Justia Constitutional Law Opinion Summaries

Joseph Terrell Goody, a documented gang member with a lengthy criminal history, was convicted of possession of a firearm by a felon. His criminal record includes convictions for cocaine possession, robbery, assault, deadly conduct, evading arrest, and burglary. On September 26, 2020, Goody was pulled over for traffic violations, and officers found cocaine, methamphetamine, and a suspicious guitar case in his car. The case contained a loaded rifle. Goody was arrested and later pleaded guilty to violations of 18 U.S.C. §§ 922(g)(1) and 924(a)(2).The United States District Court for the Southern District of Texas sentenced Goody to 57 months of imprisonment and two years of supervised release, with a special condition prohibiting him from associating with gang members. Goody appealed his conviction and the supervised-release condition.The United States Court of Appeals for the Fifth Circuit reviewed the case. Goody raised three arguments on appeal: the facial unconstitutionality of the felon-in-possession ban under the Second Amendment, a violation of the equal protection principle under the Fifth Amendment, and the vagueness of the supervised-release condition. The court rejected all three arguments. It upheld the constitutionality of the felon-in-possession ban, found no merit in the equal protection claim, and determined that the supervised-release condition was not plainly erroneous. The court noted that similar conditions have been routinely imposed and upheld by other courts. Consequently, the Fifth Circuit affirmed the district court's judgment. View "United States v. Goody" on Justia Law

A Texas statute, Senate Bill 315, prohibits individuals under 21 from working at sexually oriented businesses (SOBs) to prevent sex trafficking and sexual exploitation. Plaintiffs, including the Texas Entertainment Association and several adult cabarets and bookstores, challenged the constitutionality of S.B. 315 under the First Amendment, suing the Texas Attorney General and the Executive Director of the Texas Workforce Commission.The United States District Court for the Western District of Texas held a bench trial and upheld the statute as constitutional. The court found that Texas enacted S.B. 315 with the reasonable belief that it would curb sex trafficking and that the law was sufficiently tailored to that end. The court applied intermediate scrutiny, concluding that the statute furthered the state's interest in reducing sex trafficking and did not restrict substantially more speech than necessary.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's judgment, agreeing that intermediate scrutiny was appropriate. The court found that S.B. 315 was designed to serve a substantial governmental interest by providing evidence linking SOBs to sex trafficking and sex crimes. The court also determined that the statute allowed for reasonable alternative avenues of communication, as it did not significantly restrict the expressive conduct of SOBs or their employees. The court concluded that S.B. 315 was not overbroad, as the plaintiffs failed to demonstrate that the statute prohibited or chilled a substantial amount of protected speech. Thus, the Fifth Circuit held that S.B. 315 is constitutional under the First Amendment. View "Ass’n of Club Executives v. Paxton" on Justia Law

Brian and Susan Fernaays own a house on lot 31 in Brewers Creek Subdivision, Isle of Wight County, Virginia. A 20-foot drainage easement, shared with lot 32, contains an underground stormwater drainage pipe that has deteriorated over time, causing significant erosion. The Fernaayses estimate the repair cost at $150,000 and sued Isle of Wight County, claiming the County owns the easement and is responsible for maintaining the pipe. They argued that the County's failure to maintain the pipe resulted in an unconstitutional taking of their property under both the Virginia and U.S. Constitutions.The United States District Court for the Eastern District of Virginia reviewed the subdivision plat and the Declaration of Covenants and Restrictions. The court found that the easement was not dedicated to the County, meaning the County had no duty to maintain the drainage pipe. Consequently, the court granted summary judgment in favor of the County.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court concluded that the Brewers Creek Partnership did not unequivocally dedicate the drainage easement to the County. The court noted that the plat and the Declaration of Covenants and Restrictions did not manifest an intent to dedicate the easement or the pipe to the County. The language in the documents suggested that the easements were for the benefit of the lot owners and that the County was only permitted to use them, not obligated to maintain them. Therefore, the County was not responsible for the damage, and the Fernaayses, as property owners, would have to bear the maintenance costs. The judgment of the district court was affirmed. View "Fernaays v. Isle of Wight County" on Justia Law

