Justia Constitutional Law Opinion Summaries

Jaylin Morton was indicted for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Morton moved to dismiss the indictment, arguing that the prosecution violated his Second Amendment rights. The district court denied his motion, and Morton conditionally pleaded guilty, retaining the right to appeal the denial of his motion to dismiss.The United States District Court for the Eastern District of Kentucky denied Morton’s motion to dismiss, reasoning that his prior felonies demonstrated that he was a serious and direct threat to public safety. The court concluded that § 922(g)(1) constitutionally applied to him. Morton then appealed the district court’s decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Morton’s criminal history, which included multiple violent offenses such as shooting at his ex-girlfriend and her family, and assaulting his then-girlfriend, demonstrated his dangerousness. The court applied the framework established in United States v. Williams, which allows for disarming individuals who are deemed dangerous based on their criminal history. The court concluded that Morton’s conviction was consistent with the Second Amendment as interpreted in Williams and affirmed the district court’s denial of Morton’s motion to dismiss the indictment. View "United States v. Morton" on Justia Law

Randell Shepherd, a career coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA), invoking the Act’s presumption that he was entitled to benefits due to his over fifteen years of mining and total disability from chronic obstructive pulmonary disease (COPD), bronchitis, and emphysema. Incoal, Inc., Shepherd’s most recent employer, contested his entitlement, arguing that his disability was caused by smoking, not mining. An administrative law judge (ALJ) found Incoal’s expert opinions unpersuasive and inconsistent with the Act’s regulations and preamble, which recognize pneumoconiosis as a latent and progressive disease. The ALJ ruled that Incoal failed to rebut the presumption that Shepherd was entitled to benefits. The Benefits Review Board (BRB) affirmed the ALJ’s decision.Incoal petitioned the United States Court of Appeals for the Sixth Circuit for review, arguing that the ALJ improperly relied on the regulatory preamble over their evidence and that the presumption was effectively irrebuttable, violating the Constitution and the Administrative Procedure Act (APA). The court reviewed the case de novo, focusing on whether the ALJ’s decision was supported by substantial evidence and correctly applied the law.The Sixth Circuit held that the ALJ was entitled to reference the preamble to assess the credibility of expert opinions and found that the ALJ’s decision was supported by substantial evidence. The court noted that the BLBA’s rebuttable presumption is constitutional, as it is based on a rational relationship between the length of a miner’s career and the risk of pneumoconiosis. The court concluded that Incoal’s arguments were unpersuasive and that the ALJ applied the correct legal principles. Consequently, the court denied Incoal’s petition for review. View "Incoal, Inc. v. OWCP" on Justia Law

The case involves the Pennsylvania Professional Liability Joint Underwriting Association (JUA), which was established by the General Assembly of the Commonwealth of Pennsylvania nearly fifty years ago to address a medical malpractice insurance crisis. The JUA acts as a professional liability insurer of last resort for high-risk medical providers and is funded solely by premiums paid by its policyholders. Over the years, the JUA has accumulated a surplus of about $300 million through investments. From 2016 to 2019, the Commonwealth attempted to transfer the JUA’s surplus to the General Fund or assume control of the JUA through legislative actions.The United States District Court for the Middle District of Pennsylvania reviewed the case multiple times. In 2017, the JUA sued the Governor after the enactment of Act 44, which mandated the transfer of $200 million from the JUA to the General Fund. The District Court granted a preliminary injunction and later summary judgment in favor of the JUA, holding that the JUA was a private entity and that the Act violated the Takings Clause. In 2018, after the enactment of Act 41, which placed the JUA under the control of the Insurance Department and mandated the transfer of all its assets, the JUA again sued. The District Court ruled in favor of the JUA, reiterating its earlier decision. In 2019, the JUA challenged Act 15, which required the JUA to be funded by the Commonwealth and categorized it as a Commonwealth agency. The District Court granted partial summary judgment for the JUA, holding that certain provisions of Act 15 constituted a regulatory taking and violated the First Amendment.The United States Court of Appeals for the Third Circuit reviewed the case and applied the principles from Trustees of Dartmouth College v. Woodward to determine whether the JUA is a public or private entity. The Court concluded that the JUA is a public entity because it was created to serve a public purpose, exercises the Commonwealth’s coercive power, and only the Commonwealth has a legally protectable interest in the JUA. Consequently, the JUA cannot assert constitutional claims against the Commonwealth. The Court reversed the District Court’s rulings in part, affirmed in part, and remanded for further proceedings. View "Pennsylvania Professional Liability Joint Underwriting Association v. Governor of Pennsylvania" on Justia Law

