Justia Constitutional Law Opinion Summaries

Voters in Independence County, Arkansas, passed an ordinance requiring local elections to use hand-marked, hand-counted paper ballots. After about a year, the county quorum court repealed the ordinance, relying on state law. Bryan Norris and associated organizations sued county officials, challenging the quorum court’s authority to repeal the ordinance, claiming the state statute allowing such action was unconstitutional, and seeking to enforce the voter-adopted ordinance.The Independence County Circuit Court dismissed all claims, citing Act 975 of 2025, which purported to grant exclusive original jurisdiction over facial constitutional challenges to state statutes to the Arkansas Court of Appeals, rather than circuit courts. The County argued that the circuit court lacked subject-matter jurisdiction under this new law. Norris appealed, narrowing the issue to the constitutionality of Act 975.The Supreme Court of Arkansas reviewed the lower court’s dismissal de novo, as the issue involved a question of law. The Supreme Court held that Act 975 was unconstitutional. The Arkansas Constitution, specifically Amendment 80, vests circuit courts with original jurisdiction over all justiciable matters unless otherwise provided, and confines the Court of Appeals to appellate jurisdiction as determined by Supreme Court rule. The General Assembly’s power to establish jurisdiction is limited by the Constitution’s explicit assignments. Act 975’s attempt to strip circuit courts of original jurisdiction and confer it on the Court of Appeals—an appellate court—contradicted the Constitution’s plain language. The Supreme Court of Arkansas concluded that Act 975 is unconstitutional, reversed the circuit court’s dismissal, and remanded the case for further proceedings. View "NORRIS V. INDEPENDENCE COUNTY, ARKANSAS" on Justia Law

This case concerns a group of landowners in Indiana who own property adjacent to former railroad corridors once operated by the Peru and Indianapolis Railroad Company (PIRC). The landowners asserted that they also hold fee simple title to the land underlying these corridors. They challenged the federal government's authorization of public recreational trail use on these corridors under the National Trails System Act Amendments of 1983, claiming that this action constituted a taking of their property without just compensation, in violation of the Fifth Amendment.The United States Court of Federal Claims reviewed the dispute. The main issue was whether PIRC’s interest in the rail corridors consisted merely of easements, rather than fee simple title. The Court of Federal Claims examined two sets of parcels: those associated with a 1907 Indiana Circuit Court quiet title judgment (the Manship Parcels) and those deriving from a lost 1849 instrument (the Vanlaningham Parcels). The Court of Federal Claims concluded that PIRC held only easements in both sets of parcels, meaning that when railroad operations ceased, full title reverted to the plaintiffs under Indiana law. Thus, the court found in favor of the landowners, holding that the government’s issuance of Notices of Interim Trail Use (NITUs) resulted in an uncompensated taking.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the grant of summary judgment de novo. The Federal Circuit affirmed the lower court’s judgment, holding that the record demonstrated PIRC’s interests were limited to easements for both the Manship and Vanlaningham Parcels. The court concluded that, under Indiana law and the facts presented, the plaintiffs hold fee simple title to the corridor land, and the government’s actions constituted a taking for which just compensation is required. The judgment of the Court of Federal Claims was therefore affirmed. View "PRESSLY v. US " on Justia Law

