Justia Constitutional Law Opinion Summaries

The case involves a constitutional challenge to a Wisconsin law that prohibits the Department of Justice (DOJ) from settling most civil cases without the approval of the Joint Finance Committee (JFC). The Attorney General, DOJ, and the Governor argue that this law is unconstitutional as applied to two specific categories of cases: civil enforcement actions and cases brought by DOJ at the request of executive branch agencies. They contend that litigation in these categories constitutes core executive power, and thus, the Legislature cannot interfere.The Dane County Circuit Court agreed with the plaintiffs and granted summary judgment in their favor. However, the Court of Appeals reversed this decision, concluding that the power to settle these types of cases is a shared power between the executive and legislative branches, and legislative approval does not unduly burden executive powers.The Wisconsin Supreme Court reviewed the case and held that settling these two categories of cases falls within the core powers of the executive branch. The court found that the Legislature has not identified any constitutional role for itself in these categories of cases. Therefore, the statutory requirement for JFC approval prior to settling these cases violates the Wisconsin Constitution’s separation of powers. The court reversed the decision of the Court of Appeals and affirmed the circuit court’s decision granting summary judgment to the DOJ. View "Kaul v. Wisconsin State Legislature" on Justia Law

Ahmed Abdalla Allam was charged with possession of a firearm within 1,000 feet of school grounds, violating 18 U.S.C. § 922(q)(2)(A). Allam challenged the constitutionality of the statute under the Second Amendment, both facially and as applied to him. The district court rejected his challenges, and Allam subsequently pled guilty. He then appealed the denial of his as-applied challenge.The United States District Court for the Eastern District of Texas upheld the statute as constitutional, both facially and as applied to Allam, and denied his motion to dismiss. The court applied the framework from New York State Rifle & Pistol Assn., Inc. v. Bruen, finding no historical precursor to § 922(q)(2)(A) but concluded that late 19th-century prohibitions on possessing firearms in schools and near polling places were relevantly similar historical analogues. Following the denial of his motion, Allam pled guilty and was sentenced to 60 months in prison and three years of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court applied the Bruen framework, determining that the Second Amendment's plain text covered Allam's conduct. However, the court found that § 922(q)(2)(A) was consistent with the Nation's historical tradition of firearm regulation, particularly when considering historical laws like the Statute of Northampton and going-armed laws, which restricted carrying firearms in a manner that posed a threat to public safety. The court also considered historical firearm regulations in educational settings and buffer zones around polling places, which supported the constitutionality of disarming a visibly threatening individual near a school.The Fifth Circuit affirmed the district court's rejection of Allam's as-applied challenge and upheld his guilty-plea conviction. View "USA v. Allam" on Justia Law

Curtis Walker, who was 17 years old when he committed murder, was sentenced to life in prison with a parole eligibility date set for 2071, effectively making it a life-without-parole sentence. After serving nearly 30 years, Walker sought postconviction relief, arguing that his sentence violated the Eighth Amendment based on a series of Supreme Court decisions regarding juvenile offenders sentenced to life without parole. Walker's request for a "meaningful opportunity" to demonstrate his rehabilitation was denied by the Wisconsin state courts, prompting him to file a federal habeas corpus petition.The Wisconsin Court of Appeals denied Walker's postconviction motion, holding that his sentence did not violate the Eighth Amendment because the sentencing judge had considered his youth and its attendant circumstances. The Wisconsin Supreme Court denied review. Walker then filed a federal habeas petition, which the district court dismissed as untimely and without merit, concluding that the Wisconsin Court of Appeals did not unreasonably apply federal law.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's denial of habeas relief. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent, particularly in light of the decisions in Miller v. Alabama, Montgomery v. Louisiana, and Jones v. Mississippi. The Seventh Circuit concluded that the state court's decision was not contrary to or an unreasonable application of clearly established federal law, as the Supreme Court's precedents did not clearly establish a categorical prohibition against sentencing corrigible juvenile offenders to life without parole. View "Walker v Cromwell" on Justia Law

