Justia Constitutional Law Opinion Summaries

On June 15, 2021, two individuals in Portland, Maine reported being struck from behind by a man who inflicted a sharp pain, with one sustaining a wound on her back. The assailant was described as an African-American male with short spiky hair, wearing a green shirt, and carrying a backpack and tablet. Police identified Saad Zackaria as the likely suspect and located him at the Preble Street Resource Center, where staff permitted officers to enter. Zackaria was found fully dressed near the shower room; after he reentered the shower room with the door partially open, officers observed various sharp objects on the floor, including tweezers, a box cutter, and a wire. Zackaria was subsequently arrested.Following his arrest, Zackaria was charged in June 2021 and indicted in August. The Cumberland County Unified Criminal Docket found him incompetent to stand trial in August 2021, but competency was restored in March 2022. Pretrial motions, including a motion to suppress evidence, were denied after a hearing. Delays arose from counsel withdrawal, attorney illness, and a mistrial due to juror unavailability. Zackaria filed motions to dismiss for delay and for a new bail hearing, both denied in early January 2024. After a jury trial in January 2024, Zackaria was found guilty of aggravated assault with a dangerous weapon and two counts of assault with a dangerous weapon and received a sentence including incarceration and probation.The Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that Zackaria did not have an objectively reasonable expectation of privacy in the shower room or common area of the shelter under the Fourth Amendment, due to the circumstances of his use and the openness of the space. Additionally, the Court found no abuse of discretion in the trial court’s denial of the speedy trial claim, noting that most delays were not attributable to the State or Zackaria, and that the lengthy pretrial detention did not prejudice the defense. View "State of Maine v. Zackaria" on Justia Law

Deputy Brian Williams responded to a domestic-violence call at Tina Hight’s residence, where two dogs ran out toward him as Hight opened her door. Williams shouted warnings and fired a shot that caused the dogs to retreat. As Hight attempted to bring her dogs inside, a small Pomeranian mix ran toward Williams, prompting him to fire again in the dog’s direction. The shot missed the dog but ricocheted and struck Hight, leaving a bullet fragment in her leg.Hight filed suit in the United States District Court for the Western District of Arkansas, alleging excessive force under 42 U.S.C. § 1983 and the Fourth and Fourteenth Amendments. The district court granted summary judgment to Deputy Williams on the basis of qualified immunity, concluding that Williams did not violate Hight’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo, making all reasonable inferences in favor of Hight. The appellate court considered whether Deputy Williams’s actions constituted a Fourth Amendment seizure of Hight. Applying the requirement that a seizure by force must involve an officer’s objectively manifested intent to restrain the person affected, the court found no evidence that Williams intended to restrain Hight; his actions and statements were aimed at stopping the dog. The court held that accidental force, or force directed at another target, does not satisfy the Fourth Amendment’s seizure standard as articulated in Torres v. Madrid and related precedents.The Eighth Circuit affirmed the district court’s judgment, holding that Deputy Williams did not seize Hight within the meaning of the Fourth Amendment and thus did not violate her constitutional rights. The court declined to address arguments raised for the first time on appeal. View "Hight v. Williams" on Justia Law

Petitioners are owners and residents of units in SoHo and NoHo buildings designated under New York City’s Joint Living-Work Quarters for Artists (JLWQA) program, which, since 1971, has limited legal occupancy to certified artists or those who obtained amnesty through later amendments. In 2021, the City rezoned the area, allowing JLWQA units to be voluntarily converted to unrestricted residential use upon payment of a one-time fee calculated by square footage. The fee supports an arts fund. Petitioners challenged this fee, claiming it was an unconstitutional condition and a taking under the Fifth Amendment.The case was first heard in New York Supreme Court, which dismissed the petition, finding that the fee was a monetary obligation not subject to the Takings Clause. The Appellate Division, First Department, reversed, holding that the fee was a permit condition subject to heightened scrutiny under the Nollan and Dolan unconstitutional conditions doctrine. The court found that the City failed to show the fee had an essential nexus to a legitimate governmental interest or was roughly proportional to any harm caused by conversion, declared the fee unconstitutional, and enjoined its enforcement.The New York Court of Appeals reviewed the case and reversed the Appellate Division’s order. The Court of Appeals held that petitioners did not have a compensable property interest within the meaning of the Takings Clause regarding the opportunity to convert their JLWQA units. The fee did not constitute a taking because it did not diminish or extinguish existing property rights, nor was it imposed in lieu of a direct appropriation of property. The Court further clarified that a standalone monetary fee for conversion does not implicate the Takings Clause and that heightened scrutiny under Nollan/Dolan only applies to direct exactions or in-lieu-of-property conditions. Judgment was granted for the City. View "Matter of Coalition for Fairness in Soho & Noho, Inc. v City of New York" on Justia Law

