Justia Constitutional Law Opinion Summaries

The case centers on a challenge to a state law enacted in 2023, which prohibits health care providers from administering certain types of gender-affirming medical treatments to minors, including puberty blockers and cross-sex hormones, for the purpose of aligning a minor’s sex with their gender perception when inconsistent with their biological sex. Exceptions exist for minors with medically verifiable disorders of sex development and for those already receiving such treatments prior to the law’s effective date. Three minors, their parents, and a physician, Dr. Casas, who treats minors with gender dysphoria, initiated legal proceedings seeking declaratory and injunctive relief, arguing the law violates the North Dakota Constitution.The District Court of Burleigh County reviewed the case. It dismissed the minor plaintiffs and their parents for lack of standing, based on its interpretation that the law did not apply to minors receiving treatment before the effective date. The court found Dr. Casas had standing to pursue certain claims, including equal protection and personal autonomy on behalf of his patients, but not parental rights claims. After a seven-day trial and extensive evidence, the court concluded the law responded to legitimate concerns regarding the risks and effectiveness of gender-affirming treatments for minors and determined the statute did not violate constitutional guarantees of equal protection or personal autonomy. The court denied declaratory and injunctive relief, but clarified the law’s exception for ongoing treatment.On appeal, the Supreme Court of North Dakota addressed only whether the statute’s prohibition on gender-affirming medication for minors violates Article I, §§ 1 or 21 of the state constitution. The court held that minors do not have a fundamental right to a particular course of medical treatment under Article I, § 1. It further found the law does not classify based on sex or transgender status and is subject to rational basis review. The statute was deemed rationally related to the state’s legitimate interest in protecting minors’ health and welfare. The court affirmed the district court’s denial of relief. View "T.D. v. Wrigley" on Justia Law

The defendant was living with his romantic partner, C.P., when an argument escalated into physical and verbal abuse. During the incident, he forcibly cut C.P.’s hair, took her designer handbags and jewelry, threatened to harm her and her family if she reported him to police, forced her to withdraw cash from an ATM, and left with her possessions and car. C.P. reported the incident roughly a week later.The Superior Court of the District of Columbia indicted the defendant on eleven counts, but the jury convicted him of only two: first-degree theft and threatening to injure or kidnap a person. The court sentenced him to concurrent terms of twenty-eight months’ imprisonment, followed by three years’ supervised release, and ordered restitution of $3,638.60 for stolen property. The court also imposed assessments of $1,000 for each conviction under the Victims of Violent Crime Compensation Act (VVCCA). The defendant did not object to the VVCCA assessments at sentencing but timely appealed, arguing that the assessments constituted excessive fines in violation of the Eighth Amendment.The District of Columbia Court of Appeals reviewed the case. Applying the gross disproportionality standard articulated by the Supreme Court in United States v. Bajakajian, the court considered the nature and gravity of the offenses, the statutory penalties, the defendant’s culpability, and the harm suffered by the victim. The court concluded that the $2,000 in VVCCA assessments was not grossly disproportional to the gravity of the defendant’s offenses, especially given the statutory maximum fines and the significant harm caused. The court therefore held the assessments were constitutional and affirmed the judgment of the Superior Court. View "Delgado v. United States" on Justia Law

The defendant, a Maine resident with multiple prior felony convictions, was arrested after a state trooper observed him at a gas station and detained him based on an active felony warrant. During the arrest, Levasseur admitted to possessing a hunting rifle in his truck, which was loaded, and to having methamphetamine in the vehicle. He later stated he intended to hunt deer for food, although he lacked a hunting license, and disclosed a daily methamphetamine addiction. His criminal history included three illegal firearm possession convictions and other felonies, including drug possession and bail violations.A grand jury indicted Levasseur for possessing a firearm as a felon under 18 U.S.C. § 922(g)(1). He moved to dismiss the indictment in the United States District Court for the District of Maine, arguing the statute was unconstitutional as applied to him under the Second Amendment, referencing New York State Rifle & Pistol Ass’n v. Bruen and later United States v. Rahimi. The district court denied both his initial and renewed motions, ruling that his felony conviction for methamphetamine possession rendered him sufficiently dangerous to be disarmed under the Second Amendment, based on historical analogues of disarming categories of dangerous individuals.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s legal rulings de novo. The First Circuit assumed, without deciding, that the Second Amendment could apply to individuals with felony convictions and entertained Levasseur’s as-applied challenge. The court held that Levasseur failed to demonstrate error in the district court’s determination that he could constitutionally be disarmed due to posing a special danger of misusing firearms. Accordingly, the First Circuit affirmed his conviction, holding that 18 U.S.C. § 922(g)(1) is constitutional as applied to him. View "US v. Levasseur" on Justia Law

