Justia Constitutional Law Opinion Summaries

A qualified nonresident transmission company challenged an Iowa statute that granted incumbent utilities a right of first refusal (ROFR) for electric transmission projects, arguing it was unconstitutionally enacted. The statute prevented the company from competing for projects. The Iowa District Court for Polk County declared the statute unconstitutional under the Iowa Constitution's title and single-subject requirements and issued a permanent injunction against the statute's enforcement.The district court's decision was appealed by the State of Iowa, the Iowa Utilities Board (IUB), and two incumbent utilities, MidAmerican Energy Company and ITC Midwest, LLC. They argued that the district court could not retroactively enjoin their participation in projects awarded under the ROFR while the case was pending. They also contended that the district court lacked jurisdiction and that the nonresident company should have challenged the IUB's rule under Iowa Code chapter 17A.The Iowa Supreme Court reviewed the case and affirmed the district court's judgment and permanent injunction. The court held that the ROFR statute was void ab initio due to its unconstitutional enactment. The court determined that the district court had the authority to enjoin the parties from participating in projects awarded under the ROFR, as the incumbents were on notice of the constitutional challenge and no physical construction had begun on the projects. The court also rejected the argument that the IUB's rule could only be challenged under chapter 17A, as the constitutional challenge to the statute inherently invalidated the rule. The court deferred any remaining federal law issues to the Federal Energy Regulatory Commission (FERC). View "LS Power Midcontinent, LLC v. State" on Justia Law

In 2012, George Thomas Shifflett was charged with driving under the influence (DUI) and accepted into an Accelerated Rehabilitative Disposition (ARD) program. In 2022, Shifflett was involved in another DUI incident and was charged as a second-time offender based on his previous ARD acceptance. Shifflett pled guilty to the 2022 DUI but contested the use of his 2012 ARD as a prior offense for sentencing purposes, arguing it was unconstitutional under Alleyne v. United States.The Adams County Court of Common Pleas granted Shifflett's motion to exclude evidence of his 2012 ARD and sentenced him as a first-time offender. The Commonwealth appealed, and the Superior Court vacated the sentence, remanding for resentencing as a second-time offender, citing recent Superior Court decisions that overruled Commonwealth v. Chichkin, which had held that using ARD as a prior offense for sentencing was unconstitutional.The Supreme Court of Pennsylvania reviewed the case to determine if considering Shifflett's ARD as a prior offense for sentencing violated Alleyne. The Court held that ARD does not equate to a conviction because it lacks the procedural safeguards of a criminal trial, such as the right to a jury trial and the requirement of proof beyond a reasonable doubt. Therefore, using ARD as a prior offense for sentencing enhancement is unconstitutional under Alleyne.The Court concluded that Section 3806 of the Motor Vehicle Code, which includes ARD in the definition of a prior offense, is facially unconstitutional to the extent it allows ARD to be used for sentencing enhancement. The Court reversed the Superior Court's order and remanded the case for reinstatement of Shifflett's original sentence as a first-time offender. View "Commonwealth v. Shifflett" on Justia Law

A group of appellants, including Firearms Owners Against Crime and two firearms dealers, filed a case against the Pennsylvania State Police (PSP) Commissioner, alleging that PSP was not complying with the Pennsylvania Uniform Firearms Act. The appellants claimed that PSP was intentionally understaffing its Pennsylvania Instant Check System (PICS) Operations Section, leading to significant delays in background checks for firearm purchases, sometimes exceeding seven hours. They argued that these delays violated the statutory requirement for "instantaneous" or "immediate" background checks and caused financial harm to firearms dealers due to canceled transactions.The Commonwealth Court initially issued a preliminary injunction, finding that PSP had a statutory duty to employ sufficient personnel to ensure compliance with the Act and that the delays were causing financial harm to the dealers. However, the court later sustained PSP's preliminary objections, ruling that the statute did not specify a mandatory timeframe for background checks and that the operational decisions regarding staffing were discretionary. The court also dismissed the appellants' request for a refund of the $2.00 background check fee, as the statute did not provide for such refunds.The Supreme Court of Pennsylvania reviewed the case and held that while the statute did not require "instantaneous" responses, it did mandate that PSP provide results as quickly as possible with available resources. The court affirmed the Commonwealth Court's denial of injunctive and mandamus relief, as these would compel affirmative action barred by sovereign immunity. However, the court reversed the denial of declaratory relief, allowing the appellants to seek a judicial declaration of PSP's duties under the Act. The court also vacated the order denying leave to amend the petition, allowing the appellants to include new allegations regarding PSP's response to the preliminary injunction. The case was remanded for further proceedings consistent with these findings. View "Firearms Owners v. Comm'r of PSP" on Justia Law

