Justia Constitutional Law Opinion Summaries

The case involves six plaintiffs who are users of Tornado Cash, a cryptocurrency mixing service that uses immutable smart contracts to anonymize transactions. Tornado Cash was sanctioned by the Office of Foreign Assets Control (OFAC) under the International Emergency Economic Powers Act (IEEPA) for allegedly facilitating money laundering for malicious actors, including North Korea. The plaintiffs argued that OFAC exceeded its statutory authority by designating Tornado Cash as a Specially Designated National (SDN) and blocking its smart contracts.The United States District Court for the Western District of Texas granted summary judgment in favor of the Department of the Treasury, finding that Tornado Cash is an entity that can be sanctioned, that its smart contracts constitute property, and that the Tornado Cash DAO has an interest in these smart contracts. The plaintiffs appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and focused on whether the immutable smart contracts could be considered "property" under IEEPA. The court concluded that these smart contracts are not property because they are not capable of being owned, controlled, or altered by anyone, including their creators. The court emphasized that property, by definition, must be ownable, and the immutable smart contracts do not meet this criterion. Consequently, the court held that OFAC exceeded its statutory authority by sanctioning Tornado Cash's immutable smart contracts.The Fifth Circuit reversed the district court's decision and remanded the case with instructions to grant the plaintiffs' motion for partial summary judgment based on the Administrative Procedure Act. The court did not address whether Tornado Cash qualifies as an entity or whether it has an interest in the smart contracts, as the determination that the smart contracts are not property was dispositive. View "Van Loon v. Department of the Treasury" on Justia Law

Stephen Bullis was convicted of six federal crimes, including two counts of using a firearm during and in relation to other crimes, in violation of 18 U.S.C. § 924(c). After serving twenty-three years in prison, the United States Supreme Court struck down the “residual clause” of 18 U.S.C. § 924(c) as unconstitutional. This led the district court to set aside Bullis’s two Section 924(c) convictions and resentence him on the remaining four counts. Bullis argued that the resentencing violated his rights under the Double Jeopardy Clause because he had fully served his sentence on these counts at the time of the resentencing.The United States District Court for the Eastern District of North Carolina initially sentenced Bullis to 235 months of imprisonment on each of Counts 1, 2, 4, and 5, all to run concurrently. On Count 3, Bullis was sentenced to 360 months, and on Count 6, he received a lifetime sentence, both to run consecutively to the 235-month concurrent sentences. After the Supreme Court’s ruling, the district court vacated Counts 3 and 6 and resentenced Bullis to 450 months on Count 2 and 240 months on Counts 1, 3, and 5, all to run concurrently.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Bullis’s resentencing did not violate the Double Jeopardy Clause because his sentences for Counts 1, 2, 4, and 5 were part of a consecutive sentence package that had not been fully served. However, the court found that the district court committed reversible errors by imposing a special condition of supervised release that differed materially from the court’s oral pronouncement and by failing to incorporate clearly the Standard Conditions of Supervision as adopted in the Eastern District of North Carolina. Consequently, the Fourth Circuit vacated and remanded the case for resentencing. View "US v. Bullis" on Justia Law

Grace Smith, a high school junior, was repeatedly suspended from Laramie High School for refusing to comply with a COVID-19 indoor-mask mandate imposed by the Albany County School District No. 1 Board of Trustees. After her suspensions, she was arrested for trespassing on school grounds. Grace and her parents, Andy and Erin Smith, filed a lawsuit in the United States District Court for the District of Wyoming against the Board members, the superintendent, and the principal, alleging violations of Grace’s constitutional rights and state law claims.The district court dismissed the federal claims for lack of jurisdiction, ruling that Grace did not suffer an injury in fact necessary for standing. The court reasoned that her injuries were hypothetical because the mask mandate had expired and she was no longer a student at LHS, and that her injuries were self-inflicted. The court declined to exercise supplemental jurisdiction over the state-law claims.The United States Court of Appeals for the Tenth Circuit reviewed the dismissal de novo and reversed the district court’s decision. The appellate court held that Grace had standing to bring her claims because she suffered concrete and particularized injuries from the enforcement of the mask mandate, including suspensions and arrest. The court found that her injuries were directly inflicted by the defendants’ actions and were not self-inflicted. The case was remanded for further proceedings consistent with the appellate court’s opinion. View "Smith v. Albany County School District No. 1" on Justia Law

