Justia Constitutional Law Opinion Summaries

Shawn Sheltra, an inmate with the Idaho Department of Corrections (IDOC), filed a formal grievance in March, identifying safety concerns and threats from other inmates in his housing unit. He warned that he would be attacked in April if he did not make an extortion payment. Despite being briefly isolated, Sheltra was returned to his housing unit and was attacked by another inmate in April. He subsequently filed a lawsuit, asserting violations of the Eighth and Fourteenth Amendments due to the defendants' failure to protect him from a known harm.The United States District Court for the District of Idaho granted summary judgment for the defendants, dismissing the action for failure to exhaust administrative remedies because Sheltra did not file a formal grievance after the April attack. The court also granted summary judgment for the defendants on Sheltra's official-capacity claims, as they were barred by the Eleventh Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and adopted the continuing-violations doctrine for purposes of administrative exhaustion under the Prison Litigation Reform Act (PLRA). The court held that a properly exhausted prison grievance asserting one continuing harm or a single course of conduct can exhaust events arising out of the same alleged violation that occur after the grievance was made. Applying this doctrine, the court concluded that Sheltra's attack was part of the same continuing harm or course of conduct described in his prison grievance before the attack. Therefore, the court reversed the district court's summary judgment on Sheltra's individual-capacity claims against the defendants. However, the court affirmed the district court's grant of summary judgment for the defendants on Sheltra's official-capacity claims due to Eleventh Amendment immunity. View "SHELTRA V. CHRISTENSEN" on Justia Law

Ramel L. Sheppard was convicted of domestic violence aggravated assault after a jury trial in which the victim did not testify. The conviction was based in part on the victim's hearsay statement to a police officer identifying Sheppard as her attacker. Sheppard appealed, arguing that the trial court erred in admitting the hearsay statement as an excited utterance and that its admission violated his rights under the Confrontation Clause of the U.S. Constitution.The trial court (Androscoggin County) admitted the victim's statement under the excited utterance exception to the hearsay rule, finding that the statement was made spontaneously and while the victim was still under the stress of the assault. The court also determined that the statement was nontestimonial, as it was made in the context of an ongoing emergency and not for the primary purpose of creating evidence for prosecution. The jury found Sheppard guilty on two counts, but the court later merged one count into the other and sentenced Sheppard to seven years' imprisonment, with all but forty months suspended, and three years of probation.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court's judgment. The court held that the trial court did not abuse its discretion in admitting the victim's statement as an excited utterance, as the statement was made spontaneously and under the stress of the assault. The court also held that the statement was nontestimonial, as it was made in the context of an ongoing emergency and not for the primary purpose of creating evidence for prosecution. Therefore, the admission of the statement did not violate Sheppard's rights under the Confrontation Clause. View "State of Maine v. Sheppard" on Justia Law

Jonathan Joshua Munafo pleaded guilty to two charges related to his involvement in the January 6, 2021, attack on the U.S. Capitol. The district court accepted his plea and sentenced him to 33 months in prison, within the agreed U.S. Sentencing Guidelines range of 30-37 months. Munafo appealed, arguing that the government breached his plea agreement by not dismissing a pending misdemeanor assault charge in D.C. Superior Court and by referring to his past statements and affiliations during sentencing.The district court for the District of Columbia had accepted Munafo's guilty plea and sentenced him based on the agreed guidelines. Munafo did not raise the issue of the pending misdemeanor charge until after his sentencing, and the court did not rule on it, suggesting instead that Munafo's counsel discuss it with the U.S. Attorney's Office. Munafo also objected to the government's sentencing presentation, claiming it breached the plea agreement by including information beyond the agreed-upon Statement of Offense.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that Munafo forfeited his objection regarding the dismissal of the misdemeanor charge by not pressing it before the district court. Additionally, the court found that the plea agreement did not support Munafo's interpretation that the government was required to dismiss the pending charge. The court also held that the government's references during sentencing did not breach the plea agreement, as the agreement allowed both parties to describe fully the nature and seriousness of Munafo's misconduct.Munafo's claim that his sentence appeared to be based on his constitutionally protected political speech and affiliations was also rejected. The court noted that Munafo had waived his right to appeal his sentence unless it exceeded the statutory maximum or guidelines range, and he did not make a colorable claim of a miscarriage of justice. The court affirmed Munafo's sentence. View "USA v. Munafo" on Justia Law

