Justia Constitutional Law Opinion Summaries

J.O. has been under a conservatorship since 2016, with the San Joaquin County Public Conservator serving as his conservator and represented by County Counsel. In December 2023, Judge Guy Castillo began presiding over most mental health cases in the San Joaquin County Superior Court. Starting in May 2024, County Counsel adopted a practice of filing “blanket” motions under Code of Civil Procedure section 170.6 to disqualify Judge Guy Castillo from all cases involving the Public Conservator. On July 10, 2024, County Counsel filed both a petition to extend J.O.’s conservatorship and a section 170.6 motion; the motion was initially denied as premature. J.O. subsequently sought to have the Public Conservator removed and his sister appointed. County Counsel filed another section 170.6 motion, which was granted, removing Judge Guy Castillo from J.O.’s case. J.O. objected, arguing the blanket challenges were improper and aimed at forcing Judge Guy Castillo’s reassignment following her admonishment of County Counsel’s attorney; Judge Guy Castillo was later reassigned.The San Joaquin County Superior Court overruled J.O.’s objection, relying on Solberg v. Superior Court, which permitted blanket section 170.6 challenges. The California Court of Appeal denied writ relief. The Supreme Court of California granted review, overruling Solberg in part, and held that blanket abuses of section 170.6 could unconstitutionally interfere with core judicial functions and are subject to as-applied separation-of-powers challenges. The Supreme Court established a burden-shifting procedure to evaluate whether such challenges are made in bad faith and remanded the matter to the Court of Appeal for further proceedings.The Court of Appeal of the State of California, Third Appellate District, determined the case was not moot and issued a writ directing the Superior Court to vacate its order granting County Counsel’s section 170.6 motion. The court ordered a hearing consistent with the Supreme Court’s procedure to determine whether County Counsel’s motion was made in bad faith. View "J.O. v. Super. Ct." on Justia Law

The Secretary of Homeland Security invoked Section 102 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 to initiate a border construction project in the Big Bend Sector along the U.S.–Mexico border. Determining this area to be one of high illegal entry, the Secretary exercised statutory authority to waive several environmental and conservation laws to expedite construction. Subsequently, an individual river guide, an environmental nonprofit, and a historic church preservation organization filed suit, challenging the Secretary’s waiver determinations. Their claim focused on the argument that the Secretary violated the major questions doctrine under Article I, Section 1 of the Constitution, contending that the waivers exceeded statutory authority.The United States District Court for the Western District of Texas issued a preliminary injunction, halting the Secretary’s waivers and associated border construction. The court acknowledged its jurisdiction was limited to constitutional claims but concluded that the major questions doctrine constituted a constitutional clear statement rule, grounded in separation of powers, thus qualifying as a constitutional claim. The court additionally found that the respondents’ major questions doctrine claim was likely to succeed, reasoning that the Secretary lacked clear congressional authorization to issue the waivers.The Supreme Court of the United States reviewed an application for stay of the District Court’s injunction. The Court granted the stay, holding that the District Court lacked jurisdiction to adjudicate the respondents’ major questions doctrine claim, as the claim did not allege a violation of the Constitution but instead challenged the Secretary’s statutory authority. The Court emphasized that claims asserting the Executive exceeded statutory authority are not constitutional claims, and that the major questions doctrine is a canon of statutory interpretation, not a constitutional cause of action. The Supreme Court also found that the balance of equities favored the Government, given Congress’s clear preference for expeditious border construction. The injunction was stayed pending further proceedings. View "Mullin v. Friends of the Ruidosa Church" on Justia Law

