Justia Constitutional Law Opinion Summaries

A multi-state utility company operating a gas-fired power plant in Washington alleged that the state's Climate Commitment Act (CCA) impermissibly discriminated against interstate commerce by allocating no-cost greenhouse gas emissions allowances only for electricity sold to Washington customers. Under Washington’s Clean Energy Transformation Act (CETA) and the CCA, utilities serving in-state customers receive no-cost allowances to offset compliance costs, while electricity exported to customers in other states does not receive this benefit. The company argued that this scheme increased costs for its non-Washington customers and potentially its shareholders, as out-of-state sales from the Washington facility required purchasing emissions allowances at auction.The United States District Court for the Western District of Washington reviewed the complaint and found that the electricity generated for export was not subject to CETA’s decarbonization mandates, distinguishing it from in-state electricity. The district court concluded that the two categories were not similarly situated for purposes of Dormant Commerce Clause analysis. The court reasoned that utilities serving Washington customers were already subject to more aggressive decarbonization requirements under CETA, justifying the allocation of no-cost allowances under the CCA. The district court dismissed the complaint with prejudice, finding no plausible claim of unconstitutional discrimination, and denied the motion for preliminary injunction as moot.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal and denial of the injunction. The Ninth Circuit held that because the regulatory schemes governing in-state and exported electricity are distinct, the emissions associated with each are not similarly situated. Therefore, Washington’s allocation of no-cost allowances did not violate the Dormant Commerce Clause. The court further held that dismissal without leave to amend was appropriate, as any amendment would be futile. The decision was affirmed. View "PACIFICORP V. SIXKILLER" on Justia Law

A town administrator in Grand Chute, Wisconsin, was terminated by a newly elected faction on the town’s Board of Supervisors. The administrator, who had served since 2008, claimed his firing was retaliation for cooperating with a state Department of Justice investigation into alleged corruption by a newly elected supervisor. That supervisor had previously been involved in litigation against the town and was later indicted, though ultimately acquitted, on unrelated corruption charges. The administrator’s relationship with the new board members deteriorated, and he was perceived as politically aligned with their rivals and critical of their policies.The administrator sued the Town and individual supervisors in the United States District Court for the Eastern District of Wisconsin under 42 U.S.C. § 1983, asserting First Amendment retaliation. The supervisor also filed a counterclaim alleging the administrator had set him up for prosecution. The district court granted summary judgment for the defendants in both actions, finding the administrator’s termination did not violate the First Amendment and that qualified immunity applied due to unclear precedent regarding the firing of policymaking officials for political speech. The court also rejected the supervisor’s counterclaim, finding no evidence of state action or differential treatment required for an equal protection class-of-one claim.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The Seventh Circuit affirmed, holding that the individual defendants were entitled to qualified immunity because existing precedent did not clearly establish that firing a policymaking official under these circumstances violated the First Amendment. The court also affirmed dismissal of the counterclaim, finding neither a viable First Amendment retaliation nor an equal protection claim. View "March v. Wolff" on Justia Law

Arizona amended its election laws in 2022, introducing two provisions: one requires county recorders to cancel a voter’s registration in their county if the voter registers in a new county (“Cancellation Provision”), and the other criminalizes knowingly providing a “mechanism for voting” to someone registered in another state (“Felony Provision”). Three organizations engaged in voter registration and education activities claimed these provisions would interfere with their efforts, and sought to enjoin enforcement. They argued that the Cancellation Provision would lead to improper removal of voters and that the Felony Provision was vague and could chill their constitutionally protected activities.The United States District Court for the District of Arizona granted a preliminary injunction, barring enforcement of both provisions. The Arizona Attorney General appealed. A three-judge panel of the United States Court of Appeals for the Ninth Circuit vacated the injunction, finding that the organizations lacked standing for the Cancellation Provision and were unlikely to succeed on the merits regarding the Felony Provision. The case was then reheard en banc after the prior panel’s opinion was vacated.The United States Court of Appeals for the Ninth Circuit, sitting en banc, held that the organizations lacked standing to challenge the Cancellation Provision because they did not clearly show that it directly affected or interfered with their core activities, as required by FDA v. Alliance for Hippocratic Medicine. The court further held that the organizations had standing to challenge the Felony Provision due to a credible threat of prosecution, but were unlikely to succeed on the merits, as the statutory context indicated that “mechanism for voting” likely refers only to a ballot or ballot envelope, not to voter registration or education activities. The court vacated the preliminary injunction and remanded the case. View "ARIZONA ALLIANCE FOR RETIRED AMERICANS V. MAYES" on Justia Law

