Justia Constitutional Law Opinion Summaries

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

The case concerns a fatal shooting that took place on a MARTA train in April 2017. The defendant and the victim had previously lived together with the defendant’s girlfriend, after which the defendant accused the victim of stealing their money, personal items, and drugs. Several months later, after an earlier confrontation at a mall, the defendant encountered the victim and others on a train. Surveillance video and eyewitnesses established that the defendant boarded after the victim, lay in wait, then ambushed and fatally shot the victim, also wounding several passengers. The defendant was apprehended at the station and identified by eyewitnesses, and ballistic evidence connected the firearm he possessed to the shooting.Following indictment in the Superior Court of Fulton County, the defendant was tried by jury and found guilty of malice murder, armed robbery, aggravated assault, and firearms offenses. He received a life sentence without parole plus additional years. After trial, the defendant filed a motion for new trial, which was denied. He then appealed to the Supreme Court of Georgia.On appeal, the Supreme Court of Georgia reviewed the defendant’s claims that the trial court erred by refusing to instruct the jury on voluntary manslaughter and that trial counsel was constitutionally ineffective. The Supreme Court held that any error in failing to give the voluntary manslaughter instruction did not affect the outcome due to the strength of the evidence supporting malice murder and the lack of sufficient evidence of provocation. The Court also found that trial counsel’s performance was not deficient for not objecting to the omitted instruction, given the strategic decision to pursue a misidentification defense. The ineffective assistance claim regarding stipulation to felony status was deemed waived because it was not timely raised. The Supreme Court of Georgia affirmed the judgment. View "DANIELS v. THE STATE" on Justia Law

An individual who was convicted in Arizona for several sexual offenses moved to Georgia after completing his sentence and registration period in New Mexico. Upon arrival in Georgia, he was advised by law enforcement that he would need to register as a sex offender under Georgia law. After several years, he sought removal from the registry, arguing that he had fulfilled his obligations elsewhere, that the crimes for which he was convicted did not require registration in Georgia, and that continued enforcement of the registry against him violated his constitutional rights.The Superior Court of DeKalb County initially dismissed his petition for declaratory relief, finding it time-barred under the two-year statute of limitations for personal injury actions. The Court of Appeals affirmed this dismissal. The Supreme Court of Georgia later reversed, holding that his claims for prospective relief had not accrued and thus were not time-barred, and remanded the case. On remand, after further amendments and substitution of parties, the trial court dismissed the petition again, this time as moot, citing recent revisions to Georgia’s Registry Act which provided a statutory mechanism for requesting removal from registration requirements. The Court of Appeals affirmed the dismissal, but on the alternative ground that any decision would be an impermissible advisory opinion since only prospective relief was sought.The Supreme Court of Georgia reviewed the case and held that seeking prospective relief in a declaratory judgment action is not grounds for dismissal as an impermissible advisory opinion. The Court vacated the Court of Appeals' judgment and remanded the case for further proceedings consistent with its opinion, directing the Court of Appeals to address whether the trial court’s dismissal on mootness grounds was proper and, if not, to instruct the trial court to adjudicate the merits of the declaratory judgment claim. View "GARDEI v. TAYLOR" on Justia Law

After reports and investigations of sexual abuse allegations against a father, the State’s Department of Human Services (DHS) petitioned for foster custody of his children. The family court consolidated the cases, and in September 2024, it issued orders granting DHS foster custody and incorporating a Service Plan that required the father to participate in sex abuse treatment. Importantly, the plan mandated that he “acknowledge and take responsibility for the sexual abuse to his victims” as a condition of successful completion.The father appealed these orders to the Intermediate Court of Appeals of Hawai‘i (ICA), which affirmed the family court's decision. Due to complications with his legal representation, the father’s application for writ of certiorari to the Supreme Court of Hawai‘i was filed late, but the Supreme Court agreed to consider the merits, recognizing his constitutional right to counsel in parental rights termination proceedings.The Supreme Court of Hawai‘i reviewed whether the State can require a parent, as part of mandated rehabilitation therapy in child custody proceedings, to make incriminating disclosures. The court held that under Article I, Section 10 of the Hawai‘i Constitution, the State may not require a parent to admit to criminal misconduct as a condition of completing court-ordered therapy, as this violates the privilege against self-incrimination. However, the court clarified that if a parent’s silence or refusal to admit abuse hinders effective therapy, the court may consider that as a factor in custody determinations without violating the constitutional privilege. The court vacated the lower courts’ orders to the extent they required the father to admit to sexual abuse, and remanded for further proceedings consistent with its opinion. The lower courts’ orders were otherwise affirmed. View "In re: T.J." on Justia Law

