Justia Constitutional Law Opinion Summaries

A group of local United Methodist churches, through their trustees, sought to disaffiliate from the United Methodist Church while retaining ownership of their church property. This dispute arose amid a broader doctrinal disagreement within the denomination, particularly regarding the ordination of homosexual clergy and performance of same-sex weddings. The Conference, representing the denomination’s regional authority, asserted that church property was held in trust for the benefit of the entire denomination and could not be retained by a local church upon disaffiliation except as authorized by church law. The local churches alleged that the Conference engaged in fraudulent and collusive conduct, including misrepresentations about the procedures and timing for lawful disaffiliation, which caused them to miss the window for disaffiliation with property under denominational rules.The Circuit Court of Mercer County initially dismissed the complaint, holding that it lacked subject matter jurisdiction under the ecclesiastical abstention doctrine since the dispute required interpretation of church doctrine and governance—a matter reserved for the church’s highest tribunals. The court found that the allegations of fraud and collusion did not pertain to the procurement of a final ecclesiastical adjudication. However, following a Rule 59(e) motion by the local churches, a different judge vacated the prior dismissal, determining that the allegations of fraud and collusion raised factual questions for a jury and reopened the case.The Supreme Court of Appeals of West Virginia reviewed the matter on a petition for a writ of prohibition. The court held that constitutional limitations under the First Amendment and the West Virginia Constitution prevented civil courts from adjudicating disputes involving church doctrine, discipline, or governance. The court further clarified that the fraud or collusion exception only applies if such conduct procured a final ecclesiastical adjudication, which was not alleged here. The writ of prohibition was granted, barring enforcement of the order reopening the case, and reaffirming the circuit court’s lack of jurisdiction. View "State ex rel. Trustees of the West Virginia Conference of the United Methodist Church v. Wills" on Justia Law

A man and a female companion were suspected of shoplifting at a Walmart in White Hall, West Virginia. After the store employee alerted law enforcement, officers stopped and searched the vehicle the pair had used. The man, sitting in the passenger seat, was arrested, and officers found a black fanny pack under his seat, which contained a loaded firearm, baggies of white powder suspected to be cocaine, and pills believed to be oxycontin. He was indicted on six counts, including possession with intent to deliver cocaine and fentanyl, use or presentation of a firearm during the commission of a felony, possession of a firearm by a prohibited person, and prohibited person carrying a concealed firearm.The Circuit Court of Marion County presided over a one-day jury trial, after which the jury found the man guilty of five counts and not guilty of conspiracy. He filed a post-trial motion for judgment of acquittal or, alternatively, a new trial, arguing that the evidence was insufficient for the firearm charge and that his Sixth Amendment right to confront the forensic analyst was violated when the analyst who performed drug testing was not called to testify. The circuit court denied the motion, ruling that the sufficiency of evidence was a question for the jury and that the testimony of a substitute expert satisfied the confrontation requirement.The Supreme Court of Appeals of West Virginia reviewed the case and applied a de novo standard to the sufficiency and confrontation issues. The court held that the evidence was insufficient to sustain a conviction for use or presentation of a firearm during a felony because there was no proof the defendant actively employed the firearm. The court further held that admitting the forensic laboratory report through a surrogate expert violated the Confrontation Clause. Accordingly, the court reversed the firearm conviction, vacated the drug convictions, and remanded for a new trial on the drug charges. View "State v. Crawford" on Justia Law

Three former employees of the Senate of the Commonwealth of Puerto Rico alleged they were terminated from their positions—Protocol Officer and Liaison Technician—because of their political affiliations, in violation of their First Amendment rights. The suit was brought against Senate officials in their personal capacities under 42 U.S.C. § 1983, seeking damages for alleged unconstitutional patronage dismissals.The U.S. District Court for the District of Puerto Rico initially heard the case, which involved numerous plaintiffs and claims, including due process, equal protection, and Puerto Rico law claims. Many claims were dismissed at earlier procedural stages. The claims relevant to this appeal survived summary judgment and concerned only the First Amendment-based damages actions brought by the three former employees. The District Court denied the defendants’ motion for summary judgment, which was based on qualified immunity, finding there were genuine disputes of material fact regarding the plaintiffs’ job duties and whether defendants had considered the nature of those duties before termination.The United States Court of Appeals for the First Circuit reviewed the interlocutory appeal, which focused on the denial of qualified immunity. The First Circuit affirmed the District Court’s order. The appellate court held that the District Court erred in considering whether the officials had subjectively inquired into the plaintiffs’ job duties, as qualified immunity is an objective standard. However, the First Circuit found no error in the District Court’s other reasoning, ruling that unresolved factual disputes about the nature of the plaintiffs’ job responsibilities precluded summary judgment on qualified immunity. The court also determined that claims against the officials in their personal capacities were not discharged by the Commonwealth’s bankruptcy proceedings under PROMESA. Thus, the District Court’s denial of summary judgment was affirmed. View "Ortiz-Resto v. Rivera-Schatz" on Justia Law

