Justia Constitutional Law Opinion Summaries

Plaintiffs, CompassCare, the National Institute of Family and Life Advocates (NIFLA), and First Bible Baptist Church, challenged the constitutionality of New York Labor Law Section 203-e, which prohibits discrimination based on an employee’s or a dependent’s reproductive health decision making. They argued that the law infringed on their First Amendment rights of expressive association, speech, and religion, and that the Notice Provision, which required employers issuing employee handbooks to include information about employees' rights under the Act, compelled speech in violation of the First Amendment.The United States District Court for the Northern District of New York dismissed Plaintiffs' claims related to expressive association, speech, free exercise, religious autonomy, and vagueness. However, it permanently enjoined the enforcement of the Act’s Notice Provision. The case was then influenced by the Second Circuit's decision in Slattery v. Hochul, which held that an employer might have an associational-rights claim if the Act forces the employer to employ individuals acting against the organization’s mission.The United States Court of Appeals for the Second Circuit reviewed the case. It vacated the District Court’s dismissal of Plaintiffs’ expressive-association claim, the grant of summary judgment to Plaintiffs regarding the Notice Provision, and the permanent injunction. The Court remanded the case for the District Court to determine whether any Plaintiff has plausibly alleged an associational-rights claim under the precedent set by Slattery. The Court held that the Act’s Notice Provision is subject to rational basis review and is reasonably related to the State’s interest in preventing deception of employees regarding their statutory rights. It also affirmed the dismissal of Plaintiffs’ free speech and free exercise claims. View "CompassCare v. Hochul" on Justia Law

Two defendants, Martin Field and John Asher, were found to be sexually violent predators (SVPs) by separate juries and committed indefinitely to a state hospital. They were compelled to testify against themselves during their commitment trials. Both argued on appeal that they were similarly situated to individuals found not guilty by reason of insanity (NGIs), who are not required to testify against themselves at their commitment trials. They claimed this disparity violated equal protection principles.The California Court of Appeal, Fourth Appellate District, previously found merit in Field's equal protection argument and remanded the case to the Superior Court of San Bernardino County for an evidentiary hearing. The same conclusion was reached for Asher's case by Division Three of the Fourth Appellate District. The trial court held an evidentiary hearing and determined that the People had not met their burden to justify the disparate treatment of SVPs and NGIs. Consequently, the court concluded that equal protection principles were violated and ordered new commitment trials for both Field and Asher.The People appealed the new trial orders, arguing that the trial court erred in finding that the disparate treatment of SVPs was not justified. The California Court of Appeal, Fourth Appellate District, reviewed the case and affirmed the trial court's orders. The appellate court held that the People had not demonstrated that the testimony of SVPs was more necessary than that of NGIs to justify the disparate treatment under the strict scrutiny standard. The court emphasized that there were sufficient records and other means to evaluate SVPs without compelling their testimony, and thus, the equal protection violation was not justified. View "P. v. Field" on Justia Law

Santa Rita Holdings, Inc. applied for a conditional use permit (CUP) from the County of Santa Barbara to cultivate cannabis on a 2.54-acre parcel owned by Kim Hughes. The only access to the parcel is through a private easement over land owned by JCCrandall, LLC. The County's fire and public works departments deemed the road adequate for the project. Despite JCCrandall's objections, the County granted the CUP, and the Board of Supervisors upheld this decision.JCCrandall petitioned for a writ of administrative mandate, arguing that the use of the easement for cannabis activities was prohibited by the easement deed and federal law, that state law required their consent for such activities, and that the road did not meet County standards. The trial court denied the petition, applying the substantial evidence standard and finding the County's decision supported by substantial evidence.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The court determined that the trial court erred in applying the substantial evidence standard instead of the independent judgment standard, as JCCrandall's right to exclude unauthorized persons from their property is a fundamental vested right. The appellate court held that under federal law, cannabis is illegal, and thus, the use of the easement for cannabis transportation exceeds the scope of the easement. The court also found that the County's reliance on Civil Code section 1550.5, subdivision (b), which deems cannabis activities lawful under California law, defies the Supremacy Clause of the U.S. Constitution. Consequently, the judgment was reversed, and costs were awarded to JCCrandall. View "JCCrandall v. County of Santa Barbara" on Justia Law

