Justia Constitutional Law Opinion Summaries

Brent Burton was charged with domestic violence, a class B misdemeanor, after a 911 call was made from his residence reporting an assault. The call was purportedly made by Burton's wife, who described being grabbed and slapped by Burton. The State filed a notice of intent to use the 911 call recording as evidence, supported by a certificate of authenticity from the records custodian of Central Dakota Communications. Burton pleaded not guilty and proceeded to trial.At the jury trial, the State was unable to locate or subpoena Burton's wife. Burton objected to the introduction of the 911 call recording, arguing it violated his Sixth Amendment right to confront his accuser. The district court admitted the recording, finding it addressed an ongoing emergency. The jury found Burton guilty, and the court sentenced him accordingly.Burton appealed to the Supreme Court of North Dakota, arguing the admission of the 911 call violated his Sixth Amendment rights and that the recording was improperly authenticated and contained inadmissible hearsay. The Supreme Court reviewed the case de novo and concluded the 911 call was nontestimonial, as its primary purpose was to address an ongoing emergency. The court also found sufficient circumstantial evidence to authenticate the call and determined it fell under the present sense impression exception to the hearsay rule.The Supreme Court of North Dakota affirmed the district court's judgment, holding that the admission of the 911 call did not violate Burton's constitutional rights and that the recording was properly authenticated and admissible under the hearsay exceptions. View "State v. Burton" on Justia Law

Kyle Zittleman and ShanaLea Bibler were married in 2010 and had one child in 2012. They divorced in 2016, with a Wyoming court granting Zittleman primary residential responsibility. Bibler filed motions to modify residential responsibility and child support in 2018 and 2020, but Zittleman retained primary responsibility. Zittleman moved to North Dakota in 2019, and Bibler followed in 2022. In 2023, Bibler again moved to modify residential responsibility, citing her relocation, Zittleman’s alleged non-compliance with a judgment, and the child's worsening demeanor.The Morton County district court held an evidentiary hearing in 2024, limiting each party to two and a half hours for their case. Bibler used all her time before cross-examining two witnesses and argued this violated her due process rights. The district court found no material change in circumstances and denied her motion. Bibler appealed, claiming the time limitation and the court's findings were erroneous.The North Dakota Supreme Court reviewed the case de novo for constitutional claims and under an abuse of discretion standard for procedural matters. The court found that the district court did not violate due process by limiting the hearing time, as both parties were notified and did not object or request additional time. The court also found no abuse of discretion in the time limitation.The Supreme Court upheld the district court's finding that there was no material change in circumstances. The court noted that Bibler's move to North Dakota, Zittleman’s adherence to the judgment, and allegations of alienation did not constitute a material change. The court also found that the district court did not err in omitting a best interests analysis, as it was not required without a material change in circumstances. The Supreme Court affirmed the district court's order denying Bibler's motion to modify residential responsibility. View "Zittleman v. Bibler" on Justia Law

Bruce Henry, who pled guilty to possessing child pornography in 2013, challenged Alabama Code § 15-20A-11(d)(4), which prohibits adult sex offenders convicted of a sex offense involving a child from residing or conducting overnight visits with a minor, including their own child. Henry, who has completed his prison term, married, and fathered a son, argued that the statute violated his First Amendment right of intimate association and the Fourteenth Amendment’s guarantees of equal protection and due process.The United States District Court for the Middle District of Alabama denied Henry’s motion for a preliminary injunction but later partially granted his motion for summary judgment, finding the statute facially unconstitutional. The district court concluded that the statute was not narrowly tailored to further Alabama’s compelling interest in protecting children and issued an injunction against its enforcement.The United States Court of Appeals for the Eleventh Circuit reviewed the case and agreed that the statute violated Henry’s fundamental right to live with his child. The court held that the statute was overinclusive, underinclusive, and not narrowly tailored to achieve its goal. However, the court also concluded that the district court abused its discretion in facially enjoining the statute, as Henry had not shown that it was unconstitutional in all its applications. The court vacated the district court’s injunction and remanded the case for further proceedings consistent with its opinion. View "Henry v. Sheriff of Tuscaloosa County" on Justia Law

