Justia Constitutional Law Opinion Summaries

The case involves the State of Alaska's statutes that allow local school districts to operate correspondence study programs and provide public funds for educational expenses. Parents of public school students sued the State, arguing that these statutes violated the Alaska Constitution by allowing public funds to be used for private school tuition, which they claimed was unconstitutional.The Superior Court of Alaska ruled that the statutes were facially unconstitutional and invalidated them entirely. The court did not address the narrower question of whether the statutes were unconstitutional when applied to allow public funds to be used for private school tuition. The decision was appealed to the Supreme Court of Alaska.The Supreme Court of Alaska reviewed the case and determined that the Superior Court's ruling went too far. The Supreme Court noted that the statutes allowed for a substantial number of constitutionally valid uses of allotment funds, such as purchasing books, supplies, and other educational materials. The court emphasized that even if using allotment funds for private school tuition were unconstitutional, it would not justify invalidating the entire statutes.The Supreme Court vacated the Superior Court's judgment and remanded the case for further proceedings. The court instructed that the proper parties must be joined, and the Superior Court must first determine whether the statutes actually permit the use of allotment funds for private school tuition before addressing the constitutionality of such use. The Supreme Court did not decide whether using allotment funds for private school tuition is constitutional, leaving that question open for further consideration. View "State of Alaska, Dept. of Education & Early Development v. Alexander" on Justia Law

A group of foster children challenged the Office of Children’s Services (OCS) for using their federal Social Security benefits to reimburse itself for foster care costs. The children claimed this practice violated their due process and equal protection rights under the Alaska Constitution and sought restitution. The Superior Court of Alaska found a due process violation and ordered OCS to notify foster children about its practice regarding Social Security benefits. However, the court rejected the equal protection and restitution claims, deeming them preempted by federal law.The Superior Court held that OCS violated due process by not informing foster children about their Social Security benefits and the potential financial advantages of having a private representative payee. The court ordered OCS to provide notices explaining the concept of a representative payee, the consequences of OCS being the payee, and the possibility of proposing an alternative payee. OCS argued that complying with the notice order would violate federal privacy laws, but the court modified its order to address these concerns.The Supreme Court of Alaska reviewed the case and affirmed the Superior Court’s conclusions. The Supreme Court held that the due process claim and the court’s notice order were not preempted by federal law. The court determined that foster children have a property interest in knowing about their Social Security benefits and the ability to nominate a private payee. The court found that OCS’s systematic practice of using benefits to reimburse itself without notice created a high risk of depriving children of their rights.The Supreme Court also held that the equal protection claim was preempted because it would conflict with federal regulations governing the use of Social Security benefits. The court concluded that OCS’s practice of using benefits for foster care costs was permissible under federal law. Finally, the court rejected the proposed remedies of disgorgement and creating a trust, as they would constitute impermissible attachments on federal benefits and were preempted by federal law. View "State of Alaska, Department of Health and Social Services v. Z. C." on Justia Law

Giovani Fuster Melendez moved from Puerto Rico to Arizona in 2017 and became acquainted with the victim, A.G., through a church connection. In 2019, Melendez returned to his former apartment complex, encountered A.G., and fired multiple shots at him, missing each time. Melendez was taken into custody shortly after the incident. During his police interview, he was read his Miranda rights twice and initially chose not to speak. However, in a subsequent interview, he deferred answering some questions but eventually confessed to the shooting, claiming self-defense.The Superior Court in Maricopa County convicted Melendez of aggravated assault and five counts of endangerment, sentencing him to concurrent prison terms. On appeal, the Arizona Court of Appeals found that the State's references to Melendez's selective silence during his police interview violated his constitutional rights, constituting fundamental prejudicial error.The Arizona Supreme Court reviewed the case to determine if the State violated Melendez's due process rights by commenting on his post-Miranda statements and temporary deferrals during the trial. The Court held that the State could use a defendant’s post-Miranda statements and temporary deferrals for impeachment purposes if the defendant did not unambiguously invoke his Miranda rights and ultimately spoke on the substantive matters. The Court concluded that Melendez did not unequivocally invoke his right to remain silent and that his deferrals were tactical rather than an invocation of his rights. Therefore, the prosecutor's comments did not violate Melendez's due process rights. The Arizona Supreme Court affirmed Melendez's convictions and sentences and vacated the Court of Appeals' opinion. View "STATE OF ARIZONA v MELENDEZ" on Justia Law

