Justia Constitutional Law Opinion Summaries

A candidate for the Arkansas House of Representatives was challenged by his opponent, who argued that she was ineligible to run for office due to a prior disposition in a 2018 hot-check case. The challenger claimed that the opponent had been found guilty of violating the Arkansas Hot Check Law, which, under state constitutional and statutory provisions, would render her ineligible for election. The evidence included a district court docket showing a disposition labeled “GUILTY – BOND FORFEITURE,” as well as payment of fines, fees, and restitution related to the charge. The opponent did not contest the existence of the underlying case but denied that she had been convicted or found guilty.The case was first heard in the Pulaski County Circuit Court. After a hearing that included testimony from court and law enforcement personnel about the court’s procedures, and review of the district court records, the circuit court concluded that the bond forfeiture was not an admission of guilt. The court found that the opponent had neither entered a plea nor been found guilty by the court. The circuit court therefore held that she had not been convicted of an infamous crime or a public trust crime under Arkansas law, and denied the challenger’s petition for declaratory judgment and mandamus.On appeal, the Supreme Court of Arkansas reviewed the record and the circuit court’s findings under a clearly erroneous standard. The Supreme Court affirmed the lower court’s decision, holding that a bond forfeiture, without a plea or factual finding of guilt, does not constitute a conviction or render a candidate ineligible under Article 5, Section 9 of the Arkansas Constitution or the relevant statutes. The Supreme Court rejected the challenger’s remaining arguments and affirmed the circuit court’s judgment. View "DAY V. WARDLAW" on Justia Law

A police officer in Kalispell, Montana, conducted a traffic stop after observing traffic violations. While the officer was engaged with the driver, the defendant, Sean Doman, stopped on a nearby public sidewalk and began recording the police interaction with his phone. The officer, concerned for safety, called for backup. When the backup officer arrived, he repeatedly asked Doman to move further away from the scene, stating that filming was allowed but Doman’s proximity and engagement were distracting. Doman refused to comply with the officer’s orders to reposition, insisting on his right to film from his chosen spot. After several warnings, Doman was arrested for obstructing a peace officer.The case was first tried in the Kalispell Municipal Court, where a jury found Doman guilty of obstructing a peace officer under Montana law. At trial, the jury was instructed that citizens have a First Amendment right to film police, subject to reasonable time, place, and manner restrictions, but also that it is not a defense if the officer was acting illegally, as long as the officer acted under official authority. Doman did not raise constitutional objections to the statute during trial. On appeal to the Eleventh Judicial District Court, Doman challenged the constitutionality of the obstruction statute as applied to his conduct. The District Court affirmed the conviction, holding that Doman failed to preserve his constitutional arguments for appeal.The Supreme Court of the State of Montana reviewed the case de novo. It held that sufficient evidence supported the conviction because a rational juror could find that Doman knowingly impeded the officers’ duties by refusing to comply with reasonable orders during a traffic stop. The court declined to address Doman’s constitutional claims, finding them unpreserved and not warranting plain-error review. The Supreme Court affirmed Doman’s conviction. View "City of Kalispell v. Doman" on Justia Law

