Justia Constitutional Law Opinion Summaries

Several nonprofit, faith-based organizations that provide pregnancy-related services and oppose abortion initiated an action against the New York State Attorney General. These organizations had made statements regarding abortion pill reversal (“APR”), a protocol intended to counteract the effects of medication-induced abortion. After the Attorney General commenced a civil enforcement action in New York state court against other entities (not parties to this case) for making similar APR-related statements, the plaintiffs alleged they faced a credible threat of sanctions if they continued such speech. As a result, they stopped making APR-related statements and sought declaratory and injunctive relief in federal court, arguing that the regulation of their APR-related speech violated their First and Fourteenth Amendment rights.The United States District Court for the Western District of New York addressed the Attorney General’s argument that the federal court should abstain under the Younger v. Harris doctrine due to the parallel state enforcement action. The district court found abstention unwarranted, noting the federal claims were not inextricably intertwined with the state action and would not interfere with it. On the merits, the district court determined that the plaintiffs were likely to succeed on their First Amendment claim because the APR-related speech was noncommercial, religiously and morally motivated, involved no financial benefit or remuneration, and did not directly offer APR but instead provided information and referrals. Since the Attorney General did not show the state’s restrictions would survive strict scrutiny, the district court granted a preliminary injunction.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s order. The Second Circuit held abstention under Younger was not required, as the plaintiffs’ claims were independent of the state enforcement action. The court found no abuse of discretion in the grant of the preliminary injunction, agreeing that the plaintiffs’ APR-related speech was noncommercial and protected, and the Attorney General failed to meet the strict scrutiny standard. View "Nat'l Inst. of Fam. & Life Advocs. v. James" on Justia Law

A man who was not a member of a grand jury petitioned the Superior Court in Anchorage, Alaska, seeking to present information to a grand jury about alleged deficiencies and patterns of conduct within the Office of Children’s Services. He did not request a criminal indictment, but instead asked that the grand jury investigate certain matters of public welfare and safety. The Superior Court held hearings to clarify what he sought, but before the process concluded, the Alaska Supreme Court amended Criminal Rule 6.1, establishing a procedure for private citizens to submit concerns to the grand jury through the Attorney General.Following this amendment, the Superior Court vacated further hearings and instructed the petitioner to submit his request to the Department of Law as required by Rule 6.1(c). The petitioner did so and also appealed the Superior Court’s dismissal, arguing that the Alaska Supreme Court lacked authority to enact Rule 6.1(c) and that it improperly limited the grand jury’s constitutional powers.The Supreme Court of the State of Alaska considered the appeal. Using independent judgment for constitutional interpretation and reviewing the dismissal as a grant of summary judgment de novo, the Court held that the Alaska Constitution gives it broad rule-making authority over judicial procedure, including grand jury matters. The Court found that Rule 6.1(c) does not impermissibly suspend the grand jury’s investigatory power, nor does the Constitution guarantee individuals direct access to the grand jury. The Court also rejected claims that the rule violated statutory or common law rights and found no procedural defects in the rule’s promulgation. Accordingly, the Alaska Supreme Court affirmed the Superior Court’s denial of the man’s petition to follow a different process. View "Garber v. Superior Court, Third Judicial District" on Justia Law

A city in Alaska amended its zoning code through an ordinance designed to streamline permitting processes, reduce costs, and encourage development. The planning department reviewed the history of conditional use permits and identified certain uses that could be changed to permitted uses across multiple zoning districts. This proposed amendment underwent a series of public meetings and hearings before the city’s planning commission and city council. Notices about these meetings and the ordinance were published, and the ordinance was ultimately adopted by the city council after public participation and minor amendments.A resident challenged the ordinance in the Superior Court for the State of Alaska, Third Judicial District, Homer, claiming the city failed to comply with procedural requirements in its code, did not provide adequate public notice, and that the ordinance lacked a legitimate government purpose, violating substantive due process. He also argued the ordinance was unenforceable and objected to the award of attorney’s fees to the city. The superior court granted summary judgment in favor of the city, finding no genuine issues of material fact, and awarded attorney’s fees to the city, concluding that the city was the prevailing party and the plaintiff’s constitutional claims were frivolous.The Supreme Court of the State of Alaska reviewed the case. It held that the city code required only substantial, not strict, compliance with procedural rules and that the city had substantially complied. The court found the city’s public notices adequate and determined that the ordinance served a legitimate public purpose, rejecting claims of arbitrariness or vagueness. The court also upheld the award of attorney’s fees, finding no abuse of discretion, and concluded the constitutional claims were frivolous, thus not barring a fee award. The Supreme Court affirmed the superior court’s rulings on all issues. View "Griswold v. City of Homer" on Justia Law

