Justia Constitutional Law Opinion Summaries

A man was stopped by police late at night after an officer observed him allegedly fail to signal 100 feet before making a left turn, as required by Illinois law. After he parked in a strip mall lot, officers initiated a traffic stop and asked for his license and proof of insurance. The driver’s insurance card was expired, prompting him to exit the car to call someone for updated proof. While the stop was ongoing, another officer arrived with a drug-sniffing dog, which alerted to narcotics outside the vehicle. Police then searched the car and found a handgun hidden in the center console, but no drugs. The driver was arrested and charged with being a felon in possession of a firearm.The United States District Court for the Central District of Illinois denied the defendant’s motion to suppress the handgun, finding the officer’s testimony credible enough to establish reasonable suspicion for the traffic stop and that the stop was not impermissibly prolonged. It also found the dog’s alert provided probable cause to search the vehicle. At trial, the court denied the defendant’s motion for a directed verdict, ruling there was sufficient evidence for the jury to convict him. The defendant’s post-trial motion for a new trial was also denied.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not clearly err in crediting the officer’s testimony about the traffic violation, that the duration of the stop was not unreasonably extended, and that the dog’s alert provided probable cause for the search. The court also found that there was sufficient evidence to support the conviction for knowing possession of a firearm by a felon. The judgment was affirmed. View "USA v. Banks" on Justia Law

In this case, several Amish parents, Amish community schools, and a representative of Amish schools in New York challenged New York's school immunization law, which, since 2019, no longer provides a religious exemption to the vaccination requirement for students attending public, private, or parochial schools. The plaintiffs allege that their faith prohibits vaccination, and their schools were fined for failing to comply with the immunization law. The plaintiffs asserted that the law violated their rights under the Free Exercise Clause of the First Amendment and their parental free-exercise rights recognized in Wisconsin v. Yoder.The United States District Court for the Western District of New York dismissed the plaintiffs’ complaint, finding they failed to plausibly allege a constitutional violation. The court relied on Second Circuit precedent holding that the repeal of religious exemptions for school vaccination laws, while maintaining medical exemptions, does not violate the Free Exercise Clause. The district court also denied the request for a preliminary injunction as moot. The plaintiffs appealed, and the United States Court of Appeals for the Second Circuit initially affirmed the dismissal.After the Supreme Court vacated the Second Circuit’s judgment and remanded for reconsideration in light of Mahmoud v. Taylor, the Second Circuit reviewed supplemental briefing and recent authorities. The Second Circuit again affirmed the district court’s judgment, holding that New York's immunization law is neutral and generally applicable, and thus constitutional under rational basis review. The court also held that the law does not impose a burden “of the same character” as the parental free-exercise burdens addressed in Yoder and Mahmoud, so strict scrutiny does not apply. The Second Circuit concluded that plaintiffs failed to state a viable Free Exercise or Yoder-type claim, and affirmed the dismissal of their suit. View "Miller v. McDonald" on Justia Law

Two proposed statewide initiatives in Colorado sought to alter the process and timing of congressional redistricting and to replace the existing congressional district map for the 2028 and 2030 election cycles. Both initiatives were similar in structure and aimed to temporarily allow mid-decade redistricting by amending the state constitution to enable new congressional maps for two election cycles, with authority returning to the independent redistricting commission after the 2030 federal census. The initiatives also included detailed statutory language setting forth the new temporary map to be used, with one initiative designed to favor Democratic candidates and the other designed to favor Republican candidates, according to the briefing.After the proponents submitted final versions of their initiatives, the Title Board, a state body responsible for setting the ballot title and submission clause, held hearings and set titles for each measure. Motions for rehearing alleging violations of the single subject and clear title requirements were denied by the Title Board. Petitioners then appealed to the Colorado Supreme Court, invoking its jurisdiction to review Title Board determinations under state law.The Supreme Court of Colorado reviewed the actions of the Title Board under a deferential standard, overturning its findings only in a clear case. Upon examining the initiatives, the court concluded that both measures violated the single subject requirement of the Colorado Constitution and applicable statutes. The court held that temporarily allowing mid-decade redistricting and adopting specific new congressional maps for two election cycles were distinct and separate subjects, not necessarily or properly connected. Because the initiatives combined these separate subjects, they were susceptible to log rolling and could mislead voters. The court reversed the actions of the Title Board, ordered the titles stricken, and directed that the measures be returned to their proponents. View "Williams v. Nathan" on Justia Law

