Justia Constitutional Law Opinion Summaries

Tire Town Auto LLC, a towing service based in Marshfield, Wisconsin, operated for years on a list maintained by Wood County for dispatching towing companies to remove disabled vehicles from public roads. Wood County required businesses on the list to comply with a set of minimum standards, including 24/7 availability, liability insurance, and rules such as the use of reflective vests. After complaints about noncompliance with these standards—including failure to wear vests and alleged overcharging—Wood County removed Tire Town from the rotation list. Tire Town filed suit three years later, alleging that its removal violated its procedural due process rights under the Fourteenth Amendment.The United States District Court for the Western District of Wisconsin dismissed Tire Town’s amended complaint, finding that Tire Town had not plausibly alleged deprivation of a property interest protected by due process. The court determined that neither Wisconsin law nor any contract, statute, or ordinance guaranteed Tire Town a spot on the towing rotation list. The Minimum Standards policy explicitly stated it was not a contract and gave the county broad discretion to remove companies from the list.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The appellate court affirmed the district court’s judgment, holding that Tire Town had not plausibly alleged a protected property interest in remaining on the towing rotation list. The court concluded that the Minimum Standards policy did not restrict the county’s discretion sufficiently to create a legitimate claim of entitlement, and Tire Town could not reasonably rely on the policy as a source of property rights. The court rejected arguments based on unwritten “mutually explicit understandings,” finding no basis in law or contract for a protected property interest. View "Tire Town Auto LLC v Wood County" on Justia Law

AAC, a company that finances motorcycle purchases and holds security interests in the vehicles, acquired installment contracts for two motorcycles owned by individuals involved in a criminal case. After one owner, Brock, was killed during a gang shootout, and the other, Andrzejewski, was arrested and charged in connection with the incident, the Lexington County Sheriff’s Department seized both motorcycles as evidence. AAC was not notified of the seizures or the motorcycles’ location and learned about the events through news reports. AAC contacted the Sheriff’s Department seeking information and access to the motorcycles but was told that the vehicles would not be returned until the criminal proceedings concluded.AAC initially filed claim and delivery actions in the Lexington County Circuit Court, but the court dismissed these actions for improper service, noting it would not order release of evidence during a pending murder case. AAC then brought suit in the Lexington County Court of Common Pleas under state law and 42 U.S.C. § 1983, alleging procedural due process violations. The Sheriff’s Department removed the case to the United States District Court for the District of South Carolina, which dismissed AAC’s federal claim, holding that the seizure was lawful and that AAC’s property interests must yield to the state’s duty to preserve evidence for criminal proceedings. The district court remanded the state law claims.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit held that when property is seized in connection with a criminal investigation, the Fourth Amendment defines the process that is due, and compliance with its requirements satisfies procedural due process. The court found the seizures lawful and determined that no additional process was required for AAC as a lienholder. The court affirmed the district court’s order granting the defendants’ motion to dismiss. View "American Acceptance Corporation of SC v. Gietz" on Justia Law

A defendant, who co-founded an animal rights organization, participated in “open rescues” at two poultry farms in Sonoma County, California. These actions involved entering private property without permission to document suspected animal cruelty and, in some cases, removing animals believed to be suffering. The defendant relied on legal and veterinary opinions suggesting his actions were justified to prevent harm to the animals. He was charged with felony conspiracy to commit trespass, misdemeanor trespass, and related offenses, arising from two incidents at Sunrise Farms and Reichardt Duck Farm.The case was tried in the Superior Court of Sonoma County. The defendant represented himself and sought to present a necessity defense, arguing he believed his conduct was lawful based on legal advice. The trial court ruled the necessity defense legally unavailable, finding no emergency or imminent threat justifying trespass. It also restricted the mistake of law defense, limiting it to a statutory provision that allowed trespass only to provide food or water to animals deprived for over 12 hours. The jury convicted the defendant on most counts, except one which was dismissed after a hung verdict. The defendant appealed, raising issues about the exclusion of his necessity defense, the limited mistake of law instruction, and constitutional challenges to the statutes involved.The Court of Appeal of the State of California, First Appellate District, Division Five, reviewed the case. It held that the trial court erred by excluding evidence and jury instructions on the defendant’s good faith mistake of law based on necessity, which was relevant to the specific intent crimes charged. The appellate court reversed the convictions for conspiracy to commit trespass and trespass with intent to interfere with a business, remanding for further proceedings. The conviction for trespass by refusing to leave property was affirmed. The court rejected constitutional challenges to the relevant statutes. View "P. v. Hsiung" on Justia Law

