Justia Constitutional Law Opinion Summaries

Freddie Knipp, Jr. was convicted of two counts of distributing methamphetamine and one count of knowingly selling a firearm to a felon. The convictions stemmed from controlled drug buys and a firearm purchase facilitated by law enforcement, with Knipp selling methamphetamine to Larry Eldridge and purchasing a firearm for him, knowing Eldridge was a felon. Eldridge cooperated with law enforcement, leading to Knipp's arrest and subsequent trial.The United States District Court for the Eastern District of Kentucky denied Knipp's motion to dismiss the firearm charge, which he argued violated the Second Amendment. Knipp was found guilty on all counts by a jury and sentenced to 138 months in prison for the drug charges and 120 months for the firearm charge, to be served concurrently.The United States Court of Appeals for the Sixth Circuit reviewed the case. Knipp challenged the constitutionality of 18 U.S.C. § 922(d)(1), which prohibits selling firearms to felons, arguing it violated the Second Amendment. The court applied the two-step framework from N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen and found that while the Second Amendment covers the right to acquire firearms, historical precedent supports disarming dangerous individuals, including felons. Thus, the court upheld the statute's constitutionality.Knipp also contested the admission of Eldridge's testimony about prior drug transactions, arguing it was impermissible propensity evidence. The court found any potential error in admitting this evidence to be harmless, given the substantial other evidence of Knipp's guilt.Finally, Knipp argued that the district court erred in calculating his sentence by including drug quantities from prior transactions based on Eldridge's testimony. The appellate court found no clear error in the district court's credibility determination and upheld the sentence.The Sixth Circuit affirmed Knipp's conviction and sentence. View "United States v. Knipp" on Justia Law

The Federal Communications Commission (FCC) issued an order requiring most television and radio broadcasters to compile and disclose employment-demographics data to the FCC, which would then post the data on its website. Petitioners, a group of broadcasters and associations, challenged the order, arguing that the FCC lacked statutory authority for such a requirement, and that it violated their First and Fifth Amendment rights, and was arbitrary and capricious under the Administrative Procedure Act.The FCC reinstated the collection of employment-demographics data in February 2024, ending a 22-year hiatus. The data collection, through Form 395-B, was intended to monitor industry trends and report to Congress. The FCC had previously collected this data until 2002, when it was suspended following a court ruling that found certain FCC regulations unconstitutional. The FCC's new order also included amendments to Form 395-B, such as adding non-binary gender categories and expanding job categories.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the FCC lacked statutory authority to require broadcasters to submit Form 395-B. The court explained that the FCC's broad public-interest authority must be linked to a distinct grant of authority from Congress, which was not present in this case. The court also rejected the FCC's argument that the 1992 Cable Act ratified its authority to collect Form 395-B data, noting that the Act tied this authority to equal employment opportunity regulations that were no longer in effect.The Fifth Circuit granted the petition and vacated the FCC's order, concluding that the FCC did not have the statutory authority to mandate the collection and disclosure of employment-demographics data from broadcasters. View "National Religious Broadcasters v. FCC" on Justia Law

Holly Lawson, a guidance counselor at Franklin County High School, alleged that her Fourth Amendment rights were violated by her coworkers, Kayla Creely and Lori Franke, and by School Superintendent Mark Kopp, along with the Franklin County, Kentucky Board of Education. Lawson claimed that Creely and Franke searched her bag without her consent, discovering a firearm, and that Kopp unlawfully detained and searched her in connection with this incident.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the defendants. The court found that Creely and Franke were acting under color of state law but were entitled to qualified immunity. It also determined that Kopp's actions constituted a lawful investigative stop under Terry v. Ohio and that Lawson consented to the search of her bag.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that Creely and Franke did not act under color of state law because their actions were not authorized by any school policy or state authority. The court also agreed that Kopp's interaction with Lawson was a lawful investigative stop supported by reasonable suspicion and that Lawson voluntarily searched her own bag, negating any Fourth Amendment violation. Consequently, the court found no basis for municipal liability under Monell against the Board. View "Lawson v. Creely" on Justia Law