In 2018, the victim ended a five-year relationship with the defendant, who continued to send her text messages and occasionally parked near her home despite her efforts to avoid him. Two years later, the defendant sent the victim two text messages expressing anger and hurt. The next day, after an encounter at a fundraiser, the defendant sent another text message threatening to punch the victim.The defendant was convicted of violating the threatening to commit a crime statute in the New Bedford Division of the District Court Department. The Appeals Court affirmed the conviction, but the Supreme Judicial Court granted further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and found that the jury was not instructed to find that the defendant acted with the required mens rea, as established by the U.S. Supreme Court in Counterman v. Colorado. The Court held that the conviction violated the First Amendment because the jury was not instructed to find that the defendant consciously disregarded a substantial risk that his communication would be viewed as threatening violence. The Court also concluded that the threatening to commit a crime statute is not facially overbroad when construed to require proof of recklessness. The Court vacated the defendant's conviction and remanded the case for a new trial, allowing the Commonwealth to retry the defendant with proper jury instructions. View "Commonwealth v. Cruz" on Justia Law

Enriqueta Diaz, a former county judge and resident of Maverick County, opposed the issuance of certificates of obligation for water and sewer improvements by the Maverick County Commissioners Court. She collected signatures on a petition to force an election on the issue. Despite her petition, the commissioners decided to issue the certificates without holding an election. During the meeting, Diaz heckled the commissioners, leading County Judge English Cantu to hold her in contempt and order her removal. Diaz was detained outside in the rain for several hours and later sentenced to 24 hours in jail, though she was released without being confined.Diaz filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Texas, seeking damages for false imprisonment and bystander liability against County Judge English Cantu and three county commissioners. The district court denied the defendants' motion to dismiss, rejecting their claims of state sovereign immunity, judicial immunity, and qualified immunity. The defendants appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that constitutional county judges in Texas are not entitled to state sovereign immunity as they are considered local rather than state officers. The court also determined that English Cantu was not entitled to judicial immunity because he was acting in an administrative capacity, not a judicial one, during the commissioners court meeting. Additionally, the court found that English Cantu was not entitled to qualified immunity because he acted without discretionary authority in holding Diaz in contempt. However, the court reversed the district court's denial of qualified immunity for the commissioners on the bystander liability claims, as the law was not clearly established that they had a duty to intervene. The case was remanded for further proceedings. View "Diaz v. Cantu" on Justia Law

The American Civil Liberties Union Foundation of South Carolina (ACLU-SC) challenged the South Carolina Department of Corrections (SCDC) policy that prohibits personal contact interviews with inmates. ACLU-SC sought to record and publish interviews with death row inmate Marion Bowman, Jr., and another inmate, Sofia Cano, for a series of audio podcasts and written pieces. The SCDC policy, however, forbids such interviews. ACLU-SC filed a lawsuit alleging that the policy violates the First Amendment both facially and as applied to its planned interviews.The United States District Court for the District of South Carolina dismissed ACLU-SC’s complaint for failure to state a claim and denied its request for a preliminary injunction. The district court found that ACLU-SC has no First Amendment right to access prison inmates to conduct interviews for publication. The court relied on Supreme Court precedents that reject a claimed right to access and interview inmates, concluding that the Constitution does not mandate a right of access to government information or sources of information within the government’s control.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that ACLU-SC has no First Amendment right to interview and record SCDC inmates, as the policy does not place the press in any less advantageous position than the public generally. The court also rejected ACLU-SC’s facial challenge to the policy, finding that the policy does not prohibit a substantial amount of protected speech relative to its plainly legitimate sweep. The court concluded that the district court correctly dismissed ACLU-SC’s complaint and did not abuse its discretion in denying the preliminary injunction. View "American Civil Liberties Union Foundation of South Carolina v. Stirling" on Justia Law

Maverick Gaming LLC, a casino gaming company, filed a lawsuit challenging the State of Washington's tribal-state compacts that allow sports betting on tribal land. Maverick argued that these compacts violate the Indian Regulatory Gaming Act (IGRA), the Equal Protection Clause, and the Tenth Amendment. Maverick sought to invalidate the gaming compacts and amendments that permit sports betting on tribal lands, which would allow them to offer similar gaming activities at their cardrooms.The United States District Court for the Western District of Washington dismissed Maverick's lawsuit. The court found that the Shoalwater Bay Indian Tribe, which intervened for the limited purpose of filing a motion to dismiss, was a required party under Federal Rule of Civil Procedure 19(a). The court determined that the Tribe had a legally protected interest in the lawsuit that could be impaired or impeded in its absence. The court also concluded that the Tribe could not be feasibly joined in the litigation due to its sovereign immunity. Consequently, the court ruled that the litigation could not proceed in equity and good conscience without the Tribe and dismissed the case.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The Ninth Circuit agreed that the Tribe was a required party with a substantial interest in the legality of its gaming compact and sports betting amendment. The court also found that the federal government could not adequately represent the Tribe's interests, as their interests diverged in meaningful ways. The court held that the Tribe's sovereign immunity prevented its joinder, and the litigation could not proceed without the Tribe. The court rejected Maverick's argument that the public rights exception should apply, as the suit threatened the Tribe's legal entitlements and sovereignty. View "Maverick Gaming LLC V. United States" on Justia Law

