Justia Constitutional Law Opinion Summaries

Two plainclothes detectives in Baltimore, acting on a tip about drug activity, observed Robert Gary Moore and another individual near a parked vehicle. When approached, Moore dropped a plastic bag and fled but was apprehended. The police recovered the bag, which was later analyzed in a laboratory report stating it contained cocaine. During Moore’s trial for possession and possession with intent to distribute, the State introduced two chain-of-custody reports: one disclosed before trial and another (the ECU report) disclosed only mid-trial. The latter did not mention the chemist who performed the analysis, raising questions about whether the correct bag was tested. Moore’s counsel did not object to the late disclosure or use the discrepancy in his defense. Moore was convicted by a jury.After his conviction was affirmed on appeal by Maryland’s intermediate appellate court, Moore sought postconviction relief in Maryland state court, arguing that the State’s belated disclosure of the ECU report violated his due process rights under Brady v. Maryland and that his counsel was ineffective. The Maryland trial court initially granted relief under Brady but, upon remand from the intermediate appellate court for further factfinding, ultimately denied both claims, finding that disclosure during trial did not constitute suppression under Brady. Moore’s application for leave to appeal this denial was rejected.Moore then filed a federal habeas petition in the United States District Court for the District of Maryland. The district court found a Brady violation and granted habeas relief, ordering Moore’s conviction vacated unless retried within sixty days. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the state court had unreasonably applied federal law and that a Brady violation warranted habeas relief. However, it held that federal district courts lack authority to vacate state convictions directly and thus vacated the district court’s order, remanding for a new order consistent with the proper bounds of federal habeas relief. View "Moore v. State of Maryland" on Justia Law

A petitioner sought a declaratory judgment regarding the legal sufficiency of a proposed constitutional ballot initiative, known as Ballot Issue 4. This initiative aimed to amend the Montana Constitution to limit the powers and privileges of "artificial persons"—including corporations, nonprofit corporations, limited liability companies, unincorporated associations, and certain foreign entities—by expressly restricting their ability to engage in election and ballot issue activities. The initiative would revoke all powers previously granted to artificial persons under Montana law, regrant only those necessary for lawful business or charitable purposes, and specifically prohibit election-related activities except for certain political committees. The petitioner contended that all provisions of the initiative were integral to a unified purpose: preventing artificial persons from participating in political spending.The Montana Attorney General, supported by amici, determined that Ballot Issue 4 was legally insufficient because it violated the separate-vote requirement of Article XIV, Section 11, of the Montana Constitution. According to the Attorney General, the initiative encompassed multiple changes that were not closely related, including broad revocations and regrants of powers to artificial persons, and affected diverse areas of law beyond the stated intent. The petitioner challenged this determination, arguing that the initiative constituted a single, unified scheme and that none of its provisions could sensibly be considered separately.The Supreme Court of the State of Montana exercised original jurisdiction to review the Attorney General’s legal sufficiency determination. The Court held that Ballot Issue 4 violated the separate-vote requirement because it proposed more than one substantive constitutional change—specifically, both limiting artificial persons’ powers to those expressly provided and revoking and regranting powers in a manner that extended beyond election-related activities. The Court affirmed the Attorney General’s rejection of the initiative and denied the petitioner’s request to declare it legally sufficient. View "Transparent Election Initiative v. Knudsen" on Justia Law

