Justia Constitutional Law Opinion Summaries

The case involves a defendant who, after pleading guilty to conspiring to provide material support to ISIS, was released on bail but later violated release conditions, including absconding from supervision and failing to appear at a court-ordered status conference. Her conduct included removing an electronic monitoring device and attempting to flee, resulting in her rearrest. She later entered into a plea agreement, waiving indictment and pleading guilty to failure to appear under 18 U.S.C. § 3146, as well as agreeing to an enhancement under 18 U.S.C. § 3147 for committing the offense while on release. In exchange for her plea, the government agreed not to pursue additional charges carrying potentially higher penalties.After her guilty plea but before sentencing, the defendant moved to withdraw her plea, arguing her conduct did not fall within the scope of § 3146 because she was not released under the Bail Reform Act. The United States District Court for the Eastern District of New York denied her motion, finding a factual basis for her plea, rejecting her arguments, and sentencing her to 230 months’ imprisonment, including consecutive sentences for failure to appear and the § 3147 enhancement.On appeal to the United States Court of Appeals for the Second Circuit, the defendant argued the district court erred in denying her plea withdrawal and that applying the § 3147 enhancement violated the Double Jeopardy Clause. The Second Circuit held that the defendant’s appellate waiver, which expressly foreclosed challenges that her conduct was outside the statute’s scope, barred her first claim. The court further held that applying the § 3147 enhancement to a § 3146 conviction does not violate the Double Jeopardy Clause, as Congress clearly intended cumulative punishments. The Second Circuit therefore dismissed the appeal in part and otherwise affirmed the district court’s judgment. View "United States v. Ceasar" on Justia Law

A husband and wife, both originally from Pakistan, married there in 2008 before moving to Houston, Texas, where they accumulated substantial community assets during their marriage. The wife alleges she suffered ongoing abuse from the husband. In 2012, the husband sent the wife back to Pakistan under the pretext of renewing her visa, and in early 2013, he divorced her without her knowledge via a unilateral Islamic talaq proceeding in Pakistan. The wife was not informed of the proceedings, was not served with process, and only learned of the divorce two years later. Upon returning to Houston, she filed for divorce and sought a division of marital property in Texas.The 295th District Court of Harris County dismissed the wife’s divorce petition for lack of jurisdiction, granting comity to the Pakistani divorce judgment. The trial court found that under Pakistani law, the wife was precluded from further property claims, and since Pakistan does not recognize community property, the court rendered a take-nothing judgment against her. The Court of Appeals for the First District of Texas affirmed this judgment, agreeing that the Pakistani proceedings were conclusive.The Supreme Court of Texas reviewed the case and reversed the lower courts’ decisions. It held that the notice provided to the wife—five days of publication in a small Pakistani newspaper—was constitutionally inadequate when the husband could have easily provided direct notice. The court determined that such notice failed to satisfy fundamental principles of due process and natural justice, and that Texas courts may not afford comity to a foreign judgment obtained through procedures that violate constitutional guarantees. The case was remanded to the trial court for further proceedings consistent with this opinion. View "AZHAR v. CHOUDHRI" on Justia Law

After the Supreme Court’s Dobbs decision, Tennessee enacted a near-total abortion ban and later passed the Underage Abortion Trafficking Act, which included the “Recruitment Provision.” This provision criminalizes intentionally recruiting an unemancipated minor for an abortion that would be illegal in Tennessee, even if the procedure is legal where performed. Two advocates for abortion rights, Welty and Behn, regularly provide counseling and information to minors about obtaining legal abortions, including out-of-state options. Concerned that the new law would criminalize their advocacy and speech, they filed a pre-enforcement suit against several district attorneys general, alleging First Amendment violations.The case was first reviewed by the United States District Court for the Middle District of Tennessee. After a preliminary injunction hearing and cross-motions for summary judgment, the district court granted summary judgment in favor of Welty and Behn, holding that the Recruitment Provision is both unconstitutional as applied and facially overbroad under the First Amendment. The district court issued an injunction preventing enforcement of the Recruitment Provision by the defendants, but rejected the plaintiffs’ claim that the law was unconstitutionally vague.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s rulings de novo. The Sixth Circuit affirmed the lower court’s holding, concluding that the Recruitment Provision constitutes unconstitutional viewpoint discrimination and is substantially overbroad, thus facially violating the First Amendment. The court determined that the statute impermissibly restricts protected speech regarding legal abortions and cannot survive strict scrutiny. The court also affirmed the scope of the district court’s injunction, which barred enforcement of the Recruitment Provision. View "Welty v. Dunaway" on Justia Law