A former superintendent of two state parks was investigated after a GPS device flagged his use of a state vehicle for speeding. When initially questioned, he denied being the driver and suggested another employee was responsible, later admitting he was the driver after being shown proof. He explained his actions by citing a dissociative episode related to post-traumatic stress disorder. The Department of Natural Resources and Environmental Control (DNREC) first suspended him for three days pending further review but later recommended his termination, citing additional alleged misconduct, including misuse of a state vehicle for personal errands, disabling a GPS tracker, and inappropriate computer use, although some charges—like GPS disabling and computer misuse—were not substantiated.The employee contested his termination through a “dual appeal” to the Delaware Division of Human Resources (DHR) and the Merit Employee Relations Board (MERB). DHR found his appeal untimely. MERB initially dismissed the appeal on timeliness grounds, but the Superior Court of Delaware reversed, finding the appeal timely and remanded the case for a new hearing. At the second MERB hearing, a Department of Justice attorney who had previously represented DNREC now advised MERB and drafted its written decision upholding the termination, finding the employee violated policies and was untruthful. The Superior Court affirmed MERB’s decision, holding it was supported by substantial evidence and that no due process violation occurred, relying on the Delaware Supreme Court’s decision in Blinder, Robinson & Co. v. Bruton.The Supreme Court of the State of Delaware found that procedural due process was violated when the same attorney represented both the prosecuting agency and later the adjudicatory board in the same case. The Court held that this “personal commingling of advocacy and adjudication” created an intolerable risk of bias and reversed the Superior Court’s judgment, remanding the matter for a new hearing before MERB. View "Fasano v. Delaware Department of Natural Resources and Environmental Control" on Justia Law

Arizona voters adopted a statute requiring organizations engaging in independent election-related media spending to disclose the identities of major donors and the original sources of funds used for such communications. The law includes an opt-out provision allowing donors to prevent their contributions from being used for campaign media spending, and imposes thresholds for disclosure and reporting. Plaintiffs, consisting of two nonprofit organizations and two anonymous individuals who donate to such organizations, challenged the law’s constitutionality, alleging it violated their rights to free speech and privacy under the Arizona Constitution.The Superior Court for Maricopa County dismissed the plaintiffs’ complaint for failure to state a legally valid claim, but permitted an amended complaint to add an as-applied challenge. After defendants again moved to dismiss, the court granted the motion, and the Arizona Court of Appeals affirmed the dismissal, finding plaintiffs had not sufficiently alleged that the statute was unconstitutional on its face or as applied.Upon review, the Supreme Court of Arizona held that the plaintiffs failed to sufficiently allege that the statute is facially unconstitutional under either the Speak Freely Clause or the Private Affairs Clause of the Arizona Constitution. The court developed an Arizona-specific standard for evaluating compelled disclosure laws, requiring that such laws meaningfully further election integrity or transparency and not unreasonably burden protected expression. The court found that the plaintiffs did not plausibly allege that the statute burdens protected expression in a substantial number of its applications.However, the Supreme Court of Arizona determined that the plaintiffs sufficiently alleged an as-applied challenge under the Speak Freely Clause, based on specific allegations of threats and harassment related to campaign media spending. The court affirmed the lower courts’ dismissal of all facial and privacy claims, reversed the dismissal of the as-applied free speech claim, and remanded that claim for further proceedings. View "CENTER FOR AZ v AZ SECRETARY OF STATE" on Justia Law