Adrian Roberts, a military veteran suffering from severe mental health issues, was the subject of an involuntary commitment order after his wife raised concerns about his safety and possession of weapons. Law enforcement officers, including a specially trained response team, attempted to execute the order, initially trying to persuade Adrian to leave his home peacefully. When he refused, the team forcibly entered his residence. Shortly after entry, Deputy Evans shot and killed Adrian. The circumstances surrounding the shooting were disputed: Evans claimed Adrian charged at officers with a machete, while Adrian’s wife alleged he was shot in the back while facing away.The United States District Court for the Eastern District of North Carolina reviewed the case after Adrian’s wife brought claims under 42 U.S.C. § 1983, alleging excessive force and unlawful entry. The district court granted Evans qualified immunity and summary judgment on the unlawful entry claim but denied both on the excessive force claim. The court found that genuine disputes of material fact existed, particularly regarding whether Adrian posed an immediate threat or was resisting arrest, and relied on the autopsy report suggesting Adrian may have been shot from behind. Because these factual disputes remained, the court concluded that a reasonable jury could find Evans violated Adrian’s clearly established rights.On appeal, the United States Court of Appeals for the Fourth Circuit considered whether it had jurisdiction to review the district court’s denial of qualified immunity and summary judgment on the excessive force claim. The Fourth Circuit held that it lacked jurisdiction because the district court’s decision was based on unresolved factual disputes rather than purely legal questions. The court emphasized it could not weigh evidence or resolve factual disputes at this stage, and dismissed the appeal for lack of jurisdiction. View "Roberts v. Evans" on Justia Law

Indiana amended its laws in 2022 to prohibit and criminalize the use of telehealth and telemedicine for abortions, requiring that abortion-inducing drugs be dispensed and consumed in person by a physician in a hospital or qualified surgical center. The Satanic Temple, a Massachusetts-based religious nonprofit, operates a telehealth abortion clinic serving only patients in New Mexico but seeks to extend these services to its Indiana members. It does not run, nor intends to operate, an in-person abortion clinic in Indiana or maintain ties to Indiana hospitals or surgical centers. The Temple filed suit against the Indiana Attorney General and Marion County Prosecutor, seeking to enjoin enforcement of the criminal statute (§ 16-34-2-7(a)) and to obtain declaratory relief under Indiana’s Religious Freedom Restoration Act.The United States District Court for the Southern District of Indiana reviewed the case and granted the defendants’ motion to dismiss for lack of standing. The court found that the Satanic Temple failed to identify any specific member who suffered an injury from the challenged law, thus lacking associational standing. It also held that the Temple itself lacked standing, as it could not show an injury in fact and could not demonstrate that favorable relief would redress its alleged harms due to other Indiana laws independently barring its intended conduct.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the Satanic Temple lacked both associational and individual standing. The Temple failed to identify a specific injured member and relied only on statistical probabilities and generalized claims of stigmatic injury, which were insufficient. Additionally, the Temple did not present concrete plans to violate the law, and even if § 16-34-2-7(a) were enjoined, other statutes would independently prevent its telehealth abortion services in Indiana. Thus, the Seventh Circuit affirmed the dismissal for lack of subject matter jurisdiction. View "Satanic Temple, Inc. v Rokita" on Justia Law

In November 2020, a United States Coast Guard cutter intercepted a vessel in international waters, far from Colombia. The vessel attempted to flee but was stopped and boarded. On board, authorities found three occupants—two Costa Rican nationals, including Munoz, and a Colombian national—and seized 383 kilograms of cocaine. The vessel lacked any registration documents, flag, or markings indicating nationality, and all occupants claimed to be the master without asserting the vessel’s nationality when prompted by Coast Guard officials. Based on these facts, the Coast Guard determined the vessel was subject to United States jurisdiction.A grand jury in the District Court of the Virgin Islands indicted Munoz for conspiracy and possession with intent to distribute cocaine under the Maritime Drug Law Enforcement Act (MDLEA). Munoz moved to dismiss the indictment, arguing that the MDLEA was unconstitutional and that the United States lacked jurisdiction over the vessel, requesting an evidentiary hearing. The District Court denied his motion without a hearing. Munoz then entered a conditional guilty plea to the conspiracy charge, preserving his right to appeal the denial of his motion to dismiss. After sentencing, the government dismissed the possession charge per the plea agreement, and Munoz timely appealed.The United States Court of Appeals for the Third Circuit reviewed Munoz’s constitutional challenge to the MDLEA and the District Court’s refusal to hold an evidentiary hearing. The court held that the MDLEA does not exceed Congress’s authority under the Felonies Clause of Article I, Section 8, Clause 10 of the Constitution, because the Felonies Clause is not limited by international law. It also held that the District Court did not abuse its discretion by declining to hold an evidentiary hearing, as the parties had stipulated to all material facts, leaving only legal questions for resolution. The Third Circuit affirmed the judgment. View "USA v. Munoz" on Justia Law

