Justia Constitutional Law Opinion Summaries

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

During a traffic stop in Hidalgo County, Texas, a sheriff’s deputy pulled over Gerardo Villarreal for driving with a partially obscured license plate. The deputy discovered Villarreal did not have a driver’s license or insurance. After a canine sniff alerted to an item in the vehicle, officers searched the car, finding a handgun and a small amount of cocaine. Villarreal was later indicted for being a felon in possession of a firearm under federal law. He moved to suppress the handgun as evidence, arguing the search violated his Fourth Amendment rights.The United States District Court for the Southern District of Texas held a hearing on the motion to suppress. The court heard testimony from the arresting deputy, who explained that department policy generally required impounding vehicles when the driver lacked a license or insurance, with certain exceptions. The deputy testified he would have impounded Villarreal’s vehicle and performed an inventory search, which would have revealed the handgun. Villarreal attempted to impeach this testimony, referencing another incident where the deputy did not impound a vehicle under similar circumstances, but the deputy explained possible exceptions. The district court found the deputy credible and denied the motion to suppress, applying the inevitable-discovery doctrine.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Fifth Circuit held that the inevitable-discovery doctrine applied because the government showed by a preponderance of the evidence that an inventory search, conducted pursuant to standard department policy, would have discovered the handgun. The court found that the impounding and inventory search were imminent before any alleged misconduct, and the department’s policy sufficiently limited officer discretion. The Fifth Circuit affirmed the district court’s judgment, upholding denial of the motion to suppress. View "USA v. Villarreal" on Justia Law

A developer challenged the legality of “recreation fees” imposed by a municipality on builders of new subdivisions. The developer argued that the town’s fees, charged in lieu of dedicating land for public recreation, either exceeded statutory limits or were unconstitutional because they were not proportionate to each development’s impact. The developer further alleged that the municipality did not use the fees as required, instead commingling them with general funds and failing to create or improve public recreation areas near the developments.In the Superior Court of Wake County, the developer pursued a putative class action seeking declaratory relief and a refund of all such fees paid since November 2017. The Superior Court certified a class including all payers of the recreation fees, finding several common legal questions appropriate for resolution on a class-wide basis. These included whether the fees violated statutory requirements, whether their calculation was legally proper, whether their use complied with statutory mandates, and whether they were constitutionally proportionate. The municipality appealed directly to the Supreme Court of North Carolina, arguing that individualized factual inquiries predominated over common issues and that a class action was not the superior method of adjudication.The Supreme Court of North Carolina held that the class as certified did not satisfy the predominance requirement for class actions. The Court explained that several claims—such as whether fees exceeded fair market value or were roughly proportional—would require individualized, fact-intensive determinations for each class member, resulting in mini-trials that would overwhelm the common legal issues. Consequently, the Supreme Court vacated the trial court’s class certification order and remanded for further proceedings, instructing the lower court to reconsider class certification in light of these findings. View "Empire Contractors Inc. v. Town of Apex" on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

A member of the Sisseton Wahpeton Oyate tribe was observed by a tribal police officer driving erratically within the city limits of Sisseton, nearly causing multiple collisions and fleeing from law enforcement. He was apprehended in a tribal housing unit. Subsequently, the tribal prosecutor charged him in tribal court with driving under the influence (DUI) and resisting arrest, while South Dakota state court charged him with resisting arrest, reckless driving, and assaulting a law enforcement officer. He later pled guilty in state court to assault and was sentenced to two years in prison. The tribal court then dismissed the DUI charge without prejudice.He filed a federal lawsuit in the United States District Court for the District of South Dakota against various tribal officials, alleging that the DUI charge exceeded the tribe’s criminal jurisdiction and violated his rights under the Fourth Amendment and the Indian Civil Rights Act. The District Court dismissed the case for lack of subject matter jurisdiction, holding that the complaint failed to raise a federal question under 28 U.S.C. § 1331.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the dismissal. The court concluded that, even assuming it had jurisdiction to consider the scope of the tribe’s criminal authority, the case had become moot because the tribal DUI charge was dismissed and could not be refiled due to the expiration of the statute of limitations. The court found that neither the voluntary cessation exception nor the “capable of repetition, yet evading review” exception to mootness applied. Accordingly, the Eighth Circuit affirmed the district court’s judgment and vacated its decision, declining to address the underlying questions of tribal jurisdiction, sovereign immunity, or exhaustion of tribal remedies. View "LaBatte v. Gangle" on Justia Law

