Justia Constitutional Law Opinion Summaries

Los Angeles County Deputy Vega questioned Tekoh at the medical center where Tekoh worked regarding the reported sexual assault of a patient. Vega did not inform Tekoh of his Miranda rights. Tekoh eventually provided a written statement and was prosecuted for unlawful sexual penetration. His written statement was admitted against him at trial. After the jury returned a verdict of not guilty, Tekoh sued Vega under 42 U.S.C. 1983. The Ninth Circuit held that the use of an un-Mirandized statement against a defendant in a criminal proceeding violated the Fifth Amendment and could support a section 1983 claim.The Supreme Court reversed. A violation of the Miranda rules does not provide a basis for a section 1983 claim. In Miranda, the Court concluded that additional procedural protections were necessary to prevent the violation of the Fifth Amendment right against self-incrimination. Miranda did not hold that a violation of the rules it established necessarily constitute a Fifth Amendment violation. The Miranda rules have been described as “constitutionally based” with “constitutional underpinnings,” but a Miranda violation is not the same as a violation of the Fifth Amendment right.Miranda warnings are “prophylactic,” and can require balancing competing interests. A judicially crafted prophylactic rule should apply only where its benefits outweigh its costs. While the benefits of permitting the assertion of Miranda claims under section 1983 would be slight, the costs would be substantial. View "Vega v. Tekoh" on Justia Law

A prisoner who challenges a state’s proposed method of execution under the Eighth Amendment must identify a readily available alternative method that would significantly reduce the risk of severe pain. Nance brought suit under 42 U.S.C. 1983 to enjoin Georgia from executing him by lethal injection, the only method of execution that Georgia now authorizes. Nance proposes death by firing squad—a method currently approved by four other states. The Eleventh Circuit held that Nance could advance his method-of-execution claim only by a habeas petition. The Supreme Court reversed. Section 1983 remains an appropriate vehicle for a prisoner’s method-of-execution claim where the prisoner proposes an alternative method not authorized by the state’s death-penalty statute. Both section 1983 and the federal habeas statute enable a prisoner to complain of “unconstitutional treatment at the hands of state officials.” When a prisoner seeks relief that would “necessarily imply the invalidity of his conviction or sentence,” he must proceed in habeas. Here, Georgia would have to change its statute to carry out Nance’s execution by firing squad, so an order granting relief would not “necessarily prevent” the state from implementing the execution. The state has a pathway forward even if the proposed alternative is unauthorized by present state law. Section 1983 can compel changes to state laws when necessary to vindicate federal constitutional rights. It would be strange to read state-by-state discrepancies into how section 1983 and the habeas statute apply to federal constitutional claims. View "Nance v. Ward" on Justia Law

The State of .New York makes it a crime to possess a firearm without a license. An individual who wants to carry a firearm outside his home may obtain an unrestricted license to “have and carry” a concealed “pistol or revolver” if he can prove that “proper cause exists.” An applicant satisfies the “proper cause” requirement if he can “demonstrate a special need for self-protection distinguishable from that of the general community.” New York residents who unsuccessfully applied for unrestricted licenses to carry a handgun in public based on their generalized interest in self-defense challenged the “proper cause” requirement.The Supreme Court reversed the dismissal of the suit. New York’s "proper cause" requirement violates the Fourteenth Amendment by preventing law-abiding citizens with ordinary self-defense needs from exercising their Second Amendment right to keep and bear arms in public for self-defense. The “historical evidence from antebellum America does demonstrate that the manner of public carry was subject to reasonable regulation, but none of these limitations on the right to bear arms operated to prevent law-abiding citizens with ordinary self-defense needs from carrying arms in public for that purpose.” The Court stated that the "constitutional right to bear arms in public for self-defense is not a second-class right, subject to an entirely different body of rules than the other Bill of Rights guarantees.” The exercise of other constitutional rights does not require individuals to demonstrate to government officers some special need. View "New York State Rifle & Pistol Association., Inc. v. Bruen" on Justia Law

Twyford was convicted of aggravated murder and was sentenced to death. Ohio courts affirmed his conviction and sentence, then denied post-conviction relief, rejecting Twyford’s claim that his trial counsel was ineffective for failing to present evidence of a head injury Twyford had sustained. The district court dismissed most of Twyford’s federal habeas claims but allowed others to proceed and ordered the state to transport him to a medical facility for neurological testing that might lead to evidence to support his claim. The court cited the All Writs Act, which authorizes federal courts to “issue all writs necessary or appropriate in aid of their respective jurisdictions.” 28 U.S.C. 1651(a). The Sixth Circuit affirmed.The Supreme Court reversed. A transportation order that allows a prisoner to search for new evidence is not “necessary or appropriate in aid of” a federal court’s adjudication of a habeas corpus action when the prisoner has not shown that the desired evidence would be admissible in connection with a claim for relief. The Antiterrorism and Effective Death Penalty Act (AEDPA) restricts the ability of a federal habeas court to develop and consider new evidence: Before a federal court may decide whether to grant an evidentiary hearing or “otherwise consider new evidence” under 28 U.S.C. 2254(e)(2), it must first determine that such evidence could be legally considered in the prisoner’s case. The All Writs Act cannot be used to circumvent statutory requirements or binding procedural rules. Twyford never explained how the results of neurological testing could be admissible in his habeas proceedings, given that AEDPA review is limited to “the record that was before the state court.” View "Shoop v. Twyford" on Justia Law

