Justia Constitutional Law Opinion Summaries

A man was killed in a motor vehicle accident while working for Rent-A-Center. His widow and the mother of his minor child sued the driver responsible for the accident and other related parties in the District Court of Bryan County, Oklahoma. The employer and its insurance carrier, having paid statutory workers' compensation death benefits to the widow and child, were allowed to intervene, seeking reimbursement for the death benefits from any recovery against the tortfeasor, as authorized by 85A O.S.2014, § 43.Plaintiffs moved for summary judgment, arguing that Section 43 was unconstitutional under Article 23, section 7 of the Oklahoma Constitution. The District Court granted summary judgment in favor of the plaintiffs, finding the statute unconstitutional as applied to death benefits. The employer and insurer appealed, and the Court of Civil Appeals, Division I, reversed the trial court’s order, holding Section 43 constitutional based on precedent and persuasive authority from other jurisdictions. Plaintiffs then petitioned for certiorari review by the Oklahoma Supreme Court, which was granted.The Supreme Court of the State of Oklahoma conducted a de novo review and held that 85A O.S.2014, § 43 is constitutional and does not violate Article 23, section 7 of the Oklahoma Constitution. The court clarified that Section 43 does not abrogate the right of action for wrongful death but rather apportions recovery between dependents and the employer or insurer who paid benefits. The opinion of the Court of Civil Appeals and the trial court’s order were both vacated, and the case was remanded for further proceedings consistent with the Supreme Court’s decision. View "ALEXANDER v. DUONG" on Justia Law

James Seabrook was arrested in May 2016 and spent more than seven and a half years in pre-trial detention. In April 2019, he was convicted of criminal possession of a weapon, but juries hung on more serious charges during subsequent retrials, and Seabrook was ultimately acquitted of those charges in December 2023. On January 31, 2024, Seabrook was sentenced to an indeterminate term of three and a half to seven years for the 2019 conviction. All parties recognized at sentencing that he had already served more time than the maximum sentence, yet he was remanded to Rikers Island, where he remained for seventeen days pending transfer from the New York City Department of Correction to the New York State Department of Corrections and Community Supervision, before his release.Seabrook filed suit in the United States District Court for the Southern District of New York, alleging violations of the Eighth and Fourteenth Amendments under 42 U.S.C. § 1983, naming the City of New York and various DOC officials. The district court dismissed his claims, holding that the complaint did not adequately allege deliberate indifference by any individual defendant, nor the existence of a City policy or practice causing his over-detention. The court also found no deprivation of a cognizable liberty interest or lack of procedural protections sufficient to sustain the due process claim.The United States Court of Appeals for the Second Circuit reviewed the case and held that Seabrook had plausibly alleged both an unconstitutional City policy or practice causing his excessive detention and deliberate indifference by DOC Captain Monastero. The Court further determined that Seabrook's procedural due process claim was sufficiently pleaded, given the absence of adequate processes to prevent over-detention. The Second Circuit vacated the district court's dismissal and remanded for further proceedings. View "Seabrook v. City of New York" on Justia Law

A coalition of twenty-seven Judeo-Christian organizations challenged a change in federal immigration enforcement policy that removed longstanding protections for houses of worship. For over thirty years, the government had a "Sensitive Locations Policy" that limited immigration enforcement at places like churches, synagogues, and mosques, except in exigent circumstances or with high-level approval. In January 2025, the Department of Homeland Security rescinded this policy, instructing immigration officers to use their discretion when conducting enforcement at these locations. Subsequent agency memoranda implemented this change, allowing supervisory agents to approve enforcement operations at or near houses of worship on a case-by-case basis, with no bright-line rules. Plaintiffs, representing congregations that serve undocumented immigrants, alleged that the new policy created a credible threat of enforcement, causing declines in attendance, financial burdens, and moral dilemmas.The United States District Court for the District of Columbia denied the plaintiffs’ motion for a preliminary injunction. The court concluded that the plaintiffs were unlikely to have Article III standing, finding their asserted injuries were not sufficiently imminent, not traceable to the policy change, or not redressable by reverting to the prior policy. Specifically, the district court relied on a legal standard requiring plaintiffs to show they were uniquely targeted for enforcement, which it found was not satisfied.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s denial of the preliminary injunction. The appellate court held that the plaintiffs likely have associational standing based on the imminent threat of enforcement actions at houses of worship, which burdens expressive and religious rights. The court determined that the harm was imminent, traceable to the government’s policy change, and redressable by the requested relief. The main holding was that plaintiffs likely have standing, and the district court’s denial of the preliminary injunction was reversed and remanded for further proceedings. View "Mennonite Church USA v. DHS" on Justia Law

