Justia Constitutional Law Opinion Summaries

The defendant, Tyshon Thompson, was convicted of aggravated unlawful use of a weapon (AUUW) under Illinois law for carrying an uncased, loaded, and immediately accessible handgun in his vehicle without a concealed carry license (CCL). The incident occurred after an altercation at a gas station led to an exchange of gunfire, and police found the handgun in Thompson's glove compartment. Although Thompson had a valid Firearm Owner’s Identification (FOID) card, he had not applied for a CCL.The Cook County Circuit Court convicted Thompson, and he was sentenced to 30 months in prison. On appeal, Thompson argued that the AUUW statute violated the Second Amendment by enforcing a double licensing process requiring both a FOID card and a CCL. He contended that the appellate court erred by not applying the text-and-history test from New York State Rifle & Pistol Ass’n v. Bruen, which assesses the constitutionality of firearm regulations.The Illinois Supreme Court reviewed the case and held that Illinois’s "shall-issue" licensing regime, which includes the requirements for obtaining a FOID card and a CCL, does not violate the Second Amendment. The court noted that the Bruen decision explicitly endorsed "shall-issue" regimes, which do not require applicants to show a special need for self-defense and are based on objective criteria. The court affirmed the judgments of the Cook County Circuit Court and the appellate court, concluding that the AUUW statute’s requirements are not facially unconstitutional. View "People v. Thompson" on Justia Law

The case involves a challenge to Michigan's newborn screening program, which collects blood samples from newborns to test for diseases. The plaintiffs, consisting of parents and their children, argue that the program's retention and use of these blood samples without consent violate their Fourth and Fourteenth Amendment rights. The plaintiffs claim that the state's actions constitute a coercive, non-consensual taking and keeping of baby blood for the state's profit.Initially, the United States District Court for the Eastern District of Michigan dismissed the plaintiffs' complaint. However, a prior panel of the United States Court of Appeals for the Sixth Circuit reversed and remanded several claims, allowing the plaintiffs to pursue their Fourth and Fourteenth Amendment claims for injunctive and declaratory relief. On remand, the district court granted judgment in favor of the plaintiffs on nearly all their remaining claims and ordered the defendants to return or destroy the stored blood spots and data.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's judgment. The appellate court held that the defendants' actions of storing and using the blood spots and data did not violate the plaintiffs' Fourteenth Amendment substantive-due-process rights, as these actions did not constitute medical care or intrude on the parents' right to direct their children's medical care. Additionally, the court found that the plaintiffs failed to prove a possessory interest in the blood spots and data, which is necessary to establish a Fourth Amendment seizure claim. Consequently, the appellate court vacated the injunction requiring the defendants to destroy the stored data. View "Kanuszewski v. Michigan Dep't of Health & Human Services" on Justia Law

The case involves a dispute between the Wisconsin State Legislature and the Wisconsin Department of Public Instruction (DPI) regarding the governor's partial veto power and the allocation of funds for literacy programs. The legislature argued that the governor exceeded his constitutional authority by partially vetoing a bill that was not an appropriation bill. DPI and the governor contended that the legislature's Joint Committee on Finance (JCF) improperly withheld funds appropriated for DPI's literacy programs.The Dane County Circuit Court granted summary judgment in part for each party. The court concluded that the governor did not exceed his constitutional boundaries in partially vetoing the bill and that JCF did not improperly withhold funds from DPI. The court reasoned that the bill in question was an appropriation bill and that the governor's partial veto was valid. However, the court also held that DPI was not entitled to the funds appropriated to JCF.The Wisconsin Supreme Court reviewed the case and held that the governor breached his constitutional boundaries because the bill he partially vetoed was not an appropriation bill. The court reaffirmed the "four corners rule," which requires that an appropriation bill must set aside public funds for a public purpose within its text. The court concluded that the bill in question did not meet this requirement and, therefore, was not subject to the governor's partial veto authority. The court also held that JCF did not improperly withhold funds from DPI, as the funds were lawfully appropriated to JCF. Consequently, the court affirmed in part and reversed in part the circuit court's summary judgment order. View "Wisconsin State Legislature v. Wisconsin Department of Public Instruction" on Justia Law

