Justia Constitutional Law Opinion Summaries

Karla Smith and Holly Bladel sued Iowa state officials and the State of Iowa after Iowa opted out of federal unemployment programs established during the Covid-19 pandemic. These programs, created under the CARES Act, provided various unemployment benefits. Iowa initially participated in these programs but decided to end its participation in June 2021. Smith and Bladel claimed that this decision violated the U.S. Constitution, the Iowa Constitution, and Iowa state law.The United States District Court for the Southern District of Iowa dismissed the case, ruling that the defendants were immune from suit under the Eleventh Amendment and that the plaintiffs lacked a constitutionally protected property interest in the CARES Act benefits. Smith and Bladel appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Eleventh Amendment barred Smith's official-capacity claims against Iowa and its officials, as the claims did not fall under the Ex parte Young exception for ongoing violations of federal law. The court also found that Smith lacked a protected property interest in the CARES Act benefits because Iowa had the discretion to opt out of the programs. Consequently, Smith's due process claim against the Governor and Director in their individual capacities failed. Additionally, the court ruled that Smith's state law claim was barred by the Eleventh Amendment, and her request for declaratory relief was inappropriate as it sought to address past actions rather than future conduct. The court concluded that the district court correctly dismissed all of Smith's claims. View "Smith v. Reynolds" on Justia Law

David Herrera, Jr. pled guilty to aggravated robbery with a deadly weapon and was sentenced to five to eight years in prison by the district court, which recommended his placement in the Youthful Offender Transition Program (YOTP). Herrera filed a motion for sentence reduction upon nearing completion of the YOTP, asserting that the district court had promised to reduce his sentence if he successfully completed the program.The district court denied Herrera’s motion for sentence reduction without holding a hearing or providing an explanation. Herrera appealed, arguing that the district court abused its discretion and violated his constitutional rights by not honoring the promise made during sentencing.The Wyoming Supreme Court reviewed the case and found that the district court’s oral pronouncement at sentencing, which stated Herrera “will get a sentence reduction” if he completed the YOTP, constituted an express commitment. The court held that the district court abused its discretion by denying the motion for sentence reduction without justification, given the prior commitment. The Supreme Court reversed the district court’s decision and remanded the case for further sentencing proceedings consistent with its opinion. View "Herrera v. The State of Wyoming" on Justia Law

Mark Johnson was convicted by an Indiana jury of felony rape, felony criminal confinement, and misdemeanor battery. He appealed, arguing that the exclusion of certain DNA evidence and the destruction of the victim's blood sample before toxicology testing violated his Fourteenth Amendment due process rights. The Indiana Court of Appeals vacated his convictions for criminal confinement and battery on double jeopardy grounds but affirmed the rape conviction. Johnson's petition to transfer to the Indiana Supreme Court was denied. He then sought post-conviction review in state court and, after exhausting state remedies, sought federal habeas review under 28 U.S.C. § 2254.The United States District Court for the Southern District of Indiana denied Johnson's habeas petition, concluding that his DNA-related claim was procedurally defaulted and that the state court reasonably applied federal law in determining that the State had not acted in bad faith when discarding the blood sample. Johnson appealed to the United States Court of Appeals for the Seventh Circuit.The Seventh Circuit affirmed the district court's decision. The court held that Johnson's claim regarding the exclusion of DNA evidence was procedurally defaulted because he failed to raise it in his petition for transfer to the Indiana Supreme Court. Additionally, the court found that the Indiana Court of Appeals reasonably applied federal law in determining that the police had not acted in bad faith when disposing of the blood sample, as the evidence was only potentially exculpatory and there was no clear indication of bad faith. The court concluded that the state court's decision did not deviate from established federal law or constitute an unreasonable determination of the facts. View "Johnson v Sevier" on Justia Law

San Francisco operates a combined sewer system that collects and treats both wastewater and stormwater. In 1996, California voters approved Proposition 218, which added provisions to the California Constitution requiring voter approval for property-related charges, except for "sewer, water, and refuse collection services." Plaintiffs Robert Gluck and Adam Hertz filed a class action against the City and County of San Francisco, challenging the constitutionality of the City's sewer charges related to stormwater services. They argued that stormwater services funded by the City's sewer charges were not "sewer" services covered by the exception to Proposition 218's voter approval requirement and that the charges failed the proportionality requirement.The trial court sustained the City's demurrer without leave to amend, concluding that the City's combined sewer system provides "sewer" services falling within the voter approval exception of article XIII D, section 6(c). The court also found that the plaintiffs' fourth cause of action failed because it was based on the premise that stormwater management is not a "sewer service."The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court affirmed the trial court's judgment regarding the first three causes of action, agreeing that the City's combined sewer system provides "sewer" services exempt from the voter approval requirement. However, the court reversed the judgment regarding the fourth and fifth causes of action, concluding that the City did not establish that the plaintiffs' allegations regarding the City's reliance on wastewater factors to support charges for stormwater services were insufficient as a matter of law to establish a violation of the proportionality requirement of article XIII D, section 6(b)(3). The case was remanded for further proceedings on these claims. View "Gluck v. City and County of San Francisco" on Justia Law