The case involves a defendant who, after being indicted on multiple charges related to mail fraud, theft from an employee benefit plan, and filing false tax returns, repeatedly chose to represent herself rather than accept legal counsel. The charges stemmed from her actions following her grandmother’s death: she continued to receive and conceal pension payments that should have stopped, and she prepared fraudulent tax filings for herself and others, keeping a portion of the illicit refunds.The United States District Court for the Northern District of Illinois, Eastern Division, presided over the trial. Throughout the proceedings, the district court made extensive efforts to inform the defendant of her constitutional right to counsel, the risks and disadvantages of self-representation, and the complexity of the charges. The court appointed standby counsel, but the defendant persisted in her wish to proceed without representation and consistently rejected the assistance of counsel, including private and standby counsel. Despite her refusal to participate actively in her trial—declining to make arguments, cross-examine witnesses, or present evidence—the jury convicted her on all counts.Upon appeal to the United States Court of Appeals for the Seventh Circuit, the defendant argued that the district court should have forced her to accept counsel and that her waiver of the right to counsel was not knowing or voluntary. The Seventh Circuit reviewed the record as a whole and determined that, despite the absence of a formal Faretta hearing, the totality of circumstances demonstrated that the defendant’s waiver was knowing, intelligent, and voluntary. The court carefully examined whether she understood her options and the consequences of self-representation. Concluding that the district court had not erred, the Seventh Circuit affirmed the judgment. The holding is that a defendant’s waiver of counsel is valid if the record as a whole shows the waiver was knowing and voluntary, even without a formal hearing. View "USA v Salley" on Justia Law

Eight residents of Boothbay and Boothbay Harbor challenged a school board’s refusal to put their petition for a new referendum before the voters. The underlying issue concerned a voter-approved bond to renovate local schools. After the bond passed, the residents submitted a petition containing two articles: one seeking to reconsider and repeal the prior vote, and another proposing a new, smaller bond for a different renovation project if the repeal succeeded. The school board rejected the petition, reasoning that it did not present a proper reconsideration question as required by statute and that the second article was unrelated to reconsidering the original referendum.The residents sought judicial review in the Lincoln County Superior Court under Rule 80B and also filed independent claims for a declaratory judgment and attorney fees, alleging a First Amendment violation. The Superior Court found that the petition was not a proper reconsideration petition because it included an additional article and that the independent claims were barred by the exclusivity principle. The residents then appealed.The Maine Supreme Judicial Court reviewed the case. It held that the statute governing reconsideration petitions imposes a ministerial duty on the board to initiate a referendum if the statutory requirements are met; thus, the Superior Court had jurisdiction. However, the Court found that the residents’ petition did not comply with the statutory requirements for a reconsideration petition, as it sought affirmative repeal and included a second, unrelated article, making it ineligible for submission to voters. The Court also affirmed the dismissal of the independent claims, holding there was no First Amendment violation. The judgment of the Superior Court was affirmed. View "Minerich v. Boothbay-Boothbay Harbor Community School District" on Justia Law

The defendant owned a house on Farm Island, New Hampshire, near a summer camp with which he had a history of disputes. After hearing a group outside his house at night, he yelled at them and, when unable to reach the police, left a voicemail for the camp, using profane language and stating, “you better get them the f**k out of here or I will shoot them.” He also accused the group of damaging his property. The State charged him with harassment, alleging that his communication constituted a threat to the life or safety of another, made with the purpose to annoy or alarm.The Superior Court of Carroll County held a jury trial. During trial, the State introduced the voicemail, evidence of the contentious relationship between the defendant and the camp, and testimony from camp staff and police. Over the defendant’s objections, the court admitted testimony from a camp director about security measures the camp undertook in response to the message, including ceasing use of part of the island and enhancing security. The defendant moved to dismiss for insufficient evidence of the required mental state; the court denied the motion. The jury convicted the defendant, and he appealed.The Supreme Court of New Hampshire reviewed the case. It held that there was sufficient evidence for a rational trier of fact to find the defendant acted with the purpose to annoy or alarm and that the communication constituted a true threat as defined by federal law. However, the court found that admitting testimony about the camp’s security response was error under New Hampshire Rule of Evidence 403, as its limited probative value was substantially outweighed by the danger of unfair prejudice. This error was not harmless. The Supreme Court of New Hampshire therefore reversed the conviction and remanded for a new trial. View "State v. Owen" on Justia Law