In August 2025, the President attempted to remove a sitting member of the Board of Governors of the Federal Reserve System, Lisa Cook, citing allegations of mortgage fraud that predated her tenure. This was the first time in the Federal Reserve’s history that a Governor was purportedly fired. Cook, whose term was scheduled to run until 2038, received a letter from the President stating that her integrity was in question due to potential misconduct, and that her immediate removal was necessary. Cook filed suit, arguing both that the alleged misconduct did not constitute “cause” for removal under the governing statute, and that she had not been given the required process—namely, notice and an opportunity to respond—before her termination.The United States District Court for the District of Columbia issued a preliminary injunction preventing Cook’s removal, finding she was likely to succeed on her claims that the purported “cause” did not satisfy the statutory standard, and that she had not received constitutionally or statutorily required pre-termination process. The United States Court of Appeals for the District of Columbia Circuit declined to stay the injunction, with a concurrence emphasizing the due process issue. The Government then sought a stay from the Supreme Court.The Supreme Court of the United States denied the Government’s application for a stay. The Court held that the President’s power to remove Federal Reserve Governors is subject to judicial review and that “cause” for removal must be substantial and related to the Governor’s official duties, reflecting the Federal Reserve’s need for independence. Most importantly, the Court ruled that Governors are entitled by statute to notice and an opportunity to respond before removal. Because Cook was not afforded these protections, her removal could not stand pending further litigation. The Court declined to address broader constitutional questions, deciding the case on statutory grounds. View "Trump v. Cook" on Justia Law

After President Trump began his second term in 2025, he dismissed two Democratic commissioners from the Federal Trade Commission (FTC), Rebecca Slaughter and Alvaro Bedoya, citing that their continued service conflicted with his administration’s priorities. He did not allege any statutory cause for their removal, instead asserting authority under Article II of the Constitution. Slaughter sued, arguing her removal was unlawful under the relevant statute, the Administrative Procedure Act, and the Constitution. Bedoya’s claims were dismissed as moot after he resigned, leaving only Slaughter’s case at issue.The United States District Court for the District of Columbia granted summary judgment in Slaughter’s favor, finding that President Trump’s action was ultra vires because the relevant statute allows removal of FTC commissioners only for “inefficiency, neglect of duty, or malfeasance in office.” The court relied on the Supreme Court’s prior decision in Humphrey’s Executor v. United States, which had recognized such statutory protections for FTC commissioners. The court issued a permanent injunction prohibiting interference with Slaughter’s ability to perform her duties. The United States Court of Appeals for the District of Columbia Circuit denied the government’s motion for a stay pending appeal, finding that Humphrey’s Executor controlled the issue.The Supreme Court of the United States reversed. It held that the FTC’s statutory provision limiting removal of commissioners to “for cause” is unconstitutional because it impermissibly restricts the President’s authority to remove executive officers. The Court overruled Humphrey’s Executor to the extent it permitted such statutory insulation for executive officers, reaffirming that officers exercising executive power must be removable by the President at will to preserve the Constitution’s separation of powers. The case was remanded for further proceedings consistent with this holding. View "Trump v. Slaughter" on Justia Law

A man robbed a credit union in Midlothian, Virginia in May 2019. Police learned from witnesses and surveillance that the robber appeared to use a cell phone but could not identify him. To find leads, the officers applied for a geofence warrant, compelling Google to provide anonymized location data for all cell phones within a 150-meter radius of the credit union around the time of the crime. The warrant described a three-step process: first, Google would produce anonymized data for all devices within the geofence for an hour; second, police would narrow the list and receive additional location data for those devices; third, police would further narrow the list and obtain identifying information. Ultimately, Google provided the identities of three users, including the petitioner, whose movements matched those of the robber.The United States District Court for the Eastern District of Virginia found the geofence warrant “plainly violates the rights enshrined in [the Fourth] Amendment” but denied the motion to suppress the evidence, applying the good-faith exception to the exclusionary rule. A divided panel of the United States Court of Appeals for the Fourth Circuit affirmed, but on the ground that no Fourth Amendment search had occurred because the petitioner had no reasonable expectation of privacy in the Location History data given to Google. On rehearing en banc, the Fourth Circuit affirmed in a one-sentence opinion, dividing evenly on the search question.The Supreme Court of the United States held that police conduct a Fourth Amendment search when they acquire an individual’s cell-phone Location History data from Google, because a person has a reasonable expectation of privacy in such information. The Court vacated the Fourth Circuit’s judgment and remanded the case for further proceedings to determine whether the warrant satisfied the Fourth Amendment’s requirements of particularity and probable cause at each stage of the search process. View "Chatrie v. United States" on Justia Law

