Justia Constitutional Law Opinion Summaries

Orange City passed an ordinance requiring periodic inspections of rental properties. If entry for inspection is refused, the ordinance allows the city inspector to seek legal remedies, including obtaining an administrative search warrant. Certain owners and renters of rental units challenged the ordinance, claiming it violated article I, section 8 of the Iowa Constitution because it did not require the city to show traditional probable cause before seeking a warrant.The Iowa District Court for Sioux County ruled in favor of the challengers, declaring the ordinance's mandatory inspection requirement unconstitutional and enjoining the city from seeking administrative warrants under the ordinance. The court awarded nominal damages to the plaintiffs.The Iowa Supreme Court reviewed the case and disagreed with the lower court's ruling. The court noted that in a facial challenge, the challenger must prove that the ordinance is unconstitutional in all its applications. The court found that there are scenarios where the ordinance could operate constitutionally, such as when traditional probable cause is present, when non-warrant legal remedies are pursued, or when inspections are conducted by certified third-party inspectors, exempting the property from city inspections. Therefore, the facial challenge could not succeed.The Iowa Supreme Court reversed the district court's decision and remanded the case for further proceedings consistent with its opinion. The main holding was that the ordinance's inspection regime could operate constitutionally in certain circumstances, thus the facial challenge to the ordinance failed. View "Singer v. City of Orange City" on Justia Law

Artell Young, a federal supervised releasee, was subject to a search condition allowing federal probation officers to search his person, vehicle, or home upon reasonable suspicion of contraband or release condition violations. After receiving information that Young was dealing drugs and possessing a firearm, federal probation officers searched his home, finding small amounts of crack cocaine, powdered cocaine, and marijuana. The federal authorities turned the case over to Iowa authorities, leading to Young's conviction on several drug offenses.In the Iowa District Court for Polk County, Young moved to suppress the evidence from the search, arguing it violated the Fourth Amendment and article I, section 8 of the Iowa Constitution. The district court upheld the search, citing the "special needs" exception under both the Fourth Amendment and article I, section 8. The court also noted that the search was conducted by federal officers under federal standards, thus not subject to Iowa constitutional standards. Young was convicted by a jury of three counts of possession of a controlled substance and sentenced to six years in prison.The Iowa Supreme Court reviewed the case, focusing on whether the search violated article I, section 8 of the Iowa Constitution. The court held that the constitutionality of the search should be evaluated by the law of the sovereign that conducted the search—in this case, federal law. The court affirmed the district court's decision, concluding that the search was lawful under federal standards and that the evidence obtained was admissible in the state prosecution. The court rejected Young's claim of an illegal search and affirmed his convictions. View "State of Iowa v. Young" on Justia Law

Charles Curry, Jr., a former competitive powerlifter and bodybuilder, started a nutritional supplements business called Get Diesel Nutrition in 2002. He began selling a testosterone-boosting supplement called "Diesel Test" in 2005. Revolution Laboratories, LLC, founded by Joshua and Barry Nussbaum, also sold a supplement called "Diesel Test" starting in 2016. Curry, acting without a lawyer, filed a lawsuit against Revolution and the Nussbaums in 2017, asserting trademark claims under the federal Lanham Act and Illinois common law. Curry later obtained counsel, and the case proceeded to a jury trial in May 2023, resulting in a verdict for Curry.The jury awarded Curry $2,500 in actual damages for loss of goodwill and reputation and $500,000 as disgorgement of Revolution’s profits from the infringement. Additionally, the jury awarded Curry $300,000 in punitive damages against each of Joshua, Barry, and Revolution, totaling $900,000. The district court later ruled that disgorgement of profits under the Lanham Act is an equitable remedy for the judge to decide and recalculated the appropriate profits award to be $547,095.44.The United States Court of Appeals for the Seventh Circuit reviewed the case. Defendants challenged the district court's decision to allow Curry's punitive damages request to go to the jury and argued that the punitive damage awards were excessive in violation of the Fourteenth Amendment’s due process clause. The Seventh Circuit affirmed the district court's decision, holding that the district court did not abuse its discretion in allowing Curry to seek punitive damages and that the punitive damage awards were not unconstitutionally excessive. The court concluded that the ratio of punitive damages to the combined compensatory and disgorgement awards was constitutionally permissible. View "Curry v. Revolution Laboratories, LLC" on Justia Law

