Justia Constitutional Law Opinion Summaries

A 17-year-old individual was charged as an adult for the shooting death of a 15-year-old girl during a drive-by incident at a public park in Cheyenne, Wyoming. The evidence showed that the defendant was the front passenger in an SUV from which shots were fired into a group of teenagers. Investigators recovered shell casings and the fatal bullet, and testimony indicated the victim was killed by a bullet likely fired from the defendant’s position. While the defendant denied involvement and claimed no one in the SUV had a gun, multiple witnesses and forensic analysis pointed to his participation.The District Court of Laramie County denied the defendant’s motion to transfer the case to juvenile court, citing the seriousness of the offense, lack of adequate juvenile facilities, and insufficient evidence for rehabilitation within the juvenile system. At trial, the jury was instructed on both the charged offenses and lesser included offenses. The jury acquitted the defendant of first-degree murder and conspiracy but convicted him of second-degree murder. The defendant was sentenced to 25–35 years imprisonment. He subsequently filed two post-conviction motions under Wyoming Rule of Appellate Procedure 21, alleging ineffective assistance of counsel for failures at the juvenile transfer hearing, trial, and sentencing. The district court denied these motions.On consolidated appeal to the Supreme Court of Wyoming, the defendant argued sufficiency of evidence, error in jury instructions regarding transferred intent, and that Article 1, Section 10 of the Wyoming Constitution required a stricter standard for ineffective assistance claims than the federal Sixth Amendment. The Supreme Court of Wyoming affirmed the conviction and denial of post-conviction relief. The court held that the evidence was sufficient for second-degree murder, the jury instruction on transferred intent was not plainly erroneous, Article 1, Section 10 does not require a more protective prejudice standard than Strickland, and the defendant was not denied effective assistance of counsel. View "Munoz v. The State of Wyoming" on Justia Law

The case concerns an individual who pleaded guilty to first degree child molestation and was sentenced to prison and a term of community custody. As a part of his community custody conditions, the trial court prohibited him from possessing or accessing “sexually exploitive materials (as defined by Defendant’s treating therapist or [Community Corrections Officer]).” The condition did not define “sexually exploitive materials,” nor did it reference any statute or provide illustrative examples. The defendant argued that this condition was unconstitutionally vague.The Washington Court of Appeals, in a split decision, upheld the condition. The majority reasoned that two statutes—though not referenced in the condition or the defendant’s proceedings—could provide sufficient clarity as to what “sexually exploitive materials” meant. The dissent, however, found that the phrase was undefined, not clarified by the referenced statutes (which described different crimes or phrases), and thus failed to give ordinary people notice of what conduct was prohibited.The Supreme Court of the State of Washington reviewed the case. The court concluded that the community custody condition was unconstitutionally vague because it did not define “sexually exploitive materials,” provide statutory or case law definitions, or include clarifying examples. The court emphasized that due process requires conditions to be clear enough for an ordinary person to understand what is prohibited and to protect against arbitrary enforcement. Furthermore, because the condition implicated First Amendment rights, it also had to be narrowly tailored and directly related to the state’s goals of public safety and rehabilitation. The court found that the condition failed these requirements and reversed the Court of Appeals, remanding the case for further proceedings. The court held specifically that the condition as written does not provide constitutional notice, does not protect against arbitrary enforcement, and is not narrowly tailored. View "State v. Jeffries-Porter" on Justia Law

