Justia Constitutional Law Opinion Summaries

The case centers on the convictions of two defendants for offenses related to the 2019 murder of Donnell Brockington in Baltimore City. After the shooting, the suspects fled in a vehicle, which crashed, and four individuals—including the defendants—were apprehended. Police recovered multiple firearms from the vehicle and nearby, with DNA evidence linking all four co-defendants to the weapons. At trial, a State firearms examiner testified that certain ammunition recovered from the crime scene “was fired with” a Desert Eagle pistol found in the vehicle. None of the defendants challenged the reliability of this methodology before or during trial, nor requested a Daubert hearing.Following their convictions, the defendants appealed. During the pendency of their appeal, the Supreme Court of Maryland issued a decision in Abruquah v. State concerning firearms identification testimony. The Appellate Court of Maryland subsequently reversed the convictions on plain-error review, finding that the examiner’s unqualified testimony was prohibited by Abruquah. Additionally, one defendant challenged the trial court’s decision to close the courtroom during jury deliberations and to limit attendance at the verdict, which was prompted by escalating incidents of spectator misconduct, including direct contact between a co-defendant’s father and a juror.The Supreme Court of Maryland reviewed the case and held that the admission of the unqualified firearms examiner’s testimony was not “clear or obvious” error at the time of trial or appeal, making plain-error reversal inappropriate. The Court clarified that Abruquah was a case-specific Daubert determination, not a categorical ban. Regarding the courtroom closure, the Court adopted the Kelly framework for de minimis closures but found the closures justified under Waller v. Georgia due to legitimate concerns for juror safety and deliberative integrity. The Court reversed the convictions in part and affirmed in part, remanding for further proceedings. View "State v. Thornton" on Justia Law

A man repeatedly visited the public library in Lawrence, Kansas, where he displayed various signs and flags inside the building. Library staff informed him that these actions violated library policies aimed at maintaining a peaceful environment and, after several incidents in which he refused to comply, staff called the police and temporarily suspended his library privileges. The library’s policies prohibited disruptive behavior and forbade activities—including holding signs, protesting, or similar expressive conduct—inside the library, though expressive clothing and certain other channels for communication remained allowed.He filed suit in the United States District Court for the District of Kansas against city and library officials. He alleged violations of his rights to free speech and equal protection, deprivation of procedural due process, and retaliation for protected speech. The district court granted summary judgment to the defendants on all claims. It concluded that he lacked standing for claims involving policies not applied to him, and that the challenged restrictions were content-neutral, narrowly tailored to a significant governmental interest, and left open alternative channels for expression. The court also found he was not similarly situated to others treated differently and that his due process and retaliation claims failed.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Tenth Circuit held that the library’s restrictions on signs and similar expressive activities inside were content-neutral, narrowly tailored to maintain a quiet environment for reading and study, and left open ample alternative channels for communication. It further found that the plaintiff lacked standing for certain claims, was not treated differently from similarly situated patrons, and did not engage in constitutionally protected activity supporting a retaliation claim. The grant of summary judgment to the defendants was affirmed. View "Spiehs v. Morgan" on Justia Law

A licensed clinical social worker employed as an Education Specialist by a regional education service district in Oregon displayed books in his school offices that expressed particular viewpoints on gender identity. These books, visible to students during evaluations and meetings, prompted a complaint alleging that the displays constituted a hostile bias incident under the district’s policy designed to prevent discrimination and address bias in public education settings. The district investigated, concluded that the displays violated its policy, and ordered the employee to remove the books when students were present, warning that failure to comply could result in discipline, including termination.The employee filed a lawsuit in the United States District Court for the District of Oregon alleging violations of his First Amendment free speech rights and sought a preliminary injunction to prevent the district from enforcing its directive. The district court granted the injunction in part, allowing the employee to display the books when students were not present but prohibiting displays during student-facing activities. The court reasoned that, while engaging with students as part of his official duties, the employee spoke as a government employee rather than as a private citizen and therefore was not entitled to First Amendment protection for his displays. After the employee continued to display the books in the presence of students, the district initiated additional proceedings, resulting in his termination. The employee appealed both the partial denial of injunctive relief and the denial of his motion to enforce the injunction.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decisions. The Ninth Circuit held that the employee’s display of the books while meeting with students in his official capacity was speech as a government employee and not protected by the First Amendment. Because this speech was undertaken pursuant to his professional responsibilities, the court did not apply the Pickering balancing test. The denial of preliminary injunctive relief was found not to be an abuse of discretion. View "THEIS V. INTERMOUNTAIN EDUCATION SERVICE DISTRICT" on Justia Law

