Justia Constitutional Law Opinion Summaries

Two plaintiffs, identified as Jane Roe and John Doe, brought a defamation lawsuit against Jenna Smith and her mother, alleging that Jenna had falsely accused John of sexual assault and Jane of being a non-consensual partner while all were students at a Los Angeles County high school. These accusations, made both to other students and school officials, led to an investigation by the school, which ultimately found John not responsible for the alleged misconduct. The plaintiffs claimed significant reputational and emotional harm from the spread of these accusations and sought damages, injunctive relief, and an order preventing future defamatory statements.After the complaint was filed under pseudonyms, the First Amendment Coalition moved to unseal the plaintiffs’ names. The Superior Court of Los Angeles County, however, deemed the motion premature and directed the plaintiffs to file a formal motion to maintain anonymity. Both plaintiffs and defendants filed such motions without supporting evidence. The court granted both motions, allowing all parties to proceed pseudonymously. The Coalition then appealed the order granting anonymity to the plaintiffs, while no party appealed the order regarding defendants.The California Court of Appeal, Second Appellate District, reviewed the matter and applied independent judgment on the constitutional issue. It held that, absent statutory authorization, litigating under pseudonyms should only occur in rare circumstances and requires an evidentiary showing of an overriding interest that outweighs the public’s right of access to court records. The court found that the plaintiffs’ generalized fears of reputational harm and potential future impact on employment were insufficient and unsupported by evidence. It reversed the Superior Court’s order granting plaintiffs anonymity, emphasizing that defamation plaintiffs are generally not entitled to proceed pseudonymously without robust factual support. View "Roe v. Smith" on Justia Law

The plaintiffs in this case are entities that own and operate a four-story building in Kemah, Texas. The building houses a bar, residential rental units, and a food truck. The dispute began when, in July 2021, the city issued a zero-occupancy notice for the building after an inspection found multiple safety hazards, prohibiting anyone except the owner and repair contractors from entering. Plaintiffs allege this deprived them of almost all economic use of the property. Separately, the city took enforcement action against the food truck, culminating in its removal from the property in October 2021. Plaintiffs challenged the food truck towing in state court, but ultimately dropped their appeal. They then sued the city in federal court, raising federal and state takings, due process, and equal protection claims regarding both the zero-occupancy notice and the food truck towing, and sought declaratory relief.The United States District Court for the Southern District of Texas granted the city’s motion to dismiss. The court found the claims related to the zero-occupancy notice were not ripe because plaintiffs had not pursued available administrative appeals to the city council, as allegedly required by city ordinances. The court dismissed the food truck claims on the merits, and dismissed the request for declaratory relief because no substantive claims remained.On appeal, the United States Court of Appeals for the Fifth Circuit held that the district court erred in dismissing the zero-occupancy notice claims as unripe. The appellate court determined that the city’s issuance of the zero-occupancy notice constituted a sufficiently final decision for purposes of ripeness and that exhaustion of administrative remedies is not required for claims under 42 U.S.C. § 1983. The court reversed the dismissal of the zero-occupancy notice claims and remanded those claims, including the related request for declaratory relief, for further proceedings. However, the court found that the plaintiffs had waived their food truck claims by failing to adequately brief them on appeal and affirmed their dismissal. View "T&W Holding v. City of Kemah, Texas" on Justia Law