Washington enacted a workers’ compensation law that applied only to Hanford site workers who were “engaged in the performance of work, either directly or indirectly, for the United States.” The Hanford site, once used to produce nuclear weapons, is undergoing decontamination. Most workers involved in the cleanup process are employed by private companies under contract with the federal government; a few are state employees, private employees, and federal employees. As compared to Washington’s general workers’ compensation scheme, the law made it easier for Hanford's federal contract workers to establish entitlement to workers’ compensation, thus increasing workers’ compensation costs for the federal government. The Ninth Circuit upheld the law as within the scope of a federal waiver of immunity, 40 U.S.C. 3172.A unanimous Supreme Court reversed. Washington’s law facially discriminates against the federal government and its contractors; section 3172 does not clearly and unambiguously waive immunity from discriminatory state laws, so Washington’s law is unconstitutional. While section 3172(a) says that “[t]he state authority charged with enforcing and requiring compliance with the state workers’ compensation laws . . . may apply [those] laws to all land and premises in the State which the Federal Government owns,” and “to all projects, buildings, constructions, improvements, and property in the State and belonging to the Government, in the same way, and to the same extent as if the premises were under the exclusive jurisdiction of the State,” the waiver does not “clear[ly] and unambiguous[ly]” authorize a state to enact a discriminatory law that facially singles out the federal government for unfavorable treatment.The Court held that the case was not moot, despite Washington’s enactment of a new statute that, arguably, applies retroactively. View "United States v. Washington" on Justia Law

Maine offers tuition assistance for parents who live in school districts that neither operate a secondary school nor contract with a school in another district. Parents designate the secondary school they would like their child to attend; the school district sends payments to that school to defray tuition costs. To be eligible for tuition payments, private schools had to be accredited by the New England Association of Schools and Colleges or approved by the Maine Department of Education. Since 1981, Maine has limited tuition assistance payments to “nonsectarian” schools. The First Circuit affirmed the rejection of constitutional challenges to the “nonsectarian” requirement.The Supreme Court reversed. Maine’s “nonsectarian” requirement for otherwise generally available tuition assistance payments violates the Free Exercise Clause, which protects against “indirect coercion or penalties on the free exercise of religion, not just outright prohibitions.” A state need not subsidize private education but if it does so, it cannot disqualify some private schools solely because they are religious. A law that operates in that manner must be subjected to “the strictest scrutiny.” A neutral benefit program in which public funds flow to religious organizations through the independent choices of private benefit recipients does not offend the Establishment Clause; a state’s anti-establishment interest does not justify enactments that exclude some members of the community from an otherwise generally available public benefit because of their religious exercise. View "Carson v. Makin" on Justia Law

The Bureau of Indian Affairs filed a CFR court complaint against Denezpi, a member of the Navajo Nation, charging Denezpi with crimes alleged to have occurred within the Ute Mountain Ute Reservation: assault and battery, terroristic threats, and false imprisonment. CFR courts administer justice for Indian tribes where tribal courts have not been established. Denezpi pleaded guilty to assault and battery and was sentenced to time served. Months later, a federal grand jury indicted Denezpi for aggravated sexual abuse in Indian country, under the federal Major Crimes Act. Denezpi unsuccessfully argued that the Double Jeopardy Clause barred the consecutive prosecution and was sentenced to 360 months’ imprisonment.The Tenth Circuit and Supreme Court affirmed. The Double Jeopardy Clause does not bar successive prosecutions of distinct offenses arising from a single act, even if a single sovereign prosecutes them. Denezpi’s single act transgressed two laws: the Ute Mountain Ute Code’s assault and battery ordinance and the U.S. Code’s proscription of aggravated sexual abuse in Indian country. The two laws—defined by separate sovereigns—proscribe separate offenses, so Denezpi’s second prosecution did not place him in jeopardy again “for the same offence.” The Court did not address whether CFR prosecutors exercise tribal or federal authority because the Double Jeopardy Clause does not prohibit successive prosecutions by the same sovereign but only prohibits successive prosecutions “for the same offence.” The Double Jeopardy Clause does not ask who puts a person in jeopardy; it focuses on what the person is put in jeopardy for. View "Denezpi v. United States" on Justia Law

