Justia Constitutional Law Opinion Summaries

Police officers observed an individual walking past their cruiser and believed, based on the shape protruding from his waistband, that he was carrying a handgun. The individual entered a carry-out restaurant, and when he exited, the officers followed him, repeatedly calling out to get his attention. The individual did not respond and eventually fled, at which point the officers chased and tackled him, recovering a handgun from his person. The officers had no prior information about him, were not responding to a reported crime, and did not know if he had a permit or license to carry the firearm.The Superior Court of the District of Columbia denied the individual’s motion to suppress the evidence obtained from the stop, concluding that there was reasonable, articulable suspicion for the officers to believe he was engaged in criminal activity. The court credited the officer’s testimony that he recognized the outline of a firearm and relied on the individual’s flight as suggestive of consciousness of guilt. Following trial, the individual was convicted of multiple weapon offenses.The District of Columbia Court of Appeals reviewed the case and analyzed whether the stop was supported by reasonable, articulable suspicion as required by the Fourth Amendment. The court concluded that, in light of recent constitutional and statutory changes—including Supreme Court decisions affirming a right to carry firearms—the mere possession of a handgun does not, without additional evidence, provide reasonable suspicion for a stop. The court also determined that the circumstances surrounding the individual’s flight reduced its value as an indicator of criminal wrongdoing. The court therefore held that the officers lacked reasonable, articulable suspicion to justify the stop, vacated the convictions, and remanded the case for further proceedings. View "Quarles v. United States" on Justia Law

Two commercial fishermen and their family business challenged federal regulations that reduced catch limits for gag grouper in the Gulf of Mexico, a fish central to their livelihood. The fishermen argued that the Gulf of Mexico Fishery Management Council, which played a key role in proposing the catch limits and regulatory framework, was unconstitutionally composed and shielded from removal, violating the Appointments Clause and other constitutional provisions. Their complaint alleged significant financial harm resulting from the reduced catch limits.The United States District Court for the Southern District of Alabama found that certain powers granted to the Council—specifically, three statutory “veto” provisions that allow the Council to block actions by the Secretary of Commerce—rendered Councilmembers “officers” wielding significant federal authority. It determined their appointments violated the Appointments Clause because they were not properly appointed as principal officers. However, instead of vacating the catch limit rule, the district court severed the unconstitutional veto provisions from the governing statute and entered judgment for the plaintiffs.On appeal, the United States Court of Appeals for the Eleventh Circuit largely agreed that the Council’s veto powers confer significant authority, so Councilmembers’ appointments as currently structured are constitutionally deficient. However, the Eleventh Circuit held that the remedy should be limited to invalidating actions taken with those veto powers. Because the gag grouper rule was not promulgated using the Council’s unconstitutional veto authority but rather through an advisory process ratified by the Secretary, the rule itself was not tainted. The court vacated the district court’s judgment for the plaintiffs and remanded for entry of judgment in favor of the government, concluding that vacatur of the challenged rule was unwarranted. View "Russo v. Secretary, U.S. Department of Commerce" on Justia Law

A man convicted of aggravated sexual battery of a 10-year-old was given a 20-year sentence, with a portion suspended on the condition that he comply with probation requirements. Among the special conditions for sex offenders were restrictions on internet use: he was prohibited from using social networking sites or internet services without prior approval from his probation officer, and, if granted permission, he was required to install monitoring software and list his probation officer as an accountability partner. After release, he repeatedly violated probation by, among other things, using the internet and Facebook without permission, failing to register his accounts as required by law, using illegal drugs, and failing to comply with GPS monitoring and substance-abuse treatment. His suspended sentence was twice revoked and resuspended after these violations.After the second revocation, the man appealed to the Court of Appeals of Virginia, arguing for the first time that the internet restrictions unconstitutionally infringed his First Amendment rights. The Court of Appeals agreed, holding that the restrictions amounted to a total or near-total ban on internet use that was not narrowly tailored to serve rehabilitation or public safety purposes. The court relied heavily on Packingham v. North Carolina, a U.S. Supreme Court case involving a statute barring all social media use by sex offenders who had completed their sentences.The Supreme Court of Virginia reviewed the case and held that Packingham does not control where internet restrictions are imposed as a condition of probation for someone still serving a suspended sentence. The court found that the conditions were conditional, not absolute bans, and allowed internet use with probation officer approval and monitoring. The court concluded that such conditions are permissible under the First Amendment when judiciously crafted to aid rehabilitation and protect the public. The Supreme Court of Virginia reversed the Court of Appeals’ decision and reinstated the trial court’s judgment. View "Commonwealth v. Kuykendall" on Justia Law