OneTaste, Inc., a company founded in 2004 that promoted “orgasmic meditation,” sued Netflix for defamation in 2023. The lawsuit was based on a Netflix documentary that featured allegations from former employee Ayries Blanck, who claimed she was sexually assaulted and abused in connection with her employment and participation in OneTaste’s activities. The documentary included statements from Blanck’s sister and other former associates, as well as references to earlier media investigations and reports about alleged exploitative and abusive practices at OneTaste. OneTaste asserted that Netflix published false statements with actual malice, despite being provided with information it claimed disproved the allegations.The Superior Court of Los Angeles County reviewed Netflix’s special motion to strike under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16). Netflix argued its conduct was protected activity and that OneTaste could not demonstrate a probability of prevailing, especially on the element of actual malice. After considering the pleadings and both parties’ evidence, the trial court concluded that OneTaste failed to present sufficient evidence that Netflix published the challenged statements with actual malice. The court also found OneTaste’s additional evidence did not establish that Netflix was aware of probable falsity or recklessly disregarded the truth. As a result, the court granted Netflix’s motion to strike the complaint.On appeal, the California Court of Appeal, Second Appellate District, Division Three, affirmed the trial court’s order. The appellate court held that OneTaste did not meet its burden to show a probability of prevailing on the defamation claim because it failed to produce evidence of actual malice by Netflix. The court also rejected OneTaste’s constitutional and public policy challenges to the anti-SLAPP statute and denied its requests for judicial notice of materials not considered by the trial court. View "Onetaste Incorporated v. Netflix, Inc." on Justia Law

The defendant, Marcos Hernandez, has a documented history of violence against the mother of his child, Jessica Murillo, including multiple arrests and convictions for assault. His conduct escalated over several years, resulting in convictions for misdemeanor and felony assault of a family member under Texas law. In May 2023, Hernandez was found in possession of a short-barreled, unregistered 12-gauge shotgun while walking along a railroad track in El Paso, Texas. Subsequent investigation confirmed he had no firearms registered to his name. Hernandez was indicted for possession of a firearm by a convicted felon and possession of an unregistered firearm.The United States District Court for the Western District of Texas denied Hernandez’s motion to dismiss the indictment, in which he argued that both statutes violated the Second Amendment and, for one count, the Commerce Clause. Hernandez then pled guilty to both charges, admitting to his prior felony convictions and the facts surrounding the firearm. The district court sentenced him to concurrent terms of imprisonment and supervised release. Hernandez timely appealed.The United States Court of Appeals for the Fifth Circuit reviewed Hernandez’s constitutional challenges de novo. The court concluded that his facial Second Amendment and Commerce Clause challenges to 18 U.S.C. § 922(g)(1) are foreclosed by precedent. Regarding his as-applied Second Amendment challenges to both statutes, the Fifth Circuit held they fail because the Second Amendment does not protect possession of short-barreled shotguns and because Hernandez’s predicate offenses are crimes of violence. Under Fifth Circuit precedent, such convictions permit categorical disarmament. The court affirmed the district court’s judgment, upholding Hernandez’s convictions. View "United States v. Hernandez" on Justia Law

James Ray Davis pleaded guilty in 2017 to several charges, including commercial and residential burglary. Later, while incarcerated, Davis filed a pro se petition for writ of habeas corpus in the county of his incarceration. In his petition, Davis asserted that his guilty plea was induced by prosecutor deception, ineffective assistance of counsel, and trial court misconduct. He also alleged constitutional and due process violations. The petition included affidavits that were difficult to interpret, and although Davis used a form referencing Arkansas Code Annotated section 16-112-201, he did not claim actual innocence or request scientific testing.The Jackson County Circuit Court treated Davis’s petition as seeking habeas relief under sections 16-112-101 to -123, since he neither stated a claim under section 16-112-201 nor filed the petition in the county of conviction as required for claims based on new scientific evidence. The circuit court denied Davis’s petition, concluding that he failed to state a cognizable action for the writ to issue. Specifically, the court found that Davis did not provide a sentencing order showing the alleged illegality of his sentence and did not demonstrate either facial invalidity of the judgment or lack of circuit court jurisdiction.The Supreme Court of Arkansas reviewed the case and applied the clearly erroneous standard to the circuit court’s ruling. The court held that Davis failed to establish a basis for habeas relief because he did not show that the judgment was invalid on its face or that the circuit court lacked jurisdiction. Without the sentencing order or proof of illegality, the Supreme Court of Arkansas affirmed the circuit court’s denial of Davis’s petition. View "DAVIS v. STATE OF ARKANSAS" on Justia Law