The defendant was charged with two counts of possession of a firearm by a prohibited person. During a search of his residence by his probation officer, alcohol and a loaded rifle were found, violating his probation conditions. The probation officer also found an empty handgun box, and the defendant gave conflicting accounts of the handgun's location. Later, the defendant's girlfriend and her mother, along with the defendant's son, searched the house and found a locked case believed to contain the handgun. They handed the case to a law enforcement officer, who later obtained a warrant to open it, confirming it contained the handgun.The district court denied the defendant's motion to suppress the handgun, finding that the officer did not conduct a search but merely accepted the case from private individuals. The court also found that the officer entered the residence with consent. The defendant was found guilty of possessing the handgun but acquitted of possessing the rifle.The Nebraska Court of Appeals affirmed the conviction, agreeing that the officer entered the residence with consent and that the recovery of the locked case was not the result of a search by law enforcement. The court also found that any error in overruling the motion to suppress was harmless because the defendant did not object to the testimony and evidence presented at trial.The Nebraska Supreme Court reviewed the case and affirmed the Court of Appeals' decision. The court held that the Fourth Amendment was not violated because the search that discovered the locked case was conducted by private individuals who were not acting as government agents. The court concluded that the officer's acceptance of the case did not constitute a search and that the subsequent warrant to open the case was valid. View "State v. Langley" on Justia Law

Utility companies operating in Placer County, California, filed a complaint against the County and the Board of Equalization, seeking a refund of taxes. They alleged that the tax rate imposed on their state-assessed property was unconstitutionally higher than the rate imposed on locally-assessed property. The tax rate for state-assessed property is calculated under Revenue and Taxation Code section 100, while locally-assessed property is taxed under a different formula. The utility companies argued that this discrepancy violated article XIII, section 19 of the California Constitution, which mandates that utility property be taxed to the same extent and in the same manner as other property.The Superior Court of Placer County sustained the County's demurrer, effectively dismissing the complaint. The trial court relied on the precedent set by the appellate court in County of Santa Clara v. Superior Court, which held that the tax rates imposed on utility property were constitutional. The utility companies acknowledged that the Santa Clara decision was binding on the trial court but maintained that they had a good faith basis for their claims on appeal.The California Court of Appeal for the Third Appellate District reviewed the case. The court affirmed the trial court's decision, concluding that the utility companies had not established that the trial court erred. The appellate court found that the utility companies did not present a valid basis for defining comparability to state a valid claim. The court noted that while the utility companies argued for comparable tax rates, they failed to provide a clear standard or formula to determine what constitutes comparability. Consequently, the court held that the utility companies did not meet their burden of proving that the County's tax rates were unconstitutional. View "Pacific Bell Telephone Co. v. County of Placer" on Justia Law

Montana Environmental Information Center and Earthworks (MEIC) submitted a formal information request to the Office of the Governor of Montana on November 29, 2021. The request sought various documents related to the Montana Department of Environmental Quality’s (DEQ) dismissal of an enforcement action against Hecla Mining and its President/CEO, as well as information on the Governor’s Office’s involvement in mining and environmental decision-making. The Governor’s Office did not respond to the request, prompting MEIC to follow up multiple times. When the requested records were not provided, MEIC filed a lawsuit against the Governor’s Office, seeking to compel production of the information.The First Judicial District Court of Lewis and Clark County found that the Governor’s Office had a clear legal duty to honor MEIC’s request and issued a writ of mandamus compelling the production of the information. The Governor’s Office initially appealed but later stipulated to dismissal. MEIC then requested attorney’s fees, which the District Court denied, citing the Governor’s Office’s lack of bad faith and the potential for MEIC to obtain the information through other means.The Supreme Court of the State of Montana reviewed the case and addressed whether a party who successfully vindicates its right to know under the Montana Constitution is entitled to a presumption towards awarding attorney’s fees. The Court held that there should be a presumption towards awarding attorney’s fees to plaintiffs who successfully enforce their right to know, as this encourages public engagement and enforcement of constitutional rights. The Court vacated the District Court’s order and remanded the case for reconsideration of the attorney’s fees request, considering the presumption towards awarding fees and costs. View "MEIC v. Governor" on Justia Law

Plaintiffs, who own or operate gasoline service stations in Puerto Rico, offered two different prices to consumers: a higher price for those using credit or debit cards and a lower price for those paying with cash. In 2013, Puerto Rico's legislature enacted Law 152-2013, amending Law 150-2008 by removing a provision that allowed merchants to offer cash discounts. Plaintiffs ceased offering the lower price due to the threat of fines and criminal prosecution. They sued the Commonwealth of Puerto Rico, arguing that Law 150 is preempted by federal law and is unconstitutionally vague.The United States District Court for the District of Puerto Rico rejected the plaintiffs' arguments and granted the Commonwealth's motion to dismiss for failure to state a claim. The court found that neither the Cash Discount Act (CDA) nor the Durbin Amendment preempted Law 150. The court also declined to address the constitutional vagueness argument, noting that the complaint did not allege that Law 150 is unconstitutionally vague.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the CDA and the Durbin Amendment do not preempt Law 150. The CDA regulates the conduct of credit card issuers, not merchants or states, and does not confer an absolute right to offer cash discounts. The Durbin Amendment regulates payment card networks, not states, and does not preempt state legislation restricting cash discounts. The court also found that the plaintiffs did not properly plead a vagueness claim in their complaint, rendering the claim unpreserved for appellate review. Consequently, the First Circuit affirmed the district court's dismissal of the case. View "Asociacion de Detallistas de Gasolina de PR Inc. v. Commonwealth of Puerto Rico" on Justia Law