A police officer stopped Taylor Pinder for speeding. Pinder provided a driver's license that did not match his appearance. The officer arrested Pinder for providing false identification, a misdemeanor in Utah. During a search of the car incident to the arrest, the officer found methamphetamine and a handgun. Pinder was charged federally and moved to suppress the evidence, arguing the search violated the Fourth Amendment. The district court denied the motion, and Pinder pled guilty to possession of methamphetamine with intent to distribute, reserving the right to appeal the suppression ruling. He was sentenced to 120 months in prison and five years of supervised release.The United States District Court for the District of Utah denied Pinder's motion to suppress, concluding the search was justified under Arizona v. Gant, which allows vehicle searches incident to arrest if it is reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle. The court also suggested the search might be justified based on Pinder's supervised release conditions.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the search did not violate the Fourth Amendment. The Tenth Circuit held that Pinder's real driver's license was relevant to the crime of providing false identification, even after the officer verified his identity. The court did not address the district court's alternative reasoning regarding supervised release conditions or the government's good faith argument raised for the first time on appeal. View "United States v. Pinder" on Justia Law

Joseph W. Russell entered a conditional guilty plea to possession of methamphetamine, reserving his right to appeal the constitutionality of a warrantless search conducted as he entered the Uinta County Courthouse. The search, performed by Deputy Dan Jensen, involved a magnetometer alerting to metal in Russell's waist area, leading to a pat-down and the discovery of a snus can containing methamphetamine. Russell was charged with felony possession of a controlled substance.The district court denied Russell's motion to suppress the evidence, finding the search reasonable under the Fourth Amendment. Russell entered a conditional guilty plea, allowing him to appeal the suppression order. He was sentenced to one to three years of imprisonment, suspended in favor of two years of supervised probation. Russell timely appealed the denial of his motion to suppress.The Wyoming Supreme Court reviewed the case, focusing on whether the search violated the Fourth Amendment. The court applied a three-part test to determine the reasonableness of the search: the nature and immediacy of the governmental concern, the efficacy of the search in addressing that concern, and the nature of the privacy interest upon which the search intrudes. The court found that courthouse security is a compelling governmental interest, the use of a magnetometer and follow-up searches are effective in addressing this concern, and the privacy interest in the snus can was minimal given the context of courthouse security.The court concluded that the search was reasonable and affirmed the district court's denial of Russell's motion to suppress. The holding emphasized that the search was justified under the special needs exception to the Fourth Amendment, balancing the government's interest in courthouse security against the minimal intrusion on Russell's privacy. View "Russell v. State" on Justia Law

Victor Ibhawa, a Black, Nigerian Catholic priest, was hired by the Diocese of Buffalo in 2016 as the Parish Administrator of the Blessed Trinity Church. He was reappointed in January 2019 for another three-year term but was terminated on September 28, 2020. Ibhawa filed a complaint with the New York State Division of Human Rights (DHR) in November 2020, alleging racial discrimination, including incidents involving racial slurs and xenophobic remarks. He claimed that Diocesan officials failed to investigate these incidents and made offensive remarks about foreign priests. Ibhawa's employment was terminated, and his priestly faculties were removed, preventing him from applying for another priest position in the Diocese. He alleged hostile work environment and unlawful termination based on race and national origin.The DHR dismissed Ibhawa's complaint, citing the "ministerial exception" under the First Amendment, which it interpreted as a jurisdictional bar. The New York Supreme Court partially reversed this decision, finding that while the unlawful termination claim was properly dismissed, the hostile work environment claim required further consideration. The Appellate Division, however, reinstated the DHR's dismissal, emphasizing deference to the agency's expertise and noting the lack of controlling precedent on the ministerial exception's applicability to hostile work environment claims.The New York Court of Appeals reviewed the case and determined that the DHR erred in treating the ministerial exception as a jurisdictional bar rather than an affirmative defense. The court noted that the U.S. Supreme Court has held that the ministerial exception is an affirmative defense, not a jurisdictional bar. Consequently, the Court of Appeals reversed the Appellate Division's order and remitted the case to the DHR for further proceedings consistent with this opinion. View "Ibhawa v New York State Div. of Human Rights" on Justia Law

Trevor I. DesRosiers was convicted by a jury in the Penobscot County Unified Criminal Docket on three counts of sexual abuse of a minor and three counts of furnishing liquor to a minor. DesRosiers appealed, arguing insufficient evidence to prove he and the victim were not married during the sexual acts and to establish the victim’s age for Counts 1-4. He also claimed prosecutorial errors in closing arguments deprived him of a fair trial.The trial court denied DesRosiers’s motion for judgment of acquittal, and the jury found him guilty on all counts. The court sentenced him to concurrent terms of forty-two months for sexual abuse and three months for furnishing liquor, with all but twenty months suspended. DesRosiers appealed the conviction.The Maine Supreme Judicial Court reviewed the case. The court found sufficient evidence to support the jury’s conclusion that DesRosiers and the victim were not married, based on the victim’s age, living situation, and the nature of their relationship. The court also found sufficient evidence to establish the victim’s age during the offenses, as she was fifteen throughout the relevant period.Regarding prosecutorial errors, the court determined that most of the prosecutor’s comments did not constitute error. However, the prosecutor’s comment on DesRosiers’s invocation of his Fourth Amendment right was deemed error but not obvious error. The court concluded that this isolated comment did not undermine the trial’s integrity or affect the verdict.The Maine Supreme Judicial Court affirmed the judgment of conviction. View "State of Maine v. Desrosiers" on Justia Law

