Justia Constitutional Law Opinion Summaries

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

Dylan Youngblood was arrested in Kalispell, Montana, in September 2023 on an outstanding felony warrant. During the arrest, officers found fentanyl pills on his person and located two pistols, drug paraphernalia, and suspected methamphetamine in his car. Youngblood admitted ownership of one pistol and to having used fentanyl earlier that day. He was indicted for possessing a firearm while being an unlawful user of, and addicted to, a controlled substance, in violation of 18 U.S.C. § 922(g)(3).In the United States District Court for the District of Montana, Youngblood moved to dismiss the indictment, arguing that § 922(g)(3) was unconstitutional both on its face and as applied to him. The district court denied the motion, applying the Second Amendment framework from New York State Rifle & Pistol Ass’n v. Bruen, and found that while Youngblood’s conduct fell within the Second Amendment’s text, the statute’s application to frequent users of methamphetamine and fentanyl was consistent with a historical tradition of temporarily disarming intoxicated individuals. The district court concluded that the statute was both facially and as-applied constitutional. Youngblood then entered a conditional guilty plea, preserving his right to appeal the denial of his motion.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that its prior decision in United States v. Stennerson, which upheld the facial constitutionality of § 922(g)(3), remained binding even after the Supreme Court’s decision in United States v. Hemani, which addressed only an as-applied challenge. The Ninth Circuit also found that Youngblood waived his as-applied challenge by failing to argue it specifically and distinctly in his opening brief. The court affirmed Youngblood’s conviction. View "USA V. YOUNGBLOOD" on Justia Law

Two children, whose parents divorced in Missouri, were involved in a custody dispute. After the parents agreed to a custody arrangement, the children refused to leave the courthouse with their mother. Judge Eric Eighmy intervened, escorting the children to a conference room and later to the juvenile division, where repeated threats of foster care failed to persuade them. Ultimately, Judge Eighmy ordered a juvenile officer to lock the children in holding cells for twenty to forty minutes, after which they agreed to leave with their mother.The children’s father brought suit in the United States District Court for the Western District of Missouri, alleging violations of their Fourth Amendment rights under 42 U.S.C. § 1983. Judge Eighmy’s claim for judicial immunity was denied both at the motion-to-dismiss and summary-judgment stages, and the Eighth Circuit previously affirmed that denial in Rockett ex rel. K.R. v. Eighmy, 71 F.4th 665 (8th Cir. 2023). After a trial, the jury found for the children, awarding $5,000 each in damages. The district court resubmitted the damages issue for clarification and ultimately upheld the jury’s award, also granting $326,637.22 in attorney fees.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo and affirmed the district court’s judgment. The court held that Judge Eighmy’s actions constituted an unreasonable seizure in violation of clearly established Fourth Amendment rights. The court also dismissed the appeal regarding judicial immunity, finding it unreviewable due to procedural forfeiture. The Eighth Circuit affirmed the damages and attorney fees awards, finding no abuse of discretion by the district court. The disposition was to dismiss the appeal in part and affirm the district court’s judgments. View "Rockett v. Eighmy" on Justia Law

The defendant, after serving a prison sentence for a Florida felony drug offense, was released into the state's conditional release program. Three days post-release, he signed a certificate agreeing to various conditions, including submission to searches by his release supervisor. Shortly before his conditional release was scheduled to end, he tested positive for cocaine. The supervisor recommended a warrant for his arrest, which was issued by the Florida Commission on Offender Review. When officers executed the warrant at his residence, the supervisor conducted a warrantless search, finding drugs and a firearm. This led to federal charges including possession of a firearm by a convicted felon and possession with intent to distribute a controlled substance.The United States District Court for the Southern District of Florida denied the defendant’s motion to suppress evidence from the warrantless search, concluding he was still on conditional release at the time and that reasonable suspicion justified the search. The defendant then pleaded guilty to the firearm possession charge. During sentencing, the presentence investigation report recommended a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), listing several prior Florida convictions as possible predicate offenses. The defendant objected, arguing both legally and factually that the convictions did not qualify and that the government had not proven their existence by a preponderance of the evidence.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of the motion to suppress, holding that the defendant was still subject to conditional release and that the search was supported by reasonable suspicion. However, the appellate court vacated the sentence, finding the district court erred by imposing the ACCA enhancement without requiring the government to prove the necessary predicate convictions. The case was remanded for resentencing without the ACCA enhancement. View "USA v. Louis" on Justia Law

A high school principal was terminated by his school district’s board after an internal investigation into allegations that he mistreated a female student over several years and attempted to dissuade staff from making a mandatory report of child abuse. The investigation included interviews with the student, a school counselor, the principal, and other witnesses. The board provided the principal with written notice of the allegations and an opportunity to respond, after which it held a multi-day hearing where both sides presented evidence and witnesses. The board found, by a preponderance of the evidence, that the principal had engaged in inappropriate conduct toward the student and interfered with mandatory reporting obligations, and concluded that there was just and sufficient cause for termination.The principal appealed the dismissal to the Windham Southeast School District Board and, following the board’s decision, filed suit in the Vermont Superior Court, Bennington Unit, Civil Division. He challenged the sufficiency of the evidence, argued that the pre-termination and post-termination processes violated his constitutional rights, and asserted claims of breach of contract, wrongful termination, denial of due process, intentional infliction of emotional distress, and defamation. The civil division dismissed some claims, granted summary judgment to the defendants on the remaining claims, and found that the board’s decision was supported by the record, that the principal was afforded adequate due process, and that no evidence supported claims of bias or other wrongdoing.The Vermont Supreme Court reviewed the case and affirmed the civil division’s decision. The Court held that the principal received constitutionally adequate pre- and post-termination process, that the trial court did not abuse its discretion in denying discovery related to alleged bias, and that sufficient evidence supported the board’s findings and conclusion that just cause existed for dismissal. The Court also found that structural or actual bias claims were either unpreserved or unsupported. View "Perrin v. Windham Southeast Supervisory Union" on Justia Law

