Justia Constitutional Law Opinion Summaries

Late at night, a police officer was dispatched to a Rio Rancho cul-de-sac after a report of a fight, with someone allegedly dragged through the street, and a party ongoing all day at a house. Upon arrival, the officer observed a loud argument between a man and a woman, with the man being restrained by another individual. The officer approached the group, did not announce himself, and instructed the man to stay. Instead, the man and his friend fled, prompting the officer to chase and seize the man by grabbing his wrist. A struggle ensued, resulting in the officer being assaulted and held down until backup arrived.The defendant was indicted in the District Court for aggravated battery upon a peace officer, false imprisonment, and criminal damage to property. He moved to suppress evidence of crimes committed after the seizure, arguing the officer lacked reasonable suspicion and failed to announce himself. The District Court found no reasonable suspicion, suppressed evidence of subsequent crimes, and dismissed the case. On appeal, the New Mexico Court of Appeals reversed, holding the new crime exception applied, making evidence of subsequent crimes admissible, and declined to address reasonable suspicion.The Supreme Court of the State of New Mexico reviewed the case, applying a de novo standard to the reasonable suspicion issue. The court held that the officer had reasonable suspicion to seize the defendant, based on dispatch information and personal observations of a reported fight, loud argument, and disorderly conduct. The Supreme Court vacated the Court of Appeals opinion, denied the defendant’s motion to suppress, and remanded to the District Court for further proceedings. The new crime exception arguments were not addressed because the seizure was found to be constitutional. View "State v. Morgan" on Justia Law

In this case, a man was involved in a fight between rival gangs in downtown Des Moines, Iowa. Law enforcement broke up the fight, but it resumed later, leading to a chase. During the pursuit, a bystander informed officers that the man had a gun. When confronted, he fled but was quickly apprehended. Officers found a loaded pistol and marijuana on him, and subsequent testing confirmed drug use. He was indicted for possessing a firearm as an unlawful drug user under federal law.Previously, the United States District Court for the Southern District of Iowa denied his motion to dismiss the indictment, in which he argued that the statute violated his Second Amendment rights and was unconstitutionally vague. He entered a conditional guilty plea, preserving his right to appeal. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s ruling on the vagueness issue but found the record insufficient to resolve the as-applied Second Amendment challenge, remanding for further proceedings. On remand, the district court held a bench trial on stipulated facts, found him guilty, conducted an evidentiary hearing, and again denied his motion to dismiss, concluding that the statute did not violate the Second Amendment as applied to him.The United States Court of Appeals for the Eighth Circuit reviewed the denial of the motion to dismiss de novo and affirmed. The court held that the government bears the burden of showing, by a preponderance of the evidence, that the application of the statute is consistent with this nation’s historical tradition of firearm regulation. The court concluded that the man’s conduct—chronic drug use, gang involvement, and aggressive behavior while armed—was sufficiently analogous to conduct historically prohibited under Founding-era “going armed to terrorize” laws. Thus, the statute was constitutional as applied to him, and the district court’s denial of the motion to dismiss was affirmed. View "United States v. Baxter" on Justia Law

On February 23, 2023, Cedar Rapids police, acting on information from a confidential informant, surveilled Robert Lee Drayton, Jr., who was suspected of packaging and distributing methamphetamine. Officers observed Drayton engage in several brief encounters consistent with drug transactions throughout the day. They conducted an initial traffic stop, discovering a firearm, MDMA pills, and methamphetamine, but did not detain Drayton. Later, after observing what appeared to be a delivery of a bag to Drayton’s vehicle, police initiated a second traffic stop after observing Drayton’s car hit the fog line multiple times and change lanes without signaling. During this stop, a canine unit alerted to the presence of drugs, leading to the discovery of a duffel bag containing several kilograms of methamphetamine and another firearm. Drayton was arrested, and subsequent searches of his home and cellphones yielded additional drugs, firearms, cash, and evidence of drug transactions.Drayton moved to suppress the evidence from the second stop, his stationhouse statements, the search of his home, and drug tests, arguing the stop lacked probable cause or reasonable suspicion and was unlawfully prolonged for the canine sniff. The United States Magistrate Judge for the Northern District of Iowa conducted an evidentiary hearing and recommended denial of the motion, finding the officers credible and concluding the stop and subsequent searches were constitutional. The United States District Court for the Northern District of Iowa adopted the recommendation, and Drayton entered a conditional guilty plea.The United States Court of Appeals for the Eighth Circuit affirmed. The court held that the second traffic stop was supported by reasonable suspicion based on Drayton’s observed driving and collective law enforcement knowledge of his suspected drug activity. The canine sniff did not unlawfully prolong the stop, and there was probable cause for the vehicle search. All challenged evidence was lawfully seized, and Drayton’s constitutional rights were not violated. View "United States v. Drayton" on Justia Law

