Justia Constitutional Law Opinion Summaries

Stanley Felton, also known as G’esa Kalafi, was incarcerated at the Wisconsin Secure Program Facility from 2007 to 2015. He filed a pro se complaint under 42 U.S.C. § 1983 against several prison employees, alleging Eighth and Fourteenth Amendment violations due to his prolonged solitary confinement and First Amendment violations for the confiscation of his outgoing mail. Felton claimed that Warden Tim Haines and his successor Gary Boughton were responsible for his continued solitary confinement, and that three other officials, Lebbeus Brown, Joseph Cichanowicz, and Daniel Winkleski, illegally confiscated his mail.The United States District Court for the Western District of Wisconsin dismissed Felton’s Eighth and Fourteenth Amendment claims after screening the complaint and denied his motion to file an amended complaint. After discovery, the court granted summary judgment against Felton on his First Amendment claims, concluding that the prison officials were entitled to qualified immunity and that the confiscation of Felton’s mail did not violate his First Amendment rights.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decisions, holding that Felton did not adequately allege a Fourteenth Amendment due process violation, as the delayed review of his administrative confinement did not constitute a constitutional violation. The court also found that Felton had waived his Eighth Amendment claim on appeal by not sufficiently developing the argument. Regarding the First Amendment claims, the court concluded that the confiscation of Felton’s letter containing threatening language was justified and that the defendants were entitled to qualified immunity for retaining the state court order that accompanied the letter. The court emphasized that the defendants’ actions did not violate clearly established law. View "Felton v Brown" on Justia Law

Johnny Brown was born on August 27, 1998. On August 26, 2019, the State filed a delinquency petition in juvenile court alleging that Brown committed child molesting between June 1, 2015, and August 31, 2016. The juvenile court authorized the petition and held an initial hearing. After Brown turned twenty-one, he objected to the juvenile court's jurisdiction, but the court denied his objection and later waived the case to adult court. Brown was convicted of Class C felony child molesting in adult court.Brown filed a motion to correct error, arguing that the adult court lacked jurisdiction because he was over twenty-one at the time of the waiver hearing. The trial court denied his motion and sentenced him to four years, with credit for time served and the remainder suspended to probation. Brown appealed, and the Court of Appeals reversed his conviction, holding that retroactive application of new jurisdictional amendments would violate the ex post facto clause of the U.S. Constitution.The Indiana Supreme Court reviewed the case and concluded that the trial court lacked subject-matter jurisdiction at the time of Brown's trial because he fell into a jurisdictional gap identified in previous cases. The court also determined that the amendments to the jurisdiction statutes, enacted while Brown's case was pending, did not apply retroactively. As a result, the Indiana Supreme Court reversed Brown's conviction and remanded the case with instructions to dismiss for lack of subject-matter jurisdiction. View "Brown v. State" on Justia Law

A group of religious organizations employing nonimmigrant workers challenged a regulation by the United States Citizenship and Immigration Services (USCIS) that precludes special immigrant religious workers from filing their applications for special immigrant worker status and permanent resident status concurrently. The plaintiffs argued that this regulation violated the First and Fourteenth Amendments, the Religious Freedom Restoration Act (RFRA), the Immigration and Nationality Act (INA), and the Administrative Procedures Act (APA).The United States District Court for the Northern District of Illinois dismissed the APA claim as time-barred and granted summary judgment in favor of USCIS on the remaining claims. The court found that the regulation did not violate RFRA because it did not affect religious practice, and it did not violate the First Amendment because it was neutral and generally applicable. The court also ruled that the regulation did not violate the Due Process and Equal Protection Clauses because it was based on the risk of fraud in the special immigrant religious worker program.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the plaintiffs had standing to bring their claims and that their APA claim was not time-barred due to the Supreme Court's decision in Corner Post, Inc. v. Board of Governors of the Federal Reserve System, which held that a plaintiff’s challenge to a final agency action does not accrue under the APA until the plaintiff is injured by the action. The court remanded the APA claim for further proceedings.The Seventh Circuit affirmed the district court's decision on the RFRA and First Amendment claims, concluding that the regulation did not substantially burden the plaintiffs' religious exercise and was neutral and generally applicable. The court also affirmed the dismissal of the Establishment Clause claim, finding that the regulation did not overly burden the plaintiffs' religious practice. View "Society of the Divine Word v. United States Citizenship and Immigration Services" on Justia Law

