Justia Constitutional Law Opinion Summaries

A dispute arose following the April 22, 2025 Democratic primary runoff election for mayor of the City of Canton, Mississippi. The contest centered on whether residents of recently annexed areas—Kingston Subdivision, Westside Trailer Park, and the Trails of Madison—were appropriately allowed to vote. Although these areas had been annexed and their inclusion in municipal elections was upheld in Peco Foods, Inc. v. City of Canton (In re Enlarging City of Canton), concerns were raised that updates to the Statewide Elections Management System (SEMS) were incomplete, potentially disenfranchising voters. On the day before the election, a petition sought to delay certification and allow regular ballots for residents of the affected areas. The Madison County Circuit Court instead permitted eligible voters from those areas to cast affidavit ballots.After the election, in which Tim Scott Taylor won by forty-three votes, Comelia Walker requested a ballot-box examination and subsequently filed several petitions for judicial review and election contest in the Circuit Court. Walker alleged that failures in SEMS updates, lack of notification, and various ballot irregularities materially affected the election’s integrity. The circuit court, after hearing evidence, found that Walker failed to prove any eligible voters had been denied the right to vote, nor could she demonstrate that irregularities affected the election outcome. The circuit court denied and dismissed Walker's petitions with prejudice.On appeal, the Supreme Court of Mississippi reviewed Walker’s claims of disenfranchisement, equal protection violations, and ballot irregularities. The Court concluded that affidavit voting did not disenfranchise voters, that no evidence supported equal protection violations, and that the alleged irregularities were either minor or unsupported by evidence. The Supreme Court of Mississippi affirmed the circuit court’s judgment, holding that no statutory departures occurred sufficient to destroy the election’s integrity or make the will of the voters impossible to ascertain. View "Walker v. Taylor" on Justia Law

The defendant entered the United States in 1999 and remained without legal status after his tourist visa expired in 2000. He applied for and received a Washington concealed pistol license in 2019, falsely claiming to be a U.S. citizen. He also submitted Bureau of Alcohol, Tobacco, Firearms, and Explosives forms indicating citizenship to register handguns. A series of domestic violence incidents led to multiple restraining orders against him, each including a prohibition on owning or possessing firearms. Law enforcement seized firearms, ammunition, and a silencer from his residence in 2022. The defendant admitted to being a Brazilian citizen and acknowledged that he was not permitted to possess firearms due to his immigration status and domestic violence convictions.The United States District Court for the Western District of Washington denied the defendant’s motions to dismiss charges on Second Amendment, materiality, and vagueness grounds. The defendant was convicted in a bench trial based on stipulated facts for unlawful possession of firearms and ammunition as a noncitizen and as a person under a domestic violence restraining order, making false statements during firearm purchases, falsely claiming U.S. citizenship, and unlawful possession of a firearm silencer.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed all convictions. The court held that precedent from United States v. Vazquez-Ramirez controlled challenges to 18 U.S.C. § 922(g)(5)(A), confirming the constitutionality of prohibiting firearm possession by noncitizens unlawfully present. Materiality challenges to false statement convictions failed because the Second Amendment does not protect firearm possession by such individuals. The court found that United States v. Rahimi and United States v. VanDyke foreclosed challenges to convictions based on domestic violence restraining orders. The court held that the National Firearms Act’s silencer regulations do not violate the Second Amendment or the Fifth Amendment’s vagueness doctrine. The panel affirmed the district court’s judgment. View "USA V. DEBORBA" on Justia Law

