Justia Constitutional Law Opinion Summaries

Commercial fishers challenged the constitutionality of the Gulf of Mexico Fishery Management Council's actions, specifically targeting the approval and implementation of Amendment 54, which significantly reduced the greater amberjack catch limit. The plaintiffs argued that the Council members were improperly appointed under the Appointments Clause of the U.S. Constitution and were unconstitutionally insulated from removal. They sought a declaratory judgment and an injunction to set aside the Final Rule implementing the catch limit and to prevent further development of annual catch limits for the greater amberjack fishery.The United States District Court for the Southern District of Mississippi consolidated the cases and granted summary judgment to the government. The court found that six of the Council’s seventeen members were improperly appointed as inferior officers. However, it concluded that the plaintiffs were not entitled to relief because the constitutional violation was not the proximate cause of their injuries. The decision to implement Amendment 54 was made by the NMFS Assistant Administrator, not the Council. Additionally, the court noted that the remaining eleven Council members were properly appointed and constituted a quorum.The United States Court of Appeals for the Fifth Circuit reviewed the case and remanded it to the district court. The appellate court instructed the lower court to determine whether it had jurisdiction to consider the plaintiffs' request to declare Amendment 54 void and to enjoin the Council from developing further catch limits. The district court was also directed to address whether the NMFS Assistant Administrator’s review and approval of the Final Rule functioned as a ratification of the Council’s actions. The appellate court emphasized the need for a thorough district court analysis of the ratification issue before addressing the validity of the Council members' appointments and the plaintiffs' entitlement to relief. View "Arnesen v. Raimondo" on Justia Law

Erick Williams was stopped by Memphis police for speeding and erratic driving. Officers smelled marijuana and saw an open beer can, leading them to search the car after a canine alert. They found a loaded pistol in the trunk. Williams, a convicted felon for aggravated robbery, was indicted for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The district court denied his motion, and Williams pled guilty while reserving the right to appeal.The United States District Court for the Western District of Tennessee denied Williams's motion to dismiss the indictment. Williams then appealed to the United States Court of Appeals for the Sixth Circuit, arguing that § 922(g)(1) was unconstitutional both on its face and as applied to him.The United States Court of Appeals for the Sixth Circuit reviewed the case and upheld the district court's decision. The court held that § 922(g)(1) does not violate the Second Amendment. The court reasoned that historical precedent supports the disarmament of individuals deemed dangerous, and Williams's criminal record, including convictions for aggravated robbery and attempted murder, demonstrated that he was dangerous. Therefore, the statute was constitutional as applied to him. The court also noted that while individuals must have an opportunity to show they are not dangerous, Williams failed to do so. The court affirmed the district court's decision, maintaining Williams's conviction under § 922(g)(1). View "United States v. Williams" on Justia Law

The plaintiffs, parents of Idaho school children, sought reimbursement for fees associated with educational and extracurricular activities within Idaho public school districts. They argued that these fees were improperly assessed because the Idaho Constitution mandates "free common schools," and that the payment of such fees constituted a taking of property without due process, violating the Takings Clause of the Fifth Amendment.The United States District Court for the District of Idaho initially denied the school districts' motion for summary judgment, concluding that the plaintiffs had a property interest in a free education under the Idaho Constitution. However, the case was later reassigned to a different district judge, who revisited the issue. The second district judge granted summary judgment in favor of the school districts, concluding that the plaintiffs did not possess a property right protected by the Takings Clause because the right to a free public education in Idaho does not constitute a vested private property interest.The United States Court of Appeals for the Ninth Circuit affirmed the district court's summary judgment. The court held that the Idaho Constitution does not create a vested private property interest in specific educational benefits. It determined that public education in Idaho lacks the essential characteristics of private property, such as the right to possess, use, dispose of, or sell. Therefore, money paid to satisfy fees related to supplemental educational services is not subject to a Takings Clause claim. The court also clarified that a second district judge should not reconsider a prior judge's ruling unless specific conditions are met, but found any procedural error in this case to be harmless. View "Zeyen v. Bonneville Joint District" on Justia Law

