Justia Constitutional Law Opinion Summaries

A trade association representing internet companies challenged the enforcement of a new Tennessee statute designed to protect minors from social media risks. The law requires social media companies to verify the ages of all prospective account holders and secure parental consent before allowing minors to create accounts. It also mandates that parents be given tools to supervise their children’s accounts. The association argued that its members would suffer unrecoverable compliance costs and that the law would restrict their and their users’ First Amendment rights.The United States District Court for the Middle District of Tennessee denied the association’s motion for a preliminary injunction. The district court concluded that the association had not established irreparable harm, finding that the alleged loss of First Amendment freedoms was not sufficiently certain or imminent, and that unrecoverable compliance costs did not qualify as irreparable harm. Because the court found no irreparable harm, it did not consider the other preliminary injunction factors.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial. The appellate court disagreed with the lower court’s analysis of irreparable harm, holding that both unrecoverable compliance costs and the loss of First Amendment freedoms can satisfy the threshold requirement for irreparable harm. The court explained that compliance costs need not be extraordinary to be considered irreparable and that the chilling effect on speech, even before enforcement, can constitute irreparable harm if enforcement is likely and imminent. The Sixth Circuit vacated the district court’s order and remanded the case for further consideration of all preliminary injunction factors, directing the lower court to weigh the harm asserted and address the remaining legal standards as appropriate. View "NetChoice, LLC v. Skrmetti" on Justia Law

A group of Guatemalan nationals were recruited under the H-2A visa program by a Michigan agricultural company and its owners to work seasonal jobs between 2017 and 2019. The plaintiffs alleged that the defendants illegally charged recruitment fees, underpaid wages, forced them to live in poor conditions, confiscated personal documents, limited their freedom, and threatened them with deportation if they complained. The plaintiffs claimed these actions violated federal anti-trafficking laws, the Fair Labor Standards Act, Michigan labor and trafficking statutes, and state contract law.In the United States District Court for the Western District of Michigan, the case proceeded to a jury trial. The jury found in favor of the plaintiffs on most claims, awarding both compensatory and punitive damages, while denying certain claims against one defendant and rejecting the defendants’ counterclaims. The district court denied the defendants’ motions for mistrial, to dismiss for forum non conveniens, for a new trial, and for remittitur of punitive damages. The court entered judgment for the plaintiffs, including damages, attorney fees, and costs.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the punitive damages awarded were not grossly excessive or arbitrary and thus did not violate due process, applying the guideposts from BMW of North America, Inc. v. Gore and State Farm Mutual Automobile Insurance Co. v. Campbell. The court also found no abuse of discretion in the district court’s evidentiary rulings, denial of a mistrial, or in allowing the case to proceed in Michigan rather than Guatemala. The court further concluded that alleged statute of limitations defenses were either inapplicable or waived. The Sixth Circuit affirmed the district court’s judgment in all respects. View "Gomez-Echeverria v. Purpose Point Harvesting, LLC" on Justia Law

Reginald Smith, previously convicted of multiple cocaine-related felonies in Florida state court, was arrested in December 2019 after officers investigating illegal hunting found him holding a loaded shotgun. During a search, officers discovered additional ammunition, a hunting knife, and MDMA pills. An agent determined that Smith’s shotgun had traveled in interstate commerce, having been manufactured outside Florida. Smith, as a result, was indicted for possession of a firearm as a felon under 18 U.S.C. § 922(g)(1) and possession of MDMA under 21 U.S.C. § 844(a). He pleaded guilty to both counts.The United States District Court for the Middle District of Florida reviewed Smith’s prior convictions to determine whether they triggered the mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). The court considered evolving precedent—including United States v. Conage and United States v. Jackson—regarding whether certain Florida drug crimes qualified as “serious drug offenses” under ACCA. After law developments clarified that Smith’s two 1993 convictions for selling cocaine and his 2001 conviction for trafficking cocaine were ACCA predicates under Eleventh Circuit precedent, the court applied the ACCA enhancement. Smith was sentenced to 180 months’ imprisonment for the firearm count and 12 months for MDMA possession, to run concurrently. Smith objected to the ACCA enhancement but acknowledged its applicability under current circuit law.The United States Court of Appeals for the Eleventh Circuit affirmed Smith’s conviction and sentence. The court held that § 922(g)(1) did not violate the Second Amendment or Commerce Clause, Smith invited any error regarding ACCA classification of his convictions, the district court’s error under Erlinger v. United States did not affect Smith’s substantial rights, and any error in calculating his base offense level under the Sentencing Guidelines was harmless. View "USA v. Smith" on Justia Law

