Justia Constitutional Law Opinion Summaries

Dr. Tara Gustilo, an Asian American obstetrician-gynecologist of Filipino descent, was demoted from her position as Chair of the OBGYN Department at Hennepin Healthcare System, Inc. (HHS) in April 2021. Following her demotion, she filed charges with the Equal Employment Opportunity Commission (EEOC) and subsequently sued HHS, alleging race discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA), as well as a First Amendment retaliation claim under 42 U.S.C. § 1983.The United States District Court for the District of Minnesota granted summary judgment in favor of HHS, finding no genuine dispute of material fact regarding the race discrimination, retaliation, and First Amendment claims. The court concluded that Dr. Gustilo failed to establish a prima facie case of race discrimination and that there was no evidence she opposed an unlawful employment practice. Additionally, the court found no material fact dispute regarding whether the HHS Board considered her Facebook posts in its decision to demote her.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court reversed the district court's grant of summary judgment on the First Amendment retaliation claim, finding that there was a material fact dispute regarding whether the HHS Board ratified the MEC's decision and the basis for it, which included consideration of Dr. Gustilo's Facebook posts. The court remanded the case for further proceedings to determine if the posts were protected speech and to apply the Pickering balancing test.The court declined to review the district court's summary judgment rulings on the Title VII and MHRA claims at this time, as they are now interlocutory. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Gustilo v. Hennepin Healthcare System, Inc." on Justia Law

A grand jury indicted Derek Mims, Elmer Mims, David Belton, and Anton Whitney for conspiracy to distribute pure methamphetamine. Whitney was also charged with possession of a firearm by a drug user, and Belton was charged with possession of a firearm by a felon and drug user. Derek, Belton, and Whitney entered conditional guilty pleas, while a jury found Elmer guilty. The defendants appealed the district court's denial of motions to suppress evidence from wiretaps, a motion to recuse, and, in Belton's case, a motion to suppress evidence from a vehicle search. Elmer also appealed the sufficiency of the evidence for his conviction and the length of his sentence, while Derek and Whitney challenged their sentences.The United States District Court for the Northern District of Iowa denied the motions to suppress evidence obtained from wiretaps, finding that the necessity and probable cause requirements were met. The court also denied Belton's motion to suppress evidence from a vehicle search, applying the automobile exception to the Fourth Amendment. The court found probable cause based on the suspicious circumstances and modifications observed on the vehicle. The district court also denied the motion to recuse, stating that a judge's authorization of wiretap warrants does not require recusal from subsequent motions to suppress.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decisions, holding that the wiretap affidavits met the necessity and probable cause requirements, the vehicle search was justified under the automobile exception, and the denial of the motion to recuse was not an abuse of discretion. The court also found sufficient evidence to support Elmer's conviction and upheld the sentences of Derek, Whitney, and Elmer, finding no abuse of discretion in the district court's sentencing decisions. View "United States v. Mims" on Justia Law

Two Connecticut attorneys, Mario Cerame and Timothy Moynahan, challenged Connecticut Rule of Professional Conduct 8.4(7), which prohibits harassment or discrimination by lawyers based on fifteen protected categories. They argued that the rule violates the First and Fourteenth Amendments by imposing content-based and viewpoint-based restrictions on speech and being unconstitutionally vague. They claimed that the rule's broad language could potentially sanction their speech on controversial topics, thus chilling their First Amendment rights.The United States District Court for the District of Connecticut dismissed their complaint, ruling that Cerame and Moynahan lacked standing to bring a pre-enforcement challenge. The court found that they did not demonstrate a "real and imminent fear" of enforcement under Rule 8.4(7) and that their allegations were too general to establish a credible threat of enforcement.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Cerame and Moynahan have standing to seek pre-enforcement relief. The court held that they had sufficiently alleged an intention to engage in conduct arguably proscribed by Rule 8.4(7) and faced a credible threat of enforcement. The court noted that the rule's broad language and the lack of clear guidelines for enforcement created a substantial risk of disciplinary action, which was sufficient to establish an injury in fact. Consequently, the Second Circuit vacated the district court's judgment and remanded the case for further proceedings to consider whether the Eleventh Amendment bars the plaintiffs' claims. View "Cerame v. Slack" on Justia Law

