Justia Constitutional Law Opinion Summaries

A developer purchased a historical property in Newton, Massachusetts, and began restoration work. The Newton Historical Commission issued a stop-work order, claiming the developer violated the permit by demolishing large portions of the building. The developer, 29 Greenwood, LLC, disagreed but complied with the order and submitted revised proposals, all of which were denied. The developer then filed a lawsuit, alleging a violation of the Takings Clause of the U.S. Constitution and state law.The case was initially filed in state court but was removed to the U.S. District Court for the District of Massachusetts. The district court dismissed the complaint, ruling that the dispute was a typical zoning issue not rising to the level of a constitutional taking. The developer appealed the dismissal, arguing that the Commission acted in bad faith and would never permit the reconstruction.The United States Court of Appeals for the First Circuit reviewed the case. The court noted that two related actions were pending in state court, which could potentially resolve or narrow the federal constitutional issues. The court decided to abstain from ruling on the federal issues until the state court proceedings concluded, invoking the Pullman abstention doctrine. The court vacated the district court's dismissal and remanded the case with instructions to stay the federal proceedings pending the outcome of the state court cases. Each party was ordered to bear its own costs. View "29 Greenwood, LLC v. City of Newton" on Justia Law

Kelly Patrick Donaldson was convicted of second-degree rape in 2005 and became subject to the Sex Offenders Registration Act (SORA). At that time, SORA did not prohibit sex offenders from residing near parks. The Oklahoma Legislature later amended the law to prohibit sex offenders from living within 2,000 feet of a city park. In 2021, Donaldson sought to live in El Reno, Oklahoma, but was informed by the police that the property he intended to purchase was within 310 feet of a city park, violating the amended residency restrictions.The District Court of Canadian County granted summary judgment in favor of Donaldson, ruling that applying the 2019 residency restrictions to him violated the ex post facto clauses of the federal and state constitutions. The court found that the version of SORA in effect at the time of Donaldson's conviction should apply, which did not include the park residency restriction.The Supreme Court of the State of Oklahoma reviewed the case and reversed the lower court's decision. The court held that the residency restrictions in 57 O.S.Supp.2019, § 590(A) do not amount to punishment and therefore do not violate the ex post facto clause. The court determined that the legislative intent behind SORA was civil and regulatory, aimed at protecting the public and reducing recidivism, rather than punitive. Consequently, the current residency restrictions apply to all sex offenders, regardless of when they became subject to SORA. The case was remanded for further proceedings to determine whether Lake El Reno qualifies as a park under the statute and if the property in question falls within the restricted area. View "DONALDSON v. CITY OF EL RENO" on Justia Law

The case involves three consolidated appeals concerning the constitutionality of the Child Victims Act of 2023, which retroactively eliminated the statute of limitations for child sexual abuse claims. The plaintiffs, who are alleged survivors of childhood sexual abuse, filed lawsuits against various institutions, including the Roman Catholic Archbishop of Washington, the Board of Education of Harford County, and The Key School, Inc. The defendants argued that the 2023 Act unconstitutionally abrogated their vested rights by reviving claims that were previously time-barred.In the Circuit Court for Prince George’s County, the court denied the Archbishop’s motion to dismiss, determining that the relevant statute was a statute of limitations, not a statute of repose, and thus did not create vested rights. The Circuit Court for Harford County reached a similar conclusion regarding the Board of Education of Harford County. In the United States District Court for the District of Maryland, the court certified the question of the 2023 Act’s constitutionality to the Supreme Court of Maryland without ruling on The Key School’s motion to dismiss.The Supreme Court of Maryland held that the 2017 statute, which the 2023 Act amended, was a statute of limitations rather than a statute of repose. The court reasoned that the statute of limitations is a procedural device that does not create vested rights, whereas a statute of repose creates substantive rights that cannot be retroactively abrogated. The court concluded that the 2023 Act did not retroactively abrogate vested rights and was constitutional as applied to the defendants. The court applied heightened rational basis review and found that the 2023 Act bore a real and substantial relation to addressing the problem of delayed reporting of child sexual abuse and the need for justice for survivors. The judgments of the lower courts were affirmed, and the certified question was answered in the negative. View "Archbishop of Washington v. Doe" on Justia Law