Patricia Burnette Chastain was appointed as the clerk of superior court in Franklin County in May 2013 and was subsequently elected to the position in November 2013 and reelected in 2017. In July 2020, an attorney named Jeffrey Thompson filed an affidavit requesting an inquiry into Ms. Chastain's conduct, alleging various instances of misconduct, including distributing gift certificates to jurors, allowing a judicial candidate to address a jury, and acting unprofessionally with correctional officers, among other allegations.Judge John M. Dunlow initially suspended Ms. Chastain and set a hearing date. However, due to a conflict of interest, Judge Dunlow and another judge were recused, and Judge Thomas H. Lock was appointed to preside over the removal inquiry. After an evidentiary hearing, Judge Lock issued an order in October 2020 permanently removing Ms. Chastain from her position based on findings of willful misconduct. Ms. Chastain appealed, and the Court of Appeals vacated the order, holding that Judge Lock lacked authority under Article IV of the North Carolina Constitution to remove her and remanded the case for reconsideration under Article VI.The Supreme Court of North Carolina reviewed the case and held that Judge Lock had the authority to preside over the removal proceeding as a replacement for the recused senior regular resident superior court judge. The court also held that procedural due process requires that removal be based only on conduct identified in the initiating affidavit. Furthermore, the court clarified that the standard for removal under Article IV is "misconduct," not "willful misconduct." The Supreme Court vacated the Court of Appeals' decision and remanded the case for reconsideration of removal under the proper standards. The court also noted that discretionary review was improvidently allowed regarding the procedure for disqualification under Article VI. View "In re Chastain" on Justia Law

The case involves the father of a four-year-old child, Katy, who was initially placed with him by the Durham County Department of Social Services (DSS) after her mother, who had custody, was found to have substance abuse issues. DSS later discovered the father had a significant criminal history and was arrested for assault. Consequently, DSS recommended placing Katy with her paternal aunt and uncle, which the trial court approved. The trial court also found that both parents acted inconsistently with their constitutional rights as parents, although neither parent raised a constitutional claim during the trial.The Court of Appeals reviewed the case and, in a divided opinion, reversed the trial court's decision. The majority held that the trial court lacked authority to place Katy with anyone other than her father, as there were no allegations or findings that he was unfit or had acted inconsistently with his constitutional rights. The majority also ruled that the constitutional issue was preserved for appellate review because the father opposed DSS's recommendation. The dissent argued that the trial court's findings on the constitutional standard were premature and unnecessary.The Supreme Court of North Carolina reviewed the case and focused on whether the constitutional issue was properly preserved for appellate review. The Court held that a parent must explicitly raise a constitutional claim in the trial court to preserve it for appeal. Since the father conceded he did not argue the issue as a constitutional violation in the trial court, the Supreme Court determined the issue was not preserved. Consequently, the Court reversed the decision of the Court of Appeals, emphasizing the need for parents to inform the trial court and opposing parties of any constitutional challenges to ensure proper evidence is presented. View "In re K.C." on Justia Law

The National Collegiate Athletic Association (NCAA) conducted an investigation into the University of Mississippi's football program, which included allegations against Barney Farrar, an assistant athletics director. The NCAA found Farrar guilty of multiple recruiting violations and issued a five-year show-cause order, restricting his employment in recruiting roles at NCAA member institutions. Farrar appealed the decision, but the NCAA's Infractions Appeals Committee upheld the findings and penalties.Farrar then filed a lawsuit in the Circuit Court of Lafayette County, alleging negligence, denial of a fair hearing, malicious interference with employment, denial of due process under the Mississippi Constitution, and usurpation of judicial function. The trial court granted summary judgment in favor of the NCAA on all claims except for malicious interference with employment and denial of due process. The NCAA petitioned for an interlocutory appeal on these two issues.The Supreme Court of Mississippi reviewed the case and applied a de novo standard of review. The court held that the NCAA is not a state actor and thus not subject to due process requirements under the Mississippi Constitution. The court also found that Farrar failed to provide evidence of malice necessary to support his claim of malicious interference with employment. Consequently, the court reversed the trial court's denial of summary judgment and rendered judgment in favor of the NCAA. View "National Collegiate Athletic Association v. Farrar" on Justia Law