Fred Hodara filed a lawsuit against the Oklahoma Department of Corrections (DOC) for alleged violations of the Open Records Act, seeking access to records related to the drugs used in executions. Initially, the DOC claimed it had no responsive records, but later provided some documents, albeit heavily redacted. Hodara sought declaratory and injunctive relief, arguing that the DOC's refusal to provide the requested material was unlawful. The DOC moved to dismiss the case, citing a statutory exemption under Title 22, Section 1015(B), which was later amended in 2024 to broaden the scope of confidentiality.The district court denied both parties' motions for summary judgment due to unresolved factual disputes. However, after the statutory amendment, the DOC filed a second motion to dismiss, which the court granted, concluding that the amended statute precluded Hodara's Open Records Act claim. Hodara appealed the dismissal, challenging the retroactive application and constitutionality of the amended statute.The Supreme Court of the State of Oklahoma reviewed the case de novo, focusing on the October 4, 2024, order. The court found that the 2024 amendment to Section 1015(B) did not create a new confidentiality privilege but clarified the existing one. The court held that the amendment could be applied retroactively and did not violate the Oklahoma Constitution. The court affirmed the district court's decision, concluding that the DOC's refusal to provide the requested records was lawful under the amended statute. View "HODARA v. OKLAHOMA DEPARTMENT OF CORRECTIONS" on Justia Law

Owners of timeshare estates in a resort sued the County of Riverside, challenging the legality of an annual fee charged for separate property tax assessments. The owners argued that the fee exceeded the reasonable cost of providing the assessment, constituting a tax that required voter approval, which had not been obtained. The trial court rejected the owners' argument and ruled in favor of the County.The Superior Court of Riverside County entered judgment for the County, finding that the fee did not exceed the reasonable cost of providing the separate assessment. The court considered various costs, including those related to a new computer system and assessment appeals, even though these costs were not included in the original budget used to set the fee.The Court of Appeal, Fourth Appellate District, Division One, State of California, reversed the trial court's decision. The appellate court held that the County did not meet its burden to prove that the $23 fee was not a tax requiring voter approval under Article XIII C of the California Constitution. The court found that the County's methodology for setting the fee was flawed, as it included costs unrelated to the specific service of providing separate timeshare assessments and did not accurately reflect the actual cost of the service. The court also ruled that the trial court erred in considering costs incurred after the fiscal year used to set the fee.The appellate court remanded the case for further proceedings to determine the appropriate refund amount and to decide on the declaratory, injunctive, and/or writ relief sought by the owners. The County must prove the reasonable and necessary costs of providing the separate assessment service, excluding costs for valuing the timeshare project as a whole. View "Scott v. County of Riverside" on Justia Law

The case involves Robert Keith Ray, who was charged with multiple offenses related to the murders of Javad Marshall-Fields and Vivian Wolfe in a drive-by shooting. Marshall-Fields was set to testify against Ray in a separate shooting incident at Lowry Park, where Ray and his associate, Sir Mario Owens, were involved. Ray was convicted of nearly all charges related to the Dayton Street shooting and was initially sentenced to death. However, after Colorado abolished the death penalty, the Governor commuted Ray's sentence to life without the possibility of parole (LWOP).The Arapahoe County District Court entered the judgment of conviction and sentenced Ray to death, which was later commuted to LWOP. Ray appealed his convictions and sentence directly to the Colorado Supreme Court, challenging several evidentiary rulings, prosecutorial misconduct, and the constitutionality of his LWOP sentence. He also alleged juror misconduct and sought to subpoena jurors to investigate these claims.The Colorado Supreme Court reviewed Ray's appeal and found that while the district court made some errors in admitting certain evidence and that some of the prosecution's comments were improper, none of these errors warranted reversal. The court concluded that the district court properly denied inquiry into alleged juror misconduct under CRE 606(b) and upheld the constitutionality of Ray's LWOP sentence. The court affirmed the judgment of conviction and the commuted sentence. View "People v. Ray" on Justia Law

Isaiah Ismael Rios was charged with multiple counts, including first-degree murder, related to a series of crimes over eighteen days. His trial, initially set for July 2020, was delayed due to the COVID-19 pandemic. The trial court, following public health guidelines, excluded all spectators from the physical courtroom, providing virtual access instead. Rios objected, arguing this violated his Sixth Amendment right to a public trial. The trial proceeded with these restrictions, and Rios was convicted.The Colorado Court of Appeals reviewed the case and determined that the exclusion of the public from the courtroom constituted a nontrivial partial closure. However, it concluded that Rios's right to a public trial was not violated because the closure was justified under the Supreme Court's standard in Waller v. Georgia. The court found that the closure was warranted due to the public health crisis, was no broader than necessary, and that reasonable alternatives were considered.The Supreme Court of Colorado reviewed the case and held that virtual access alone does not satisfy the Sixth Amendment right to a public trial. The court determined that a courtroom closure occurred but concluded that the closure did not violate Rios's right to a public trial. The court found that the closure was justified under the Waller factors due to the public health concerns related to COVID-19. Therefore, the Supreme Court of Colorado affirmed the judgment of the court of appeals. View "Rios v. People" on Justia Law

