Justia Constitutional Law Opinion Summaries

Plaintiffs, who own or operate gasoline service stations in Puerto Rico, offered two different prices to consumers: a higher price for those using credit or debit cards and a lower price for those paying with cash. In 2013, Puerto Rico's legislature enacted Law 152-2013, amending Law 150-2008 by removing a provision that allowed merchants to offer cash discounts. Plaintiffs ceased offering the lower price due to the threat of fines and criminal prosecution. They sued the Commonwealth of Puerto Rico, arguing that Law 150 is preempted by federal law and is unconstitutionally vague.The United States District Court for the District of Puerto Rico rejected the plaintiffs' arguments and granted the Commonwealth's motion to dismiss for failure to state a claim. The court found that neither the Cash Discount Act (CDA) nor the Durbin Amendment preempted Law 150. The court also declined to address the constitutional vagueness argument, noting that the complaint did not allege that Law 150 is unconstitutionally vague.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the CDA and the Durbin Amendment do not preempt Law 150. The CDA regulates the conduct of credit card issuers, not merchants or states, and does not confer an absolute right to offer cash discounts. The Durbin Amendment regulates payment card networks, not states, and does not preempt state legislation restricting cash discounts. The court also found that the plaintiffs did not properly plead a vagueness claim in their complaint, rendering the claim unpreserved for appellate review. Consequently, the First Circuit affirmed the district court's dismissal of the case. View "Asociacion de Detallistas de Gasolina de PR Inc. v. Commonwealth of Puerto Rico" on Justia Law

Two Korean spas, collectively referred to as "the Spa," had a policy of granting entry only to biological women, excluding men and preoperative transgender women. The Washington State Human Rights Commission (HRC) initiated an enforcement action against the Spa, alleging that this policy violated the Washington Law Against Discrimination (WLAD), which prohibits discrimination in public facilities based on sexual orientation, including gender expression or identity. The Spa did not challenge the statute's definition or argue that their conduct did not fit within it but claimed that enforcing WLAD against their policy violated their First Amendment rights.The United States District Court for the Western District of Washington dismissed the Spa's complaint with prejudice under Rule 12(b)(6). The court held that the Spa's conduct discriminated based on gender identity, thus falling within WLAD's scope. It also found that the HRC's enforcement did not impermissibly burden the Spa's First Amendment rights to free speech, free exercise of religion, or free association.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The court held that the Spa's entrance policy discriminated based on gender identity, which is included in WLAD's definition of sexual orientation. The court applied intermediate scrutiny to the Spa's free speech claim, concluding that WLAD imposed an incidental restriction on speech no greater than necessary to eliminate discriminatory conduct. The court also applied rational basis review to the Spa's free exercise claim, finding that WLAD was neutral and generally applicable, and that eliminating discrimination based on sex and transgender status is a legitimate government purpose. Finally, the court rejected the Spa's free association claim, determining that the Spa was neither an intimate nor an expressive association. The court affirmed the district court's dismissal of the complaint. View "Olympus Spa v. Armstrong" on Justia Law

A thirty-four-year-old man engaged in a months-long sexual relationship with a sixteen-year-old girl, whom he met online. The relationship involved repeated sexual encounters, the exchange of nude photographs and explicit video calls, and the provision of marijuana and offers of other gifts. The girl reported the relationship to police, who struggled to identify the perpetrator due to his use of pseudonyms and anonymous messaging apps. State detectives, working as part of a federal task force, requested that federal officers use federal administrative subpoenas to obtain electronic records from service providers, which ultimately led to the identification and arrest of the defendant. A search of his home yielded physical evidence linking him to the victim.The Second District Court in Davis County denied the defendant’s motion to suppress the electronic records obtained via federal subpoenas, rejected his motions to arrest judgment and for a directed verdict on several charges, and admitted evidence of uncharged conduct from another county. The jury convicted the defendant on all counts, and the court partially granted a post-trial motion to arrest judgment, but left convictions for human trafficking of a child and sexual exploitation of a minor intact. The defendant appealed.The Supreme Court of the State of Utah held that Utah’s Electronic Information or Data Privacy Act (EIDPA) does not require suppression of evidence lawfully obtained by federal officers under federal law and then shared with state officers, and that the Utah Constitution does not mandate exclusion of such evidence. The court vacated the conviction for human trafficking of a child, holding that the statute requires proof that something of value was actually given or received in exchange for a sexual act, not merely offered. The court affirmed the convictions for sexual exploitation of a minor and distribution of a controlled substance, and found no reversible error in the admission of evidence related to uncharged conduct. View "State v. Andrus" on Justia Law