During a shopping trip at Walmart, William Montgomery was stopped by a store employee and subsequently by Officer Armando Cruz, who suspected shoplifting after Montgomery declined to show a receipt. Officer Cruz directed Montgomery to raise his hands, handcuffed him, and proceeded to search his pockets. Without conducting a pat-down, Officer Cruz reached into Montgomery’s pockets, removing a prescription bottle and a wallet, and looked for Montgomery’s driver’s license. Montgomery was detained briefly, but Walmart employees determined he had paid for the items and he was released.Montgomery filed suit in the United States District Court for the District of Colorado, alleging that Officer Cruz violated his Fourth Amendment rights by searching his pockets and wallet without proper justification. Officer Cruz moved for summary judgment on the basis of qualified immunity, arguing that his actions did not violate clearly established law. The district court denied the motion for summary judgment, finding that factual disputes existed regarding whether Officer Cruz had patted Montgomery down before reaching into his pockets and whether Montgomery had consented to the search of his wallet.The United States Court of Appeals for the Tenth Circuit reviewed the denial of summary judgment de novo. The court held that, accepting the district court’s factual conclusions, Officer Cruz’s search of Montgomery’s pockets without a pat-down or arrest constituted a clearly established violation of the Fourth Amendment. The court further concluded that the subsequent search of Montgomery’s wallet was not justified by consent, as any statement made by Montgomery after the illegal search could not retroactively legitimize the search. The Tenth Circuit affirmed the district court’s denial of qualified immunity to Officer Cruz. View "Montgomery v. Cruz" on Justia Law

A Christian ministry in Washington State, organized as a private nonprofit, operates various social service programs such as shelters, health clinics, and meal services, with a central mission to spread the Gospel. The organization requires all employees to adhere to its religious beliefs and practices, including those regarding marriage and sexuality. When hiring for non-ministerial positions (such as IT technician and operations assistant), it screens applicants for agreement with its religious tenets and only hires co-religionists. Anticipating the need to fill numerous non-ministerial roles, the ministry faced applicants who disagreed with its faith-based requirements.After the Washington Supreme Court’s decision in Woods v. Seattle’s Union Gospel Mission, which interpreted the Washington Law Against Discrimination (WLAD) exemption for religious organizations as limited to ministerial positions, the ministry filed a pre-enforcement federal action against the Washington State Attorney General and Human Rights Commission. The Eastern District of Washington initially dismissed the case for lack of standing, but the Ninth Circuit reversed and remanded, finding the ministry had standing. On remand, the district court granted a preliminary injunction, holding the ministry was likely to succeed on its First Amendment claim and enjoining the State from enforcing WLAD against it for hiring only co-religionists in non-ministerial positions. The State appealed.Reviewing the case, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s preliminary injunction. The court held that the church autonomy doctrine, rooted in the First Amendment’s Religion Clauses, protects religious organizations’ decisions to hire co-religionists for non-ministerial roles when those decisions are based on sincerely held religious beliefs. The holding does not extend to discrimination on other grounds and is limited to religious organizations. The Ninth Circuit found all preliminary injunction factors favored the ministry and affirmed the injunction. View "UNION GOSPEL MISSION OF YAKIMA WASHINGTON V. BROWN" on Justia Law

