Justia Constitutional Law Opinion Summaries

A fourteen-year-old boy, Tanner Smith, was vaccinated against COVID-19 at his school clinic without his or his mother Emily Happel's consent. The school clinic, operated in partnership with Old North State Medical Society (ONSMS), administered the vaccine despite lacking the required parental consent. Plaintiffs, Smith and Happel, sued the Guilford County Board of Education and ONSMS for battery and violations of their state constitutional rights.The Superior Court of Guilford County dismissed the case, agreeing with the defendants that the federal Public Readiness and Emergency Preparedness (PREP) Act preempted the plaintiffs' state law claims, granting them immunity. The Court of Appeals affirmed this decision, holding that the PREP Act's broad immunity shielded the defendants from liability for all of the plaintiffs' claims.The Supreme Court of North Carolina reviewed the case and held that the PREP Act's immunity only covers tort injuries and does not bar state constitutional claims. The court concluded that the PREP Act does not preempt claims brought under the state constitution, specifically those related to the right to control a child's upbringing and the right to bodily integrity. The court affirmed the dismissal of the battery claim but reversed the dismissal of the state constitutional claims and remanded the case for further proceedings. View "Happel v. Guilford Cnty. Bd. of Education" on Justia Law

Willie Dennis was convicted of three counts of cyberstalking under 18 U.S.C. § 2261A(2)(B) for sending repeated abusive electronic communications to his former partners at the law firm K&L Gates LLP after his ouster from the partnership. Dennis argued that the statute was unconstitutional as applied to his case because the trial evidence was insufficient to prove that his communications constituted "true threats" of physical harm, which would fall outside the First Amendment's protection of free speech. He also contended that erroneous jury instructions allowed the jury to find him guilty without proof of true threats and that he was unduly prejudiced by trial rulings and the trial judge's statements about his pro se status.The United States District Court for the Southern District of New York convicted Dennis on three counts of cyberstalking. Dennis appealed, arguing that the evidence was insufficient to prove true threats and that the jury instructions were erroneous. He also claimed that he was prejudiced by the exclusion of certain evidence and by the trial judge's comments.The United States Court of Appeals for the Second Circuit reviewed the case and found that the evidence was sufficient to permit a reasonable jury to find true threats in Dennis's communications to two of the victims, Bicks and Bostick, but insufficient as to the third victim, Cottle. The court held that Dennis's conviction on Count Two must be reversed due to insufficient evidence of true threats. The court also found that Dennis's failure to raise a true-threat challenge to the jury instructions in the district court limited appellate review to plain error, which was not evident. The court concluded that Dennis's other arguments were without merit.The Second Circuit affirmed Dennis's conviction on Counts One and Four but reversed the conviction on Count Two. View "United States v. Dennis" on Justia Law

Jeffrey Pitts was convicted in February 2021 for sexually battering his four-year-old daughter, AGC. The incident came to light when AGC told her grandmother and mother about inappropriate touching by Pitts. AGC later provided consistent details during a forensic interview and at trial. Pitts was indicted by a Rankin County grand jury and his trial began in February 2021. During the trial, a tender years hearing was held to determine the reliability of AGC's statements, and the trial judge found them reliable. AGC testified in court with a screen obstructing her view of Pitts, which was contested by the defense.The Rankin County Circuit Court allowed the use of the screen, and AGC's testimony was presented to the jury. The jury found Pitts guilty, and the Court of Appeals upheld the conviction. Pitts then petitioned for a writ of certiorari, which was granted by the Supreme Court of Mississippi.The Supreme Court of Mississippi reviewed whether the use of the screen violated Pitts's right to confrontation. The court held that the statutory provision allowing the screen did not require a specific finding of emotional trauma and that all essential elements of confrontation were met. The court emphasized that the statute was enacted under the authority granted by the Mississippi Constitution to protect crime victims' rights. The court found that Pitts's right to cross-examine AGC and observe her demeanor was preserved, and thus, the use of the screen did not violate his constitutional rights. The Supreme Court of Mississippi affirmed the lower court's decision. View "Pitts v. State of Mississippi" on Justia Law

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity. View "McClain v. Delgado" on Justia Law