Petitioner was sentenced to multiple consecutive terms of imprisonment in 2019 for obtaining property by false pretenses. In June 2020, he filed a petition for writ of habeas corpus, claiming his detention was unlawful due to the North Carolina Department of Public Safety's inability to protect him from COVID-19, which he argued violated the Eighth Amendment and the North Carolina Constitution. The trial court denied his petition.The Superior Court of Wake County summarily denied the petition, citing N.C.G.S. § 17-4(2), which mandates denial of habeas corpus applications when the petitioner is held under a valid final judgment by a competent court. The Court of Appeals affirmed the trial court's decision but held that N.C.G.S. § 17-33(2) provided an exception to the rule in § 17-4(2). Despite acknowledging the case was moot due to the petitioner's release, the Court of Appeals applied the public interest exception to the mootness doctrine and proceeded to the merits.The Supreme Court of North Carolina reviewed the case to determine if the Court of Appeals erred in its interpretation. The Supreme Court held that the plain language of N.C.G.S. § 17-4(2) requires summary denial of habeas corpus applications for those detained by a final judgment of a competent court. The Court found no conflict between §§ 17-4 and 17-33, as the latter applies only to those detained by civil process, not criminal judgments. The Supreme Court modified and affirmed the Court of Appeals' decision, emphasizing that habeas corpus relief is not available under the circumstances presented by the petitioner. View "State v. Daw" on Justia Law

In the early days of the COVID-19 pandemic, Governor Roy Cooper of North Carolina issued an executive order limiting attendance at outdoor venues to twenty-five people. Robert Turner, who operated Ace Speedway in Alamance County, publicly opposed these restrictions and kept the racetrack open. This led to a series of events where Governor Cooper allegedly pressured local officials to enforce the order against Ace Speedway, culminating in the North Carolina Department of Health and Human Services (DHHS) issuing an abatement order to shut down the racetrack as a health hazard.The Superior Court of Alamance County initially issued a preliminary injunction against Ace Speedway, prohibiting it from holding events until it complied with the abatement order. Ace Speedway and its operators counterclaimed, alleging constitutional violations, including the right to earn a living and selective enforcement. The trial court denied the State’s motion to dismiss these counterclaims, and the State appealed. The North Carolina Court of Appeals affirmed the trial court’s decision, allowing the case to proceed.The Supreme Court of North Carolina reviewed the case and affirmed the Court of Appeals' decision. The Court held that Ace Speedway sufficiently alleged colorable claims under the North Carolina Constitution. The allegations suggested that the State's actions were not for a proper governmental purpose but to retaliate against Turner for his public criticism, thus violating the right to earn a living. Additionally, the selective enforcement claim was deemed colorable because Ace Speedway alleged it was targeted while other similar venues were not, based on Turner’s exercise of his First Amendment rights. The Court concluded that these claims were sufficient to overcome the State’s sovereign immunity at this stage. View "Kinsley v. Ace Speedway Racing, Ltd" on Justia Law

In 1994, Loran Cole and his companion encountered John Edwards and his sister while they were camping. Cole murdered John and raped his sister. Cole was indicted and found guilty of first-degree murder, kidnapping, robbery, and sexual battery. The jury recommended the death penalty, which the trial court imposed. Cole's convictions and death sentence were affirmed on direct appeal, and his certiorari petition was denied by the U.S. Supreme Court in 1998.Cole filed multiple postconviction relief motions, all of which were denied by the circuit court and affirmed by the Florida Supreme Court. His claims included ineffective assistance of counsel, newly discovered evidence, and constitutional challenges. Cole also sought federal habeas relief, which was denied. His subsequent motions for postconviction relief, including claims based on newly discovered evidence and Hurst v. Florida, were also denied.The Florida Supreme Court reviewed Cole's fourth successive motion for postconviction relief and his public records requests. Cole argued newly discovered evidence regarding his treatment at the Dozier School for Boys, Eighth Amendment violations due to his prison conditions, and the unconstitutionality of Florida's lethal injection procedures. The postconviction court denied these claims as untimely, procedurally barred, or without merit. The Florida Supreme Court affirmed the postconviction court's decision, finding no error in the summary denial of Cole's claims and public records requests. The court also denied Cole's motion to stay his execution and his request for oral argument. View "Cole v. State of Florida" on Justia Law

Dallas County sued state officials in Travis County, alleging that the Texas Health and Human Services Commission (HHSC) failed to take custody of criminal defendants adjudicated incompetent to stand trial, imposing costs on the County. The district court denied the State’s plea to the jurisdiction, leading to an appeal in the Third Court of Appeals. However, due to legislative changes, this appeal is set to be transferred to the newly created Fifteenth Court of Appeals, which will have exclusive jurisdiction over certain state-related cases.The Third Court of Appeals could not resolve the appeal before its mandatory transfer to the Fifteenth Court. Dallas County preferred to remain in the Third Court and petitioned the Supreme Court of Texas to bar the transfer and declare the legislation creating the Fifteenth Court unconstitutional. The County argued that the Fifteenth Court’s statewide jurisdiction, its jurisdictional scope, and the appointment process for its justices were unconstitutional.The Supreme Court of Texas reviewed the case and held that it had jurisdiction over Dallas County’s petition. The Court concluded that the creation of the Fifteenth Court was constitutional. It found that the Texas Constitution allows the legislature substantial discretion in creating courts and defining their jurisdiction. The Court also held that the appointment process for the Fifteenth Court’s justices, who will be appointed initially and then elected in the next general election, was constitutional. Consequently, the Court denied Dallas County’s request for relief, meaning the appeal must be transferred to the Fifteenth Court as scheduled. View "IN RE DALLAS COUNTY, TEXAS AND BROWN" on Justia Law