The defendant was convicted in 2011 of first degree murder, multiple sexual offenses, and related crimes stemming from incidents in July 2008. A jury found him guilty and determined that he personally and intentionally discharged a firearm causing great bodily injury or death. Additional findings included three prior prison terms. He was originally sentenced to 78 years to life in prison. Following a change in the law eliminating one-year sentence enhancements for prior prison terms, the defendant petitioned for resentencing. The trial court resentenced him to 77 years to life, removing the prior prison term enhancements but retaining all other aspects of the sentence, including the gun enhancement.After the resentencing, the defendant argued that the trial court should have dismissed the gun enhancement under Penal Code section 1385(c), specifically referencing the Racial Justice Act (RJA). He contended that applying the enhancement would result in a discriminatory racial impact. In the Alameda County Superior Court, the trial judge found that dismissing the enhancement would endanger public safety and that none of the mitigating factors, including those based on racial bias, were established. The defendant’s evidence of racial bias was based on a statistical report and a claim of bias by the original sentencing judge, but the trial court found these claims insufficient under the RJA.On appeal, the California Court of Appeal, First Appellate District, Division Three, held that the defendant failed to present evidence meeting the RJA’s requirements. Specifically, he did not show that he received a longer sentence than similarly situated individuals of other races in the same county, nor did he provide comparator cases or adequate statistical evidence. The appellate court affirmed that to trigger section 1385(c)(2)(A), a defendant must satisfy the RJA’s standard, which the defendant did not. Accordingly, the judgment was affirmed. View "People v. Savoy" on Justia Law

The defendant was indicted in Floyd County, Georgia, and convicted by a jury of possession of less than one ounce of marijuana and possession of a firearm by a convicted felon. His firearm conviction was based on three prior non-violent felonies. Before trial, he filed a general demurrer, arguing that the statute prohibiting felons from possessing firearms was unconstitutional as applied to him because it imposed a permanent ban on non-violent offenders. He was sentenced to twelve months for the marijuana conviction and ten years for the firearm conviction, with four years to be served in prison.After briefs and a hearing, the Superior Court of Floyd County denied his demurrer, citing precedent upholding the constitutionality of the statute and reasoning that felons are presumptively excluded from firearm possession. The trial court reaffirmed this position when denying his motion for new trial.On appeal to the Supreme Court of Georgia, the defendant again argued that the statute, as applied to non-violent felons, violated the Second Amendment. However, the Attorney General, participating as amicus, raised a procedural issue: the defendant had not served the Attorney General with notice of his constitutional challenge, as required by OCGA § 9-4-7(c). The Supreme Court of Georgia determined that the notice requirement applies not only to civil actions but also to criminal prosecutions challenging the constitutionality of a statute. Because the defendant failed to serve the Attorney General, the trial court lacked subject-matter jurisdiction to decide the constitutional issue.The Supreme Court of Georgia vacated the portion of the trial court’s order addressing the constitutional challenge and remanded the case for compliance with the statutory notice requirement, without reaching the merits of the Second Amendment claim. View "TRAMMELL v. THE STATE" on Justia Law

In 2023, the Tennessee General Assembly enacted a statute imposing a cap of twenty voting members on metropolitan councils, affecting the Metropolitan Government of Nashville and Davidson County, which had a forty-member council. Metro Nashville and several individual plaintiffs challenged the statute, arguing it violated the Local Legislation Clause and the Exemption Clause of the Tennessee Constitution. They sought declaratory and injunctive relief to prevent implementation of the law.The Chancery Court for Davidson County, sitting as a three-judge panel, held that the cap violated both constitutional provisions and issued a permanent injunction against enforcement. The panel found some claims moot due to expired compliance deadlines but concluded that the main cap provision remained justiciable. The Court of Appeals reversed, holding that the cap did not violate either clause and that the claims were not moot, except as to certain implementation provisions.After granting permission to appeal, the Supreme Court of Tennessee reviewed the case. During the proceedings, the General Assembly amended the statute, removing the implementation provisions and the language linking the cap to those provisions. The Supreme Court determined that these amendments rendered the Local Legislation Clause claim moot, as the alleged defect no longer existed. The Court vacated the Court of Appeals’ judgment on this issue and instructed the trial court to dismiss the claim.The Court further held that the Exemption Clause claim remained justiciable but, on the merits, concluded that the Exemption Clause only exempts consolidated governments from constitutional requirements regarding legislative bodies, not from statutory requirements imposed by the legislature. Therefore, the twenty-member cap does not violate the Exemption Clause. The Supreme Court of Tennessee affirmed the Court of Appeals’ judgment on this issue and remanded the case for further proceedings consistent with its opinion. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law