Samantha Hall-Haught was involved in a head-on collision, leading to the discovery of drug paraphernalia in her vehicle. At the hospital, a state trooper observed signs of drug use and obtained a warrant to test her blood, which revealed the presence of THC. Hall-Haught was charged with vehicular assault, and at her trial, a lab supervisor testified about the blood test results instead of the technician who conducted the test. Hall-Haught objected, arguing that her right to confront the witness against her was violated.The trial court admitted the lab results, and Hall-Haught was convicted. She appealed, and the Washington Court of Appeals affirmed the conviction, reasoning that the supervisor's independent review and testimony did not violate the confrontation clause. The court relied on the precedent set in State v. Lui, which allowed expert witnesses to testify based on data prepared by others.The Supreme Court of Washington reviewed the case and reversed the Court of Appeals' decision. The court held that the confrontation clause was violated because the lab report was testimonial, and the technician who performed the test was the actual witness against Hall-Haught. The court emphasized that the supervisor's testimony, which relied on the technician's report, was admitted for its truth, thus implicating the confrontation clause. The court remanded the case for further proceedings consistent with this opinion. View "State v. Hall-Haught" on Justia Law

Aaron Spencer was charged with second-degree murder and a firearm enhancement for the shooting death of Michael Fosler. Fosler had been charged with sexual offenses against Spencer’s daughter and was out on bond. On the night of the incident, Spencer found his daughter in Fosler’s truck and forced it off the road, resulting in an altercation where Spencer shot Fosler, who died at the scene. The case garnered significant media attention, leading the State to request a gag order to preserve the integrity of the jury pool and ensure a fair trial.The Lonoke County Circuit Court granted the State’s motion for a gag order without holding a hearing. The order restricted various parties, including attorneys, public officials, and Spencer’s family, from making public statements about the case. Spencer opposed the gag order, arguing it violated his constitutional rights to a fair and public trial and free speech. He filed a petition for writ of certiorari with the Arkansas Supreme Court, seeking to vacate the gag order.The Arkansas Supreme Court reviewed the case and found that the gag order was overly broad, vague, and lacked a factual basis. The court held that the order constituted a plain, manifest, clear, and gross abuse of discretion. The court emphasized that gag orders should be a last resort and must be narrowly tailored based on specific factual findings. The court granted Spencer’s petition for writ of certiorari, issued the writ, and vacated the circuit court’s gag order. The court did not preclude the possibility of a subsequent, more narrowly tailored gag order after an evidentiary hearing. View "SPENCER v. STATE OF ARKANSAS" on Justia Law

A juvenile court in a dependency proceeding granted a restraining order requested by a mother, K.B., against her 17-year-old dependent child, D.B. The Santa Clara County Department of Family and Children’s Services had received multiple referrals over the years concerning D.B.'s well-being due to alleged abuse and neglect by the mother. D.B. had a history of physical altercations with her mother and was placed in protective custody after her mother refused to allow her back home following an arrest for assault.The Santa Clara County Superior Court assumed jurisdiction over D.B. and declared her a dependent child. The court adopted a case plan that included supervised visitation with the mother. However, D.B. struggled in her placement and exhibited behavioral issues. The mother later requested termination of reunification services, which the court granted with D.B.'s agreement.Subsequently, the mother filed for a restraining order against D.B., citing threats and harassment. The court issued a temporary restraining order and later a one-year restraining order after a hearing. The court found that section 213.5 of the Welfare and Institutions Code authorized it to issue restraining orders against a dependent child and determined that it was in D.B.'s best interest to do so.The California Court of Appeal, Sixth Appellate District, reviewed the case and affirmed the juvenile court's decision. The appellate court held that section 213.5, subdivision (a), grants the juvenile dependency court authority to issue restraining orders against a dependent child, provided the child's best interest is considered. The court found substantial evidence supporting the restraining order and concluded that it did not violate D.B.'s constitutional rights, as reunification services had already been terminated with D.B.'s consent. View "In re D.B." on Justia Law

The Heidi Group, Inc. alleged that several Texas officials violated the Fourth Amendment and Texas law by conspiring with a private citizen to steal documents from a cloud-based file storage system. The officials moved for judgment on the pleadings and asserted various immunity defenses. The district court denied the motions in relevant part.The United States District Court for the Western District of Texas reviewed the case and denied the defendants' motions for judgment on the pleadings. The defendants then appealed to the United States Court of Appeals for the Fifth Circuit. The appeal involved four distinct groups of orders: the denial of qualified immunity for individual capacity defendants on the Fourth Amendment claim, the denial of judgment on the pleadings for the official capacity Fourth Amendment claim, the denial of state law immunity for the individual capacity defendants on the unlawful-access claim, and the denial of judgment on the pleadings for the state law religious-discrimination claim.The United States Court of Appeals for the Fifth Circuit dismissed the appeal regarding the religious-discrimination claim and declined to exercise pendent appellate jurisdiction over the official capacity Fourth Amendment claim. The court held that only Gaylon Dacus engaged in state action and was not entitled to qualified immunity for the Fourth Amendment claim. The court found that Dacus used a former employee to access Heidi's documents without proper authorization, violating clearly established Fourth Amendment rights. The court also affirmed the denial of state law immunity for the individual capacity defendants on the unlawful-access claim, as their actions were not in good faith. The court reversed the denial of judgment on the pleadings for Johnson and Kaufman on the individual capacity Fourth Amendment claim and remanded for further proceedings. View "Heidi Group v. Texas Health and Human Services Commission" on Justia Law