Drug task force officers in West Virginia observed a car with expired registration, dark window tint, and a malfunctioning taillight, driven by Cornelious Johnson—an individual known to them from a prior drug conviction and currently on federal supervised release. The officers watched as Johnson and his passenger interacted with a man, Jackie Byrd, at an apartment complex previously associated with drug investigations. Although the officers suspected a drug transaction, they did not witness any exchange of items. Shortly after, Tremayne Hawkins entered the back seat, and the car left the complex. Officer Stanley, informed by the task force, stopped the car for the observed traffic violations and, suspecting drug activity, separated and questioned the occupants about their interaction with Byrd. Citing minor inconsistencies in their answers, Stanley called for a K9 unit, which alerted to drugs. A subsequent search yielded a firearm on Hawkins, who admitted to being prohibited from possessing one due to a prior conviction.The United States District Court for the Northern District of West Virginia denied Hawkins’ motion to suppress the firearm, holding that the officers had reasonable suspicion to extend the stop based on the area’s reputation, Johnson’s prior conviction, the observed interaction with Byrd, and the inconsistent statements from the occupants.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The Fourth Circuit held that none of the cited factors—alone or in combination—provided reasonable suspicion to extend the stop. The court emphasized that presence in an area associated with prior investigations, a dated conviction, innocuous interactions, and minor, reconcilable inconsistencies in statements did not collectively amount to reasonable suspicion of criminal activity. Accordingly, the Fourth Circuit reversed the district court’s denial of the suppression motion and remanded the case for further proceedings. View "US v. Hawkins" on Justia Law

A proposed constitutional initiative in Montana sought to require that Supreme Court and district court elections remain nonpartisan, reflecting a legal tradition in Montana since 1935. The proponent organization submitted both the initiative and a draft explanatory ballot statement to the Secretary of State, which was then reviewed by the Legislative Services Division. The organization’s draft statement explained the initiative would constitutionalize the existing statutory requirement, making future changes possible only by constitutional amendment.After the statutory review process, the Attorney General concluded the initiative met legal sufficiency but chose to substitute his own revised ballot statement, claiming the revision would improve clarity and better inform voters of the initiative’s effects. He did not detail any statutory deficiencies in the proponent's original statement. The proponent organization, joined by another organization interested in nonpartisan judicial elections, challenged the Attorney General’s authority to revise the statement without a written determination that the original was not clear or impartial. The Attorney General responded that only the proponent of the specific initiative could bring such a challenge.The Supreme Court of the State of Montana first found that only the proponent organization had statutory standing to pursue this challenge, dismissing the second organization from the proceeding. The Court then held that the Attorney General lacked authority to revise the proponent’s ballot statement because he had not made the required written determination that the original was statutorily noncompliant. The Court concluded that the proponent’s original statement was clear, impartial, and met statutory requirements. Accordingly, the Court certified the proponent’s original statement to the Secretary of State and ordered its use in the ballot process. View "MFIJ v. Knudsen" on Justia Law