Yaakov Markel, an Orthodox Jewish man, worked as a mashgiach for the Union of Orthodox Jewish Congregations of America (OU) from 2011 to 2018. His role involved supervising food preparation to ensure kosher compliance, particularly for grape products. Markel claimed that his supervisor, Rabbi Nachum Rabinowitz, promised him a promotion and a raise, which he did not receive, and that OU withheld certain overtime compensation. Markel resigned and filed suit, bringing wage and hour and fraud and misrepresentation claims against OU and Rabbi Rabinowitz.The United States District Court for the Central District of California granted summary judgment in favor of the defendants, holding that the First Amendment’s ministerial exception barred Markel’s employment-related claims. The court determined that OU is a religious organization and that a mashgiach is considered a minister within Orthodox Judaism, thus invoking the ministerial exception.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that the ministerial exception categorically barred Markel’s claims because OU is a religious organization and a mashgiach is a minister. The court emphasized that the acceptance of revenue does not deprive an organization with a religious mission of First Amendment protections. The court also rejected Markel’s argument that the ministerial exception was inapplicable because his dispute involved only secular issues, noting that a religious institution’s decisions, even if facially secular, are often intertwined with religious doctrine. The court further held that the ministerial exception protects both religious organizations and their leaders from claims brought by ministerial employees. View "MARKEL V. UNION OF ORTHODOX JEWISH CONGREGATIONS OF AMERICA" on Justia Law

Michael Blake DeFrance was convicted of assaulting his girlfriend in 2013 under Montana Code Annotated section 45-5-206(1)(a), a misdemeanor. In 2018, he was found in possession of three firearms, leading to a federal indictment for violating 18 U.S.C. § 922(g)(9), which prohibits firearm possession by individuals convicted of a misdemeanor crime of domestic violence.The United States District Court for the District of Montana denied DeFrance's motion to dismiss the indictment, which argued that the Montana statute could be violated without the use of physical force. DeFrance was subsequently convicted and appealed the decision.The United States Court of Appeals for the Ninth Circuit reviewed the case and applied the categorical approach to determine whether a conviction under Montana's PFMA statute qualifies as a "misdemeanor crime of domestic violence" under 18 U.S.C. § 922(g)(9). The court concluded that because the Montana statute can be violated by inflicting emotional distress rather than physical injury, it does not have, as an element, the use or attempted use of physical force as required by 18 U.S.C. § 921(a)(33)(A)(ii). Consequently, the court held that DeFrance's conviction under the Montana statute does not qualify as a misdemeanor crime of domestic violence.The Ninth Circuit reversed DeFrance's conviction under 18 U.S.C. § 922(g)(9), vacated his sentence, and remanded the case for resentencing or other proceedings consistent with their opinion. View "USA V. DEFRANCE" on Justia Law

Residents of Humboldt County filed a putative class action under 42 U.S.C. § 1983, alleging that the County’s system of administrative penalties and fees for cannabis abatement violates the Eighth Amendment’s Excessive Fines Clause. The County Code imposes daily fines of $6,000 to $10,000 for illegal cannabis cultivation. Plaintiffs claimed that the County charges landowners based on imprecise data or previous owners' conduct, causing emotional distress and financial burdens due to ongoing penalties and abatement costs.The United States District Court for the Northern District of California dismissed the case, concluding that plaintiffs lacked standing as they had not paid any fines, rendering the Eighth Amendment claim unripe. The court also found both facial and as-applied challenges untimely, reasoning that the statute of limitations began when the ordinance was enacted.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that plaintiffs’ claim under the Excessive Fines Clause was constitutionally ripe and that they had standing due to the imposition of penalties causing concrete injuries, including emotional distress and financial expenses. The court also found that prudential ripeness considerations supported allowing the litigation to proceed. The court determined that the statute of limitations for facial challenges begins when plaintiffs know of the actual injury, not when the ordinance is enacted. Thus, some plaintiffs’ facial challenges were timely. The court also found that several plaintiffs had timely as-applied challenges, except for Cyro Glad, whose claim was untimely.On the merits, the Ninth Circuit held that plaintiffs plausibly alleged a violation of the Excessive Fines Clause, as the penalties and demolition orders were punitive and potentially excessive. The court reversed the district court’s dismissal of the Eighth Amendment claim and remanded for further proceedings, affirming the dismissal only for Cyro Glad’s as-applied claim. View "THOMAS V. COUNTY OF HUMBOLDT" on Justia Law

Two Starbucks employees, Echo Nowakowska and Tristan Bussiere, were terminated after engaging in labor organizing activities. Starbucks claimed the terminations were due to policy violations and poor performance. However, the National Labor Relations Board (NLRB) found that the terminations were motivated by the employees' organizing activities, violating Sections 8(a)(1) and 8(a)(3) of the National Labor Relations Act (NLRA). The NLRB sought enforcement of its order, while Starbucks cross-petitioned for review on several issues, including the constitutionality of the NLRB's administrative law judges (ALJs) and the sufficiency of evidence supporting the NLRB's conclusions.The ALJ concluded that Starbucks failed to prove it would have terminated the employees absent their organizing activities. The ALJ found substantial evidence that the terminations and reduction in hours were motivated by anti-union animus, supported by internal communications and the timing of disciplinary actions. The NLRB adopted the ALJ's findings and ordered Starbucks to reinstate the employees and compensate them for lost earnings and benefits.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that it lacked jurisdiction to consider Starbucks' constitutional challenge to the ALJ removal protections and found that Starbucks failed to demonstrate injury from these protections. The court also found substantial evidence supporting the NLRB's conclusions that the terminations and reduction in hours were due to the employees' organizing activities. Additionally, the court upheld the NLRB's finding that Starbucks knew about the employees' recording activities before their terminations, precluding the use of after-acquired evidence to limit remedies.However, the court vacated the portion of the NLRB's order requiring Starbucks to compensate the employees for direct or foreseeable pecuniary harms, finding it exceeded the Board's authority under the NLRA. The case was remanded for further proceedings consistent with the court's opinion. View "NLRB v. Starbucks Corp" on Justia Law

