Justia Constitutional Law Opinion Summaries

Several individuals and a nonprofit organization in Minnesota, focused on election integrity, wished to publicly advocate their interpretation that certain felons—specifically those still on supervised release—are constitutionally ineligible to vote in Minnesota. State law, however, allows felons to vote once released from incarceration, regardless of whether they are on parole or probation. Concerned about possible prosecution under a Minnesota statute that criminalizes knowingly false statements about voter eligibility made within 60 days of an election, the plaintiffs sought to continue their advocacy without facing criminal or civil penalties.After the Minnesota Supreme Court held that the group lacked standing to challenge the felon voting law in state court, the plaintiffs filed suit in the United States District Court for the District of Minnesota. They sought declaratory and injunctive relief against the enforcement of the election disinformation statute, arguing it violated the First Amendment. In response, the Anoka County Attorney filed a counterclaim, seeking to restrain the plaintiffs from violating the law and to obtain damages. The district court dismissed the plaintiffs’ complaint and denied a preliminary injunction, concluding that the law could constitutionally restrict their speech. The plaintiffs appealed the denial of a preliminary injunction while the counterclaim remained pending.The United States Court of Appeals for the Eighth Circuit reviewed the denial of preliminary injunctive relief and found that the plaintiffs had standing due to both actual and imminent injuries. The court held that the statute at issue regulated protected political speech based on its content and was therefore subject to strict scrutiny. The court determined that Minnesota’s law was not narrowly tailored to serve a compelling state interest, as it both overreached and underreached in its restriction of speech, and also authorized unconstitutional prior restraints. The Eighth Circuit reversed the denial of a preliminary injunction in part, affirmed in part, and remanded for entry of a preliminary injunction in favor of the plaintiffs. View "Minnesota Voters Alliance v. Ellison" on Justia Law

In December 1995, Holsey Ellingburg, Jr. robbed a bank. He was convicted by a jury in August 1996 and sentenced in November 1996 by the United States District Court for the Western District of Missouri, which ordered him to pay $7,567.25 in restitution. At the time of his offense, the Victim and Witness Protection Act of 1982 (VWPA) governed restitution, limiting liability to twenty years after judgment. However, the Mandatory Victim Restitution Act (MVRA), enacted after his offense but before his conviction, extended the government’s ability to collect restitution to the later of twenty years after judgment or twenty years after release from imprisonment, and made interest awards mandatory unless the defendant was unable to pay. After his release in 2022, Ellingburg challenged the continued enforcement of his restitution order, arguing that retroactive application of the MVRA violated the Ex Post Facto Clause.The district court held that the MVRA’s extended liability period did not increase Ellingburg’s punishment and rejected his petition. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed, reasoning that MVRA restitution was not criminal punishment and therefore did not implicate the Ex Post Facto Clause. Ellingburg sought review in the Supreme Court, which reversed, holding that MVRA restitution is criminal punishment under the Ex Post Facto Clause, and remanded for further proceedings on whether the MVRA’s extended liability period increased his punishment.On remand, the United States Court of Appeals for the Eighth Circuit determined that the MVRA applied to Ellingburg because he was convicted after its enactment. The court held that retroactive application of the MVRA’s extended liability period increased Ellingburg’s punishment by prolonging his restitution liability well beyond what the law permitted at the time of his offense. The court therefore concluded that applying the MVRA to Ellingburg violated the Ex Post Facto Clause, vacated the district court’s judgment, and remanded for further proceedings. View "United States v. Ellingburg" on Justia Law

