Justia Constitutional Law Opinion Summaries

One afternoon, a group of seven individuals, including the appellant, were standing near a breezeway at an apartment complex in Southeast Washington, D.C. Police officers, who were on routine patrol and not responding to any specific report of criminal activity, stopped near the complex and began approaching the group from about 100 feet away. Upon noticing the officers, the appellant and another man immediately fled at a full sprint through the complex. The officers pursued the appellant, who led them on a chase over fences and through yards, ultimately dropping a firearm as he was apprehended. The police recovered the weapon, and the appellant was charged with several firearm-related offenses.The case was first reviewed by the Superior Court of the District of Columbia. At a suppression hearing, the appellant moved to exclude the gun, arguing the officers lacked reasonable suspicion for his seizure. The trial court found that the seizure occurred when an officer grabbed the appellant’s leg as he attempted to scale a second fence. The court concluded that the officers had reasonable articulable suspicion to justify the seizure, relying on the appellant’s immediate flight upon seeing police, the extended and desperate nature of the chase, and testimony that the apartment complex was a high-crime area. The appellant was convicted at a stipulated trial after the suppression motion was denied.On appeal, a panel of the District of Columbia Court of Appeals vacated the convictions, finding an absence of reasonable suspicion. The court then granted en banc rehearing and vacated the panel’s opinion. The en banc District of Columbia Court of Appeals held that, under the totality of the circumstances, the officers had reasonable articulable suspicion to seize the appellant, primarily due to his unprovoked flight upon seeing police, the particularized testimony about crime at the complex, and the desperation evident in his flight. The court affirmed the convictions. View "D.W. v. United States" on Justia Law

The Legislature enacted a statute in 2014 mandating that police vehicles acquired after March 1, 2015 and used primarily for traffic stops be equipped with mobile video recording systems (MVRS). At the same time, the Legislature increased the surcharge for driving while intoxicated (DWI) offenses by $25, directing the additional funds to cover the cost of MVRS installation. In 2015, Deptford Township challenged the MVRS mandate before the Council on Local Mandates, arguing that the surcharge was insufficient to cover the costs and that the statute constituted an unfunded mandate. Deptford did not challenge the legality of the surcharge itself.The Council determined that the MVRS mandate was an unfunded mandate because there was a significant disparity between the anticipated costs and the funds generated by the surcharge. The Council declared the MVRS statute unconstitutional and also found the $25 surcharge provision “nugatory,” or without legal effect. In 2021, class actions were filed by individuals subjected to the surcharge, alleging its continued collection was unconstitutional. The complaints were consolidated in the Superior Court, which dismissed them. The Appellate Division affirmed, finding that the Council had exceeded its authority by invalidating the surcharge, because it was a funding mechanism and not an unfunded mandate.The Supreme Court of New Jersey reviewed whether judicial review of the Council’s decisions was available and whether the Council had authority to invalidate the surcharge. The Court held that the Council is subject to judicial review when it acts beyond its constitutionally defined authority. It found that the Council’s power ended after it determined the MVRS mandate was unfunded, and it was not authorized to invalidate the $25 surcharge. The Court affirmed the Appellate Division’s judgment. View "Reed v. Muoio" on Justia Law