Two individuals, citizens of Ecuador and Brazil, respectively, entered the United States without inspection in 2001 and 2014. In late 2025 and early 2026, each was arrested by U.S. Immigration and Customs Enforcement and detained, without the possibility of bond, under 8 U.S.C. § 1225(b)(2)(A). This marked a change in government practice, as similar noncitizens had previously been detained or released under 8 U.S.C. § 1226(a), which allows for discretionary bond if the person is not a danger or flight risk. In 2025, the government began applying § 1225(b)(2)(A) to noncitizens already present in the United States who entered without inspection, resulting in mandatory detention without bond.Both individuals filed habeas petitions in the United States District Court for the Eastern District of Pennsylvania, arguing their detentions violated the Immigration and Nationality Act (INA). The district courts granted their petitions, finding that § 1225(b)(2)(A) did not apply to them and that their continued detention without bond violated the INA. One district court also held that such detention violated the Fifth Amendment’s Due Process Clause. Both petitioners were subsequently released, and the government appealed these decisions.The United States Court of Appeals for the Third Circuit reviewed the statutory language and structure of the INA and considered relevant precedent. The court held that § 1225(b)(2)(A) applies only to noncitizens who are both “applicants for admission” and “seeking admission,” meaning those engaged in a present or ongoing attempt to gain lawful entry into the United States. The court concluded that noncitizens already present in the United States who are not actively seeking admission are not subject to mandatory detention under this provision and should be considered under § 1226(a), which allows for bond. The Third Circuit also held that detaining such individuals without a bond hearing violates the Due Process Clause. The court affirmed the district courts’ orders directing the release of the petitioners. View "Morocho v. Warden Philadelphia FDC" on Justia Law

A Jamaican citizen, Jacques, entered the United States as a teenager and overstayed his visa. In 2021, he was arrested in Utah during a traffic stop and pleaded guilty to misdemeanor possession of marijuana with intent to distribute. After serving a suspended sentence and probation, he was detained by Immigration and Customs Enforcement. Jacques applied for withholding of removal, arguing his return to Jamaica would place him in danger due to his mother’s political activities and murder. An Immigration Judge twice granted Jacques’s application for withholding of removal, finding his conviction was not a particularly serious crime barring relief.The Department of Homeland Security (DHS) appealed both grants to the Board of Immigration Appeals (BIA). In both instances, the BIA or DHS failed to send notices of appeal and briefing schedules to the correct detention address, despite having updated information on Jacques’s location. As a result, Jacques was excluded from participating in both appellate proceedings, and did not respond to the appeals or submit briefs. The BIA reversed the Immigration Judge’s decisions each time, determining that Jacques’s conviction constituted a particularly serious crime and denying him withholding of removal.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Jacques’s due process rights were violated because the government failed to serve him with reasonably calculated notice of DHS’s appeals, excluding him from participating in the proceedings. The court further held that Jacques was prejudiced by this deprivation, as the outcome of the appeals may have been affected had he been given notice and an opportunity to respond. The Ninth Circuit granted Jacques’s petition, vacated the BIA’s orders, and remanded with instructions to re-notice the appeal and reissue a briefing schedule to the correct address. View "JACQUES V. BLANCHE" on Justia Law