The case involves the City of Myrtle Beach's response to a surge in violent crime in an area known as "the Superblock." Between 2015 and 2016, eleven people were shot, and dozens more were sexually assaulted, battered, or robbed in the Superblock, primarily around a small cluster of bars. The City increased police presence and investigated these establishments for compliance with safety regulations. Despite these measures, crime persisted, leading the City to shut down two bars for repeated legal violations, while a third bar closed due to lack of business. Years later, the bars and the landlord sued the City and the City Manager, alleging violations of the Takings Clause, Due Process Clause, Equal Protection Clause, and 42 U.S.C. § 1985, claiming the City unlawfully targeted them because their owners and clientele were predominantly racial minorities.The United States District Court for the District of South Carolina granted directed verdicts for the City on all claims during a jury trial. The court held that the appellants did not have a constitutionally protected property interest in the right to conduct their business. It found that the City's enforcement actions were within the legitimate bounds of state police power and rejected the § 1985 civil conspiracy claims based on the intra corporate conspiracy doctrine, which states that corporate and government agents cannot conspire with themselves.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The appellate court held that the City acted within its lawful authority to address serious public safety threats and enforce compliance with state and local regulations. The appellants' claims were deemed speculative and unsupported by the evidence presented at trial. The court found no discriminatory intent or violation of due process, and it upheld the application of the intra corporate conspiracy doctrine, concluding that the City officials did not possess a personal stake independent of their relationship to the City. View "Brady v. City of Myrtle Beach" on Justia Law

A couple, the Marons, alleged that Florida's Disposition of Unclaimed Property Act violated the Takings Clause of the Fifth Amendment. They claimed that the Act allowed the state to take their unclaimed property without compensating them for the earnings accrued while the property was in the state's custody. The Act requires holders of unclaimed property to deliver it to the state's Department of Financial Services, which then uses the property for public purposes, including investing it. The Marons argued that they were entitled to these earnings.The United States District Court for the Northern District of Florida dismissed the Marons' suit. The court reasoned that the state could constitutionally escheat the property altogether, so it could also keep the property in its custody without compensating for the earnings. The court also addressed jurisdictional issues, concluding that the Marons had standing and that their claim was not fully barred by sovereign immunity, but ultimately found that the Marons failed to state a claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that the district court had jurisdiction over the Marons' takings claim, as the Marons had standing, the claim was ripe, and it was not barred by sovereign immunity. However, the appellate court disagreed with the district court's analysis on the merits. The appellate court held that the Act did not transfer title of the unclaimed property to the state, but merely placed it in the state's custody. The court vacated the district court's judgment and remanded the case for further proceedings to determine whether the Marons' property was directly appropriated by the state and whether the Act provided just compensation. View "Maron v. Chief Financial Officer of Florida" on Justia Law

A child was temporarily removed from her parents' care shortly after birth and placed in the custody of the Department of Children and Families (DCF) due to concerns about domestic violence. DCF sought to vaccinate her according to an age-based immunization schedule, but her parents, practicing Rastafarians, objected on religious grounds. A Juvenile Court judge allowed DCF to facilitate vaccinations for the child. The parents sought to stop future vaccinations, arguing that vaccinating their child over their religious objections violated their constitutional rights.The Juvenile Court judge found that the parents' religious beliefs were outweighed by the child's best interests and allowed DCF to vaccinate the child. The parents petitioned the Appeals Court for interlocutory relief, which was denied. The parents then appealed to the Appeals Court panel, and the child sought direct appellate review in the Supreme Judicial Court, which was granted.The Supreme Judicial Court of Massachusetts held that the order allowing the child to be vaccinated violated the parents' constitutional rights. The court concluded that the parents' sincerely held religious beliefs were substantially burdened by DCF's vaccination efforts. The court applied the State constitutional protections afforded to parents exercising their free exercise rights and determined that DCF failed to demonstrate that exempting the child from vaccinations would substantially hinder the fulfillment of DCF's interests in promoting child health. The court noted the Commonwealth's allowance of religious exemptions from vaccination requirements for parents who have not lost custody and DCF's inconsistent exercise of its authority to order vaccinations for children in its care. The order allowing the joint motion by DCF and the child to facilitate the vaccination of the child was reversed. View "Care and Protection of Eve" on Justia Law

A citizen-journalist from South Bend, Indiana, challenged the constitutionality of Indiana's "buffer law," which makes it a crime to knowingly or intentionally approach a law enforcement officer within 25 feet after being ordered to stop approaching. The journalist, who records and livestreams police activity, argued that the law violated his First Amendment right to record the police in public spaces. The incident leading to the challenge occurred when the journalist was ordered by police to move back while recording a crime scene, which he complied with under threat of arrest.The United States District Court for the Northern District of Indiana consolidated the journalist's motion for a preliminary injunction with a trial on the merits. The district court found the buffer law constitutional, ruling that it only had an incidental effect on the public's First Amendment rights and served legitimate public safety interests. The court denied the journalist's request for an injunction and entered final judgment for the defendants.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Indiana's buffer law is a content-neutral regulation of the time, place, and manner of expression. It found that the law is narrowly tailored to serve significant government interests, such as officer and bystander safety and the integrity of police investigations, without burdening substantially more speech than necessary. The court also determined that the law leaves open ample alternative channels for communication, as it does not prevent individuals from recording police activity from a reasonable distance. The Seventh Circuit affirmed the district court's judgment, upholding the constitutionality of Indiana's buffer law. View "Nicodemus v City of South Bend" on Justia Law