A group of individuals who had received traffic citations under a local ordinance enacted by the City of Tuskegee permitting automated photographic enforcement of traffic laws brought suit against the City, certain city officials, and JENOPTIK, the company involved in the installation and operation of the enforcement devices. The plaintiffs challenged the validity of the ordinance, raised constitutional concerns, and sought declaratory and injunctive relief as well as damages, including tort claims for negligence, invasion of privacy, and fraud. The City later enacted resolutions cancelling outstanding citations, refunding fines, and ultimately suspending enforcement of the ordinance.The case was initially filed in the Macon Circuit Court. The City and JENOPTIK moved to dismiss, arguing lack of a justiciable controversy, mootness, lack of standing, and other grounds, including lack of personal jurisdiction over JENOPTIK. The trial court denied these motions to dismiss, treating them as motions under Rule 12 and excluding extraneous materials, but did not provide detailed reasoning.On review, the Supreme Court of Alabama held that because the plaintiffs either paid the fines or failed to contest the citations under the administrative procedures provided in the ordinance, and because the City subsequently nullified the citations and provided for reimbursement, their claims challenging the legality of the ordinance were moot. The Court directed the trial court to dismiss those claims. However, the Supreme Court denied the petitions insofar as they sought dismissal of the plaintiffs’ tort claims, holding that the City and JENOPTIK did not demonstrate a clear right to mandamus relief on those claims at this stage. The Court likewise declined to dismiss the tort claims against JENOPTIK for lack of personal jurisdiction based on the current record. View "In re: Busby v. City of Tuskegee" on Justia Law

The plaintiffs, a trade association and a vape shop operator, filed suit challenging an Alabama law regulating electronic nicotine delivery systems (ENDS), which includes e-cigarettes and vapes. The law, effective June 1, 2025, established strict requirements for the sale of ENDS, including a product directory listing only approved products, mandates that products be manufactured in the United States or have federal FDA marketing authorization, and imposed significant penalties for violations. The plaintiffs claimed these regulations would cause them immediate and irreparable harm, including loss of profits, employees, and potential closure of their businesses due to prohibitions and penalties outlined in the law.The Montgomery Circuit Court initially granted a temporary restraining order (TRO) in favor of the plaintiffs, finding they would suffer irreparable harm and had no adequate remedy at law because the State defendants were protected by sovereign immunity. After a hearing, the court denied the plaintiffs’ motion for a preliminary injunction but extended the TRO pending appeal. The State defendants appealed, challenging the plaintiffs’ standing, while the plaintiffs cross-appealed the denial of the preliminary injunction.The Supreme Court of Alabama reviewed both appeals. It held that the plaintiffs had standing, as they faced concrete, particularized, and actual harm directly resulting from the enforcement of the Alabama law. However, the Court found the plaintiffs did not demonstrate a reasonable likelihood of success on the merits of their constitutional claims, including implied preemption and dormant Commerce Clause challenges. The Court determined that the Alabama Act was not preempted by federal law and served legitimate state interests related to health and safety. Therefore, the Supreme Court of Alabama affirmed the trial court's denial of the preliminary injunction. View "Spencer v. Vapor Technology Association" on Justia Law

The appellant was charged in two separate cases with theft from a person and evading arrest with a vehicle. He pled guilty to both charges and received deferred adjudication for ten years as part of a plea agreement, which also resulted in the State not pursuing habitual-offender enhancement. After being arrested for additional offenses, the State filed a petition to proceed to adjudication, alleging violations of the appellant’s community supervision, which was later amended to include further infractions. The appellant objected to the hearing being conducted virtually, citing concerns under the Due Process and Equal Protection Clauses as well as the Confrontation Clause.The trial court in Tarrant County held the hearing via Zoom, overruled the appellant’s objections, and adjudicated him guilty of both offenses, revoking his probation. The appellant filed motions for a new trial and notices of appeal, which were denied. On appeal to the Second Court of Appeals, he argued that the virtual hearing violated his rights under the Confrontation Clause and the Fourteenth Amendment. The appellate court found that the virtual hearing did not significantly impair his participation and concluded there was no violation of Due Process. It further held that the Confrontation Clause did not apply to revocation proceedings, reasoning that these are not criminal prosecutions as contemplated by the Sixth Amendment, and affirmed the trial court’s rulings.Upon review, the Court of Criminal Appeals of Texas considered only the Confrontation Clause issue. The court held that the Confrontation Clause does not apply to hearings on motions to enter adjudication of guilt and probation revocation, as such proceedings are not criminal prosecutions under the Sixth Amendment. Accordingly, the court affirmed the judgment of the Second Court of Appeals. View "MONTGOMERY v. STATE OF TEXAS" on Justia Law

