Justia Constitutional Law Opinion Summaries

Donika Rae Gonzales was convicted in 2014 by a jury of first-degree manslaughter and aggravated assault for beating her boyfriend’s four-year-old son to death. Gonzales filed a petition for a writ of habeas corpus, arguing that the jury district, which included residents from both Brule and Buffalo Counties, diluted the percentage of prospective Native American jurors, violating her constitutional rights. She also claimed ineffective assistance of counsel for her attorney’s failure to introduce certain evidence at trial. The habeas court found that the jury district violated both federal and state constitutions and reversed her conviction without addressing the ineffective assistance claims.The Circuit Court of the First Judicial Circuit initially sent jury questionnaires to only Buffalo County residents, but due to an inadequate number of responses, included Brule County residents as well, based on a 2011 standing order. Gonzales agreed to hold the trial in Brule County and use a combined jury pool from both counties. The jury pool consisted of 236 jurors, with 22% Native American representation, compared to 29% in the combined population of the two counties. Gonzales appealed her conviction, but it was summarily affirmed by the South Dakota Supreme Court in 2016.The South Dakota Supreme Court reviewed the case and reversed the habeas court’s decision. The court held that the use of a jury district comprising Buffalo and Brule Counties did not violate the South Dakota Constitution’s requirement for a trial by a jury of the “county or district” where the offense occurred. The court also found that Gonzales failed to establish a violation of the Sixth Amendment’s fair cross-section requirement, as the absolute disparity in Native American representation was only 7%, below the constitutional threshold. Consequently, Gonzales’ ineffective assistance claims were also deemed without merit, and the order granting habeas relief was vacated. View "Gonzales v. Markland" on Justia Law

Space Exploration Technologies Corp. (SpaceX) operates a space launch business and a global satellite-based internet service called Starlink. In June 2022, a group of SpaceX employees sent an open letter demanding certain actions from the company and solicited support through a survey. SpaceX discharged four employees involved in the letter's distribution for violating company policies. Additional employees were later discharged for lying during a leak investigation and for unrelated performance issues. These employees filed charges with the National Labor Relations Board (NLRB) in November 2022, alleging violations of the National Labor Relations Act.The NLRB Regional Director found merit in the claims and issued an order consolidating the employees' cases with a hearing set for March 2024. SpaceX sued the NLRB in the Southern District of Texas (SDTX) in January 2024, challenging the NLRB's structure as unconstitutional and seeking declaratory and injunctive relief. The NLRB moved to transfer the case to the Central District of California (CDCA), arguing improper venue. The SDTX granted the transfer motion in February 2024. SpaceX petitioned for an emergency writ of mandamus to vacate the transfer order, which was initially stayed but later denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. SpaceX argued that the district court effectively denied its motion for a preliminary injunction by failing to rule on it by May 2, 2024. The Fifth Circuit found that SpaceX did not demonstrate the "serious, perhaps irreparable, consequence" required for an immediate appeal. The court noted that participating in the administrative proceeding did not constitute irreparable harm and that the district court did not act unreasonably in waiting to resolve procedural challenges. Consequently, the Fifth Circuit dismissed SpaceX's appeal for lack of subject-matter jurisdiction. View "Space Exploration Technologies Corp. v. National Labor Relations Board" on Justia Law

The case involves two charitable organizations, Catholic Medical Mission Board, Inc. (CMMB) and Food for the Poor, Inc. (FFP), which were issued cease and desist orders and civil penalties by the California Attorney General for allegedly overvaluing in-kind donations and making misleading statements in their solicitations. The Attorney General found that both organizations used inflated domestic market prices for donated medicines, which could not be distributed within the U.S., and misrepresented their program efficiency ratios to donors.The Superior Court of Los Angeles County reviewed the case and found that the challenged statutory provisions, sections 12591.1(b) and 12599.6(f)(2) of the Government Code, were unconstitutional as they constituted prior restraints on speech. The court vacated the civil penalties and issued permanent injunctions against the Attorney General, preventing the enforcement of these provisions. The court also reformed section 12591.1(b) by adding language to exclude violations of section 12599.6 from the Attorney General's cease and desist authority.The California Court of Appeal, Second Appellate District, reviewed the case and concluded that the trial court abused its discretion by granting the permanent injunctions without requiring the plaintiffs to plead and prove their entitlement to such relief. The appellate court vacated the injunctions and remanded the case to allow the plaintiffs to amend their complaints and prove their entitlement to injunctive relief. The appellate court affirmed the trial court's reformation of section 12591.1(b), allowing the Attorney General to issue cease and desist orders for violations unrelated to speech. The appellate court also vacated the postjudgment orders awarding attorney fees and directed the trial court to reconsider the fees in light of the remand. View "Catholic Medical Mission Board v. Bonta" on Justia Law

