Justia Constitutional Law Opinion Summaries

A woman was the primary caregiver for her friend, residing in her friend’s condominium for several years. After the friend passed away, ownership of the condo transferred to a living trust, and the caregiver became trustee. She continued living in the condo for a month to recover from illness and remove her belongings. The friend’s nephew contacted local police, claiming the right to evict her, and presented officers with a superseded will listing him as a beneficiary but not mentioning the condo. The officers accompanied the nephew to the condo, told the caregiver she had ten minutes to leave, threatened her with arrest, pushed her out, and took her key.The United States District Court for the Southern District of Ohio reviewed the case after the caregiver sued various parties, alleging Fourth Amendment violations. The court granted summary judgment to some defendants but denied it for the officers, reasoning that the caregiver, as trustee, held a possessory interest in the condo, and the officers’ actions constituted active participation in an eviction without proper legal authority. The court relied on Sixth Circuit precedent to find the seizure unreasonable and the right clearly established.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that the caregiver had a possessory interest in the condo at the time of the eviction, the officers actively participated in the eviction, and their conduct was unreasonable under the Fourth Amendment because there was no court order or exigent circumstances justifying the seizure. The court further held that existing precedent clearly established the unlawfulness of the officers’ actions. The Sixth Circuit affirmed the district court’s denial of summary judgment, leaving the officers subject to further proceedings. View "Bender v. Village of Mariemont" on Justia Law

After the 2020 mayoral election in Maricao, Puerto Rico, the Popular Democratic Party candidate, Wilfredo Ruiz-Feliciano, assumed office, replacing the New Progressive Party incumbent. Odette López Collazo, a longstanding NPP member who had served as Internal Auditor since 1994, was not reappointed by the new mayor. López Collazo alleged that her non-reappointment was due solely to her political affiliation and constituted political discrimination in violation of her First and Fourteenth Amendment rights. She also asserted related claims against other municipal officials regarding the failure to pay out her accrued leave, but only the claim against Ruiz-Feliciano for political discrimination remained at issue in this appeal.The United States District Court for the District of Puerto Rico granted summary judgment in favor of Ruiz-Feliciano. The court concluded that First Amendment protections against political discrimination did not apply to a decision not to hire or reappoint, and further reasoned that because the Internal Auditor position was a “trust” position under Puerto Rico law, the mayor could hire and fire at will, including for political reasons. López Collazo moved for reconsideration, which was denied, and then sought partial final judgment under Rule 54(b) to appeal. After resolving procedural questions regarding finality, all claims but the political discrimination claim against Ruiz-Feliciano were dismissed with prejudice, and the appeal proceeded.The United States Court of Appeals for the First Circuit reviewed the district court’s grant of summary judgment de novo. The Court of Appeals held that First Amendment protections do apply to a failure to hire or reappoint a public employee, and that legislative classification of a position as a “trust” position is not dispositive in determining whether political affiliation is an appropriate requirement. The appellate court vacated the district court’s summary judgment and remanded for further proceedings. View "Lopez Collazo v. Ruiz-Feliciano" on Justia Law

Deanthony Cullins was indicted on multiple counts, including malice murder and aggravated assault, stemming from a June 2022 incident in which he was accused of shooting at a vehicle, resulting in the death of Dy’Sheae Hall. Cullins claimed self-defense. In the lead-up to trial, the State sought a continuance days before the scheduled date, citing late receipt of deposition transcripts, but the trial court denied the request. The State also filed an untimely motion to admit other acts evidence, which was denied. During trial, the prosecutor questioned a detective about Cullins’s refusal to make a statement to police, prompting the defense to object on grounds that the questioning improperly commented on Cullins’s right to remain silent. The defense moved for a mistrial, suggesting the prosecutor’s conduct was intentional to provoke a mistrial, and the trial court granted the mistrial.After the mistrial, Cullins filed a plea in bar, arguing that retrial should be barred under the Double Jeopardy Clause because the State had intentionally provoked the mistrial. The Superior Court of DeKalb County held a hearing and found that the prosecutor’s actions were deliberate, noting the State’s lack of readiness for trial, the benefit to the State of a second chance, and the seasoned experience of those involved. The trial court concluded that the State had goaded the defense into seeking a mistrial.On appeal, the Supreme Court of Georgia reviewed whether the trial court clearly erred in finding that the State had intentionally provoked a mistrial. The Supreme Court determined there was evidence to support the trial court’s findings and that they were not clearly erroneous. The Court affirmed the grant of the plea in bar, holding that retrial was barred because the prosecutor’s conduct was intended to provoke a mistrial for a more favorable opportunity to convict. View "STATE v. CULLINS" on Justia Law