A 2023 Tennessee law amended the structure and appointment process for the board of commissioners of the Metropolitan Nashville Airport Authority, reducing its board size and transferring most appointment powers to state officials. The changes applied only to the Nashville authority and not to any other airport authority in the state. The Metropolitan Government of Nashville and Davidson County filed suit, alleging that the new law violated specific provisions of the Tennessee Constitution, including the Local Legislation Clause and Anti-Ripper Clause.The Chancery Court for Davidson County, sitting as a three-judge panel, found that the law violated all three constitutional provisions alleged and enjoined its enforcement. The state defendants appealed and the Tennessee Court of Appeals affirmed the trial court in part, holding that the law violated the Local Legislation Clause, but reversed on the Law of the Land Clause. The Anti-Ripper Clause claim was not addressed by the appellate court. The state sought further review in the Supreme Court of Tennessee.While the case was pending before the Supreme Court of Tennessee, the General Assembly repealed and replaced the challenged provisions with new legislation that applied more broadly to multiple airport authorities. The Supreme Court of Tennessee held that these legislative changes rendered the case moot because the specific statutory provisions challenged were no longer in effect and could not reasonably be expected to recur. It found no basis to apply the voluntary cessation exception to mootness, as there was no evidence the legislature would reenact the specific challenged provisions. The Supreme Court vacated the lower courts’ judgments and remanded the case to the trial court with instructions to dismiss it as moot. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law

A man serving a life sentence for terrorism-related convictions at a federal prison in Colorado, who is severely disabled with both arms amputated above the elbow and vision loss in one eye, filed suit against several federal officials. He alleged violations of his federal constitutional and statutory rights stemming from his conditions of confinement and medical care while incarcerated. His claims included inadequate dental and medical care, denial of a medical diet, lack of proper prosthetics, and insufficient accommodation for his disabilities.The United States District Court for the District of Colorado dismissed most claims on the defendants’ motions to dismiss and for summary judgment. Some claims were dismissed as moot or for failure to exhaust administrative remedies, while others, including his Eighth Amendment deliberate indifference claim, were dismissed for failure to state a claim under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. The district court also found his Administrative Procedure Act (APA) claim challenging his placement at the prison was time-barred. The plaintiff voluntarily dismissed his remaining claims with prejudice and then appealed.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment. The appellate court held that the plaintiff could not pursue his Eighth Amendment deliberate indifference claim under the APA because he failed to allege a final agency action and sued individual officers rather than the agency or officials in their official capacities. The court also held that his Bivens claim for deliberate indifference arose in a new context and was foreclosed due to the existence of the Bureau of Prisons’ administrative remedies. The appellate court further found no abuse of discretion in denying leave to amend the complaint and ruled that the plaintiff had waived his challenge to deposition transcript fees by failing to object before the magistrate judge. View "Mostafa v. Blanche" on Justia Law

During a protest at San Jose City Hall, the plaintiff attended as a peaceful participant. At one point in the evening, after some protestors threw bottles and objects at the police, an officer equipped with a 40mm projectile impact weapon responded by firing into the crowd. The plaintiff, who did not throw anything or engage with the police, was struck behind the knee by a foam baton round and subsequently developed a pulmonary embolism as a result of his injury.After these events, the plaintiff filed suit in the United States District Court for the Northern District of California against the officer and the City of San Jose, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and California’s Bane Act, as well as common law claims. The case proceeded to trial, where the plaintiff argued that the officer fired indiscriminately into the crowd rather than targeting a specific threat. The jury found in favor of the plaintiff on all claims against the officer, awarding damages, and specifically found that the officer fired indiscriminately. The district court denied the officer’s post-verdict motion for judgment as a matter of law on the Fourth Amendment and Bane Act claims.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court concluded that the officer’s actions constituted a seizure and that the use of force was excessive, thus violating the plaintiff’s Fourth Amendment rights. However, the court held that the law was not clearly established for purposes of qualified immunity because prior precedent, particularly Nelson v. City of Davis, was materially distinguishable from the circumstances present here. As a result, the Ninth Circuit reversed the district court’s denial of qualified immunity on the Fourth Amendment claim, vacated the award of attorneys’ fees, and remanded for recalculation pending resolution of the state law claim, which was certified to the California Supreme Court. View "JOHNSON V. ADGAR" on Justia Law

In this case, Indiana enacted legislation in 2021 that imposed new requirements on public school teachers who wished to have union dues automatically deducted from their paychecks. These requirements included submitting a written authorization containing a specific statement regarding their First Amendment rights, annual renewal of the authorization, confirmation via official work email, and annual notice of their right to resign from the union. These procedures applied only to teachers and not to other public employees in Indiana.Previously, the United States District Court for the Southern District of Indiana reviewed the case after teachers’ unions and individual members challenged the law, arguing it violated their First Amendment rights to free speech and association. The district court initially found that the mandated statement on the authorization form constituted compelled speech and issued a preliminary injunction. After Indiana amended the statute in response, the district court concluded that the revised law no longer violated the Free Speech Clause, but still found that the additional requirements on teachers constituted viewpoint discrimination against their freedom of association. The court permanently enjoined enforcement of the provisions and the State appealed.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s judgment. The Seventh Circuit held that the authorization form’s required statement was government speech, not compelled private speech, and did not violate the Free Speech Clause. However, the court agreed with the district court that the additional requirements imposed only on teachers and their unions amounted to unconstitutional viewpoint discrimination under the First Amendment’s Freedom of Association protections. The court applied strict scrutiny and found Indiana’s justifications insufficient. As a result, the Seventh Circuit affirmed the district court’s judgment permanently enjoining enforcement of the challenged provisions. View "Anderson Federation of Teachers v. Rokita" on Justia Law