Andrew Miller was convicted by a jury in the Circuit Court of Raleigh County, West Virginia, of wanton endangerment, malicious wounding, and felony possession of a firearm by a prohibited person. The jury also found him to be a recidivist felon, leading to a life sentence with the possibility of parole. The case arose from an incident where Miller allegedly shot Anthony Goard during a dispute over drugs at Niesha Dotson’s apartment. Miller claimed that another individual, J.T., was the actual shooter.At trial, the State presented testimony from Dotson and Goard, both of whom had used drugs at the time of the incident. Dotson testified about a disagreement over drugs between her and Miller, while Goard identified Miller as the shooter but initially told hospital staff he did not know who shot him. The State also introduced a 9 millimeter firearm with Miller’s DNA, although Goard identified a different firearm as the one used in the shooting. Miller testified in his defense, asserting that J.T. shot Goard and that he left the scene to avoid being implicated due to his parole status.The Supreme Court of Appeals of West Virginia reviewed the case, focusing on Miller’s claim that his constitutional right to silence was violated. The court found that the circuit court erred by allowing the State to cross-examine Miller about his post-arrest silence, which was not harmless beyond a reasonable doubt. The court noted that this improper questioning directly prejudiced Miller’s defense, as it suggested to the jury that Miller fabricated his story about J.T. being the shooter.The Supreme Court of Appeals of West Virginia vacated Miller’s convictions and remanded the case for a new trial, concluding that the constitutional error was not harmless and affected the jury’s verdict. View "State of West Virginia v. Miller" on Justia Law

Samuel Joseph was convicted of drug and firearm offenses. He appealed the district court's denial of his motion to suppress evidence seized during two encounters with law enforcement. The first encounter occurred in Charleston, West Virginia, where an officer, after receiving a tip about possible drug activity, observed Joseph's suspicious behavior and items consistent with drug distribution in a motel room. Joseph was apprehended after fleeing from officers, and a search of his duffel bag, which he abandoned during the chase, revealed drugs and firearms.The United States District Court for the Southern District of West Virginia denied Joseph's motion to suppress the evidence obtained during the encounters. Joseph argued that the officers lacked reasonable suspicion to stop him and that the search and seizure violated his Fourth Amendment rights. The district court found that the officers had reasonable suspicion based on their observations and Joseph's behavior, and that the subsequent search and seizure were lawful.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that the officers had reasonable suspicion to stop Joseph based on their observations and his unprovoked flight. The court also found that the officers' actions following the stop, including the use of a drug-detection dog and obtaining a search warrant for the duffel bag, were permissible and did not violate the Fourth Amendment. Additionally, the court rejected Joseph's arguments regarding the lack of bodycam footage and the reliability of the initial tip, as well as his claim that the traffic stop in Parkersburg was impermissibly prolonged. The court concluded that the district court's factual findings were not clearly erroneous and upheld the denial of the motion to suppress. View "United States v. Joseph" on Justia Law

Barry Jackson was convicted of illegally possessing two firearms as a domestic violence misdemeanant. After his conviction, but before pleading guilty, he was found with three additional firearms, one of which had a large-capacity magazine. Jackson challenged the constitutionality of 18 U.S.C. § 922(g)(9) and the reasonableness of his sentence.The United States District Court for the Western District of Oklahoma denied Jackson's motion to declare § 922(g)(9) unconstitutional. Jackson then pleaded guilty without a plea agreement. At sentencing, the court determined that Jackson's possession of firearms on two separate occasions constituted relevant conduct, leading to a higher advisory Sentencing Guidelines range. Jackson was sentenced to 72 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that § 922(g)(9) is constitutional as applied to Jackson, consistent with the principles established in United States v. Rahimi and United States v. Rogers. The court found that Jackson's prior domestic violence convictions demonstrated a propensity for violence, justifying his disarmament under § 922(g)(9). The court also upheld the district court's determination that Jackson's possession of additional firearms was relevant conduct, supporting the sentence imposed.The Tenth Circuit affirmed the district court's judgment of conviction and sentence, concluding that the sentence was both procedurally and substantively reasonable. View "United States v. Jackson" on Justia Law