Two Korean spas, collectively referred to as "the Spa," had a policy of granting entry only to biological women, excluding men and preoperative transgender women. The Washington State Human Rights Commission (HRC) initiated an enforcement action against the Spa, alleging that this policy violated the Washington Law Against Discrimination (WLAD), which prohibits discrimination in public facilities based on sexual orientation, including gender expression or identity. The Spa did not challenge the statute's definition or argue that their conduct did not fit within it but claimed that enforcing WLAD against their policy violated their First Amendment rights.The United States District Court for the Western District of Washington dismissed the Spa's complaint with prejudice under Rule 12(b)(6). The court held that the Spa's conduct discriminated based on gender identity, thus falling within WLAD's scope. It also found that the HRC's enforcement did not impermissibly burden the Spa's First Amendment rights to free speech, free exercise of religion, or free association.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The court held that the Spa's entrance policy discriminated based on gender identity, which is included in WLAD's definition of sexual orientation. The court applied intermediate scrutiny to the Spa's free speech claim, concluding that WLAD imposed an incidental restriction on speech no greater than necessary to eliminate discriminatory conduct. The court also applied rational basis review to the Spa's free exercise claim, finding that WLAD was neutral and generally applicable, and that eliminating discrimination based on sex and transgender status is a legitimate government purpose. Finally, the court rejected the Spa's free association claim, determining that the Spa was neither an intimate nor an expressive association. The court affirmed the district court's dismissal of the complaint. View "Olympus Spa v. Armstrong" on Justia Law

A thirty-four-year-old man engaged in a months-long sexual relationship with a sixteen-year-old girl, whom he met online. The relationship involved repeated sexual encounters, the exchange of nude photographs and explicit video calls, and the provision of marijuana and offers of other gifts. The girl reported the relationship to police, who struggled to identify the perpetrator due to his use of pseudonyms and anonymous messaging apps. State detectives, working as part of a federal task force, requested that federal officers use federal administrative subpoenas to obtain electronic records from service providers, which ultimately led to the identification and arrest of the defendant. A search of his home yielded physical evidence linking him to the victim.The Second District Court in Davis County denied the defendant’s motion to suppress the electronic records obtained via federal subpoenas, rejected his motions to arrest judgment and for a directed verdict on several charges, and admitted evidence of uncharged conduct from another county. The jury convicted the defendant on all counts, and the court partially granted a post-trial motion to arrest judgment, but left convictions for human trafficking of a child and sexual exploitation of a minor intact. The defendant appealed.The Supreme Court of the State of Utah held that Utah’s Electronic Information or Data Privacy Act (EIDPA) does not require suppression of evidence lawfully obtained by federal officers under federal law and then shared with state officers, and that the Utah Constitution does not mandate exclusion of such evidence. The court vacated the conviction for human trafficking of a child, holding that the statute requires proof that something of value was actually given or received in exchange for a sexual act, not merely offered. The court affirmed the convictions for sexual exploitation of a minor and distribution of a controlled substance, and found no reversible error in the admission of evidence related to uncharged conduct. View "State v. Andrus" on Justia Law

Samantha Hall-Haught was involved in a head-on collision, leading to the discovery of drug paraphernalia in her vehicle. At the hospital, a state trooper observed signs of drug use and obtained a warrant to test her blood, which revealed the presence of THC. Hall-Haught was charged with vehicular assault, and at her trial, a lab supervisor testified about the blood test results instead of the technician who conducted the test. Hall-Haught objected, arguing that her right to confront the witness against her was violated.The trial court admitted the lab results, and Hall-Haught was convicted. She appealed, and the Washington Court of Appeals affirmed the conviction, reasoning that the supervisor's independent review and testimony did not violate the confrontation clause. The court relied on the precedent set in State v. Lui, which allowed expert witnesses to testify based on data prepared by others.The Supreme Court of Washington reviewed the case and reversed the Court of Appeals' decision. The court held that the confrontation clause was violated because the lab report was testimonial, and the technician who performed the test was the actual witness against Hall-Haught. The court emphasized that the supervisor's testimony, which relied on the technician's report, was admitted for its truth, thus implicating the confrontation clause. The court remanded the case for further proceedings consistent with this opinion. View "State v. Hall-Haught" on Justia Law