Two consolidated cases involved fathers incarcerated in Idaho whose parental rights were terminated in private proceedings initiated by the mothers of their children. In each case, a county public defender was initially appointed to represent the indigent father at the trial level. After the 2025 enactment of Senate Bill 1181, which altered the state’s indigent defense system, the counties argued they were no longer responsible for providing counsel in private termination cases, and the new State Public Defender (SPD) asserted it was not statutorily required to represent parents in such cases. The trial courts ultimately appointed counsel at county expense. After judgments terminating parental rights were entered and appeals were filed, questions arose as to whether the fathers were entitled to counsel and appellate costs at public expense, and if so, who was responsible for providing and funding these services.Previously, Idaho law categorically provided indigent parents in termination proceedings the right to appointed counsel, with counties typically responsible for payment. Senate Bill 1181, effective July 1, 2025, limited the right to counsel to cases where it is “constitutionally required” and made clear that the SPD’s obligation to provide indigent defense did not extend to private termination cases. It also barred counties from being required to fund indigent defense in such cases. With these statutory changes, the Idaho Supreme Court confronted the resulting gap in representation.The Idaho Supreme Court held that, under the Due Process Clauses of the Idaho and U.S. Constitutions, indigent parents in private termination cases may be constitutionally entitled to counsel at public expense, including on appeal, but this right is not automatic and must be determined case by case. The Court further held that, after the legislative changes, no state agency or county can be required to provide such representation, though they may do so voluntarily. However, all indigent parents appealing termination orders are constitutionally entitled to records and transcripts at public expense, and if not otherwise provided, those costs must be paid from the county district court fund. View "Doe v. Doe" on Justia Law

The defendant, a person of Mexican descent, worked at a tax preparation business serving Spanish-speaking clients in Boise, Idaho. He was indicted on seven counts of preparing and presenting false and fraudulent tax returns. During jury deliberations, it became undisputed that one juror made racially biased comments about Mexicans. This juror, identified as Juror 5, participated in nearly all deliberations and expressed views suggesting animus toward Mexicans, including remarks about how Mexicans "hate Americans" and allegations connecting the defendant's employer to criminal activity.After the biased statements were reported, the United States District Court for the District of Idaho conducted a special voir dire with all jurors to determine the impact of the comments. Several jurors confirmed hearing the remarks, but most denied being influenced by them. The district court excused Juror 5 for good cause but allowed the remaining eleven jurors to continue deliberations without instructing them to start anew. Thirteen minutes later, the jury returned a partial verdict. The defendant moved for a mistrial and later for a new trial, arguing that his Sixth Amendment right to an impartial jury was violated. The district court denied both motions, applying the standard from United States v. Sarkisian, which asks whether exposure to prejudicial comments tainted the verdict.On appeal, the United States Court of Appeals for the Ninth Circuit held that the district court applied an incorrect legal standard. The Ninth Circuit concluded that the proper standard is from United States v. Remmer, which presumes prejudice when juror bias is discovered before a verdict is accepted, and places a heavy burden on the government to prove harmlessness. The court found that the government failed to rebut this presumption, and therefore reversed the district court’s denial of the motion for a new trial and remanded for a new trial. View "USA V. SANCHEZ" on Justia Law

A group of plaintiffs challenged the Oklahoma State Board of Education’s adoption of the 2025 Social Studies Standards, arguing the standards were improperly enacted and violated statutory and constitutional rights, including compelled viewpoint-specific speech in public education. After the Board approved the standards, the plaintiffs sought declaratory and injunctive relief to prevent their implementation, claiming both procedural errors in their adoption and substantive harms to students, parents, and teachers.The District Court for Oklahoma County heard the case and granted the defendants’ motions to dismiss, determining that the plaintiffs were unlikely to succeed and that their claims about the Oklahoma Administrative Code were incorrect. The District Court also denied the plaintiffs’ request for a preliminary injunction. The plaintiffs appealed, raising issues about administrative procedures, standing, and the denial of an opportunity to amend their petition.While the appeal was pending, the Oklahoma Supreme Court in Randall v. Fields, 2025 OK 91, held that the 2025 Social Studies Standards could not be enforced due to violations of the Oklahoma Open Meeting Act, rendering the standards void. In light of this, the Supreme Court of the State of Oklahoma determined that the plaintiffs’ claims for relief were now moot because the challenged standards no longer existed. The Court found that neither the “broad public interest” nor “capable of repetition yet evading review” exceptions to mootness applied. Accordingly, the Supreme Court dismissed the appeal as moot, reversed the District Court’s judgment, and directed the lower court to dismiss the plaintiffs’ petition without prejudice due to mootness. View "FORD v. THE OKLAHOMA STATE DEPARTMENT OF EDUCATION" on Justia Law

A group of noncitizens from Mexico, El Salvador, Venezuela, Nicaragua, and Guatemala, who had lived in the United States for years without lawful status, were arrested by federal immigration authorities and detained under 8 U.S.C. § 1225(b)(2)(A) without being granted bond hearings. Most had only minor traffic offenses and many were parents to U.S.-citizen children. Their detention was based on the interpretation that, as “applicants for admission,” they were subject to mandatory detention without individualized assessment of flight risk or dangerousness.Each petitioner filed a writ of habeas corpus in either the United States District Court for the Eastern District of Michigan or the Western District of Michigan. They argued that they should have been detained, if at all, under 8 U.S.C. § 1226, which allows for bond hearings, not under the mandatory detention provision. They also claimed that detention without a bond hearing violated their Fifth Amendment due process rights. The district courts agreed with the petitioners, holding that § 1226(a) governed their detention, requiring bond hearings, and that detention without such a hearing violated due process for those who had lived in the interior of the United States for years.The United States Court of Appeals for the Sixth Circuit reviewed these consolidated appeals. The court held that noncitizens present in the interior of the United States who have not affirmatively sought lawful entry are not “seeking admission” under § 1225(b)(2)(A) and therefore are not subject to mandatory detention without bond. Instead, their detention is governed by § 1226, which requires an individualized bond hearing. The court also affirmed that detaining such noncitizens without a bond hearing violates the Fifth Amendment’s Due Process Clause. The court affirmed the district courts’ judgments granting habeas relief. View "Lopez-Campos v. Raycraft" on Justia Law

