentenced Moore to 84 months in prison followed by three years of supervised release after he pleaded guilty to the firearm possession charge. Moore reserved the right to appeal the constitutionality of § 922(g)(1) as applied to him.The United States Court of Appeals for the Third Circuit reviewed the case and held that Moore, as a convict on supervised release, does not have a Second Amendment right to possess a firearm. The court found that historical analogues, such as 18th-century forfeiture laws, supported the disarmament of convicts during their sentences. The court concluded that these historical practices justified the application of § 922(g)(1) to Moore. Consequently, the court affirmed Moore’s conviction, rejecting his as-applied and facial challenges to the statute. View "United States v. Moore" on Justia Law

Rachel Spivack, an employee at the Philadelphia District Attorney’s Office (DAO), was subject to a COVID-19 vaccine mandate. The DAO denied her request for a religious exemption, leading to her termination. Spivack then sued the City of Philadelphia and District Attorney Lawrence Krasner, alleging that the mandate violated her constitutional right to the free exercise of religion.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the defendants, holding that the vaccine mandate was neutral and generally applicable, thus subject to rational basis review. The court found that the mandate was rationally related to the DAO’s interests in curtailing the spread of COVID-19, avoiding staffing shortages, and reducing the risk of death and serious illness among DAO staff and the public. The court also held that the mandate satisfied strict scrutiny as an alternative ruling. Spivack appealed the decision.The United States Court of Appeals for the Third Circuit reviewed the case and found that there were disputes of material fact that needed to be resolved by a jury. Specifically, the court noted that it was unclear whether Spivack’s exemption request was evaluated under the August 2021 policy, which allowed for individualized, discretionary religious exemptions, or the January 2022 policy, which categorically denied religious exemptions. Additionally, the court found that comments made by Krasner during his deposition could be interpreted as showing hostility toward religious beliefs, which would undermine the neutrality of the policy.The Third Circuit vacated the District Court’s order and remanded the case for trial, instructing that a jury must resolve these factual disputes to determine the applicable standard of scrutiny. If the policy is found to be neutral and generally applicable, it would be subject to rational basis review. If not, it would be subject to strict scrutiny. View "Spivack v. City of Philadelphia" on Justia Law

The New Jersey Staffing Alliance, the American Staffing Association, and the New Jersey Business and Industry Association sought to enjoin a New Jersey law designed to protect temporary workers. The law, known as the Temporary Workers’ Bill of Rights, mandates recordkeeping, disclosure requirements, and state certification procedures for staffing firms. It also imposes joint and several liability on clients hiring temporary workers and requires staffing firms to pay temporary workers wages equivalent to those of permanent employees performing similar work.The United States District Court for the District of New Jersey denied the preliminary injunction, concluding that the Staffing Associations were unlikely to succeed on the merits of their claims. The court found that the law did not discriminate against out-of-state businesses, as it imposed the same burdens on both in-state and out-of-state firms. The court also rejected the void-for-vagueness claim, reasoning that the law provided sufficient guidance on its requirements. Additionally, the court determined that the law was a reasonable exercise of New Jersey’s police power, as it was rationally related to the legitimate state interest of protecting temporary workers.The United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit agreed that the Staffing Associations failed to show a likelihood of success on their claims. The court held that the law did not violate the dormant Commerce Clause, as it did not favor in-state businesses over out-of-state competitors. The court also found that the law was not unconstitutionally vague, as it provided adequate notice of its requirements. Finally, the court upheld the law as a permissible exercise of state police power, as it was rationally related to the goal of protecting temporary workers. View "New Jersey Staffing Alliance v. Fais" on Justia Law

Delaware residents and organizations challenged two new state gun laws in federal court. One law bans the possession, manufacture, sale, and transport of "assault weapons," while the other bans magazines that hold more than seventeen rounds. The plaintiffs sought a preliminary injunction to prevent the enforcement of these laws, arguing that they violated the Second and Fourteenth Amendments.The United States District Court for the District of Delaware denied the preliminary injunction. The court found that the plaintiffs were unlikely to succeed on the merits because the laws were consistent with the nation's historical tradition of firearm regulation. Additionally, the court did not presume that all Second Amendment harms are irreparable and noted that the plaintiffs retained ample alternatives for self-defense. The court did not reach the other factors for granting a preliminary injunction due to the plaintiffs' failure to show a likelihood of success or irreparable harm.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit emphasized that a preliminary injunction is an extraordinary remedy that should not be granted automatically, even if the plaintiffs are likely to succeed on the merits. The court highlighted that the primary purpose of a preliminary injunction is to preserve the status quo and the court's ability to render a meaningful judgment, not merely to prevent harm. The court found that the plaintiffs failed to demonstrate irreparable harm, as they did not provide evidence that Delaware had attempted to enforce the laws against them or that they had an urgent need for the banned firearms and magazines. The court also noted that the balance of equities and public interest weighed against granting the injunction, given the importance of respecting state sovereignty and the democratic process. View "Delaware State Sportsmens Association Inc v. Delaware Department of Safety and Homeland Security" on Justia Law

