Justia Constitutional Law Opinion Summaries

A middle school student in the Alamance-Burlington School District alleged that her teacher violently assaulted her in the classroom. The teacher, who was not licensed at the time, reportedly grabbed the student, slammed her into a door, and then onto the ground, causing physical and emotional harm. After the incident, the Board of Education suspended the student, later reversed the suspension when media reported on the attack, but still transferred her to an alternative school without her consent. The student’s academic performance suffered as a result.The student, through her guardian, sued the teacher and the Board of Education in Superior Court, claiming assault, emotional distress, negligent hiring and supervision, and violations of the North Carolina constitutional right to a sound basic education. The Board moved to dismiss, arguing sovereign immunity on the tort claims and failure to state a constitutional claim. The Superior Court granted the Board’s motion, dismissing all claims against it. The North Carolina Court of Appeals affirmed, finding that the student had not adequately alleged waiver of sovereign immunity or a constitutional violation under relevant precedent.On appeal, the Supreme Court of North Carolina reviewed whether the student’s complaint stated a viable constitutional claim. The Supreme Court held that, accepting the allegations as true, the Board’s actions—suspending and transferring the student after she was assaulted by a teacher—could constitute deliberate indifference to her right to access a sound basic education under the state constitution. The Court found the student lacked any other adequate remedy due to sovereign immunity and that her complaint met the necessary elements for a direct constitutional claim. The Supreme Court reversed the Court of Appeals and remanded for further proceedings. View "K.H. v. Dixon" on Justia Law

The case concerns a defendant whose vehicle crossed the center line and collided with a motorcycle, resulting in the deaths of both riders. The defendant left the scene but later turned himself in. He was charged with several offenses, including driving while impaired, felony hit and run, attaining violent habitual felon status, and two counts of second-degree murder. Before trial, the defendant pled guilty to driving while license revoked and, through written stipulations and oral colloquies, admitted to several facts related to the charges, including being the driver, the collision, and his revoked license status.At trial in the Superior Court of Rowan County, the defendant’s counsel, with the defendant’s partial consent, conceded certain elements of the offenses. During closing argument, counsel asked the jury to find the defendant guilty of the lesser included offenses—misdemeanor death by vehicle and misdemeanor hit and run—without explicitly seeking a not guilty verdict. The jury convicted the defendant of two counts of second-degree murder and felony hit and run. The defendant appealed, arguing his counsel provided ineffective assistance by conceding guilt to the lesser charges without his knowing consent.The North Carolina Court of Appeals held that, under State v. Harbison, a defense counsel’s admission of guilt without the defendant’s consent is per se ineffective assistance, and remanded for an evidentiary hearing to determine if the defendant had consented. The State sought discretionary review.The Supreme Court of North Carolina clarified that, following Florida v. Nixon, the per se prejudice rule of Harbison is limited. The general standard for ineffective assistance of counsel is Strickland v. Washington’s two-prong test, unless the narrow United States v. Cronic exception applies (where the defendant is wholly surprised by the concession). Because the defendant was not wholly surprised and could not show prejudice, the Supreme Court of North Carolina reversed the decision of the Court of Appeals. View "State v. Farook" on Justia Law

A Chinese drone manufacturer and its subsidiary challenged their designation by the U.S. Secretary of Defense as a “Chinese military company” under Section 1260H of the National Defense Authorization Act. The designation, which is published annually, restricts the company from contracting with certain government agencies and can damage its business reputation. DJI was added to the list in 2022 and again in 2024 and 2025 without prior notice. DJI petitioned for removal, which was denied, and subsequently received a report explaining the designation, though portions of the rationale were redacted.DJI filed suit in the United States District Court for the District of Columbia, alleging violations of the Fifth Amendment’s Due Process Clause and the Administrative Procedure Act. The company argued that it was denied due process, that there was insufficient evidence for the designation, that the agency failed to explain disparate treatment compared to other companies, and that the Secretary’s finding that DJI “contributes” to the Chinese defense industrial base was unsupported. The district court granted summary judgment against DJI, relying solely on the unclassified administrative record and declining to review the classified materials.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The appellate court affirmed the district court’s rejection of DJI’s due process, evidentiary, and disparate treatment claims, holding that DJI failed to show deprivation of a protected liberty or property interest, and that sufficient evidence supported the finding that DJI received government assistance. However, the appellate court reversed the district court’s conclusion regarding DJI’s “contribution” to the Chinese defense industrial base, finding that the lower court improperly relied on post hoc agency arguments and failed to review the classified record. The case was remanded for further proceedings on that issue. View "SZ DJI Technology Co., Ltd. v. DOD" on Justia Law