Rhonda Fleming, an inmate at Federal Correctional Institution Tallahassee (FCIT), filed a pro se lawsuit against Warden Erica Strong and the United States, alleging Eighth Amendment violations due to her exposure to mold, asbestos, and COVID-19, which she claimed caused severe health issues. Fleming sought injunctive relief and damages under Bivens and the Federal Tort Claims Act (FTCA). She alleged that despite her complaints, the prison officials, including Warden Strong, failed to address the hazardous conditions, leading to her contracting COVID-19 twice and requiring hospitalization.The United States District Court for the Northern District of Florida partially granted and partially denied the defendants' motion to dismiss. The magistrate judge recommended dismissing most of Fleming's claims, including all claims against Strong, citing that Bivens did not provide a remedy for her Eighth Amendment claim. However, the district court disagreed, finding that Fleming's Eighth Amendment claim was similar to a previously recognized Bivens claim and allowed it to proceed. The district court did not address the issue of qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court had to determine whether it had jurisdiction to hear an interlocutory appeal from the district court's order recognizing a Bivens cause of action. The Eleventh Circuit joined four other circuits in holding that the collateral-order doctrine does not extend to Bivens-extension orders that do not address qualified immunity. The court emphasized that qualified immunity adequately protects government officials from the burdens of litigation and that separation-of-powers concerns with Bivens extensions do not justify immediate appeal. Consequently, the Eleventh Circuit dismissed the appeal for lack of jurisdiction. View "Fleming v. FCI Tallahassee Warden" on Justia Law

Corrigan Clay, an American citizen, pleaded guilty to sexually abusing his minor adopted daughter while living in Haiti, violating 18 U.S.C. § 2423(c). Clay argued that Congress lacked the power to enact § 2423(c), which criminalizes illicit sexual conduct by U.S. citizens abroad. He contended that his non-commercial conduct did not fall under Congress's authority to regulate foreign commerce or its treaty power.The United States District Court for the Western District of Pennsylvania denied Clay's motion to dismiss the indictment, ruling that § 2423(c) was a constitutional exercise of Congress's power to regulate the channels of foreign commerce. The court did not address the treaty power arguments. Clay then pleaded guilty without a plea agreement and was sentenced to 235 months' imprisonment, the bottom of the Sentencing Guidelines range. He appealed, challenging the constitutionality of § 2423(c) and the procedural and substantive reasonableness of his sentence.The United States Court of Appeals for the Third Circuit reviewed the case and upheld the District Court's decision. The Third Circuit held that § 2423(c) is a permissible exercise of congressional power under both the Foreign Commerce Clause and the Necessary and Proper Clause. The court reasoned that Congress has broader authority to regulate foreign commerce than interstate commerce, and § 2423(c) fits within this power as it regulates the channels of foreign commerce and activities that substantially affect foreign commerce. Additionally, the court found that § 2423(c) is rationally related to implementing the Optional Protocol to the United Nations Convention on the Rights of the Child on the Sale of Children, Child Prostitution, and Child Pornography, thus falling under the Necessary and Proper Clause.The Third Circuit also found no procedural or substantive errors in Clay's sentencing, affirming the District Court's judgment. The court concluded that the sentence was reasonable and appropriately reflected the seriousness of the offense, the need for just punishment, deterrence, and rehabilitation. View "USA v. Clay" on Justia Law

The case involves a proposed charter amendment in Baltimore City, known as the Baby Bonus Amendment, which would mandate a one-time payment of at least $1,000 to every eligible city resident upon the birth or adoption of a child. The Maryland Child Alliance, Inc. sponsored the petition for this amendment, which was certified by the Baltimore City Board of Elections for inclusion on the ballot for the November 2024 Presidential General Election.The Mayor and City Council of Baltimore, along with other city officials, filed a lawsuit in the Circuit Court for Baltimore City against the Baltimore City Board of Elections and the State Board of Elections, seeking judicial review, a writ of mandamus, declaratory judgment, and an injunction to prevent the Baby Bonus Amendment from being placed on the ballot. The circuit court granted the City’s motion for summary judgment, declaring the Baby Bonus Amendment unconstitutional as it violated Article XI-A, § 3 of the Maryland Constitution by removing meaningful discretion from the City over an area within its legislative purview and being legislative in nature rather than proper charter material.The Supreme Court of Maryland reviewed the case and affirmed the circuit court’s decision. The Court held that the Baby Bonus Amendment did not concern the form or structure of government and encroached upon the City’s police or general welfare powers, thus violating Article XI-A, § 3 of the Maryland Constitution. The Court also declined to sever the mandatory payment provision from the amendment, concluding that the dominant purpose of the amendment would not be achieved without the $1,000 payment provision, which abrogated the City’s law-making authority in violation of the Constitution of Maryland. View "Baltimore City Board of Elections v. Mayor and City Council of Baltimore" on Justia Law

The defendant, a police captain in the West Springfield police department, was found guilty of obtaining an unwarranted privilege with fraudulent intent by using over $1,000 from the police department's evidence room to pay his home mortgage. The defendant was sentenced to a one-year term of probation. He appealed his conviction on the grounds that the statutes under which he was convicted were unconstitutionally vague and that the evidence was insufficient to prove he acted with fraudulent intent or that the unwarranted privilege had a fair market value of over $1,000 in any twelve-month period.The Superior Court denied the defendant's pretrial motion to dismiss the indictment. After a jury-waived trial, the trial judge found the defendant guilty and denied his motion for a required finding of not guilty. The defendant then appealed to the Supreme Judicial Court of Massachusetts.The Supreme Judicial Court affirmed the conviction, holding that the statutes in question were not unconstitutionally vague. The court found that the terms "unwarranted privilege" and "fraudulent intent" provided sufficient notice of prohibited conduct to a person of reasonable intelligence. The court also concluded that the evidence was sufficient to prove the defendant acted with fraudulent intent, as he had secreted money from the evidence room to pay his mortgage and made false statements to investigators. Additionally, the court determined that the fair market value of the unwarranted privilege exceeded $1,000, based on the face value of the money taken from the evidence room. View "Commonwealth v. Spaulding" on Justia Law