Three individuals alleged that New Jersey child protection caseworkers violated their constitutional rights during investigations into suspected child abuse. The caseworkers entered the plaintiffs’ home without a warrant, pressured them to sign family agreements under threat of child removal, and ultimately removed the children from parental custody without prior court authorization. The removal was based on concerns about one parent’s alleged past violence, home conditions, and another parent’s mental health history. The plaintiffs claimed these actions violated their Fourth Amendment rights and their substantive and procedural due process rights under the Fourteenth Amendment.The United States District Court for the District of New Jersey dismissed the complaint, finding the defendants were entitled to qualified immunity. The court relied on facts outside the complaint, including allegations from a child abuse report and statements from caseworkers, to support its ruling. The District Court also dismissed claims for money damages against the Division and its employees in their official capacities and found one plaintiff lacked standing. On appeal, the United States Court of Appeals for the Third Circuit reviewed the dismissal de novo, considering only the facts alleged in the complaint and not external materials.The Third Circuit affirmed the dismissal of most claims, including the substantive and procedural due process claims, holding that the law was not clearly established to put the defendants on notice that their conduct violated constitutional rights. However, the court reversed the dismissal of the Fourth Amendment claim against the caseworker who entered the home without a warrant. The court held that the plaintiffs plausibly alleged a violation of clearly established Fourth Amendment law, and that qualified immunity did not shield the caseworker from liability on this claim. The case was remanded for further proceedings on the Fourth Amendment claim. View "O'Bryant v. DCP&P" on Justia Law

Police officers observed a man and his girlfriend in a car at a location known for drug trafficking. After smelling marijuana and spotting evidence of its use in the vehicle, the officers approached the man inside a store, where he consented to a pat-down search that yielded nothing. Outside the store, the couple initially consented to a search of the car but later revoked consent, leading the officers to arrest and handcuff the man. He was searched again on the hood of the car, with no contraband found. The officers then transported him to the police station, where they conducted a strip search solely for evidence, but nothing was recovered.The U.S. District Court for the Middle District of Pennsylvania reviewed the man’s federal civil-rights claims under 42 U.S.C. § 1983, challenging the stop, arrest, and three searches as unreasonable under the Fourth Amendment and retaliatory under the First Amendment. The District Court granted summary judgment to the officers on all federal claims, finding the initial stop, arrest, and first two searches reasonable, and the strip search protected by qualified immunity. It dismissed the state-law claims for lack of supplemental jurisdiction.The United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that while the initial stop, arrest, and two searches were reasonable, the search-incident-to-arrest doctrine does not justify strip searches outside of a jail or prison without a warrant, exigent circumstances, or consent. A warrant supported by probable cause is required for strip searches in such contexts. However, because this legal limitation was not clearly established at the time, the officers were entitled to qualified immunity. The court also concluded that the First Amendment retaliation claim was barred by qualified immunity. View "Beatty v. Gardner" on Justia Law

The defendant engaged in repeated threatening communications directed at two members of Congress, including violent voicemails and explicit threats to harm and kill them. These actions occurred over a period from 2022 to 2024, escalating in severity, culminating in a particularly violent message in July 2024. The defendant pleaded guilty to transmitting a threat in interstate commerce based on the July 2024 voicemail.The United States District Court for the Eastern District of Tennessee sentenced the defendant to twenty-four months’ imprisonment and one year of supervised release. As a condition of supervised release, the court imposed a broad ban prohibiting any contact with all members of Congress, directly or indirectly, including through third parties and social media, regardless of the nature or purpose of the communication. The district court stated the condition was necessary to protect the public and deter similar conduct. The defendant did not object at sentencing but timely appealed, arguing the condition was overly broad and infringed his First Amendment rights.The United States Court of Appeals for the Sixth Circuit reviewed the supervised release condition for plain error, due to the lack of objection below. The court found that the district court’s condition was overly broad and constituted error, as it imposed a greater deprivation of liberty than was reasonably necessary and burdened constitutional rights, including the right to petition Congress. However, the Sixth Circuit concluded that the error was not obvious or clear under existing law, since there was no binding precedent directly addressing such a broad restriction in this specific context. Therefore, the court affirmed the district court’s decision, holding that while the supervised release condition was erroneous, it did not meet the stringent requirements for plain error reversal. View "United States v. Hayes" on Justia Law

Several owners of shoreline properties along Lake Austin challenged a 2019 ordinance enacted by the City of Austin. The ordinance declared that their properties had always been within Austin’s full-purpose jurisdiction, repealed a 1986 ordinance that had previously classified the properties as limited-purpose (which restricted taxation until city services were provided), and subjected the properties to full taxation. The plaintiffs alleged that Austin taxed their properties as if they were full-purpose residents but provided fewer municipal services than other full-purpose residents, raising federal and state law claims.Initially, the United States District Court for the Western District of Texas dismissed all claims under the Tax Injunction Act. On appeal, the United States Court of Appeals for the Fifth Circuit reversed the dismissal of all but two claims and remanded the case. Upon remand, the City reasserted several grounds for dismissal, including the political-question doctrine, Pullman abstention, Burford abstention, and failure to state a claim. The magistrate judge recommended Pullman abstention, which the district court adopted, dismissing the claims without prejudice and entering final judgment. The plaintiffs appealed again.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision and held that the case was not moot, as recent state legislation neither refunded taxes nor automatically disannexed the properties. The Fifth Circuit concluded that Pullman abstention was inappropriate because the plaintiffs’ federal equal protection claim did not hinge on any uncertain or disputed question of Texas law. Accordingly, the Fifth Circuit reversed the district court’s judgment and remanded the case for consideration of the City’s remaining grounds for dismissal, expressly declining to reach those grounds itself. View "Harward v. City of Austin" on Justia Law

