Justia Constitutional Law Opinion Summaries

A Michigan-based real estate developer and related parties sought to redevelop a commercial property in the City of Pontiac to include medical marijuana cultivation and processing facilities. After purchasing the property in 2019, the developer obtained rezoning approval from the city, but the process of securing required permits and special exceptions for tenants became protracted. The city clerk cited deficiencies in tenant applications and, at one point, argued that the project violated city ordinances regarding overlay districts for marijuana businesses. Despite eventual approvals—including a court order requiring the city to issue permits—the tenants withdrew due to the delays, and the project collapsed. Subsequently, the developer’s affiliate lost another business opportunity, which plaintiffs attributed to city officials’ retaliation.The plaintiffs filed suit in Oakland County Circuit Court, seeking injunctive, declaratory, and monetary relief, and later brought civil rights claims under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan. The district court granted summary judgment for the city and the city clerk, finding insufficient evidence of constitutional violations and concluding that the delays and alleged retaliation did not violate the plaintiffs’ rights.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The court held that the plaintiffs lacked a cognizable property interest under the Due Process Clause because city approval for marijuana facilities was discretionary, not a matter of right. The court also found that the delays did not constitute a “taking” under the Fifth Amendment, as the length and nature of the delays were not extraordinary. The equal protection claim failed for lack of evidence that similarly situated applicants were treated more favorably. Finally, the court determined that the plaintiffs’ First Amendment retaliation claim could not proceed against the city because the mayor lacked final policymaking authority over zoning and no municipal policy or custom was established. View "Rubicon Real Estate Holdings v. City of Pontiac" on Justia Law

Dusty Ray Spencer was convicted of murdering his wife, Karen Spencer, in 1992. The incident involved a series of violent altercations in the weeks preceding the murder, culminating in Spencer attacking Karen in their backyard, inflicting fatal stab wounds and blunt force trauma. Karen’s teenage son, Timothy Johnson, witnessed and attempted to intervene during both the January 4 and January 18 attacks. Spencer was apprehended and tried, with the jury recommending the death penalty by a seven-to-five vote.Following conviction, the trial court sentenced Spencer to death. On direct appeal, the Supreme Court of Florida affirmed the conviction but vacated the death sentence due to improper consideration of aggravating and mitigating factors, remanding for reconsideration. After further proceedings, the trial court again imposed the death penalty, which the Supreme Court of Florida affirmed. Spencer’s subsequent collateral attacks on his conviction and sentence in both state and federal courts were unsuccessful. In May 2026, nearly three decades after his sentence became final, Governor DeSantis signed Spencer’s death warrant, prompting Spencer to file a third successive motion for post-conviction relief and a request for a stay of execution.The Supreme Court of Florida reviewed the trial court’s summary denial of Spencer’s latest motion. The Court held that Spencer’s claims—challenging the lethal injection protocol based on alleged deviations and his cirrhosis, and asserting a categorical exemption from execution due to his advanced age—were untimely and without legal merit. The Court found that Spencer failed to demonstrate any exception to the one-year filing requirement, did not meet the legal standard for a method-of-execution claim, and was foreclosed from relief based on age. The Supreme Court of Florida affirmed the trial court’s denial of post-conviction relief and declined to stay the execution. View "Spencer v. State" on Justia Law