Erik Harris, a frequent marijuana user, purchased three pistols over a short period. Each time, he falsely stated on federal forms that he was not an unlawful user of marijuana. After losing one of the guns while intoxicated, Harris reported it stolen and bought a replacement. When the missing gun was found with a felon, Harris admitted to regular marijuana use during police questioning.The United States District Court for the Western District of Pennsylvania denied Harris's motion to dismiss the charges, which included three counts under 18 U.S.C. §922(g)(3) for possessing guns as an unlawful drug user and three counts under §922(a)(6) for lying to obtain the guns. The court concluded that §922(g)(3) was constitutional as applied to Harris, using means-end scrutiny. Harris then pleaded guilty to all counts but preserved his right to appeal the denial of his motion to dismiss.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that history and tradition justify §922(g)(3)’s restrictions on those who pose a special danger of misusing firearms due to frequent drug use. However, the court found insufficient facts to determine whether the law's restrictions are constitutional as applied to Harris. The court affirmed the statute's constitutionality in general but vacated Harris's conviction under §922(g)(3) and remanded the case for further fact-finding. The court also held that §922(g)(3) is not unconstitutionally vague as applied to Harris and upheld his convictions under §922(a)(6) for lying on the federal forms. View "United States v. Harris" on Justia Law

David Valle, an inmate at the California Men’s Colony, was found in possession of a 14-inch by 1-inch sharpened plastic fragment, metal fragments from a shower valve cover, and a folded metal sheet during a cell search. The plastic fragment was described as a weapon resembling a spear or knife. Valle admitted to having the items but claimed he could not remember why.Valle was convicted by a jury of possessing a sharp instrument in prison under Penal Code section 4502. The trial court sentenced him as a third-strike offender to 25 years to life in prison. Valle appealed, arguing that section 4502 is unconstitutionally vague because it does not define "sharp instrument."The California Court of Appeal, Second Appellate District, reviewed Valle's constitutional challenge de novo and rejected it. The court held that section 4502 is not unconstitutionally vague, either facially or as applied to Valle. The court reasoned that the statute's purpose is to protect inmates and prison officials from assaults by armed prisoners and that it provides a clear standard of conduct. The court cited previous California decisions that consistently upheld the statute's constitutionality.The court concluded that a 14-inch by 1-inch sharpened piece of hard, non-flexible plastic is a sharp instrument prohibited by section 4502. Valle's possession of such items, concealed in his cell, demonstrated his understanding that they were prohibited. The judgment was affirmed. View "People v. Valle" on Justia Law

A nonprofit organization, Students for Fair Admissions (SFFA), challenged the University of Texas at Austin (UT) for its admissions policies, alleging they violated the Equal Protection Clause and Title VI by considering race as a factor. After the Supreme Court's decision in Students for Fair Admissions, Inc., v. President & Fellows of Harvard College, UT revised its admissions policy to exclude race as a factor but allowed admissions officers access to applicants' racial data. SFFA claimed this access still constituted a violation and sought declaratory and injunctive relief.The United States District Court for the Western District of Texas dismissed all claims as moot, reasoning that UT's policy changes addressed the issues raised by SFFA. The district court concluded that the claims related to the old policy were moot and that the new policy did not violate the law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court agreed that claims related to UT's pre-Harvard policy were moot because the policy had been repealed and could not reasonably be expected to recur. However, the court found that claims related to UT's post-Harvard policy were not moot. The court noted that admissions officers' access to racial data could still potentially allow for racial discrimination, thus maintaining a live controversy.The Fifth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. The court held that SFFA's claims regarding the revised admissions policy remained live and required further examination to determine if the policy was a subterfuge for continued race discrimination. View "Students for Fair Admissions v. University of Texas Austin" on Justia Law

In 2023, Maine voters passed "An Act to Prohibit Campaign Spending by Foreign Governments" to prevent foreign governments and entities influenced by them from contributing to or influencing elections. The Act also requires media platforms to ensure they do not distribute communications that violate this prohibition, with violators facing civil and criminal penalties. Several companies and individuals, including Central Maine Power (CMP) and Versant Power, challenged the Act, claiming it violated the First Amendment. The district court granted a preliminary injunction against the Act, and Maine appealed.The United States District Court for the District of Maine granted the preliminary injunction, finding that the Act was likely unconstitutional under the First Amendment. The court held that the Act's prohibition on spending by entities with at least 5% foreign ownership was not narrowly tailored to a compelling state interest. It also found that the definition of "foreign government-influenced entity" was overly broad and likely to stifle domestic speech regardless of actual foreign influence. The court declined to sever the unconstitutional provisions from the rest of the Act, reserving the issue for later consideration.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that the Act's 5% foreign ownership threshold was not narrowly tailored and that the definition of "foreign government-influenced entity" was overly broad. The court also found that the Act's restrictions on contributions and expenditures were likely unconstitutional. The court did not address the issue of severability, leaving it for the district court to decide. The court also did not find it necessary to discuss the preemption determination in affirming the injunction. View "Central Maine Power Co. v. Commission on Governmental Ethics and Election Practices" on Justia Law

