Justia Constitutional Law Opinion Summaries

A man with two prior felony convictions for carrying a pistol without a license in the District of Columbia was sentenced in 2022 to a period of supervised probation in lieu of imprisonment for his second offense. While still under this court-ordered supervision, he knowingly possessed a firearm, which was reportedly stolen and modified for automatic firing, and was alleged to have brandished it during a shootout. He was indicted by a federal grand jury under 18 U.S.C. § 922(g)(1), the federal felon-in-possession statute.In the United States District Court for the District of Columbia, the defendant moved to dismiss the indictment, arguing that § 922(g)(1) violated the Second Amendment both facially and as applied to him, particularly in light of the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, which emphasized historical tradition over means-end scrutiny in Second Amendment cases. The district court rejected his arguments, holding that earlier circuit precedent (Medina v. Whitaker) upholding § 922(g)(1) remained good law, and denied the motion to dismiss. The defendant then pleaded guilty while preserving his right to appeal the constitutional issue.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court held that, even assuming prior precedent did not control and that § 922(g)(1) implicated conduct covered by the Second Amendment, there exists a widespread historical tradition of temporarily disarming felons while they are serving their criminal sentences, including during periods of noncustodial supervision such as probation or supervised release. Therefore, § 922(g)(1) is constitutional as applied to individuals still serving their sentences, and is not facially unconstitutional. The court affirmed the judgment of the district court. View "USA v. Richardson" on Justia Law

Three firefighters and a police officer responded to a call about a woman found unconscious under a bridge. The firefighters woke her, and although she refused medical treatment, she did provide her name. When the police officer arrived, he ran a warrant check using the name she gave and discovered an outstanding warrant. The officer then arrested her, and during a search at the jail, methamphetamine was found in her possession. She was charged with possession of methamphetamine and possession of drug paraphernalia.The case proceeded in Reno District Court, where the defendant moved to suppress the evidence obtained from the search, arguing that she was unlawfully seized during what began as a public welfare check. The district court conducted a hearing, found that she had not been seized for purposes of the Fourth Amendment, denied the suppression motion, and later convicted her on stipulated facts. She received a suspended sentence and probation. On appeal, the Kansas Court of Appeals reversed the district court, holding that she had been unlawfully seized, and ordered suppression of the evidence, thus vacating her convictions and sentence. One judge dissented.Upon review, the Supreme Court of the State of Kansas held that the Fourth Amendment does not restrict its application only to law enforcement officers but to all government actors. The court considered the actions of both the firefighters and the police officer in assessing whether a reasonable person in the defendant's position would have felt free to end the encounter. The court concluded that the officials’ conduct did not amount to a seizure because their words and actions conveyed that she was free to leave. Therefore, the court reversed the judgment of the Court of Appeals and affirmed the district court’s decision to deny the motion to suppress. View "State v. Willard " on Justia Law

The case concerns a man who was convicted by an Alabama jury of murdering his girlfriend and her mother. The key facts established at trial showed that after the murders occurred in the victims’ home, the defendant left the state with the children, the victims’ car, and their checks, traveling to Cleveland, Ohio. Witness testimony placed him at the scene around the time of the murders, and his fingerprints were found on duct tape used to bind one of the victims. Additional evidence included his efforts to obtain cash using the victims’ checks, his lies about needing money for a child’s medical care, and his subsequent standoff with police in Cleveland. Family members of the defendant, including his aunt and uncle, were involved in alerting police to possible trouble at the victims’ home before the bodies were discovered.The Alabama Court of Criminal Appeals, reviewing the conviction and death sentence, agreed that the trial court erred in admitting testimony from a police investigator about a statement the defendant allegedly made to his aunt (“I hurt them girls”) without proper impeachment procedure. However, the appellate court held that this error was harmless beyond a reasonable doubt, given the overwhelming evidence of guilt.After unsuccessful state postconviction proceedings, the defendant sought federal habeas relief in the United States District Court for the Northern District of Alabama, arguing that admission of his alleged statement violated his federal due process rights. The district court denied relief, ruling that any error was not prejudicial in light of the full record. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed, holding that admission of the statement did not violate due process because it was not a crucial or highly significant factor in the conviction, and any error was harmless under both state and federal standards. View "Brown v. Commissioner, Alabama Department of Corrections" on Justia Law