Michael Williams was convicted by a Wisconsin jury of reckless homicide and possession of a firearm as a convicted felon. He appealed his convictions to the Wisconsin Court of Appeals, arguing that a jury instruction unconstitutionally lowered the government's burden of proof and that the prosecutor's closing arguments improperly shifted the burden of proof to him. The Wisconsin Court of Appeals affirmed the convictions, and the Wisconsin Supreme Court denied his petition for review.Williams then filed a petition for habeas corpus in the United States District Court for the Eastern District of Wisconsin. The district court held that the state appellate court reasonably applied Supreme Court precedent in concluding that it was not reasonably likely the jury applied the instruction in an unconstitutional manner. The court also held that Williams had not demonstrated that the prosecutor's remarks violated clearly established Supreme Court precedent.On appeal to the United States Court of Appeals for the Seventh Circuit, Williams raised the same two arguments. The Seventh Circuit affirmed the district court's decision. The court held that the Wisconsin Court of Appeals did not unreasonably apply Supreme Court precedent regarding the jury instruction on reasonable doubt. The court also found that the prosecutor's comments during closing arguments did not shift the burden of proof to the defense in a manner that violated due process, especially considering the trial court's curative instructions. The Seventh Circuit concluded that Williams had not shown that the state court's rulings were so lacking in justification as to constitute an unreasonable application of clearly established federal law. View "Williams v Meisner" on Justia Law

Defendants Jerrold Chavarria and Jerry Romero were accused of kidnapping and murdering a woman in Eddy County, New Mexico. They were charged with the federal crime of kidnapping resulting in death under 18 U.S.C. § 1201(a). The indictment claimed that the defendants used a motor vehicle, a Jeep, as an instrumentality of interstate commerce in committing the crime. However, the indictment did not provide details on how the kidnapping affected interstate commerce.The United States District Court for the District of New Mexico dismissed the superseding indictment, ruling that it lacked an adequate nexus to interstate commerce. The court found that the use of a motor vehicle alone, without more, was insufficient to establish federal jurisdiction under the Commerce Clause.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that not all motor vehicles are per se instrumentalities of interstate commerce. It emphasized that for an object to be considered an instrumentality of interstate commerce, it must serve the end of commerce. The court found that the government’s indictment was insufficient because it did not allege how the use of the motor vehicle in this case affected interstate commerce. The Tenth Circuit affirmed the district court’s dismissal of the superseding indictment, concluding that the federal kidnapping statute did not apply in this instance due to the lack of a sufficient connection to interstate commerce. View "United States v. Chavarria" on Justia Law

Mark Hamilton, the former Chief of the Fire Department of Wilmer, Texas, was terminated after testifying at a probation revocation hearing for a former employee, Craig Lawrence, who had hidden recording devices in fire station bathrooms. Hamilton testified in uniform, drove a city car to the hearing, and did not take leave from work. He claimed his termination was in retaliation for his protected First Amendment activity.The United States District Court for the Northern District of Texas dismissed Hamilton's complaint under Federal Rule of Civil Procedure 12(b)(6). The court found that Hamilton did not state a claim for First Amendment retaliation, as his speech was not protected under the First Amendment. Hamilton appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that Hamilton did not speak as a citizen on a matter of public concern, as his testimony was given pursuant to his official duties as Fire Chief. The court also found that even if Hamilton's speech were protected, the City of Wilmer had adequate justification for treating him differently from any other member of the public due to his use of city resources and uniform during his testimony. The court affirmed the district court's dismissal of Hamilton's claims and denied his request for leave to amend his complaint, finding that any amendment would be futile. View "Hamilton v. City of Wilmer, Texas" on Justia Law

On December 21, 2022, Oklahoma City Police officers received a tip that Karen Gonzalez, who had an outstanding arrest warrant, was at a Days Inn. Officers surveilled the area and followed a car they believed she entered to a gas station. They confirmed her identity and arrested her. Jonas Tyler, who was near the car, was detained, handcuffed, and placed in a police car. Despite his compliance and lack of suspicion, officers detained him further while waiting for a K-9 unit, which eventually led to the discovery of a firearm and drugs in his car.The United States District Court for the Western District of Oklahoma denied Mr. Tyler's motion to suppress the evidence found in his car, ruling that his continued detention was reasonable. Mr. Tyler then entered a conditional guilty plea to possession of a firearm by a previously convicted felon, reserving his right to appeal the suppression ruling. He was sentenced to 84 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case and found that Mr. Tyler's continued detention after the arrest of Ms. Gonzalez was unreasonable and violated his Fourth Amendment rights. The court held that the government did not have a sufficient justification for detaining Mr. Tyler beyond the initial arrest of Ms. Gonzalez, as there was no reasonable suspicion of wrongdoing or dangerousness on his part. Consequently, the court vacated Mr. Tyler's conviction and sentence and remanded the case for further proceedings consistent with their opinion. View "United States v. Tyler" on Justia Law