Federal agents began investigating the defendant in early 2021 after receiving information that he was operating a firearms manufacturing and dealing business from his home without the required federal license. Undercover agents arranged the purchase of a semi-automatic firearm and a high-capacity magazine from him, during which he described the magazine as “highly illegal.” Following a year-long investigation, law enforcement executed a search warrant and recovered two unregistered short-barreled rifles and an unregistered suppressor from his residence.A grand jury indicted the defendant on two counts: dealing and manufacturing firearms without a license under federal law, and possession of unregistered National Firearms Act (NFA) firearms (the rifles and suppressor). He moved to dismiss both counts, alleging the NFA violated his Second Amendment rights. The United States District Court for the District of Connecticut denied his motion, holding that the Second Amendment did not cover possession of unregistered rifles and suppressors. The defendant then entered a conditional guilty plea to the NFA count, preserving his right to appeal the denial and his sentence. He was sentenced to twelve months and one day in prison.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the defendant lacked standing to challenge the NFA as amended after his offense because the amendment was not retroactive. The court applied the Bruen framework, assumed without deciding that short-barreled rifles and suppressors are “arms,” but concluded the NFA’s registration and taxation requirements did not meaningfully constrain the defendant’s Second Amendment rights. The court also found no procedural or substantive error in the district court’s sentencing determination. The Second Circuit affirmed the judgment of the district court. View "United States v. DeFelice" on Justia Law

The petitioner was convicted of murder and conspiracy to commit murder in connection with the shooting death of a woman who was pregnant with his child. After unsuccessfully convincing the victim to have an abortion, he conspired with a close friend to kill her. The friend ultimately fired the fatal shot. Weeks later, the friend confessed to a mutual acquaintance, who later served as a key prosecution witness. That witness also participated in a subsequent robbery with the friend, using the same firearm as in the murder. Information from the robbery investigation helped implicate both the friend and the petitioner in the murder. At trial, the witness testified that he had not been promised any deals or consideration for his testimony, although he later alluded to unspecified “considerations.” His defense attorney also testified, indicating there would be some consideration for truthful testimony but denying any formal agreement.The habeas court, Superior Court in the judicial district of Tolland, denied the petitioner’s request for a writ of habeas corpus. The court found that the witness’s testimony about the scope of any agreement was truthful and that the jury had been made aware that something would be done in exchange for his testimony. It further concluded that any ambiguity was clarified by testimony from the witness’s defense attorney, who explained that consideration would be given but no specific deal existed.The Supreme Court of Connecticut reviewed the case and held that the prosecutor violated Napue v. Illinois by eliciting false or substantially misleading testimony regarding the existence and nature of an agreement with the witness, failing to correct those misimpressions, and relying on the misleading testimony in closing argument. The court found these violations were material, as there was a reasonable likelihood they affected the jury’s verdict. The judgment of the habeas court was reversed, and the case remanded with instructions to grant the habeas petition, vacate the conviction, and order a new trial. View "Bryan v. Commissioner of Correction" on Justia Law