A journalist with over twenty-five years of experience covering the Utah Legislature previously received media credentials while working for established news organizations. After founding an independent news outlet, he applied for a media credential under a new policy that categorically excluded bloggers, independent media, and freelance journalists from receiving credentials. This exclusion prevented him from accessing restricted areas and events within the Capitol that were available only to credentialed journalists, limiting his ability to gather news directly from legislative press conferences and availabilities.The plaintiff filed suit in the United States District Court for the District of Utah against legislative officials, alleging that the credentialing policy was unconstitutional as both facial and as-applied viewpoint discrimination under the First Amendment, along with claims of retaliation, prior restraint, and vagueness. The district court dismissed all claims, including denying a preliminary injunction as moot. The court reasoned, in part, that there was no protected speech implicated by the policy and that the plaintiff’s continued reporting without a credential undercut the retaliation claim.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the district court erred in dismissing both the facial and as-applied viewpoint discrimination claims. The appellate court found that the plaintiff plausibly alleged denial of access based on his viewpoint and that the exclusion from a government-created forum for journalists implicated protected speech. The court remanded those claims for further proceedings. The Tenth Circuit affirmed the district court’s dismissal of the retaliation, prior restraint, and vagueness claims, finding no plausible allegation of chilling effect and determining the policy did not regulate expression sufficiently to support a prior restraint or vagueness challenge. View "Utah Political Watch v. Musselman" on Justia Law

Several parents, some acting on behalf of their children, challenged a presidential executive order issued in January 2025. The order declared that children born in the United States to parents who were unlawfully or temporarily present would not be considered “subject to the jurisdiction” of the United States, and therefore would not be entitled to citizenship under the Fourteenth Amendment or the Immigration and Nationality Act. The plaintiffs argued that this order violated both the Constitution and the INA, as it denied citizenship to children based solely on the immigration status of their parents at the time of birth.The United States District Court for the District of New Hampshire reviewed the case and agreed with the plaintiffs. It provisionally certified a nationwide class of children affected by the order and issued a preliminary injunction, blocking enforcement of the executive order. The government appealed, and the Supreme Court of the United States granted certiorari before judgment from the United States Court of Appeals for the First Circuit.The Supreme Court held that children born in the United States to parents who are unlawfully or temporarily present are “subject to the jurisdiction” of the United States, and are entitled to citizenship at birth under the Fourteenth Amendment’s Citizenship Clause. The Court based its holding on the historical understanding of citizenship rooted in the English common law, the repudiation of Dred Scott v. Sandford, and the precedent established in United States v. Wong Kim Ark. The Court affirmed the judgment of the District Court, upholding birthright citizenship for these children. View "Trump v. Barbara" on Justia Law

A group of candidates and political party committees, including then-Senate candidate JD Vance and various Republican campaign committees, challenged federal limits on coordinated campaign expenditures by political parties under the Federal Election Campaign Act (FECA). These limits restrict the amount a party can spend in direct coordination with a candidate’s campaign. Plaintiffs argued that the restrictions violate the First Amendment, especially given modern developments in campaign finance law and enforcement tools such as earmarking and disclosure requirements. JD Vance maintained standing to challenge the law, as he had an active Statement of Candidacy and a campaign committee, despite later becoming Vice President.The case was first reviewed by the en banc United States Court of Appeals for the Sixth Circuit, which upheld FECA’s coordinated-expenditure limits. The Sixth Circuit relied primarily on the Supreme Court’s 2001 precedent, Federal Election Commission v. Colorado Republican Federal Campaign Committee (Colorado II), which had previously sustained these limits against First Amendment challenges. However, several Sixth Circuit judges questioned whether Colorado II remained good law in light of more recent Supreme Court decisions, including McCutcheon v. Federal Election Commission and Federal Election Commission v. Ted Cruz for Senate.The Supreme Court of the United States granted certiorari and ultimately reversed the Sixth Circuit. The Court held that FECA’s limits on political-party coordinated expenditures violate the First Amendment. Applying rigorous scrutiny, the Court determined that the limits are not necessary, narrowly tailored, or proportionate to the government’s interest in preventing circumvention of candidate contribution limits, especially given the effectiveness of existing earmarking rules and disclosure laws. The Court explicitly overruled Colorado II, concluding that subsequent precedents have rendered it obsolete. The judgment of the Sixth Circuit was reversed and the case remanded for further proceedings. View "National Republican Senatorial Committee v. Federal Election Commission" on Justia Law

A state law in West Virginia prohibited male students, as determined by biological sex, from participating on female sports teams. A student who is a biological male but identifies as female and has taken puberty blockers and hormones sought to participate on the girls’ cross-country and track-and-field teams and brought suit against West Virginia officials, alleging violations of Title IX and the Equal Protection Clause. Similarly, Idaho passed a law barring male students from female sports teams; a transgender woman who is a biological male but identifies as female and had taken hormones challenged Idaho’s law after trying out for collegiate women’s sports. Both states justified their laws by referencing inherent physical differences between the sexes and concerns for safety and competitive fairness in women’s sports.The United States District Court for the Southern District of West Virginia granted summary judgment for the state, finding no violation of Title IX or the Equal Protection Clause. The United States Court of Appeals for the Fourth Circuit reversed the ruling on the Title IX claim and remanded for further factual findings on the Equal Protection claim. Meanwhile, in Idaho, the United States District Court for the District of Idaho issued a preliminary injunction against enforcement of the statute; the United States Court of Appeals for the Ninth Circuit affirmed that decision, finding a likely violation of the Equal Protection Clause.The Supreme Court of the United States reversed both appellate court decisions. It held that Title IX permits schools to maintain separate men’s and women’s sports teams determined by biological sex and does not require exceptions for transgender athletes, regardless of puberty blockers or hormone use. The Court further held that the Equal Protection Clause does not bar states from limiting female sports teams to biological females, finding the sex-based classification substantially related to important government interests in safety and competitive fairness. The cases were remanded for further proceedings consistent with this opinion. View "West Virginia v. B. P. J." on Justia Law

