Justia Constitutional Law Opinion Summaries

A group of parolees who had been detained challenged the procedures used by the Missouri Department of Corrections for revoking parole, arguing that these procedures violated their due process rights. The plaintiffs brought a class action suit under 42 U.S.C. § 1983 on behalf of all adult parolees in Missouri who currently face or will face parole revocation proceedings. The district court issued an order in 2020 requiring the Department to implement certain changes. After further proceedings, the plaintiffs sought and were awarded attorneys’ fees for their partial success and for monitoring the Department’s compliance.The Missouri Department of Corrections appealed the district court’s fee awards, arguing that the Prison Litigation Reform Act (PLRA) limited the attorneys’ fees that could be awarded. The district court had repeatedly rejected the Department’s argument, finding that the PLRA’s fee cap did not apply because the certified class included parolees who were not detained and because some of the relief benefited non-detained parolees. The district court issued its final judgment in January 2025 and permanently enjoined the Department while awarding additional attorneys’ fees.The United States Court of Appeals for the Eighth Circuit considered whether the PLRA’s attorneys’ fee cap under 42 U.S.C. § 1997e(d) applied to the class action. The Eighth Circuit held that the fee cap does apply because the certified class consisted of individuals who are, or will be, detained during parole revocation proceedings and thus fall under the statutory definition of “prisoner.” The court also found that the PLRA’s fee cap section is not limited to actions challenging prison conditions. The Eighth Circuit vacated the fee awards and remanded the case for the district court to recalculate the fee awards in accordance with the PLRA’s limitations. View "Gasca v. Precythe" on Justia Law

A licensed mental health counselor in Colorado, who provides talk therapy to clients—including minors—challenged a state law that prohibits licensed counselors from engaging in “conversion therapy” with minors. The law defines conversion therapy broadly to include any practice or treatment that attempts to change an individual’s sexual orientation or gender identity, including efforts to alter behaviors, expressions, or attractions. However, the law permits counselors to support clients exploring their identity or undergoing gender transition. The counselor’s practice involves helping clients pursue their own stated goals, which may include support for changes in sexual orientation or gender identity, but she only utilizes talk therapy and does not engage in any physical interventions.The United States District Court for the District of Colorado first reviewed the case. That court, and later the United States Court of Appeals for the Tenth Circuit, concluded that the counselor had standing to bring a pre-enforcement, as-applied First Amendment challenge to the law. Both courts interpreted the law as prohibiting her from using speech to help clients change their sexual orientation or gender identity. Nevertheless, both courts denied her request for a preliminary injunction, reasoning that the law regulates professional conduct, not speech, and any effect on speech is merely incidental. Applying rational-basis review, they found the law constitutionally permissible.The Supreme Court of the United States granted review to resolve a circuit split. The Supreme Court held that, as applied to the counselor’s talk therapy, the Colorado law regulates speech based on viewpoint, not merely conduct, and that the lower courts erred by applying only rational-basis scrutiny. The Supreme Court ruled that the law is subject to strict scrutiny under the First Amendment and reversed the Tenth Circuit’s decision, remanding the case for further proceedings consistent with its opinion. View "Chiles v. Salazar" on Justia Law

A class of inmates at the Louisiana State Penitentiary alleged that the prison’s medical care was constitutionally inadequate and that the facility failed to comply with the Americans with Disabilities Act and the Rehabilitation Act. The lawsuit began in 2015, and evidence was introduced at trial in 2018. In 2021, the United States District Court for the Middle District of Louisiana issued a lengthy opinion finding systemic Eighth Amendment violations and ADA/RA noncompliance. While prison officials began making improvements ahead of a scheduled remedial trial, the district court later issued a Remedial Opinion and Order, prescribing detailed institutional changes and appointing special masters to oversee compliance.The district court’s Remedial Order required the state to bear the costs of three special masters, directed broad institutional reforms, and did not expressly adhere to the limitations imposed by the Prison Litigation Reform Act (PLRA). The court entered final judgment in favor of the plaintiffs, retaining jurisdiction only for compliance procedures. After entry of judgment, the defendants appealed. During the appeal, a panel of the United States Court of Appeals for the Fifth Circuit stayed the Remedial Order. The Fifth Circuit, sitting en banc, subsequently reviewed whether it had appellate jurisdiction and the validity of the district court’s orders.The United States Court of Appeals for the Fifth Circuit held that it had appellate jurisdiction under 28 U.S.C. § 1291 or, alternatively, § 1292(a)(1). The Fifth Circuit found that the district court’s Remedial Order violated the PLRA by failing to apply the statutory needs-narrowness-intrusiveness standard, improperly appointing multiple special masters, and requiring the state to pay their fees. The Fifth Circuit also concluded that the district court erred by disregarding ongoing improvements to prison medical care and by misapplying the standards for injunctive relief under the Eighth Amendment and the ADA/RA. The court vacated the district court’s judgment and remanded for further proceedings. View "Parker v. Hooper" on Justia Law