A coalition of trade associations, real estate brokerage firms, landlords, and related entities challenged New York City’s Fairness in Apartment Rental Expenses Act (FARE Act), passed in November 2024. The Act prohibits brokers from charging tenants fees for apartments where they have published listings with a landlord’s permission or agreed to work for the landlord, and prevents landlords from making rental conditional on prospective tenants hiring agents. The plaintiffs argued that the Act infringed their federal and state free speech rights, particularly by burdening their ability to publish listings and receive compensation, and violated the Contracts Clause of the U.S. Constitution by rendering certain existing agreements unenforceable.The United States District Court for the Southern District of New York heard the case, with the City opposing injunctive relief and moving to dismiss the claims. The district court dismissed the plaintiffs’ First Amendment claims, finding the FARE Act to be content-neutral regulation of commercial speech that survived intermediate scrutiny under the Central Hudson test. The court denied the plaintiffs’ motion for a preliminary injunction on those claims. As for the Contracts Clause argument, the district court denied the City’s motion to dismiss, reasoning that factual issues remained, but denied a preliminary injunction after finding plaintiffs unlikely to succeed on the merits. The district court also rejected a state preemption claim.The United States Court of Appeals for the Second Circuit reviewed the appeal, affirming the district court’s judgment. The Second Circuit held that the FARE Act regulates commercial speech in a content-neutral manner and is valid under the Central Hudson test. It also concluded that the Act does not violate the Contracts Clause, as plaintiffs failed to establish a substantial likelihood of success on that claim. The court thus affirmed denial of injunctive relief and dismissal of the constitutional claims. View "Real Estate Board of New York, Inc. v. The City of New York" on Justia Law

New York State created a congestion-pricing program in 2019, requiring vehicles entering the Central Business District (CBD) in Manhattan to pay a daily toll. The stated purposes of the program include reducing traffic congestion and raising funds to support mass transit projects. Rockland and Orange Counties, neighboring municipalities with limited mass-transit access to Manhattan, argued that this program disproportionately burdens their residents, who often rely on driving rather than transit. Before the program began, Rockland and Orange Counties sued the Triborough Bridge and Tunnel Authority and the Metropolitan Transportation Authority, alleging that the toll was an unauthorized tax, violated the right to travel, and infringed upon the Due Process, Equal Protection, and Excessive Fines Clauses of both the New York and U.S. Constitutions.The United States District Court for the Southern District of New York consolidated the cases and granted the defendants’ motion to dismiss for failure to state a claim, also denying leave to amend. The court found that the plaintiffs failed to plausibly allege constitutional violations and determined that any challenge to the toll as a tax should be brought in state court.The United States Court of Appeals for the Second Circuit reviewed the appeal, assuming without deciding that the toll was not a tax. The Second Circuit affirmed the district court’s dismissal, holding that the congestion-pricing program does not create invidious distinctions or more than a minor restriction on the right to travel and thus is reviewed for reasonableness. The court found the toll to be a reasonable user fee, rationally related to legitimate state interests in funding transit and reducing congestion. It also determined there was no due process, equal protection, or excessive fines violation. The Second Circuit further ruled that the district court did not abuse its discretion in denying leave to amend the complaints. View "County of Rockland v. Triborough Bridge & Tunnel Auth." on Justia Law