A real estate developer in Michigan entered into a lease agreement with a machinery manufacturer, promising to construct a facility on its property within a tight ten-month timeline. The property lacked access to a public sewer, requiring the developer to obtain a septic permit from the county health division before construction could begin. The developer and the township attempted to negotiate an arrangement to allow construction to proceed without the permit, but negotiations failed. The developer applied for necessary site plan approvals and began the permitting process, but did not combine lots as required by the health division, resulting in delays. Eventually, the lease was terminated after construction could not proceed on schedule.The developer filed suit in the United States District Court for the Eastern District of Michigan against the township and its supervisor, alleging violations of equal protection, due process, and First Amendment retaliation under 42 U.S.C. § 1983, along with a state-law claim. The district court granted summary judgment in favor of the defendants on all federal claims except for one First Amendment retaliation claim and the state-law claim, which settled before trial. The developer appealed the district court’s summary judgment rulings on its equal protection, due process, and First Amendment retaliation claims.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The Sixth Circuit affirmed the district court’s judgment, holding that the township had a rational basis for its permitting decisions, did not deprive the developer of a protected property interest without due process under Michigan law, and imposed constitutionally permissible, content-neutral restrictions on communications to comply with Michigan’s Open Meetings Act. The court concluded that no constitutional violations occurred and affirmed summary judgment for the township and its supervisor. View "GSL Holdings, LLC v. Charter Township of Lyon Township" on Justia Law

A group of nine tenured professors at a public Kansas university were terminated after the Kansas Board of Regents (KBOR) temporarily amended its policy, citing COVID-19-related financial pressures. The amendment permitted universities to suspend or terminate tenured faculty without the usual protections, including hearings or proof of financial exigency. ESU administrators drafted a framework for implementing these terminations, which KBOR approved. The professors received termination letters referencing general financial concerns, but allegedly lacking specific reasons. The professors claimed ESU was not facing financial exigency, and that their terminations were motivated by their political activities and beliefs. All nine appealed through the Office of Administrative Hearings (OAH); six had their terminations reversed and three had them affirmed. Litigation ensued, with the professors asserting constitutional violations under 42 U.S.C. § 1983, including due process, liberty, association, and equal protection claims.The United States District Court for the District of Kansas denied the defendants’ motion to dismiss most claims, finding that qualified immunity did not bar them. It ruled the professors had adequately alleged deprivation of a property interest in continued employment without due process and allowed other constitutional claims to proceed. The court dismissed liberty interest claims against KBOR and some administrators where no statements were attributed to them, but denied dismissal for others allegedly involved in drafting termination letters.The United States Court of Appeals for the Tenth Circuit reviewed the appeal at the motion-to-dismiss stage, adopting facts as alleged. It held that the professors had a state-created property interest in tenure and that the process used to terminate their employment plausibly violated clearly established procedural due process rights. The court affirmed denial of dismissal for procedural due process and related conspiracy claims, but reversed as to substantive due process claims, finding no clearly established violation. It also reversed denial of dismissal for liberty, association, equal protection, and conspiracy claims against KBOR and certain administrators, instructing the district court to dismiss those claims, while leaving claims against the university president intact. View "Miracle v. Hush" on Justia Law

Several chambers of commerce and business associations challenged two California statutes—the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261)—on First Amendment grounds. SB 253 requires large companies to annually disclose greenhouse gas emissions in three categories: Scope 1 (direct emissions from owned or controlled sources), Scope 2 (indirect emissions from purchased energy), and Scope 3 (indirect emissions throughout the company’s value chain, including suppliers and customers). SB 261 mandates covered companies to publicly disclose climate-related financial risk information, including assessments about their exposure to climate change and related business impacts.The United States District Court for the Central District of California denied the plaintiffs’ motion for a preliminary injunction. The court determined that both SB 253 and SB 261 regulate commercial speech and thus are not subject to strict scrutiny. Applying intermediate scrutiny and, for SB 253, the more deferential Zauderer standard, the district court found that both statutes reasonably advance California’s substantial interests such as providing investors with information and reducing emissions. It concluded that the plaintiffs were unlikely to succeed on their First Amendment claims and failed to meet the other requirements for preliminary relief.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of injunctive relief. The Ninth Circuit affirmed the denial as to SB 253’s Scope 1 and Scope 2 disclosure requirements, holding these provisions regulate commercial speech and withstand intermediate scrutiny. However, it reversed the denial as to SB 253’s Scope 3 disclosure requirement and SB 261 in its entirety. The court found that Scope 3 disclosures and SB 261 compel noncommercial speech subject to strict scrutiny, which the State could not satisfy. The case was remanded for the district court to determine whether SB 253’s Scope 3 disclosure provisions are severable. View "UNITED STATES OF AMERICA CHAMBER OF COMMERCE V. SANCHEZ" on Justia Law