A veteran who served in the Marine Corps, including a tour in Vietnam, began experiencing fatigue and underwent a medical evaluation at a Veterans Affairs Medical Center in 2010. His blood tests showed elevated lymphocyte counts. However, VA physicians in Florida diagnosed him with monoclonal B-cell lymphocytosis (MBL), not chronic lymphocytic leukemia (CLL), and did not inform him of a CLL diagnosis. Years later, after his condition worsened and he relocated to Tennessee, a VA oncologist diagnosed him with CLL and retroactively opined that his medical records met the diagnostic criteria for CLL since 2010. The veteran then applied for VA disability compensation. The VA assigned a 100% disability rating with an effective date of January 29, 2016, the date his claim was filed.The veteran appealed, arguing for an earlier effective date due to the alleged misdiagnosis and failure to inform him about his CLL. The Board of Veterans’ Appeals partially granted his request, assigning an effective date of January 29, 2015, but declined to go earlier, finding that the law did not allow equitable considerations to affect the effective date under 38 U.S.C. § 5110. The veteran then appealed to the United States Court of Appeals for Veterans Claims, raising arguments that the VA should be equitably estopped from enforcing § 5110’s effective date restrictions, and that those restrictions were unconstitutional as applied to him. The Veterans Court affirmed the Board’s decision.On further appeal, the United States Court of Appeals for the Federal Circuit affirmed the Veterans Court. The Federal Circuit held that equitable estoppel cannot override the effective date limitations of 38 U.S.C. § 5110, and that § 7331 does not create a statutory precondition to enforcement of § 5110. It also held that the statute’s effective date limitations were not unconstitutional as applied to the veteran’s circumstances. View "LEY v. COLLINS " on Justia Law

The case centers on the death of a two-year-old child, Hayden, who lived with his mother, Hailey, and her husband, Joseph. The family struggled financially, and Joseph was often home caring for Hayden while Hailey worked. On the morning of December 27, 2021, Hayden died after being repeatedly struck by Joseph and subsequently smothered by Hailey, according to Hailey’s testimony. Medical evidence indicated Hayden suffered extensive recent and past injuries consistent with ongoing physical abuse. Both Joseph and Hailey were indicted for capital murder. Hailey pleaded guilty to first-degree murder and received a life sentence, while Joseph pleaded not guilty and went to trial.The case was first tried in the Harrison County Circuit Court, Second Judicial District. A jury found Joseph guilty of capital murder and, after a penalty phase, unanimously sentenced him to death, finding he had attempted to kill Hayden and that the murder was committed during felonious child abuse and was especially heinous, atrocious, or cruel. Joseph’s post-trial motions for a new trial or judgment notwithstanding the verdict were denied.On direct appeal, the Supreme Court of Mississippi reviewed multiple claims of error, including the admission of expert and lay testimony, the exclusion of certain character evidence, the jury instructions regarding aggravating circumstances, the sufficiency of the evidence, and the proportionality and constitutionality of the death sentence. The Court applied heightened scrutiny due to the death penalty. It held that there was no reversible error in the admission of testimony, the aggravating circumstances were properly found, and the evidence was sufficient to support the jury’s findings. The Court affirmed Joseph’s conviction and death sentence, finding neither cumulative error nor constitutional infirmity. Claims of ineffective assistance of counsel were preserved for possible post-conviction relief but were not resolved on direct appeal. View "Heard v. State of Mississippi" on Justia Law