A group of individuals who were instrumental in the campaign to incorporate the City of Erda sought to prevent approximately 8,000 acres from being annexed out of Erda and into Grantsville City. The controversy arose after an entity, Six Mile Ranch, initiated and amended an annexation petition to move land from Erda’s boundaries into Grantsville, during and after Erda’s incorporation process. The Grantsville City Recorder determined that the annexation petition met statutory requirements and certified it, which was followed by Grantsville approving the annexation by ordinance and entering a development agreement for the property. The sponsors challenged the annexation, alleging it violated both statutory requirements and constitutional provisions, and sought to invalidate the annexation ordinance and prevent the Lieutenant Governor from certifying it.In the Third District Court, Tooele County, the sponsors filed a petition for extraordinary relief under rule 65B of the Utah Rules of Civil Procedure. The district court dismissed the petition, concluding that the sponsors lacked statutory, traditional, and alternative standing to challenge the annexation, and denied related motions.On direct appeal, the Supreme Court of the State of Utah affirmed the dismissal but on alternative grounds. The court held that the sponsors, lacking statutory standing, had no other remedy for their statutory claims but failed to demonstrate that rule 65B(d)(2)(B) or the judiciary’s constitutional writ authority permitted relief where a public official had performed their statutory duty, albeit allegedly incorrectly. Regarding the constitutional claims, the court found that a plain, speedy, and adequate remedy was available through declaratory judgment actions, as clarified by recent appellate decisions. Therefore, the sponsors could not obtain extraordinary relief under rule 65B for either set of claims, and the dismissal was affirmed. View "Erda Community Association v. Baugh" on Justia Law

The defendant was charged with multiple counts of predatory criminal sexual assault, aggravated criminal sexual assault, and aggravated criminal sexual abuse involving his younger half-sister, K.P., who was under the age of thirteen at the time of the alleged offenses. The key evidence presented was a video-recorded, victim-sensitive interview conducted with K.P. when she was nine years old, in which she described repeated sexual abuse by the defendant. Prior to trial, the State sought to admit this interview under section 115-10 of the Illinois Code of Criminal Procedure, and the Cook County circuit court held a reliability hearing, ultimately finding the statement sufficiently reliable for admission if K.P. testified.At trial, K.P. showed reluctance and limited recall when testifying, acknowledging her participation in the interview and identifying the defendant, but consistently stating she did not remember the events described or her prior statements. The defense emphasized that her statements were made following a brutal beating by another household member. Despite K.P.’s minimal substantive testimony regarding the abuse, the jury found the defendant guilty on several counts. The circuit court sentenced him to consecutive prison terms totaling 21 years and denied his motion for a new trial.The Appellate Court of Illinois, First District, affirmed the convictions, holding that K.P.’s in-court testimony satisfied the statutory and constitutional requirements for admitting her out-of-court statements. On further appeal, the Supreme Court of Illinois held that section 115-10(b)(2)(A) and the confrontation clauses of both the state and federal constitutions do not require a child witness to recall or accuse the defendant at trial for such statements to be admissible. The Court found that K.P. was available for cross-examination, and the admission of her prior statements did not violate the defendant’s confrontation rights. The judgments of the circuit and appellate courts were affirmed. View "People v. Butler" on Justia Law

The defendant was charged with several offenses after a violent confrontation with a 20-year-old escort in his Queens home, leading to a police investigation that uncovered weapons, ammunition, forgery devices, and other items on the premises. During the jury trial, an alternate juror replaced a dismissed juror, leaving no further alternates. After the jury began deliberations, the foreperson reported an encounter outside his home with a man acting "on behalf of" the defendant, who provided court documents and claimed the defendant’s innocence. The foreperson, shaken by the incident, felt unable to remain impartial and was discharged from the jury.The Supreme Court, Queens County, held a hearing and found by clear and convincing evidence that the defendant orchestrated the confrontation with the foreperson, including feigning illness to leave court early. The court determined that this egregious misconduct was intended to improperly influence the jury. With no alternates available, the court, relying on forfeiture principles from prior cases, concluded the defendant forfeited his constitutional right to a jury of 12, and proceeded with 11 jurors. The 11-person jury found the defendant guilty on some counts and acquitted him on others.The Appellate Division affirmed the conviction, holding that the defendant’s "egregious" misconduct warranted forfeiture of the right to a 12-person jury. A dissenting Justice argued that such forfeiture should only occur in extreme circumstances, analogizing the right to a jury of 12 to the right to counsel. Upon review, the New York Court of Appeals held that a defendant who engages in egregious conduct affecting a sworn juror after deliberations begin, resulting in discharge and no alternates remaining, forfeits the right to a jury of 12. The court affirmed the trial court’s exercise of discretion in proceeding to verdict with 11 jurors. View "People v Sargeant" on Justia Law

