Justia Constitutional Law Opinion Summaries
State v. Lee
Garrett Alan Lee, a 25-year-old, engaged in an online conversation with an undercover law enforcement officer posing as a 12-year-old girl. Lee discussed meeting the girl for sex and was apprehended by law enforcement when he arrived at the arranged location. He was charged with Sexual Abuse of Children under Montana law and pleaded guilty.The Thirteenth Judicial District Court sentenced Lee to 100 years at the Montana State Prison, with 65 years suspended, and imposed a 25-year parole restriction. Lee appealed, arguing that the mandatory 25-year parole restriction was unconstitutional and that the District Court violated his due process rights by considering information from a prior psychosexual examination not admitted into evidence.The Montana Supreme Court reviewed the case. The court held that Lee's constitutional and statutory arguments concerning the mandatory parole restriction were not properly before the court because he was not sentenced under the mandatory minimum provision. Instead, the District Court imposed the parole restriction under its discretionary sentencing power. The court also found that Lee's due process rights were not violated, as he had the opportunity to rebut or correct any information in the presentence investigation report, and the information was not materially false.The Montana Supreme Court affirmed the District Court's judgment, concluding that Lee's sentence was legal and within the statutory parameters. The court declined to review the constitutional and statutory claims related to the mandatory parole restriction and did not find plain error in the due process claim. View "State v. Lee" on Justia Law
Andrews v. Lombardi
In 2012, the City of Providence suspended cost-of-living adjustment (COLA) pension benefits for retired police and fire department members. The retirees challenged this suspension, leading to a series of legal actions. Most retirees settled, agreeing to a ten-year suspension of their COLA benefits, but some plaintiffs opted out and pursued further legal action, claiming breach of contract and constitutional violations.The Superior Court granted partial summary judgment for the City on some claims and, after a bench trial, ruled against the plaintiffs on the remaining claims. The plaintiffs appealed, and the Rhode Island Supreme Court in Andrews I found that the 2012 ordinance violated the separation of powers doctrine by attempting to override prior consent judgments and judicial decisions. The case was remanded, and the Superior Court reinstated the plaintiffs' COLAs and awarded accrued benefits but did not address prejudgment interest.The plaintiffs then sought prejudgment interest on the past-due COLA payments, which the Superior Court denied, reasoning that the damages were not contractual in nature but were awarded based on constitutional grounds. The plaintiffs appealed this decision.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the plaintiffs' recovery of past-due COLAs was based on the enforcement of final judgments, not on a breach of contract. Since the award was rooted in constitutional law rather than contract law, the plaintiffs were not entitled to prejudgment interest under the relevant statute, which applies strictly to tort and contract claims. View "Andrews v. Lombardi" on Justia Law
Andrews v. Lombardi
The plaintiffs, retired police officers and firefighters, challenged the constitutionality of a 2011 Medicare Ordinance enacted by the City of Providence, which required retirees to enroll in Medicare upon eligibility and terminated city-paid health care coverage for Medicare-eligible retirees. The plaintiffs, who opted out of a settlement agreement that provided certain Medicare-related benefits, sought retroactive reimbursement for out-of-pocket health care expenses incurred during the litigation.The Superior Court initially granted partial summary judgment in favor of the City on some claims and, after a bench trial, denied relief on the remaining claims. The plaintiffs appealed, and the Rhode Island Supreme Court in Andrews II remanded the case with instructions to enter judgment consistent with the specific provisions of the 2013 Final and Consent Judgment, which did not include retroactive reimbursement for health care expenses.Upon remand, the plaintiffs sought reimbursement for out-of-pocket expenses, but the Superior Court denied this request, concluding that such relief was outside the scope of the Supreme Court's mandate in Andrews II. The plaintiffs appealed this decision.The Rhode Island Supreme Court affirmed the Superior Court's judgment, holding that the mandate in Andrews II did not contemplate or include retroactive relief for health care expenses. The Court emphasized that the mandate was prospective in nature and aligned with the 2013 Final and Consent Judgment, which did not provide for reimbursement of past expenses. The Court also noted that the plaintiffs had waived claims for individual damages during the trial and had not sought such damages in their amended complaint. View "Andrews v. Lombardi" on Justia Law
Civil Rights Dept. v. Cathy’s Creations