Faytima Howard failed to pay her property taxes, leading Macomb County, Michigan, to seize and sell her property in 2023. Howard sued, claiming the county violated the Takings Clause of the Fifth Amendment by keeping proceeds exceeding her tax debt. Previously, Michigan's foreclosure regime was found unconstitutional for not compensating property owners for the surplus from foreclosure sales. However, Michigan amended its law in 2020 to allow property owners to claim any surplus value from foreclosed properties. Howard did not utilize this process.The United States District Court for the Eastern District of Michigan dismissed Howard's complaint for failure to state a claim. The court noted that Michigan's amended law provided a procedure for property owners to claim surplus proceeds, which Howard did not follow. The district court concluded that because Howard did not take advantage of the process, her claim was invalid.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Michigan's procedure for claiming surplus proceeds from foreclosure sales complies with the Takings Clause, as it provides property owners with a reasonable opportunity to claim any surplus. The court distinguished this case from others where no such process was available, emphasizing that Howard's failure to follow the state procedure meant no taking occurred. The court also rejected Howard's arguments that the process was overly burdensome and that the lack of interest and attorney's fees constituted a taking. The court concluded that Michigan's procedures are constitutionally sound and do not violate the Fifth Amendment. View "Howard v. Macomb Cnty., Mich." on Justia Law

Fathiree Ali, a Muslim inmate, requested the Michigan Department of Corrections to provide him with a halal diet, which is required by his religion. The prison chaplain directed him to apply for the vegan meal option, but another official rejected his application after discovering that Ali had purchased over one hundred non-halal items from the prison commissary. Ali then sued the chaplain, the special activities coordinator, the warden, and the Michigan Department of Corrections under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the Free Exercise Clause, and 42 U.S.C. § 1983.The United States District Court for the Western District of Michigan dismissed Ali’s claims against the Department of Corrections and granted summary judgment in favor of the officials. Ali appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and dismissed Ali’s appeal in part for lack of jurisdiction and affirmed the rest of the district court’s decision. The court held that RLUIPA does not authorize money-damages claims against officials sued in their official or individual capacities. The court also found that Ali’s claims for injunctive relief against the chaplain and warden were moot because they no longer had the power to adjust his meal plan after his transfer to a different prison. Additionally, the court held that Ali’s claim for injunctive relief against the special activities coordinator was moot because the coordinator no longer worked for the Department of Corrections.The court concluded that Ali did not have a cognizable claim for injunctive or declaratory relief under RLUIPA because he had alternatives to access halal meat and could reapply for the vegan meal plan. The court also found that Ali failed to state a claim against the Michigan Department of Corrections as he did not identify a policy that violated RLUIPA. Finally, the court held that the officials were entitled to qualified immunity on Ali’s Free Exercise Clause claims under § 1983. View "Ali v. Adamson" on Justia Law

Plaintiffs, a nonprofit corporation and its founder, applied for a special use permit to conduct church activities on agricultural land they purchased in Maui. The Maui Planning Commission denied their application, citing concerns about traffic, safety, and environmental impacts. Plaintiffs continued using the land for non-agricultural purposes without permits, leading to fines. They applied again, addressing some concerns, but the Commission denied the second application as well.The plaintiffs sued the County of Maui and the Commission, alleging violations of the Religious Land Use and Institutionalized Persons Act (RLUIPA) and other constitutional claims. The United States District Court for the District of Hawaii granted summary judgment to the County on most claims, except for the RLUIPA equal-terms claim, which went to trial. An advisory jury found for the County, and the district court entered judgment accordingly. Plaintiffs appealed, and the Ninth Circuit reversed the summary judgment, remanding the case for further proceedings.On remand, the district court severed an unconstitutional provision from the zoning law and proceeded to trial on the remaining claims. The jury found for the County on all counts. Plaintiffs appealed again, arguing that the substantial-burden inquiry under RLUIPA should have been decided by the court, not the jury.The United States Court of Appeals for the Ninth Circuit held that the substantial-burden inquiry under RLUIPA is a question of law for the court to decide. Although the district court erred in submitting this question to the jury, the error was deemed harmless because the jury's verdict was consistent with the required legal outcome. The Ninth Circuit affirmed the district court's judgment in favor of the County of Maui. View "SPIRIT OF ALOHA TEMPLE V. COUNTY OF MAUI" on Justia Law

In 2010, Thomas Steven Sanders kidnapped and murdered a twelve-year-old girl, L.R., after killing her mother, Suellen Roberts. Sanders was apprehended and confessed to the crimes. He was prosecuted under federal law and, in 2014, a jury in the Western District of Louisiana convicted him of kidnapping and murder, sentencing him to death on both counts.Sanders appealed, raising numerous challenges to his convictions and sentences. The United States Court of Appeals for the Fifth Circuit reviewed the case. Sanders argued that the district court erred by not ordering a competency hearing, denying his motion to suppress statements made during interrogation, and violating the Double Jeopardy Clause by imposing two sentences for one act. He also challenged the jury selection process, the death-qualification of the jury, the sufficiency of the evidence, the admission of victim impact testimony, prosecutorial misconduct, and the constitutionality of the Federal Death Penalty Act (FDPA).The Fifth Circuit found that the district court did not abuse its discretion in failing to order a competency hearing or in denying the motion to suppress. However, the court agreed with Sanders that his conviction and sentence under 18 U.S.C. § 924(c) and (j) violated the Double Jeopardy Clause, as Congress did not authorize cumulative punishment for violations of § 1201(a) and § 924(j). Consequently, the court vacated Sanders’s conviction and sentence under Count Two of the indictment.The court rejected Sanders’s other arguments, including those related to jury selection, death-qualification, sufficiency of the evidence, victim impact testimony, prosecutorial misconduct, and the constitutionality of the FDPA. The court concluded that Sanders’s sentences were not imposed under the influence of passion, prejudice, or any other arbitrary factor and that the cumulative-error doctrine did not apply. The Fifth Circuit affirmed the district court’s judgment in all other respects. View "United States v. Sanders" on Justia Law