An organization based in Virginia requested access to Minnesota’s Registered Voter List under a federal statute, asserting it was entitled to the records despite Minnesota’s exemption from the law. Minnesota denied the request, citing its exemption as a state with continuous election-day registration since August 1, 1994. The organization also sought the information under a Minnesota statute, but was again denied because no Minnesota-registered voter joined the request. The organization acknowledged it could obtain the information by recruiting a Minnesota voter but did not do so. It then filed suit, claiming Minnesota’s exemption from the federal disclosure requirement was unconstitutional, alleging informational injury and other adverse consequences.The United States District Court for the District of Minnesota reviewed the case. Minnesota moved to dismiss, and the United States intervened to defend the statute’s constitutionality. The district court dismissed the organization’s claim on the merits, concluding that the “equal sovereignty” principle does not apply to Congress’s authority under the Elections Clause.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether the organization had Article III standing. The court reviewed standing de novo and focused on whether the plaintiff had suffered a concrete injury in fact. The court held that a purely informational injury does not satisfy Article III’s requirements and found the plaintiff’s alleged downstream consequences insufficient, as they lacked a nexus to the interests Congress sought to protect. The court concluded the plaintiff failed to allege a concrete injury and therefore lacked standing.The Eighth Circuit vacated the district court’s judgment and remanded with instructions to dismiss the complaint for lack of jurisdiction. View "Public Interest Legal Foundation, Inc. v. Simon" on Justia Law

The case concerns Cesar Gomez Almonte, who was convicted for his role in an international drug-smuggling conspiracy. Beginning in 2016, conspirators based in the Dominican Republic transported large quantities of cocaine into the United States using boats with secret compartments. Almonte was responsible for procuring and outfitting these vessels. After U.S. officials became aware of the operation, Almonte was indicted under seal in Washington, D.C., and later arrested during a layover at Miami International Airport.The United States District Court for the District of Columbia oversaw Almonte’s trial, during which a jury found him guilty of conspiracy to import cocaine and sentenced him to 184 months in prison. Almonte raised several constitutional claims on appeal: he argued that the 18-month delay between his indictment and arrest violated his Sixth Amendment right to a speedy trial, that venue in D.C. was improper under Article III and 18 U.S.C. § 3238, and that the district court’s refusal to grant a new trial after certain jurors expressed concerns about his counsel denied him an impartial jury.The United States Court of Appeals for the District of Columbia Circuit reviewed these claims. The court held that the delay between indictment and arrest did not violate Almonte’s right to a speedy trial, given the government’s good-faith investigative reasons and his failure to show specific prejudice. On venue, the court found that Almonte waived his only meritorious venue argument regarding the Eastern District of Virginia by not raising it when invited, and his other arguments about venue in Florida were either without merit or forfeited. Regarding juror impartiality, the court concluded that the district court handled the matter appropriately through voir dire and did not abuse its discretion in denying a mistrial or new trial. The judgment of the district court was affirmed. View "USA v. Almonte" on Justia Law

A group of premium cigar manufacturers and trade associations challenged California’s Unflavored Tobacco List statute, which requires tobacco products to be approved and listed by the California Attorney General before they may be sold to consumers, retailers, or wholesalers in the state. To be listed, manufacturers must submit detailed applications and pay fees, certifying their products lack any characterizing flavor. The plaintiffs argued that the law would impose considerable compliance costs, particularly burdensome for the premium cigar industry where products are hand-made in smaller batches and change blends frequently. They asserted that their premium cigars, by federal definition, do not contain flavoring additives, and that the application and fee requirements would force them to reduce their product offerings in California.The plaintiffs sought a preliminary injunction against enforcement of the statute in the United States District Court for the Central District of California. They contended that the federal Family Smoking Prevention and Tobacco Control Act (TCA) expressly preempts California’s law as applied to premium cigars and that the statute’s presumption against flavoring based on manufacturers’ speech violates the First Amendment. The district court denied the motion, concluding the plaintiffs were unlikely to succeed on the merits of their claims.Upon review, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of a preliminary injunction. The appellate court held that the TCA’s Savings Clause exempts state requirements related to the sale of tobacco products from preemption, and the challenged statute falls within this exemption as it is directly tied to retail sales. The court also found that, based on the Attorney General’s representations, the statute imposes only a minimal burden on commercial speech and does not restrict speech more than necessary. Thus, the Ninth Circuit affirmed the denial of injunctive relief. View "ROCKY PATEL PREMIUM CIGARS, INC. V. BONTA" on Justia Law