Six nonbinary individuals born in Puerto Rico sought to amend their birth certificates to reflect a nonbinary gender marker ("X"), arguing that the existing Application for Gender Change, which only allowed selection of "male" or "female," discriminated against them. Their request followed an earlier federal court decision (Arroyo González v. Rossello Nevares) that required Puerto Rico to allow transgender binary individuals to amend their birth certificates, but did not address nonbinary persons. After their request was denied by the Director of the Demographic Registry, the plaintiffs filed suit, alleging violations of their constitutional rights under the Equal Protection and Due Process Clauses of the Fourteenth Amendment and the First Amendment.The United States District Court for the District of Puerto Rico reviewed cross-motions for summary judgment. The district court granted summary judgment to the plaintiffs on their Equal Protection claim, finding that Puerto Rico’s Birth Certificate Policy created a facial classification between binary and nonbinary individuals. The court applied rational basis review and concluded that Puerto Rico’s stated interests—including separation of powers and maintaining the integrity of public records—did not justify the exclusion of a nonbinary option. It found no rational basis for the policy and inferred animosity towards nonbinary persons, ordering Puerto Rico to amend its Application for Gender Change to include an "X" gender marker.The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment order de novo. The appellate court concluded that Puerto Rico's Birth Certificate Policy is supported by a rational basis, specifically Puerto Rico’s legitimate interest in protecting privacy rights. Because the plaintiffs did not demonstrate that the policy infringes on their privacy rights or that privacy rights are not furthered by the policy, the court found a rational relationship between the challenged classification and the government’s legitimate goals. The First Circuit vacated the district court’s order and remanded for further proceedings. View "de la Fuente Diaz v. Gonzalez Colon" on Justia Law

A pickup truck driven by Lilly Laroque collided head-on with another vehicle on a Montana highway, resulting in serious injuries to Laroque and the death of the other driver, Delaney Doherty. At the crash scene, law enforcement found marijuana-related items in Laroque’s vehicle, and evidence suggested Laroque had been texting and using marijuana while driving shortly before the crash. While hospitalized after the accident, Sergeant Stoner of the Montana Highway Patrol requested a blood sample from Laroque to test for intoxicants, reading her the Montana Implied Consent Advisory. Laroque did not respond verbally to repeated requests for consent, and the officer directed medical staff to draw her blood, which later tested above the legal limit for THC.The Eighteenth Judicial District Court of Montana reviewed Laroque's motion to suppress the blood sample and toxicology report, considering arguments that the warrantless blood draw violated her constitutional protections against unreasonable searches and seizures. The State argued that Montana’s Implied Consent statute authorized the blood draw, relying on precedent from City of Great Falls v. Allderdice. The District Court found Laroque did not exhibit understanding or consent required by the Implied Consent Advisory, distinguishing her case from Allderdice. The court suppressed the evidence, finding no exception to the warrant requirement applied and declined to apply the good faith exception. The State appealed this suppression order.The Supreme Court of the State of Montana reviewed whether the District Court’s finding that Laroque did not consent was clearly erroneous. Applying the clear error standard, the Supreme Court found substantial evidence supported the District Court’s conclusion that Laroque did not consent to the warrantless blood draw. The Supreme Court affirmed the suppression of the blood sample and toxicology report, holding the District Court’s factual findings were not clearly erroneous and declining to address the State’s good faith doctrine argument, as it was not raised below. View "State v. Laroque" on Justia Law