A native and citizen of Honduras entered the United States without admission or parole and was taken into custody. Shortly after her release, the Department of Homeland Security (DHS) served her with a Notice to Appear, written in English, which informed her of the obligation to notify the immigration court of any change of address. She provided an address in Hanford, California, which was used for subsequent correspondence. After moving to a new address without notifying the immigration court, she missed a scheduled removal hearing, and was ordered removed in absentia.The Immigration Judge (IJ) denied her motion to reopen the removal proceedings, finding that she had received proper notice by mail to her last known address. Her subsequent motion to reconsider was also denied; the IJ found she had constructive notice because the Notice to Appear was sent to her last provided address, and that she had been properly informed of her obligation to update her address. On appeal, the Board of Immigration Appeals (BIA) upheld the IJ’s decisions, concluding that jurisdiction was not impacted by the allegedly defective Notice to Appear, and that mailing the Notice of Hearing to her last provided address was sufficient under the applicable statutory and Supreme Court precedent.On review, the United States Court of Appeals for the Ninth Circuit held that DHS is not constitutionally required to provide a translation of the entirety of a Notice to Appear—including the obligation to update an address—in an alien’s native language. The court found that English-language notices are generally sufficient to satisfy due process because they are reasonably calculated to inform recipients of their obligations. The petition for review was denied. View "URQUIA-YANEZ V. BLANCHE" on Justia Law

The case concerns the process by which a proposed constitutional amendment, authorizing partisan gerrymandering of congressional districts in Virginia, was submitted to the voters. The General Assembly approved the proposed amendment during a disputed special session in October 2025, after voting in the general election for the House of Delegates had already begun. Approximately 1.3 million votes had been cast before the General Assembly’s first vote on the amendment. The General Assembly then approved the proposal again in the 2026 regular session, and the amendment was put to a popular vote, ultimately passing by a narrow margin. The new map, contingent on the amendment’s approval, would have significantly shifted the partisan balance of Virginia’s congressional delegation.The Circuit Court of Tazewell County reviewed challenges to the constitutional amendment process, focusing on whether the requirements of Article XII, Section 1 of the Virginia Constitution, which governs the procedure for amending the state constitution, were properly followed. The central issue was whether the intervening general election required by the Constitution occurred after the General Assembly’s first vote on the amendment but before the second, thus giving voters the intended opportunity to influence the process.The Supreme Court of Virginia held that the legislative process used to advance the proposed amendment violated Article XII, Section 1 of the Virginia Constitution because the first legislative vote occurred after voting in the general election had already begun. The court concluded that the “general election” includes the entire period when votes are cast, not just Election Day, and strict compliance with the constitutionally mandated procedure is required. As a result, the referendum and the amendment were declared null and void. The court affirmed that the existing, nonpartisan congressional maps remain in effect for the upcoming elections. View "Scott v. McDougle" on Justia Law

The case centers on an economic development agreement between a city and county in Texas and a private foundation, aimed at fostering the construction of a retail shopping center anchored by a Gander Mountain store. The city and county pledged portions of future sales-tax revenues to the foundation, which used the funds to secure a construction loan for the facility. The agreements required that the tax proceeds be used solely to repay the construction debt. Gander Mountain operated for eleven years before closing its store, but the shopping center continued to generate significant economic activity and tax revenue, with the former anchor tenant’s space later occupied by another retailer.After Gander Mountain’s closure in 2015, the city and county ceased payments, claiming the public purpose of the grants had ended. They sought declaratory relief in the District Court of Navarro County, arguing that continued payments would be unconstitutional under the Texas Constitution’s Gift Clauses. The district court granted summary judgment to the city and county, ruling that the closure ended the public purpose and that the agreements lacked sufficient controls to ensure public purposes were met. The Court of Appeals for the Tenth District of Texas affirmed, holding that the economic development grants remained subject to the Gift Clauses and that the agreements failed to satisfy their requirements.The Supreme Court of Texas reviewed the case and held that economic-development grants authorized by article III, section 52-a of the Texas Constitution remain subject to the Gift Clauses. The Court determined that the lower courts erred by focusing narrowly on the operation of a specific store rather than the broader public purpose of economic development. It held that the agreements likely satisfied the constitutional requirements of public purpose, consideration, and adequate controls, and that summary judgment was improper. The Supreme Court of Texas reversed the lower courts’ judgments and remanded the case for further proceedings. View "JPMORGAN CHASE BANK, N.A. v. CITY OF CORSICANA AND NAVARRO COUNTY" on Justia Law