Several adult-entertainment establishments and individual dancers in Jacksonville, Florida, challenged a city ordinance that effectively prohibits erotic dancers under the age of 21 from performing in adult-entertainment venues. The ordinance also requires dancers aged 21 and older to obtain a Work Identification Card through a licensing process. The plaintiffs argued that the age restriction and the licensing scheme violated the First Amendment.The United States District Court for the Middle District of Florida upheld both the age restriction and the licensing scheme. The court concluded that the age restriction is a content-neutral regulation aimed at reducing human trafficking and other criminal activities associated with adult-entertainment establishments. Applying intermediate scrutiny, the court found that the restriction furthered a substantial government interest and was appropriately tailored. The court also held that the licensing scheme did not impose an unconstitutional prior restraint, as it provided sufficient procedural protections, including a 14-day period for the sheriff to approve or deny applications and the ability for applicants to continue dancing while their applications were pending.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the ordinance's age restriction must be treated as a content-neutral regulation of expressive activity and is thus subject to intermediate scrutiny, which it survives. The court found that the restriction furthers the city's substantial interest in combatting human trafficking and is narrowly tailored to achieve that interest. Additionally, the court concluded that the licensing scheme includes sufficient procedural safeguards to avoid being an unconstitutional prior restraint, as it requires the sheriff to make licensing decisions within a reasonable time and allows dancers to continue performing while their applications are under review. View "Wacko's Too, Inc. v. City of Jacksonville" on Justia Law

Three criminal defendants in San Francisco, on behalf of themselves and a putative class, challenged the constitutionality of the San Francisco Sheriff's Office (SFSO) Pre-Trial Electronic Monitoring program (PTEM). They specifically contested Rule 5, which requires enrollees to submit to warrantless searches, and Rule 11, which allows SFSO to share participants’ location data with other law enforcement agencies without a warrant and to retain the data. The plaintiffs were divided into two subclasses: those enrolled in the program before May 2023 ("original rules subclass") and those enrolled after May 2023 ("revised rules subclass").The United States District Court for the Northern District of California granted a preliminary injunction in favor of the plaintiffs, finding that the Program Rules likely violated their rights under the United States and California constitutions. The court enjoined the enforcement of the challenged Program Rules for both subclasses. The Sheriff appealed the injunction, particularly the prohibition on enforcing the location sharing provision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that it had jurisdiction over the appeals and that abstention was not warranted. The court found that the plaintiffs were unlikely to succeed on their facial challenges to Rule 11’s location sharing requirement for the revised rules subclass. The court determined that the Superior Court exercises a core judicial power in imposing PTEM and that the Sheriff’s program does not create separation-of-powers issues. The court also found that the location sharing provision was reasonable under the Fourth Amendment and the California Constitution when ordered by the Superior Court following an individualized determination. The court vacated the preliminary injunction as to the revised rules subclass but affirmed it for the original rules subclass due to the lack of a clear record that location sharing was a condition of PTEM enrollment. The court also granted the Sheriff’s motion to stay the district court’s subsequent order enforcing the preliminary injunction. View "SIMON V. CITY AND COUNTY OF SAN FRANCISCO" on Justia Law

A sheriff's deputy in San Bernardino County, California, pursued a suspect who fled from a traffic stop. The suspect, Richard Delacruz, ran towards the backyard of Michael Newman's home. The deputy, Todd Underhill, lost sight of Delacruz but believed he might have entered the house. Underhill and other deputies entered the home without a warrant, found Newman, and eventually located and arrested Delacruz inside the house.The United States District Court for the Central District of California granted summary judgment in favor of the defendants, ruling that the deputies did not violate the Fourth Amendment because the hot-pursuit exception to the warrant requirement applied. The court found that the deputies had probable cause to believe Delacruz was inside the house and that the pursuit was immediate and continuous.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that the deputies had probable cause to enter the home, as a reasonable person would believe there was a fair probability that Delacruz was inside. The court also determined that the pursuit was immediate and continuous, despite a nine-minute delay between losing sight of Delacruz and entering the home. The court concluded that the hot-pursuit exception justified the warrantless entry, as the deputies were in immediate and continuous pursuit of a fleeing suspect who had committed a felony. The Ninth Circuit affirmed the summary judgment in favor of the defendants. View "NEWMAN V. UNDERHILL" on Justia Law

Intellectual Capitol, Inc., JMI Sports, and JMIS College, LLC (Appellants) obtained contracts through the state procurement process with the South Carolina Workers' Compensation Commission (WCC) and Clemson University (Respondents). Disputes arose under these contracts, leading Respondents to file Requests for Resolution of Contract Controversy with the Chief Procurement Officer (CPO) for the State of South Carolina. Appellants then filed separate declaratory judgment actions in circuit court, challenging the constitutionality of section 11-35-4230 of the South Carolina Code, which grants the CPO exclusive jurisdiction over state contract disputes.The circuit court granted Respondents' motions to dismiss the declaratory judgment actions, ruling that section 11-35-4230 placed exclusive jurisdiction over the State's contract disputes with the CPO. The court also dismissed Appellants' constitutional claims as premature due to their failure to exhaust administrative remedies. Appellants appealed this decision.The South Carolina Supreme Court reviewed the case and affirmed the circuit court's dismissal of the declaratory judgment actions, but modified the reasoning. The Supreme Court held that the contracts between Appellants and Respondents contained a clear choice-of-forum provision, which unambiguously gave the CPO exclusive authority to resolve disputes. By agreeing to this provision, Appellants waived their right to have their disputes decided by a court of the unified judicial system. Consequently, there was no justiciable controversy, rendering the constitutional challenge to section 11-35-4230 a purely academic exercise. The Supreme Court affirmed the circuit court's dismissal of the declaratory judgment actions, as there were no legal rights at issue. View "Intellectual Capital, Inc. v. Chief Procurement Officer" on Justia Law

