Justia Constitutional Law Opinion Summaries

The case involved a defendant who killed her two young daughters by asphyxiation, believing she was protecting them from imagined abuse and exploitation by family members. The defendant had a documented history of severe mental illness, including schizoaffective disorder with both schizophrenic and bipolar symptoms, and had experienced increasing paranoia and delusions in the months before the offenses. After the killings, she drove to the police station, called 911, and confessed. Prior to the incident, she had made several reports to police, which were investigated and determined to be unfounded, and she was involuntarily hospitalized months before the offenses. The children were returned to her care following her treatment, and the killings occurred two months later.Following her arrest, questions arose regarding her competency to stand trial and potential insanity at the time of the offense. A defense-retained expert initially found her incompetent, but after further evaluation, both the defense and a State-retained expert agreed she was competent. The trial court later appointed the State’s expert as a “disinterested” expert for the insanity evaluation. At trial, the defense challenged the admissibility of the State’s expert’s testimony, arguing that the expert violated the defendant’s Fifth Amendment rights during the competency exam by inquiring about her mental state at the time of the offense, and that the expert was not a disinterested party as required by statute. The trial court overruled the objection. The jury found the defendant guilty of capital murder, and she was sentenced to life without parole.The Fifth District Court of Appeals initially held the defendant had failed to preserve her complaints for review but alternatively found that, even if error occurred, there was no substantial harm. The Texas Court of Criminal Appeals found that the defendant had preserved her claims. However, it held that even if the appointment of the expert was error, it did not affect the defendant’s substantial rights because the expert’s testimony did not have a substantial and injurious effect on the verdict. The court also concluded there was no constitutional error under the Fifth Amendment, as none of the allegedly improper statements were introduced by the State at trial. The judgment of the court of appeals was affirmed. View "MCDONALD v. STATE OF TEXAS" on Justia Law

Wyoming’s Constitution requires the legislature to provide a thorough and efficient education for all students. Historically, public education was funded by local property taxes, resulting in significant disparities between districts. Decades of litigation and legislative reform led to a statewide, cost-based funding model for school operations and facilities. This model, known as the legislative model (LM), was intended to ensure equal educational opportunities by using a block grant system based on the estimated cost of an adequate education (the “basket of goods and services”). Periodic recalibrations and annual adjustments for inflation were required to keep the model current.The plaintiffs, including the Wyoming Education Association and several school districts, sued in 2022, alleging that the legislature’s funding model was no longer cost-based, wasn’t properly adjusted for inflation, and lacked funding for certain innovations such as elementary school counselors, nutrition services, and school resource officers. They also claimed the State’s facilities oversight was inadequate. The District Court of Laramie County, after a bench trial, found in favor of the plaintiffs on all issues, concluding that the legislature failed to fund actual costs, address inflation, and include necessary innovations, and that the State’s facilities process was constitutionally deficient.The Supreme Court of Wyoming reviewed the case. The Court affirmed the district court’s findings that the legislature violated students’ equal protection rights by failing to fund the true cost of teacher salaries and by not properly adjusting for inflation. However, it reversed the requirement to fund a one-to-one technology ratio, nutrition services, and school resource officers, finding insufficient evidence that these innovations required statewide funding. The Court also reversed the order requiring statewide assessment of educational suitability for facilities, holding the State’s administrative process was constitutionally adequate. The Court ended the lower court’s retention of jurisdiction, assuming the legislature would act in good faith to comply with constitutional requirements. View "The State of Wyoming v. Wyoming Education Association" on Justia Law

A group of organizations and individuals challenged the constitutionality of a statewide initiative approved by Washington voters in November 2024. The initiative, known as I-2066, enacted broad changes to energy regulation, including requirements for utilities and local governments to ensure natural gas access, restrictions on local air quality regulators, removal of zero-emission goals from state law, amendments to the Decarbonization Act, and limitations on the state building code council’s authority regarding gas usage and transitions away from fossil fuels.The King County Superior Court reviewed the case following cross-motions for summary judgment by the parties. The court declared I-2066 unconstitutional in its entirety, finding that it violated three constitutional requirements: it impermissibly encompassed more than one subject, failed to include its subjects in the title, and failed to set forth the laws it amended. This judgment was appealed directly to the Supreme Court of the State of Washington.The Supreme Court of the State of Washington reviewed the superior court’s ruling de novo. The court held that I-2066 violated the single-subject requirement of article II, section 19 of the Washington Constitution. It found that the initiative combined several distinct subjects with separate regulatory effects, lacking the necessary rational unity among its provisions. The court concluded that the provisions introducing distinct subjects were not severable and thus rendered the entire initiative unconstitutional. The Supreme Court affirmed the superior court’s judgment on the narrower ground of the single-subject violation and did not address the other constitutional arguments raised. View "Climate Sols. v. State" on Justia Law