Belinda Fitzpatrick owns two adjacent homes in Lansing, Michigan. In September 2021, Ingham County Animal Control received a complaint about Fitzpatrick harboring up to 30 chickens in unsanitary conditions. Officer Kyle Hanney from Animal Control investigated and observed severe unsanitary conditions, including a strong odor of ammonia and chicken feces throughout the house. Hanney obtained a warrant to search both homes for evidence of animal neglect and cruelty. He invited Matthew Simon, a local housing-code official, to join the search. Simon concluded that both homes were unfit for human occupancy and placed red tags on them, prohibiting entry until cleaned.Fitzpatrick sued Officer Hanney, Simon, and the City of Lansing, alleging violations of her Fourth and Fourteenth Amendment rights. Simon moved to dismiss based on qualified immunity. The United States District Court for the Western District of Michigan denied Simon’s motion, concluding that Simon had plausibly violated Fitzpatrick’s clearly established constitutional rights. Simon then filed an interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Simon was entitled to qualified immunity on Fitzpatrick’s Fourth Amendment claims because it was not clearly established that Simon needed a separate warrant for housing-code violations when he was searching for the same conditions as authorized by Hanney’s warrant. The court also held that Simon was entitled to qualified immunity on Fitzpatrick’s Fourteenth Amendment claims, as the unsanitary conditions in her homes constituted exigent circumstances justifying immediate eviction without prior notice. The court reversed the district court’s decision and remanded with instructions to dismiss the claims against Simon. View "Fitzpatrick v. Hanney" on Justia Law

Antonio Smith, an inmate at Green Bay Correctional Institution in Wisconsin, was on a prolonged hunger strike to protest prison conditions. After refusing to leave his cell for a wellness check, correctional officers used force to extract him for three consecutive days without incident. On the fourth day, Captain Jay Van Lanen used pepper spray, despite knowing Smith had a medical contraindication. Smith experienced severe respiratory distress and was placed naked in a cold cell for 23 hours.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the defendants, concluding that there were no Eighth Amendment violations. Smith appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that a jury could determine that the use of pepper spray and the conditions of Smith's confinement violated the Eighth Amendment. However, the court ultimately affirmed the district court's decision based on qualified immunity, which protects officials from liability unless they violated clearly established statutory or constitutional rights.The court held that while the actions of Captain Van Lanen and Lieutenant Retzlaff could be seen as excessive and lacking legitimate penological purpose, the specific rights violated were not clearly established at the time. Therefore, the defendants were entitled to qualified immunity. The court also found no evidence of excessive force during Smith's escort to the health unit, affirming summary judgment for the defendants on all claims. View "Smith v Kind" on Justia Law

Two Wichita police officers stopped Gina Wilson after observing her fail to signal properly. Wilson admitted her license was suspended and refused consent to search her vehicle. Officers called for a K-9 unit, which arrived nine minutes later. The dog, Oden, indicated the presence of drugs, leading officers to search the car and find 30 oxycodone pills. Wilson was arrested and charged with possession of an opiate and driving while suspended.Wilson moved to suppress the evidence, arguing the search violated the Fourth Amendment. The Sedgwick District Court denied the motion, finding no constitutional violation as the stop was not meaningfully extended. A jury convicted Wilson. The Kansas Court of Appeals affirmed, agreeing that the dog sniff did not extend the stop's duration and thus did not violate the Fourth Amendment.The Kansas Supreme Court reviewed the case, focusing on whether the search was permissible under the Fourth Amendment. The court held that a drug dog's sniff of a vehicle's exterior is not a search under the Fourth Amendment. Since Wilson's car was legally parked and she admitted to driving with a suspended license, the officers had probable cause to search the vehicle based on the dog's alert. The court affirmed the lower courts' rulings, concluding the search was constitutional and the evidence was properly admitted. View "State v. Wilson " on Justia Law