A physician brought a lawsuit on behalf of the United States under the False Claims Act (FCA), alleging that her employer and associated healthcare entities knowingly submitted false diagnosis codes to Medicare in order to obtain inflated payments. The case proceeded for several years. In February 2024, the defendants sought judgment on the pleadings or dismissal, arguing that the FCA’s qui tam provisions—which allow private individuals (relators) to sue on behalf of the government—violated the Constitution’s Appointments Clause, Take Care Clause, and Vesting Clause.The United States District Court for the Middle District of Florida granted the defendants’ motion, concluding that the qui tam provisions violated the Appointments Clause. The district court reasoned that relators are “officers of the United States” because they exercise significant federal authority and occupy a continuing position established by law, but are not appointed by the President as required by Article II. The court dismissed the case, finding the relator lacked authority to proceed on behalf of the United States, and did not address the other constitutional arguments.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s constitutional analysis de novo. The Eleventh Circuit disagreed with the lower court’s conclusion, holding that relators under the FCA are not officers of the United States because they do not occupy a continuing position established by law. The court explained that relators’ roles are temporary, personal, and lack a continuing emolument or transferable duties. Therefore, the FCA’s qui tam provisions do not violate the Appointments Clause. The Eleventh Circuit vacated the district court’s dismissal and remanded the case for consideration of the remaining constitutional arguments. View "Zafirov v. Florida Medical Associates, LLC" on Justia Law

Sidney Campbell was convicted by a jury of second degree murder in 2003 after he and his brother shot and killed a 15-year-old boy following a confrontation related to a damaged bicycle rim. Witnesses testified that Campbell was one of the shooters, and the jury found he personally used and discharged a firearm during the offense. The jury was not instructed on felony murder or the natural and probable consequences doctrine, but was instructed on implied malice.Following his conviction, Campbell was sentenced to 35 years to life. The California Court of Appeal previously affirmed his conviction. In 2022, Campbell filed a petition for resentencing under Penal Code section 1172.6, arguing that recent statutory amendments and relevant case law might render him eligible for relief because his conviction could have rested on an imputed malice theory, particularly given ambiguities in the aiding and abetting instructions. The Los Angeles County Superior Court summarily denied the petition at the prima facie stage, finding Campbell ineligible for resentencing as a matter of law.The California Court of Appeal, Second Appellate District, Division Six, reviewed the trial court’s denial after the California Supreme Court directed reconsideration in light of People v. Lopez (2026) 19 Cal.5th 639, which clarified that the ability to raise instructional error on direct appeal does not categorically bar relief under section 1172.6. The appellate court independently reviewed the record and concluded that the jury instructions did not allow for conviction based on imputed malice and that it was not reasonably likely the jury relied on such a theory. Therefore, Campbell was found ineligible for resentencing as a matter of law. The order denying Campbell’s section 1172.6 petition was affirmed. View "People v. Campbell" on Justia Law

Federal agents intercepted a package containing three silencers shipped from China to Joseph Berger’s residence in Bethlehem, Pennsylvania. Upon searching the home with a warrant, agents discovered more than sixty firearms, including thirteen fully automatic guns (mostly AK-47 variants), a dozen silencers, and parts for converting semi-automatic weapons into machine guns. Berger was indicted for possession of machine guns and unregistered silencers, violations of federal law. He is a Navy veteran who lived with his father, and evidence suggested both were involved in acquiring conversion parts.In the U.S. District Court for the Eastern District of Pennsylvania, Berger raised an as-applied Second Amendment challenge. The court denied his challenge, finding that machine guns were “dangerous and unusual weapons” not commonly used for self-defense, and that silencers were not “bearable arms” under the Second Amendment. Berger then pleaded guilty to possessing a machine gun and an unregistered silencer, reserving his right to appeal the Second Amendment issue. The government dismissed the charge of possessing an unregistered machine gun as part of the plea agreement.The United States Court of Appeals for the Third Circuit reviewed Berger’s appeal de novo, focusing on pure issues of law. The court held that the Second Amendment does not protect possession of machine guns because they are not commonly used for lawful purposes and are classified as “dangerous and unusual.” Furthermore, the registration requirement for silencers under the National Firearms Act imposes only a minimal, objective burden and does not infringe upon Second Amendment rights. The court affirmed Berger’s conviction and sentence, holding that both the machine-gun ban and the silencer registration requirement are constitutional as applied to Berger. View "USA v. Berger" on Justia Law