On October 1, 2021, Heather Marichal was involved in a car accident in Auburn, Maine, after driving on the wrong side of the road and crashing into another vehicle, then striking a snowplow. Marichal admitted to an officer that she had consumed alcohol at a brew fest and was the sole driver. She submitted to an Intoxilyzer test that showed a blood-alcohol content of .21 grams per 210 liters of breath. Marichal was charged with criminal operating under the influence (OUI), a Class D offense.The Androscoggin County Unified Criminal Docket handled the case, with multiple continuances throughout 2022, 2023, and 2024. Marichal sought to secure the appearance of a defense witness who allegedly would testify that someone else was driving. She served a subpoena and moved for a writ of capias ad respondendum when the witness ignored the subpoena. The court issued a civil warrant for the witness, but he did not appear for the December 2024 trial. Marichal filed motions in limine to admit hearsay statements from the witness and requested another arrest warrant. The trial court denied both the motion to continue and the motion in limine, finding Marichal had not demonstrated due diligence or likelihood of securing the witness, and that the hearsay exception was not met.The Maine Supreme Judicial Court reviewed the appeal following Marichal’s conditional guilty plea. The Court held that the trial court did not abuse its discretion in denying the motion to continue, as Marichal had not shown due diligence in securing the witness nor a likelihood that a continuance would procure the witness’s attendance. The Court also determined that Marichal’s constitutional rights to compulsory process and due process were not violated, as the witness’s absence was not attributable to State action or omission. The judgment of conviction was affirmed. View "State of Maine v. Marichal" on Justia Law

Chinwendu Alisigwe, a lawful permanent resident, was suspected by international law enforcement agencies of using fraudulent passports and identification documents to open bank accounts in the names of real individuals. Between 2017 and 2020, he opened thirty-six accounts, deposited millions from fraudulent schemes, transferred money to disguise its origins, and sent funds abroad. In 2019 and again in 2021, officers at John F. Kennedy International Airport stopped Alisigwe, manually searched his cellphone, and found evidence of identity theft and communications with co-conspirators.The United States District Court for the Southern District of New York denied Alisigwe’s motion to suppress evidence from the cellphone searches, reasoning that such searches require reasonable suspicion, and finding that law enforcement had reasonable suspicion both times due to ongoing investigations and evidence linking Alisigwe to fraudulent documents. The district court also imposed sentencing enhancements: an eighteen-point enhancement for intended loss under U.S.S.G. § 2B1.1(b)(1)(J), and a two-point enhancement for obstruction of justice under § 3C1.1 based on Alisigwe’s testimony at a duress hearing, which the court found to be fabricated.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The main holding is that no suspicion is required before the government searches a traveler’s cellphone at the border; routine border searches of property, including cellphones, are reasonable under the Fourth Amendment. The court further held that the First Amendment does not impose an independent warrant requirement for border searches of cellphones. The court also upheld the district court’s application of sentencing enhancements for both intended loss and obstruction of justice. View "United States v. Alisigwe" on Justia Law

The case centers on a challenge to a state law enacted in 2023, which prohibits health care providers from administering certain types of gender-affirming medical treatments to minors, including puberty blockers and cross-sex hormones, for the purpose of aligning a minor’s sex with their gender perception when inconsistent with their biological sex. Exceptions exist for minors with medically verifiable disorders of sex development and for those already receiving such treatments prior to the law’s effective date. Three minors, their parents, and a physician, Dr. Casas, who treats minors with gender dysphoria, initiated legal proceedings seeking declaratory and injunctive relief, arguing the law violates the North Dakota Constitution.The District Court of Burleigh County reviewed the case. It dismissed the minor plaintiffs and their parents for lack of standing, based on its interpretation that the law did not apply to minors receiving treatment before the effective date. The court found Dr. Casas had standing to pursue certain claims, including equal protection and personal autonomy on behalf of his patients, but not parental rights claims. After a seven-day trial and extensive evidence, the court concluded the law responded to legitimate concerns regarding the risks and effectiveness of gender-affirming treatments for minors and determined the statute did not violate constitutional guarantees of equal protection or personal autonomy. The court denied declaratory and injunctive relief, but clarified the law’s exception for ongoing treatment.On appeal, the Supreme Court of North Dakota addressed only whether the statute’s prohibition on gender-affirming medication for minors violates Article I, §§ 1 or 21 of the state constitution. The court held that minors do not have a fundamental right to a particular course of medical treatment under Article I, § 1. It further found the law does not classify based on sex or transgender status and is subject to rational basis review. The statute was deemed rationally related to the state’s legitimate interest in protecting minors’ health and welfare. The court affirmed the district court’s denial of relief. View "T.D. v. Wrigley" on Justia Law

The defendant was living with his romantic partner, C.P., when an argument escalated into physical and verbal abuse. During the incident, he forcibly cut C.P.’s hair, took her designer handbags and jewelry, threatened to harm her and her family if she reported him to police, forced her to withdraw cash from an ATM, and left with her possessions and car. C.P. reported the incident roughly a week later.The Superior Court of the District of Columbia indicted the defendant on eleven counts, but the jury convicted him of only two: first-degree theft and threatening to injure or kidnap a person. The court sentenced him to concurrent terms of twenty-eight months’ imprisonment, followed by three years’ supervised release, and ordered restitution of $3,638.60 for stolen property. The court also imposed assessments of $1,000 for each conviction under the Victims of Violent Crime Compensation Act (VVCCA). The defendant did not object to the VVCCA assessments at sentencing but timely appealed, arguing that the assessments constituted excessive fines in violation of the Eighth Amendment.The District of Columbia Court of Appeals reviewed the case. Applying the gross disproportionality standard articulated by the Supreme Court in United States v. Bajakajian, the court considered the nature and gravity of the offenses, the statutory penalties, the defendant’s culpability, and the harm suffered by the victim. The court concluded that the $2,000 in VVCCA assessments was not grossly disproportional to the gravity of the defendant’s offenses, especially given the statutory maximum fines and the significant harm caused. The court therefore held the assessments were constitutional and affirmed the judgment of the Superior Court. View "Delgado v. United States" on Justia Law