A bakery refused to sell a predesigned white cake to a same-sex couple for their wedding reception, citing a policy against providing cakes for same-sex weddings based on the owner's religious beliefs. The California Civil Rights Department (CRD) filed a lawsuit on behalf of the couple, alleging discrimination under the Unruh Civil Rights Act (UCRA). The trial court ruled in favor of the bakery, finding no violation of the UCRA because the CRD failed to prove intentional discrimination and concluded that referring the couple to another bakery constituted full and equal access under the UCRA. The trial court also considered the bakery's First Amendment defenses, concluding that the UCRA compelled the bakery to speak a message about marriage to which they objected.The CRD appealed, challenging the trial court's interpretation and application of the UCRA and its conclusions regarding the bakery's affirmative defenses. The California Court of Appeal reviewed the case and determined that the bakery's policy was not facially neutral and misconstrued the intentional discrimination standard. The court found that the policy was inherently discriminatory as it required a distinction in service based on the sexual orientation of the end user. The court also concluded that referring the couple to another bakery did not satisfy the UCRA's full and equal access requirement.The court further analyzed the bakery's First Amendment defenses, determining that the cake in question did not constitute pure speech or expressive conduct protected by the First Amendment. The court found that the cake was a generic, multi-purpose product and that its preparation and delivery did not convey any particularized message about marriage. Additionally, the court concluded that the UCRA is a neutral and generally applicable law that satisfies rational basis review and does not violate the bakery's free exercise of religion under the federal or state constitutions.The California Court of Appeal reversed the trial court's judgment and remanded the case for further proceedings consistent with its opinion. View "Civil Rights Dept. v. Cathy's Creations" on Justia Law
F.S. v. Missouri Department of Corrections, Division of Probation and Parole
F.S. was found guilty by a jury of statutory sodomy of an 11-year-old victim and sentenced to five years in prison. After completing her sentence and parole, she was subjected to lifetime electronic monitoring by the Missouri Department of Corrections under section 217.735. This monitoring involves wearing an ankle bracelet that tracks her location via GPS. F.S. challenged the constitutionality of this lifetime monitoring requirement, arguing it violated her Fourth Amendment rights.The Circuit Court of Cole County upheld the constitutionality of section 217.735. During the bench trial, the court received stipulated facts, exhibits, and testimony from experts. The court found that GPS monitoring can deter recidivism among sex offenders by enforcing exclusion zones and increasing the certainty of legal repercussions. The court also noted that F.S. had not reoffended since completing parole but found that sex offenders with child victims tend to reoffend over a longer period. The court concluded that the GPS monitoring was a reasonable search under the Fourth Amendment, given F.S.'s diminished expectation of privacy as a convicted sex offender and the state's legitimate interest in protecting potential victims.The Supreme Court of Missouri reviewed the case de novo and affirmed the circuit court's judgment. The court held that F.S. failed to present particularized evidence showing that section 217.735 was unconstitutionally applied to her circumstances. The court emphasized that F.S.'s status as a female offender and her lack of reoffending did not suffice to demonstrate that the statute was unreasonable as applied to her. The court concluded that the statute did not clearly contravene any specific constitutional provision and upheld the lifetime monitoring requirement. View "F.S. v. Missouri Department of Corrections, Division of Probation and Parole" on Justia Law
K. J. V. JACKSON
A high school student, K.J., was involved in a fight on campus and was initially suspended for three days. After reviewing surveillance footage and learning about injuries sustained during the fight, school officials extended K.J.'s suspension and recommended his expulsion, without informing him of the new charges or evidence. K.J. was not given an opportunity to respond to these new allegations.The United States District Court for the Southern District of California found that the school officials violated K.J.'s procedural due process rights by not informing him of the new charges or evidence. However, the court granted summary judgment in favor of the defendants, holding that they were entitled to qualified immunity because the law was not clearly established regarding due process protections for suspension extensions. The court also held that K.J. lacked standing to seek expungement of his disciplinary record, as it was speculative that the record would harm his reputation or future prospects.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment. The Ninth Circuit agreed that K.J.'s due process rights were violated, as he was not given notice of the new charges or an opportunity to respond. The court held that the defendants were not entitled to qualified immunity because the requirements for due process in school suspensions were clearly established in Goss v. Lopez. The court also held that K.J. had standing to seek expungement of his disciplinary record and that such relief was not barred by Eleventh Amendment sovereign immunity. The case was remanded to the district court to consider K.J.'s claims for damages and expungement. View "K. J. V. JACKSON" on Justia Law
Densmore v. People
In February 2017, Adam Douglas Densmore lived in Boulder with his child and the child's mother, Ashley Mead. After Mead went missing, Densmore was arrested in Oklahoma with the child. The Oklahoma Department of Human Services took custody of the child, and caseworker Jessica Punches interviewed Densmore at the jail without providing Miranda warnings. Punches's role was to ensure the child's safety and find appropriate placement, not to conduct criminal investigations.The trial court denied Densmore's motion to suppress his statements to Punches, finding that she was not acting as an agent of law enforcement. The court of appeals affirmed, applying a totality of the circumstances test and concluding that Punches's primary duties were related to child welfare, not law enforcement.The Supreme Court of Colorado reviewed the case to determine if Miranda v. Arizona applies when a Department of Human Services caseworker conducts a custodial interrogation. The court concluded that courts must consider the totality of the circumstances, including both objective and subjective factors, to determine if a caseworker acted as an agent of law enforcement. Applying this standard, the court found that Punches did not act as an agent of law enforcement and was not required to provide Miranda warnings. The court affirmed the judgment of the court of appeals. View "Densmore v. People" on Justia Law