A religious nonprofit organization sought to purchase a former university campus property after being selected as the winning bidder in a competitive process conducted by a state university system. Following the public announcement of the award, there was significant public opposition to the sale, particularly due to the religious nature of the winning bidder. Two unsuccessful bidders filed administrative protests, raising both procedural and substantive objections, including criticism of the university's decision to sell to a religious organization. The university's designated official initially denied these protests, but upon further internal review, a higher-level administrator determined that a flaw in the bid evaluation process—specifically, the failure to consider cost-saving proposals for existing infrastructure—warranted rescinding the award and restarting the process. In the new round, the property was awarded to a different bidder who scored higher under revised criteria.The original winning bidder, the religious organization, challenged the university's decision in the United States District Court for the District of Maine, alleging violations of the Equal Protection and Free Exercise Clauses of the U.S. Constitution. The district court denied the plaintiff’s motions for a temporary restraining order and a preliminary injunction, finding that the plaintiff failed to show a likelihood of success on the merits of either claim. The court credited testimony that the university’s decision was motivated by cost-saving considerations rather than religious bias, and found no clear evidence of procedural irregularity or pretext.On appeal, the United States Court of Appeals for the First Circuit reviewed the denial of the preliminary injunction for abuse of discretion. The Court affirmed the district court’s decision, holding that the lower court applied the correct legal standards and did not clearly err in its factual findings. The Court concluded that the plaintiff failed to demonstrate a likelihood of success on the merits of its constitutional claims. View "Calvary Chapel Belfast v. University of Maine System" on Justia Law

A Michigan physician was charged with twenty-one counts of unlawfully distributing controlled substances to his patients. Over several years, he prescribed large quantities of medications to individuals who exhibited signs of drug-seeking behavior, failed drug screens, engaged in doctor shopping, and requested specific highly abused drugs. The physician often ignored red flags such as patients’ substance abuse histories and failed to perform required physical examinations. His practices led to at least one patient’s overdose death. Evidence at trial included expert testimony that his prescribing was inappropriate and outside the usual course of professional practice.The case was first tried in the United States District Court for the Eastern District of Michigan, but the initial trial ended in a mistrial. A retrial was delayed and declared a mistrial due to the COVID-19 pandemic. The third trial proceeded in March 2023, with the district court requiring witnesses to wear masks while testifying. After a 13-day trial, a jury convicted the physician on all counts. Post-trial motions for acquittal or a new trial were denied, and the physician was sentenced to twenty years on the count involving death, with concurrent sentences on the remaining counts. He appealed, challenging the sufficiency of the evidence, the authority of the Attorney General to regulate prescribing, the jury instructions, and the mask mandate’s constitutionality.The United States Court of Appeals for the Sixth Circuit reviewed the appeal. It held that sufficient evidence supported the convictions, the jury instructions accurately reflected the law and were not misleading or confusing, and the district court’s mask mandate did not constitute reversible error under the Confrontation Clause. The court found no plain error in the regulatory and constitutional challenges and affirmed the district court’s judgment in its entirety. View "United States v. Shelton" on Justia Law

Plaintiffs had their property taken by the Commonwealth of Puerto Rico through eminent domain. They received over two million dollars in compensation, including interest accrued up to the time of payment. However, they alleged a second violation occurred when the court-administered disbursement process failed to notify them of further accrued interest and deducted a 15% administrative fee from that interest. They challenged these practices as unconstitutional takings and violations of due process, seeking declaratory and equitable relief against the Administrator of the Administration of Tribunals.The United States District Court for the District of Puerto Rico initially dismissed most claims, finding plaintiffs lacked standing because they had not alleged an attempt to withdraw the accrued interest, making their injury speculative. After reconsideration, the court revived the claim challenging the deduction of administrative fees, but limited relief to prospective injunctive relief due to Eleventh Amendment constraints. The court ultimately granted summary judgment to the defendant, finding the administrative fee reasonable and not an unconstitutional taking, as plaintiffs provided no evidence to the contrary.The United States Court of Appeals for the First Circuit reviewed the case and confronted jurisdictional issues arising from Puerto Rico’s Title III bankruptcy under PROMESA. The court held that the administrative fee claim was void for violating the automatic stay provisions, as it amounted to a demand for property of the debtor (the Commonwealth), and dismissed that portion of the appeal. Regarding the interest claim, the court affirmed the district court’s dismissal, ruling plaintiffs lacked standing because they failed to allege they sought disbursement or challenged existing procedures. The First Circuit thus dismissed the appeal from summary judgment and affirmed the district court's dismissal. View "Hernandez-Castrodad v. Steidel-Figueroa" on Justia Law