In this case, two organizations and four individuals brought an action under 42 U.S.C. § 1983 against the City of Phoenix and several police officers, alleging violations of their constitutional rights during a protest outside a rally held by then-President Trump at the Phoenix Convention Center on August 22, 2017. The plaintiffs claimed that the police used excessive force and violated their First, Fourth, and Fourteenth Amendment rights by dispersing the protesters with tear gas, chemical irritants, and flash-bang grenades.The United States District Court for the District of Arizona certified two classes and granted summary judgment to the defendants on all claims except for the individual Fourth Amendment excessive-force claims asserted by three plaintiffs against certain officers. The court found that there was no "seizure" of the class members under the Fourth Amendment and evaluated the excessive-force claims under the Fourteenth Amendment's "shocks-the-conscience" test. The court also granted summary judgment to the defendants on the First Amendment claims, finding no evidence of retaliatory intent.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's summary judgment for the defendants on the class claims. The Ninth Circuit agreed that the use of airborne and auditory irritants did not constitute a "seizure" under the Fourth Amendment and that the Fourteenth Amendment's "purpose to harm" standard applied. The court found no evidence of an improper purpose to harm by the officers.The Ninth Circuit reversed the district court's denial of summary judgment to the individual defendants on the excessive-force claims asserted by the three plaintiffs, holding that the officers were entitled to qualified immunity. The court found that the officers acted reasonably under the circumstances or did not violate clearly established law. The court also affirmed the district court's summary judgment for the individual defendants on the First Amendment claims, finding that the officers had objectively reasonable grounds to disperse the crowd due to a clear and present danger.Finally, the Ninth Circuit affirmed the district court's summary judgment for Police Chief Williams and the City of Phoenix, concluding that there was no evidence that Williams caused or ratified the use of excessive force or that the City was deliberately indifferent to the plaintiffs' constitutional rights. View "PUENTE V. CITY OF PHOENIX" on Justia Law

Defendant Torolan Williams was convicted of first-degree murder for the deaths of five victims and sentenced to a mandatory term of natural life imprisonment. He filed a pro se postconviction petition claiming that his sentence violated the proportionate penalties clause of the Illinois Constitution, arguing that evolving brain science supports treating emerging adults as juveniles for sentencing purposes. Williams was 22 years old at the time of the offenses. He also claimed ineffective assistance of trial and appellate counsel for not raising this issue. The Cook County circuit court summarily dismissed the petition, and the appellate court affirmed the dismissal.The appellate majority held that the petition was frivolous and without merit because Williams did not allege any specific facts about his case, other than his age, to support his claim that the sentencing statute was unconstitutional as applied to him. The dissenting justice believed that Williams had met the low threshold for advancing to the second stage of postconviction review, arguing that a pro se petitioner should not be expected to provide more detailed allegations without the assistance of counsel.The Supreme Court of Illinois reviewed the case and affirmed the lower courts' decisions. The court held that Williams failed to provide sufficient factual detail specific to his circumstances to support his claim that the mandatory life sentence violated the proportionate penalties clause. The court emphasized that a postconviction petitioner must allege more than just their age and general brain science; they must provide specific facts about their background and the circumstances of their case. As a result, the court concluded that Williams' attorneys were not ineffective for failing to raise the meritless issue at sentencing or on direct appeal. View "People v. Williams" on Justia Law

The City of Fargo, a home rule municipality, adopted zoning ordinances prohibiting the sale of firearms and ammunition as home occupations and in non-farm commercial use zoned districts. In 2023, the North Dakota legislature passed House Bill 1340, amending N.D.C.C. §§ 40-05.1-06 and 62.1-01-03 to limit the authority of political subdivisions, including home rule cities, regarding firearms and ammunition. Fargo filed a declaratory judgment action challenging the constitutionality of H.B. 1340 and seeking a declaration that the amended statutes did not void its ordinances.The District Court of Cass County granted summary judgment in favor of the State, holding that H.B. 1340 did not violate the North Dakota Constitution and expressly preempted and voided Fargo’s zoning ordinances. Fargo appealed the decision.The North Dakota Supreme Court reviewed the case de novo and affirmed the district court’s judgment. The court held that H.B. 1340 was a valid exercise of the legislature’s constitutional authority to define the powers of home rule cities. The court concluded that the amended statutes were constitutional as applied to Fargo’s home rule charter and ordinances. The court also determined that H.B. 1340 preempted and rendered void Fargo’s zoning ordinances prohibiting the sale of firearms and ammunition, as the legislature had expressly limited the authority of political subdivisions in this area. View "City of Fargo v. State" on Justia Law

In 2022, the Kentucky General Assembly enacted Senate Bill 1 (S.B. 1), which restructured the relationship between the Jefferson County Board of Education and its superintendent. The bill required the Board to delegate day-to-day operations to the superintendent, limited the Board's meeting frequency, and granted the superintendent additional administrative powers. The Jefferson County Board of Education filed a declaratory judgment action, claiming S.B. 1 violated Sections 59 and 60 of the Kentucky Constitution, which prohibit local or special legislation.The Jefferson Circuit Court ruled in favor of the Board, declaring S.B. 1 unconstitutional. The court found that the bill effectively applied only to Jefferson County, thus constituting impermissible local legislation. The court also ruled, sua sponte, that S.B. 1 violated the equal protection rights of Jefferson County residents. The Kentucky Court of Appeals affirmed the trial court's decision on the grounds of Section 59 but did not address the equal protection ruling.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that S.B. 1 did not violate Sections 59 and 60 of the Kentucky Constitution. The Court reasoned that the bill's language created an open classification applicable to any county with a consolidated local government, not just Jefferson County. The Court also found that the Board had standing to challenge the bill and that the superintendent was not a necessary party to the action. The Court declined to address the equal protection issue, as it was not properly raised or developed in the lower courts. View "COLEMAN V. JEFFERSON COUNTY BOARD OF EDUCATION" on Justia Law