In this case, the defendant was convicted and sentenced to death for a 2003 murder. The victim, a young man, was found strangled and stabbed in a motel room. The defendant had worked with the victim and became a suspect when his vehicle matched that associated with another double homicide. Physical evidence included a hair and shoe impressions linking the defendant to the scene. The prosecution also presented evidence of the defendant’s involvement in other similar murders. At trial, the State argued that the murder involved sadistic sexual assault, relying in part on DNA evidence found on the victim, which was attributed to another individual living at the motel.Following the conviction, the defendant sought postconviction relief in the Circuit Court, arguing, among other things, that the State had withheld evidence in violation of Brady v. Maryland. The evidence in question consisted of Florida Department of Law Enforcement (FDLE) call logs indicating that analysts believed the DNA found was unlikely to be the result of secondary transfer, contrary to the State’s theory at trial. The postconviction court found that this evidence was withheld and was favorable to the defense, but concluded it was not exculpatory and denied relief.The Supreme Court of Florida reviewed the appeal. The Court held that the State violated its obligations under Brady by suppressing material impeachment evidence regarding the likelihood of secondary DNA transfer. The undisclosed evidence could have impeached key State witnesses and undermined the prosecution’s theory. The Court found that the suppressed evidence was material and that its absence prejudiced the defendant, creating a reasonable probability of a different verdict. Accordingly, the Supreme Court of Florida reversed the postconviction court’s denial of relief, set aside the conviction, and remanded for a new trial. View "Jones v. State of Florida" on Justia Law

Kristina Gulley, who previously served as justice of the peace for District 10 in Pulaski County, Arkansas, sought reelection after having been disqualified in earlier proceedings due to two prior misdemeanor hot-check convictions from 1997 and 2003. Multiple prior legal actions had resulted in findings that these convictions constituted “infamous crimes” under article 5, section 9 of the Arkansas Constitution, rendering her ineligible to run for or hold public office. Despite these rulings, Gulley again filed as a candidate in the 2026 primary election. Registered voters in the district challenged her eligibility, seeking a declaratory judgment and writ of mandamus to prevent her name from appearing on the ballot and to prohibit counting any votes cast for her.The Pulaski County Circuit Court held an expedited hearing, denied Gulley’s requests for a continuance and for relief from judgment, and reaffirmed her ineligibility based on the prior convictions. The court found that neither the sealing of her record nor a gubernatorial pardon restored her eligibility to run for office, and it ordered the Board of Election Commissioners not to certify her as a candidate or count votes for her. Gulley appealed, challenging the circuit court’s findings on factual and constitutional grounds. However, she did not obtain a stay of the court’s order or the certification of the election results.Upon review, the Supreme Court of Arkansas determined that the appeal was moot because the March 2026 primary election had already occurred, and the election results had been certified. The court held that no effective relief could be granted as to the election in question, and none of the recognized exceptions to the mootness doctrine applied. Accordingly, the Supreme Court of Arkansas granted the motion to dismiss the appeal as moot and dismissed the case. View "GULLEY v. JEFFREY" on Justia Law

A recently enacted Georgia law restricts minors’ ability to create accounts on social media platforms. The statute requires covered platforms to verify users’ ages, prohibits minors under sixteen from creating accounts without parental consent, and limits how personal data may be used for advertising to minors. The law defines “social media platform” broadly, but includes numerous exceptions for platforms with different primary functions. An internet trade association, representing major social media companies, challenged the law before its effective date, arguing that it violates the First Amendment, is unconstitutionally vague, and is preempted by Section 230 of the Communications Decency Act.The United States District Court for the Northern District of Georgia granted a preliminary injunction, preventing enforcement of the law. The court found that the association had associational and third-party standing, that the law was likely a content-based speech restriction failing strict scrutiny, was unconstitutionally vague, and was preempted by federal law.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the association had standing and whether it demonstrated a likelihood of success on the merits. The circuit court held that the association had associational standing to challenge the law on behalf of its members. However, the court concluded that the association failed to meet the burden required for a facial First Amendment challenge under the standard set forth in Moody v. NetChoice, LLC, because it did not adequately address the full range of the law’s applications and did not demonstrate that unconstitutional applications substantially outweighed constitutional ones. The court also found that the vagueness and Section 230 preemption claims were unlikely to succeed. The Eleventh Circuit affirmed the standing determination, vacated the preliminary injunction, and remanded the case for further proceedings. View "NetChoice v. Attorney General, State of Georgia" on Justia Law