After Oklahoma entered into a Master Settlement Agreement with the tobacco industry in 1998, the state created the Tobacco Settlement Endowment Trust Fund (TSET) through a constitutional amendment approved by voters in 2000. TSET was established to manage and disburse funds from the settlement for health-related programs, especially those targeting tobacco prevention and cessation. The TSET Board of Directors was designed to be independent, with seven members appointed by various state officials for staggered, fixed seven-year terms, ensuring geographic and political diversity and preventing control by any single authority.During the 2025 legislative session, the Oklahoma Legislature passed HB 2783, amending the statute governing the TSET Board. The new law allowed directors to serve at the pleasure of their appointing authority, subject to a maximum seven-year term, effectively converting the Board members’ tenure from fixed terms to at-will appointments. TSET challenged this amendment, claiming it violated the Oklahoma Constitution’s requirement for fixed seven-year terms.The Supreme Court of the State of Oklahoma reviewed the case in its original jurisdiction because of its statewide importance and the need for a prompt decision. The Court found the constitutional language in Article X, Section 40(D) to be clear and unambiguous, requiring staggered, fixed seven-year terms for TSET directors with no provision for at-will removal. The Court held that HB 2783 was unconstitutional because it conflicted with the constitutional mandate for fixed terms and undermined the independence of the Board. Accordingly, the Court granted declaratory relief, invalidating HB 2783. View "TOBACCO SETTLEMENT ENDOWMENT TRUST FUND v. STITT" on Justia Law

Wilson and two associates attempted to purchase a firearm from D.J. at a gas station, only to discover that the firearm was fake. In retaliation, Wilson retrieved a handgun modified with a machinegun conversion device and an extended magazine from his vehicle. He confronted D.J. and fired multiple rounds, fatally wounding him. Wilson and his companions then robbed D.J. and fled the scene. Police subsequently located Wilson, who confessed to the shooting and acknowledged the weapon was equipped with a machinegun conversion device.Wilson was charged in the United States District Court for the Northern District of Texas with unlawful possession of a machinegun under 18 U.S.C. § 922(o). He moved to dismiss the indictment, arguing that § 922(o) violated the Second Amendment, but the district court denied the motion. Wilson pleaded guilty without a written plea agreement. At sentencing, the Presentence Investigation Report applied the Sentencing Guidelines cross-reference to second-degree murder due to the death resulting from Wilson's conduct, resulting in a recommended sentence of 120 months, the statutory maximum. Wilson objected, claiming the cross-reference failed to account for his self-defense claim, but the district court overruled his objection, adopted the PSR, and imposed the recommended sentence.The United States Court of Appeals for the Fifth Circuit reviewed Wilson’s appeal. He challenged his conviction on Second Amendment grounds and the application of the second-degree murder cross-reference during sentencing. The Fifth Circuit held that circuit precedent, specifically Hollis v. Lynch, forecloses any Second Amendment protection for machineguns, and that Supreme Court precedent in New York State Rifle & Pistol Association, Inc. v. Bruen does not overrule this holding. The court also found no plain error in the district court’s application of the second-degree murder cross-reference. The Fifth Circuit affirmed the district court’s judgment. View "United States v. Wilson" on Justia Law