Several members of the public submitted requests to a large social media company seeking information about political advertisements displayed on its platforms to users in Washington State. The company did not dispute that its responses to these requests failed to comply with Washington’s Fair Campaign Practices Act (FCPA) and the law’s implementing regulations, as it did not provide all the required information. The State of Washington, through the Attorney General’s Office, filed suit against the company, alleging multiple violations of the FCPA’s disclosure requirements.The case was heard in King County Superior Court, where both sides moved for summary judgment. The trial court granted summary judgment for the State, holding the company liable for violating the FCPA, and imposed maximum statutory penalties for each advertisement for which the required information was not disclosed. The court found the violations to be intentional, trebled both the civil penalties and attorney fees, and granted an injunction. On appeal, the Washington Court of Appeals affirmed the trial court’s rulings on liability, statutory interpretation regarding penalty calculation, and the constitutionality of the penalty assessed.Before the Supreme Court of the State of Washington, the company argued that the FCPA’s disclosure requirements violate the First Amendment as applied, that the penalty was improperly calculated, and that the penalty violated the Eighth Amendment’s excessive fines clause. The Supreme Court, with no single majority opinion, affirmed the company’s liability under the FCPA, holding that the law as applied does not violate the First Amendment. The court also let the penalty judgment stand, as no majority view existed to reverse or modify it, and further held by a majority that the penalty does not violate the Eighth Amendment. Thus, the judgment of the Court of Appeals was affirmed, upholding both the liability finding and the civil penalty. View "State v. Meta Platforms, Inc." on Justia Law

A group of former and sitting justices of New York State courts challenged the constitutionality of the mandatory judicial retirement age imposed by article VI, § 25 (b) of the New York State Constitution, which requires judges to retire at age 70, with a certification process allowing some to serve until age 76. Petitioners argued that this age limit was implicitly repealed by the 2024 Equal Rights Amendment (ERA), which amended article I, § 11 to prohibit discrimination based on age, among other characteristics, in civil rights.The proceeding was brought as a hybrid article 78 and declaratory judgment action against the State of New York and the Office of Court Administration. Supreme Court denied petitioners’ request for preliminary relief and dismissed the petition, granting the State’s cross-motion. The Appellate Division, First Department, affirmed the dismissal, holding that the ERA did not implicitly repeal the mandatory retirement provision. The Appellate Division found no reference in the ERA to judicial eligibility or retirement age and concluded that the ERA and article VI, § 25 (b) addressed different subject matters and could be harmonized. The court declined to address whether strict scrutiny applies to age-based classifications or whether the ERA made article I, § 11 self-executing.On appeal, the New York State Court of Appeals reviewed whether article VI, § 25 (b) was implicitly repealed by the ERA. The Court of Appeals held that repeal by implication is disfavored and that the two provisions are not antagonistic, operating independently. The Court concluded that article VI, § 25 (b) remains in effect and was not repealed or invalidated by the ERA. Accordingly, the Court of Appeals affirmed the Appellate Division’s order dismissing the petition. View "Miller v State" on Justia Law

The defendant was indicted for first-degree sexual assault following an incident in March 2021. The complainant testified that she was invited to a social gathering by the defendant, consumed alcohol throughout the night, and later awoke in an unfamiliar motel room unable to move, where she observed the defendant engaging in sexual acts against her will. The complainant denied consenting to sexual activity or going to the motel. A motel employee corroborated that the complainant appeared intoxicated, and forensic testing on her clothing and swabs revealed DNA consistent with the defendant. The defendant conceded to sexual intercourse but claimed it was consensual.The case was tried before the Kent County Superior Court, where a jury heard testimony from the complainant, witnesses, and forensic experts. The laboratory supervisor who reviewed and approved the DNA analysis, but did not perform the testing herself, testified regarding the DNA findings. The defendant moved to strike her testimony, arguing it violated his right to confront the analyst who performed the testing, relying on Supreme Court precedents. The trial justice denied the motion, referencing prior Rhode Island Supreme Court decisions permitting supervisory analysts to testify.On appeal, the Supreme Court of Rhode Island reviewed whether the defendant properly preserved his Confrontation Clause objection and whether an intervening Supreme Court decision, Smith v. Arizona, warranted a departure from the raise-or-waive rule. The Court held that the defendant’s objection was not based on a novel rule of law and was untimely, as prior precedent already addressed the issue. The Court concluded that the intervening decision did not alter existing controlling law and affirmed the Superior Court’s judgment of conviction. View "State v. Vasquez" on Justia Law