Gateway Conservation Alliance challenged the Montana Department of Environmental Quality’s (DEQ) issuance of an opencut mining permit to TMC, Inc. for a site in Gallatin County. After DEQ approved the permit, Gateway filed an administrative appeal with the Board of Environmental Review, alleging violations of environmental statutes related specifically to the permit and site. While that administrative appeal was pending, Gateway also filed a complaint in the Gallatin County District Court, arguing that recent legislative amendments (HB 599) to the governing mining statute violated Montana’s constitutional right to a clean and healthful environment. Gateway sought a declaration of unconstitutionality, an injunction against enforcement, and vacatur of the permit.The District Court for the Eighteenth Judicial District dismissed Gateway’s complaint, holding that Gateway had failed to exhaust its administrative remedies before seeking judicial review, as required under the Montana Administrative Procedure Act (MAPA). The District Court reasoned that Gateway’s constitutional challenge was not a pure facial attack on the administrative scheme itself, but was instead tied to the specific permit at issue, and thus did not fall within any exception to the exhaustion requirement.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal. The Supreme Court held that a party challenging an agency decision governed by MAPA must first complete the administrative process and obtain a final agency decision before seeking judicial review, even if the challenge includes constitutional claims. The only exception recognized is for pure facial constitutional challenges to the administrative process itself, which was not present here. The Court concluded that Gateway’s claims could be raised on judicial review after exhausting administrative remedies, but not before. The order of dismissal was affirmed. View "Gateway Conservation Alliance v. State" on Justia Law

A Lebanese citizen who worked as a physician and educator in the United States traveled to Lebanon to visit family and, upon her return to Boston Logan International Airport, was detained by Customs and Border Protection (CBP) officers. During inspection, officers reviewed her phone and found photos and videos related to Hezbollah, which is designated as a foreign terrorist organization by the United States. She acknowledged deleting some of the photos before her arrival, explained her religious motivations and familial connections, and denied supporting Hezbollah’s political or military activities. After an interview, CBP officers determined she was inadmissible as an immigrant without valid documents because her intentions could not be verified due to derogatory information found during inspection. She was issued an expedited removal order, her H-1B visa was revoked, and she was returned to Lebanon, subject to a five-year bar on reentry.The United States District Court for the District of Massachusetts dismissed her amended habeas corpus petition for lack of jurisdiction, finding that the Immigration and Nationality Act (INA) strips federal courts of jurisdiction to review expedited removal orders except in narrow circumstances not present in her case. The district court also concluded that the Suspension Clause did not preserve jurisdiction for her claims and that her remaining arguments fell outside the scope of habeas review permitted under the INA.The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that it lacked jurisdiction to review the petitioner’s challenge to the expedited removal order and the revocation of her visa because her claims did not fall within the exceptions enumerated in 8 U.S.C. § 1252(e)(2). The court further concluded that the Suspension Clause did not require broader habeas review in these circumstances and rejected arguments that her case was distinguishable from binding Supreme Court precedent. View "Alawieh v. Mullin" on Justia Law