Bryan Burwell and Aaron Perkins were involved in a series of bank robberies and were convicted in the United States District Court for the District of Columbia. They were sentenced to lengthy prison terms, including mandatory minimum sentences for firearms-related convictions under 18 U.S.C. § 924(c), which mandates enhanced penalties for using a firearm during a crime of violence. Burwell and Perkins argued that their convictions under § 924(c) were erroneous because federal bank robbery under 18 U.S.C. § 2113(a) is not categorically a crime of violence.The District Court denied their post-conviction motions, which challenged the application of § 924(c) based on the Supreme Court's decision in United States v. Davis, which invalidated the residual clause of § 924(c) as unconstitutionally vague. Burwell and Perkins appealed, arguing that bank robbery by extortion does not involve the use or threat of force and thus cannot be considered a crime of violence under the elements clause of § 924(c).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that 18 U.S.C. § 2113(a) is indivisible regarding the means of committing bank robbery—by force and violence, intimidation, or extortion. The court concluded that extortion, as a means of committing bank robbery, does not necessarily involve the use or threat of force. Therefore, bank robbery under § 2113(a) does not qualify as a crime of violence under § 924(c). Consequently, the court vacated Burwell's and Perkins's § 924(c) convictions and remanded the case to the District Court to determine whether to release them immediately. View "United States v. Burwell" on Justia Law

In 2016, Rhode Island enacted the RhodeWorks Act, which imposed tolls on tractor-trailers crossing thirteen bridges within the state. The toll revenue was intended for the replacement, reconstruction, operation, and maintenance of these bridges. The tolls were subject to three statutory caps: a truck could not pay more than once in each direction, more than $40 per day, or more than $20 for a single through trip from Connecticut to Massachusetts. The American Trucking Associations and several trucking companies challenged the tolls, arguing they violated the dormant Commerce Clause by discriminating against interstate commerce and failing to fairly approximate use of the bridges.The U.S. District Court for the District of Rhode Island permanently enjoined the tolls, finding that they discriminated against interstate commerce and did not fairly approximate use. The court concluded that the tolls' application solely to tractor-trailers and the statutory caps each violated the dormant Commerce Clause.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the statutory caps on tolls were unconstitutional because they disproportionately benefited in-state over out-of-state tractor-trailers, thus discriminating against interstate commerce. However, the court held that the tolls' application solely to tractor-trailers did not violate the fair-approximation test, as it was not wholly unreasonable for Rhode Island to rely on studies showing that tractor-trailers caused the most damage to the bridges.The First Circuit concluded that the unconstitutional caps were severable from the rest of the statute. Therefore, the court affirmed the district court's judgment in part, reversed it in part, and remanded the case for the entry of judgment consistent with its opinion. View "American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority" on Justia Law

The case involves the Protecting Americans from Foreign Adversary Controlled Applications Act, which was signed into law on April 24, 2024. The Act identifies certain countries, including China, as foreign adversaries and prohibits the distribution or maintenance of applications controlled by these adversaries, specifically targeting the TikTok platform. TikTok Inc. and ByteDance Ltd., along with other petitioners, challenged the constitutionality of the Act, arguing that it violates the First Amendment, the Fifth Amendment's equal protection and takings clauses, and the Bill of Attainder Clause.The lower courts had not previously reviewed this case, as it was brought directly to the United States Court of Appeals for the District of Columbia Circuit. The petitioners sought a declaratory judgment and an injunction to prevent the Attorney General from enforcing the Act. The court had to determine whether the petitioners had standing and whether their claims were ripe for judicial review.The United States Court of Appeals for the District of Columbia Circuit concluded that TikTok had standing to challenge the Act and that its claims were ripe. The court assumed without deciding that strict scrutiny applied to the First Amendment claims and upheld the Act, finding that it served compelling governmental interests in national security and was narrowly tailored to achieve those interests. The court also rejected the equal protection, bill of attainder, and takings clause claims, concluding that the Act did not constitute a punishment, was not overinclusive or underinclusive, and did not result in a complete deprivation of economic value. The petitions were denied. View "TikTok Inc. v. Garland" on Justia Law

A police officer initiated a traffic stop of Ashlee Mumford because the vehicle's license plate was obscured by dirt and grime. During the stop, a drug detection dog conducted a sniff around the vehicle, briefly touching the passenger door and momentarily breaking the plane of the passenger window. The dog alerted to the presence of controlled substances, leading to a search that uncovered methamphetamine in the glove compartment and marijuana and a methamphetamine pipe in Mumford's purse. Mumford was arrested and charged with possession of methamphetamine, marijuana, and drug paraphernalia. She was acquitted of methamphetamine possession but convicted of marijuana and drug paraphernalia possession.In the Iowa District Court for Madison County, Mumford moved to suppress the evidence obtained from the traffic stop, arguing it violated her constitutional rights against unreasonable searches and seizures. The district court denied her motion, concluding the traffic stop was supported by probable cause and the use of the drug detection dog did not violate the Federal or State Constitution. Mumford was convicted of possession of marijuana and drug paraphernalia following a bench trial.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that the traffic stop was supported by probable cause due to the obscured license plate, and the use of the drug detection dog did not constitute an unlawful search. The court also found sufficient evidence to support Mumford's conviction for possession of marijuana, rejecting her argument that lab testing was required to prove the substance was marijuana. The court concluded that the district court did not err in denying Mumford's motion to suppress evidence or her motion in arrest of judgment. View "State v. Mumford" on Justia Law