A transgender student, Rebecca Roe, and the Sexuality and Gender Alliance (SAGA) at Boise High School challenged Idaho Senate Bill 1100 (S.B. 1100), which mandates that public school students use restrooms and changing facilities corresponding to their "biological sex." They argued that the law violates the Equal Protection Clause, Title IX, and the right to informational privacy. Roe and SAGA sought a preliminary injunction to prevent the law from being enforced.The United States District Court for the District of Idaho denied the preliminary injunction, concluding that SAGA was unlikely to succeed on the merits of its claims. The court found that the State's interest in protecting student privacy was an important governmental objective and that S.B. 1100 was substantially related to achieving that objective. The court also determined that SAGA did not show that the State had clear notice that Title IX prohibited segregated access to facilities based on transgender status. Additionally, the court found that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit agreed that SAGA did not establish a likelihood of success on the merits of its equal protection claim, as the State's interest in protecting bodily privacy was deemed important and the means chosen were substantially related to that objective. The court also held that SAGA failed to show that the State had clear notice that Title IX prohibited the exclusion of transgender students from facilities corresponding to their gender identity. Lastly, the court concluded that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy, as the statute did not necessarily disclose a student's transgender status. View "ROE V. CRITCHFIELD" on Justia Law

William Patterson was convicted of sexually abusing his girlfriend’s four-year-old niece. The incident occurred on September 15, 2019, when Patterson was watching the child and her twin sister. The children later reported the abuse to their mother, who contacted the police. The children were interviewed, and one disclosed the abuse. However, the district attorney initially decided not to charge Patterson. Three years later, the children provided more details, leading to charges against Patterson. He was convicted by a jury of second and third-degree sexual abuse of a minor.The District Court of Natrona County sentenced Patterson to 14-20 years in prison for second-degree sexual abuse of a minor, noting that the same act formed the basis for both convictions. Patterson appealed, arguing that the prosecutor improperly commented on his right to remain silent during the trial. The district court had denied Patterson’s motion for a mistrial, concluding that the prosecutor’s statement was not an improper comment on his right to remain silent and that any potential prejudice was mitigated by the court’s curative actions.The Supreme Court of Wyoming reviewed the case and determined that the prosecutor’s statement during opening arguments, which mentioned Patterson’s refusal to speak with law enforcement, was an impermissible comment on his constitutional right to remain silent. The court reaffirmed that such comments are prejudicial per se under the Wyoming Constitution and require reversal of the conviction. The court overruled previous case law that allowed for a distinction between a “comment” and a “reference” to silence, clarifying that any improper comment on the right to silence is prejudicial per se. Consequently, the Supreme Court of Wyoming reversed Patterson’s conviction and remanded the case for a new trial. View "Patterson v. State" on Justia Law

On December 9, 2021, the New York City Council passed a bill amending the New York City Charter to allow lawful permanent residents to vote in municipal elections. The bill became effective on January 9, 2022, as Local Law 11, after both outgoing Mayor Bill de Blasio and incoming Mayor Eric Adams neither signed nor vetoed it. Local Law 11 permitted certain noncitizens to vote in elections for New York City offices such as Mayor, Public Advocate, Comptroller, Borough President, and City Council Member.Plaintiffs, including current and former elected officials and New York City registered voters, filed a lawsuit against the New York City Council, Mayor Eric Adams, and the New York City Board of Elections. They sought to declare Local Law 11 null and void, arguing it violated the New York State Constitution, the New York State Election Law, and the Municipal Home Rule Law. The Supreme Court granted summary judgment in favor of the plaintiffs on all grounds, declaring Local Law 11 unconstitutional and enjoining its implementation. The Appellate Division modified the judgment regarding the Election Law claim but otherwise affirmed the decision, with one justice dissenting. The City Council and intervenors appealed to the Court of Appeals.The New York Court of Appeals held that Article II, Section 1 of the New York State Constitution restricts voting to citizens, thus invalidating Local Law 11. The court found that the Constitution's language and historical context clearly limit the right to vote to U.S. citizens. The court rejected arguments that Article IX of the Constitution, which grants home rule powers to local governments, overrides this restriction. Consequently, the Court of Appeals modified the Appellate Division's order and, as modified, affirmed the decision, maintaining the invalidation of Local Law 11. View "Fossella v Adams" on Justia Law