Six residents of the Town of Newburgh sued the Town and its Town Board, alleging that the Board’s at-large electoral system unlawfully diluted the votes of Black and Hispanic residents, in violation of Section 17-206 of the New York Voting Rights Act (NYVRA). The plaintiffs argued that the method of electing all five Town Board members at-large prevented Black and Hispanic voters, who together made up about 40% of the population, from electing their preferred candidates or influencing election outcomes. They sought a court declaration that the at-large system violated the NYVRA and an injunction requiring the Town to implement a different electoral system.The Town of Newburgh moved for summary judgment, arguing that Section 17-206 was facially unconstitutional under the Equal Protection Clauses of the U.S. and New York Constitutions, and that its current election system complied with the NYVRA. The Supreme Court, Orange County, granted the Town’s motion, holding that the Town could challenge the statute because it allegedly could not comply with the NYVRA without violating equal protection, and declared the provision—and the entire NYVRA—unconstitutional. The Appellate Division reversed, holding that the Town lacked capacity to bring this challenge since it had not shown that compliance with the NYVRA would force it to violate equal protection, and that the Supreme Court erred in invalidating the statute.The New York Court of Appeals reviewed the case and held that the Town of Newburgh, as a political subdivision created by the State, could not bring a facial constitutional challenge to the NYVRA's vote-dilution provision. The court reaffirmed the longstanding rule that political subdivisions generally lack authority to challenge state laws unless a narrow exception applies, and found that no such exception was met here. The Appellate Division’s order was affirmed. View "Clarke v Town of Newburgh" on Justia Law

The defendant was indicted for aggravated assault, a second-degree felony, and tried in Harris County district court in January 2023. During the trial, the court required all participants, including witnesses, to wear surgical masks at all times, except when necessary for in-court identifications. The defendant’s counsel objected to the mask mandate on Sixth Amendment grounds, arguing that masking hindered the jury’s ability to assess witness credibility by observing facial expressions. The objection was overruled, and the two key witnesses to the assault testified while masked. The defendant was subsequently convicted.On appeal, the Fourteenth Court of Appeals reversed and remanded the conviction, finding that the mask mandate violated the defendant’s constitutional right to confrontation. The appellate court emphasized that concealing facial features impairs the fact-finder’s ability to evaluate witness demeanor, citing Romero v. State and other precedents. When considering whether this constitutional error was harmless, the court relied on a procedural rule that places the burden on the State to show harmlessness beyond a reasonable doubt. Because the State did not substantively address the issue of harm in its brief, the court presumed harm and reversed the judgment.The Court of Criminal Appeals of Texas reviewed the case. It agreed that the trial court’s mandatory masking policy violated the defendant’s Sixth Amendment right to confrontation, as it did not make any case-specific findings of necessity or individualized determinations for masking. However, the Court held that the appellate court erred by applying a rule of default and presuming harm solely because the State did not brief the issue. The Court clarified that appellate courts have an independent duty to assess harmlessness under Chapman v. California and Rule 44.2(a), regardless of the State’s briefing. The judgment was reversed and remanded to the Fourteenth Court of Appeals to determine whether the error was harmless beyond a reasonable doubt. View "SMITH v. STATE OF TEXAS" on Justia Law