The defendant was found driving a car in which police discovered an assault rifle with a large-capacity magazine on the front seat. He attempted to evade a traffic stop and subsequently fled the vehicle. The prosecution charged him with felony “receiving” a large-capacity magazine under California Penal Code section 32310, subdivision (a). The only evidence presented was that the defendant possessed the magazine, with no additional evidence about how or when he acquired it.The Contra Costa County Superior Court convicted the defendant of felony receiving a large-capacity magazine. The defendant appealed, contending there was insufficient evidence to support the conviction for receiving, as opposed to mere possession, and that the jury was incorrectly instructed on the distinction between the two offenses. He also argued the statute was unconstitutional. The prosecution argued that the evidence was sufficient to support the felony conviction and that the defendant’s actions supported a finding of receiving rather than just possessing.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed the case. The court concluded that Penal Code section 32310 distinguishes between “receiving” and “possessing” a large-capacity magazine, with “receiving” punishable as a felony or misdemeanor and “possessing” punishable as a misdemeanor or infraction. The appellate court found that mere possession is insufficient to support a conviction for receiving; additional evidence is required to show how or when the defendant acquired the magazine. Because the record contained no such evidence, the court reversed the defendant’s felony conviction for receiving a large-capacity magazine. The rest of the judgment was affirmed. The appellate court did not reach the issues of instructional error or the statute’s constitutionality. View "P. v. Newt" on Justia Law

While incarcerated at Augusta Correctional Center in Virginia, Daniel Jackson, proceeding without an attorney, filed a complaint using a standard prisoner form. He named the prison’s medical department and two healthcare providers as defendants, describing his medical condition and alleging a series of events: the confiscation of his prescribed ankle sleeve, the denial of a lower bunk assignment despite his medical needs, and pain caused by required work footwear. Jackson also claimed he was denied proper physical therapy and pain medication, and asserted that one nurse suggested he acquire drugs illicitly. His complaint sought compensation for lost wages, treatment for his pain, and damages for suffering.The United States District Court for the Western District of Virginia screened the complaint under 28 U.S.C. § 1915A. It construed the action as asserting Eighth Amendment deliberate indifference claims against the individual healthcare providers, dismissing the prison medical department as an improper defendant under § 1983. After allowing Jackson to supplement his complaint with additional allegations—such as retaliation by one nurse—the district court recognized both deliberate indifference and First Amendment retaliation claims. The retaliation claim was dismissed for lack of plausible causation. Ultimately, the district court granted summary judgment for the defendants on the deliberate indifference claims, finding no genuine disputes of material fact regarding the adequacy of medical care provided.Jackson, now represented by counsel, appealed to the United States Court of Appeals for the Fourth Circuit. He argued that the district court should have construed his complaint to assert a claim under the Americans with Disabilities Act (ADA). The Fourth Circuit held that the district court did not err in construing Jackson’s complaint as presenting only an Eighth Amendment claim, emphasizing that courts must liberally construe pro se pleadings but are not required to identify every conceivable claim. The judgment in favor of the defendants was affirmed. View "Jackson v. Dameron" on Justia Law

The case concerns a petitioner who was convicted in West Virginia state court in 2004 of sexually abusing his son. After the trial, it was discovered that, during jury deliberations, one juror told others that he knew the petitioner’s family and feared for his own family’s safety if the petitioner was acquitted. Four jurors later confirmed that the comments had been made, though the juror in question denied them. The petitioner argued this introduced an impermissible external influence into the deliberations, violating his right to an impartial jury.The trial court in West Virginia denied the petitioner’s request for a new trial, finding insufficient evidence of juror impartiality and concluding that the statements related only to the jury’s deliberative process, not to any external influence. The Supreme Court of Appeals of West Virginia affirmed this decision, holding that the comments were intrinsic to the deliberations and thus not grounds to set aside the verdict. The petitioner then sought federal habeas relief under 28 U.S.C. § 2254 in the United States District Court for the Southern District of West Virginia, which denied his petition, concluding the state court had not unreasonably applied Supreme Court precedent.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of habeas relief de novo but applied the deferential standard required by § 2254. The Fourth Circuit held that the state court did not unreasonably apply clearly established Supreme Court law in finding that the juror’s comments were intrinsic, not external, to the deliberation process. The court concluded that, under existing Supreme Court precedent, the statements did not rise to the level of external influence necessary to violate the petitioner’s Sixth Amendment rights. Accordingly, the Fourth Circuit affirmed the district court’s judgment denying habeas relief. View "Daugherty v. Dingus" on Justia Law

Darion Baker and Gregory Dees were driving a stolen car from California with plans to reach Tennessee. In Stratford, Texas, police officers Richard Coborn and Michael McHugh became suspicious of their vehicle, followed them to a gas station, and confirmed the car was stolen. As Baker and Dees returned to their car, the officers approached with weapons drawn and gave commands. Baker put the car in drive, and the officers fired shots—first before the car moved, then as Baker drove away. Baker was fatally shot from behind, while Dees was unharmed.The plaintiffs, including Baker’s estate and family, sued the officers in the United States District Court for the Northern District of Texas, alleging excessive force under 42 U.S.C. § 1983 and violations of the Fourth and Fourteenth Amendments. The officers asserted qualified immunity and moved for summary judgment. The district court granted qualified immunity for the shots fired before the car moved and ruled the second round of shots was reasonable under the Fourth Amendment. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit agreed with the district court regarding the first round of shots but disagreed about the second round, finding that a jury could decide whether the second round was objectively unreasonable. The panel remanded for the district court to decide whether the right was clearly established.On remand, the district court denied qualified immunity for the second round of shots, finding that the violation was clearly established. The officers appealed. The United States Court of Appeals for the Fifth Circuit affirmed, holding that, when the facts are viewed in the light most favorable to the plaintiffs, Coborn’s conduct during the second round of shots constituted a clearly established violation of the Fourth Amendment. Thus, Coborn was not entitled to qualified immunity for the second round of shots. View "Baker v. Coborn" on Justia Law