A homeowner in Meridian, Idaho, rented space on his property to the owner of a mobile tiny home, which was certified as a recreational vehicle and hooked up to utilities. Shortly after the tiny home was installed, a neighbor complained to the city’s code enforcement office. The city investigated both the property with the tiny home and another nearby property, determining that the tiny homes violated city ordinances because they were not affixed to improved foundations and were being used as residences outside of approved RV parks. The city issued notices of violation and orders to abate. The property owner erected a privacy fence and claimed the tiny home was vacated, but city officials remained unconvinced.The property owner and the tiny home’s owner filed suit in the District Court of the Fourth Judicial District of Idaho, Ada County. Their amended complaint challenged several city code provisions on substantive due process grounds and alleged selective enforcement under the Idaho Constitution’s equal protection clause. After a bench trial, the district court dismissed the substantive due process claims as moot, finding that even if some ordinances were unconstitutional, the plaintiffs would still be denied a permit due to the unified ownership requirement. It also dismissed the selective enforcement claim with prejudice, finding no disparate treatment as enforcement was triggered by a neighbor's formal complaint.The Supreme Court of the State of Idaho reviewed the case. It affirmed the district court’s dismissal of the substantive due process claims, but on ripeness grounds rather than mootness, holding that the plaintiffs’ pre-application challenge was too speculative for judicial review since they had not actually applied for a permit. The court also affirmed the dismissal of the equal protection claim, finding substantial evidence supported the district court’s conclusion that enforcement was based on a formal complaint rather than unconstitutional selective enforcement. Costs were awarded to the city. View "Decker v. City of Meridian" on Justia Law

During the summer of 2018, housing advocates interacted with tenants at the Yale Park Apartment Complex in Omaha, documenting alleged building code violations and submitting complaints to the City. Based largely on this information, the City’s Chief Housing Inspector applied for and received an inspection warrant. Subsequent searches led to the closure of the complex, and tenants were forced to relocate. The City later provided AB Realty, LLC—the owner—and Kay and Janae Anderson with a list of violations and barred reopening until repairs were made. AB Realty attempted to challenge the closure through the Property Management Appeals Board and faced ongoing notices and prosecution for code violations. After completing repairs and reopening the complex in 2021, AB Realty and the Andersons initiated a lawsuit.The United States District Court for the District of Nebraska granted the defendants’ motion to dismiss in part and stayed proceedings pending the outcome of Kay Anderson’s criminal trial. After a state-court jury convicted Kay on a few counts but acquitted him of most, the district court dismissed the remaining claims against the City of Omaha and associated defendants.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The court held that the search warrant, even excluding disputed information, was supported by probable cause based on the complaints and evidence of violations. It further determined that violations of Nebraska state law regarding warrants did not sustain a federal constitutional claim under 42 U.S.C. § 1983. The court also found AB Realty’s procedural due process allegations insufficiently specific to identify constitutionally protected interests or responsible parties. Finally, the court ruled that AB Realty failed to plead either a per se or regulatory taking under the Fifth Amendment, as the City did not physically appropriate the property and the closure for code violations did not constitute a regulatory taking. All claims against all defendants were dismissed. View "AB Realty, LLC v. Lane" on Justia Law