Ali Hemani, a dual citizen of the United States and Pakistan, lived in Texas with his parents and maintained steady employment. In 2022, federal agents searched his home based on suspicions of terrorism-related activity. Hemani cooperated fully with law enforcement, surrendering a firearm and marijuana found on the property, and admitted during an interview that he used marijuana about every other day. Several months later, the government charged Hemani under 18 U.S.C. §922(g)(3) for possessing a gun while being an unlawful user of a controlled substance, relying solely on his admitted marijuana use.The United States District Court for the Northern District of Texas granted Hemani’s motion to dismiss the indictment, finding the prosecution violated his Second Amendment rights. The government appealed, but the United States Court of Appeals for the Fifth Circuit affirmed the dismissal, prompting the government to seek review from the Supreme Court.The Supreme Court of the United States reviewed whether the government’s prosecution of Hemani under §922(g)(3) was consistent with the Second Amendment. The Court held that the government’s automatic ban on firearm possession for anyone who regularly uses a controlled substance, without individualized proof of dangerousness or any pre-deprivation process, is inconsistent with the Second Amendment’s protections. The government failed to demonstrate that §922(g)(3), as applied, was sufficiently analogous to historical regulations targeting habitual drunkards, which operated for different reasons, targeted different groups, and provided procedural safeguards. The Court’s decision is narrow, addressing only the automatic application of the statute to regular drug users without further showing. The judgment of the Fifth Circuit was affirmed. View "United States v. Hemani" on Justia Law

Hunter was charged with ten counts of bank and wire fraud, involving a scheme that cost financial institutions approximately $500,000. He entered a written plea agreement with the government, pleading guilty to one count of aiding and abetting wire fraud. In exchange, the government dismissed the other nine charges and agreed not to prosecute Hunter for related conduct in the future. The plea agreement contained an appeal waiver, barring him from appealing his conviction and sentence, except for claims of ineffective assistance of counsel. The agreement stipulated that any modification must be in writing and signed by all parties. At sentencing, the District Court imposed 51 months’ imprisonment and three years of supervised release, including a requirement that Hunter participate in a mental-health treatment program and take any prescribed medications. Hunter objected to the medication condition, but the District Court stated he could address any disputes with the probation officer or the court. At the conclusion of sentencing, the court erroneously informed Hunter that he had a right to appeal, without objection from either party.Hunter appealed, challenging the mandatory-medication condition as violating his fundamental due process rights. The government moved to dismiss the appeal based on the plea agreement’s waiver. Hunter conceded he had knowingly and voluntarily signed the waiver, but argued it was unenforceable because the sentence allegedly infringed on a fundamental constitutional right and that the District Court’s statement at sentencing, coupled with the prosecutor’s silence, voided the waiver. The United States Court of Appeals for the Fifth Circuit dismissed the appeal, holding that the District Court’s misstatement did not invalidate the waiver and that Fifth Circuit precedent permitted appeals despite a waiver only in cases of ineffective assistance of counsel or sentences exceeding the statutory maximum.The Supreme Court of the United States held that an appeal waiver is unenforceable when its enforcement would result in a miscarriage of justice—specifically, when it would leave in place an egregious error undermining the judicial system’s integrity. The Court vacated the Fifth Circuit’s judgment and remanded the case for consideration under this miscarriage-of-justice standard. View "Hunter v. United States" on Justia Law