Florida enacted a statute (HB3) restricting minors’ access to social media platforms that employ certain “addictive features,” such as infinite scrolling, push notifications, and auto-play. Platforms meeting defined criteria—including algorithmic content selection and significant minor usage—must prohibit account creation by those under 14 and require parental consent for those aged 14–15. The Computer & Communications Industry Association and NetChoice, representing affected platforms, challenged the law on First Amendment grounds, asserting both facial and as-applied claims.The United States District Court for the Northern District of Florida initially denied a preliminary injunction for lack of associational standing, but after the plaintiffs amended their complaint and renewed their motion, the court granted a preliminary injunction. The district court found that the trade groups had standing, abstention under Younger v. Harris was unwarranted, and that although HB3 was a content-neutral regulation, it was insufficiently tailored to survive intermediate scrutiny, thus likely unconstitutional.On appeal, the United States Court of Appeals for the Eleventh Circuit first held that the plaintiffs had associational standing to challenge HB3 on behalf of their members. The court also determined that the district court properly declined to abstain under Younger because substantial proceedings had already occurred in federal court before the state enforcement action was initiated. Addressing the merits, the Eleventh Circuit concluded that HB3 is a content-neutral regulation implicating the First Amendment, but it likely survives intermediate scrutiny due to its age-based tailoring and focus on addictive features. The court rejected the facial challenge, holding that the plaintiffs had not demonstrated, as required by Moody v. NetChoice, LLC, that HB3’s unconstitutional applications substantially outweighed its constitutional ones. The disposition affirmed in part, reversed in part, vacated in part, and remanded for further proceedings. View "Computer & Communications Industry Association v. Attorney General, State of Florida" on Justia Law

Two nonprofit organizations dedicated to increasing voter participation, especially among underrepresented groups, sent mail ballot applications to Kansas voters during the 2020 election. These mailings included applications that had been partially prefilled with voter information obtained from public and commercial sources. Due to outdated or inaccurate data, many applications contained errors, leading to voter confusion and administrative burdens for local election officials who had to process erroneous or duplicate applications and respond to concerned voters.Following this experience, the Kansas legislature enacted a law prohibiting private entities from mailing partially prefilled advance ballot applications to registered voters. The nonprofits challenged the law in the United States District Court for the District of Kansas, arguing that it infringed on their First Amendment rights. The district court initially enjoined enforcement of the law, but the United States Court of Appeals for the Tenth Circuit reversed and remanded, instructing the district court to apply intermediate scrutiny unless it found the law was enacted with an improper purpose. On remand, the district court found that the Kansas legislature had acted with an improper purpose, concluded that strict scrutiny should apply, and again enjoined the law.On the second appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s findings de novo. The appellate court held that the district court erred in finding improper legislative intent, as there was no sufficient evidence in the law’s text, justifications, or legislative history to support that conclusion. Applying intermediate scrutiny, the Tenth Circuit found that the law served significant governmental interests—minimizing voter confusion, facilitating efficient election administration, and fostering confidence in elections—and was narrowly tailored to those interests without substantially burdening protected speech. Consequently, the Tenth Circuit reversed the district court’s judgment. View "VoteAmerica v. Schwab" on Justia Law