The defendant, Erin Warren, was charged with first-degree assault for failing to seek medical attention for her daughter A.D.'s head wound, and second-degree assault for binding A.D.'s arms. A.D. was admitted to the hospital with a severe, infected head wound and other injuries. The hospital staff reported the case to the New Hampshire Division for Children, Youth and Families (DCYF) and the Rochester Police Department. A.D. was placed in foster care, where she disclosed further abuse by the defendant.The Superior Court allowed A.D. to testify via one-way video feed outside the defendant's presence, citing potential trauma to A.D. The jury convicted the defendant on both charges. The defendant appealed, arguing that her confrontation rights were violated, among other issues.The New Hampshire Supreme Court reviewed the case. It held that allowing A.D. to testify outside the defendant's presence violated the defendant's right to meet witnesses "face to face" under the New Hampshire Constitution. The court reversed the second-degree assault conviction, finding that A.D.'s testimony was crucial to that charge and its exclusion was not harmless. However, it affirmed the first-degree assault conviction, concluding that other overwhelming evidence supported the verdict.The court also addressed the admissibility of uncharged conduct evidence, finding no error in the trial court's decision to admit it to rebut the defense's suggestibility argument and explain A.D.'s delayed disclosure. The court upheld the trial court's determination of A.D.'s competency to testify and found no error in the in camera review of DCYF and Community Partners records. The case was remanded for further proceedings consistent with the opinion. View "State v. Warren" on Justia Law

The Human Rights Defense Center (HRDC) sought to mail its publications to inmates at the Baxter County Jail and Detention Center. HRDC's materials, which include books and magazines about prisoners' legal rights and criminal justice news, were rejected due to the jail's policy limiting non-legal mail to postcards. HRDC filed a lawsuit against Baxter County, claiming the policy violated its First and Fourteenth Amendment rights.The United States District Court for the Western District of Arkansas awarded partial summary judgment to HRDC on the due process claim, finding a technical violation of HRDC's right to notice. However, after a bench trial, the court held that the postcard-only policy did not violate HRDC's free speech rights. The Eighth Circuit Court of Appeals vacated and remanded the decision, requiring additional fact-finding on whether HRDC had alternative means to exercise its First Amendment rights.Upon remand, the district court found that the jail's policies effectively banned HRDC's publications and that allowing these publications would have a de minimis impact on jail operations. The court concluded that the policy was not reasonably related to legitimate penological objectives and violated HRDC's rights. It awarded HRDC nominal damages, a permanent injunction against the postcard-only policy as applied to publisher mail, and attorney fees and costs.The United States Court of Appeals for the Eighth Circuit affirmed the district court's judgment. The court held that the jail's postcard-only policy was not reasonably related to its penological goals and constituted an exaggerated response, effectively banning HRDC's publications. The court also upheld the award of attorney fees and costs to HRDC, finding no abuse of discretion in the district court's decisions. View "Human Rights Defense Center v. Baxter County Arkansas" on Justia Law

Amelia Baca, a 75-year-old woman with dementia, was fatally shot by Officer Jared Cosper in Las Cruces, New Mexico. On April 16, 2022, Baca's daughter called 911, reporting that Baca had become aggressive and threatened to kill her and her daughter. Officer Cosper, who was nearby, responded to the call. Upon arrival, he saw Baca holding knives and ordered her to drop them. Baca did not comply and took two slow steps towards Cosper, who then shot her twice, resulting in her death.The Estate of Amelia Baca filed a complaint in the United States District Court for the District of New Mexico, alleging that Officer Cosper used excessive force in violation of the Fourth Amendment. The district court granted summary judgment in favor of Cosper on qualified immunity grounds, concluding that the Estate had not raised a genuine dispute of material fact regarding Cosper's perception of an immediate threat.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court concluded that the district court erred in granting summary judgment. Viewing the evidence in the light most favorable to the Estate, the Tenth Circuit determined that a reasonable jury could find a Fourth Amendment excessive-force violation. The court also held that such a violation was clearly established under controlling law at the time of the shooting. Consequently, the Tenth Circuit reversed the district court's grant of summary judgment and remanded the case for further proceedings. View "Baca v. Cosper" on Justia Law

Petitioners Jason Fabrizius and Fabrizius Livestock LLC sought review of a USDA Judicial Officer's order that denied their appeal of two USDA ALJ orders. The ALJ found Fabrizius Livestock responsible for ensuring animals transported interstate had required documentation and issued a $210,000 fine against the company. Fabrizius Livestock, a Colorado corporation dealing in horses, often sold horses intended for slaughter and kept them in conditions that made them vulnerable to disease. The company sold horses across state lines without the necessary documentation, including ICVIs and EIA test results.The ALJ found Fabrizius liable for violations of the CTESA and AHPA regulations, including transporting horses without owner/shipper certificates and selling horses without ICVIs. The ALJ imposed a $210,000 fine, which included penalties for each violation. Fabrizius appealed to a USDA Judicial Officer, arguing that the regulation was unconstitutionally vague, they were not among the "persons responsible," they lacked adequate notice, the fine was arbitrary and capricious, and the fine was excessive under the Eighth Amendment. The Judicial Officer rejected these arguments and affirmed the ALJ's orders.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the regulation was not unconstitutionally vague and provided adequate notice. The court found that the term "persons responsible" reasonably included sellers like Fabrizius. The court also held that the $200,000 fine for the AHPA violations was not arbitrary or capricious, as the Judicial Officer had considered all relevant factors. Finally, the court found that the fine was not excessive under the Eighth Amendment, given the gravity of the violations and the potential harm to the equine industry. The court denied the petition for review. View "Fabrizius v. United States Department of Agriculture" on Justia Law