Several federally licensed firearms dealers (FFLs), including both brick-and-mortar and home-based businesses, gun rights organizations, and private citizens challenged a California statute, Section 26806, which requires all FFLs to maintain a digital video and audio recording system on their business premises. The statute mandates 24/7 surveillance of specific areas, such as points of sale and firearm display areas, and limits when and how recordings may be released or accessed, including requirements for posting notification signs and annual certification of system functionality. Plaintiffs argued that this law infringed their rights under the First, Fourth, and Fifth Amendments by imposing surveillance burdens, chilling speech, violating privacy, and effecting a taking of property.The United States District Court for the Central District of California dismissed the complaint for failure to state a claim. The district court found that Plaintiffs had not sufficiently alleged a likelihood of success on the merits of any claims, denied injunctive relief, and granted leave to amend. Plaintiffs eventually chose not to further amend and requested final judgment, which the district court entered, leading to this appeal.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The court held that Plaintiffs failed to allege a cognizable Fourth Amendment claim because there was no physical government intrusion or access to recordings, nor did mere compliance with the statute transform FFLs into state actors. The court also found no Fifth Amendment violation, as the statute did not result in a physical or regulatory taking; FFLs retained ownership and control over their recording systems, and the economic impact did not rise to a taking. Finally, the court ruled that the First Amendment theories advanced by Plaintiffs—overbreadth, violations of the right to anonymity and association, and chilling of speech—were unsupported because the statute did not regulate or compel speech or disclosure, nor did it plausibly chill protected expression. The Ninth Circuit therefore affirmed the district court’s judgment. View "RICHARDS V. NEWSOM" on Justia Law

A fourteen-year-old student, JPZ, was suspended from school following an altercation. The school principal, Melissa Arendts, notified JPZ's mother and requested JPZ be picked up. Upon arrival, JPZ's grandmother found him isolated and awaiting questioning by Scott Labish, a sheriff’s deputy serving as a school resource officer. Labish, in uniform, questioned JPZ, allegedly in a threatening manner, and told him about a “Three Strike” policy that would result in criminal prosecution and expulsion after another infraction. JPZ became distressed, left school, and subsequently died by suicide at home several hours later. JPZ's father, Brian Zimmermann, as administrator of JPZ’s estate, sued Arendts, Labish, the school district, and Macomb County, alleging federal due process violations and state law claims.The United States District Court for the Eastern District of Michigan dismissed the wrongful death claim but allowed four other claims to proceed: deprivation of substantive due process, conspiracy, intentional infliction of emotional distress, and Monell liability. Defendants moved to dismiss the remaining claims based on qualified and state governmental immunity and deficiencies in the Monell claim. The district court denied these motions in part, leading to an interlocutory appeal by the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial de novo. The Sixth Circuit held that the facts did not support a substantive due process claim under the state-created danger doctrine, as the defendants neither increased JPZ’s risk of harm from a third party nor acted with deliberate indifference. The conspiracy and Monell claims failed because no underlying constitutional violation was adequately alleged. The court also found the defendants entitled to state governmental immunity for the intentional infliction of emotional distress claim, as the conduct alleged did not indicate malice. The Sixth Circuit reversed the district court’s denial of the motions to dismiss and remanded the case. View "Zimmermann v. Labish" on Justia Law