The case involved a traffic stop of Shawna Rae Pendleton in October 2021 due to expired vehicle registration. Officer Miller and his drug dog, Edo, were called to conduct a free-air sniff around Pendleton’s vehicle. During the sniff, Edo closely investigated the vehicle doors and briefly touched the exterior handle of at least one door with the tip of his nose before alerting to the presence of illegal drugs. A subsequent search of the vehicle revealed methamphetamine, marijuana, alprazolam, and drug paraphernalia, resulting in Pendleton’s arrest and charges for possession offenses.Pendleton moved to suppress the evidence, arguing that Edo’s brief contact with her vehicle constituted a trespass, transforming the sniff into an unlawful search under the Fourth Amendment. The District Court of the Fourth Judicial District in Ada County agreed with Pendleton, relying on State v. Dorff and finding that Edo’s contact amounted to intermeddling and a trespass for the purpose of obtaining information. The court granted the motion to suppress. The State appealed, and the Idaho Court of Appeals reversed, determining the contact was not trespassory and that Edo’s alert prior to contact provided probable cause for the search. Pendleton petitioned for review, which the Idaho Supreme Court granted.The Supreme Court of the State of Idaho held that Edo’s momentary and minimal contact with the vehicle did not rise to the level of intermeddling and therefore was not trespassory. The Court concluded that such brief contact did not meaningfully interfere with Pendleton’s possessory interest in the vehicle. Absent a trespass, the sniff did not constitute a search within the meaning of the Fourth Amendment. The district court’s order suppressing the evidence was reversed and the case remanded for further proceedings. View "State v. Pendleton " on Justia Law

A Milwaukee County Sheriff’s deputy, while on duty and driving his unmarked vehicle, caused a fatal collision after running a red light at a controlled intersection. The deputy failed to notice the light change because he was distracted—looking at either his cellphone or his dashboard computer—for over 15 seconds as he approached the intersection. He was traveling at or just below the speed limit at the time. The victim, Ceaser Stinson, was lawfully passing through the intersection when his vehicle was struck and he was killed. Investigations confirmed the deputy’s inattention as the cause of the accident.Following the crash, Stinson’s estate filed a lawsuit in state court against the deputy, Milwaukee County, and the county’s insurer, alleging, among other claims, a violation of Stinson’s substantive due process rights under 42 U.S.C. § 1983. After removal to the United States District Court for the Eastern District of Wisconsin, the court dismissed some claims but permitted the estate’s § 1983 claim against the deputy to proceed. The defendants moved for summary judgment, arguing that the deputy’s conduct did not meet the threshold for a constitutional violation and that he was entitled to qualified immunity. The district judge denied the motion, concluding that a jury should decide whether the conduct was egregious enough to violate due process and deferred ruling on qualified immunity until after a jury verdict.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the estate failed to show the deputy acted with deliberate indifference to a known and imminent harm, as required for a substantive due process violation. The court further held that it was not clearly established that distracted driving by a law enforcement officer violates due process. Accordingly, the court reversed the district court’s judgment and ordered entry of judgment in favor of the deputy, finding him entitled to qualified immunity. View "Estate of Stinson v. Streicher" on Justia Law

California enacted the No Vigilantes Act, which, among other things, requires any non-uniformed federal law enforcement officer operating in the state to visibly display identification showing their agency and either a name or badge number while performing enforcement duties. This requirement, codified at California Penal Code § 13654, applies broadly to federal officers, subject to narrow exceptions, and provides for criminal penalties for willful violations. The Act also allows agencies to avoid these requirements by publicly posting a written identification policy that complies with the statute.After the Act was passed, the United States filed a lawsuit in the United States District Court for the Central District of California, challenging the constitutionality of the identification requirement before it had been enforced. The United States argued that the law violated the Supremacy Clause by directly regulating federal law enforcement operations. The district court denied the United States’ request for a preliminary injunction against enforcement of the identification requirement, finding the government had not shown that California’s law interfered with or controlled federal operations to a degree that would render it unconstitutional. The district court did, however, grant partial relief under a different statute, and ruled that the United States lacked standing to challenge other provisions.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s denial of a preliminary injunction. The Ninth Circuit concluded that the United States was certain to succeed on its Supremacy Clause claim because the Act directly regulated federal operations without congressional authorization, in violation of intergovernmental immunity. The court held that no set of circumstances existed under which the challenged requirement would be valid, and that the other factors for preliminary injunctive relief also favored the United States. The Ninth Circuit ordered the district court to enter a preliminary injunction barring enforcement of the identification requirement against the United States, its agencies, and officers. View "USA V. STATE OF CALIFORNIA" on Justia Law