The defendant was convicted after jury trials in 2011 and 2012 of attempted murder, evading an officer, unlawfully taking a vehicle, and shooting at an inhabited dwelling. Each count included enhancements for gang involvement and firearm use, and he was sentenced to a total of 46 years and eight months to life in prison. Following direct appeal, the judgment was modified to reflect life with the possibility of parole on two counts, with a minimum parole eligibility of 15 years, and otherwise affirmed.Years later, the defendant filed a petition for recall and resentencing under California Penal Code section 1170, subdivision (d)(1), arguing that as a juvenile at the time of the offense and having served over 15 years, his lengthy sentence was effectively a life without parole (LWOP) term. He relied on appellate decisions holding that juvenile offenders sentenced to de facto LWOP terms should be eligible for relief under section 1170, subdivision (d)(1), on equal protection grounds. The Los Angeles County Superior Court reviewed the petition, considered recent appellate decisions and parties’ arguments, and denied the petition.The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. Applying de novo review, it held that the defendant’s sentence did not constitute the functional equivalent of LWOP, as he was eligible for youthful offender parole under section 3051 at age 41. The court determined that section 1170, subdivision (d)(1) only applies to explicit LWOP sentences for juveniles and does not violate equal protection by excluding those sentenced to lengthy indeterminate terms. It affirmed the trial court’s denial of the petition. View "People v. Cortez" on Justia Law

A group of Riverside County residents, having voted in the November 2025 special election on Proposition 50, challenged the actions of the county sheriff’s department. The sheriff, responding to claims by a community group of a significant discrepancy between unofficial poll worker ballot intake logs and the Registrar of Voters’ final certified count, obtained search warrants and seized approximately 650,000 voted ballots. The Registrar of Voters maintained any discrepancy was minimal and within normal bounds, and no party disputed that the alleged discrepancy could not have changed the election outcome.After the sheriff’s department seized and began examining the ballots, the voters filed a petition for a writ of mandate directly in the Supreme Court of California. They argued the sheriff’s actions violated the Elections Code’s strict rules regarding the custody of ballots and requested the court order the immediate return of the ballots to the Registrar. The Registrar did not oppose this relief, and both the Secretary of State and Attorney General supported the petitioners’ position. The sheriff argued his actions were lawful as part of a criminal investigation supported by search warrants.The Supreme Court of California held that the seizure and removal of the ballots from the Registrar’s custody was unlawful under Elections Code section 15551, subdivision (d). The Court explained that the Elections Code specifically requires that voted ballots remain in the custody of the elections official at all times and that this rule applies even during criminal investigations. The Court issued a peremptory writ of mandate directing the sheriff to return all packages containing voted ballots to the Registrar and to refrain from further handling of the ballots, but denied the request for additional relief regarding non-ballot election materials and chain-of-custody reporting. The Court’s order superseded the previously issued superior court search warrants to the extent of any conflict. View "Cervantes v. Bianco" on Justia Law

The defendant was charged with reckless discharge of a firearm, unlawful possession of a weapon by a felon (UPWF), and misdemeanor domestic battery after an incident in his Chicago apartment. He had a prior felony conviction for aggravated unlawful use of a weapon, specifically for possessing a firearm without a valid Firearm Owners Identification (FOID) card. Evidence at trial showed he possessed and fired a handgun during a domestic dispute. The circuit court of Cook County, after a bench trial, found him guilty on all counts.On direct appeal to the Illinois Appellate Court, the defendant challenged the constitutionality of the UPWF statute under the Second Amendment, arguing both facially and as applied to him in light of New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The appellate court rejected both challenges, holding that Bruen’s standards did not apply to felons and that sufficient historical precedent supported felon firearm bans. The appellate court also considered and rejected the defendant’s as-applied challenge, despite the State’s argument that the issue was forfeited because it was not raised before the circuit court.The Supreme Court of the State of Illinois reviewed the appellate court’s judgment regarding the as-applied constitutional challenge. The court held that an as-applied challenge requires a developed factual record, which was lacking because the defendant did not raise the issue in the circuit court for an evidentiary hearing. The court vacated the part of the appellate court judgment that considered the merits of the as-applied challenge, affirmed the remainder of the appellate court’s judgment, and affirmed the defendant’s UPWF conviction. The main holding is that an as-applied constitutional challenge to the UPWF statute cannot be decided without a factual record developed in the trial court. View "People v. Benson" on Justia Law

A two-year-old child was discovered deceased in the home of the appellant, who had been dating the child’s mother. Police, suspecting foul play based on blood found at the scene, obtained a search warrant for electronic devices in the home. The search revealed videos of the appellant abusing the child, disturbing text messages, and evidence of file deletion software use. At trial, extensive forensic and medical evidence indicated the child was smothered, not killed by a fall, and DNA linked the appellant to a bloody pillow found in the crib. The appellant was convicted of capital murder and sentenced to life without parole.The Second Court of Appeals reviewed the case, focusing on the appellant’s claim that the search of electronic devices violated the Fourth Amendment because the warrant’s supporting affidavit lacked sufficient facts to establish probable cause. The court found the search unconstitutional and conducted a constitutional harm analysis, concluding that admission of the incriminating evidence from the devices was harmful. The court reversed the conviction, finding the GoPro video particularly prejudicial and determining that the other evidence was not overwhelming.The Court of Criminal Appeals of Texas reviewed the case on the State’s petition for discretionary review. The court assumed error in admitting the evidence and addressed only harm, holding that the court of appeals applied the wrong harm standard. Because the police acted in good faith reliance on the warrant, exclusion was required only under Texas’s statutory rule, so the nonconstitutional harm standard applied. The court found that, given the overwhelming medical, forensic, and DNA evidence, any error in admitting the videos and file deletion evidence was harmless. The judgment of the court of appeals was reversed and the trial court’s conviction was affirmed. View "STALEY v. STATE OF TEXAS" on Justia Law