Peter Navarro, a former senior adviser in the Trump administration, published materials and made public statements in 2021 about a plan to delay the certification of the 2020 presidential election. The U.S. House Select Committee investigating the January 6th Capitol attack subpoenaed Navarro for documents and deposition testimony related to these statements. Navarro refused to comply, asserting executive privilege before even seeing the subpoena and declining to engage with the Committee regarding his privilege claim. After the compliance deadline passed, the House voted to hold him in contempt, and a grand jury indicted him on two counts of contempt of Congress.In the United States District Court for the District of Columbia, Navarro moved to dismiss the indictment, arguing that former President Trump had invoked executive privilege on his behalf. After an evidentiary hearing, the district court found no evidence that Trump or his designee had actually invoked executive privilege in connection with the subpoena and denied the motion to dismiss. The court also granted a government motion to prevent Navarro from arguing at trial that a good-faith belief in executive privilege excused his noncompliance. A jury found Navarro guilty on both counts.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that only the President or a designated official can invoke executive privilege and that the district court did not clearly err in finding no such invocation occurred for Navarro’s subpoena. The court further held that executive privilege, even if properly invoked, would not have excused Navarro’s blanket refusal to comply, especially regarding his public statements and writings. It also affirmed that a mistaken belief in the applicability of executive privilege is not a defense to contempt of Congress. The appellate court affirmed the district court’s judgment. View "USA v. Navarro" on Justia Law

A defendant was charged with 44 federal offenses, including bank fraud, wire fraud, aggravated identity theft, obstruction of official proceedings, and witness tampering, arising from an alleged scheme to defraud the Paycheck Protection Program. The defendant, a Black Muslim man, co-founded a nonprofit for transitional housing and allegedly used stolen identities and fraudulent loan applications for the nonprofit and two shell entities. He represented himself at trial, arguing law enforcement targeted him due to his race and religion.The United States District Court for the Northern District of California presided over the trial. During jury selection, an alternate juror expressed strong negative reactions to the defendant’s defense, stating he could not put aside his personal experiences and doubted his ability to be impartial. Despite the defendant’s request to excuse this juror, the district court deferred its inquiry and allowed the juror to serve as an alternate. When a regular juror was dismissed during trial, the alternate joined the deliberating jury after a brief, belated colloquy in which he claimed to have moved past his initial bias. The defendant objected, arguing the juror remained biased. The jury subsequently convicted the defendant on all counts, and the district court sentenced him to 204 months’ imprisonment.The United States Court of Appeals for the Ninth Circuit reviewed the proceedings and held that the district court abused its discretion by failing to promptly investigate the alternate juror’s bias and by conducting an inadequate inquiry after the juror had heard evidence. The appellate court found that these errors deprived the defendant of his Sixth Amendment right to an impartial jury and constituted structural error. The Ninth Circuit vacated the convictions, reversed the district court’s judgment, and remanded the case for a new trial. View "USA V. COLAR" on Justia Law