The defendant, a Maine resident with multiple prior felony convictions, was arrested after a state trooper observed him at a gas station and detained him based on an active felony warrant. During the arrest, Levasseur admitted to possessing a hunting rifle in his truck, which was loaded, and to having methamphetamine in the vehicle. He later stated he intended to hunt deer for food, although he lacked a hunting license, and disclosed a daily methamphetamine addiction. His criminal history included three illegal firearm possession convictions and other felonies, including drug possession and bail violations.A grand jury indicted Levasseur for possessing a firearm as a felon under 18 U.S.C. § 922(g)(1). He moved to dismiss the indictment in the United States District Court for the District of Maine, arguing the statute was unconstitutional as applied to him under the Second Amendment, referencing New York State Rifle & Pistol Ass’n v. Bruen and later United States v. Rahimi. The district court denied both his initial and renewed motions, ruling that his felony conviction for methamphetamine possession rendered him sufficiently dangerous to be disarmed under the Second Amendment, based on historical analogues of disarming categories of dangerous individuals.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s legal rulings de novo. The First Circuit assumed, without deciding, that the Second Amendment could apply to individuals with felony convictions and entertained Levasseur’s as-applied challenge. The court held that Levasseur failed to demonstrate error in the district court’s determination that he could constitutionally be disarmed due to posing a special danger of misusing firearms. Accordingly, the First Circuit affirmed his conviction, holding that 18 U.S.C. § 922(g)(1) is constitutional as applied to him. View "US v. Levasseur" on Justia Law

Three individuals alleged that New Jersey child protection caseworkers violated their constitutional rights during investigations into suspected child abuse. The caseworkers entered the plaintiffs’ home without a warrant, pressured them to sign family agreements under threat of child removal, and ultimately removed the children from parental custody without prior court authorization. The removal was based on concerns about one parent’s alleged past violence, home conditions, and another parent’s mental health history. The plaintiffs claimed these actions violated their Fourth Amendment rights and their substantive and procedural due process rights under the Fourteenth Amendment.The United States District Court for the District of New Jersey dismissed the complaint, finding the defendants were entitled to qualified immunity. The court relied on facts outside the complaint, including allegations from a child abuse report and statements from caseworkers, to support its ruling. The District Court also dismissed claims for money damages against the Division and its employees in their official capacities and found one plaintiff lacked standing. On appeal, the United States Court of Appeals for the Third Circuit reviewed the dismissal de novo, considering only the facts alleged in the complaint and not external materials.The Third Circuit affirmed the dismissal of most claims, including the substantive and procedural due process claims, holding that the law was not clearly established to put the defendants on notice that their conduct violated constitutional rights. However, the court reversed the dismissal of the Fourth Amendment claim against the caseworker who entered the home without a warrant. The court held that the plaintiffs plausibly alleged a violation of clearly established Fourth Amendment law, and that qualified immunity did not shield the caseworker from liability on this claim. The case was remanded for further proceedings on the Fourth Amendment claim. View "O'Bryant v. DCP&P" on Justia Law

Police officers observed a man and his girlfriend in a car at a location known for drug trafficking. After smelling marijuana and spotting evidence of its use in the vehicle, the officers approached the man inside a store, where he consented to a pat-down search that yielded nothing. Outside the store, the couple initially consented to a search of the car but later revoked consent, leading the officers to arrest and handcuff the man. He was searched again on the hood of the car, with no contraband found. The officers then transported him to the police station, where they conducted a strip search solely for evidence, but nothing was recovered.The U.S. District Court for the Middle District of Pennsylvania reviewed the man’s federal civil-rights claims under 42 U.S.C. § 1983, challenging the stop, arrest, and three searches as unreasonable under the Fourth Amendment and retaliatory under the First Amendment. The District Court granted summary judgment to the officers on all federal claims, finding the initial stop, arrest, and first two searches reasonable, and the strip search protected by qualified immunity. It dismissed the state-law claims for lack of supplemental jurisdiction.The United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that while the initial stop, arrest, and two searches were reasonable, the search-incident-to-arrest doctrine does not justify strip searches outside of a jail or prison without a warrant, exigent circumstances, or consent. A warrant supported by probable cause is required for strip searches in such contexts. However, because this legal limitation was not clearly established at the time, the officers were entitled to qualified immunity. The court also concluded that the First Amendment retaliation claim was barred by qualified immunity. View "Beatty v. Gardner" on Justia Law