A bakery, owned by Catharine Miller, refused to sell a predesigned, plain white cake to a same-sex couple, the Rodriguez-Del Rios, for their wedding reception. The bakery's policy prohibited the sale of any preordered cake for same-sex weddings based on Miller's religious beliefs that marriage is between a man and a woman. The couple ultimately obtained a similar cake from another bakery.The Civil Rights Department (CRD) filed a lawsuit against the bakery and Miller, alleging discrimination under the Unruh Civil Rights Act (UCRA). The Kern County Superior Court ruled in favor of the bakery, concluding there was no intentional discrimination and that Miller's referral of the couple to another bakery constituted full and equal access under the UCRA. The court also found that the bakery's refusal was protected by the First Amendment as both pure speech and expressive conduct.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court determined that the bakery's policy was facially discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court concluded that the trial court erred in its determination that the policy was facially neutral and in its application of the intentional discrimination standard. The court also found that Miller's referral to another bakery did not satisfy the UCRA's full and equal access requirement.Regarding the First Amendment defenses, the appellate court held that the plain white cake was not pure speech or expressive conduct protected by the First Amendment. The court reasoned that the cake was a generic, multi-purpose product and did not convey any particularized message about marriage. The court also upheld the UCRA's application under the federal and state Constitutions' free exercise clauses, concluding that the law is neutral and generally applicable and that there are no less restrictive means to achieve the state's compelling interest in ensuring full and equal access to goods and services irrespective of sexual orientation. The appellate court reversed the trial court's judgment and remanded the case for further proceedings. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law

Rebecca Hartzell, a parent of children attending Dove Mountain K-CSTEM school, was banned from the school premises following an incident where she allegedly assaulted the school principal, Andrea Divijak. Hartzell claimed that she was banned in retaliation for her protected speech criticizing the school and its administration. The Marana Unified School District and Divijak argued that the ban was due to Hartzell's conduct, specifically the alleged assault.The United States District Court for the District of Arizona granted summary judgment in favor of the defendants on Hartzell's procedural due process claim, her First Amendment retaliation claim against Divijak, and part of her defamation claim. The court also denied Hartzell's motion to amend her complaint to add a First Amendment theory to her procedural due process claim. At trial, the court precluded Hartzell from pursuing a Monell claim against the District based on a "final policymaker" theory and granted judgment as a matter of law in favor of the District on her First Amendment claim. The jury found in favor of Divijak on the remaining defamation claim.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that the district court did not abuse its discretion in excluding Hartzell's "final policymaker" theory but erred in granting judgment as a matter of law on her First Amendment claim against the District. The court found that a reasonable jury could conclude that Hartzell was banned pursuant to an unconstitutional District policy prohibiting "offensive or inappropriate" speech. The court also affirmed the district court's ruling that Divijak was entitled to qualified immunity on the First Amendment claim. Additionally, the court reversed the summary judgment on Hartzell's defamation claim regarding one of the documents sent to her employer, finding it potentially defamatory. The case was remanded for further proceedings consistent with these findings. View "HARTZELL V. MARANA UNIFIED SCHOOL DISTRICT" on Justia Law

Amber Simpson, Britney Foster, and Stephanie Olivarri, former inmates at the Linda Woodsman State Jail in Texas, filed a lawsuit in August 2020 against Joe Cisneros, a jail guard, alleging sexual abuse and harassment. They claimed violations of their Eighth Amendment rights under the Cruel and Unusual Punishment Clause and their Fourteenth Amendment rights under the Due Process Clause. The plaintiffs described various instances of inappropriate sexual conduct by Cisneros, including sexual comments, physical assaults, and requests for sexual favors.The case was referred to Magistrate Judge Jeffrey C. Manske in the Western District of Texas. Cisneros moved for summary judgment, arguing that the plaintiffs' claims under both the Eighth and Fourteenth Amendments were invalid. The Magistrate Judge recommended granting summary judgment for Cisneros on the Eighth Amendment claims but denying it on the Fourteenth Amendment claims. The district court adopted this recommendation, leading Cisneros to appeal the denial of summary judgment on the Fourteenth Amendment claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the Eighth Amendment, not the Fourteenth Amendment, protects inmates from abusive treatment. The court found that the plaintiffs did assert a Fourteenth Amendment claim in their initial complaint but concluded that the Eighth Amendment provides the explicit textual source of protection for prisoners, making the Fourteenth Amendment inapplicable in this context. Consequently, the court reversed the district court's ruling on the Fourteenth Amendment claim, granted summary judgment in favor of Cisneros on that claim, and remanded the case for further proceedings. View "Simpson v. Cisneros" on Justia Law