A group of former employees of the Washington Department of Children, Youth, and Families challenged the agency’s implementation of a COVID-19 vaccine mandate issued by the Governor of Washington. After their requests for religious exemptions were granted, the agency denied their requests for reasonable accommodations that would allow them to remain unvaccinated and continue in their positions. The agency explained that, due to the nature of their roles, unvaccinated employees could not safely perform essential functions without posing a risk to others. The employees were ultimately separated from employment. They alleged constitutional violations and state law claims, asserting that the agency and certain officials discriminated against them based on religion and failed to provide required procedural protections.The United States District Court for the Western District of Washington dismissed all claims. It found that the employees had not sufficiently alleged ongoing violations of federal law for injunctive relief, nor had they adequately alleged personal involvement by any official in the claimed constitutional violations. The court dismissed the federal claims and all state law claims, initially granting leave to amend. After the employees filed an amended complaint naming additional officials and asserting similar legal theories without new factual allegations, the district court dismissed the case without leave to amend and denied reconsideration.The United States Court of Appeals for the Ninth Circuit reviewed the dismissal de novo. The court held that the employees failed to plausibly allege personal involvement by any official in constitutional violations, and that official-capacity claims for prospective injunctive relief were barred by the Eleventh Amendment because there was no ongoing violation of federal law. It further concluded that the district court acted within its discretion in denying leave to amend, as amendment would have been futile. The Ninth Circuit affirmed the district court’s dismissal and denial of leave to amend. View "SEAGRAVES V. WASHINGTON STATE DEPARTMENT OF CHILDREN YOUTH AND FAMILIES" on Justia Law

The petitioner, a lawful permanent resident originally from the West Bank, lived in Vermont and was pursuing graduate studies at Columbia University. Following his vocal participation in student demonstrations protesting military actions in Gaza, he was arrested at a USCIS facility in April 2025 by Homeland Security agents, who commenced removal proceedings against him. The Notice to Appear cited a determination by the Secretary of State that his presence or activities posed potentially serious adverse foreign policy consequences, referencing his alleged rhetoric and conduct at protests. The government also presented prior allegations related to firearm purchases and drug possession, which the petitioner denied or had resolved.After his arrest, the petitioner’s attorney filed a habeas corpus petition in the United States District Court for the District of Vermont, alleging that the government targeted him for removal based on constitutionally protected speech. The petition sought to invalidate the Secretary of State’s determination, bar removal based on advocacy for Palestinian rights, and obtain his release. The district court granted his release pending review of the petition, finding a likelihood of success on the First Amendment claim and determining it had jurisdiction despite statutory provisions that restrict judicial review in immigration matters.The United States Court of Appeals for the Second Circuit reviewed the appeal. Applying a de novo standard for subject matter jurisdiction, the court concluded that 8 U.S.C. § 1252(b)(9) channels judicial review of questions arising from removal actions to the administrative process and ultimately to a petition for review of a final order of removal in the circuit courts. The court held that the district court lacked jurisdiction to entertain the habeas petition because the petitioner’s claims were intertwined with the removal proceedings. The court vacated the district court’s release order and remanded with instructions to dismiss the habeas petition for lack of jurisdiction. View "Mahdawi v. Trump" on Justia Law

The case involves a police encounter at a gas station in Philadelphia, which was known as a base for the Ozone Gang, a group associated with gun violence and drug activity. Officers arrived in an unmarked car and approached Phillip Shivers, who was seated near known gang members. Upon seeing the officers, Shivers fled, and police pursued and apprehended him, finding a loaded firearm in his possession. Shivers was charged with multiple firearm and related offenses.After a preliminary hearing, the case was set for trial in the Court of Common Pleas of Philadelphia County. Shivers filed motions to suppress the physical evidence and to compel the Commonwealth to produce objective evidence that the area was indeed a high-crime area. At the suppression hearing, Shivers argued the police lacked reasonable suspicion or probable cause to detain him, but did not specifically argue that Pennsylvania’s Constitution provided greater protection than federal law on this issue. The trial court denied suppression, finding Shivers’s unprovoked flight in a high-crime area gave officers reasonable suspicion, and subsequently convicted him on all charges. Shivers appealed, arguing the “high-crime area” factor should not suffice for reasonable suspicion under Article I, Section 8 of the Pennsylvania Constitution.The Superior Court affirmed the conviction, holding it was bound by prior precedent equating the state and federal constitutional standards in stop-and-frisk cases. On further appeal, the Supreme Court of Pennsylvania reviewed whether Shivers properly preserved his “departure claim”—that Article I, Section 8 should offer greater protection than the Fourth Amendment. The Court held that Shivers had not adequately preserved this claim in the trial court because he failed to provide any analysis or reasons for departure from federal law, as required by Commonwealth v. Bishop. The Court affirmed the Superior Court’s decision, holding the departure claim was waived. View "Commonwealth v. Shivers" on Justia Law