Several young Utah residents filed a lawsuit challenging statutory provisions and government actions related to fossil fuel development. They claimed that these provisions and actions were designed to maximize fossil fuel development in Utah, which they argued endangered their health and shortened their lifespans by exacerbating climate change. They sought a declaration from the district court that these provisions and actions violated their rights under the Utah Constitution.The government defendants moved to dismiss the case, arguing that the requested relief would not redress the alleged injuries. The Third District Court, Salt Lake County, agreed and dismissed the claims with prejudice, concluding that the plaintiffs lacked standing because their claims were not redressable.The Utah Supreme Court reviewed the case and affirmed the dismissal on the ground that the district court lacked subject-matter jurisdiction. The court found that the challenge to the energy policy provision was moot because the legislature had significantly amended the statute since the complaint was filed. The plaintiffs lacked standing to challenge the remaining statutory provisions because success on those challenges would not provide relief likely to redress their injuries. The court noted that the challenged provisions did not limit the government defendants' discretion in making decisions about fossil fuel development, and thus, striking these provisions would not necessarily lead to less fossil fuel development.The court also held that the challenges to the government defendants' conduct were not justiciable because they were not supported by a concrete set of facts. The plaintiffs had identified general categories of conduct without tying their claims to any specific government actions. The court instructed the district court to modify its ruling to reflect that the dismissal was without prejudice, allowing the plaintiffs the opportunity to refile their claims if they could address the jurisdictional deficiencies. View "Roussel v. State" on Justia Law

On November 30, 2021, a 15-year-old student, E.C., brought a gun to Oxford High School in Michigan and shot ten students and one teacher, resulting in four student deaths. E.C. pled guilty to first-degree murder and is serving a life sentence. His parents were also convicted of manslaughter. Victims of the shooting filed multiple lawsuits in state court against school and law enforcement officials, alleging various tort claims. The consolidated federal cases here involve claims that school officials violated the plaintiffs' constitutional rights to due process.The United States District Court for the Eastern District of Michigan largely dismissed the plaintiffs' claims, holding that the plaintiffs had not alleged facts sufficient to support an inference that the school officials' actions were so outrageous as to shock the conscience. However, the court allowed one claim to proceed, finding that a statement made by a school counselor, Shawn Hopkins, to E.C.'s parents about contacting Child Protective Services if they did not get counseling for E.C. within 48 hours, could potentially support a constitutional claim.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal of most claims. The appellate court agreed that the plaintiffs had not plausibly alleged that the school officials' actions were so egregious as to violate due process. The court found that the actions of returning E.C.'s backpack and failing to inform other officials about the risk did not constitute affirmative acts that increased the danger to the plaintiffs. The court also held that Hopkins' statement to E.C.'s parents did not demonstrate reckless or callous indifference. Consequently, the Sixth Circuit reversed the district court's decision to allow the claim based on Hopkins' statement to proceed and remanded the case with instructions to dismiss all claims. View "St. Juliana v. Oxford Community School District" on Justia Law

The case involves Plaintiff Tyler Luethje, who filed a § 1983 complaint against Defendants Travis Kyle and Scott Kelly, both employed by the Douglas County Sheriff’s Office. On February 11, 2022, the deputies responded to a 911 call about a broken window at Luethje’s residence. Upon arrival, they sent a police canine, Sig, into the house without announcing themselves. Sig bit Luethje, who was in bed, and continued to bite him while the deputies questioned him. Luethje was then handcuffed and taken to the hospital. He was not charged with any crime.The United States District Court for the District of Colorado reviewed the case and denied the deputies' motion to dismiss based on qualified immunity. The court held that the deputies violated Luethje’s Fourth Amendment rights regarding unlawful entry and search, unlawful arrest, and excessive force. The court found that the law clearly established these rights.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that the deputies were not entitled to qualified immunity. The court held that the deputies’ actions violated Luethje’s constitutional rights and that these rights were clearly established. The court found that the deputies lacked an objectively reasonable belief in an ongoing emergency to justify the warrantless entry, did not have probable cause for the arrest, and used excessive force by allowing the canine to continue biting Luethje after he was subdued. View "Luethje v. Kyle" on Justia Law