Justia Constitutional Law Opinion Summaries

A Black man was charged with two counts of first-degree sexual abuse and one count of attempted robbery after allegedly assaulting a white woman. During jury selection, the government used its peremptory strikes to remove all six nonwhite prospective jurors—four Black, one Asian, and one Hispanic—from a venire of thirty-six, resulting in an all-white jury. The defense objected, arguing that the prosecutor’s actions were racially discriminatory and violated the precedent established in Batson v. Kentucky. The government provided purportedly race-neutral reasons for the strikes of the Black jurors, such as concerns about their ability to understand scientific testimony or responses during voir dire. The trial court accepted these explanations, found them credible and race-neutral, and denied the Batson challenge.A jury in the Superior Court of the District of Columbia acquitted the defendant of attempted robbery but convicted him on both sexual abuse counts. On appeal, a division of the District of Columbia Court of Appeals affirmed the convictions, concluding that the trial court had adequately scrutinized the government’s justifications for the jury strikes. The defendant sought en banc review, and the division’s decision was vacated pending review by the full District of Columbia Court of Appeals.The District of Columbia Court of Appeals, sitting en banc, held that the trial court’s Batson analysis was insufficient because it failed to rigorously scrutinize the prosecutor’s explanations in the context of the entire record, including statistical evidence and the racially charged nature of the case. The court found that at least one of the government’s strikes was more likely than not racially discriminatory. Accordingly, it reversed the defendant’s convictions and remanded for a new trial. View "Smith v. United States" on Justia Law

Authorities responded to a residence to investigate an alleged assault involving a young child. Upon arrival, social workers and a detective entered the property through an open garage door, which led to an interior entryway. The resident, Shantel Lais, allowed them inside. Once inside, the detective observed hazardous conditions, including accessible firearms, open alcohol, drugs, and drug paraphernalia within reach of a two-year-old child. As a result, Christopher Golberg was charged with child neglect, unlawful possession of drug paraphernalia, and unlawful possession of a firearm.Prior to trial in the District Court of Mercer County, South Central Judicial District, Golberg moved to suppress evidence obtained during the search, arguing the detective unlawfully entered the garage without a warrant or consent, thus tainting the evidence subsequently gathered. A suppression hearing was held, where the detective testified that the garage functioned as the main entrance due to home construction and that the exterior door was open. The district court found that Golberg did not have a reasonable expectation of privacy in the garage under these circumstances and denied the motion to suppress. At trial, Golberg twice moved for judgment of acquittal on the basis that he did not reside at the house; both motions were denied. The jury found Golberg guilty of child neglect and not guilty on the other charges.On appeal, the Supreme Court of North Dakota considered whether the denial of the suppression motion and the sufficiency of the evidence were erroneous. The court held that the open garage, serving as the main access point and lacking express signs restricting entry, did not afford Golberg a reasonable expectation of privacy. Thus, no unlawful search occurred. The court also found that sufficient evidence supported the jury’s verdict on child neglect. The amended criminal judgment was affirmed. View "State v. Golberg" on Justia Law

During a traffic stop in South Bend, Indiana, in February 2021, police discovered that Jose Reyna was in possession of marijuana, methamphetamine intended for distribution, and a loaded handgun with its serial number obliterated. Reyna admitted to dealing drugs and to having intentionally removed the serial number from the firearm. A grand jury indicted him for possessing a firearm with an altered or obliterated serial number in violation of 18 U.S.C. § 922(k), to which he pleaded guilty without a plea agreement. Shortly before sentencing, Reyna moved to dismiss the indictment, arguing that § 922(k) was unconstitutional under the Second Amendment, relying on the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen.The United States District Court for the Northern District of Indiana found good cause to consider Reyna's otherwise untimely motion but denied it on the merits. The district judge ruled that the possession of a firearm with an obliterated serial number was not covered by the plain text of the Second Amendment and therefore rejected the constitutional challenge at the first step of the Bruen framework. The judge did not address whether the statute was consistent with the nation’s historical tradition of firearm regulation.The United States Court of Appeals for the Seventh Circuit reviewed the constitutionality of § 922(k) de novo. While the appellate court was not persuaded that the challenge could be resolved solely on the text of the Second Amendment, it proceeded to Bruen’s second step, as clarified by United States v. Rahimi. The court concluded that although modern serialization lacks a direct historical analogue, historical practices of marking, inventorying, and inspecting firearms for militia purposes provide a relevant tradition. The Seventh Circuit held that § 922(k) is consistent with the principles underlying this tradition and affirmed the judgment of the district court. View "USA v Reyna" on Justia Law