Appellant M.T., a transgender woman, petitioned to legally change her name and gender in 2017, which was granted by the Stanislaus Superior Court in 2018. In 2023, M.T. requested the court to seal the entire record of her name change and gender marker correction, citing harassment and threats after being "outed" on social media. The trial court denied the request to seal the entire record but sealed the application to seal, its supporting documentation, and a physician's letter attached to the initial petition.The trial court found that M.T. had not shown an overriding interest that would overcome the right of public access to the records. The court noted that California's liberal name change policy presumes name changes should be public to prevent fraud and ensure creditors and others can locate individuals who have changed their names. The court also found insufficient evidence that the harassment M.T. experienced was directly linked to the public availability of her court records.The California Court of Appeal, Fifth Appellate District, reviewed the case and concluded that M.T. had demonstrated an overriding privacy and safety interest in sealing her records. The court found that the harassment and threats M.T. experienced were likely linked to the public availability of her records and that there was a substantial probability of future harm if the records remained unsealed. The appellate court determined that M.T.'s privacy and safety interests outweighed the public's right of access to the records and that sealing the entire record was necessary to protect those interests.The appellate court reversed the trial court's order denying the request to seal the entire record and remanded the case with instructions to seal all records that reveal M.T.'s name change or gender marker correction. View "In re M.T." on Justia Law

Cristian Omar Martinez successfully moved to vacate his conviction and withdraw his plea under Penal Code section 1473.7. He then filed a motion to dismiss the charges against him, which the trial court denied. Martinez appealed, arguing that section 1473.7 does not allow the trial court to reinstate the original charges and that doing so violates the double jeopardy clause of the Fifth Amendment. The Attorney General contended that the order denying Martinez’s motion to dismiss is not appealable and that the trial court did not err in denying the motion.The Santa Clara County Superior Court initially granted Martinez’s motion to vacate his conviction and withdraw his plea. However, when Martinez subsequently moved to dismiss the charges, the trial court denied the motion, stating that section 1473.7 does not provide for dismissal after a plea is set aside.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court agreed with the Attorney General that the order denying the motion to dismiss is not appealable. However, the court exercised its discretion to treat the appeal as a petition for writ of mandate. Upon examining the merits, the court concluded that section 1473.7 does not mandate the dismissal of charges after a conviction is vacated and a plea is withdrawn. The court also found that section 1203.4, which provides for the dismissal of charges upon successful completion of probation, does not preclude the refiling of charges once a conviction is vacated under section 1473.7. Additionally, the court held that the original charges could be reinstated as felonies despite their prior reduction to misdemeanors. The court denied the petition for writ of mandate and directed the parties to proceed on the reinstated information. View "Martinez v. Super. Ct." on Justia Law

On November 5, 2021, officers from the Mountain View Police Department investigated a reported armed robbery at Brendan Krepchin’s apartment. They found no evidence of a robbery but discovered a note suggesting a plan for violence, law enforcement equipment, and firearms. The police department petitioned for a gun violence restraining order (GVRO), which the Santa Clara County Superior Court issued initially as an emergency order and later as a three-year order after a hearing in January 2023. The order barred Krepchin from possessing firearms or ammunition.The Santa Clara County Superior Court issued the emergency GVRO on November 5, 2021, and later a three-year GVRO after a hearing in January 2023. The court found clear and convincing evidence that Krepchin posed a significant danger of causing personal injury by possessing firearms. Krepchin appealed, arguing the GVRO violated his Second Amendment rights, was procedurally defective, and that the trial court erred in qualifying an officer as a threat assessment expert and admitting hearsay evidence.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that the GVRO did not violate the Second Amendment, referencing the U.S. Supreme Court’s decision in New York State Rifle & Pistol Association, Inc. v. Bruen and United States v. Rahimi, which upheld firearm restrictions for individuals posing a threat. The court also found no procedural defects in the GVRO issuance and ruled that the trial court did not abuse its discretion in qualifying the officer as an expert or admitting hearsay evidence. The court concluded that substantial evidence supported the GVRO, affirming the lower court’s decision. View "Mountain View Police Dept. v. Krepchin" on Justia Law

Robert Mann, a taxpayer, filed a lawsuit against the State of California and the California Highway Patrol (CHP), challenging CHP’s vehicle impound policies. Mann argued that the impoundment of vehicles without a warrant and inadequate notice procedures constituted illegal expenditures of public funds. He sought declaratory and injunctive relief to prevent what he characterized as wasteful, unlawful, and unconstitutional law enforcement policies. The trial court granted a permanent injunction requiring CHP to consider vehicle owners’ ability to pay towing and storage fees during impound hearings and vehicle release procedures, and to revise its notice form to advise owners of procedures for retrieving impounded vehicles.The Superior Court of Los Angeles County initially reviewed the case. At the close of the plaintiffs’ case, the trial court granted a motion for judgment against Youth Justice Coalition and entered judgment in favor of defendant Warren A. Stanley, who had retired before the trial. The court found that Stanley, as a former public officer, was no longer a proper defendant. The trial court issued a permanent injunction requiring CHP to revise its vehicle impound procedures, including considering the ability to pay and revising notice forms.The Court of Appeal of the State of California, Second Appellate District, Division Two, reviewed the case. The court reversed the trial court’s judgment, holding that the injunction improperly required CHP to contravene valid statutes, relied on inapplicable case law, conflicted with the existing statutory scheme, and mandated unnecessary revisions to its notice procedures. The appellate court concluded that the trial court erred in requiring CHP to conduct ability-to-pay hearings and revise its notice forms, as these requirements were not mandated by due process and conflicted with statutory provisions. The judgment was reversed, and costs on appeal were awarded to the appellant. View "Mann v. State of Cal." on Justia Law