In 1989, a man committed a brutal murder at a Kentucky laundromat, killing a 61-year-old employee after she asked him to leave. After his arrest, he was charged with several crimes, including murder. Five years later, he pleaded guilty to all charges. He sought to have a judge, rather than a jury, decide his sentence, hoping for a more favorable outcome due to the nature of his crimes. After a series of legal maneuvers and a failed attempt to withdraw his guilty plea, a judge ultimately sentenced him to death, despite the presentation of significant mitigating evidence about his abusive childhood and mental health struggles.On direct appeal, the Kentucky Supreme Court affirmed both his conviction and sentence, rejecting his arguments that his guilty plea was not knowing and voluntary and that the sentencing court had failed to consider all mitigating evidence. The court found that while the trial court’s plea colloquy did not specifically enumerate every right waived by pleading guilty, it was sufficient to show that the defendant understood the consequences. The court also concluded that the sentencing judge had considered all mitigating evidence, even if he found it unpersuasive.After exhausting state postconviction remedies, the petitioner filed a federal habeas corpus petition in the United States District Court for the Eastern District of Kentucky, raising multiple grounds for relief. The district court denied relief and declined to issue a certificate of appealability. The United States Court of Appeals for the Sixth Circuit granted a limited certificate and reviewed two claims de novo: whether the plea was knowing and voluntary, and whether the trial court failed to consider mitigating evidence.The Sixth Circuit held that the Kentucky Supreme Court had not unreasonably applied clearly established federal law in either respect. The record affirmatively demonstrated the petitioner’s understanding of his rights, and the sentencing court’s consideration of mitigation evidence was constitutionally adequate. Accordingly, the Sixth Circuit affirmed the district court’s denial of habeas relief. View "Johnson v. Plappert" on Justia Law

Several individuals who reside in DeKalb County, Georgia, outside the city limits of Atlanta, opposed the construction of a new public safety training facility on city-owned land and wished to collect signatures for a referendum petition to repeal the city ordinance authorizing the lease for the facility. Atlanta’s municipal code required that signature gatherers for such petitions be residents of the City of Atlanta. Because they did not meet this residency requirement, the plaintiffs filed suit against the City, arguing that the restriction violated their First Amendment rights. They sought a preliminary injunction to prevent enforcement of the residency requirement, as well as other relief connected to the signature collection process.The United States District Court for the Northern District of Georgia granted the preliminary injunction, enjoining Atlanta from enforcing the residency requirement for signature gatherers. The court also ordered the City to issue new petitions without the residency restriction and restarted the 60-day signature collection period, while counting previously collected signatures. The City appealed the injunction and obtained a stay from the United States Court of Appeals for the Eleventh Circuit.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs failed to demonstrate irreparable harm sufficient for injunctive relief. The court specified that, under Kemp v. City of Claxton, 496 S.E.2d 712 (Ga. 1998), Georgia law does not allow the use of a referendum petition to challenge or repeal a city ordinance unless it amends the city charter. Because the plaintiffs could not lawfully utilize the referendum process for their intended purpose, they lacked a right to the process and consequently could not show irreparable injury. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings. View "Baker v. City of Atlanta" on Justia Law

A group of eleven current and former employees of the Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority challenged the Authority’s COVID-19 vaccine mandate, which required all employees to be fully vaccinated unless they qualified for a medical or religious exemption. The policy allowed for exemptions if an employee provided sufficient medical documentation or demonstrated a sincerely held religious belief, provided that reasonable accommodations could be made without undue burden to the Authority. Thirteen employees applied for religious exemptions, but only the request of one fully remote employee was granted. One employee received a temporary medical exemption but was ultimately terminated after refusing vaccination once that exemption expired. Four appellants later became vaccinated and remained employed; the remaining seven were fired for noncompliance.After the Authority enacted its policy, the plaintiffs filed suit, alleging violations of their rights under the Massachusetts Declaration of Rights, the First and Fourteenth Amendments, and Massachusetts anti-discrimination law. The state court initially granted a temporary restraining order, but after removal to the United States District Court for the District of Massachusetts, the district court denied their preliminary injunction request. On a prior appeal, the United States Court of Appeals for the First Circuit affirmed the denial as to most claims but remanded for further consideration of the First Amendment claim, instructing the district court to address the relevance of the granted medical exemption and to determine the appropriate level of scrutiny.On remand, the district court again denied a preliminary injunction, finding the policy to be generally applicable and thus subject to rational basis review, which it held the policy satisfied. The United States Court of Appeals for the First Circuit affirmed, holding that the policy’s medical and religious exemptions were not comparable for Free Exercise purposes, the policy was generally applicable, and the Authority’s interests justified the mandate under rational basis review. View "Brox v. Woods Hole, Martha's Vineyard & Nantucket Steamship Authority" on Justia Law