Investigators suspected Lamont Coleman of running a heroin operation from his apartment building in Gary, Indiana. They conducted fourteen controlled drug purchases using confidential informants and undercover officers. Evidence from these buys and surveillance led to a search warrant for Coleman’s apartment and a neighboring house he owned. The search uncovered drugs, money, and firearms, leading to Coleman’s conviction on most counts of the indictment.The United States District Court for the Northern District of Indiana held a Franks hearing and denied Coleman’s motion to suppress evidence, finding sufficient probable cause for the search warrant. At trial, the jury convicted Coleman of being a felon in possession of a firearm, conspiring to distribute heroin, and possessing heroin with intent to distribute. The jury acquitted him of some drug distribution charges and possession of cocaine base with intent to distribute. Coleman was sentenced to 240 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed Coleman’s appeal, which included four claims. Coleman argued that the district court constructively amended his indictment by issuing generic jury instructions, the government withheld exculpatory information, the court improperly excluded an affidavit as evidence, and the court erred in considering acquitted conduct at sentencing. The Seventh Circuit affirmed the district court’s decisions on all grounds. The court found no prejudice from the alleged constructive amendment, determined that the new evidence about the surveillance recordings was not material, upheld the exclusion of Leroy Coleman’s affidavit due to its unreliability, and noted that current precedent allows the consideration of acquitted conduct at sentencing. View "USA v Coleman" on Justia Law

Yelp, a company that publishes consumer reviews, introduced a notification on its business pages for crisis pregnancy centers (CPCs) in 2022, stating that these centers typically offer limited medical services. After objections from several state Attorneys General, including Texas Attorney General Ken Paxton, Yelp replaced the notice with one stating that CPCs do not offer abortions or abortion referrals. Despite this change, Paxton initiated an investigation and sent Yelp a notice of intent to file suit, alleging that the original notice violated the Texas Deceptive Trade Practices – Consumer Protection Act (DTPA). Yelp then filed a lawsuit in federal court, claiming First Amendment retaliation, and sought to enjoin Paxton from further action. The next day, Paxton filed a state court action against Yelp.The United States District Court for the Northern District of California dismissed Yelp’s federal case based on the Younger abstention doctrine, which prevents federal courts from interfering with ongoing state judicial proceedings. The district court found that the requirements for Younger abstention were met and that the bad faith exception did not apply.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that Younger’s bad faith exception did not apply because Yelp had not sufficiently established that the Texas civil enforcement action was brought without a reasonable expectation of obtaining a valid judgment or was facially meritless. The court also found that Yelp failed to show that Paxton’s enforcement action was motivated by a desire to harass or retaliate against Yelp for its support of abortion rights. The court concluded that the district court did not err in denying Yelp’s request for discovery and an evidentiary hearing. View "YELP INC. V. PAXTON" on Justia Law

Roberto Felix, Jr., a law enforcement officer, stopped Ashtian Barnes for suspected toll violations. During the stop, Barnes began to drive away, prompting Felix to jump onto the car's doorsill and fire two shots, fatally wounding Barnes. Barnes's mother sued Felix, alleging a violation of Barnes's Fourth Amendment right against excessive force.The District Court granted summary judgment to Felix, applying the Fifth Circuit’s “moment-of-threat” rule, which focuses solely on whether the officer was in danger at the precise moment deadly force was used. The court found that Felix could have reasonably believed he was in danger during the two seconds he was on the doorsill of the moving car. The Court of Appeals affirmed, adhering to the same rule and limiting its analysis to the final moments before the shooting.The Supreme Court of the United States reviewed the case and held that the “moment-of-threat” rule improperly narrows the Fourth Amendment analysis. The Court emphasized that the reasonableness of police force must be assessed based on the “totality of the circumstances,” which includes events leading up to the use of force. The Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings, instructing the lower courts to consider the entire context of the incident, not just the final moments. View "Barnes v. Felix" on Justia Law