A substitute teacher in a large Maryland public school system challenged the school board’s policy requiring all staff, including substitutes, to affirm that they would refer to students by their preferred pronouns and not disclose a student’s gender identity to parents without the student’s consent. The teacher, citing her sincerely held religious beliefs, refused to sign the affirmation and requested a religious accommodation, which was ultimately denied. As a result, she was not permitted to substitute teach in the following school years.She brought claims in the United States District Court for the District of Maryland against the school board, asserting violations of Title VII of the Civil Rights Act related to religious accommodation, and First Amendment violations of her rights to free speech and free exercise of religion. She sought damages, declaratory relief, and a preliminary injunction. The district court dismissed her First Amendment claims under Rule 12(b)(6) for failure to state a claim, finding the policy to be neutral and generally applicable, thus subject to rational basis review, and rationally related to legitimate government interests, including compliance with Title IX and student safety. The court concluded that the speech at issue was part of her official duties as a teacher and thus not protected by the First Amendment. The court denied a preliminary injunction, finding no likelihood of success on the merits for the constitutional claims and no irreparable harm for the Title VII claim, which was allowed to proceed.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s dismissal of the First Amendment claims and denial of a preliminary injunction. The Fourth Circuit held that the policy was neutral and generally applicable, survived rational basis review, and the compelled speech fell within the teacher’s official duties. Therefore, the plaintiff was not entitled to injunctive relief on her constitutional claims. View "Polk v. Montgomery County Public Schools" on Justia Law

In this case, the defendant was charged with raping three different women on three separate occasions in Philadelphia, spanning from 2011 to 2015. Each victim underwent a sexual assault examination, and DNA evidence was collected but did not initially match any known profiles. In December 2018, a DNA database search revealed that the same DNA profile was present in all three cases. This profile was subsequently identified as belonging to the defendant, who was then arrested and charged separately for each incident.The prosecution moved to consolidate the three cases for a joint jury trial, arguing that the assaults were sufficiently similar to be admissible under the common plan, scheme, or design exception to Pennsylvania’s rule against propensity evidence. The defendant objected, but the Philadelphia County Court of Common Pleas granted the consolidation and allowed the introduction of rape kit reports prepared by nurse examiners who did not testify at trial. The defendant was convicted on multiple counts, and the court imposed an aggregate sentence. On appeal, the Superior Court of Pennsylvania affirmed the convictions and the admission of the rape kit reports, finding the cases sufficiently similar for consolidation and the reports non-testimonial and admissible under hearsay exceptions.Upon review, the Supreme Court of Pennsylvania concluded that consolidation was improper under the current interpretation of the common plan, scheme, or design exception, holding that such consolidation is permissible only if the offenses are signature crimes or part of a common goal, neither of which applied here. Additionally, the court held that admitting the rape kit reports without the testimony of the nurse examiners violated the defendant’s right to confront witnesses under the Confrontation Clause. Accordingly, the Supreme Court of Pennsylvania vacated the judgment of sentence and remanded for further proceedings. View "Commonwealth v. Walker" on Justia Law

