Justia Constitutional Law Opinion Summaries

Dedric Mayfield, a felon, was convicted by a jury of possessing ammunition in violation of 18 U.S.C. § 922(g)(1) after being recorded by a police-operated camera firing a handgun during an altercation. Mayfield had five prior adult felony convictions. Before trial, he did not stipulate to the authenticity or admissibility of any government exhibits. When the camera operator became unavailable for trial, Mayfield volunteered to stipulate to the authenticity and admissibility of the footage, allowing a detective to testify about it. The district court denied the government's motion for a continuance and instructed Mayfield to stipulate to the authenticity and admissibility of exhibits unless he had a good-faith basis not to do so. Mayfield stipulated to some exhibits, and the jury found him guilty. He was sentenced to 120 months in prison.The United States District Court for the District of Colorado handled the initial trial. Mayfield did not object to the district court's instructions regarding stipulations during the trial. He later argued that these instructions violated his Sixth Amendment fair-trial and Fourteenth Amendment due-process rights by coercing his counsel into stipulating to the government's evidence, thus depriving him of a fair trial.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court assumed without deciding that the district court's instructions were erroneous but found that Mayfield failed to demonstrate a reasonable probability that the outcome of the trial would have been different but for the error. The court also rejected Mayfield's argument that 18 U.S.C. § 922(g)(1) is facially unconstitutional under the Second Amendment, citing precedent that upheld the statute's constitutionality. The Tenth Circuit affirmed the district court's decision. View "United States v. Mayfield" on Justia Law

Jacqusyn Grubb was charged with unlawful possession of a firearm as an unlawful user of a controlled substance under 18 U.S.C. § 922(g)(3). Grubb moved to dismiss the indictment, arguing that the statute violated his Second Amendment rights, particularly as he was a user of marijuana, not a more dangerous controlled substance. The government contended that Grubb's challenge was premature due to undeveloped facts.The United States District Court for the Northern District of Iowa denied Grubb's motion to dismiss, ruling that the statute was constitutional on its face but held Grubb's as-applied challenge pending trial. The court rejected Grubb's request for an evidentiary hearing, stating it would amount to unauthorized discovery. Grubb then entered a conditional guilty plea, reserving his right to appeal the denial of his motion to dismiss. The district court later reconsidered and requested supplemental briefing but ultimately denied the motion to dismiss, concluding the statute was constitutional as applied to Grubb.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a trial on the merits was necessary to resolve Grubb's pretrial motion to dismiss the indictment. The court emphasized that there is no summary judgment procedure in federal criminal cases and that the government is not required to present all its evidence before trial. The court concluded that the district court should have deferred ruling on the as-applied challenge until trial. Consequently, the Eighth Circuit reversed the district court's order, vacated the judgment, and remanded the case for further proceedings, allowing Grubb to choose whether to adhere to his guilty plea or proceed to trial. View "United States v. Grubb" on Justia Law

8fig, Incorporated, a technology company, entered into agreements with several e-commerce merchants (Defendant-Appellants) to purchase projected revenue in exchange for an up-front payment. 8fig alleged that the Defendant-Appellants failed to remit the agreed payments and instead transferred the funds to a religious movement, World Olivet Assembly, closed their bank accounts, and went out of business. 8fig filed a lawsuit under 18 U.S.C. §§ 1964, 1962, and various state and common law claims. The parties filed a Joint Agreed Motion to Administratively Close and Seal Proceedings, which the district court granted, and the case settled quickly.Newsweek Digital, LLC moved to intervene and unseal the judicial record, arguing that the seal hindered its reporting. The district court granted Newsweek’s motion to intervene and unseal, allowing any party to propose redactions. Certain defendants filed proposed redactions, which the district court granted, and denied a motion to extend filing deadlines. The district court proceeding has been unsealed for over a year, except for documents with redacted versions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Newsweek had standing to intervene, as alleged violations of the public right to access judicial records and gather news are cognizable injuries-in-fact. The court found that the district court did not abuse its discretion in unsealing the records, emphasizing the public’s common law right of access to judicial records and the presumption in favor of transparency. The court affirmed the district court’s order granting Newsweek’s motion to intervene and unseal the proceeding. View "8Fig v. Stepup Funny" on Justia Law