The case concerns a late-night car crash in Bloomington, San Bernardino County, where Steven Richard Castro collided with a parked vehicle, injuring its occupant. Neighbors restrained Castro, who tried to flee, and emergency personnel transported him to the hospital due to his combative behavior. CHP Officer Pope, stationed at the hospital on another matter, was notified about Castro's arrival and subsequently observed Castro sedated and unresponsive in the ER. Pope noted the smell of alcohol and, after gathering information from witnesses and the victim, arrested Castro on suspicion of DUI causing injury. Without seeking a warrant, Pope ordered a blood draw, relying on implied consent law. The blood test showed a high BAC.In the San Bernardino County Superior Court, Castro moved to suppress the blood test results, arguing that a warrant should have been obtained. The magistrate denied the motion, citing exigent circumstances per Mitchell v. Wisconsin, reasoning that Officer Pope’s time in the hospital justified the warrantless blood draw. Castro renewed his suppression request in a pretrial motion, but the court again found the officers’ actions constitutional based on the totality of circumstances and Castro’s unconsciousness, leading Castro to enter a no contest plea.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the record did not support a finding of exigency sufficient to excuse the failure to obtain a warrant for the blood draw. The court emphasized that Mitchell v. Wisconsin does not create a categorical rule for unconscious DUI suspects and, following its reasoning in People v. Alvarez, found no evidence that obtaining a warrant would have interfered with other pressing duties. The judgment was reversed, and the matter remanded with directions to grant the suppression motion and permit Castro to withdraw his plea. View "People v. Castro" on Justia Law

A man was convicted for malice murder and related offenses stemming from a murder-for-hire scheme in 2000, where the victim was killed in her Georgia apartment. The prosecution argued that the murder was orchestrated by the victim’s father-in-law, who opposed her marriage, and that the appellant was the hired killer, with testimony from accomplices and witnesses supporting this theory. The appellant's trial was marked by difficulties in securing expert witnesses and conducting mitigation investigations due to funding shortfalls in Georgia’s indigent defense system, which hampered his defense’s ability to prepare. Eventually, he was convicted on several counts and initially sentenced to death, with subsequent modifications after further proceedings.After conviction, the appellant’s attorneys from the Capitol Defender’s Office filed a motion for a new trial, later amended and supplemented by other attorneys from the same office. The Superior Court of Fulton County partially granted the motion, ordering a new trial solely on the issue of “mental retardation” for sentencing purposes, due to the late development of evidence related to this issue, which was attributed to a breakdown in indigent defense funding. Later, a new judge re-sentenced the appellant to life without parole in accordance with that order. Other grounds for a new trial were denied, and the appellant retained private counsel to pursue his appeal.The Supreme Court of Georgia reviewed the case and determined that, because this appeal was the appellant’s first opportunity to raise ineffective assistance of counsel claims (having been continuously represented by the same public defender’s office), the record was insufficiently developed on this issue. The Court vacated the trial court’s judgment in part and remanded the case for an evidentiary hearing on the ineffective assistance claims. Other claims regarding denial of a continuance and competency to stand trial were rejected, as the appellant failed to show harm or preserve those issues. Judgment was affirmed in part and vacated and remanded in part. View "CLARK v. THE STATE" on Justia Law