The Coachella Valley Water District (Water District) appealed a judgment finding that the rates it charged for Coachella Canal water violated Article XIII C of the California Constitution. The Water District argued that the rates were lawful and that no refund remedy was authorized. The court rejected both arguments, finding the rates unlawful and that a refund remedy was constitutionally mandated.In the lower court, the Superior Court of Riverside County ruled that the Water District's Canal Water rates and the Irrigation Water Availability Assessment (IWAA) violated Proposition 218. The court found that the Water District's historical priority argument was not persuasive and that the Water District had made no attempt to show that the rates complied with the California Constitution. The court deferred ruling on remedies and later awarded Class 2 customers approximately $17.5 million in refunds and interest for invalid charges from March 2018 through June 2022.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that Howard Jarvis Taxpayers Association (Howard Jarvis) had standing to challenge the Class 2 rates because domestic customers paid the rates indirectly. The court found that the Class 2 rates were taxes under Article XIII C and did not fall under any exceptions. The court rejected the Water District's arguments that the rates were justified based on historical priority and that they were expenditures of funds. The court also found that the IWAA was an assessment under Proposition 218 and that the Water District failed to show it was proportional to the benefits conferred on the properties.The court affirmed the lower court's ruling on liability and the amount of refund relief awarded. However, the court found that the injunction in the judgment was overbroad and modified the judgment to strike the paragraph enjoining the Water District from imposing any future Canal Water rates and charges that did not comply with Proposition 218. As modified, the judgment was affirmed, and Howard Jarvis was awarded its costs on appeal. View "Howard Jarvis Taxpayers Assn. v. Coachella Valley Water Dist." on Justia Law

Andre Lester was charged and convicted of multiple sex offenses with a minor. At trial, the State presented Verizon phone records to link Lester to the crimes. Exhibit #2 showed the time, date, and connecting number for every call made to or from the phone allegedly belonging to Lester. Exhibit #3 featured a subset of that data, showing communications between Lester’s phone and the victim’s phone. Lester argued that the admission of these exhibits violated the Confrontation Clause and hearsay rules because he could not cross-examine the source of the data.The Superior Court of Wake County admitted the exhibits under Rule 803(24), the catch-all hearsay exception, despite acknowledging that they did not meet the business records exception under Rule 803(6). The jury convicted Lester on all counts, and he appealed. The Court of Appeals reversed the convictions, holding that the admission of the exhibits violated the Confrontation Clause and hearsay rules, and ordered a new trial.The Supreme Court of North Carolina reviewed the case and found that the Court of Appeals misapplied the Confrontation Clause analysis. The Supreme Court held that machine-generated raw data, if truly machine-generated, are neither hearsay nor testimonial under the Confrontation Clause. The Court emphasized that the primary purpose test should focus on why the data were created, not why they were later retrieved. The Court concluded that if Verizon’s systems recorded the data as part of routine operations, the data were not created for use in a trial. The Supreme Court reversed the decision of the Court of Appeals and remanded the case for consideration of Lester’s remaining issues. View "State v. Lester" on Justia Law

In 2011, plaintiffs sued the Roman Catholic Diocese of Charlotte, alleging sexual abuse by priests in the 1970s and 1980s. The trial court granted summary judgment for the Diocese, finding the claims time-barred by the statute of limitations. One plaintiff appealed and lost, while the other did not appeal. Both judgments became final a decade ago.In 2019, the General Assembly passed the SAFE Child Act, which revived previously time-barred claims for child sexual abuse. In 2020, plaintiffs filed new lawsuits asserting the same claims dismissed in the earlier judgments, arguing that the SAFE Child Act allowed them to do so. The trial court dismissed these new lawsuits with prejudice, citing the res judicata effect of the earlier judgments. The Court of Appeals affirmed, holding that the new lawsuits were barred by res judicata because final judgments had already been entered on the same claims.The Supreme Court of North Carolina reviewed the case and affirmed the Court of Appeals' decisions. The court held that the General Assembly does not have the power to set aside a final judgment of the judicial branch. The court emphasized that under the North Carolina Constitution, the judicial power belongs exclusively to the judicial branch, and the legislature cannot annul a judgment or decree of a court. The court concluded that the SAFE Child Act, like any other legislative act, cannot overturn a final judgment entered by the judicial branch. View "Doe v. Roman Cath. Diocese" on Justia Law