An individual was convicted in 1997 of indecent assault and battery on a child under fourteen and served a sentence of incarceration. Before his release, the Commonwealth petitioned to have him civilly committed as a sexually dangerous person (SDP) under Massachusetts law. Two qualified examiners evaluated him but, misunderstanding the scope of evidence they could consider, both opined that he did not meet the statutory criteria for an SDP. Despite this, the case proceeded to trial, and, based on other expert testimony and additional evidence, a judge found him to be an SDP and ordered his civil commitment in 2002. The individual unsuccessfully attempted to appeal, and over the years, filed and withdrew several discharge petitions.A Superior Court judge had denied his original motion for summary judgment, finding that a fact finder could rely on other expert testimony, not just that of the qualified examiners. After his commitment, his attempt to appeal the judgment was dismissed as untimely. Years later, he filed a petition for a writ of habeas corpus, arguing that, following the Massachusetts Supreme Judicial Court’s decision in Johnstone, petitioner, 453 Mass. 544 (2009), his commitment was unlawful because neither qualified examiner had opined that he was an SDP. The Superior Court granted the writ, but the Appeals Court reversed, holding that habeas corpus was not available since alternative remedies existed.The Supreme Judicial Court of Massachusetts reviewed the case and held that, under the statutory scheme, the individual was entitled to a required finding of not sexually dangerous where neither qualified examiner so opined. However, the court concluded that habeas corpus was not available because he had alternative remedies, specifically a motion for relief from judgment. The court vacated the grant of habeas corpus and remanded the case to the Superior Court with instructions to treat the petition as a motion for relief from judgment, which must be allowed. View "Pierce, Petitioner" on Justia Law

Several pharmaceutical manufacturers and a trade association challenged a Louisiana statute, Act 358, which restricts drug manufacturers from interfering with the delivery of federally discounted drugs through contract pharmacies. The statute was passed in response to manufacturers’ efforts to limit the distribution of discounted drugs under the federal 340B Program, particularly through arrangements with contract pharmacies serving vulnerable populations. The plaintiffs argued that the Louisiana law was preempted by federal law and violated several constitutional provisions, including the Takings Clause, the Contracts Clause, and the Due Process Clause’s prohibition on vagueness.The United States District Court for the Western District of Louisiana considered three related cases together. It denied the manufacturers’ motions for summary judgment and instead granted summary judgment for the State of Louisiana and the Louisiana Primary Care Association (LPCA) on all claims. The district court also allowed LPCA to intervene in each case, over the objection of one plaintiff.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that Act 358 is not preempted by federal law. It found that the federal 340B statute does not occupy the field of pharmacy regulation and does not conflict with or frustrate federal objectives, as it is silent on the use of contract pharmacies and leaves room for state regulation. The court also concluded that Act 358 does not effect a physical or regulatory taking, does not substantially impair contract rights under the Contracts Clause, and is not unconstitutionally vague. However, the Fifth Circuit reversed the district court’s order permitting LPCA to intervene in AbbVie’s case, finding that LPCA’s interests were adequately represented by the State and it did not show it would present a distinct defense. The court affirmed summary judgment for Louisiana on all claims. View "AstraZeneca v. Murrill" on Justia Law

Two individuals, a political commentator and a state legislator, brought suit against Minnesota officials to challenge a state statute that criminalizes the dissemination of “deep fake” content intended to influence elections. The law applies to realistic depictions that could mislead a reasonable person into believing a public figure engaged in speech or conduct they did not. The commentator created an AI-generated video of Vice President Harris, which he labeled as parody with a clear disclaimer. The legislator shared the same video without any disclaimer. Both plaintiffs argued that the statute infringed their First and Fourteenth Amendment rights.After the complaint was filed in the United States District Court for the District of Minnesota, the district court found that the commentator lacked standing because the only videos he posted were labeled as parody and thus not covered by the statute. The court concluded that the legislator did have standing, since she shared content that could plausibly be seen as a deep fake under the law. However, the court denied her motion for a preliminary injunction, concluding she had unreasonably delayed in seeking relief—waiting over sixteen months after the statute’s enactment without sufficient explanation.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decisions. The appellate court held that the commentator did not demonstrate a credible threat of prosecution or show any evidence of injury, including from third parties. The court also determined that the legislator’s delay in seeking a preliminary injunction undermined her claim of irreparable harm, and the district court did not abuse its discretion in denying extraordinary relief. The Eighth Circuit left open the possibility of further proceedings on the merits, including a permanent injunction, but affirmed the denial of preliminary relief. View "Kohls v. Ellison" on Justia Law