After being arrested in connection with several shootings, the defendant was informed of the charges against him at his initial municipal court appearance, where he was appointed counsel and bail was set. Later that day, police detectives interrogated him, reading him his Miranda rights, which he acknowledged and waived by answering questions. During the interrogation, he confessed to involvement in one shooting and a separate theft. About 45 minutes into the interrogation, after being pressed about another crime, he asked, “Like, I can’t talk to a lawyer?” The detective replied that anyone could talk to a lawyer, and the defendant made a statement that was interpreted by the trial court as an invocation of his right to counsel. The interrogation continued, and he made further statements.The Hamilton County Court of Common Pleas granted the defendant’s motion to suppress all statements made during the interrogation. The trial court ruled that Article I, Section 10 of the Ohio Constitution provides a broader right to counsel than the Sixth Amendment, and found that the defendant’s state constitutional right was violated by the interrogation without counsel present. Alternatively, it held that the defendant unambiguously invoked his federal Sixth Amendment right to counsel during the interrogation, requiring suppression of all subsequent statements. The First District Court of Appeals affirmed, relying solely on the Ohio Constitution and interpreting it to provide a broader right to counsel than the federal Constitution.The Supreme Court of Ohio reversed. It held that Article I, Section 10 of the Ohio Constitution guarantees the right to counsel only at “trial,” not at preindictment investigatory interviews, and therefore was not implicated by the interrogation. The court further held that the defendant’s Sixth Amendment right to counsel attached at his initial appearance, but he did not unambiguously and unequivocally invoke that right during the interrogation. The court remanded the case to the trial court, instructing it to vacate its suppression order. View "State v. Morris" on Justia Law

A religious nonprofit organization in New Jersey, active since 1985, provides counseling and resources to pregnant women but does not offer or refer for abortions due to its belief that life begins at conception. In 2022, the state’s Attorney General created a task force that accused groups like this one of spreading misleading information about abortion. Subsequently, the Attorney General issued a subpoena demanding the group turn over documents identifying many of its donors, except those who donated through one specific webpage. The subpoena warned that noncompliance could lead to contempt charges and other penalties.The organization responded by filing a lawsuit in the United States District Court, seeking to block enforcement of the subpoena and arguing that the compelled disclosure of its donor information would chill its First Amendment rights by deterring donors. The district court denied the group’s request for a preliminary injunction and dismissed the complaint, holding there was no justiciable claim because no court had yet ordered the group to comply with the subpoena, so no injury had occurred. The United States Court of Appeals for the Third Circuit affirmed, finding that the group lacked standing since any potential harm was not sufficiently concrete or imminent.The Supreme Court of the United States reversed the Third Circuit’s decision. The Court held that the subpoena itself, even before enforcement, constitutes an ongoing injury to the organization’s First Amendment associational rights by deterring donors and burdening protected association. The Court clarified that the injury arises when the government issues such a demand—not only if and when a court enforces it. The Court further held that the possibility of later confidentiality protections or limited exceptions in the subpoena did not eliminate the injury. The case was remanded for further proceedings. View "First Choice Women's Resource Centers, Inc. v. Davenport" on Justia Law

After the 2020 census, Louisiana redrew its congressional districts, enacting a map (HB1) with only one majority-black district. Plaintiffs challenged this map in the United States District Court for the Middle District of Louisiana, arguing that it diluted black voting power in violation of Section 2 of the Voting Rights Act. The court agreed, finding a likely Section 2 violation and ordering the state to add a second majority-black district. To avoid a court-imposed map, the legislature enacted a new map (SB8) with a second majority-black district, which connected distant black populations across the state.The new SB8 map was then challenged as an unconstitutional racial gerrymander in the United States District Court for the Western District of Louisiana (a three-judge court). The court found that race predominated in the drawing of SB8’s District 6 and that the state could not justify its actions under the Equal Protection Clause. The court concluded that the state had failed to show that Section 2 of the Voting Rights Act required the creation of an additional majority-black district or that compliance with the Act was a compelling interest. The court therefore held SB8 unconstitutional.On direct appeal, the Supreme Court of the United States addressed whether compliance with Section 2 of the Voting Rights Act can ever justify intentional race-based districting. The Court held that Section 2, properly interpreted, requires liability only when there is a strong inference of intentional discrimination, not merely disparate impact. The Court also clarified that a plaintiff’s illustrative maps must satisfy all the state’s legitimate districting goals without using race as a predominant factor and that evidence of racially polarized voting must be disentangled from partisan affiliation. The Supreme Court affirmed the district court’s ruling, holding that Louisiana’s SB8 map was an unconstitutional racial gerrymander because Section 2 did not require a second majority-black district, and no compelling interest justified the use of race. The case was remanded for further proceedings. View "Louisiana v. Callais" on Justia Law