In 2023, Wyoming enacted two laws restricting abortion: the Life is a Human Right Act, which broadly banned abortion procedures with limited exceptions, and a separate statute prohibiting the prescription or use of drugs to induce abortions, also with exceptions. These laws imposed criminal and civil penalties on violators, excluding the pregnant person. After the laws took effect, several plaintiffs—including medical professionals, non-profit organizations, and an individual woman—challenged the statutes in District Court of Teton County, arguing they violated Article 1, Section 38 of the Wyoming Constitution, which guarantees each competent adult the right to make their own health care decisions.The district court granted summary judgment in favor of the plaintiffs, finding that the challenged laws unreasonably and unnecessarily infringed on the constitutional right to make health care decisions, and issued a permanent injunction preventing enforcement of the abortion restrictions. The State of Wyoming appealed directly to the Wyoming Supreme Court.The Wyoming Supreme Court, exercising de novo review, held that the decision to terminate or continue a pregnancy is a health care decision protected by Article 1, Section 38. The Court determined that this provision confers a fundamental right, and that statutes restricting it must satisfy strict scrutiny: the State must show such laws are narrowly tailored to achieve a compelling governmental interest and use the least restrictive means. The majority found that the State failed to present sufficient evidence that the abortion restrictions and their exceptions were the least restrictive means of protecting prenatal life. Accordingly, the Wyoming Supreme Court affirmed the district court’s ruling, holding the 2023 abortion laws unconstitutional under the Wyoming Constitution. View "State of Wyoming v. Johnson" on Justia Law

An 11-year-old child, L.D., was placed in foster care with Trina Mae Johnson. Over a period of fifteen months, Johnson inflicted severe abuse on L.D., including physical torture, starvation, denial of medical care, and psychological torment. The abuse resulted in significant weight loss, untreated injuries, and lasting trauma. Johnson concealed the abuse, enlisted others in her household to participate, and intimidated L.D. into silence. The abuse came to light when Johnson brought L.D. to a youth shelter, prompting an investigation by child services and the FBI.Johnson and several co-defendants were indicted on charges of child torture, child neglect, child endangerment, and assaulting a minor with a dangerous weapon in both federal and Minnesota state law violations. Some co-defendants pleaded guilty, while Johnson’s sister went to trial. Johnson was unable to accept a plea agreement because it was contingent on both sisters pleading guilty. She ultimately pleaded guilty without an agreement. The United States District Court for the District of Minnesota sentenced Johnson to 216 months in prison, after considering the relevant sentencing factors and victim impact statements. The sentence was below the government’s recommendation but above the prior plea offer.On appeal to the United States Court of Appeals for the Eighth Circuit, Johnson argued that the district court judge’s direct, sympathetic comments to L.D. at sentencing demonstrated judicial bias and violated her due process right to an impartial tribunal. The Eighth Circuit applied plain error review, noting Johnson did not object to the judge’s comments at sentencing or seek recusal. The court held that the judge’s empathetic remarks to the victim did not display deep-seated favoritism or antagonism that would make fair judgment impossible. Finding no plain error or due process violation, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Johnson" on Justia Law

On the evening of April 2, 2019, Thedarious Mitchell was shot and killed at a motel in DeKalb County. Security footage captured two men entering Mitchell’s room, followed by a violent altercation and Mitchell’s attempt to flee. As he ran, one of the men shot him in the back. Witness R.W., present during the incident, testified that the shooter was known to her as “Baldhead” or “Chris,” later identifying Christopher Sellers both in a photo lineup and at trial. Another witness, Calvin Leslie, recounted that while incarcerated, Sellers admitted to shooting a man in a Georgia motel. Evidence found at the scene and testimony at trial supported the prosecution’s theory that Sellers was the shooter.A DeKalb County grand jury indicted Sellers on multiple charges, including malice murder and firearm offenses. Following a jury trial in the Superior Court of DeKalb County, Sellers was found guilty on all counts. The court sentenced him to life imprisonment without parole for malice murder, with additional consecutive sentences for firearm offenses. Sellers’ motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.Reviewing the case, the Supreme Court of Georgia affirmed both Sellers’ conviction and his sentence. The Court held that the evidence was constitutionally sufficient to support the malice murder conviction, as a rational jury could have found Sellers guilty beyond a reasonable doubt. The trial court did not plainly err in instructing the jury on parties to a crime, as there was at least slight evidence supporting such a theory. Finally, the sentence of life without parole was not found to be cruel and unusual punishment under the Eighth and Fourteenth Amendments, nor grossly disproportionate to the crime, and thus was affirmed. View "SELLERS v. THE STATE" on Justia Law