Ali Al-Timimi, a respected lecturer at an Islamic center in Virginia, became acquainted with a group of young Muslim men who engaged in activities including paintball, which some saw as preparation for “jihad in the form of combat.” While Al-Timimi did not directly participate in these preparations, he offered advice on discretion after FBI attention. Following the September 11, 2001 attacks, Al-Timimi attended a gathering where he urged attendees to repent, leave the United States, and join militant groups abroad, including Lashkar-e-Taiba (LET) in Pakistan. His statements inspired several individuals to make concrete plans to travel overseas for training, though he did not provide operational details or set timelines. Some group members subsequently traveled to Pakistan but did not engage in combat.The United States District Court for the Eastern District of Virginia indicted and convicted Al-Timimi on multiple counts, including conspiracy, solicitation, and aiding terrorist groups. He was sentenced to life imprisonment and other consecutive terms. Over two decades, his case saw numerous appeals and remands, including vacatur of certain counts based on changes in law regarding “crimes of violence” (as in Johnson v. United States and United States v. Davis). Ultimately, Al-Timimi appealed his remaining convictions (Counts 2–6, 9, and 10), asserting First Amendment protection for his speech.The United States Court of Appeals for the Fourth Circuit reviewed de novo whether Al-Timimi’s speech constituted unprotected incitement, solicitation, or facilitation of criminal acts. The court held that his speech, though inflammatory and disturbing, did not incite imminent lawless action nor did it intentionally solicit or assist a specific crime. As his advocacy did not meet the narrow exceptions to First Amendment protection, the court vacated Al-Timimi’s remaining convictions and remanded for judgments of acquittal. View "US v. Al-Timimi" on Justia Law

Police in Milwaukee searched Michael Yumang’s car and home in 2019 and 2022, finding distribution quantities of methamphetamine, a handgun, and ammunition. Before the 2022 search, a postal inspector intercepted a package containing a quarter pound of meth addressed to Yumang’s residence from California. Yumang admitted to regularly obtaining meth from California and reselling it in Wisconsin. He was charged with three drug-trafficking offenses related to each meth seizure and the intercepted shipment, as well as unlawful possession of a firearm in furtherance of a drug crime.After an indictment and pretrial proceedings, Yumang waived his right to a jury trial and had a bench trial in the United States District Court for the Eastern District of Wisconsin. The government called multiple witnesses, including three forensic chemists who analyzed the seized meth, confirming its purity and quantity. Prior to trial, the government disclosed—subject to a protective order—that the DEA chemist who tested the 2019 meth had been placed on a performance improvement plan in 2023. At trial, Yumang’s attorney sought to cross-examine the chemist about the plan, but the judge ruled the information irrelevant since the performance issues arose years after the chemist’s work on the case. The judge found Yumang guilty on all counts and imposed a sentence of 180 months.On appeal to the United States Court of Appeals for the Seventh Circuit, Yumang argued that briefly closing the courtroom to make a record of the sidebar discussion about the chemist’s performance plan violated his Sixth Amendment right to a public trial, and that the exclusion of the proposed cross-examination was both evidentiary error and a Confrontation Clause violation. The Seventh Circuit held that the five-minute courtroom closure was too trivial to constitute a Sixth Amendment violation and that excluding the cross-examination was neither an evidentiary nor constitutional error. The court affirmed the judgment. View "USA v Yumang" on Justia Law