A minor, Iyana Crenshaw, was injured while working at Sonic Drive In of Greenville, Inc. Her father, Derrick Crenshaw, filed a negligence lawsuit against Sonic, alleging that the injury was caused by Sonic's negligence. The complaint did not seek workers' compensation benefits but solely pursued a negligence claim.The Butler Circuit Court dismissed the negligence action, concluding that the exclusive-remedy provisions of the Alabama Workers' Compensation Act barred the claim. Crenshaw did not dispute that Iyana's injury was subject to the Act but argued that the Act itself was unconstitutional under Article I, § 13, of the Alabama Constitution of 2022. The attorney general and Sonic defended the constitutionality of the Act, and the circuit court rejected Crenshaw's constitutional challenges, leading to the dismissal of the negligence action.The Supreme Court of Alabama reviewed the case and affirmed the lower court's decision. The court held that the Alabama Workers' Compensation Act does not violate Article I, § 13, of the Alabama Constitution. The court applied both the vested-rights approach and the common-law-rights approach to determine the constitutionality of the Act. Under the vested-rights approach, the Act did not deprive Crenshaw of a vested right in a cause of action. Under the common-law-rights approach, the court concluded that the Act was a valid exercise of the legislature's police power, as it eradicated or ameliorated a perceived social evil. Therefore, the Act's exclusive-remedy provisions were upheld, and the dismissal of the negligence action was affirmed. View "Crenshaw v. Sonic Drive In of Greenville, Inc." on Justia Law

Plaintiffs Tati Abu King and Toni Heath Johnson were unable to register to vote in Virginia due to felony convictions. King was convicted of felony drug possession in 2018, and Johnson was convicted of multiple felonies, including drug possession, in 2021. Virginia's constitution disenfranchises individuals convicted of felonies unless their civil rights are restored by the Governor or other appropriate authority. King and Johnson argued that this disenfranchisement violated the Virginia Readmission Act, a federal statute from 1870, which they claimed restricted Virginia from amending its constitution to disenfranchise individuals for crimes that were not felonies at common law in 1870.The United States District Court for the Eastern District of Virginia dismissed three of the four counts in the plaintiffs' complaint for failure to state a claim but allowed one count based on the Virginia Readmission Act to proceed. The defendants, including various state election officials and the Governor of Virginia, moved to dismiss the complaint on sovereign immunity grounds, which the district court rejected.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that the plaintiffs' claim met the requirements of the Ex parte Young doctrine, which allows suits for prospective relief against state officials to prevent ongoing violations of federal law. The court affirmed the district court's decision to allow the claim to proceed against most defendants but reversed the decision regarding the Governor of Virginia and the Secretary of the Commonwealth, finding that they lacked enforcement responsibility for the challenged state action. The court concluded that the Governor and Secretary must be dismissed from the case on sovereign immunity grounds. The district court's order was thus affirmed in part and reversed in part. View "King v. Youngkin" on Justia Law

James Thesing was charged with domestic violence in November 2022 and released under a pre-dispositional order prohibiting contact with the alleged victim. In March 2023, he was arrested for violating this order by initiating contact with the protected person while in custody. He was charged with two counts of violating the order, class A misdemeanors. In July 2023, the original domestic violence charge was dismissed, and the pre-dispositional order was terminated.Thesing filed a motion to dismiss one count in November 2023, arguing that the order only applied while he was released from custody. The District Court of Cass County denied the motion in December 2023, concluding that the order remained in effect after his arrest, was not contingent on release, and met constitutional requirements. Thesing entered a conditional guilty plea in February 2024, preserving his right to appeal, and the other count was dismissed. He appealed in March 2024.The North Dakota Supreme Court reviewed the case, focusing on statutory interpretation. The court found that the statute, N.D.C.C. § 12.1-31.2-02, unambiguously allowed the pre-dispositional order to remain in effect even after Thesing was taken back into custody. The court also noted that the order itself explicitly prohibited contact by any means and was to terminate only upon case disposition unless modified by the court.Thesing's argument that the order was a condition of release and did not apply while he was in custody was rejected. The court also dismissed his claim that the statute was unconstitutionally vague, noting that his brief lacked supporting arguments and citations. The North Dakota Supreme Court affirmed the district court's judgment. View "State v. Thesing" on Justia Law