Three property owners in Oregon alleged that the federal government committed a taking of their property rights under the Fifth Amendment when the Surface Transportation Board (STB) issued a Notice of Interim Trail Use or Abandonment (NITU) involving a railroad corridor that crossed their properties. The corridor, previously used for freight trains by the Port of Tillamook Bay Railroad (POTB), was also leased to the Oregon Coast Scenic Railroad (OCSR), which operated a scenic passenger-excursion service both before and after the NITU was issued. After severe storm damage in 2007, POTB ceased freight operations, but OCSR continued using the corridor under its lease, which extended at least until 2026.The United States Court of Federal Claims previously found that a taking had occurred due to the issuance of the NITU. The case then proceeded to a valuation phase to determine just compensation. The Court of Federal Claims ruled that the property owners did not meet their burden to prove that the NITU caused a reduction in the fair market value of their land. The court found that the “before” condition for valuation properly included OCSR’s ongoing operations, and that the property owners failed to show an actual market value loss resulting from the NITU and the new trail-use easement.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Court of Federal Claims’ judgment. The Federal Circuit held that the “before” condition for compensation must reflect the ongoing encumbrance of the scenic railroad’s operations, as the lease and use by OCSR would have existed regardless of the NITU. The court also concluded that the property owners had not proven with reasonable certainty any diminution in market value attributable to the NITU or the trail easement, and thus were not entitled to compensation. The judgment was affirmed. View "LOVERIDGE v. US " on Justia Law

Several proposed initiatives regarding Colorado’s congressional redistricting were submitted for review by the state’s Title Board. Initiative #241 sought to replace the Colorado constitutional independent congressional redistricting commission with an identical commission established by statute, but made its effectiveness contingent on the passage of Initiative #242. Initiative #242, in turn, proposed to create a new temporary congressional district map for the 2028 and 2030 elections, and would only take effect if Initiative #241 was also adopted. Initiative #328, which was similar in structure to #242 but provided a different map, was likewise conditioned on the passage of Initiative #241.The Title Board, after initial hearings, determined by unanimous vote that both Initiative #241 and #242 each contained a single subject and set their respective titles. Motions for rehearing were denied by a two-to-one vote. Petitioner Robert Balink challenged these decisions before the Colorado Supreme Court, arguing that conditioning the effectiveness of each measure on the passage of the other violated the constitutional single subject rule. For Initiative #328, the Title Board declined to set a title, finding that it did not constitute a single subject because it was expressly contingent on the passage of a separate measure, and denied a rehearing.On review, the Supreme Court of Colorado held that an initiative violates the single subject requirement of article V, section 1(5.5) of the Colorado Constitution and section 1-40-106.5, C.R.S., when its effectiveness is conditioned on the passage of a separate initiative. The court reasoned that such interdependence creates multiple subjects, as each measure’s effect is not properly and necessarily connected to the other. As a result, the court reversed the Title Board’s decision to set titles for Initiatives #241 and #242 and affirmed the Board’s refusal to set a title for Initiative #328. View "Balink v. Nathan" on Justia Law

A man was stopped by police late at night after an officer observed him allegedly fail to signal 100 feet before making a left turn, as required by Illinois law. After he parked in a strip mall lot, officers initiated a traffic stop and asked for his license and proof of insurance. The driver’s insurance card was expired, prompting him to exit the car to call someone for updated proof. While the stop was ongoing, another officer arrived with a drug-sniffing dog, which alerted to narcotics outside the vehicle. Police then searched the car and found a handgun hidden in the center console, but no drugs. The driver was arrested and charged with being a felon in possession of a firearm.The United States District Court for the Central District of Illinois denied the defendant’s motion to suppress the handgun, finding the officer’s testimony credible enough to establish reasonable suspicion for the traffic stop and that the stop was not impermissibly prolonged. It also found the dog’s alert provided probable cause to search the vehicle. At trial, the court denied the defendant’s motion for a directed verdict, ruling there was sufficient evidence for the jury to convict him. The defendant’s post-trial motion for a new trial was also denied.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not clearly err in crediting the officer’s testimony about the traffic violation, that the duration of the stop was not unreasonably extended, and that the dog’s alert provided probable cause for the search. The court also found that there was sufficient evidence to support the conviction for knowing possession of a firearm by a felon. The judgment was affirmed. View "USA v. Banks" on Justia Law