The case involves Tahjair Dorsey, who was convicted for possession of a firearm by a convicted felon under 18 U.S.C. § 922(g)(1). Dorsey had previously pleaded guilty to carrying a firearm without a license, a felony under Pennsylvania law. He was paroled in June 2021. In August 2021, during an investigation into suspected gang activity, Dorsey was observed leaving a residence under surveillance and was apprehended after fleeing a vehicle stop. A stolen handgun was recovered nearby, and Dorsey's DNA was found on it. He was subsequently indicted for being a felon in possession of a firearm.Dorsey pleaded guilty but later appealed his conviction, arguing that § 922(g)(1) was unconstitutional as applied to him under the Second Amendment. However, he had not raised this objection at any stage of the District Court proceedings. The District Court sentenced Dorsey to time served and three years of supervised release.The United States Court of Appeals for the Third Circuit reviewed the case for plain error. The court referred to its en banc decision in Range v. Attorney General, which held that disarming an individual with a single, almost-thirty-year-old criminal conviction for food stamp fraud was not consistent with the Second Amendment. The court found that Dorsey could not show that he was similarly situated to the appellant in Range for Second Amendment purposes. The court noted that Dorsey's prior conviction was for a state firearm law violation, was more recent, and he was on state parole at the time of the offense. The court concluded that any Second Amendment error inherent in Dorsey’s conviction was not plain and affirmed the lower court's decision. View "USA v. Dorsey" on Justia Law

The case revolves around a local ordinance in the Borough of Camp Hill that regulates the display of signs on private property. The ordinance categorizes signs into about twenty different types, each with its own set of restrictions. Two residents, Katherine Pearson and Caroline Machiraju, displayed political signs on their lawns in the lead-up to the 2022 midterm elections. However, they were told to remove their signs as they violated the local sign ordinance. The ordinance categorized their signs as "Temporary Signs" and further classified them as "Personal Expression Signs," which express a non-commercial message. The ordinance limited the number of such signs a resident could display and the time frame within which they could be displayed.The residents complied with the directive but subsequently sued Camp Hill, challenging the provisions of the ordinance under the First Amendment. The United States District Court for the Middle District of Pennsylvania granted them summary judgment on their facial challenge, ruling that the provisions were content-based and failed strict scrutiny.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals found that the ordinance was content-based as it classified signs based on their content, favoring commercial expression over noncommercial and holiday messages over non-holiday messages. The court held that such content-based restrictions could only stand if they furthered a compelling government interest and were narrowly tailored to achieve that interest. The court found that Camp Hill's interests in traffic safety and aesthetics, while legitimate, were not compelling and that the ordinance was not narrowly tailored to serve those interests. The court concluded that the ordinance was unconstitutional on its face. View "Camp Hill Borough Republican Association v. Borough of Camp HIll" on Justia Law

The case involves a challenge to New Jersey's primary election ballot design, known as the "county-line" ballot. The plaintiffs, Andy Kim, Sarah Schoengood, and Carolyn Rush, who are all Democratic candidates for various offices, argue that the county-line ballot design infringes their First Amendment rights. They contend that the design unfairly favors candidates endorsed by local party leaders, placing them in prime ballot positions, while disadvantaging those who are not endorsed or choose not to associate with certain candidates.The case was initially heard in the United States District Court for the District of New Jersey, where the plaintiffs sought a preliminary injunction to prevent the use of county-line ballots and require the use of office-block format ballots instead. The District Court granted the injunction, finding that the plaintiffs had shown a severe burden on their First Amendment rights and that the state's interests did not outweigh these burdens.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals agreed that the county-line ballot design imposed a severe burden on the plaintiffs' First Amendment rights. It also found that the design likely violated the Elections Clause of the Constitution, which limits a state's power to regulate elections. The court concluded that the plaintiffs had demonstrated a substantial likelihood of success on the merits of their claims, and that they would suffer irreparable harm without the injunction. The court also found that the balance of harms and the public interest favored the plaintiffs. View "Kim v. Hanlon" on Justia Law

The case revolves around a defendant, Davit Davitashvili, who was charged with violating federal law by transmitting threats to injure his ex-wife, Olga Volosevich, and other unnamed individuals. This was after a long history of abusive behavior towards Volosevich, culminating in threatening messages sent to her via the messaging app Viber. Davitashvili appealed his conviction, arguing that his threats towards unnamed individuals were constitutionally protected speech.The United States Court of Appeals for the Third Circuit disagreed with Davitashvili's claim. It noted that Davitashvili's threats towards "others" were not protected speech under the First Amendment, as they targeted particular individuals, supporting a conviction. The court pointed out that the jury instructions required the jury to find that Davitashvili’s communication threatened to "injure a person or a group of people," which accurately reflected the relevant federal law.As for the defendant's argument that his conviction was based on an invalid theory (threatening unspecified "others"), the court held that the jury likely would have convicted Davitashvili based on his threats to Volosevich alone, even if the "kill others" theory was excluded. The court concluded that the trial was error-free and affirmed the judgment of conviction. View "USA v. Davitashvili" on Justia Law