A young adult defendant was charged with vandalism and vehicle theft in Santa Clara County. After the prosecution indicated the defendant met initial eligibility requirements for a young adult deferred entry of judgment program under Penal Code section 1000.7, the trial court referred the defendant to the county probation department for further assessment. The probation department determined the defendant was unsuitable for the program because he resided in Alameda County, which did not operate a corresponding program, and concluded that he could not benefit from Santa Clara County’s services due to his residency.The Superior Court of Santa Clara County accepted the probation department’s determination and continued the criminal cases, effectively denying deferred entry of judgment. The defense argued that section 1000.7 did not prohibit out-of-county residents from participating, that the trial court should have authority to make the final eligibility determination, and that if the statute granted exclusive authority to probation, it would violate the constitutional separation of powers. The trial court found the statute unambiguously vested eligibility determinations with the probation department.The California Court of Appeal, Sixth Appellate District, reviewed the case on a petition for writ of mandate, prohibition, or alternative relief. The court held that section 1000.7 gives the probation department—not the trial court—the authority to decide whether a defendant meets the statutory criteria for participation in the deferred entry of judgment program. The court also held that assigning this responsibility to the probation department does not violate the separation of powers doctrine. Finally, the court determined that the probation department did not abuse its discretion by denying the defendant entry into the program based on his out-of-county residence. The petition was denied. View "Armstrong v. Superior Ct." on Justia Law

Eric Smith was the majority owner, chairman, and CEO of Consulting Services Support Corporation (CSSC), which wholly owned CSSC Brokerage Services, Inc. (CSSC-BD), a registered FINRA broker-dealer. Although CSSC-BD was registered, Smith did not personally register with FINRA, claiming an exemption so long as he was not involved in managing the securities business. However, between 2010 and 2015, Smith actively managed CSSC-BD, including overseeing debt offerings, preparing offering documents with false statements, and soliciting investments totaling $130,000 from four investors. A FINRA examination and investor complaints uncovered these activities.Following an investigation, FINRA’s Department of Enforcement filed a complaint against Smith for violations of federal securities laws and FINRA rules. After a disciplinary proceeding, FINRA found against Smith and imposed sanctions, including $130,000 in restitution and a bar from associating with any FINRA member. Smith appealed to the United States Securities and Exchange Commission (SEC), which affirmed FINRA’s findings and sanctions. Smith then sought review in the United States Court of Appeals for the Sixth Circuit, arguing that FINRA lacked jurisdiction over him and that the proceedings violated his rights under Article III and the Seventh Amendment.The United States Court of Appeals for the Sixth Circuit held that FINRA had statutory authority to discipline Smith because, despite not registering, he controlled a FINRA member firm and was therefore a “person associated with a member” under the relevant statute. The court found Smith’s constitutional claims barred because he failed to raise them before the SEC as required by statute, and none of the exceptions to the exhaustion requirement applied. The petition for review was denied. View "Smith v. Securities and Exchange Commission" on Justia Law

The petitioner, a Jamaican national who became a lawful permanent resident of the United States in 1971, was removed from the country in 2007 following a 1996 conviction under New York law for the attempted sale of a “narcotic drug.” Many years later, based on a recent Second Circuit decision—United States v. Minter—that held the relevant New York statute was broader than its federal counterpart, the petitioner filed a motion to reconsider or reopen his removal order, arguing that the legal basis for his removal no longer applied. He filed this motion within thirty days of the Minter decision.The Board of Immigration Appeals (BIA) denied the petitioner’s motion, concluding that he had not demonstrated the due diligence necessary to warrant equitable tolling of the filing deadlines for such motions. The BIA reasoned that an earlier Second Circuit case, Harbin v. Sessions, should have prompted the petitioner to file sooner. The BIA interpreted the petitioner’s arguments as asserting that Harbin constituted a fundamental change in the law sufficient to support his motion, and therefore found his delay unreasonable.On review, the United States Court of Appeals for the Second Circuit found that the BIA mischaracterized the petitioner’s arguments and misunderstood the legal significance of the Harbin and Minter decisions. The court held that the petitioner’s rights to relief did not arise until Minter, and he was not required to file earlier motions based on law that had not yet changed. The Second Circuit therefore held that the BIA abused its discretion, vacated the BIA’s order, granted the petition for review and motion to stay removal, and remanded the case to the BIA for further proceedings consistent with its opinion. View "Ramsay v. Bondi" on Justia Law