The case involves an individual who, following advice from his accountant, opened and maintained several foreign bank accounts in Switzerland and Panama between 2006 and 2012. He did not timely file the required Reports of Foreign Bank and Financial Accounts (FBARs) disclosing these accounts to the United States government. The accounts were significant in value and were sometimes held under an alias. The individual self-prepared his tax returns during this period, and while he reported domestic investment income, he did not disclose his foreign accounts. In 2014, after learning of the FBAR requirements, he entered an IRS voluntary disclosure program, filed untimely FBARs, and attempted to resolve his liabilities with the IRS through a settlement, which was ultimately not honored by the IRS.The United States initiated a civil suit in the United States District Court for the Northern District of Georgia to collect penalties for the willful failure to file timely FBARs. The individual moved for summary judgment, asserting affirmative defenses of accord and satisfaction and equitable estoppel, based on his attempted settlement with the IRS. The United States also moved for summary judgment, seeking a finding of willfulness as a matter of law. The district court granted summary judgment to the United States, finding the failure to file was willful, rejecting the affirmative defenses, and holding that the Eighth Amendment's Excessive Fines Clause did not apply to FBAR penalties.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the district court’s rulings on willfulness and rejection of the affirmative defenses, holding that the failure to file FBARs was willful under an objective standard and that the IRS agents lacked authority to bind the government to a settlement. However, the Eleventh Circuit reversed the district court’s determination regarding the Excessive Fines Clause, holding that FBAR penalties are subject to the Eighth Amendment and remanding for factual development on whether the penalties were unconstitutionally excessive. View "USA v. Niksich" on Justia Law

While incarcerated at Sussex 1 State Prison in Virginia, the plaintiff was accused of indecent exposure in July 2017. He consistently denied the charge and urged prison officials to review video footage from a RapidEye camera, which he claimed would show he was elsewhere when the incident occurred. The officials did not review the footage, stating it was of poor quality and not helpful, and ultimately found the plaintiff guilty after a delayed hearing. As a result of this conviction, and considering his prior offenses, the plaintiff’s security classification was increased and he was transferred to a higher-security facility. He requested that the video footage be preserved, but the prison officials failed to do so.The plaintiff filed suit, alleging procedural due process and First Amendment retaliation claims. The United States District Court for the Eastern District of Virginia initially dismissed the due process claim and granted summary judgment on the retaliation claim. On appeal, the United States Court of Appeals for the Fourth Circuit reversed, noting the importance of the missing video evidence to the plaintiff’s case and remanded for further proceedings. During discovery on remand, it became clear that the video footage had not been preserved, leading the plaintiff to move for spoliation sanctions. The magistrate judge began considering the sanctions motion, but the district court granted summary judgment to the defendants on all claims before ruling on the sanctions issue.The United States Court of Appeals for the Fourth Circuit held that the district court abused its discretion by granting summary judgment before addressing the plaintiff’s motion for sanctions related to the missing video footage. Because the footage was central to the claims, the appellate court vacated the district court’s decision and remanded with instructions to fully consider the sanctions motion. View "Shaw v. Foreman" on Justia Law

A nonprofit religious corporation, incorporated under Missouri law, sought to restore its governance authority over a university in Texas that was established as an agency of the church. The university, although separately incorporated, was subject to church governance under its charter and bylaws. In 2022, the university’s regents unilaterally amended their governing documents to reject the church’s authority. The church’s internal adjudicatory body declared these amendments void, and the church’s convention directed action to restore church control. The university refused to recognize church-appointed regents as its governing body.Litigation ensued in the United States District Court for the Western District of Texas. The church, through its corporate body, sued the university and its leaders in federal court, asserting diversity jurisdiction. The university counter-sued in Texas state court, naming the church as an unincorporated association. The federal actions were consolidated. The district court, adopting a magistrate judge’s report, held that the church was an unincorporated association and the real party in interest, and that joining the church as a plaintiff destroyed diversity jurisdiction because its members included Texas citizens. The court dismissed the federal suit and remanded the state suit to state court.The United States Court of Appeals for the Fifth Circuit reversed the district court’s dismissal. The appellate court held that the district court’s approach violated the church autonomy doctrine under the First Amendment by imposing secular interpretations on the church’s governance structure and disregarding the church’s own description of its internal polity. The court found that the nonprofit corporation is the appropriate party for civil litigation and that diversity jurisdiction exists. The case was remanded for further proceedings. View "Lutheran Church v. Christian" on Justia Law