A man was accused of raping his four-year-old granddaughter. After being interviewed by detectives, he confessed to the offense. Initially, he was charged by complaint in municipal court, and the matter was transferred to the Knox County Common Pleas Court. There, he waived his right to an indictment and pleaded guilty to a bill of information charging him with rape of a child under the age of ten, though the plea agreement and colloquy misstated the mandatory penalty for the offense. Under Ohio law, such a charge must be prosecuted by indictment, and the right to indictment cannot be waived.After the trial court accepted his guilty plea but before sentencing, the prosecution realized the error in the charging instrument and moved to dismiss the bill of information. The court granted the motion. The case was then presented to a grand jury, which returned an indictment for the same offense. The defendant pleaded not guilty and moved to dismiss the indictment, arguing that double jeopardy barred further prosecution. The trial court denied this motion, finding that jeopardy had not attached to the guilty plea to the unlawful bill of information. The defendant was found guilty in a bench trial, sentenced to 15 years to life, and his conviction was affirmed by the Fifth District Court of Appeals, which rejected his double-jeopardy argument.The Supreme Court of Ohio reviewed the case and held that jeopardy does not automatically attach when a trial court unconditionally accepts a guilty plea. Instead, whether the Double Jeopardy Clauses bar further proceedings depends on whether the defendant had a legitimate expectation of finality in the plea proceeding and whether concerns of prosecutorial overreach existed. Because the original charging instrument was not authorized by law, the defendant never acquired a legitimate expectation of finality, and double jeopardy protections did not apply. The court affirmed the judgment of the Fifth District Court of Appeals. View "State v. Thoen" on Justia Law

A student with severe cognitive disabilities attended a public high school in Hawai‘i and was repeatedly sexually abused by male students, resulting in significant psychological harm, including a psychotic breakdown and persistent post-traumatic stress disorder. The student’s mother, acting for herself and her daughter, sued the State of Hawai‘i, the Department of Education, and school employees for negligence, alleging failure to protect her daughter despite the school’s awareness of her vulnerabilities and repeated warning signs. The evidence at trial showed that school staff recognized the student’s extraordinary vulnerability and received multiple reports of abuse but failed to take reasonable steps to prevent or address it.The Circuit Court of the First Circuit conducted a lengthy bench trial and found the State liable for negligently failing to protect the student, awarding over $14 million in damages to the plaintiffs. However, without a request from the State, the court sua sponte reduced the damages by 30%, attributing that portion of fault to the male students who committed the abuse, citing Hawai‘i Revised Statutes § 663-10.5. The State had not argued at trial that the male students should be apportioned fault; instead, its arguments for apportionment focused on the mother’s alleged negligence, which the court rejected. Plaintiffs moved to amend the judgment to reverse the apportionment, but the court denied the motion.On appeal, the Supreme Court of the State of Hawai‘i held that the circuit court’s sua sponte allocation of fault to the male students violated the plaintiffs’ constitutional due process rights because they lacked notice and an opportunity to be heard on the issue. The court further found insufficient evidence that the male students were “other tortfeasors” under the statute and held that apportionment under HRS § 663-10.5 is an affirmative defense, for which the State bears the burden of pleading and proof. The Supreme Court vacated the apportionment, affirmed the remainder of the circuit court’s judgment, and remanded for entry of an amended judgment awarding plaintiffs the full damages. The State’s cross-appeal regarding discovery and damages was rejected. View "R.H. v. Hayashi" on Justia Law

A former Michigan Department of Corrections prisoner with asthma and an alleged allergy to dogs experienced allergic reactions while incarcerated at multiple facilities that housed dogs for training purposes. He reported symptoms such as asthma attacks and respiratory infections to prison officials, who provided prescribed treatments but did not confirm a specific dog allergy. After pursuing the prison’s grievance process, he was moved within the facility but still encountered dogs during required programming. Subsequently, he requested an ADA accommodation to be housed away from dogs, but this was denied due to lack of medical documentation. He later filed suit, alleging violations of the Eighth Amendment, the ADA, the Rehabilitation Act, and state laws.The United States District Court for the Western District of Michigan granted summary judgment in favor of the defendants. The court found that prison officials were not deliberately indifferent to his medical needs under the Eighth Amendment, as they consulted medical staff who did not recommend a transfer based on his condition. For the ADA and Rehabilitation Act claims, the court determined that inadequate medical treatment was not actionable under those statutes and that the plaintiff had not demonstrated denial of prison services or programs due to his disability. The court also declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the grant of summary judgment, holding that the prison counselor was entitled to qualified immunity because no clearly established law required the transfer of prisoners with asthma to facilities without dog programs. The court also found that the plaintiff failed to provide sufficient medical documentation to support the necessity of the requested accommodation under the ADA and Rehabilitation Act and did not establish discriminatory animus. The district court’s refusal to exercise supplemental jurisdiction over state-law claims was also affirmed. View "Miles-El v. Michigan" on Justia Law