Virden v. City of Austin
Jennifer Virden, a small business owner in Austin, Texas, ran for city council in 2020 and for mayor in 2022. The City of Austin has a regulation that prohibits candidates from fundraising outside a one-year period before the general election. Virden announced her candidacy for the 2022 election in March 2021, which was seven months before she could start fundraising under the ordinance. She filed a lawsuit challenging the one-year fundraising window as unconstitutional under the First Amendment.The United States District Court for the Western District of Texas initially denied Virden's request for a preliminary injunction, finding no irreparable harm. Virden's interlocutory appeal was dismissed as moot after the fundraising window opened. The district court later granted summary judgment in part, ruling that the one-year fundraising window was unconstitutional and awarding nominal damages to Virden and her donor, William Clark. The court found that the claims for declaratory and injunctive relief were moot since the 2022 election had ended and there were no concrete plans for future campaigns. The court also refused to consider evidence regarding Virden's desire to contribute to another candidate in the 2024 election, deeming the submission untimely.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that the one-year fundraising window was unconstitutional, agreeing that it violated the First Amendment. The court also upheld the award of nominal damages to Virden and Clark. Additionally, the court found that the district court did not abuse its discretion in refusing to consider the late evidence regarding the 2024 election. The Fifth Circuit concluded that the suit was timely, Virden had standing, and the city's arguments were without merit. The court affirmed the district court's decision in its entirety. View "Virden v. City of Austin" on Justia Law
Pitsilides v. Barr
George Pitsilides, a successful restaurateur and professional poker player, was convicted in 1998 in Pennsylvania for criminal conspiracy to commit pool selling and bookmaking, and two counts of pool selling and bookmaking. These offenses are classified as first-degree misdemeanors in Pennsylvania, punishable by up to five years’ imprisonment. Consequently, under 18 U.S.C. § 922(g)(1), Pitsilides is barred from possessing a firearm. Despite these convictions, Pitsilides continued to engage in illegal gambling activities, leading to further convictions in Virginia in 2011 for operating an illegal gambling enterprise.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of the Government, applying the two-step framework from Binderup v. Attorney General. The court concluded that Pitsilides failed to show his convictions were not serious and rejected his argument that his offenses fell within the carveout for business-related offenses under 18 U.S.C. § 921(a)(20)(A).The United States Court of Appeals for the Third Circuit reviewed the case. The court noted that the legal landscape had changed significantly since the District Court's decision, particularly with the Supreme Court's rulings in New York State Rifle & Pistol Ass’n v. Bruen and United States v. Rahimi, and the Third Circuit's en banc decision in Range v. Attorney General. These cases emphasized the need for individualized assessments of whether a felon poses a danger to public safety when challenging firearm prohibitions under the Second Amendment.The Third Circuit concluded that the record was insufficient to determine whether § 922(g)(1) is unconstitutional as applied to Pitsilides. The court affirmed in part, vacated in part, and remanded the case to the District Court for further factual development to assess whether Pitsilides poses a special danger of misusing firearms. View "Pitsilides v. Barr" on Justia Law
OLSON V. COUNTY OF GRANT
Haley Olson was arrested in Idaho for marijuana possession and consented to a search of her phone by Idaho police, who created a copy of its contents. Glenn Palmer, then-Sheriff of Grant County, Oregon, learned of the arrest and, curious about Olson's relationship with Grant County Deputy Tyler Smith, asked County Attorney Jim Carpenter to request the phone extraction from the Idaho prosecutor. Carpenter obtained and reviewed the extraction, allegedly deleting it afterward. However, Olson later heard gossip about the contents of her phone, including nude photos, seemingly originating from the sheriff’s office. Olson sued Palmer, Carpenter, and Grant County, alleging Fourth Amendment violations.The United States District Court for the District of Oregon granted summary judgment for Palmer, finding no supervisory liability, and for Carpenter, granting him qualified immunity as his actions did not violate clearly established law. Olson appealed these decisions.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court agreed that Palmer was not liable due to lack of supervisory authority over Carpenter. The court also held that Carpenter was entitled to qualified immunity because Olson’s right to be free from Carpenter’s search was not clearly established at the time. However, the court concluded that Carpenter’s search did violate Olson’s Fourth Amendment rights, as it was conducted without a warrant, consent, or suspicion of criminal activity. The court emphasized the importance of developing constitutional precedent in this area, despite affirming the grant of qualified immunity to Carpenter. View "OLSON V. COUNTY OF GRANT" on Justia Law