Arteaga-Martinez, a citizen of Mexico, was removed and reentered the U.S. His earlier removal order was reinstated and he was detained under 8 U.S.C. 1231(a). Arteaga-Martinez applied for withholding of removal and relief under the Convention Against Torture. An asylum officer determined he had established a reasonable fear of persecution or torture if returned to Mexico. DHS referred him for withholding-only proceedings before an immigration judge. After being detained for four months, Arteaga-Martinez filed a habeas corpus petition, challenging his continued detention without a bond hearing. The government conceded that Arteaga-Martinez would be entitled to a bond hearing after six months of detention based on circuit precedent. The district court ordered a bond hearing. The Third Circuit affirmed. At the bond hearing, the Immigration Judge authorized his release pending resolution of his application for withholding of removal.The Supreme Court reversed and remanded. Section 1231(a)(6) does not require the government to provide noncitizens, detained for six months, with bond hearings in which the government bears the burden of proving, by clear and convincing evidence, that a noncitizen poses a flight risk or a danger to the community. Section 1231(a)(6) “does not permit indefinite detention” but “limits an alien’s post-removal-period detention to a period reasonably necessary to bring about that alien’s removal from the United States”; it allows the government to provide bond hearings but does not require them. The Court remanded for consideration of Arteaga-Martinez’s alternative theory. View "Johnson v. Arteaga-Martinez" on Justia Law

Boule’s business, “Smuggler's Inn,” abuts the Canadian border. Boule sometimes helped federal agents identify and apprehend persons engaged in unlawful cross-border activities but also provided transportation and lodging to illegal border crossers. Boule informed U.S. Border Patrol agent Egbert that a Turkish national had scheduled transportation to Smuggler’s Inn. Egbert followed Boule's vehicle to the Inn. Boule claims he asked Egbert to leave, but Egbert refused, threw Boule to the ground, checked the immigration paperwork for Boule’s guest, then left. Boule filed an unsuccessful grievance with Egbert’s supervisors and an unsuccessful administrative claim. Egbert allegedly retaliated by reporting Boule’s license plate to the state for referencing illegal activity, and by prompting an IRS audit. Boule sued Egbert, alleging Fourth Amendment excessive force and First Amendment retaliation.Reversing the Ninth Circuit, The Supreme Court held that "Bivens" does not extend to Boule's claims. In Bivens, the Court created a damages action against federal agents for violating a plaintiff’s Fourth Amendment rights. The Court subsequently fashioned new causes of action under the Fifth and Eighth Amendments.Recognizing a Bivens cause of action is “a disfavored judicial activity." Boule’s Fourth Amendment claim presented a new Bivens context, not akin to a “conventional” excessive-force claim. Concerns about undermining border security foreclose Bivens relief. Congress has provided alternative remedies: Border Patrol must investigate alleged violations and accept grievances. The Court has never held that a Bivens alternative must provide for judicial review. Boule’s First Amendment retaliation claim also presents a new Bivens context. Congress is better suited to authorize a damages remedy. Extending Bivens to alleged First Amendment violations would pose an acute “risk that fear of personal monetary liability and harassing litigation will unduly inhibit officials in the discharge of their duties.” View "Egbert v. Boule" on Justia Law

Under the Trustee Program, administrative functions previously handled by bankruptcy judges are handled by U.S. Trustees, within the Department of Justice. Six judicial districts in North Carolina and Alabama opted out of the Trustee Program; those bankruptcy courts continue to appoint bankruptcy administrators. Both programs handle the same administrative functions. The Trustee Program is funded entirely by user fees, largely paid by Chapter 11 debtors, 28 U.S.C. 589a(b)(5). The Administrator Program is funded by the Judiciary’s general budget. Under a Judicial Conference standing order, all districts nationwide charged similarly-situated debtors uniform fees. A 2017 fee increase was made applicable to currently pending and newly-filed cases in the Trustee Program and only to newly-filed cases in Administrator Program districts. Reversing the bankruptcy court, the Fourth Circuit held that the fee increase did not violate the Bankruptcy Clause uniformity requirement.A unanimous Supreme Court reversed, holding that the enactment of a significant fee increase that exempted debtors in two states violated the uniformity requirement. Nothing in the Bankruptcy Clause suggests a distinction between substantive and administrative laws; its language, embracing “laws on the subject of Bankruptcies,” is broad. Congress cannot evade the affirmative limitation of the uniformity requirement by enacting legislation pursuant to other grants of authority such as the Necessary and Proper Clause. The 2017 Act does not confer discretion on bankruptcy districts to set regional policies based on regional needs but exempts debtors in two states from a fee increase that applied to debtors in 48 states, without identifying any material difference between debtors across those states. The Bankruptcy Clause does not permit arbitrary geographically disparate treatment of debtors. View "Siegel v. Fitzgerald" on Justia Law