Two private hunting clubs, each owning substantial contiguous acreage in rural Pennsylvania, sought to maintain privacy over their lands, which are used by members and guests for hunting and other recreational activities. The clubs posted “no trespassing” signs, marked boundaries with purple paint, installed gates, and in some areas, fenced their properties. Despite these efforts to exclude non-members, officers from the Pennsylvania Game Commission repeatedly entered the clubs’ land without consent, a warrant, or probable cause, sometimes installing trail cameras and issuing citations for alleged hunting violations. The clubs argued that such warrantless searches violated their constitutional rights.The clubs filed a petition for declaratory and injunctive relief in the Commonwealth Court of Pennsylvania, naming the Game Commission and a game warden as respondents. They challenged specific provisions of the Game and Wildlife Code that authorize warrantless entry onto private land outside buildings and curtilage. The Commonwealth Court, sitting en banc, granted summary relief for the Commission and denied relief to the clubs, reasoning that it was bound by the Pennsylvania Supreme Court’s prior decision in Commonwealth v. Russo, which held that Article I, Section 8 of the Pennsylvania Constitution does not extend privacy protections to open fields.On appeal, the Supreme Court of Pennsylvania reviewed its precedent in Russo and conducted an independent constitutional analysis. The court overruled Russo, holding that Article I, Section 8 of the Pennsylvania Constitution provides more robust protection than the Fourth Amendment regarding open fields. Specifically, the court determined that landowners who take sufficient steps to exclude intruders—such as posting signs, fencing, or gating—have a reasonable expectation of privacy in their open fields. As a result, the Game Commission’s statutory authority to enter posted private land without a warrant was struck down as unconstitutional, and the Commonwealth Court’s order was reversed. View "Punxsutawney Hunting Club v. PGC" on Justia Law

The case involves Tamarcus Ellis, who was tried and convicted for conspiracy to traffic methamphetamine and actual drug trafficking in Greensboro, North Carolina. During his four-day trial in federal court, a government witness, Malcolm Russell, appeared intimidated while testifying. The U.S. Marshals Service reported that individuals in the gallery were making audible noises and gestures perceived as signaling disagreement with Russell’s testimony. Based on this, the district court partially closed the courtroom for approximately one hour during Russell’s testimony, excluding most members of the public but allowing Ellis’ family and defense counsel’s family to remain.After Ellis was convicted and sentenced to 480 months’ imprisonment by the United States District Court for the Eastern District of North Carolina, he appealed. Ellis argued that the partial closure violated his Sixth Amendment right to a public trial, asserting this was structural error requiring automatic reversal and a new trial.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. The court acknowledged that the closure was not trivial and implicated the Sixth Amendment’s Public Trial Clause. It applied the modified Waller test for partial courtroom closures, which requires a “substantial reason” for the closure, that the closure be no broader than necessary, consideration of reasonable alternatives, and adequate findings by the trial court. The Fourth Circuit found that the district court had a substantial reason to partially close the courtroom to prevent witness intimidation, tailored the closure appropriately, considered alternatives, and made sufficient findings on the record. Therefore, the Fourth Circuit held that the partial closure did not violate Ellis’ Sixth Amendment right to a public trial and affirmed the district court’s judgment. View "US v. Ellis" on Justia Law