A minor child, S.M., through a conservator, alleged abuse at a residential facility operated by Meadowlark Academy, asserting several tort claims against Meadowlark and two individuals. Meadowlark responded by filing counterclaims, including breach of contract, based on an alleged pre-litigation settlement agreement. S.M. (at that time, not yet represented by a conservator) failed to timely answer the counterclaims. There was a substantial delay before a conservator, Mr. Moran, was formally appointed and filed an amended complaint. Meadowlark then sought and obtained entry of default against Moran for failing to answer the counterclaims. Moran eventually answered, but only after default had been entered and a motion for default judgment was pending.The District Court of Laramie County denied Meadowlark’s initial motion to dismiss, finding that S.M. had standing despite procedural irregularities regarding the appointment of a conservator, and that there was no enforceable settlement agreement. After Meadowlark asserted counterclaims, the court entered default when those claims were not answered. Moran filed a late answer and opposed default judgment but did not specifically move to set aside the default under the relevant procedural rules or provide supporting legal authority. The district court granted default judgment to Meadowlark and, by implication, denied Moran’s oral motion to set aside the default.On appeal, the Supreme Court of the State of Wyoming affirmed the district court’s order. The Supreme Court held that Moran failed to establish good cause to set aside the entry of default under Wyoming Rules of Civil Procedure 55(c) and 60(b), as he did not articulate a valid legal justification or provide supporting argument and authority. The court also held that Moran’s due process rights were not violated, as he had notice and an opportunity to be heard through his counsel. The judgment was affirmed. View "Moran v. Meadowlark Academy Inc." on Justia Law

The case concerned a Black defendant who was convicted of second-degree felony murder. During jury selection, the prosecution used a peremptory challenge to exclude juror 40, who was white and had selected “prefer not to answer” regarding gender on a questionnaire. This juror had expressed strong concerns about racial bias in law enforcement and the criminal justice system. Defense counsel objected to the State’s peremptory strike by citing General Rule 37 (GR 37), but specifically raised only an argument about gender identity discrimination, not race or ethnicity.At trial, the King County Superior Court allowed the State’s challenge, finding that juror 40’s political views and demeanor, not their (presumed) gender identity, were valid grounds for exclusion. On appeal, the Washington Court of Appeals affirmed the conviction, holding that defense counsel’s objection based on gender identity did not preserve a GR 37 claim related to race, and thus the trial court did not err.The Supreme Court of the State of Washington reviewed the case. It clarified that an objection to a peremptory strike under GR 37 can be preserved by simply invoking the rule, but in this instance, defense counsel undermined the objection by focusing solely on gender identity. However, the Supreme Court exercised its discretion to review the race discrimination claim, emphasizing the importance of addressing racial bias even if not properly preserved below.The Supreme Court held that the State failed to comply with GR 37(i) procedures by relying on uncorroborated demeanor-based justifications for its peremptory challenge, which could not be considered. While the State’s use of juror 40’s views on law enforcement as a justification was presumptively invalid under GR 37(h), the totality of circumstances rebutted this presumption. The court concluded that an objective observer could not view race as a factor in the State’s strike and affirmed the lower court’s decision. View "State v. Hogan" on Justia Law