An inmate with a history of heart issues experienced unusually severe chest pain while incarcerated and took medication without relief. He promptly reported his symptoms to a corrections officer, expressing the need for immediate medical attention and warning of his medical vulnerability. The officer dismissed the complaint, ordering the inmate back to his cell, and allegedly threatened further discipline. Instead, the inmate sat in a nearby wheelchair. Another prison official later intervened and arranged for the inmate to be transported to the medical wing, resulting in an eight-minute delay from the initial complaint. After waiting about an hour in the medical wing without treatment, the inmate suffered a heart attack but ultimately recovered.The inmate initiated a lawsuit in the United States District Court for the Eastern District of Michigan, asserting that the officer’s conduct constituted deliberate indifference to his serious medical needs in violation of the Eighth Amendment and also violated his Fourteenth Amendment rights. The officer sought summary judgment on qualified immunity grounds. A magistrate judge recommended dismissing the Fourteenth Amendment claim but found that a reasonable jury could determine that the officer was deliberately indifferent and thus denied qualified immunity. The district court adopted this recommendation, concluding that there was sufficient evidence for the Eighth Amendment claim to proceed to trial.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the officer was entitled to qualified immunity as a matter of law. The Sixth Circuit held that the officer did not violate a clearly established constitutional right because existing precedent did not put a reasonable officer on notice that failing to immediately respond to a prisoner’s oral complaint of chest pain, absent visible signs of medical distress, violated the Eighth Amendment. The court reversed the district court’s denial of summary judgment and remanded the case for entry of judgment in favor of the officer. View "Richardson v. Falk" on Justia Law

Two businesses operating an industrial warehouse and distribution center in Bonner Springs, Kansas, were affected by an ordinance enacted by the neighboring City of Edwardsville. This ordinance prohibited vehicles weighing over six tons from traveling on 110th Street—the street dividing the two cities—unless the trucks were entering or exiting Edwardsville. As a result, heavy trucks serving the businesses could not access 110th Street to enter or exit their properties. In response, the businesses filed suit against Edwardsville and certain city officials, alleging violations of federal and state law and seeking a preliminary injunction to prevent enforcement of the ordinance.The United States District Court for the District of Kansas dismissed the plaintiffs’ federal claims, including those under the Surface Transportation Assistance Act, the Equal Protection Clause, and the Dormant Commerce Clause, and denied the request for a preliminary injunction. However, the district court declined to dismiss the remaining state-law claims, leaving them pending.While the appeal was pending before the United States Court of Appeals for the Tenth Circuit, Edwardsville repealed the challenged ordinance and replaced it with a new one. The new ordinance allowed southbound trucks to enter the businesses from 110th Street, though certain restrictions remained. The Tenth Circuit determined that the repeal and replacement of the ordinance rendered the appeal moot because the controversy over the original ordinance no longer existed. The court found no exception to mootness applied and declined to vacate the district court’s order or exercise pendent appellate jurisdiction over the dismissed claims. Accordingly, the Tenth Circuit dismissed the appeal for lack of jurisdiction. View "Scannell Properties #516 v. City of Edwardsville, Kansas" on Justia Law