James Lamont Bagsby was convicted and sentenced to 107 years to life for violent crimes committed at age 15. After serving over 15 years, he petitioned for recall and resentencing under Penal Code section 1170(d), which applies to juveniles sentenced to life without parole. Bagsby argued his sentence was the functional equivalent of life without parole, citing People v. Heard, which held that denying such juveniles the opportunity to petition for resentencing violates equal protection. The trial court agreed, granted his petition, and ordered his release, but stayed the release pending appeal.The People appealed, asking the Court of Appeal to strike down the section 1170(d) resentencing provision or reconsider Heard. They also argued the trial court had jurisdiction to resentence Bagsby and erred in ordering his release. Bagsby cross-appealed the stay order.The California Court of Appeal, Fourth Appellate District, Division One, affirmed the trial court's orders. The court upheld Heard, finding no compelling reason to overturn it. The court rejected the People's arguments, noting that the Legislature had not repealed the section 1170(d) resentencing provision despite amendments to related laws. The court also found that the trial court correctly applied Proposition 57 and Senate Bill 1391 retroactively, making Bagsby's judgment nonfinal and placing him outside juvenile court jurisdiction.The court declined to reverse the stay order, noting it would expire upon remittitur, making Bagsby's release effective as of the original release date for custody credit purposes. The court presumed the California Department of Corrections and Rehabilitation would calculate Bagsby's custody credits correctly. View "People v. Bagsby" on Justia Law

Mark Uhlenbrock was convicted by a jury for violating 18 U.S.C. § 2261A(2)(B) by posting nude images and videos of his ex-girlfriend, YT, on Reddit, along with explicit stories written in her name. Some of the images were taken with her consent during their relationship, while others were recorded without her knowledge. Uhlenbrock's posts included personal details about YT, such as her occupation and employer, and invited men to proposition her. YT discovered the posts through a family friend and reported Uhlenbrock to the FBI.The United States District Court for the Western District of Texas denied Uhlenbrock's motion to dismiss the indictment on First Amendment and vagueness grounds. During the trial, the court allowed testimony about Uhlenbrock's prior similar conduct, which included a 2016 guilty plea for cyberstalking YT. The jury found Uhlenbrock guilty, and the district court sentenced him to 60 months in prison, three years of supervised release, and restitution. The court also revoked his supervised release from the 2016 case and sentenced him to an additional 12 months in prison. Uhlenbrock appealed both the new conviction and the revocation of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decisions. The court held that Uhlenbrock's posts constituted unprotected defamation and that the application of § 2261A(2)(B) did not violate the First Amendment. The court also found that the statute was not unconstitutionally vague and that the district court did not abuse its discretion in admitting evidence of Uhlenbrock's prior conduct. The court concluded that there was sufficient evidence for a reasonable jury to find that Uhlenbrock intended to harass or intimidate YT and that his conduct caused her substantial emotional distress. The court also rejected Uhlenbrock's claims of constructive amendment of the indictment and double jeopardy. View "USA v. Uhlenbrock" on Justia Law

Plaintiffs, representing West Virginia Parents for Religious Freedom and others, filed a lawsuit challenging West Virginia's mandatory vaccination requirement for children, claiming it violates the Free Exercise Clause of the First Amendment. The law mandates immunizations for children attending public, private, or parochial schools, with medical exemptions but no religious exemptions. Plaintiffs sought declaratory and injunctive relief against state health officials.The United States District Court for the Northern District of West Virginia applied the Pullman abstention doctrine, deciding not to resolve the Free Exercise claim and staying the case. The court reasoned that a recent state law, the Equal Protection for Religion Act (EPRA), might impact the vaccination mandate and should be interpreted by state courts first. The district court denied the plaintiffs' motion for summary judgment and granted the defendants' motion to abstain.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court erred in applying the Pullman abstention doctrine because the plaintiffs' claim did not present an unclear issue of state law requiring interpretation. The court emphasized that federal courts have a duty to exercise their jurisdiction and that abstention is only appropriate in special circumstances. The Fourth Circuit vacated the district court's abstention ruling and remanded the case for further proceedings, including addressing the defendants' arguments regarding Ex Parte Young and Article III standing, and if necessary, resolving the Free Exercise claim. View "West Virginia Parents for Religious Freedom v. Christiansen" on Justia Law