Jason Wayne Gowen, a pretrial detainee at the Lynchburg Adult Detention Center, was placed in solitary confinement for 125 days after complaining about hot conditions in his cell and encouraging other inmates to do the same. Gowen filed a lawsuit against several correctional officers, alleging violations of his First Amendment rights due to retaliation for his grievances and his Fourteenth Amendment rights for being placed in solitary confinement without due process.The United States District Court for the Western District of Virginia dismissed Gowen’s First Amendment retaliation claim, stating that he failed to show a causal connection between his grievances and the adverse actions taken against him. The court later granted summary judgment to the officers on Gowen’s Fourteenth Amendment due process claim, concluding that he failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Gowen adequately alleged a First Amendment retaliation claim by showing that he engaged in protected activity, faced adverse action, and established a causal connection through temporal proximity and the officers' awareness of his grievances. The court also determined that Gowen did not forfeit his argument regarding the exhaustion of administrative remedies, as his verified complaint contained sufficient evidence of his attempts to use the grievance process and the officers' failure to respond.The Fourth Circuit reversed the district court’s dismissal of Gowen’s First Amendment retaliation claim and vacated the summary judgment on his Fourteenth Amendment due process claim. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Gowen v. Winfield" on Justia Law

In the spring of 2018, People's Electric Cooperative and Oklahoma Gas and Electric Company (OG&E) submitted competing bids to provide retail electric service to the Tall Oak Woodford Cryo Plant in Coal County, Oklahoma. The Plant is located in People's certified territory, which grants them exclusive rights to provide electricity under the Retail Electric Supplier Certified Territory Act (RESCTA). OG&E's proposal relied on the Large Load exception to RESCTA, which allows a supplier to extend its service into another supplier's territory for large-load customers. OG&E used third-party transmission facilities to provide service to the Plant without extending its own distribution lines.The Oklahoma Corporation Commission enjoined OG&E from serving the Plant, finding that OG&E was not "extending its service" as authorized by RESCTA. The Commission determined that a retail electric supplier may not use third-party transmission lines to extend its service into another supplier's certified territory under the Large Load exception. OG&E appealed the decision.The Supreme Court of the State of Oklahoma reviewed the case and upheld the Commission's determination. The Court held that Article 9, Section 20 of the Oklahoma Constitution requires a limited review of the Commission's order. The Court affirmed the Commission's interpretation that the Large Load exception does not permit a supplier to use third-party transmission lines to extend its service into another supplier's certified territory. The Court's decision applies prospectively only and does not affect existing retail electric services and facilities established under the Large Load exception. View "OKLAHOMA GAS AND ELECTRIC CO. v. STATE" on Justia Law

Jackson Daniel Bowers was convicted in 2019 of possession of heroin with intent to distribute and sentenced to 36 months imprisonment followed by three years of supervised release. In 2023, while on supervised release, Bowers was accused of committing two state crimes: fourth-degree assault and violating a protective order. His probation officer recommended revoking his supervised release. Bowers resolved his state charges by entering a deferral agreement without admitting guilt.The United States District Court for the Eastern District of Washington held a revocation hearing. Bowers requested a jury trial, which the district court denied. The court found by a preponderance of the evidence that Bowers had committed the alleged violations and revoked his supervised release, sentencing him to nine months imprisonment followed by 36 months of supervised release. Bowers appealed, arguing that Article III, Section 2 of the Constitution guarantees the right to a jury trial in revocation proceedings, separate from the Sixth Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Article III’s jury provision and the Sixth Amendment are equivalent in scope. It found that the history and precedent indicate that the Sixth Amendment was meant to complement, not supersede, Article III. Therefore, a right not triggered by the Sixth Amendment cannot be independently triggered by Article III. The Ninth Circuit affirmed the district court’s revocation of Bowers’ supervised release. View "United States V. Bowers" on Justia Law

Reed Day and Albert Jacobs, Arizona residents, wanted to ship wine directly from out-of-state retailers who do not have in-state premises in Arizona. Arizona law, however, requires retailers to have a physical presence in the state to ship wine directly to consumers. Plaintiffs filed a civil rights action under 42 U.S.C. § 1983 against Arizona state officials, claiming that this statutory scheme violates the Commerce Clause.The United States District Court for the District of Arizona granted summary judgment in favor of the state officials and the intervenor-defendant, the Wine and Spirits Wholesalers Association of Arizona. The district court found that the plaintiffs likely lacked standing and that, even if they did, the Arizona laws were not discriminatory. The court reasoned that the physical presence requirement applied equally to in-state and out-of-state retailers and was essential to Arizona’s three-tier system for alcohol distribution.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that the plaintiffs had standing because the district court could grant some form of relief. However, the court found that the plaintiffs failed to show that Arizona’s physical presence requirement was discriminatory. The requirement applied even-handedly to all retailers, regardless of their state of origin, and was not so onerous as to be discriminatory. The court noted that out-of-state businesses could and did obtain retail licenses in Arizona, indicating that the laws did not have a discriminatory effect in practice. The court concluded that Arizona’s laws did not violate the dormant Commerce Clause. View "Day v. Henry" on Justia Law