Several property owners and ranching entities challenged amendments adopted in 2023 by the Albany County Board of County Commissioners to the Aquifer Protection Overlay Zone (APOZ) regulations. The Casper Aquifer, which supplies drinking water to many residents of Albany County and the City of Laramie, had been the subject of prior regulatory efforts. The 2023 amendments included a 35-acre minimum lot size requirement and revised procedures for changing the APOZ boundaries. Appellants argued that the Board exceeded its authority, violated equal protection guarantees, and acted arbitrarily and capriciously in enacting the amendments.Previously, in Bienz v. Board of County Commissioners, County of Albany, 2024 WY 102 (Bienz I), the Wyoming Supreme Court reviewed whether amendments to the APOZ regulations were subject to direct judicial review under the Wyoming Administrative Procedure Act (WAPA). The district court had concluded it lacked jurisdiction, finding the Board's actions legislative and not reviewable under the WAPA. The Supreme Court reversed, holding that legislative agency actions are reviewable, and remanded the case for the district court to consider the merits. While litigation was pending, the Board further amended the APOZ regulations, requiring the district court to identify which amendments remained at issue. The district court ultimately upheld the Board’s authority and the amendments.On appeal, the Supreme Court of Wyoming addressed whether the Board exceeded its authority, whether the amendment procedures violated equal protection, and whether the arbitrary and capricious standard applied to agency legislative action. The Court held the Board acted within its statutory authority in protecting the Casper Aquifer, the distinct procedures for overlay zone amendments did not violate equal protection guarantees, and agency legislative actions are subject to the arbitrary and capricious standard. It concluded the 2023 APOZ amendments, including the 35-acre minimum lot size, were not arbitrary, capricious, or contrary to law, and affirmed the district court’s decision. View "Warren Livestock, LLC v. Board of County Commissione" on Justia Law

Stephen and Deborah Gmeiner owned waterfront property in Michigan and sought a permit to construct a walking path through wetlands to the lake. The Michigan Department of Environment, Great Lakes, and Energy initially denied their permit application, citing environmental concerns and suggesting a boardwalk as a less damaging alternative. The Gmeiners appealed, and an administrative law judge found that township ordinances made a boardwalk infeasible without constructing a home, so the permit was granted. When the Department issued the permit, it included an indemnification clause requiring the Gmeiners to hold the State harmless for claims arising from their actions in connection with the permit. The Gmeiners objected, arguing that the clause was unauthorized under Michigan law and imposed an unconstitutional condition on their First Amendment right to petition by potentially barring lawsuits against the State for its own misconduct.The United States District Court for the Western District of Michigan denied the Gmeiners’ request for a preliminary injunction and dismissed their complaint. The court interpreted the indemnification clause narrowly, holding that it only required indemnification for claims resulting from the Gmeiners’ own actions, not for state misconduct. It concluded that the clause did not violate the First Amendment Petition Clause and that sovereign immunity barred the state-law claim in federal court.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The court held that, even assuming the unconstitutional-conditions doctrine under the Takings Clause applied to the Petition Clause, the indemnification clause was limited to claims arising from the Gmeiners’ own conduct and did not bar them from suing the State for its own misconduct. The court also held that Michigan’s sovereign immunity barred the Gmeiners from seeking state-law relief against state officials in federal court. The district court’s judgment was affirmed. View "Gmeiner v. Kent" on Justia Law