A police officer in Columbia, South Carolina, shot and killed a high school senior, J.R., during the COVID-19 curfew. The officer was responding to a report of teenagers looking into cars and saw J.R. walking alone. When the officer approached, J.R. ran away. The officer chased J.R. and, during the pursuit, observed that J.R. was armed. Despite repeatedly commanding J.R. to stop, get on the ground, and show his hands, J.R. did not comply. At one point, J.R. crouched near a fence, picked up his gun, and then ran again. The officer fired multiple shots, ultimately striking J.R. in the forehead and killing him.J.R.’s mother, acting as his personal representative, sued the officer under 42 U.S.C. § 1983, asserting that the use of deadly force violated J.R.’s Fourth Amendment rights. The United States District Court for the District of South Carolina denied the officer’s motion for summary judgment based on qualified immunity, finding that although J.R. was armed, ignored commands, and turned to face the officer, there was no undisputed evidence that J.R. made a threatening movement with his weapon. The court concluded that genuine disputes of material fact remained and that it was clearly established law that deadly force could not be used under these circumstances.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that, at the time of the shooting, clearly established law prohibited a police officer from using deadly force against a fleeing, armed suspect who did not make a furtive or threatening movement with his weapon. The court concluded that the officer was not entitled to qualified immunity and allowed the case to proceed. View "Ruffin v. Davis" on Justia Law

A private company specializing in the disposal of wastewater from oil and gas fracking leased land in an urban area and constructed two saltwater-injection wells. After two earthquakes were recorded near the wells, the State of Ohio determined the company’s activities caused the seismic events and temporarily suspended operations at both wells. One well was later permitted to resume limited operations, but the suspension of the second well remained until 2021. The company had been aware of seismicity risks before acquiring its leasehold and warned investors of possible regulatory shutdowns.After the suspension, the company pursued administrative and judicial challenges, including an appeal to the Ohio Oil and Gas Commission and the Tenth District Court of Appeals, both of which upheld the State’s actions. The company then filed a petition for a writ of mandamus in the Eleventh District Court of Appeals, claiming a regulatory taking of its property. The Eleventh District initially denied relief, but following multiple remands from the Supreme Court of Ohio, it ultimately found no total taking but did find a compensable partial regulatory taking under the Penn Central analysis, ordering the State to initiate eminent-domain proceedings.On appeal, the Supreme Court of Ohio reviewed whether the suspension order constituted a total or partial regulatory taking. The court held that the company failed to prove it was deprived of all economically beneficial use, rejecting the total taking claim. The court further held that, under a proper balancing of the Penn Central factors, the State’s actions did not amount to a compensable partial taking. The Supreme Court of Ohio affirmed the Eleventh District’s denial of the total takings claim, reversed its partial takings finding, and denied the writ of mandamus. View "State ex rel. AWMS Water Solutions, L.L.C. v. Mertz" on Justia Law

The case involves a defendant who, in 2020, confronted individuals renting his neighbor’s house through Airbnb by approaching them with a shotgun, using racial slurs, and threatening them. He also left threatening voicemails for the property owner, making explicit references to race. The defendant was charged in two separate cases: one involving the renters (with charges including reckless endangerment and threatening) and another involving the neighbor (with charges including intimidation based on bigotry or bias and harassment). Ultimately, under a plea agreement, the defendant pleaded guilty to reckless endangerment in the second degree, threatening in the first degree (both under the Alford doctrine), and intimidation based on bigotry or bias in the third degree. The remaining charges were nolled.In the Superior Court for the judicial district of New Britain, the defendant entered his pleas. The trial court conducted a plea canvass, accepted the pleas, and later denied the defendant’s motion to withdraw them, in which he argued that the canvass was constitutionally deficient because the court did not specifically confirm that he was knowingly waiving his rights to a jury trial, to confront accusers, and against self-incrimination. On appeal, the Appellate Court affirmed the trial court’s judgment, holding that the plea canvass was sufficient under Boykin v. Alabama, as the record did not presume a waiver from silence and demonstrated the defendant’s understanding of the rights he was waiving.The Connecticut Supreme Court reviewed the case and affirmed the Appellate Court’s judgment. It held that Boykin does not require an express advisement or enumeration of each constitutional right during a plea canvass. Rather, the totality of the circumstances must show that the plea was made knowingly and voluntarily. Here, the defendant’s responses, counsel’s statements, and the overall canvass were constitutionally adequate, though barely so, and the plea was valid. View "State v. Roberts" on Justia Law