This case involved two major cellular service providers that were investigated by the Federal Communications Commission (FCC) for allegedly mishandling customer location data, potentially violating laws and regulations concerning confidentiality. Following reports of security breaches, the FCC issued notices of apparent liability to the companies and, after reviewing their responses, assessed monetary penalties—about $57 million against one provider and $47 million against the other. The companies paid these penalties but challenged the process, contending that their Seventh Amendment right to a jury trial was violated because the FCC imposed penalties through an administrative process without the involvement of a jury.One of the companies sought review in the United States Court of Appeals for the Fifth Circuit, which ruled in its favor, holding that the FCC’s process violated the Seventh Amendment since the agency found facts, interpreted the law, and assessed penalties without a jury. The other provider’s case was heard by the United States Court of Appeals for the Second Circuit, which upheld the FCC’s process. The Second Circuit reasoned that the FCC’s forfeiture order did not, by itself, compel payment, and any actual collection would require the Department of Justice to file a civil suit, at which point a jury trial would be available.The Supreme Court of the United States reviewed both cases to resolve the conflict. The Court held that the FCC’s procedures did not violate the Seventh Amendment because the forfeiture orders did not create a binding obligation to pay, nor were the FCC’s factual findings conclusive. Instead, a party could insist on a jury trial in a de novo civil enforcement action brought by the government to collect the penalty. The judgment of the Fifth Circuit was reversed and remanded, while the judgment of the Second Circuit was affirmed. View "FCC v. AT&T" on Justia Law

The defendant was indicted for aggravated sexual assault of a child. During the trial, an associate judge presided over the voir dire proceedings, including ruling on two Batson challenges raised by the defendant and denying his request to supplement the record with exhibits related to those challenges. The elected district judge later addressed the defendant's request to supplement the record, handled the excusal of a problematic juror, and presided over the remainder of the trial, ultimately pronouncing the sentence. The jury convicted the defendant of the lesser-included offense of indecency with a child by sexual contact and assessed a five-year prison sentence.Following the conviction, the defendant appealed to the First Court of Appeals in Houston, arguing that his conviction was void because an associate judge presided over voir dire. The appellate court rejected this contention, affirming both the conviction and sentence. The defendant then petitioned the Texas Court of Criminal Appeals for discretionary review, raising a facial constitutional challenge to certain provisions of the Texas Government Code that authorize associate judges to conduct voir dire in felony cases.The Texas Court of Criminal Appeals reviewed whether the defendant had preserved his constitutional challenge for appellate review. The court held that, because the defendant did not object at trial to the associate judge presiding over voir dire or to the relevant statutes, he failed to preserve his complaint. The court also found that the defendant’s claim did not fit within any recognized exceptions for void judgments. As a result, the court affirmed the judgment of the First Court of Appeals, holding that facial constitutional challenges to statutes must be preserved at trial before they can be raised on appeal. View "BAPTISTE v. State" on Justia Law

In this matter, Alabama enacted a congressional district map in 2023 that included only one district in which Black voters constituted a majority. Plaintiffs challenged the map, arguing that it diluted Black voting strength in violation of Section 2 of the Voting Rights Act and the Fourteenth Amendment. The essential factual dispute centered on whether Alabama’s map failed to provide an additional district offering Black voters an opportunity to elect their preferred candidates, and whether the State had intentionally avoided implementing a remedial map previously ordered by the court.The United States District Court for the Northern District of Alabama first enjoined the use of Alabama’s 2023 congressional map, finding it violated Section 2 because it did not include an additional Black-opportunity district and concluding that the State’s actions also violated the Fourteenth Amendment as a deliberate refusal to comply with prior remedial requirements. After the Supreme Court vacated this injunction in light of its decision in Louisiana v. Callais, the District Court issued a new injunction on similar grounds. State officials then applied to the Supreme Court for a stay of the District Court’s order.The Supreme Court of the United States granted Alabama’s application for a stay, holding that the State is likely to succeed on the merits. The Court concluded that the District Court failed to apply the updated standards for Section 2 liability announced in Callais, particularly the requirement that a plaintiff’s alternative map must perform “just as well” with respect to all constitutionally permissible districting criteria, and erred in its evaluation of alleged discriminatory intent. The Supreme Court stayed the District Court’s order pending further proceedings, emphasizing the importance of not altering election rules close to an election. View "Allen v. Milligan" on Justia Law