A residential subdivision in Black Hawk, South Dakota, known as Hideaway Hills, was constructed atop land with a history of both underground and surface gypsum mining. The State of South Dakota, through the South Dakota Cement Plant Commission, purchased the property, conducted surface mining, and reclaimed the land to pasture before selling it at public auction, while retaining subsurface mineral rights. Subsequent private owners and developers, aware of prior mining activity, developed the land into residential lots. Years later, residents began experiencing foundational problems and sinkholes, which culminated in a significant sinkhole event in 2020, leading to evacuation and property devaluation.After previous lawsuits against various parties were dismissed, a class action was brought in the Circuit Court of the Fourth Judicial Circuit, Meade County, against the State and related entities. The plaintiffs alleged inverse condemnation, asserting that the State’s reclamation and retention of subsurface rights amounted to a taking or damaging of private property for public use under the South Dakota Constitution. The circuit court granted summary judgment to the State, holding that the plaintiffs’ claims were, in essence, tort claims barred by sovereign immunity.On appeal, the Supreme Court of the State of South Dakota affirmed the circuit court’s decision. The Supreme Court held that the plaintiffs failed to establish a viable inverse condemnation claim because the alleged governmental actions occurred while the State owned the property, and thus did not implicate “private property.” The Court further found that the State’s activities were not for “public use” within the meaning of the state constitution, as the retained mineral rights did not confer a public right of use. The Supreme Court affirmed summary judgment for the State. View "Morse v. State" on Justia Law

Police investigating a fatal fentanyl overdose in Leavenworth, Kansas, suspected that a supplier was distributing drugs from a woman’s residence. Over several weeks, law enforcement surveilled the home and a related apartment, observing frequent short visits, repeated appearances by suspected dealers, and traffic consistent with narcotics sales. A trash pull at the residence yielded evidence of drug activity, including baggies with residue testing positive for controlled substances, a handwritten ledger, and mail addressed to the resident. Additional evidence included drug paraphernalia found in the resident’s car and information linking associates to drug distribution and overdoses. Based on these observations, an officer compiled an affidavit and obtained a search warrant, leading to a search that uncovered substantial drug evidence and resulted in criminal charges.In the Leavenworth District Court, the defendant moved to suppress the evidence, arguing that the affidavit failed to show probable cause. The district court agreed, finding the affidavit’s details—especially those about the trash pull and vehicle search—insufficient to connect the alleged criminal activity to the residence. The court also found that much of the supporting information was uncorroborated or indicative of innocent conduct. The State appealed, and the Kansas Court of Appeals agreed the affidavit was deficient, but held that the evidence was admissible under the good-faith exception.The Supreme Court of the State of Kansas reviewed the case and concluded that both the district court and the Court of Appeals used an incorrect legal standard by analyzing the affidavit’s facts in isolation rather than considering the totality of the circumstances. The Supreme Court held that the affidavit provided the issuing judge with a substantial basis for finding probable cause. The court affirmed the reversal of the suppression order but on different grounds, and remanded the case, vacating the Court of Appeals’ discussion of the good-faith exception. View "State v. Gardner " on Justia Law

Texas law allows certain students, including those who are not lawfully present in the United States, to qualify for in-state tuition rates at public colleges if they meet residency requirements. The Texas Education Code provisions in question—sections 54.051(m) and 54.052(a)—permit illegal aliens who establish residency in Texas to pay discounted tuition, while out-of-state U.S. citizens must pay higher rates. The United States brought suit against Texas, alleging that these provisions violate federal law, specifically 8 U.S.C. § 1623(a), which bars states from granting postsecondary education benefits to illegal aliens based on residency unless all U.S. citizens and nationals are eligible for the same benefit regardless of residency.The United States District Court for the Northern District of Texas approved a consent judgment permanently enjoining Texas from enforcing the challenged provisions. After judgment, advocacy groups, a community college, and a student moved to intervene and sought to vacate or alter the judgment, arguing the provisions were not preempted by federal law. The district court denied intervention, reasoning it was legally futile because 8 U.S.C. § 1623(a) expressly preempts the Texas statutes.The United States Court of Appeals for the Fifth Circuit reviewed the denial de novo and affirmed. The court held that intervention was futile because federal law expressly preempts the Texas provisions, barring states from conferring in-state tuition benefits to illegal aliens based on residency unless all U.S. citizens and nationals may receive the same benefit without regard to residency. The court also dismissed the remaining claims for lack of appellate jurisdiction, as the movants were not parties to the case and therefore had no right to appeal the consent judgment. View "USA v. Texas" on Justia Law