The case involves two charitable organizations, Catholic Medical Mission Board, Inc. (CMMB) and Food for the Poor, Inc. (FFP), which were issued cease and desist orders and civil penalties by the Attorney General of California for allegedly making false or misleading statements in their charitable solicitations. The Attorney General found that both organizations overvalued in-kind donations and misrepresented their program efficiency ratios, leading to misleading donor solicitations.The Superior Court of Los Angeles County reviewed the case and found that the challenged statutory provisions, sections 12591.1(b) and 12599.6(f)(2) of the Government Code, were unconstitutional under the First Amendment as they constituted prior restraints on speech. The court vacated the civil penalties and issued permanent injunctions against the Attorney General, preventing the enforcement of these provisions. The court also reformed section 12591.1(b) to exclude violations of section 12599.6 from the Attorney General’s cease and desist authority.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the trial court’s constitutional rulings but vacated the permanent injunctions, stating that the trial court abused its discretion by granting them without requiring the plaintiffs to plead and prove entitlement to such relief. The appellate court remanded the case to allow the plaintiffs to amend their complaints to seek injunctive relief and to prove they are entitled to it. The court also affirmed the trial court’s reformation of section 12591.1(b) and vacated the postjudgment orders awarding attorney fees, directing the trial court to reconsider the fees in light of the appellate court’s rulings. View "Catholic Medical Mission Board, Inc. v. Bonta" on Justia Law

Jasper Nelson, a 19-year-old, ran away with a 12-year-old girl, A.S.J., who had left a note expressing suicidal thoughts. Law enforcement, suspecting a sexual relationship, located A.S.J. and later arrested Nelson. Nelson admitted to having sex with A.S.J. multiple times and soliciting sex from an 11-year-old girl, J.W. Nelson pleaded guilty to amended charges, including third-degree rape of a child and second-degree child molestation. The court imposed a Special Sex Offender Sentencing Alternative (SSOSA), suspending his 87-month sentence on conditions including community custody and treatment.Nelson violated his SSOSA by accessing unauthorized electronic devices and inappropriate content, leading to a revocation hearing. He admitted to the violations, and the court revoked his SSOSA, reinstating his original sentence. Nelson appealed, challenging the revocation process and several community custody conditions, including those requiring breath analysis (BA) and urinalysis (UA) testing for alcohol and drug use.The Washington Court of Appeals affirmed the revocation and addressed Nelson's challenges to the community custody conditions. The court held that the BA and UA testing conditions were valid for monitoring compliance with the prohibitions on alcohol and drug use, even though these prohibitions were not directly related to his crimes.The Washington Supreme Court reviewed the case, focusing on whether the BA and UA testing conditions violated Nelson's constitutional rights. The court held that Nelson's preenforcement challenge was not ripe for review due to the need for further factual development. However, the court addressed the merits, affirming that the BA and UA testing conditions were narrowly tailored to serve the state's compelling interest in monitoring compliance with valid community custody conditions. The court concluded that these conditions were constitutionally permissible, even if not directly related to the underlying offenses. View "State v. Nelson" on Justia Law

This case involves the termination of parental rights and an adoption proceeding. Jane Doe 1 ("Mother") and John Doe ("Father") had a child out of wedlock. Approximately eight months after the child's birth, Mother and her fiancé filed a petition to terminate Father's parental rights and allow the fiancé to adopt the child. Mother did not serve the petition on Father, and he did not participate in the proceedings. The magistrate court terminated Father's parental rights and granted the adoption. Father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. This appeal concerns Father's second motion.The magistrate court denied Father's second motion, finding it barred by res judicata. The district court disagreed, reversed the magistrate court's order, and remanded the matter for the magistrate court to consider the motion on its merits. Mother appealed, arguing that Father's motion was barred by procedural doctrines, including res judicata and waiver.The Supreme Court of Idaho held that Father's Rule 60(b)(4) motion alleged a fundamental error that deprived him of his right to procedural due process, which in turn violated his fundamental constitutional right to raise his child. The Court concluded that the fundamental error doctrine applies to create an exception to the doctrines of res judicata and waiver. The Court affirmed the district court's decision and remanded the matter to the magistrate court to hold an evidentiary hearing to determine whether Father's Rule 60(b)(4) motion was timely and, if so, whether the termination and adoption judgment is void. The Court also awarded partial attorney fees to Father for defending against certain arguments raised by Mother on appeal. View "Doe v. Doe" on Justia Law