A woman arrived at a hospital emergency room in the early morning, reporting that she had just been raped nearby. While waiting to be treated, she spoke with a police officer who asked her basic questions about the location, identity, and description of the perpetrator. The woman, visibly distressed and still processing the traumatic event, spontaneously provided additional details about the assault. Later, a Sexual Assault Nurse Examiner (SANE) conducted a medical exam, gathering information to both treat her and document injuries, and recorded the woman's statements about the assault in a standard report. The woman later died from unrelated causes.After the woman’s death, the State charged Arthur Wayne Najera with aggravated kidnapping and aggravated assault. Since the woman could not testify at trial, the State sought to admit her statements to both the officer and the nurse. Najera objected, arguing that admitting these statements would violate his Sixth Amendment Confrontation Clause rights and the rule against hearsay. The Third District Court, Salt Lake County, held several hearings and ultimately admitted both sets of statements, finding them nontestimonial and falling under the excited utterance and medical treatment exceptions to hearsay. Najera then petitioned for an interlocutory appeal.The Supreme Court of the State of Utah reviewed the interlocutory order. It held that the woman’s statements to the officer were nontestimonial because the primary purpose of the interaction was to assess the situation for immediate safety, not to collect evidence for prosecution. Those statements were also admissible as excited utterances. The court further held that the statements to the nurse were primarily for medical treatment under the circumstances and thus were also nontestimonial; they were admissible under the hearsay exception for medical diagnosis or treatment. The court affirmed the lower court’s rulings admitting both sets of statements. View "State v. Najera" on Justia Law

On the night of November 29, 2021, a Hattiesburg police officer conducted a traffic stop of a vehicle due to a defective tag light. The driver, unable to provide identification or insurance, was asked to exit the car. During a protective pat-down, the officer discovered a concealed firearm on the driver, who initially denied its presence. The officer then approached the passenger, Andrew Ducksworth, who stated he was paralyzed from the waist down. After requesting Ducksworth to raise his hands and initiating a pat-down, the officer felt a hard object between Ducksworth’s legs, which Ducksworth denied was a firearm. Upon further investigation and backup, officers found a loaded firearm in Ducksworth’s possession and learned he was a convicted felon.Ducksworth was charged in the United States District Court for the Southern District of Mississippi with being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). He moved to suppress the firearm, arguing the officer lacked reasonable suspicion for the pat-down, and also moved to dismiss the indictment on Second Amendment grounds. After a hearing, with officer testimony and corroborating body- and dash-cam footage, the district court denied both motions. At a bench trial, Ducksworth stipulated to all elements of the offense, presented no evidence, was found guilty, and sentenced to thirty-six months in prison and three years of supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the denial of the motions and the sufficiency of the evidence. The court held that, considering the totality of the circumstances—including the driver’s possession and concealment of a firearm, the high-crime area, and the officer’s safety concerns—there was reasonable suspicion for the pat-down. The court also held that Ducksworth’s stipulation satisfied the statutory element of a prior felony conviction and rejected his constitutional challenges, affirming the district court’s judgment in full. View "United States v. Ducksworth" on Justia Law