A Texas law, Senate Bill 17, prohibits individuals who are domiciled in certain “designated countries,” including China, from acquiring interests in Texas real estate. The law defines “domicile” as a person’s true, fixed, and permanent home to which the individual intends to return whenever absent. Peng Wang, a Chinese citizen who has lived in Texas for sixteen years on an F-1 student visa, challenged the law’s constitutionality. Wang attends school in Texas, intends to remain in the state after graduation, and does not plan to return to China.The United States District Court for the Southern District of Texas dismissed Wang’s suit for lack of jurisdiction, holding that he lacked standing. The district court found that Wang was not domiciled in China based on his long-term residence and stated intentions to remain in Texas. The court also concluded that Wang faced no substantial risk of future enforcement of the statute against him, citing repeated in-court statements by the Texas Attorney General disavowing any intent to enforce the law against Wang.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. It affirmed the district court’s dismissal, holding that Wang lacked standing for two independent reasons. First, Wang failed to allege he was domiciled in China, so the statute did not arguably proscribe his conduct. Second, he did not demonstrate a credible threat of enforcement of the law, given the Attorney General’s in-court assurances and lack of any enforcement action or procedures targeting Wang. The Fifth Circuit therefore affirmed the dismissal for lack of jurisdiction. View "Wang v. Paxton" on Justia Law

A non-profit publisher mailed its legal resource book, The Habeas Citebook, to prisoners at a Washington state correctional facility. In 2018, the state's Department of Corrections implemented two policies: one prohibited inmates from possessing case law documents unless approved, and another barred possession of legal materials containing information about other Washington state inmates. Relying on these policies, prison officials at Coyote Ridge Corrections Center rejected and delayed delivery of the book. Although the Department’s Publication Review Committee later found the book permissible, the publisher was not notified of this reversal, and delivery to prisoners was significantly delayed—sometimes by over a year.The Human Rights Defense Center sued the prison superintendent and mailroom sergeant in the United States District Court for the Eastern District of Washington, alleging violations of the First and Fourteenth Amendments and seeking damages and injunctive relief. The district court initially granted summary judgment for the defendants on all claims, holding that the claims were either moot, failed on the merits, or did not establish personal liability. On appeal, the United States Court of Appeals for the Ninth Circuit reversed and remanded, finding genuine disputes of material fact and instructing the district court to reconsider standing and liability issues. On remand, the district court again granted summary judgment for the defendants and denied requests for injunctive relief.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the defendants were entitled to qualified immunity against damages on the First and Fourteenth Amendment claims regarding the mail policies and lack of notice, as there was no clearly established precedent finding such policies unconstitutional. However, it reversed the district court’s denial of injunctive relief related to both the mail policy and notice procedures, finding that the appropriate legal standards had not been applied. The court also reversed the grant of qualified immunity on the delayed delivery claim, finding the right at issue clearly established, and remanded for further proceedings. View "HUMAN RIGHTS DEFENSE CENTER, INC. V. UTTECHT" on Justia Law

In this case, two licensed medical marijuana businesses in Arkansas challenged the validity of twenty-eight legislative amendments made by the Arkansas General Assembly to Amendment 98 of the Arkansas Constitution, which established a framework for medical marijuana use in the state. The businesses argued that these amendments were unconstitutional because they had not been submitted for voter approval, as they claimed was required, and that the amendments were not germane to the pertinent section as required by the constitutional language.The Pulaski County Circuit Court agreed with the plaintiffs, relying on the precedent set by Arkansas Game & Fish Commission v. Edgmon, and ruled that the General Assembly lacked authority to amend a voter-initiated constitutional amendment without submitting those amendments to a public vote. The court also found that the legislative amendments were not germane to section 23 of Amendment 98 and were therefore unconstitutional and void. The State of Arkansas appealed this ruling.The Supreme Court of Arkansas reviewed the case and reversed the circuit court’s decision. The court held that Article 5, section 1 of the Arkansas Constitution does grant the General Assembly authority to amend voter-initiated laws, including initiated constitutional amendments, by a two-thirds vote of both legislative chambers. The court explicitly overruled Arkansas Game & Fish Commission v. Edgmon, finding its reasoning inconsistent with the plain constitutional text. Additionally, the court determined that the word “section” in section 23(a) of Amendment 98 should be interpreted as “amendment,” so the germaneness requirement applies to the amendment as a whole. Consequently, the Supreme Court of Arkansas reversed and dismissed the lower court’s ruling. View "STATE OF ARKANSAS v. GOOD DAY FARM ARKANSAS, LLC" on Justia Law