A group of inmates under death sentences brought a lawsuit in Franklin Circuit Court in 2006 seeking declaratory and injunctive relief regarding Kentucky’s execution procedures. They challenged the Kentucky Department of Corrections’ execution protocols, arguing that the protocols had not been properly promulgated as administrative regulations under Kentucky’s Administrative Procedures Act. After the Kentucky Supreme Court ruled in 2009 that formal rulemaking was required, the Department issued new regulations, leading to ongoing litigation as the inmates continued to challenge subsequent amendments to the execution regulations on constitutional and statutory grounds, including issues regarding intellectual disability, insanity determinations, attorney access, and execution procedures.After further amendments to the execution regulations in 2023 and 2024, the inmates updated their claims, and the Commonwealth moved to dismiss, arguing the inmates had not exhausted administrative remedies as required by KRS 454.415. The Franklin Circuit Court denied the motion, finding that the grievances concerned the validity and constitutionality of regulations—matters not suited for administrative resolution—and that exhaustion was not required. The Commonwealth then petitioned the Supreme Court of Kentucky for a writ of prohibition, asserting that the circuit court lacked jurisdiction to proceed without exhaustion.The Supreme Court of Kentucky held that the Franklin Circuit Court had subject matter jurisdiction over declaratory and constitutional challenges to administrative regulations, regardless of whether exhaustion of administrative remedies was required or fulfilled for particular claims. The Court concluded that exhaustion is a non-jurisdictional procedural requirement, and any errors relating to exhaustion can be addressed on appeal after final judgment. Consequently, the Supreme Court of Kentucky denied the petition for a writ of prohibition. View "COMMONWEALTH OF KENTUCKY V. SHEPHERD" on Justia Law

The applicant was convicted of capital murder for intentionally killing a peace officer in Bexar County, Texas. The prosecution’s case included evidence that the applicant, after drinking with a friend, approached a deputy at a red light and fired at least forty-six shots, killing the officer. The applicant’s identity as the shooter was not disputed at trial. The defense conceded the shooting but argued the applicant was in an automatistic state due to a combination of alcohol, drugs, head injury, brain dysfunction, and hypoglycemia. The state countered with expert testimony disputing this defense. At sentencing, the state highlighted the brutality of the crime and the applicant’s lack of remorse, while the defense presented limited mitigation evidence, primarily focusing on positive aspects of the applicant’s character and hardships he faced.The case was initially tried in the 175th District Court of Bexar County, which sentenced the applicant to death after the jury answered special punishment issues in a manner requiring such a sentence. The Texas Court of Criminal Appeals affirmed the conviction and sentence on direct appeal. The applicant then filed an initial habeas corpus application, raising claims of jury misconduct, ineffective assistance of counsel in various trial phases (including jury selection, guilt, punishment, and competency), and a Brady claim alleging withheld impeachment evidence.The Texas Court of Criminal Appeals reviewed the writ application. It held that the jury misconduct claim was procedurally barred. The court found claims of ineffective assistance regarding the guilt phase investigation, jury selection, competency trial, and the Brady claim were without merit. On the claim that counsel failed to investigate and present adequate mitigating evidence at sentencing, the court assumed without deciding that counsel may have performed deficiently but concluded there was no reasonable probability the outcome would have been different, given the facts of the offense and the jury’s deliberations. Relief was denied on all claims. View "EX PARTE GONZALEZ" on Justia Law

In June 2017, a man killed his friend and her two adult daughters in their home. After purchasing weapons and related items, he arranged to visit the home when the daughters were away, but they returned during his visit. He assaulted the mother, then restrained all three women using threats and physical restraints. He proceeded to stab the mother, smother one daughter, and strangle the other, causing all of their deaths. The next day, their bodies were discovered after concerned friends and family entered the home. The suspect was located several days later after a police standoff, subsequently confessed, and was arrested.The case was first heard in the Cuyahoga County Court of Common Pleas, where a three-judge panel accepted the defendant’s guilty plea to multiple counts of aggravated murder, aggravated burglary, kidnapping, and gross abuse of a corpse. After a mitigation hearing, the panel sentenced him to death for each victim. On appeal, the Supreme Court of Ohio vacated the convictions and sentences, finding that the defendant had not been properly advised of certain constitutional rights during his plea. The case was remanded for new proceedings. Upon remand, the defendant again pleaded guilty before a new three-judge panel, which found him guilty and again imposed three death sentences after a mitigation hearing.The Supreme Court of Ohio reviewed the case as a matter of right. The defendant raised numerous legal issues, including claims regarding the weighing of aggravating and mitigating factors, the sufficiency of the indictment, the plea and jury waiver processes, the admission of evidence, and the constitutionality of Ohio’s death penalty scheme. The court overruled all claims. It held that the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt for each murder and that the death sentences were appropriate and proportionate to similar cases. The convictions and death sentences were affirmed. View "State v. Brinkman" on Justia Law