Officers observed Trevon Hatcherson-Ross walking on a sidewalk in the late afternoon when one officer noticed an “L-shaped” bulge in his waistband, suspecting it was a firearm. When the officers approached to investigate, Hatcherson-Ross fled, leading them on a short foot chase that ended with him climbing into the backyard of a private residence and hiding under a porch. After the officers found and detained him, they searched the backyard and discovered a gun in a storage bin under the porch, as well as ammunition in Hatcherson-Ross’s pocket.The Superior Court of the District of Columbia reviewed Hatcherson-Ross’s pretrial motion to suppress the gun and ammunition as the fruits of an unlawful seizure. The trial court denied the motion, reasoning that Hatcherson-Ross had abandoned the firearm in the backyard, thereby relinquishing any expectation of privacy in it. The court did not make specific findings as to whether or when the officers had reasonable suspicion to stop him, relying instead on the abandonment theory. After trial, a jury convicted Hatcherson-Ross of firearm-related offenses.The District of Columbia Court of Appeals considered whether Hatcherson-Ross had been unlawfully seized before he entered the backyard and whether the search of the backyard and storage bin implicated his Fourth Amendment rights. The court held that Hatcherson-Ross was not seized until officers physically detained him under the porch, at which point he did not contest that reasonable suspicion existed. The court further held that Hatcherson-Ross had no reasonable expectation of privacy in a stranger’s backyard or storage bin, making the abandonment issue irrelevant. The court affirmed both the denial of the suppression motion and Hatcherson-Ross’s convictions. View "Hatcherson-Ross v. United States" on Justia Law

A commercial property owner that operates a large shopping mall in Nassau County, New York, was fined approximately $4.8 million by county officials for failing to provide financial information as required under the county’s Annual Statement of Income and Expenses (ASIE) Law. This law mandates commercial property owners to report financial data to county assessors or face a fine calculated as a percentage of the property’s market value. The property owner did not submit the required statements for two consecutive years and was subsequently notified of the fine.After receiving notice of the penalty, the property owner filed suit in the United States District Court for the Eastern District of New York, rather than pursuing remedies under state law or contesting the fine through state administrative proceedings. The owner argued that the ASIE Law and the resulting penalty violated the Eighth Amendment’s Excessive Fines Clause, the Fourteenth Amendment’s Due Process Clause, and several state laws. The district court granted summary judgment in favor of Nassau County and its officials, finding that the fine was not excessive, that adequate procedural due process was available through an Article 78 state court proceeding, and that the ASIE Law did not violate substantive due process. The district court also denied the owner’s motion for sanctions against the county, finding no evidence of bad faith or egregious conduct.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that the Excessive Fines Clause applies to business entities, including trusts, and that the fine imposed was not grossly disproportional to the offense. The court further found that the available procedures satisfied due process requirements and that the ASIE Law was rationally related to a legitimate government interest. The denial of sanctions was also upheld. View "The Retail Property Trust v. Nassau Cnty. Dep't of Assessment" on Justia Law

Several residential property owners and a short-term rental platform challenged two ordinances enacted by the city. The first ordinance, adopted in 2023, restricts short-term rental licenses to one per residential block and distributes them by lottery. The second ordinance, adopted in 2024, requires short-term rental platforms to verify the license status of properties before facilitating transactions, and to periodically reverify this status. Plaintiffs alleged that these ordinances infringed upon their constitutional and statutory rights, including claims under the Takings Clause and Section 230 of the Communications Decency Act.The United States District Court for the Eastern District of Louisiana reviewed the plaintiffs’ claims. It dismissed all claims under Rule 12(b)(6), except for Airbnb’s Fourth Amendment challenge regarding a monthly reporting requirement in the 2024 Ordinance. The district court granted Airbnb summary judgment on that particular claim. Airbnb appealed the dismissal of its other claims.The United States Court of Appeals for the Fifth Circuit examined the case de novo. The court held that the 2023 Ordinance did not constitute a per se or regulatory taking under the Takings Clause, noting that the ordinance neither physically appropriated property nor severely impaired economic expectations. It also found the ordinance to be a reasonable zoning regulation that balanced public interests. Regarding Section 230, the Fifth Circuit ruled that neither the booking nor verification requirements of the 2024 Ordinance treated Airbnb as the publisher or speaker of third-party content, and thus were not preempted. The court affirmed the district court’s dismissal of the Takings Clause claim and the Section 230 claim, as well as the dismissal of other claims raised by the plaintiffs. View "Bodin v. New Orleans" on Justia Law