The mayor of a city in Massachusetts decided to commission and install two ten-foot-tall bronze statues of Saint Michael and Saint Florian on the façade of a new public safety building, using public funds. Both figures are Catholic saints, recognized for their religious significance and as patron symbols of police and firefighters. The statues were to be the only adornments on the building, which serves various public functions and is located on a prominent city street. The city had already spent over $760,000 on the statues, with additional costs anticipated for their installation. News of the statues’ religious symbolism led to significant public opposition, including protests, petitions, and statements from local faith leaders expressing concern about the exclusionary message conveyed by featuring only Catholic figures on a municipal building.Fifteen city residents and taxpayers filed suit in Norfolk County Superior Court against the city and the mayor in his official capacity. They sought to enjoin further expenditure of public funds and prohibit installation of the statues, arguing that the actions violated Article 3 of the Massachusetts Declaration of Rights, as amended, which bars the establishment or subordination of any religious sect. The Superior Court judge granted a preliminary injunction stopping further installation and denied the city’s motion to dismiss, finding the plaintiffs had standing as taxpayers and had shown a likelihood of success under the standard set in *Colo v. Treasurer & Receiver General*.On direct appellate review, the Supreme Judicial Court of Massachusetts affirmed the Superior Court’s orders. The Court held that the plaintiffs had standing under the ten-taxpayer statute and that the constitutionality of the statues must be analyzed under the framework set out in *Colo*, which emphasizes constitutional text, history, purpose, and factors such as secular purpose, primary effect, and potential for divisiveness. The Court concluded that the statues likely violated Article 3 by conveying government endorsement of a particular religion, and that the public interest favored an injunction. The orders granting the preliminary injunction and denying the motion to dismiss were affirmed. View "Fitzmaurice v. City of Quincy" on Justia Law

Three related business entities and an individual were audited by the Mississippi Department of Revenue (MDOR) for sales and income taxes covering various periods between 2019 and 2021. After a meeting to discuss the audit results, the taxpayers updated their mailing address with MDOR. MDOR subsequently determined that the entities and individual owed tax assessments and mailed these assessments to the updated address. The taxpayers later claimed they did not receive the assessments and missed the statutory deadline to appeal.The taxpayers attempted to appeal the assessments to the MDOR Board of Review, but their appeal was denied as untimely. They then appealed to the Board of Tax Appeals, which also affirmed the denial. The taxpayers next appealed to the Hinds County Chancery Court, arguing that MDOR had not sufficiently proven the assessments were actually mailed and that the statutory notice provisions violated due-process rights. Both parties moved for summary judgment. The chancery court granted summary judgment in favor of MDOR, finding the statutory notice provisions had previously been upheld as constitutional.The Supreme Court of Mississippi reviewed the case de novo, considering both the grant of summary judgment and the legal questions presented. The Court held that MDOR had provided sufficient evidence, through affidavits and mailing records, to establish that the assessments were mailed according to statutory requirements. The Court also held that the notice provisions in Mississippi Code Sections 27-65-37(2) and 27-77-5(1) are constitutional, as they are reasonably calculated to provide notice and an opportunity to contest the assessments, satisfying due-process requirements. The judgment of the Hinds County Chancery Court was affirmed. View "Carroll Brothers, LLC v. Graham" on Justia Law