In June 2019, the petitioner's 13-year-old daughter, T., disclosed to a friend, a teacher, a police officer, and a caseworker from the New York City Administration for Children's Services (ACS) that the petitioner had struck her with an extension cord. The caseworker took photographs of T.'s injuries, and a physician confirmed that the injuries were consistent with being struck by an extension cord. ACS initiated a Family Court article 10 neglect proceeding against the petitioner and her husband. The Family Court authorized an adjournment in contemplation of dismissal (ACD), and the case was dismissed in February 2020 after the petitioner complied with the court's conditions.The police officer reported the incident to the Statewide Central Register of Child Abuse and Maltreatment (SCR). In July 2019, ACS determined the report against the petitioner was indicated. The petitioner challenged this determination, but the New York State Office of Children and Family Services (OCFS) upheld it after an internal review. A fair hearing was held in August 2020, and OCFS concluded that the allegations were substantiated by a fair preponderance of the evidence.The petitioner then commenced a CPLR article 78 proceeding to challenge OCFS's determination. The Supreme Court transferred the proceeding to the Appellate Division, which confirmed OCFS's determination, denied the petition, and dismissed the proceeding. The Appellate Division held that the petitioner had no constitutional right to assigned counsel during the SCR hearing and that the statutory changes to Social Services Law § 422 did not apply retroactively.The New York Court of Appeals affirmed the Appellate Division's decision. The Court held that the petitioner had no constitutional right to assigned counsel during the SCR administrative hearing. It also concluded that the statutory amendments to Social Services Law § 422 (8) (b) (ii) did not apply retroactively to OCFS determinations rendered before the effective date of the amendments. The Court further held that OCFS's determination was supported by substantial evidence. View "Matter of Jeter v. Poole" on Justia Law

The plaintiffs, Clarence Cocroft and Tru Source Medical Cannabis, L.L.C., challenged Mississippi's restrictions on advertising medical marijuana, arguing that the First Amendment protects their right to advertise because the state permits the underlying commercial transactions. They sought declaratory and injunctive relief against state officials in their official capacities.The United States District Court for the Northern District of Mississippi dismissed the case under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court applied the Central Hudson test for commercial speech and held that because federal law criminalizes marijuana, including medical marijuana, the advertising of such transactions does not qualify for First Amendment protection.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that under the Central Hudson test, commercial speech must concern lawful activity to receive First Amendment protection. Since the Controlled Substances Act (CSA) prohibits marijuana nationwide, including in Mississippi, the underlying commercial conduct is illegal. Therefore, the state faces no constitutional obstacle to restricting commercial speech related to unlawful transactions. The court concluded that the First Amendment does not protect the advertising of medical marijuana in Mississippi due to its illegal status under federal law. View "Cocroft v. Graham" on Justia Law

In 2021, the Texas Legislature enacted Senate Bill 8, known as the Texas Heartbeat Act, which prohibits physicians from performing abortions if a fetal heartbeat is detected. The Act allows enforcement only through private civil actions. Plaintiffs, including Allison Van Stean and various Planned Parenthood entities, alleged that Texas Right to Life (TRTL) organized efforts to sue those violating the Act. They filed multiple suits challenging the Act's constitutionality and sought injunctions to prevent TRTL from enforcing it. The cases were consolidated, and TRTL filed a plea to the jurisdiction and a motion to dismiss under the Texas Citizens Participation Act (TCPA), both challenging the plaintiffs' standing. The trial court denied both motions.TRTL appealed the denial of the TCPA motion, but the Court of Appeals for the Third District of Texas affirmed the trial court's order, stating that the TCPA did not apply to the plaintiffs' claims. The court did not address the standing issue raised by TRTL. TRTL then petitioned for review.The Supreme Court of Texas reviewed the case and held that the Court of Appeals erred by not addressing the standing issue, which is a prerequisite for subject-matter jurisdiction. The Supreme Court emphasized that jurisdictional questions must be resolved before addressing the merits of a case. The court reversed the judgment of the Court of Appeals and remanded the case for further proceedings to determine whether the plaintiffs had standing to sue. If the plaintiffs lack standing, the case should be dismissed; if they have standing, the Court of Appeals should then address the merits of the TCPA motion. View "TEXAS RIGHT TO LIFE v. STEAN" on Justia Law