Three Venezuelan nationals, alleged by the government to be members of the Tren de Aragua gang, were detained in Texas following a presidential proclamation under the Alien Enemies Act (AEA). This proclamation, issued in March 2025, authorized immediate removal of Venezuelan citizens aged fourteen or older, residing in the United States, who were not naturalized or lawful permanent residents and were identified as members of the gang. The petitioners challenged the proclamation, arguing that it exceeded the President’s authority under the AEA and violated due process rights. They sought class certification and injunctive relief to prevent removal under the AEA.The United States District Court for the Northern District of Texas denied temporary restraining orders and class certification. On appeal, the Fifth Circuit initially dismissed the case for lack of jurisdiction. The Supreme Court, in A.A.R.P. v. Trump, vacated that dismissal and remanded, instructing the Fifth Circuit to address two issues: whether the petitioners were entitled to a preliminary injunction against removal under the AEA, and whether the notice provided for due process claims was sufficient for the putative class. The Supreme Court also allowed the government to remove the petitioners under other lawful authorities.After remand, the three named petitioners were removed from the United States under the Immigration and Nationality Act (INA), not the AEA. The United States Court of Appeals for the Fifth Circuit concluded that, because the petitioners were no longer in the country and no class had been certified, it was impossible to grant any effectual relief. The Fifth Circuit dismissed the appeal as moot for lack of jurisdiction, declining to substitute new class representatives on appeal but leaving open the possibility for future proceedings in the district court. View "W.M.M. v. Trump" on Justia Law

Four professors employed by Indiana’s public universities brought a facial constitutional challenge against a new state law, which mandates that university boards adopt and enforce policies promoting “free inquiry, free expression, and intellectual diversity.” The law conditions tenure and promotion decisions, as well as periodic reviews of tenured faculty, on compliance with these principles. The professors argued that these requirements, and related university policies, compelled them to alter their teaching and course materials, thereby chilling their First Amendment rights. They described changes they made to their syllabi and teaching practices out of concern for violating the law or university policies, but none had faced discipline or explicit threats as a result.Previously, the United States District Court for the Southern District of Indiana dismissed the professors’ initial suit for lack of standing, finding no credible threat of enforcement since the law regulated university boards rather than faculty directly. After the universities adopted “interim” policies to implement the law, the professors sued again, targeting both the statute and these new policies. The district court again dismissed the case, reasoning that the professors’ fears of enforcement were speculative because the policies were not final and no actions had been taken against them under the new regime.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal for lack of subject-matter jurisdiction. The Seventh Circuit held that the professors failed to establish Article III standing, as they did not demonstrate a credible threat that the law or university policies would actually be enforced against them, nor an objectively reasonable chilling effect on their speech. The court emphasized that neither the indirect application of the law nor the interim status of the policies categorically precluded standing, but found that the record did not support a sufficient injury-in-fact to proceed. View "McDonald v Trustees of Indiana University" on Justia Law

In this case, the appellant was convicted of malice murder and related offenses stemming from the shooting death of a victim in 2013. He, along with a co-defendant, was indicted and subsequently went to trial in early 2015. After being found guilty on all counts by a jury, he received multiple sentences, including life imprisonment. Following his conviction, he filed a timely motion for new trial, which remained unresolved for approximately ten years due to various delays in post-conviction proceedings, including changes in appointed counsel and a lack of substantive action on his case.Throughout this period, the Superior Court of Cobb County experienced significant delays in hearing and resolving the appellant’s motion for new trial. The motion was finally amended and heard in 2025. At the hearing, the appellant argued that the delay in his post-conviction proceedings violated his due process rights, particularly because his trial counsel no longer possessed the trial file, which he claimed hindered his ability to effectively pursue post-conviction relief. The trial court, applying the four-factor test from Barker v. Wingo and Chatman v. Mancill, found that the appellant failed to show actual prejudice resulting from the delay and denied the motion for new trial.Upon appeal, the Supreme Court of Georgia reviewed the Superior Court’s decision. The Supreme Court reiterated that, under Georgia law, actual (not presumed) prejudice must be shown for a due process violation based on appellate delay. The appellant did not provide specific evidence that the outcome of his appeal would have been different absent the delay. The Supreme Court of Georgia affirmed the trial court’s decision, holding that the appellant’s due process rights were not violated by the post-conviction delay because no actual prejudice was demonstrated. View "KELLY v. STATE" on Justia Law

Three men, including the appellant, were indicted in connection with the shooting death of an individual outside a local game room. The incident occurred after a fight broke out near the game room’s entrance, resulting in the victim being shot multiple times and dying at the scene. Witnesses saw the appellant and his co-defendants at or near the scene around the time of the shooting, and evidence linked the appellant to a firearm that matched shell casings found at the scene. The State also presented evidence that all three men were members of the same street gang and suggested a retaliatory motive based on the victim’s cooperation with police.The Superior Court of Emanuel County tried all three defendants together before a jury. The jury found the appellant guilty on all charges, including felony murder, armed robbery, aggravated assault, and possession of a firearm during the commission of a felony. The State conceded that the evidence was insufficient to support the gang-related charge against the appellant, and the trial court granted a new trial as to that count and later entered an order of nolle prosequi on it. The trial court denied the appellant’s motion for a new trial on the remaining convictions.On direct appeal to the Supreme Court of Georgia, the appellant challenged the sufficiency of the evidence, the admission of certain testimony, and a jury instruction. The Supreme Court of Georgia held that the evidence was sufficient to support the convictions under both federal due process and Georgia statutory law. The court found no plain error in the admission of testimony referencing statements by the appellant’s roommate, nor in a minor misstatement by the trial court during jury instructions, concluding that the written instructions properly informed the jury. The Supreme Court of Georgia affirmed the appellant’s convictions. View "SOMERVILLE v. STATE" on Justia Law