In September 2020, Microsoft and Google each reported to the National Center for Missing and Exploited Children (NCMEC) that images suspected to be child sexual abuse material (CSAM) were uploaded from the same IP address to their platforms. The images were not viewed by the companies or by NCMEC; instead, they were flagged by automated systems after matching hash values of known CSAM. NCMEC forwarded these reports to the Wisconsin Department of Justice, which traced the IP address to Peter Braun's residence. Special Agent Aaron Koehler viewed the images without a warrant, conducted surveillance, and obtained a prior report from 2015 indicating Braun had been observed chatting online with very young girls. Based on this information, Koehler applied for and obtained a state search warrant for Braun’s home, leading to charges of producing CSAM.The United States District Court for the Eastern District of Wisconsin, after referral to a magistrate judge, granted Braun’s motion to suppress the evidence from the search. The district court found that Agent Koehler’s warrantless viewing of the images was unlawful, and that, excluding his descriptions of the images, the warrant affidavit did not establish probable cause. The court also determined that the good-faith exception to the exclusionary rule did not apply. The government appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case, applying de novo review to legal conclusions and clear error review to factual findings. The Seventh Circuit held that, even without the descriptions of the images obtained from the unlawful search, Agent Koehler’s affidavit contained sufficient information—such as the reliability of the reporting sources, the incriminating file name, and corroborating evidence regarding Braun’s prior behavior—to establish probable cause for the search. The court concluded that the decision to seek the warrant was not prompted by the unlawfully obtained information. Accordingly, the Seventh Circuit reversed the district court’s order suppressing the evidence. View "USA v. Braun" on Justia Law

Police in Montgomery County, Maryland, responded to a high-priority call reporting that a Black male had placed three children into the trunk of a black Tesla, possibly indicating a kidnapping. Officers quickly traced the vehicle and address to Fareed Hayat. Upon arriving at his home, they found Hayat and his wife on the porch and initiated questioning. Hayat acted evasively, did not answer whether he had been at the location in question, cut off his wife’s conversation with officers, and attempted to retreat into his house, insisting the police could not enter. The officers prevented him from closing the door, entered the front hall, handcuffed Hayat, and checked on the children’s welfare. After confirming no kidnapping had occurred, the officers released Hayat.Hayat subsequently filed a lawsuit in the United States District Court for the District of Maryland against the officers, the Chief of Police, and Montgomery County. He alleged violations of his Fourth and Fourteenth Amendment rights, as well as various federal and state law claims. The district court dismissed most claims and granted summary judgment to the defendants on the remaining claims, finding that the officers had a reasonable suspicion justifying a Terry stop prior to Hayat’s retreat into his home. The court also held that the officers were justified in entering the home to complete the stop and to confirm the children’s welfare, given the exigency created by Hayat’s conduct.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officers had reasonable articulable suspicion to justify a Terry stop based on corroborated eyewitness accounts and Hayat’s suspicious behavior. The court further held that entry into the home was justified to complete the Terry stop and to ensure the safety of the children, under both the exigent circumstances and “hot pursuit” exceptions to the warrant requirement. The court concluded that Hayat’s Fourth Amendment rights were not violated. View "Hayat v. Diaz" on Justia Law

The Nevada Legislature enacted Assembly Bill 519 in 2023 to promote school district capital projects. This law included specific provisions requiring counties with populations between 52,500 and 57,500 to levy a property tax to fund these projects, with a default tax imposed if such a levy was not enacted by a certain date. At the time of the latest census, only Elko County fell within this population range, making it the sole county affected by these mandatory provisions. Elko County challenged the constitutionality of these sections, arguing that they constituted a local or special law targeting a single county rather than applying statewide.The First Judicial District Court, Carson City, reviewed Elko County’s complaint and granted summary judgment in its favor. The court found that the challenged sections were unconstitutional local or special laws because they singled out Elko County. The court also concluded that these provisions violated the Nevada Constitution’s requirement for a uniform system of county government and severed the offending sections from the rest of the legislation, allowing the remainder of the law to stand. Only the Nevada Legislature appealed this ruling to the next level.The Supreme Court of the State of Nevada affirmed the district court’s decision. The Supreme Court concluded that the population-based provisions of Assembly Bill 519 were not rationally related to the law’s purpose and created an improper, narrowly tailored distinction that targeted Elko County. The Court held that these sections were local or special laws and violated Article 4, Section 20 of the Nevada Constitution by impermissibly regulating county business. As a result, the Supreme Court affirmed the order granting summary judgment and held that the challenged sections of the law were unconstitutional. View "The Legislature of the State of Nevada v. Elko County" on Justia Law