The case concerns challenges to groundwater replenishment charges imposed by a water district in a desert region where groundwater is the main source of potable water. The water district operates three areas of benefit (AOBs) and levies replenishment charges on customers who pump significant groundwater. Domestic customers do not pay these charges directly, but their payments for drinking water are allocated to the replenishment funds through the district’s enterprise fund system. Plaintiffs, including a taxpayer association, alleged that the replenishment charges were unconstitutionally structured, resulting in higher rates for certain AOBs and unfair subsidies for others, benefitting large agricultural businesses.The litigation began with a combined petition and class action in the Superior Court of Riverside County, which was dismissed because the court found the validation statutes applied and the statute of limitations had expired. Subsequent reverse validation actions for later fiscal years were timely filed and consolidated. The Superior Court, in rulings by two judges, found the replenishment charges to be unconstitutional taxes because they did not satisfy the requirements of California Constitution Article XIII C, Section 1, subdivision (e)(2). Specifically, the court found that the district failed to show the allocation of replenishment costs bore a fair or reasonable relationship to the burdens or benefits received by each AOB, and thus the charges were not exempt from being classified as taxes. The court awarded substantial refunds to affected ratepayers and enjoined the district from imposing similar unconstitutional charges in the future.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed both the district’s appeal of the remedies and liability findings and the taxpayer association’s cross-appeal on procedural grounds. The appellate court affirmed in full, holding that the replenishment charges were unconstitutional, the remedies were proper, and that the validation statutes applied to these charges, thus barring untimely claims for earlier years. The appellate court also found no error in the trial court’s grant of refund and injunctive relief. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

The case arises from the enactment of the 2017 Lesbian, Gay, Bisexual, and Transgender Long-Term Care Facility Residents’ Bill of Rights in California, which, among other things, prohibits staff at long-term care facilities from willfully and repeatedly failing to use a resident’s preferred name or pronouns after being clearly informed of them, when such conduct is based on the resident’s sexual orientation, gender identity, gender expression, or HIV status. The plaintiff, an association claiming taxpayer status, challenged this provision before it took effect, arguing that it was facially unconstitutional under the First Amendment.The Sacramento County Superior Court denied the petition for a writ of mandate, finding the pronouns provision to be a permissible, content-neutral restriction narrowly tailored to serve the state’s interest in preventing discrimination and harassment in long-term care facilities. The trial court rejected arguments that the law compelled speech or censored viewpoints, and found no First Amendment violation. On appeal, the California Court of Appeal, Third Appellate District, reversed in part. It held that the provision was content-based, subject to strict scrutiny, and was overinclusive, restricting more speech than necessary to achieve the government’s compelling interest in eliminating discrimination. The appellate court did not address standing.Upon review, the Supreme Court of California first concluded that the plaintiff lacked standing under the current version of Code of Civil Procedure section 526a, as amended in 2018, which limits taxpayer standing to suits against local, not state, entities. Nevertheless, due to the procedural posture and public importance, the court exercised its discretion to decide the merits. The Supreme Court of California held that the pronouns provision is a regulation of discriminatory conduct, not subject to First Amendment scrutiny as speech. Even if intermediate scrutiny applied, the law would be upheld. The court reversed the judgment of the Court of Appeal. View "Taking Offense v. State" on Justia Law

The plaintiffs, a microbrewery and its owner, operated a seasonal business in a tourist town and became known for engaging in political advocacy. The business applied for various permits to operate both an indoor retail outlet and, later, an outdoor beer garden. Despite being granted permits that included specific conditions—such as restrictions on outdoor operations—the plaintiffs repeatedly violated these conditions, operated without proper permits, and explicitly stated their intention to continue doing so regardless of regulatory decisions. Throughout this period, the owner was vocal in criticizing local officials on social media.After several rounds of permit applications, denials, suspensions, and revocations, the plaintiffs’ most recent permit application for an outdoor beer garden was denied by the county committee, which cited the plaintiffs’ ongoing and willful violations of permit conditions and their declared intent to continue such violations. The plaintiffs appealed administrative actions to the Oneida County Board of Adjustment, which upheld the revocations. Subsequently, the plaintiffs filed a lawsuit in the United States District Court for the Western District of Wisconsin, asserting that the permit denials and revocations constituted retaliation for protected political speech, in violation of the First Amendment. They sought a preliminary injunction to reinstate their permit and prevent further alleged retaliation.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the preliminary injunction and affirmed it. The Seventh Circuit held that, while the plaintiffs engaged in protected speech and suffered adverse permit actions, they failed to demonstrate a likelihood of success on the merits of their First Amendment retaliation claim. The court concluded that the permit denials and revocations were based on the plaintiffs’ repeated and admitted violations of permit conditions, not on retaliatory motives, and that the plaintiffs offered no evidence of disparate treatment or pretext. View "Minocqua Brewing Company LLC v Hess" on Justia Law