A woman was stopped by police in Idaho for driving with an expired vehicle registration. During the traffic stop, a drug detection dog named Edo was deployed to conduct a “free-air sniff” around her vehicle. While sniffing, Edo briefly touched the vehicle’s door handle with the tip of his nose and alerted to the presence of drugs. Based on this alert, officers searched the vehicle and discovered methamphetamine, marijuana, alprazolam, and drug paraphernalia, leading to her arrest and subsequent charges for possession.After an earlier appeal concerning discovery issues related to Edo’s performance records, the defendant moved to suppress the evidence from the stop, arguing that the dog’s contact with her vehicle transformed the sniff into a trespassory search in violation of the Fourth Amendment. The District Court of the Fourth Judicial District in Ada County heard testimony and reviewed video evidence, ultimately granting the motion to suppress. The court concluded that the brief nose contact constituted trespassing and an unlawful search under Idaho precedent, specifically State v. Dorff, 171 Idaho 818, 526 P.3d 988 (2023).The State appealed, and the Idaho Court of Appeals reversed the district court’s suppression order, finding that the contact was not trespassory and that Edo’s alert provided probable cause for the search. The defendant then petitioned for review, which was granted by the Supreme Court of the State of Idaho. The Supreme Court held that the drug dog’s fleeting, momentary nose contact did not amount to “intermeddling” or trespassory conduct under the property-based Fourth Amendment analysis established in Dorff. Therefore, the contact did not transform the free-air sniff into a search, and the district court erred in granting the motion to suppress. The suppression order was reversed and the case remanded for further proceedings. View "State v. Pendleton " on Justia Law

A group of parents, authors, a free speech organization, and a book publisher brought a lawsuit against a county school board, challenging the removal of certain library books from public school libraries. The school board had adopted policies, as required by Florida law, mandating the removal of materials deemed pornographic or describing sexual conduct, and established procedures for reviewing objections to specific books. After objections were raised to various titles, review committees and the superintendent made recommendations, and the school board ultimately voted to remove several groups of books based on its existing policies and a directive aligned with state guidelines.Prior to this appeal, the United States District Court for the Northern District of Florida considered whether members of the school board could claim legislative privilege to avoid being deposed about their reasons for voting to remove the books. The district court ruled that legislative privilege did not apply in this context, finding that the board members’ votes to remove specific books constituted administrative acts—applying established policy to particular facts—rather than legislative acts involving the creation or amendment of policy. The district court denied the board members’ motion for a protective order and subsequent motions to quash deposition subpoenas.The United States Court of Appeals for the Eleventh Circuit reviewed whether legislative privilege shielded the school board members from testifying about their decisions to remove the books. The Eleventh Circuit affirmed the district court, holding that the board members’ votes to remove specific books, as applications of existing policy to individual cases, were administrative rather than legislative acts. Therefore, legislative privilege did not bar their depositions regarding those specific removal decisions. The court emphasized its holding was limited to the particular facts of this case and did not address whether other privileges or rules might limit such discovery. View "Pen American Center, Inc. v. Adams" on Justia Law

A Ukrainian Catholic parish near Pittsburgh owns two plots of land, one containing its church and the other, a cemetery and mausoleum. The parish sought to build a large shrine dedicated to Mary and the sanctity of life on its second plot in Collier Township, but the township’s zoning code did not allow such a use. The parish applied to amend the code and rezone its land to facilitate the project, submitting plans and a traffic study. After a public hearing, the township’s Board of Commissioners denied the application, citing traffic concerns, fundraising issues, and objections to the shrine’s pro-life message. The parish then proposed a smaller chapel, which was approved but with restrictive conditions. Initially, the parish appealed in state court, but it abandoned that appeal to file a federal lawsuit, alleging violations of the First Amendment and RLUIPA.The U.S. District Court for the Western District of Pennsylvania reviewed the parish’s motion for a preliminary injunction. The court denied the motion, reasoning that the parish was not substantially likely to succeed on the merits, the requested relief was unclear, and granting an injunction would disrupt the status quo rather than preserve it. The court also found that no injunction was necessary to keep the case viable.The United States Court of Appeals for the Third Circuit reviewed the District Court’s denial of the preliminary injunction. Applying a deferential standard, the Third Circuit affirmed the denial, holding that although the parish had a strong likelihood of success on its RLUIPA substantial-burden claim, it failed to demonstrate irreparable harm or the necessity of preliminary relief. The court emphasized that preliminary injunctions are meant to preserve the status quo pending trial, not to grant final relief. The denial was affirmed. View "Holy Trinity Ukrainian Catholic Church v. Township of Collier" on Justia Law

Santa Clara County’s Board of Supervisors responded to significant anticipated federal funding cuts, stemming from Congress’s enactment of H.R. 1, by declaring an emergency and calling for a special election to seek voter approval for Measure A—a five-year general sales tax increase. The Board determined that these federal cuts would have an immediate and severe impact on healthcare and social safety net services for county residents, and that waiting until the next general election would result in deep service reductions. The Board’s resolution outlined detailed findings about the emergency’s nature and magnitude, and the measure was placed before voters in a special election.Prior to the election, individual county residents challenged the legal sufficiency of the emergency declaration in the Superior Court of Santa Clara County. They argued that the “cases of emergency” exception in article XIII C, section 2 of the California Constitution was improperly applied, and that the measure’s ballot question and impartial analysis were not impartial or accurate as required by the Elections Code. After expedited proceedings, the trial court denied their petition regarding the emergency declaration but ordered agreed-upon modifications to some ballot language.On appeal, the California Court of Appeal, Sixth Appellate District, held that the “cases of emergency” clause should be interpreted according to its ordinary meaning—referring to unforeseen circumstances requiring immediate action—and does not require a narrow or specially defined scope. The court found that the Board’s resolution and findings provided sufficient factual basis for the emergency declaration and that the trial court’s handling of judicial notice, even if imperfect, was not prejudicial. The court declined to address arguments about the specific ballot language or impartial analysis, finding those issues moot. The judgment denying the writ was affirmed. View "Holtz v. Moreles" on Justia Law