Stephen Rippey pled guilty to one count of aggravated sexual abuse of a child and one count of object rape of a child. He was sentenced to two concurrent prison terms of fifteen years to life. Ten years after his conviction, a district court reinstated Rippey’s time to file a direct appeal. On appeal, Rippey challenged several aspects of his plea, conviction, and sentence, leading the Supreme Court of Utah to address whether the Plea Withdrawal Statute (PWS) is constitutional.The Third District Court in West Jordan initially accepted Rippey’s guilty plea after a colloquy and a signed plea form. Rippey did not move to withdraw his plea before sentencing. He later filed a pro se petition for post-conviction relief under the Post-Conviction Remedies Act (PCRA), listing seventeen claims. The district court dismissed eight claims as frivolous and the remaining claims for failure to state a claim. Rippey’s requests for appointed counsel were denied. The Utah Court of Appeals upheld the district court’s dismissal, concluding that Rippey’s claims were unpreserved except for ineffective assistance of counsel, which lacked merit.The Supreme Court of Utah reviewed the constitutionality of the PWS, specifically subsections (2)(b) and (2)(c). The court held that subsection (2)(b)’s preservation rule and the corresponding waiver in subsection (2)(c) violate the separation of powers under the Utah Constitution. These provisions were deemed procedural, not substantive, and thus beyond the legislature’s authority to enact. The court concluded that the PWS does not bar Rippey’s challenge to his guilty plea, and his appeal is now governed by standard rules of preservation. The court instructed the parties to brief the merits of Rippey’s challenges under these standards. View "State v. Rippey" on Justia Law

POM of Kansas, LLC, owns and distributes Dragon's Ascent, an arcade game where players shoot dragons for prizes redeemable for cash. Concerned about the game's legality under Kansas law, POM sought approval from state agencies, which declined to provide a formal opinion. POM proceeded with the game's launch and filed a lawsuit seeking a declaratory judgment that the Kansas Expanded Lottery Act does not apply to Dragon's Ascent, that the game complies with Kansas' criminal gambling statutes, and that those statutes are unconstitutionally vague.The Shawnee District Court dismissed the claims against the Kansas Racing and Gaming Commission and the Douglas County District Attorney, ruling that no real controversy existed as neither had investigated the game nor threatened prosecution. The court retained the Kansas Attorney General in the case due to the constitutional challenges raised. The district court later dismissed POM's claims for lack of subject-matter jurisdiction and ruled against the constitutional challenges on the merits.The Kansas Supreme Court reviewed the case and focused on the issue of standing. The court held that POM lacked standing to seek a declaratory judgment about the Kansas Expanded Lottery Act because no defendant suggested the Act applied to Dragon's Ascent. The court also found that POM lacked standing to seek a declaration that Dragon's Ascent is lawful under Kansas criminal gambling statutes, as there was no credible threat of prosecution or seizure of the devices. Finally, the court concluded that POM lacked standing to raise a constitutional vagueness challenge to the gambling statutes, as there was no credible threat of prosecution.The Kansas Supreme Court affirmed the district court's dismissal of POM's claims regarding the Expanded Lottery Act and the legality of Dragon's Ascent, vacated the ruling on the constitutional vagueness challenge, and remanded the matter for dismissal. View "POM of Kansas v. Kobach" on Justia Law

On January 6, 2021, Darrell Neely, a radio host, entered the U.S. Capitol building during the riot that disrupted the certification of the 2020 presidential election. Neely spent over an hour inside the Capitol, during which he stole items belonging to the U.S. Capitol Police. He was later indicted and convicted of five misdemeanor offenses, resulting in a 28-month prison sentence. Neely appealed, challenging the denial of three pretrial motions on statutory and constitutional grounds.The United States District Court for the District of Columbia denied Neely's motions to dismiss certain charges, transfer venue, and suppress a confession. Neely argued that the statute under which he was charged did not apply to his conduct, that he could not receive a fair trial in the District of Columbia, and that his confession was obtained in violation of his Miranda rights. The District Court rejected these arguments, leading to Neely's conviction and sentencing.The United States Court of Appeals for the District of Columbia Circuit reviewed Neely's appeal. The court held that the statute in question did apply to Neely's conduct, as it did not specify that only the Secret Service could restrict the relevant areas. The court also found that the statute was not unconstitutionally vague. Regarding the motion to suppress, the court determined that Neely's Miranda rights were not violated, as there was no evidence of a deliberate two-step interrogation strategy by the FBI. Finally, the court upheld the denial of the motion to transfer venue, finding no presumption of jury prejudice. Consequently, the court affirmed Neely's convictions and sentence. View "USA v. Neely" on Justia Law