Justia Constitutional Law Opinion Summaries

In 1985, Gerald Ross Pizzuto, Jr. was convicted by a jury in Idaho state court of murdering Berta and Del Herndon during a robbery, and he was sentenced to death. Over the following decades, Pizzuto challenged his conviction and death sentence through numerous state and federal post-conviction proceedings, but those efforts were unsuccessful. In 2021, Pizzuto sought clemency from the Idaho Commission of Pardons and Parole, which recommended that his death sentences be commuted to life without parole. However, the Governor of Idaho rejected this recommendation in accordance with an Idaho statute requiring gubernatorial approval for commutation in capital cases.Following the Governor’s denial, Pizzuto argued in Idaho state court that the Governor lacked authority under the Idaho Constitution to overrule the Commission’s recommendation. The Idaho Supreme Court upheld the statute granting the Governor final authority in capital commutation cases, concluding that a 1986 amendment to the Idaho Constitution permitted the legislature to establish the procedures for granting clemency. Pizzuto filed a petition for rehearing, asserting that the Idaho Supreme Court’s decision was so arbitrary as to violate his federal due process rights, but the Idaho Supreme Court summarily denied rehearing.Pizzuto then brought a habeas corpus petition in the United States District Court for the District of Idaho, raising the due process claim. The district court denied relief, finding that the claim was not cognizable in federal habeas and would fail on the merits. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed. The court held that Pizzuto’s claim essentially challenged the Idaho Supreme Court’s interpretation of state law, which is not a cognizable federal habeas claim. Even if the claim were cognizable, the court determined that Pizzuto did not demonstrate a due process violation under clearly established federal law, and the Idaho Supreme Court’s decision was not so arbitrary as to support habeas relief. View "PIZZUTO V. VALLEY" on Justia Law

Several media organizations challenged an Indiana policy that restricts attendance at state executions to a limited set of individuals, including prison officials, spiritual advisors, a small number of people invited by the inmate, and immediate family members of the victim. The policy does not allow members of the press or the general public to attend executions unless they are specifically invited by the inmate. While the guidelines permit media representatives to be present outside the execution chamber and to report freely on the event, they cannot witness the execution itself unless included on the inmate’s guest list.After filing suit under 42 U.S.C. § 1983 in the United States District Court for the Southern District of Indiana, the plaintiffs alleged that Indiana’s policy violated their First Amendment rights—specifically, the qualified right of access to certain government proceedings and the Press Clause. They sought declaratory and injunctive relief and soon requested a preliminary injunction to prevent enforcement of the state’s attendance restrictions for upcoming executions. The district court denied their motion, finding that the plaintiffs were unlikely to succeed on the merits. The court concluded that Supreme Court precedent on public access to criminal proceedings did not extend to executions and that Indiana’s rules did not discriminate against the press because they were treated the same as the public.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that executions have not historically been open to the press or the general public, so no qualified First Amendment right of access attaches. The court also determined that Indiana’s policy is generally applicable and does not target the press for unfavorable treatment in violation of the Press Clause. Accordingly, the denial of the preliminary injunction was affirmed. View "Associated Press v Neal" on Justia Law

A man was charged with aggravated kidnapping and rape after holding a woman hostage and abusing her over several months. After his arrest, the State filed charges, and during pretrial proceedings, questions arose regarding his competency to stand trial and his desire to represent himself rather than be represented by counsel. The district court found him competent and, upon his request, allowed him to proceed pro se, appointing standby counsel. He represented himself during several pretrial hearings, including a competency hearing in March 2018 and a motions hearing in May 2018, before ultimately requesting counsel during trial, at which point standby counsel took over. He was found guilty on all counts and sentenced to 331 months in prison.The Kansas District Court conducted the initial proceedings, including the hearings at issue. On appeal, a panel of the Kansas Court of Appeals concluded that the March and May 2018 hearings were critical stages at which the defendant did not have counsel and had not validly waived his right to counsel. The panel determined that these errors were structural and not subject to harmless error analysis, reversing his convictions and remanding for a new trial.The Supreme Court of the State of Kansas reviewed the case. It agreed that the March 2018 competency hearing and the portion of the May 2018 hearing regarding the State’s motion were critical stages and that the defendant had not validly waived his right to counsel at those stages. However, the court held that such errors are not categorically structural and may be subject to harmless error analysis, depending on the extent and circumstances of the deprivation. In this instance, the court found the errors harmless beyond a reasonable doubt because they did not affect the trial’s outcome. The court affirmed the district court’s judgment and partially affirmed and partially reversed the Court of Appeals’ decision. View "State v. Allen " on Justia Law

A woman convicted of attempted murder and sentenced to twenty-five years in the custody of the Mississippi Department of Corrections (MDOC) participated in various educational and rehabilitative programs during her incarceration. Despite her reclassification to minimum security and her involvement in these programs, MDOC did not grant her trusty earned time, which could reduce her sentence. She challenged this denial through MDOC’s Administrative Remedy Program, arguing that the legislature had not excluded those convicted of attempted murder from eligibility for trusty time and that MDOC lacked the authority to expand the list of ineligible offenses. She further asserted that, if such authority were delegated, it would violate the Mississippi Constitution’s separation of powers.After MDOC denied her request, citing internal policy and recent legislative changes, she sought judicial review in the Circuit Court of Rankin County. The circuit court upheld MDOC’s decision, concluding that the department had the statutory discretion to deny trusty earned time to her. She then appealed to the Supreme Court of Mississippi.The Supreme Court of Mississippi reviewed whether MDOC’s policy violated Mississippi Code Section 47-5-138.1 and whether the statute, as applied, was unconstitutional. The court determined that MDOC has authority to define trusty status and that the statutory requirements for trusty time eligibility only apply to inmates whom MDOC has already granted trusty status. Because the appellant was never given trusty status under MDOC’s classification, the statute did not entitle her to trusty time. The court also concluded that denying trusty time did not increase her sentence or violate the separation of powers, as inmates are not entitled to such reductions. Accordingly, the Supreme Court of Mississippi affirmed the decisions of MDOC and the circuit court. View "Hudson v. Department of Corrections" on Justia Law

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