An IT analyst who is openly gay was hired by a large, Catholic-affiliated nonprofit based in Maryland. At the time of hiring, he was told his husband would be covered under the organization’s dependent health benefits. However, several months after his employment began, the organization informed him that providing benefits to his same-sex spouse was contrary to its religious beliefs and terminated those benefits. The employee declined alternative compensation and ultimately resigned from the organization after several years.The employee sued in the United States District Court for the District of Maryland, bringing claims under federal and state employment discrimination laws, including Title VII, the Equal Pay Act, and the Maryland Fair Employment Practices Act (MFEPA). The district court granted summary judgment for the employee on the Title VII and Equal Pay Act claims and, after certifying questions to the Maryland Supreme Court regarding the scope of the MFEPA’s religious exemption, held a bench trial and entered judgment for the employee on the remaining MFEPA claim. The parties stipulated to damages, but the employer reserved the right to appeal on liability.The United States Court of Appeals for the Fourth Circuit reviewed the employer’s statutory and constitutional defenses. The court held that Title VII’s religious employer exemption does not shield religious organizations from liability for discrimination based on sex, even if the employment decision is rooted in religious belief. Similarly, under MFEPA, the court found the exemption applies only to employees whose duties directly further the core mission of the organization; the employee’s roles did not meet this test. The court also held that the Religious Freedom Restoration Act does not apply to suits between private parties. Constitutional arguments based on the First Amendment’s Religion Clauses and church autonomy doctrine were rejected as grounds for immunity. The Fourth Circuit affirmed the district court’s judgment on Title VII and MFEPA claims and dismissed the Equal Pay Act appeal as moot. View "Doe v. Catholic Relief Services" on Justia Law

A Texas-based energy company, structured as a subsidiary of a Chinese corporation, sought to develop renewable energy projects in Texas, including the Blue Star Solar Project, and to interconnect these projects to the Texas electric grid managed by the Electric Reliability Council of Texas (ERCOT). The Texas Lone Star Infrastructure Protection Act (LSIPA), enacted in 2021, prohibits entities majority-owned or controlled by Chinese citizens or corporations from owning or controlling critical infrastructure, including the state’s electric grid. In 2022, ERCOT, applying LSIPA, denied the company’s request to interconnect the Blue Star project and rejected subsequent efforts to repurpose the project.The company sued in the United States District Court for the Western District of Texas, arguing that LSIPA was preempted by federal law—specifically, the Committee on Foreign Investment in the United States (CFIUS) regime under the Defense Production Act and its amendments. The company also asserted constitutional claims, but ultimately narrowed its appeal to the preemption issue. The district court dismissed the claims, holding that LSIPA was not preempted by the federal CFIUS regime, finding no conflict or field preemption.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed. The Fifth Circuit held that the federal CFIUS regime does not impliedly preempt LSIPA. The court found that LSIPA and CFIUS operate in purposive harmony, with LSIPA providing additional state-level protections without conflicting with federal objectives. The court also held that CFIUS is not a pervasive federal regulatory scheme that would field-preempt state law in this area. Accordingly, the Fifth Circuit affirmed the district court’s dismissal of the preemption claims. View "GH America v. Fohn" on Justia Law

Antoine Cook was arrested after his then-girlfriend, E.C., contacted his parole officer and reported both his arrest for domestic violence and their recent drug use. When parole officers arrived at the hotel, E.C. had Cook’s cell phone and stated it was her only means of communication. She provided the officers with the phone’s passcode and consented to their request to search the device. On the phone, officers found incriminating images and videos depicting drugs and firearms. Based on this evidence and a subsequent consent search of the hotel room, officers discovered ammunition and controlled substances.The United States District Court for the Northern District of Ohio denied Cook’s motion to suppress evidence obtained from the cell phone, holding that Cook’s parole conditions permitted warrantless searches. The district court also rejected Cook’s challenges regarding the authority to consent to the phone search and permitted the evidence from the hotel room. Cook was later convicted by a jury on counts of possessing methamphetamine and cocaine with intent to distribute, and being a felon in possession of ammunition. He appealed, arguing improper denial of the suppression motion, ineffective assistance of counsel, and judicial bias.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that E.C. had common authority over the cell phone and could consent to its search, obviating the need to consider parole-based search arguments. The court also found no plain error in the seizure of the phone, as officers had probable cause and Cook’s possessory interest was not meaningfully interfered with while he was in custody. The court declined to address the ineffective assistance of counsel claim due to an insufficient record and found no evidence of judicial bias by the district judge. View "United States v. Cook" on Justia Law