In 2005, an individual was convicted of endangering the welfare of a child and placed on Parole Supervision for Life (PSL) in New Jersey. The State Parole Board imposed two special conditions: a ban on accessing social media and a ban on viewing or possessing pornography. In 2018, the individual was arrested on a parole warrant for allegedly violating both conditions. After a hearing, the Parole Board found violations, revoked PSL, and ordered twelve months of incarceration. The individual challenged the constitutionality of the conditions, arguing they violated First Amendment rights. While an appeal was pending, the Parole Board vacated the revocation in February 2020 and later discharged the conditions. On June 1, 2020, the Board issued a decision stating there was no clear and convincing evidence of violations.The complainant and spouse then filed suit under the New Jersey Civil Rights Act (CRA) and the Tort Claims Act (TCA) against the State and others, alleging substantive due process violations, gross negligence, deliberate indifference, and false arrest/imprisonment. The trial court dismissed all claims as time-barred, holding that the statute of limitations began to run at various points before June 2020. The Appellate Division affirmed, finding that the claims accrued earlier and that even under the favorable-termination rule from Heck v. Humphrey, the relevant accrual event was the Board's February 2020 vacatur of the revocation.The Supreme Court of New Jersey held that the favorable-termination rule from Heck v. Humphrey applies to claims under the CRA and the TCA, meaning that civil rights claims that necessarily challenge the validity of a criminal or quasi-criminal proceeding do not accrue until that proceeding is terminated in the plaintiff’s favor. The Court determined that substantive due process and related claims accrued on June 1, 2020, making them timely, but that any false arrest/imprisonment claim accrued earlier and was time-barred. The Court reversed the dismissal of the first three counts and affirmed the dismissal of the false arrest/imprisonment claim. View "C.A.L. v. State of New Jersey" on Justia Law

Charles Hembree was previously convicted in Mississippi state court in 2018 for simple possession of methamphetamine, a felony offense. In 2022, he was indicted under federal law for being a felon in possession of a firearm, in violation of 18 U.S.C. § 922(g)(1). Hembree moved to dismiss the indictment, arguing that applying § 922(g)(1) to him violated the Second Amendment, particularly in light of the U.S. Supreme Court’s ruling in New York State Rifle & Pistol Association v. Bruen. The district court denied his motion, after which Hembree entered a guilty plea under an agreement that reserved his right to challenge the denial of his motion to dismiss on Second Amendment grounds. He was sentenced to six months in prison and three years of supervised release.After sentencing, Hembree appealed to the United States Court of Appeals for the Fifth Circuit, preserving only his as-applied Second Amendment challenge to § 922(g)(1). He argued that there was no historical tradition justifying the disarmament of individuals based solely on a conviction for simple drug possession. The government contended that historical analogues, such as laws disarming dangerous persons or severely punishing possession of contraband, supported the statute’s application to Hembree’s circumstances.The Fifth Circuit held that the government failed to meet its burden of demonstrating a historical tradition supporting the permanent disarmament of individuals convicted only of simple drug possession. The court concluded that neither the tradition of punishing possession of contraband nor the disarmament of “dangerous persons” provided a sufficient analogue for Hembree’s predicate offense. Therefore, the Fifth Circuit found § 922(g)(1) unconstitutional as applied to Hembree and reversed his conviction. The court did not address Hembree’s additional constitutional claims, as resolution of the as-applied challenge was dispositive. The court also granted Hembree’s motion to supplement the record. View "United States v. Hembree" on Justia Law