A nonprofit organization and several individuals, most residing near Franklin Park in Boston, challenged the city’s decision to enter into agreements allowing a private company to demolish and reconstruct White Stadium and to lease a portion of the new stadium for use as a professional women’s soccer venue. The plaintiffs argued that the land in question, originally acquired as parkland, remained subject to Article 97 of the Amendments to the Massachusetts Constitution, which requires a two-thirds legislative vote to dispose of or change the use of protected parkland. They also claimed that the agreements breached the terms of a public charitable trust, the George Robert White Fund, from which the stadium parcel was transferred, and that the city failed to meet other statutory requirements.The Superior Court dismissed the plaintiffs’ trust-based claims for lack of standing, finding that only the Attorney General or trustees can enforce a public charitable trust unless an individual plaintiff can show a distinct personal interest. After a bench trial, the court ruled in favor of the defendants on the remaining claims, concluding that the stadium parcel was no longer protected parkland at the time of the agreements and that the plaintiffs had not demonstrated violations regarding areas outside the stadium parcel.On appeal, the Supreme Judicial Court of Massachusetts affirmed. The court held that the plaintiffs lacked standing to enforce the White Fund’s trust terms. It further determined that, due to legislative actions in 1947 and 1950, the stadium parcel was removed from its park designation and dedicated as a school facility, so Article 97’s protections did not apply. The court also found that the agreements did not grant an easement over other areas of Franklin Park and that planned improvements outside the stadium parcel did not alter their park use. The judgment for the defendants was affirmed. View "Emerald Necklace Conservancy, Inc. v. City of Boston" on Justia Law

A police officer in Thief River Falls, Minnesota, attempted to stop Nicholas Engel’s van late at night because he did not see a rear license plate or visible temporary registration. Rather than pull over, Engel turned on his hazard lights and continued driving for several miles, despite the officer’s emergency lights, siren, and repeated verbal commands to stop. Engel eventually stopped only after additional officers arrived and boxed in his vehicle near a protest camp. He was arrested and charged with felony fleeing a peace officer in a motor vehicle.The Thief River Falls District Court denied Engel’s motion to suppress evidence of his vehicular flight, concluding the officer had an objective reason to initiate the stop. After a jury convicted Engel, the Minnesota Court of Appeals affirmed, though all panel members agreed the traffic stop was unconstitutional because the officer lacked reasonable, articulable suspicion for the stop. The majority held that suppression of evidence of Engel’s flight was not warranted, while the dissent argued that the flight was fruit of the unconstitutional seizure and should be suppressed.The Supreme Court of Minnesota reviewed the case to determine whether evidence of Engel’s vehicular flight, which constituted a new crime in response to an unconstitutional stop, must be suppressed under the exclusionary rule of the Minnesota Constitution. The court held that when a suspect commits a new crime after law enforcement commits a constitutional violation, courts must apply the four-factor attenuation test from State v. Warndahl to determine whether the evidence of the new crime is fruit of the poisonous tree. Applying this test, the court found Engel’s flight to be an intervening act not sufficiently connected to the unconstitutional stop to warrant suppression. The court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