C.L., a twelve-year-old student, was invited by her teacher, Jenna Riep, to an after-school art club meeting, which turned out to be a Gender and Sexualities Alliance (GSA) meeting. During the meeting, a guest speaker, Kimberly Chambers, discussed gender identity and suggested that students uncomfortable with their bodies might be transgender. Chambers also warned students that it might not be safe to tell their parents about the meeting and provided her personal contact information for further communication. C.L. announced herself as transgender at the meeting and later informed her parents, who subsequently disenrolled her from the school. H.J., another student, had similar experiences and also faced emotional distress, leading her parents to disenroll her from the school.The parents of C.L. and H.J. sued the Poudre School District and its Board of Education, alleging a violation of their Fourteenth Amendment parental substantive-due-process rights. The United States District Court for the District of Colorado dismissed the complaint without prejudice. The parents then moved to amend their complaint, focusing solely on a claim against the school district for monetary damages. The district court denied the motion to amend, concluding that the parents had failed to plausibly allege municipal liability.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the parents did not plausibly allege that the school district's official policy was the moving force behind their alleged injuries. The court found that the parents failed to establish a direct causal link between the district's policies and the constitutional injury they claimed. View "Lee v. Poudre School District R-1" on Justia Law

Three federal prisoners, Jason Bricker, Ellis McHenry, and Lois Orta, sought compassionate release under 18 U.S.C. § 3582(c)(1)(A), citing a new policy statement by the Sentencing Commission, U.S.S.G. § 1B1.13(b)(6). This policy allows for sentence reductions based on nonretroactive changes in the law if certain conditions are met, including serving at least 10 years of an "unusually long sentence" and a "gross disparity" between the actual and hypothetical sentences under current law.In the Northern District of Ohio, the district court granted Bricker's motion for compassionate release, finding that his sentence would be significantly shorter under current law. The court acknowledged a Sixth Circuit precedent, United States v. McCall, which held that nonretroactive changes in the law are not "extraordinary and compelling reasons" for sentence reduction, but asserted that the Sentencing Commission had overruled this precedent. The government appealed this decision.In McHenry's case, the district court denied his motion for compassionate release, stating that applying the new policy would require disregarding the statutory mandatory minimum and the binding precedent set by McCall. Similarly, in Orta's case, the district court denied the motion, relying on McCall to conclude that nonretroactive changes in sentencing law do not constitute "extraordinary and compelling reasons" for release. Both McHenry and Orta appealed these decisions.The United States Court of Appeals for the Sixth Circuit reviewed the consolidated appeals and held that the Sentencing Commission overstepped its authority with U.S.S.G. § 1B1.13(b)(6). The court concluded that the policy statement was invalid as it conflicted with the statute and the separation of powers. Consequently, the Sixth Circuit reversed the district court's decision in Bricker's case and affirmed the denials in McHenry's and Orta's cases, denying compassionate release for all three prisoners. View "United States v. Bricker" on Justia Law

Bruce Holder was accused of running a fentanyl distribution ring in western Colorado, distributing thousands of counterfeit pills resembling oxycodone. He was convicted of four federal drug crimes, including charges related to the death and serious injury of buyers of his product. Holder challenged the constitutionality of his trial, arguing that the district court’s COVID-19 protocols violated his right to a public trial, that the jury pool unreasonably underrepresented certain racial groups, that several counts were constructively amended at trial, and that the evidence was insufficient to support the jury’s finding that his fentanyl distribution resulted in a victim’s death.The United States District Court for the District of Colorado imposed COVID-19 protocols, including social distancing, mask-wearing, and limited public access to the courtroom. Holder objected to these protocols, particularly the lack of video access and the limited public attendance. The jury convicted Holder on all four counts.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the district court’s COVID-19 protocols did not violate Holder’s public trial rights, as the partial closure of the courtroom was justified by the substantial interest in protecting public health. The court also found no unreasonable racial disparity in the jury pool, as the absolute and comparative disparities were within acceptable limits. Additionally, the court determined that the indictment was not constructively amended, as the jury instructions did not alter the essential elements of the charges. Finally, the court held that there was sufficient evidence to support the jury’s finding that Holder’s fentanyl distribution resulted in a victim’s death.The Tenth Circuit affirmed Holder’s conviction. View "United States v. Holder" on Justia Law