A real estate developer purchased a vacant parcel of land in Worthington, Ohio, previously owned by a youth home. The property was primarily zoned for public or institutional uses such as parks, hospitals, and churches. The developer sought to build a mixed-use project and applied for rezoning and development plan approval. After public meetings where concerns about greenspace, traffic, and density were raised, the municipal planning commission tabled the initial application. The developer later reduced the number of proposed residential units, but the commission still declined to recommend approval, and the city council denied the rezoning application. Subsequently, the city amended its comprehensive plan to emphasize greenspace. The developer, having purchased the property after waiving a rezoning contingency, filed suit, alleging constitutional violations due to the city’s refusal to rezone and amend the comprehensive plan.The United States District Court for the Southern District of Ohio dismissed most of the developer’s claims at the motion-to-dismiss stage, including due process counts, and granted summary judgment to the city on the remaining regulatory takings and declaratory judgment claims. The developer appealed, challenging the dismissal and grant of summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment and dismissal de novo. The court held that the city’s actions did not constitute a regulatory taking under the Penn Central factors, as the developer lacked a reasonable investment-backed expectation of rezoning approval and the city’s actions had legitimate public purposes. The court also found that the zoning ordinance was not unconstitutional beyond fair debate and that the developer failed to allege a cognizable property interest or arbitrary government action for its due process claims. The Sixth Circuit affirmed the district court’s judgment in all respects. View "Lifestyle Communities, Ltd. v. City of Worthington" on Justia Law

A non-governmental organization challenged a county planning department’s decision to approve a land division in the Bitterroot Valley. The organization alleged that the planning department authorized a property owner to divide an 80-acre tract into eight parcels using a family transfer exemption, but failed to provide public notice before approving the application. The organization discovered the land division after it had occurred and argued that the lack of public notice violated the county’s subdivision regulations, the Montana Subdivision and Platting Act, the Montana Public Participation Act, and constitutional rights to know and participate.The case was first heard in the Montana Twenty-First Judicial District Court, which granted the county’s motion to dismiss all claims. The district court concluded that the applicable county regulations did not require the planning department to provide published notice before reviewing or approving subdivision exemption applications. The court held that the organization had not stated a plausible claim because the regulations required only that the department accept public comments, not that it give notice.The Supreme Court of the State of Montana reviewed the case and reversed the district court’s dismissal of the claims related to declaratory relief. The Supreme Court held that the county subdivision regulations, while silent on the specific mechanics of notice, require the planning department to provide public notice of pending exemption applications in order to give meaningful effect to the public’s right to comment, as mandated by the regulations. The court emphasized that public comment is meaningless without notice, and remanded the case for further proceedings, directing the district court to require the planning department to provide notice and an adequate opportunity for public comment before reevaluating the exemption application. View "Sapphire v. Ravalli County" on Justia Law

The case concerns an individual who was convicted under federal law for possessing a firearm after having previously been convicted of a misdemeanor crime of domestic violence. The predicate offense was a 2010 conviction under Maine law for simple assault against his then-wife, to which he pleaded no contest after the original charge of "Domestic Violence Assault" was reduced. Several years later, he was charged federally after he admitted to police that he owned a firearm. At his federal trial, he stipulated to many elements of the offense but sought to introduce evidence that he believed, based on his plea arrangement and representations by the prosecution and his attorney in state court, that he was legally allowed to possess a firearm.Initially, the United States District Court for the District of Maine convicted him, but the United States Court of Appeals for the First Circuit vacated that conviction after the Supreme Court decided Rehaif v. United States, which clarified the knowledge requirement for firearms offenses. On remand, he was retried and again convicted, but a First Circuit panel vacated the conviction due to errors in jury instructions. Sitting en banc, the First Circuit clarified the applicable knowledge standard, vacated the conviction, and remanded for another trial. On further remand, the District Court denied his Second Amendment challenge to the statute, excluded his proffered evidence regarding his belief about firearm possession, and again convicted him after a jury trial.The United States Court of Appeals for the First Circuit held that 18 U.S.C. § 922(g)(9), which prohibits firearm possession by those convicted of misdemeanor crimes of domestic violence, does not violate the Second Amendment, either facially or as applied, in light of the Supreme Court’s guidance in United States v. Rahimi. The court also held that the District Court did not abuse its discretion in excluding evidence of the defendant’s belief about the lawfulness of his conduct, as the statute does not require knowledge that firearm possession is unlawful, only knowledge of the facts that make one ineligible. The conviction and denial of the motion to dismiss were affirmed. View "US v. Minor" on Justia Law