Steven Morgan was convicted by a jury of three drug-trafficking crimes for smuggling cocaine from the Caribbean into South Florida. The scheme involved shipping jars of shaving gel with false bottoms containing cocaine. The operation was discovered when law enforcement dogs in Puerto Rico alerted on packages containing cocaine. A controlled delivery led to Morgan's arrest, during which two cellphones were found near him. Morgan initially claimed ownership of both phones but later stated only the iPhone was his.The United States District Court for the Southern District of Florida suppressed Morgan's statement in the patrol car and his statements made 18 months later but admitted the LG phone's contents, finding Morgan had abandoned it. The court also allowed the government to introduce Morgan's initial statement claiming ownership of both phones but later reversed this decision during the trial.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court did not err in finding Morgan had abandoned the LG phone, thus allowing its contents to be admitted. The court also found that the Fifth Amendment did not require suppression of the phone's contents, as Morgan's statement was voluntary despite being obtained in violation of Miranda. The court affirmed the district court's denial of a mistrial after an agent referred to Morgan's suppressed statement, finding no substantial prejudice. The court also upheld the admission of testimony from Agent Gaviria and expert testimony from Agent Suarez, finding no plain error in the government's expert disclosures. Finally, the court found no cumulative error warranting reversal and affirmed Morgan's conviction. View "United States v. Morgan" on Justia Law

No Labels Party of Arizona (No Labels) is a political party that only seeks to run candidates for the offices of President and Vice President of the United States. During the 2024 election, five No Labels party members filed statements of interest to run for down-ballot positions. No Labels requested that the Arizona Secretary of State (the Secretary) disregard these filings, but the Secretary refused, citing Arizona law that mandates acceptance of candidate filings by eligible persons.The United States District Court for the District of Arizona granted No Labels a permanent injunction, finding that the Arizona law substantially burdened No Labels's First Amendment rights by forcing it to associate with candidates for offices it did not wish to pursue. The court concluded that Arizona's interests were minimal and did not outweigh the burden on No Labels's rights.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court's decision. The Ninth Circuit held that the Secretary's enforcement of Arizona's election law, which allowed eligible No Labels party members to be placed on the primary ballot, imposed at most a minimal burden on No Labels's associational rights. The court found that Arizona's interests in ensuring voter and candidate participation, avoiding voter confusion, and limiting opportunities for fraud and corruption outweighed any burden on No Labels. The court concluded that the Secretary's actions were narrowly tailored to advance these compelling state interests. Consequently, the Ninth Circuit vacated the permanent injunction issued by the district court. View "No Labels Party of Arizona v. Fontes" on Justia Law

Ronnie Alexander was arrested and detained in Henderson County Jail while awaiting trial. He falsely informed jail officials that he was suicidal to be transferred out of the group holding cell. Consequently, he was moved to the jail's suicide-prevention cell, known as the "violent cell," which lacked basic amenities such as a toilet, running water, or bedding, and had lights on at all hours. Alexander was housed there for five days before being released. He subsequently filed a lawsuit challenging the conditions of his confinement and the adequacy of the jail's mental health services.The United States District Court for the Northern District of Texas granted the defendants' motions to dismiss Alexander's federal and state-law claims. The court found that Alexander failed to state a claim under 42 U.S.C. § 1983 against the Taft defendants, Henderson County, and the correctional officers. The court also declined to exercise supplemental jurisdiction over Alexander's remaining state-law claims and dismissed them without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The court held that the conditions of the violent cell were reasonably related to the legitimate governmental interest of protecting suicidal inmates from self-harm. The court found that the conditions, although harsh, were not punitive and did not violate Alexander's constitutional rights. The court also determined that the mental health care provided to Alexander met the constitutional minimum required, and there was no deliberate indifference by the Taft defendants or the county. Consequently, Alexander's claims were dismissed. View "Alexander v. Taft" on Justia Law