A man was shot and killed inside a DeKalb County restaurant. The shooter, described as wearing dark clothing, a hat, and glasses, fired multiple times and referenced “my nephew” before fleeing. Surveillance footage from the restaurant and a nearby drugstore captured individuals and vehicles at the scene. Investigators linked a black Dodge Charger, seen near the time of the shooting, to the defendant, whose driver’s license photo resembled the shooter in the footage. The defendant’s supervisor, familiar with him from daily work interactions, identified him in stills from the surveillance video. A search of the defendant’s car revealed glasses and ammunition similar to those associated with the shooting. Evidence also showed that, prior to the shooting, the defendant searched online for information about his nephew’s murder (in which the victim was a suspect) and about the victim himself.A DeKalb County grand jury indicted the defendant on multiple counts, including malice murder and firearm-related charges. At trial in the Superior Court of DeKalb County, a jury found him guilty on all counts. The court sentenced him to life without parole for malice murder and additional time for firearm possession. The defendant filed a motion for a new trial, later amended, which the court denied after an evidentiary hearing.On appeal, the Supreme Court of Georgia reviewed claims that the trial court erred by admitting lay identification testimony from the supervisor, allowing the defendant to be shackled at trial, and that counsel was ineffective. The Court held that the identification testimony was admissible under the rules for lay opinion based on familiarity. Although the trial court did not make specific findings justifying shackling, the error was harmless because the shackles were hidden from the jury. The Court also found no ineffective assistance of counsel. The Supreme Court of Georgia affirmed the convictions. View "MINOR v. STATE" on Justia Law

Two men were convicted of malice murder and related crimes following the shooting death of an individual who attempted to break up a fight outside an apartment complex in May 2015. The incident arose after a series of confrontations triggered by suspicions that a resident’s acquaintance was falsely claiming membership in a street gang. During the final altercation, eyewitnesses reported that one defendant instructed the other to retrieve a firearm, after which shots were fired and the victim was killed. Both defendants fled the scene. Forensic evidence indicated multiple firearms were used. At trial, one defendant admitted to firing a gun but claimed it was only into the air.The Superior Court of Fulton County conducted a joint trial, where a jury found both men guilty on all counts. The court imposed life sentences and additional concurrent and consecutive terms. Both defendants filed motions for new trial, raising issues including sufficiency of the evidence, juror misconduct, trial errors, and ineffective assistance of counsel. After an evidentiary hearing, the Superior Court denied their motions.On appeal, the Supreme Court of Georgia reviewed the convictions. The Court held that the evidence was constitutionally sufficient for the malice murder conviction, including as a party to the crime. The Court found no abuse of discretion in the trial court’s rejection of juror misconduct claims and determined that issues with jury instructions and evidentiary rulings did not warrant reversal. Claims of Brady violations and ineffective assistance of counsel were also rejected because the alleged errors did not prejudice the defense or would not have succeeded if raised. Although one jury instruction regarding the gang activity charge was erroneous, the Court found the error harmless. The Supreme Court of Georgia affirmed all convictions and sentences. View "CLIFTON v. STATE" on Justia Law

The case concerns the conviction of a defendant for malice murder and related crimes stemming from the shooting death of a man during a robbery. The defendant, along with several co-defendants, planned to rob the victim, a known drug dealer, because the defendant needed money. The group lured the victim to a meeting, forced him into a car at gunpoint, and then drove to his home, where they took money, drugs, and other items. The victim, his girlfriend, and their child were tied up, and the group left with the victim, who was later shot and killed by the defendant. The co-defendants testified against the defendant, and physical evidence supported their accounts.Following indictment in the Superior Court of Troup County, the co-defendants pleaded guilty to lesser charges, and the defendant was tried alone and found guilty on all counts. He was sentenced to life without parole for malice murder and a consecutive life term for kidnapping with bodily injury. His timely motion for new trial was amended several times and ultimately denied by the trial court without a hearing, resulting in a significant delay before appeal.The Supreme Court of Georgia reviewed the case on appeal. The court held that evidence of the defendant’s prior drug use was properly admitted under the old Evidence Code to show motive. Any error in admitting evidence of his arrest in New York was harmless in light of strong evidence of guilt. The court also found no violation of the defendant’s Sixth Amendment right to counsel when the trial court required him to proceed with second-chair counsel after his lead counsel became ill, as he was still represented by competent counsel. The court affirmed the convictions. View "ALLEN v. STATE" on Justia Law