Cody Byron Teerlink was convicted of making a false statement during the acquisition of a firearm. He had previously pleaded guilty to a third-degree felony for driving under the influence in Utah and completed his probation successfully. Despite being eligible for a reduction of his felony to a misdemeanor under Utah law, he did not apply for it. In 2021, Teerlink attempted to purchase firearms on three occasions, falsely stating on ATF Form 4473 that he had not been convicted of a felony. He was able to purchase a rifle once due to a system glitch but was denied on the other two attempts.The United States District Court for the District of Utah directed the parties to agree on jury instructions. The parties jointly submitted an instruction defining "proof beyond a reasonable doubt," which included language criticized by the Tenth Circuit and the Supreme Court. The jury convicted Teerlink on one count of making a false statement during the acquisition of a firearm and acquitted him on the other counts. He was sentenced to eight months' imprisonment.The United States Court of Appeals for the Tenth Circuit reviewed the case. Teerlink argued that the jury instruction lowered the government's burden of proof, violating his Fifth Amendment rights. However, the court held that Teerlink invited any alleged error by jointly submitting the instruction and failing to object at trial. The court emphasized that parties cannot propose jury instructions and later challenge them on appeal. The court also rejected Teerlink's argument that a footnote in the jury instructions preserved his right to plain-error review, stating that such a footnote cannot immunize a party from the invited-error doctrine. The Tenth Circuit affirmed the district court's decision. View "United States v. Teerlink" on Justia Law

The case involves a group of in-state and out-of-state precious metal traders and their representatives (the "Bullion Traders") challenging Minnesota Statutes Chapter 80G, which regulates bullion transactions. The Bullion Traders argued that the statute violated the dormant Commerce Clause due to its extraterritorial reach, as defined by the term "Minnesota transaction."The United States District Court for the District of Minnesota initially found that Chapter 80G violated the dormant Commerce Clause. The case was then remanded by the United States Court of Appeals for the Eighth Circuit for a severability analysis. The district court concluded that striking portions of the "Minnesota transaction" definition cured the extraterritoriality concern and complied with Minnesota severability law.The Bullion Traders appealed, arguing that the severed statute still applied extraterritorially and that the district court erred in applying Minnesota severability law. The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court found that the severed definition of "Minnesota transaction" no longer regulated wholly out-of-state commerce and that the statute, as severed, was complete and capable of being executed in accordance with legislative intent.The Eighth Circuit held that the district court correctly severed the extraterritorial provisions from Chapter 80G, and the remaining statute did not violate the dormant Commerce Clause. The court also agreed that the severed statute complied with Minnesota severability law, as the valid provisions were not essentially and inseparably connected with the void provisions, and the remaining statute was complete and executable. The judgment of the district court was affirmed. View "Styczinski v. Arnold" on Justia Law

Principal Springer was involved in drug dealing within 1,000 feet of a school and had multiple firearms in his apartment. Following a lengthy investigation, a search of his apartment revealed drugs, drug paraphernalia, and firearms. He was charged with conspiring to deal drugs within a school zone and unlawfully possessing firearms due to his drug use and a prior misdemeanor domestic-violence conviction. Springer moved to dismiss the firearm count, arguing that the restrictions violated the Second Amendment. The district court disagreed, and Springer pleaded guilty while reserving the right to appeal his Second Amendment challenges. He was sentenced to 110 months in prison.The United States District Court for the Northern District of Iowa denied Springer’s motion to dismiss the firearm count. Springer then pleaded guilty but reserved his right to appeal the Second Amendment issues. He received concurrent sentences of 110 months in prison.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the statute prohibiting drug users from possessing firearms, 18 U.S.C. § 922(g)(3), is not facially unconstitutional, referencing its previous decision in United States v. Veasley. The court also rejected Springer’s as-applied challenge to the statute prohibiting domestic abusers from possessing firearms, 18 U.S.C. § 922(g)(9), noting that a conviction under any one of the § 922(g) categories is sufficient. Additionally, the court found no abuse of discretion in the district court’s decision not to grant a downward variance in sentencing. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Springer" on Justia Law