Sandra K. Nieveen owned property in Lincoln, Nebraska, which was free of encumbrances. After failing to pay property taxes, TAX 106 purchased a tax certificate for the delinquent taxes. TAX 106 later transferred its interest to Vintage Management, LLC, which obtained a tax deed for the property. Nieveen alleged that the property was worth significantly more than the tax debt and claimed that the issuance of the tax deed violated her constitutional rights.The District Court for Lancaster County dismissed Nieveen’s constitutional claims for failure to state a claim and later granted summary judgment in favor of the county on her remaining claim. The court found that Nieveen was not entitled to an extended redemption period due to a mental disorder. Nieveen appealed, and the Nebraska Supreme Court initially affirmed the district court’s decision.The U.S. Supreme Court vacated the Nebraska Supreme Court’s judgment and remanded the case for reconsideration in light of Tyler v. Hennepin County, which recognized a plausible takings claim when a property was sold for more than the tax debt. Upon reconsideration, the Nebraska Supreme Court concluded that Nieveen had alleged a plausible takings claim against Vintage Management, LLC, as the issuance of the tax deed deprived her of property value exceeding her tax debt. The court affirmed the dismissal of claims against other defendants and declined to reconsider the Excessive Fines Clause claim, as just compensation under the Takings Clause would provide complete relief.The Nebraska Supreme Court affirmed the district court’s judgment in part, reversed it in part, and remanded the case for further proceedings regarding the takings claim against Vintage Management, LLC. View "Nieveen v. TAX 106" on Justia Law

Kevin L. Fair and his wife owned property in Scotts Bluff County, Nebraska, but failed to pay property taxes. The county treasurer sold a tax certificate to Continental Resources for the unpaid taxes. After three years, Continental notified the Fairs that they needed to redeem the property by paying the total amount due, which they did not. Consequently, Continental requested and received a tax deed from the county treasurer, transferring title to the property free of any encumbrances.The District Court for Scotts Bluff County granted summary judgment in favor of Continental Resources, rejecting Fair’s constitutional claims, including those under the Takings Clauses of the U.S. and Nebraska Constitutions. Fair argued that the issuance of the tax deed constituted a taking without just compensation. The district court found no merit in Fair’s claims and ruled in favor of Continental. Fair appealed, and the Nebraska Supreme Court initially affirmed the district court’s decision.The U.S. Supreme Court vacated the Nebraska Supreme Court’s judgment and remanded the case for reconsideration in light of Tyler v. Hennepin County. Upon reconsideration, the Nebraska Supreme Court concluded that the district court erred in granting summary judgment to Continental on Fair’s takings claim. The court found that Fair had a protected property interest in the value of his property exceeding the tax debt and that Continental’s acquisition of the tax deed constituted a taking without just compensation. The court determined that Continental, as a state actor, could be liable for the taking.The Nebraska Supreme Court affirmed the district court’s judgment in all other respects but reversed the summary judgment in favor of Continental on the takings claim, remanding the case for further proceedings. View "Continental Resources v. Fair" on Justia Law

Xiomara Santiago was hired as the Deputy Director for the Head Start Program in Utuado, Puerto Rico. Following a mayoral election, the new mayor, Jorge Pérez, terminated her employment. Santiago claimed her dismissal violated her Fourteenth Amendment due process rights and was politically motivated, violating her First Amendment rights. She sought a preliminary injunction to be reinstated.The United States District Court for the District of Puerto Rico held hearings and ultimately denied Santiago's request for a preliminary injunction. The court concluded that Santiago had not shown a likelihood of success on the merits of either her due process or political discrimination claims. The magistrate judge's Report & Recommendation, which the district judge adopted, found that Santiago's initial hire was contrary to Puerto Rico law, meaning she did not have a property interest in her employment. Additionally, the court found insufficient evidence to support her claim of political discrimination.The United States Court of Appeals for the First Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Santiago had not demonstrated a likelihood of success on the merits of her claims. The court noted that Santiago's argument regarding the incorrect application of Puerto Rico law was waived because it was raised for the first time on appeal. Furthermore, the court found no clear error in the district court's assessment that Santiago's political affiliation was not a substantial factor in her termination. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction. View "Santiago v. Municipality of Utuado" on Justia Law