The City of Tea passed a resolution imposing a special assessment on properties abutting a road construction project, including property owned by KJD, LLC. The City found that the improvement conferred special benefits on the abutting properties beyond those experienced by the public. KJD objected to the assessment, arguing it was unconstitutional as the project did not confer a special benefit on its property. The circuit court held that KJD did not rebut the presumption that the City’s assessment was valid and did not prove by clear and convincing evidence that the City’s findings were incorrect, thus denying KJD’s objection.KJD appealed to the Supreme Court of South Dakota. The Supreme Court reviewed the case de novo, noting that the City’s findings in its resolution are presumed correct and that KJD had the burden to rebut this presumption with substantial, credible evidence. The Court found that KJD failed to present such evidence. The City’s findings included that the project would improve aesthetics, safety, and access to the properties, which are considered special benefits. The Court also noted that the City’s method of calculating the assessment based on the cost of the project was constitutionally permissible.The Supreme Court of South Dakota affirmed the circuit court’s decision, holding that KJD did not meet its burden of proving by clear and convincing evidence that the City’s special assessment was unconstitutional. The Court concluded that the City’s findings were supported by the record and that the special assessment did not exceed the value of the benefits conferred on KJD’s property. View "KJD, LLC v. City Of Tea" on Justia Law

Nathaniel Jacobs was found guilty by a jury of several drug and gun possession offenses, as well as witness tampering. The case began when Jacobs appeared at a hospital with a gunshot wound and admitted to police that he had accidentally shot himself with a firearm he was not legally allowed to possess. A search of his home revealed firearms, ammunition, and drug-related evidence, including methamphetamine and paraphernalia. Jacobs was indicted on multiple counts, including illegal possession of firearms, possession with intent to distribute methamphetamine, possession of a firearm in furtherance of a drug trafficking crime, and witness tampering.The United States District Court for the Southern District of Indiana handled the initial proceedings. During pretrial, the court granted a government motion to exclude evidence of Jacobs’s girlfriend’s pending criminal charges, which Jacobs wanted to use to suggest her potential bias. The jury trial proceeded, and Jacobs was convicted on all counts.The United States Court of Appeals for the Seventh Circuit reviewed the case. Jacobs raised two issues on appeal: a violation of his Sixth Amendment rights due to the district court's restriction on cross-examining his ex-girlfriend about her potential bias, and a Fourth Amendment challenge regarding the admission of drug evidence found in his home. The appellate court found that any potential Sixth Amendment violation was harmless beyond a reasonable doubt due to the overwhelming evidence against Jacobs. Additionally, the court determined that Jacobs had not shown good cause for failing to file a suppression motion regarding the drug evidence and that the search of the tobacco cans was within the scope of the warrant.The Seventh Circuit affirmed the district court’s judgment, upholding Jacobs’s convictions. View "United States v. Jacobs" on Justia Law

Kenneth Jouppi, the owner of an airplane, was convicted of transporting beer into the village of Beaver, Alaska, which prohibits the importation of alcoholic beverages. Following his conviction, Alaska law mandated the forfeiture of his airplane as it was used to commit the offense. Jouppi argued that the forfeiture violated the Excessive Fines Clause of the U.S. Constitution.The District Court of the State of Alaska, Fourth Judicial District, Fairbanks, initially declined to order the forfeiture on statutory grounds. The State appealed, and the Court of Appeals reversed, mandating the forfeiture. On remand, the trial court again declined to order the forfeiture, this time on constitutional grounds, finding it unconstitutionally excessive. The State appealed again, and the Court of Appeals vacated the trial court’s ruling, remanding for further fact-finding, as it concluded the trial court failed to correctly apply the test for excessive fines from United States v. Bajakajian.The Supreme Court of the State of Alaska reviewed the case. It held that the forfeiture of the airplane did not violate the Excessive Fines Clause because it was not grossly disproportional to the gravity of the offense. The court found that the forfeiture was punitive and thus a "fine" under the Eighth Amendment. Applying the Bajakajian factors, the court concluded that the forfeiture was not excessive given the nature and extent of the crime, the legislative intent behind the statute, and the harm caused by the offense. The court also noted that Jouppi failed to preserve his arguments under the Alaska Constitution and the Sixth Amendment, and thus did not address them. The judgment of the Court of Appeals was vacated, and the case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Jouppi v. State of Alaska" on Justia Law

Efrain Leonides-Seguria, a Mexican citizen without legal status in the United States, was detained by Immigration and Customs Enforcement (ICE) on June 15, 2021, for illegal reentry. Six days later, ICE referred him for criminal prosecution. On June 23, federal prosecutors filed a criminal complaint, and a magistrate judge issued an arrest warrant. Leonides-Seguria remained in immigration custody until June 28, when he was arrested on the criminal complaint. He later waived prosecution by indictment, consenting to the filing of a criminal information on July 27.The United States District Court for the Northern District of Illinois denied Leonides-Seguria’s motions to dismiss the federal charge, arguing that the government violated the Speedy Trial Act and that 8 U.S.C. § 1326 is unconstitutional. He pled guilty but reserved the right to appeal these denials. The district court sentenced him to 51 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit reviewed the case. Leonides-Seguria argued that the Speedy Trial Act was violated because the criminal information was filed more than 30 days after his apprehension. He urged the court to recognize a "ruse exception," where civil detention by immigration authorities is used to delay criminal prosecution. The Seventh Circuit declined to resolve the legal question of the ruse exception, finding that the facts did not support its application. The court found no evidence of collusion between ICE and federal prosecutors to circumvent the Speedy Trial Act. The court affirmed the district court’s denial of the motion to dismiss and upheld the constitutionality of 8 U.S.C. § 1326, consistent with precedent. The Seventh Circuit affirmed the district court’s judgment. View "USA v Leonides-Seguria" on Justia Law