In this case, Montgomery County, Maryland, enacted amendments to its County Code in 2021 and 2022 regulating firearms. The amendments expanded the definition of “place of public assembly,” prohibited the possession of firearms (including “ghost guns”) in or within 100 yards of such places, and removed exceptions for state-issued handgun permit holders. The amendments also imposed new restrictions concerning minors’ access to firearms and regulated ghost guns and their components. The petitioners, two businesses and eight individuals, claimed these provisions were preempted by state law, not a valid local law, and amounted to an unconstitutional taking.After removal to federal court and a partial remand, the Circuit Court for Montgomery County ruled in favor of the challengers, finding the county’s provisions preempted by state law, not a local law, and an unconstitutional taking, and issued declaratory and injunctive relief. The Appellate Court of Maryland remanded for further analysis of preemption and takings issues, particularly concerning the expansion of “place of public assembly.”The Supreme Court of Maryland reviewed the case, holding that new issues may only be properly added by amending the complaint, not through summary judgment motions. The Court determined that Criminal Law § 4-209(b)(1) authorizes charter counties to regulate firearms in limited contexts (with respect to minors, law enforcement, and within 100 yards of certain public places), and that this authority was not abrogated by other state preemption statutes. The Court found Montgomery County’s regulation valid for parks, places of worship, schools, libraries, courthouses, legislative assemblies, recreational and multipurpose exhibition facilities, and polling places, but invalid for hospitals, health centers, long-term care, childcare facilities, government buildings as broadly defined, and generalized gatherings. The Court also clarified the scope of local regulation regarding minors and found no unconstitutional taking occurred. The judgment of the Appellate Court was vacated and remanded with instructions for further proceedings consistent with these holdings. View "Engage Armament v. Montgomery Cnty." on Justia Law

In December 2021, an individual with a lower leg amputation and a history of medical episodes broke into a car dealership in Chesterfield County, Virginia. After the alarm was triggered, police—including an officer and his police K-9—responded to the scene. The individual hid in a storage room, unarmed and passively waiting to be arrested. When the officer and his leashed K-9 located him lying in a submissive, fetal-like position, the officer allegedly gave no orders or warnings before directing the dog to attack. The K-9 inflicted severe injuries, including to sensitive areas of the individual’s body, resulting in significant blood loss and destruction of his prosthetic leg. Following the incident, the individual was charged with trespassing and vandalism, but no violent offenses.The individual filed suit in the United States District Court for the Eastern District of Virginia, asserting a Fourth Amendment excessive force claim under 42 U.S.C. § 1983, as well as related state law claims. The officer moved to dismiss, arguing that the use of force was objectively reasonable and that qualified immunity applied because the right in question was not clearly established. The district court ruled that the complaint plausibly alleged a Fourth Amendment violation but concluded that the specific right was not clearly established, granting the officer qualified immunity and dismissing the federal claim. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and held that, as of 2013, it was clearly established that a non-threatening, unarmed, and passively-resisting suspect had a right to be free from unnecessary, gratuitous, and disproportionate force by deployment of a police K-9. The court vacated the district court’s judgment and remanded for further proceedings. View "Harrold v. Hagen" on Justia Law