Edward Williams was convicted in Pennsylvania for driving under the influence of alcohol at the “highest rate,” a crime punishable by up to five years in prison due to a prior DUI offense. He was sentenced to home confinement for ninety days to two years, but his conviction triggered 18 U.S.C. § 922(g)(1), which prohibits firearm possession by anyone convicted of a crime punishable by more than one year of imprisonment. Williams continued to possess firearms until learning of the prohibition, after which he divested himself of firearms and refrained from further possession.The United States District Court for the Eastern District of Pennsylvania reviewed Williams’s claim that § 922(g)(1), as applied to him, violated the Second Amendment. Both parties moved for summary judgment. The District Court granted summary judgment in favor of Williams, holding that the statute’s application to his nonviolent DUI conviction was unconstitutional under the Second Amendment. The United States appealed this decision.The United States Court of Appeals for the Third Circuit, sitting en banc, affirmed the District Court’s judgment. The Court held that the permanent firearm prohibition imposed by § 922(g)(1) was not consistent with the Nation’s historical tradition of firearm regulation when applied to individuals convicted of nonviolent offenses, such as Williams’s DUI. The Court emphasized that longstanding restrictions targeted individuals who posed a risk of violence or misuse of arms, not felons in general or those convicted of nonviolent conduct. The government failed to show that Williams’s offense or current status justified permanent disarmament under historical analogues. The Court concluded that Williams, as a peaceable citizen who poses no present risk, is constitutionally protected in his right to possess firearms. The District Court’s decision was affirmed. View "Williams v. Attorney General" on Justia Law

An employee with a long tenure at a state agency suffered a heart attack and was subject to permanent medical restrictions preventing him from performing his original job duties at a coal-fired power plant. The agency accommodated him for two years with a temporary assignment and ultimately offered him a permanent position that met his medical restrictions, but at a lower hourly wage. The employee did not respond to the offer and was subsequently terminated.The employee sought review of his termination before the Civil Service Division of the Office of Management and Enterprise Services (OMES). An administrative law judge found he failed to meet his burden to prove that the agency had no reasonable basis for his termination, and OMES adopted that decision. The employee then sought judicial review in the District Court of Mayes County, which reversed OMES’s order. The district court found that the employee had a substantial interest in his employment and that the statutory and regulatory procedures for termination under 62 O.S. § 34.301 violated due process. The district court also concluded that the agency lacked a reasonable basis to terminate the employee and ordered further proceedings.The Supreme Court of the State of Oklahoma reviewed the case. It held that the Civil Service Modernization Act does not create a constitutionally protected property interest in continued public employment for state employees, so due process protections are not triggered by terminations under this statute. The Court further held that the district court erred in reweighing the evidence and misapplied the statutory burden of proof: the employee did not prove there was no reasonable basis for his termination. The Supreme Court reversed the district court’s judgment and affirmed OMES’s final agency order upholding the termination. View "TURNER v. OKLAHOMA GRAND RIVER DAM AUTHORITY" on Justia Law

James Bost previously pleaded guilty to several crimes in Pennsylvania, including terroristic threats, which involved threatening to commit a violent crime with intent to terrorize another. Years after his conviction, Bost was found by police with a stolen pistol while on bail for an unrelated charge. This led to federal charges for possessing a firearm as a felon under 18 U.S.C. § 922(g)(1), and for possessing a stolen firearm under § 922(j). Bost moved to dismiss the indictment, contending that the felon-in-possession law was unconstitutional both on its face and as applied to him, citing his Second Amendment rights.The U.S. District Court for the Western District of Pennsylvania denied Bost’s motion to dismiss. It reasoned that his conviction for terroristic threats sufficed to show he could not be trusted with a firearm and rejected his facial challenge to the statute, finding he could not demonstrate that the law was unconstitutional in every application. Bost then entered a conditional guilty plea, preserving his right to appeal the Second Amendment claims.The United States Court of Appeals for the Third Circuit, sitting en banc, reviewed the District Court’s denial de novo. The Third Circuit held that certain predicate crimes, such as Bost’s conviction for terroristic threats, establish a prima facie risk of physical violence from misuse of firearms and thus justify disarmament under § 922(g)(1). The court concluded that because Bost’s predicate crime involved a threat of physical violence, his disarmament was consistent with the historical tradition of firearm regulation. The court rejected his facial, vagueness, and Commerce Clause challenges, as well as his challenge to the stolen firearm statute. The Third Circuit affirmed the judgment of the District Court. View "USA v. Bost" on Justia Law