Three individuals filed a class action lawsuit against San Francisco, challenging new water rates adopted by the city’s Public Utility Commission in May 2023. The plaintiffs alleged that the new rates violated Proposition 218 of the California Constitution by including costs unrelated to the actual provision of water service, resulting in charges that exceeded the cost of service. Before adopting the new rates, the city provided required notice to ratepayers, including information about a 120-day period for legal challenges under the applicable validation statutes. The plaintiffs sought a refund, declaratory and equitable relief, and a writ of mandate.After the class action was filed, the City litigated the case for over a year. It participated in discovery, case management, and even moved for summary judgment, without initially arguing that the suit was procedurally improper. Eventually, the City moved for judgment on the pleadings, arguing that plaintiffs’ action was subject to the validation statutes, specifically Government Code section 53759 and Code of Civil Procedure sections 860 et seq., which require reverse validation actions attacking agency matters like water rates to be brought within 120 days and with specific notice by publication to all interested parties. The trial court (San Francisco County Superior Court) agreed with the City, finding the statutes mandatory and jurisdictional, and dismissed the case for failure to comply with the procedural requirements, including timely filing and appropriate notice.On appeal, the California Court of Appeal, First Appellate District, Division Two, reviewed the judgment de novo. The court held that compliance with the validation statutes was mandatory and jurisdictional. Plaintiffs’ failure to file a proper reverse validation action and to provide notice by publication deprived the court of jurisdiction. The court rejected arguments that the City had waived these requirements or that good cause existed for noncompliance. The judgment in favor of the City was affirmed. View "Toy v. City & County of S.F." on Justia Law

An inmate incarcerated at an Indiana prison was twice transported by correctional officers between the facility and a hospital in June 2019. During the first transport, after a medical appointment, the inmate was placed in a van in restraining gear that prevented him from buckling his seatbelt, and the officers refused to buckle it for him. One of the officers then drove the van in a manner the inmate described as reckless, resulting in a sudden stop that threw the inmate to the floor and caused a broken collarbone. The inmate alleged the officers made threatening remarks referencing his prior grievances against staff and later colluded to create consistent incident reports. On the second transport, after surgery, the inmate was buckled in but not placed in the more secure area he requested. Officers drove in a way that jostled his recent injuries, deliberately drove over rough terrain and railroad tracks, and laughed in response to his pain.The United States District Court for the Southern District of Indiana allowed the inmate’s Eighth Amendment claims against three officers to proceed, along with First Amendment retaliation claims. At summary judgment, the district court granted qualified immunity to all three officers on the Eighth Amendment claims, finding that the law was not clearly established for the conduct alleged, and entered judgment for the officers. The court analyzed the claims under both deliberate indifference and excessive force standards, depending on the officer’s role and the facts alleged.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed in part and vacated in part. The court held that the officer who failed to buckle the inmate’s seatbelt and did not intervene during reckless driving on the first transport was not entitled to qualified immunity, as it was clearly established that subjecting a restrained inmate to reckless driving without a seatbelt posed a substantial risk of serious harm. However, the court affirmed summary judgment for the officers involved in the second transport, finding the law was not clearly established that their conduct—though troubling—violated the Eighth Amendment under the specific facts presented. The case against the first officer was remanded for further proceedings. View "Smith v. Price" on Justia Law

A nonprofit organization dedicated to election integrity requested a copy of Wisconsin’s voter registration list, seeking access under the National Voter Registration Act (NVRA). Wisconsin, however, is exempt from the NVRA because it has permitted same-day polling-place registration since before August 1, 1994. The state processed the request under its public-records law, which required redaction of birth dates and imposed a fee of $12,500 due to the size of the list. The organization objected to both the fee and the redactions, arguing that Wisconsin’s exemption from the NVRA was unconstitutional.The United States District Court for the Western District of Wisconsin dismissed the case. The district judge held that the plaintiff’s claims—asserting violations of the “equal state sovereignty” principle from Shelby County v. Holder and the “congruence and proportionality” requirement from City of Boerne v. Flores—were not supported by law. While the judge found that the plaintiff had Article III standing due to the alleged financial injury, he expressed doubt about prudential standing but decided the case on the merits, concluding that neither cited Supreme Court decision undermined the validity of Wisconsin’s exemption.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The court agreed that the plaintiff had Article III standing but questioned prudential standing, as the legal theories invoked state, rather than individual, rights. Nonetheless, the court bypassed this issue, holding that the NVRA’s exemption for states like Wisconsin does not violate equal state sovereignty or the congruence and proportionality standard. The court emphasized that the exemption relieves, rather than imposes, federal regulatory burdens and that Congress acted under its Elections Clause authority, making City of Boerne inapplicable. The Seventh Circuit affirmed the district court’s dismissal. View "Public Interest Legal Foundation, Inc. v. Wolfe" on Justia Law