Police officers investigating a suspicious package at a UPS facility in Pennsylvania found it to be heavily taped, sent by next-day air, and addressed to a likely fake recipient. A drug-sniffing dog alerted to the presence of drugs, and a subsequent search warrant revealed six pounds of methamphetamine inside the box. To identify the intended recipient, officers sought and obtained a GPS tracker order and a search warrant for Apartment 2 at the delivery address. The officer’s affidavit also requested permission to secure the package at any secondary location, but neither the warrant nor the tracker order explicitly authorized entry into other residences.When the package was delivered, Davone Walker took it into Apartment 1, a different apartment in the same building. Officers waited but did not see the box opened. Eventually, they entered Apartment 1 without a warrant specific to that location, secured the scene, and applied for a new warrant, which permitted a search of Apartment 1. The search uncovered substantial quantities of methamphetamine, fentanyl, cocaine, and drug paraphernalia. Walker was charged with drug offenses and moved to suppress the evidence, arguing the original warrant did not cover Apartment 1 and the tracker order gave no authority for entry.The United States District Court for the Eastern District of Pennsylvania denied Walker’s suppression motion. It found that the officer’s belief he was authorized to enter Apartment 1 was unreasonable, but concluded the mistake was isolated negligence, not grossly negligent or deliberate misconduct warranting exclusion.The United States Court of Appeals for the Third Circuit reviewed the facts for clear error and legal conclusions de novo. It held that suppression is reserved for deliberate, reckless, or grossly negligent misconduct, not isolated mistakes. Finding Trooper Montz’s error to be, at most, isolated negligence, the court affirmed both the denial of Walker’s suppression motions and his conviction. View "USA v. Walker" on Justia Law

During the COVID-19 pandemic, Dr. Scott Jensen, a physician and former Minnesota state senator, publicly voiced opposition to vaccine mandates and business closures. As a Republican candidate for governor in 2022, he became the subject of 18 complaints alleging he spread misinformation and endangered public health. The Minnesota Board of Medical Practice initiated four investigations, each requiring Jensen to respond and cooperate fully, including providing documents and hiring legal counsel. One investigation lasted over a year and demanded an in-person conference. Jensen claims these investigations caused him to spend substantial time and money, self-censor his public statements, and decline speaking engagements due to fear of professional repercussions.The United States District Court for the District of Minnesota dismissed Jensen’s amended complaint for lack of standing, finding his allegations “too conclusory” and lacking specific instances of chilled speech or imminent enforcement threats. The court determined he did not demonstrate injury sufficient to invoke federal jurisdiction, thus preventing further review of his constitutional claims seeking damages and injunctive relief.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal. It found that Jensen’s general factual allegations of time, money spent, and self-censorship—the chilling effect—were sufficient to establish standing at the pleading stage. The court concluded that both monetary harms and reasonable self-censorship due to credible threats of enforcement constituted concrete and particularized injuries. The appellate court held that Jensen had standing to pursue his claims for damages and injunctive relief. The judgment of the district court was reversed and the case remanded for further proceedings on the merits. View "Jensen v. Minn. Bd. of Medical Practice" on Justia Law

An association composed of parents, students, and concerned citizens filed suit under 42 U.S.C. § 1983, challenging student speech policies adopted by a New York school district. The association claimed that these policies violated the First and Fourteenth Amendment rights of its members’ children by chilling their ability to express certain social and political views in school. The association sought a preliminary injunction against enforcement of the challenged policies, arguing that the speech codes were impermissibly overbroad, vague, and compelled students to affirm views with which they disagreed.The United States District Court for the Southern District of New York denied the motion for a preliminary injunction and dismissed the action for lack of subject matter jurisdiction. The district court relied on Aguayo v. Richardson, 473 F.2d 1090 (2d Cir. 1973), which held that associations lack standing to sue on behalf of their members under § 1983. The association appealed to the United States Court of Appeals for the Second Circuit, but, acknowledging Aguayo, moved for summary affirmance, which the Second Circuit granted. Subsequently, the association petitioned for reconsideration en banc, asking the Court to overrule Aguayo.The United States Court of Appeals for the Second Circuit, after circulating the opinion to all active judges and receiving no objection, overruled Aguayo’s bar on associational standing under § 1983. The Court adopted the Supreme Court’s rule from Hunt v. Washington State Apple Advertising Commission, 432 U.S. 333 (1977): a membership organization has standing to sue on behalf of its members under § 1983 if (1) members have standing to sue in their own right; (2) the interests are germane to the organization's purpose; and (3) individual member participation is unnecessary. The Second Circuit reversed the district court’s dismissal and remanded for further proceedings. View "Defending Education v. Croton-Harmon Union Free School District" on Justia Law