A financial trustee acting on behalf of bondholders filed a proof of claim for $8.5 billion in the Commonwealth of Puerto Rico’s bankruptcy-like restructuring proceedings. The claim was based on allegations that the Commonwealth had impaired statutory and constitutional rights that were intended to protect bondholders in connection with revenue bonds issued by the Puerto Rico Electric Power Authority (PREPA), a public utility corporation. The Commonwealth had enacted laws that, according to the trustee, limited PREPA’s ability to set rates and satisfy its bond obligations, thereby breaching a statutory covenant not to impair PREPA’s ability to repay the bonds. The trustee characterized these statutory protections as a material inducement for investors to purchase the bonds.The United States District Court for the District of Puerto Rico, acting as the Title III court under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), had previously confirmed the Commonwealth’s Plan of Adjustment. This Plan created separate classes of claims, including one (Class 64) for claims subordinated under 11 U.S.C. § 510(b), which covers damages “arising from the purchase or sale” of a debtor’s security. The trustee’s claim was classified in Class 64, which receives no distribution, rather than as a general unsecured claim (Class 58), which would have allowed a partial recovery. The district court held that the trustee’s claim was properly subordinated under § 510(b).The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court’s judgment, holding that § 510(b) applies to the trustee’s claim because the damages sought arose from the purchase of PREPA’s revenue bonds, induced by the alleged statutory protections. The court also rejected procedural and constitutional avoidance arguments, and found that any challenge to the level of subordination was waived. View "FOMB v. SIG Structured Products, LLC" on Justia Law

Several individuals living within a five-mile radius of the Seattle-Tacoma Airport sued two major airlines and the Port of Seattle. They alleged that pollution from aircraft takeoffs and landings caused harm to their health and property, particularly from particulate matter and other pollutants released by aircraft engines and fuselages. Plaintiffs claimed the defendants had knowledge of studies linking these pollutants to negative health outcomes and property devaluation but failed to remediate or prevent further pollution. The affected community was described as disproportionately composed of minority, immigrant, and low-income residents.The plaintiffs initially brought their case in King County Superior Court, but the defendants removed it to the United States District Court for the Western District of Washington. The plaintiffs advanced state tort and constitutional claims, seeking various remedies including damages, injunctive relief, and remediation. The defendants moved to dismiss, arguing that the claims were a collateral attack on federal agency actions, were expressly and impliedly preempted by federal law, and failed to state a claim. The district court denied the motions, finding that the complaint did not directly challenge any specific agency order and that preemption was not clearly established at this stage. The district court certified its order for interlocutory appeal.Reviewing the case on interlocutory appeal, the United States Court of Appeals for the Ninth Circuit held that the district court properly exercised jurisdiction because the collateral attack doctrine did not apply; defendants could not identify any specific agency orders inescapably implicated by the plaintiffs’ claims. However, the court held that the claims were expressly preempted by Section 233 of the Clean Air Act, which bars states from enforcing any emission standards for aircraft pollutants unless identical to federal standards. The court reversed the district court’s order denying the motion to dismiss and remanded the case. View "CODONI V. PORT OF SEATTLE" on Justia Law

In this case, the petitioner was convicted of capital murder and sentenced to death following a 2003 armed robbery in Houston, Texas, during which a restaurant employee was killed. Key evidence included eyewitness testimony, statements from co-defendants and jailhouse informants, and information about the petitioner’s criminal history and conduct in prison. The prosecution’s case centered on the petitioner being the sole gunman, though there was conflicting testimony about whether a second person entered the restaurant.The Texas Court of Criminal Appeals affirmed the conviction and sentence on direct appeal and denied state habeas relief, finding the petitioner’s subsequent and additional habeas claims to be procedurally barred as an abuse of the writ. The petitioner then sought federal habeas relief in the United States District Court for the Southern District of Texas, raising thirteen claims, including allegations of false evidence, inconsistent prosecutorial theories, Brady violations, ineffective assistance of counsel, and racial bias. The district court denied relief on the merits where permitted and found the remaining claims procedurally barred due to default under Texas law, ruling that the petitioner had not shown cause, actual prejudice, or a fundamental miscarriage of justice to excuse the default.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether a certificate of appealability (COA) should issue for the claims dismissed as procedurally barred. The court held that the petitioner failed to show that jurists of reason could debate the district court’s procedural rulings. The court concluded that the claims were subject to an adequate and independent state procedural bar, and the petitioner had not demonstrated cause and prejudice or actual innocence to overcome that bar. The Fifth Circuit therefore denied the application for a certificate of appealability. View "Marshall v. Guerrero" on Justia Law