After President Donald J. Trump began his second term, he issued two executive orders requiring federal agencies to end “diversity, equity, and inclusion” (DEI) programs in their grant and contracting processes. These directives included provisions for agencies to terminate DEI-related offices, positions, and funding (“Termination Provision”); to require federal grantees and contractors to certify compliance with anti-discrimination laws and the absence of DEI programs that violate those laws (“Certification Provision”); and to prepare a report on steps to deter illegal DEI programs (“Enforcement Threat Provision”). The plaintiffs—a city government and two organizations involved in higher education and academic advocacy—alleged that these provisions violated their constitutional rights and sought a preliminary injunction to halt their enforcement.The United States District Court for the District of Maryland found the plaintiffs likely to succeed on their constitutional claims and issued a nationwide preliminary injunction against most of the challenged provisions, except for the preparation of the enforcement report. The defendants appealed and the United States Court of Appeals for the Fourth Circuit granted a stay of the injunction pending appeal. The plaintiffs later sought to have the injunction vacated so they could amend their complaint, but the district court denied this request.Reviewing the case, the United States Court of Appeals for the Fourth Circuit held that the plaintiffs lacked standing to challenge the Enforcement Threat Provision because their alleged injuries were too speculative and intertwined with intra-governmental processes. However, the court found the plaintiffs had standing to challenge the Termination and Certification Provisions because these provisions resulted in concrete and imminent injuries, such as loss of funding or compelled changes in organizational activities.On the merits, the Fourth Circuit concluded the plaintiffs were unlikely to succeed on their facial constitutional challenges. The court ruled that the Termination Provision was not unconstitutionally vague under the Fifth Amendment, and that the Certification Provision did not violate the First Amendment on its face. The court vacated the preliminary injunction and remanded the case for further proceedings. View "Natl. Assoc. of Diversity Officers in Higher Edu. v. Trump" on Justia Law

Several organizations and individuals petitioned to prevent the Idaho State Tax Commission from implementing a newly enacted parental choice tax credit. This tax credit, established in 2025, provides refundable credits to parents, guardians, and foster parents for certain private educational expenses, including private school tuition and related services, for dependent students not enrolled in public schools. The law caps total annual credits and includes prioritization based on income and previous participation. The petitioners, including advocacy groups, a school district, and parents, argued that the statute creates a separate, non-public education system funded by public resources, allegedly violating the Idaho Constitution’s mandate for a single, general, uniform, and thorough system of public schools. They also claimed the statute failed the “public purpose doctrine,” asserting it primarily benefits private rather than public interests.Before the Idaho Supreme Court, the petitioners sought a writ of prohibition, which would prevent the Tax Commission from carrying out the law. The respondents, including the State and the Idaho Legislature, contested the petitioners’ standing and the merits of the constitutional claims. The Supreme Court determined that the petitioners lacked traditional standing but, given the urgency and importance of the constitutional question and the absence of another suitable challenger, relaxed standing requirements to address the merits.The Supreme Court of Idaho denied the petition. It held that Article IX, section 1 of the Idaho Constitution does not restrict the legislature from enacting educational measures beyond the required public school system, so long as the public system remains intact and constitutionally sufficient. The Court also found that the tax credit serves a legitimate public purpose—supporting parental choice in education—even if private entities benefit. The petition was dismissed, and the Tax Commission was awarded attorney fees and costs. View "Committee to Protect and Preserve v. State" on Justia Law