Donna Miller Bruenger, the ex-wife of the late Coleman Miller, filed a petition for declaratory judgment against Courtenay Ann Miller, Coleman’s daughter, seeking entitlement to Coleman’s Federal Employee’s Group Life Insurance (FEGLI) benefits. Coleman had failed to designate a beneficiary for his FEGLI benefits before his death, and MetLife distributed the benefits to Courtenay. Bruenger argued that Coleman’s legal obligation under a Qualified Domestic Relations Order (QDRO) to assign her the benefits should prevail.The Jefferson Circuit Court ruled against Bruenger, concluding that federal law precluded her claim because Coleman’s employer did not receive the QDRO before his death. Bruenger’s subsequent appeal was dismissed by the Court of Appeals as untimely, and the court also imposed sanctions for filing a frivolous appeal. Bruenger then sought relief under CR 60.02, which the trial court granted, allowing her to refile the appeal. The Court of Appeals dismissed the refiled appeal as frivolous and awarded attorney’s fees to Courtenay.The Supreme Court of Kentucky reviewed the case and determined that the Court of Appeals had jurisdiction to consider the merits of the CR 60.02 relief. The Supreme Court held that RAP 11(B) authorizes the award of attorney’s fees as a sanction for frivolous appeals but found that the imposition of sanctions in this case violated due process because Bruenger was not given notice or an opportunity to be heard. The Supreme Court affirmed the dismissal of the appeal for lack of jurisdiction but reversed the sanctions imposed by the Court of Appeals. View "BRUENGER V. MILLER" on Justia Law

Blake Jeffreys was arrested during a sting operation after unknowingly communicating with an undercover police officer and arranging to meet at a hotel for sex in exchange for $120. On May 14, 2021, Jeffreys pled guilty to promoting human trafficking. The Jefferson Circuit Court sentenced him to one year in prison, probated for five years, and ordered him to pay a $10,000 fee under KRS 529.130. Jeffreys requested the trial court waive the payment under KRS 534.030(4), but the court declined. Jeffreys appealed, arguing the fee was an unconstitutional excessive fine and should be waived.The Court of Appeals rejected Jeffreys' arguments and affirmed the trial court's decision. Jeffreys sought discretionary review from the Kentucky Supreme Court, focusing solely on the argument that the fee should be waived. The Kentucky Supreme Court granted the motion for review.The Kentucky Supreme Court affirmed the Court of Appeals' decision. The court held that KRS 529.130 imposes a human trafficking victims service fee, not a fine, and is not subject to waiver under KRS 534.030(4). The court also found that KRS 453.190, which defines a "poor person" for the purpose of waiving court costs, does not apply to the fee imposed under KRS 529.130. However, the court noted that Jeffreys could seek a show cause hearing under KRS 534.020(3)(a)1 to potentially reduce or waive the payment based on his ability to pay. The court emphasized that the trial court should consider various factors, including the defendant's financial status and dependents, when determining the ability to pay. View "JEFFREYS V. COMMONWEALTH OF KENTUCKY" on Justia Law

Matthew Ryan Hunt was charged with violating 18 U.S.C. § 922(g)(1), which prohibits individuals convicted of a crime punishable by imprisonment for a term exceeding one year from possessing firearms. Hunt's 2017 conviction for breaking and entering in West Virginia served as the predicate offense. In May 2022, Hunt pleaded guilty without raising a Second Amendment challenge. On appeal, Hunt argued that § 922(g)(1) violated the Second Amendment both facially and as applied to him. He also contended that the district court erred in applying a four-point enhancement to his offense level under the federal sentencing guidelines.The United States District Court for the Southern District of West Virginia accepted Hunt's guilty plea and applied the four-point enhancement, finding that Hunt had fired a gun inside an apartment building during a domestic violence incident, which constituted wanton endangerment under West Virginia law. Hunt appealed the decision, arguing that the statute was unconstitutional and that the district court's factual findings were erroneous.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reaffirmed that § 922(g)(1) is facially constitutional, consistent with its prior decision in United States v. Canada. The court also rejected Hunt's as-applied challenge, holding that neither the Supreme Court's decisions in New York State Rifle & Pistol Association, Inc. v. Bruen nor United States v. Rahimi abrogated the Fourth Circuit's precedent foreclosing as-applied challenges to § 922(g)(1). Additionally, the court concluded that § 922(g)(1) would survive Second Amendment scrutiny even if decided anew.The Fourth Circuit also upheld the district court's application of the four-point enhancement, finding no clear error in the factual determination that Hunt fired a gun in the apartment. Consequently, the court affirmed the district court's judgment. View "US v. Hunt" on Justia Law