Several individuals and a nonprofit organization in Minnesota, focused on election integrity, wished to publicly advocate their interpretation that certain felons—specifically those still on supervised release—are constitutionally ineligible to vote in Minnesota. State law, however, allows felons to vote once released from incarceration, regardless of whether they are on parole or probation. Concerned about possible prosecution under a Minnesota statute that criminalizes knowingly false statements about voter eligibility made within 60 days of an election, the plaintiffs sought to continue their advocacy without facing criminal or civil penalties.After the Minnesota Supreme Court held that the group lacked standing to challenge the felon voting law in state court, the plaintiffs filed suit in the United States District Court for the District of Minnesota. They sought declaratory and injunctive relief against the enforcement of the election disinformation statute, arguing it violated the First Amendment. In response, the Anoka County Attorney filed a counterclaim, seeking to restrain the plaintiffs from violating the law and to obtain damages. The district court dismissed the plaintiffs’ complaint and denied a preliminary injunction, concluding that the law could constitutionally restrict their speech. The plaintiffs appealed the denial of a preliminary injunction while the counterclaim remained pending.The United States Court of Appeals for the Eighth Circuit reviewed the denial of preliminary injunctive relief and found that the plaintiffs had standing due to both actual and imminent injuries. The court held that the statute at issue regulated protected political speech based on its content and was therefore subject to strict scrutiny. The court determined that Minnesota’s law was not narrowly tailored to serve a compelling state interest, as it both overreached and underreached in its restriction of speech, and also authorized unconstitutional prior restraints. The Eighth Circuit reversed the denial of a preliminary injunction in part, affirmed in part, and remanded for entry of a preliminary injunction in favor of the plaintiffs. View "Minnesota Voters Alliance v. Ellison" on Justia Law

In December 1995, Holsey Ellingburg, Jr. robbed a bank. He was convicted by a jury in August 1996 and sentenced in November 1996 by the United States District Court for the Western District of Missouri, which ordered him to pay $7,567.25 in restitution. At the time of his offense, the Victim and Witness Protection Act of 1982 (VWPA) governed restitution, limiting liability to twenty years after judgment. However, the Mandatory Victim Restitution Act (MVRA), enacted after his offense but before his conviction, extended the government’s ability to collect restitution to the later of twenty years after judgment or twenty years after release from imprisonment, and made interest awards mandatory unless the defendant was unable to pay. After his release in 2022, Ellingburg challenged the continued enforcement of his restitution order, arguing that retroactive application of the MVRA violated the Ex Post Facto Clause.The district court held that the MVRA’s extended liability period did not increase Ellingburg’s punishment and rejected his petition. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed, reasoning that MVRA restitution was not criminal punishment and therefore did not implicate the Ex Post Facto Clause. Ellingburg sought review in the Supreme Court, which reversed, holding that MVRA restitution is criminal punishment under the Ex Post Facto Clause, and remanded for further proceedings on whether the MVRA’s extended liability period increased his punishment.On remand, the United States Court of Appeals for the Eighth Circuit determined that the MVRA applied to Ellingburg because he was convicted after its enactment. The court held that retroactive application of the MVRA’s extended liability period increased Ellingburg’s punishment by prolonging his restitution liability well beyond what the law permitted at the time of his offense. The court therefore concluded that applying the MVRA to Ellingburg violated the Ex Post Facto Clause, vacated the district court’s judgment, and remanded for further proceedings. View "United States v. Ellingburg" on Justia Law