Two men were convicted in the Circuit Court for Baltimore City on charges related to the 2019 murder of Donnell Brockington, who was surrounded and fatally shot multiple times by a group of six individuals. After the suspects fled, four, including the two respondents, were apprehended when their vehicle crashed. Police recovered several firearms, and DNA evidence linked both respondents to a Desert Eagle 9mm pistol found in the vehicle. At trial, a State firearms examiner testified that certain ammunition components were fired from that pistol, but neither respondent challenged the reliability of the examiner’s methodology or requested a Daubert hearing.After trial, the Supreme Court of Maryland decided Abruquah v. State, clarifying the limits on firearms identification testimony. The Appellate Court of Maryland reversed the respondents’ convictions on plain-error review, concluding that the firearms examiner’s unqualified testimony was exactly the kind prohibited by Abruquah. Additionally, one respondent challenged the trial court’s decision to close the courtroom during jury deliberations and partially restrict attendance during the verdict, arguing it violated the Sixth Amendment. The Appellate Court found these closures de minimis and rejected the public trial claim.The Supreme Court of Maryland held that the admission of the firearms examiner’s unqualified opinion was not “clear or obvious” error for plain-error review purposes, since the law was unsettled both at trial and on appeal; Abruquah was a case-specific ruling, not a categorical ban on such testimony. The Court also concluded that the courtroom closures were not de minimis but were justified under Waller v. Georgia, given the trial court’s findings of escalating spectator misconduct and concern for juror safety. The Supreme Court reversed the Appellate Court’s judgment on the convictions, affirmed its ruling on the public trial issue, and remanded for further proceedings. View "State v. Thornton" on Justia Law

In 1995, a man was convicted by a jury in the Dauphin County Court of Common Pleas for first-degree murder following the shooting death of another individual related to a drug deal. Two key prosecution witnesses, both facing pending charges themselves, testified against him in exchange for plea agreements. The prosecution did not disclose all pending charges against these witnesses, though defense counsel was able to impeach their credibility based on other known charges. Despite this, the jury convicted the defendant, who was sentenced to life imprisonment. He unsuccessfully challenged his conviction on direct appeal and through multiple post-conviction proceedings in state court.After eventually discovering the full extent of the witnesses' pending charges, the petitioner filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Middle District of Pennsylvania, asserting a Brady violation. The District Court denied the petition as untimely under the statute of limitations, and subsequent requests for a certificate of appealability were also denied. Following a significant change in Third Circuit law announced in Dennis v. Secretary, Pennsylvania Department of Corrections, the petitioner sought to reopen his federal habeas case under Federal Rule of Civil Procedure 60(b)(6). After a remand for further analysis, the District Court again denied the Rule 60(b)(6) motion, finding that the factors for extraordinary relief were not met.The United States Court of Appeals for the Third Circuit reviewed the denial, applying an abuse-of-discretion standard and weighing the Cox factors. The Court held that, although the materiality and diligence factors favored the petitioner, the remaining factors—likelihood of success, finality and comity, lack of actual innocence, and non-capital sentence—strongly disfavored relief. The Third Circuit affirmed the District Court’s denial of the Rule 60(b)(6) motion. View "Bracey v. Superintendent Rockview SCI" on Justia Law