Media Matters for America and Eric Hananoki, a senior investigative reporter, filed a lawsuit against Warren Kenneth Paxton, Jr., in his official capacity as the Attorney General of Texas. The plaintiffs alleged that the Texas Office of the Attorney General launched a retaliatory campaign against them after they published an unfavorable article about X.com, a social media platform owned by Elon Musk. The article reported that corporate advertisements on X appeared next to antisemitic posts and that Musk endorsed an antisemitic conspiracy theory. Following the publication, the Texas Attorney General's office issued a civil investigative demand (CID) to Media Matters, requiring them to produce extensive records.The United States District Court for the District of Columbia granted the plaintiffs' motion for a preliminary injunction and denied Paxton's motion to dismiss for improper venue and lack of personal jurisdiction and subject matter jurisdiction. The court found that the investigation and CID constituted cognizable injuries sufficient to establish the plaintiffs' standing. The court concluded that the plaintiffs satisfied the requisite factors for a preliminary injunction, including a likelihood of success on the merits of their First Amendment retaliation claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the District Court's judgment. The appellate court held that Paxton was subject to personal jurisdiction in the District of Columbia because he purposefully directed actions at the plaintiffs in the District. The court also found that the plaintiffs' complaint raised a justiciable claim of First Amendment retaliation, as they alleged concrete and ongoing harms resulting from the retaliatory investigation. The court concluded that the District of Columbia was a proper venue for the action and that the District Court did not err in issuing the preliminary injunction. View "Media Matters for America v. Paxton." on Justia Law

Ryan Castaneira, a U.S. citizen, filed a Form I-130 petition to obtain permanent residency for his spouse, a Mexican national. USCIS issued a Notice of Intent to Deny the petition due to Castaneira's prior convictions in Georgia for crimes that appeared to qualify as "specified offenses against a minor" under the Adam Walsh Act. Castaneira argued that his convictions involved an undercover officer, not a minor, and thus should not be considered offenses against a minor. He also challenged the agency's use of the "beyond any reasonable doubt" standard to prove he posed no risk to his spouse.The United States District Court for the District of Columbia dismissed Castaneira's claims. The court held that his prior convictions fell within the statutory definition of "specified offense against a minor" and that the Adam Walsh Act's grant of "sole and unreviewable discretion" to USCIS precluded judicial review of the evidentiary standard applied by the agency. The court concluded that it lacked jurisdiction to review the standard of proof used by USCIS in making the no-risk determination.The United States Court of Appeals for the District of Columbia Circuit affirmed the District Court's ruling in part, agreeing that Castaneira's prior convictions were covered by the Adam Walsh Act. However, the appellate court vacated the District Court's jurisdictional ruling regarding the evidentiary standard. The court held that while USCIS's ultimate no-risk determinations are unreviewable, challenges to the agency's departure from its own binding precedent, such as the standard of proof, are reviewable under the Administrative Procedure Act. The case was remanded for further proceedings to determine whether USCIS violated its own precedent by applying the "beyond any reasonable doubt" standard. View "Castaneira v. Noem" on Justia Law

The Texas Attorney General alleged that Annunciation House, a nonprofit organization in El Paso, was unlawfully harboring illegal aliens. The Attorney General sought to examine the organization's records and initiate quo warranto proceedings, which could lead to the revocation of its charter. Annunciation House, which provides shelter to immigrants and refugees, was served with a records request by state officials, who demanded immediate compliance. Annunciation House sought legal relief, arguing that the request violated its constitutional rights.The 205th Judicial District Court in El Paso County granted a temporary restraining order and later a temporary injunction against the Attorney General's records request. The court also denied the Attorney General's motion for leave to file a quo warranto action, ruling that the statutes authorizing the records request were unconstitutional and that the allegations of harboring illegal aliens did not constitute a valid basis for quo warranto. The court further held that the statutes were preempted by federal law and violated the Texas Religious Freedom Restoration Act (RFRA).The Supreme Court of Texas reviewed the case on direct appeal. The court held that the trial court erred in its constitutional rulings and that the Attorney General has the constitutional authority to file a quo warranto action. The court emphasized that it was too early to express a view on the merits of the underlying issues and that the usual litigation process should unfold. The court also held that the statutes authorizing the records request were not facially unconstitutional and that the trial court's injunction against the Attorney General's records request was improper. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "PAXTON v. ANNUNCIATION HOUSE, INC." on Justia Law