Michael Malinowski was sentenced to 150 months in prison followed by a lifetime of supervised release after pleading guilty to receiving child pornography. His release conditions included participating in sex-offender treatment, avoiding committing another crime, and not having deliberate contact with children. After moving to the Northern District of Illinois, Malinowski underwent a psychosexual assessment, leading to a recommendation that he refrain from accessing any pornography. A probation officer proposed modifying his supervised release conditions to include a prohibition on possessing or accessing any pornographic or sexually stimulating materials, which Malinowski accepted without a hearing.In 2022, Malinowski violated his supervised release by cashing a fraudulent check and failing to attend a therapy session. The district court did not revoke his release but warned him to comply with his conditions. A week later, Malinowski was found in a school with a child, violating his release conditions. The district court found him guilty of three violations and sentenced him to 12 months in prison, above the advisory range but below the statutory maximum. The court also modified his supervised release conditions, including a prohibition on possessing sexually stimulating materials and a condition barring children from entering his home.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed Malinowski's 12-month sentence, finding no procedural error. However, it vacated the two challenged supervised release conditions. The court found the condition barring possession of sexually stimulating materials to be overbroad and unconstitutional, requiring revision consistent with United States v. Adkins. The court also noted a conflict between the district court's oral pronouncement and written judgment regarding the condition barring children from entering Malinowski's home, requiring correction on remand. View "United States v Malinowski" on Justia Law

Scott Rendelman was convicted in 2008 for mailing threatening communications under 18 U.S.C. § 876(c). The district court instructed the jury that the government only needed to prove that a “reasonable person” would find Rendelman’s communications threatening. In 2023, the Supreme Court held in Counterman v. Colorado that the First Amendment requires the government to prove that the defendant was subjectively aware of the threatening nature of his statements. Rendelman now seeks authorization to file a successive 28 U.S.C. § 2255 motion to vacate his conviction based on this new ruling.Previously, the district court denied Rendelman’s first § 2255 motion, and the United States Court of Appeals for the Fourth Circuit declined to authorize a second § 2255 motion. Rendelman’s conviction was affirmed on direct appeal.The United States Court of Appeals for the Fourth Circuit reviewed Rendelman’s motion for authorization to file a successive § 2255 motion. The court concluded that Rendelman satisfied the gatekeeping requirements of 28 U.S.C. § 2255(h), as the Supreme Court’s decision in Counterman announced a new rule of constitutional law that applies retroactively and was previously unavailable to Rendelman. The court rejected the government’s argument that Rendelman must also show a plausible claim for relief, adhering to the standard that a prima facie showing of possible merit is sufficient. Consequently, the Fourth Circuit granted Rendelman’s motion for authorization to file a successive § 2255 motion. View "In re Rendelman" on Justia Law

Raymon Risner was charged with several drug trafficking and firearms offenses. He moved to dismiss the firearm-related counts, arguing that the statutes violated the Second Amendment. The district court denied his motion, and Risner pleaded guilty to conspiracy to distribute methamphetamine and possessing a firearm in furtherance of a drug trafficking offense. He retained the right to appeal the denial of his motion to dismiss and filed a timely appeal.The United States District Court for the Eastern District of Kentucky denied Risner’s motion to dismiss the firearm-related counts. Risner then pleaded guilty to conspiracy to distribute methamphetamine and possessing a firearm in furtherance of a drug trafficking offense. The district court dismissed the felon-in-possession charge pursuant to the plea agreement.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Risner lacked standing to challenge the constitutionality of 18 U.S.C. § 922(g)(1) because the charge was dismissed and there were no collateral consequences. The court also held that 18 U.S.C. § 924(c)(1)(A) did not violate the Second Amendment, as the statute’s restriction on using a firearm in furtherance of a drug trafficking crime was consistent with the Nation’s historical tradition of firearm regulation. The court concluded that the Second Amendment does not protect the possession of weapons for unlawful purposes, and Risner’s challenge failed. View "United States v. Risner" on Justia Law