The petitioner, a 67-year-old native and citizen of Guatemala, entered the United States in 1985 without admission or parole. In removal proceedings, he conceded removability but sought several forms of relief, including asylum, withholding of removal, relief under the Convention Against Torture (CAT), cancellation of removal under 8 U.S.C. § 1229b(b)(1), and relief pursuant to the Nicaraguan Adjustment and Central American Relief Act (NACARA). An immigration judge (IJ) denied all forms of relief, and the Board of Immigration Appeals (BIA) upheld the removal order in 2018. The petitioner then filed a motion to reopen proceedings, which the BIA denied in 2019.The BIA upheld the IJ's decision, concluding that the petitioner had withdrawn his asylum application, was ineligible for cancellation of removal due to a conviction for a crime involving moral turpitude, and did not merit NACARA relief. The BIA also found no sufficient indicia of incompetency to mandate remand for a competency evaluation. The petitioner then sought review of both the 2018 and 2019 BIA decisions.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court clarified its jurisdictional rules in light of recent Supreme Court decisions, concluding that it has jurisdiction over constitutional claims and questions of law, including fact-intensive mixed questions of law. The court lacks jurisdiction over purely factual findings and discretionary determinations.The Ninth Circuit held that the BIA abused its discretion by not remanding the case to the IJ for a competency determination, given the extensive evidence of the petitioner's potential incompetence. The court also found that the BIA erred in its assessment of the petitioner's fear of harm due to his mental illness, concluding that the petitioner established a reasonable likelihood of future harm if institutionalized in Guatemala. The court denied the petitioner's other claims and dismissed parts of the petition for lack of jurisdiction. The case was remanded for further proceedings consistent with the court's opinion. View "LEMUS-ESCOBAR V. BONDI" on Justia Law

This case involves a property on Maui in which Wade Brady owned a 50% interest. Beverly and James Spence obtained a default judgment against Wade and Katherine Brady in 2010, which they recorded as a lien against Wade Brady’s interest in the property. After the Bradys failed to satisfy their debt, the Spences obtained a writ of execution to sell the property. The sale was advertised by publication, and Wade Brady’s interest was sold to the Spences. At the time of the sale, Peter J. Winn and Westminster Realty, Inc. (the Winn parties) also had a recorded junior judgment lien on the property but did not receive personal notice of the sale.The Circuit Court of the Second Circuit confirmed the sale, stating it was free of all junior liens. The Winn parties later sought to execute their judgment on the property, but the circuit court denied their motion, stating they were not entitled to personal notice. The Intermediate Court of Appeals (ICA) vacated the circuit court’s order, holding that the Winn parties had a constitutionally protected property interest and were entitled to personal notice of the sale.The Supreme Court of the State of Hawai‘i reviewed the case. The court held that a recorded judgment lien under HRS § 636-3 creates a constitutionally protected property interest. The court further held that due process requires personal notice to junior judgment lienholders when the executing party knows or should know of their interest. However, the court decided that this ruling would apply prospectively only, due to the potential impact on prior and pending execution sales and the substantial prejudice to the intervenors. The court reversed the ICA’s decision to reinstate the Winn parties’ lien on the property. View "Winn v. Brady" on Justia Law

After a welfare check was requested by his fiancée, Joseph Maser was involved in a standoff with police at his suburban Iowa home. Maser had threatened suicide, fired a gun inside his house, and was reportedly intoxicated with access to firearms. Officers attempted to negotiate with Maser for nearly an hour, during which Maser became increasingly agitated and made threats. Maser exited his garage holding a rifle, ignored commands to drop the weapon, and raised the rifle outward from his body. Officer Joshua Van Brocklin, perceiving a threat, shot Maser twice in the chest. Maser survived and subsequently brought a claim under 42 U.S.C. § 1983, alleging that Officer Van Brocklin used excessive force in violation of the Fourth Amendment.Initially, Maser filed suit in state court against Officer Van Brocklin, the City of Coralville, and other officers, asserting both state and federal claims. The case was removed to the United States District Court for the Southern District of Iowa. Following a decision by the Iowa Supreme Court in Burnett v. Smith, which foreclosed excessive force claims under the Iowa Constitution, the district court granted summary judgment on those claims. The district court also granted summary judgment for Officer Van Brocklin on the federal excessive force claim, finding no constitutional violation and awarding qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of the circumstances, Officer Van Brocklin’s use of deadly force was objectively reasonable because Maser’s actions—raising a rifle outward after repeated noncompliance and threats—created an imminent threat of serious harm. The court found no genuine dispute of material fact and affirmed the district court’s grant of summary judgment, holding that Maser’s Fourth Amendment rights were not violated. View "Maser v. City of Coralville, IA" on Justia Law