A prison inmate was transferred from Phillips State Prison in Georgia, where he had stabbed a high-ranking member of the Bloods gang, to Baldwin State Prison after being placed in protective custody due to the imminent threat of retaliation. The transfer request cited his need for mental health services and mentioned the risk posed by his known enemy, but did not specify risks at Baldwin. Upon arriving at Baldwin, the inmate was placed in the general population, and after briefly requesting protective custody—which he later withdrew—he was stabbed to death by another inmate, allegedly a Bloods member. The parents and estate of the deceased sued five Georgia Department of Corrections officials, alleging that each was deliberately indifferent to the risk of harm under the Eighth Amendment.The United States District Court for the Middle District of Georgia initially dismissed certain wrongful death claims as time-barred, but allowed Eighth Amendment claims by the estate against all five defendants to proceed. The district court ultimately granted summary judgment in favor of the defendants, holding that each was entitled to qualified immunity because there was no violation of clearly established law and no evidence of subjective awareness by any defendant that their conduct caused a substantial risk of harm.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s rulings de novo. The Eleventh Circuit affirmed the district court’s judgment, holding that none of the defendants possessed the requisite subjective knowledge that their actions or inactions placed the inmate at substantial risk of serious harm. Applying the deliberate indifference standard established in Wade v. McDade and Farmer v. Brennan, the court concluded that all defendants were protected by qualified immunity, as there was no constitutional violation. View "McClinton v. Warden" on Justia Law

A nonprofit organization planned to run several political advertisements critical of socialism and the Democratic Socialists of America ahead of the 2025 New York City Mayoral Election. New York’s independent expenditure disclosure law, which requires entities spending money on political elections to register and disclose information about their expenditures, was interpreted by state regulators to cover these advertisements, as the only citywide candidate affiliated with the DSA was running for mayor. The organization feared enforcement of the law against its ads and sought judicial relief.After filing its complaint in the United States District Court for the Southern District of New York, the organization moved for a preliminary injunction to prevent the State from enforcing the disclosure law against its advertisements before the upcoming election. The district court denied this emergency motion. The organization then appealed the denial to the United States Court of Appeals for the Second Circuit while the underlying challenge to the law was stayed in the district court at the organization’s request.The United States Court of Appeals for the Second Circuit dismissed the appeal as moot. The court explained that the motion for preliminary injunction sought relief only for an injury related to the 2025 mayoral election, which had already occurred, making it impossible for the appellate court to grant effectual relief. The court further held that the “capable of repetition, yet evading review” exception to mootness did not apply because the underlying action remained pending in the district court, and thus could still be litigated and reviewed in the future. The appeal was therefore dismissed for lack of a live controversy, with instructions that any future appeals concerning preliminary injunctions in this matter would be heard by the same panel. View "Am. Future Fund, Inc. v. N.Y. Bd. of Elections" on Justia Law

In December 2024, Colton Kenneth Defoe was stopped by a McKenzie County Sheriff’s officer due to an outstanding warrant. The officer cleared Defoe’s vehicle of other passengers and used a K-9 unit to inspect the car, which resulted in an alert for narcotics. A search revealed a plastic baggie and a bindle, both containing methamphetamine residue, and a plastic tube with burn marks. Although Defoe and his passengers denied possession, lab tests confirmed methamphetamine in both the baggie and the bindle, while the tube yielded inconclusive results. No gabapentin was detected, contrary to initial suspicions.Defoe was charged in the District Court of McKenzie County, Northwest Judicial District, with possession of methamphetamine, possession of drug paraphernalia, and driving under suspension. Two additional charges were dismissed before trial. The jury found Defoe guilty on all counts, and the district court entered judgment. Defoe appealed, arguing improper jury instructions deprived him of due process and that there was insufficient evidence to support his convictions. He did not object to the jury instructions at trial but argued the issue in his Rule 29 motion for acquittal, which was denied.The Supreme Court of North Dakota reviewed the appeal. It held that Defoe had not preserved any challenge to the jury instructions for appellate review, as he failed to object distinctly and specifically as required under N.D.R.Crim.P. 30(c). The Court also found no plain error in the instructions, concluding they accurately stated the law and did not mislead the jury. Additionally, the Court determined that substantial evidence supported the jury’s verdicts. The criminal judgment was affirmed. View "State v. Defoe" on Justia Law