The case involves a challenge to Governor Tony Evers' use of his partial veto authority under the Wisconsin Constitution. The dispute centers on the 2023-25 biennial budget bill, where the governor used his partial veto power to extend an education revenue limit increase from two fiscal years to 402 fiscal years by striking certain words and digits from the bill.The petitioners did not ask the court to overrule existing precedent but instead brought two novel challenges. They argued that the governor's partial vetoes violated Article V, Section 10(1)(b) of the Wisconsin Constitution because extending a duration from two years to 402 years is not a "part" of two years. They also contended that the vetoes violated Section 10(1)(c) because it prohibits the governor from striking digits to create new numbers.The Wisconsin Supreme Court rejected both arguments. The court found that the first argument improperly relied on the holding in Citizens Utility Board v. Klauser, which was limited to the specific circumstance of write-in vetoes, not applicable here. The second argument failed because Section 10(1)(c) does not prohibit the governor from striking digits to create new numbers. The court concluded that the 2023 partial vetoes did not violate the constitution and denied the petitioners' requested relief.The court also highlighted potential legislative options to address the governor's partial veto power, including future budget bills, constitutional amendments, and legislative drafting strategies. The court upheld the partial vetoes as consistent with the Wisconsin Constitution. View "LeMieux v. Evers" on Justia Law

A recently enacted Mississippi statute, House Bill 1126, aims to protect minors from harmful online material by requiring digital service providers (DSPs) to verify users' ages, obtain parental consent for minors, limit data collection, and implement strategies to mitigate harmful content exposure. NetChoice, L.L.C., a trade association for internet-focused companies, challenged the statute's constitutionality under the First and Fourteenth Amendments and sought a preliminary injunction to prevent its enforcement.The United States District Court for the Southern District of Mississippi granted the preliminary injunction, finding that NetChoice was likely to succeed on its claims that the statute was unconstitutional. The court determined that NetChoice had associational standing to bring the suit on behalf of its members and that the statute imposed significant regulatory burdens that could cause financial harm. The Attorney General of Mississippi appealed, arguing that the district court erred in its findings and failed to perform the necessary facial analysis as mandated by the Supreme Court in Moody v. NetChoice, LLC.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the district court did not conduct the required two-step analysis outlined in Moody. This analysis involves defining the law's scope and determining which applications violate the First Amendment. The Fifth Circuit noted that the district court did not fully assess the range of activities and actors regulated by the statute or the specific regulatory burdens imposed on different DSPs. Consequently, the court vacated the preliminary injunction and remanded the case to the district court for further factual analysis consistent with the Supreme Court's opinion in Moody and Fifth Circuit precedent. View "NetChoice v. Fitch" on Justia Law

AT&T sought review of a Federal Communications Commission (FCC) forfeiture order, which fined the company $57 million for mishandling customer data in violation of section 222 of the Telecommunications Act. The FCC found that AT&T failed to protect customer proprietary network information (CPNI) and issued the fine after an internal adjudication process. AT&T argued that the FCC's in-house adjudication violated the Constitution by denying it an Article III decisionmaker and a jury trial.The FCC's Enforcement Bureau investigated AT&T following reports of misuse of customer location data by service providers. The Bureau issued a Notice of Apparent Liability for Forfeiture (NAL), proposing the penalty. AT&T responded in writing, contesting the penalty and raising constitutional challenges. The FCC rejected AT&T's arguments and affirmed the penalty, leading AT&T to pay the fine and seek review in the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit, guided by the Supreme Court's decision in SEC v. Jarkesy, agreed with AT&T that the FCC's enforcement procedures violated the Seventh Amendment and Article III. The court found that the FCC's imposition of civil penalties was akin to a common law action for money damages, which traditionally requires a jury trial. The court also determined that the public rights exception did not apply, as the action was closely related to common law negligence and did not fall within the historical categories of non-Article III adjudications.The court concluded that the FCC's process, which allowed for a section 504 trial only after the agency had already adjudicated the matter, did not satisfy the constitutional requirements. As a result, the Fifth Circuit granted AT&T's petition and vacated the FCC's forfeiture order. View "AT&T v. Federal Communications Commission" on Justia Law