The case involves Maxim Levin and Vodka Properties LLC, who owned a residential building in Buffalo, New York, that was demolished by the City of Buffalo in 2019 under emergency procedures. The City justified the emergency demolition by citing illegal drug activity on the property, including a recent overdose death, and the building’s vacant and allegedly structurally compromised condition. Plaintiffs contested whether these circumstances actually warranted an immediate demolition without a pre-deprivation hearing and argued that their constitutional rights were violated.A magistrate judge in the United States District Court for the Western District of New York recommended denying summary judgment on some constitutional claims, finding disputed facts about the condition of the property and notice provided. The district court, however, dismissed certain claims, including procedural due process, based on its finding that adequate notice was given and that the individual City employees (except the City itself) were entitled to qualified immunity. The court also dismissed claims against the demolition company for lack of state action and dismissed claims against the City, concluding there was no municipal liability under Monell v. Department of Social Services.The United States Court of Appeals for the Second Circuit held that summary judgment was improper on the procedural due process, unlawful taking, and unreasonable seizure claims, because there were unresolved factual questions about whether the property’s condition justified emergency demolition. The appellate court further determined that Commissioner James Comerford, Jr. was the City’s final policymaker regarding demolition decisions, so Monell liability was improperly dismissed. The court reversed the grant of qualified immunity for the Commissioner due to factual disputes but affirmed summary judgment for the other individual employees and the demolition company. The court affirmed dismissal of the substantive due process and state law claims. The judgment was affirmed in part, vacated in part, and the case remanded for further proceedings. View "Levin v. City of Buffalo" on Justia Law

A group of Wisconsin taxpayers challenged a state program that provides need-based college grants to students belonging to specified racial, national origin, ancestry, or alienage groups attending private and technical colleges. The program, administered by the Higher Educational Aids Board (HEAB), was created to address disproportionate attrition rates among certain minority students by offering them financial support. Students who do not fall into the listed preferred groups are categorically ineligible for this aid.The Jefferson County Circuit Court ruled in favor of HEAB, holding that the taxpayers had standing and that the program was constitutional. The court relied on the U.S. Supreme Court’s decision in Grutter v. Bollinger, finding that fostering diversity in higher education is a compelling state interest and that the program was narrowly tailored to address high attrition rates among minority students. The taxpayers appealed this decision.While the case was on appeal, the United States Supreme Court decided Students for Fair Admissions, Inc. v. President & Fellows of Harvard College, which held that achieving diversity in higher education is no longer a compelling interest justifying race-based classifications. Applying this new precedent, the Wisconsin Court of Appeals reversed the circuit court, holding the program unconstitutional under the Equal Protection Clause and ordering HEAB to stop administering it.On further review, the Supreme Court of Wisconsin held that the taxpayers had standing because any illegal expenditure of public funds creates taxpayer injury. The court also held that the grant program violates the Equal Protection Clause of the Fourteenth Amendment. It found that neither promoting diversity nor equalizing educational opportunity for certain groups was a sufficiently compelling interest under current law, and that the means chosen were not narrowly tailored. The Supreme Court of Wisconsin affirmed the Court of Appeals and enjoined HEAB from operating the program. View "Rabiebna v. Higher Educational Aids Board" on Justia Law

A deputy sheriff sergeant was terminated from his employment after an incident where he encountered two individuals with active “time pay” warrants for failure to pay fines. Despite confirming the existence and validity of the warrants, which were issued by a county court and directed to any law enforcement officer, he told the individuals that he would not arrest them because he believed doing so would be pointless. The interaction was recorded on his body camera. After the sheriff’s office conducted an internal investigation, the sergeant was found to have violated standard operating procedures by neglecting his duty.The sergeant appealed the termination to the county sheriff’s merit commission, which upheld the decision after a hearing. He then filed a petition in error with the District Court for Lancaster County, arguing that the evidence did not support his termination, that due process was denied because he was not given notice regarding issues of credibility or prior investigations, that the commission’s decision was void for untimely delivery, and that he had not waived any objections by failing to object during the administrative hearing. The district court found sufficient evidence supported the commission’s decision, determined the procedures were constitutionally adequate, rejected the argument about untimely delivery because no specific deadline for notification was violated, and concluded there was no prejudice regarding any waiver issue.The Nebraska Supreme Court reviewed the case. It held that sufficient evidence supported the finding that the sergeant neglected his statutory duty to execute the warrants, which justified termination under the governing procedures. The court also held that due process requirements were satisfied, as the sergeant received notice of the charges, an explanation of the evidence, and an opportunity to be heard. The court affirmed the district court’s judgment, finding no prejudicial error in the proceedings. View "Schmuecker v. Lancaster County" on Justia Law