Justia Constitutional Law Opinion Summaries

Robert Hutton secretly installed a hidden camera in the bathroom of his home and, over the course of about a year, recorded several nude videos and images of his 14-year-old stepdaughter without her knowledge. He edited some of the footage to focus on moments when the victim was visibly nude. The victim discovered the existence of these files after seeing a suspicious file name on Hutton’s phone and subsequently reported the matter to the police. A search of Hutton’s residence uncovered additional child pornography, including images of other minors.The United States District Court for the Eastern District of Washington presided over a bench trial based on stipulated facts. Hutton was charged with sexually exploiting a minor under 18 U.S.C. § 2251(a). He moved for a judgment of acquittal, arguing that the images were not “lascivious,” that the statute was unconstitutionally vague as applied, and that he did not “use” the victim within the meaning of the statute. The district court denied these motions, found Hutton guilty, and sentenced him to 20 years’ imprisonment.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed Hutton’s arguments de novo where appropriate and for clear error regarding factual findings. The court held that existing Ninth Circuit precedent foreclosed Hutton’s arguments on all grounds. Specifically, the court found that the district court did not clearly err in determining the images were “lascivious” under the Dost factors, that § 2251(a) is not unconstitutionally vague as applied, and that Hutton’s conduct constituted “use” of a minor under the statute. The court also held that the Supreme Court’s decision in Dubin v. United States, which interpreted the term “use” in a different statutory context, did not undermine the Ninth Circuit’s precedent regarding § 2251(a). The Ninth Circuit affirmed the conviction. View "USA V. HUTTON" on Justia Law

Adam Gomez was charged with receiving and possessing a firearm that had an obliterated serial number. He moved to dismiss the indictment, arguing that the statute under which he was charged, 18 U.S.C. § 922(k), was unconstitutional. After the United States District Court for the Northern District of New York denied his motion, Gomez pleaded guilty to the offense. His appeal centers on the claim that the statute is facially unconstitutional in light of the Supreme Court’s decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, which clarified the scope of the Second Amendment.The United States District Court for the Northern District of New York denied Gomez’s motion to dismiss the indictment, rejecting his constitutional challenge to § 922(k). Following this denial, Gomez entered a guilty plea and was convicted. He then appealed the judgment, arguing that the statute violates the Second Amendment as interpreted by the Supreme Court in Bruen.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The Second Circuit held that 18 U.S.C. § 922(k) is facially constitutional. The court reasoned that the statute does not infringe upon the right to bear arms because it does not prevent anyone from possessing any type of firearm, and firearms with obliterated serial numbers are not weapons in common use for lawful purposes. The court also noted that Gomez’s facial challenge failed because he did not demonstrate that the statute is unconstitutional in all its applications or that it lacks a plainly legitimate sweep. Accordingly, the Second Circuit affirmed the conviction. View "United States v. Gomez" on Justia Law

Several landowners in Walton County, Florida, owned beachfront properties that were affected by a county ordinance enacted during the early stages of the COVID-19 pandemic. In March and April 2020, the county first closed public beaches, then issued a new ordinance that closed all beaches—public and private—making it a criminal offense for anyone, including private owners, to access or use their own beachfront property. The ordinance was enforced by law enforcement officers who entered private property, excluded owners, and threatened arrest for violations. The ordinance remained in effect for about a month, after which it expired and was not renewed.The landowners filed suit in the United States District Court for the Northern District of Florida, raising several claims, including a Takings Clause claim under the Fifth Amendment, and seeking both damages and prospective relief. The district court dismissed the claims for prospective relief as moot, finding the ordinance had expired and was unlikely to recur. On the merits, the district court granted summary judgment to the county on all damages claims, holding that the ordinance was not a per se physical taking but rather a use restriction, and that the government’s actions during a public health emergency were entitled to deference.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the dismissal of the claims for prospective relief, agreeing that the ordinance’s expiration rendered those claims moot. However, the court reversed the district court’s judgment on the Takings Clause claim, holding that the ordinance constituted a per se physical taking because it barred owners from their property and allowed government officials to physically occupy and control access. The court remanded for a determination of just compensation, holding that no public emergency, including COVID-19, creates an exception to the Takings Clause. View "Alford v. Walton County" on Justia Law

A group of nonprofit associations representing non-residential property owners in New Castle County, Delaware, challenged a temporary state law enacted in response to a recent county-wide property reassessment. The reassessment, ordered by the Delaware Court of Chancery in a prior case, updated decades-old property valuations to reflect current fair market values, resulting in significant tax increases for many residential homeowners and shifting the overall tax burden toward residential properties. In reaction to public outcry, the Delaware General Assembly passed House Bill 242 (HB242), which authorized school districts in New Castle County to implement a one-year split-rate property tax system for the 2025-2026 tax year, imposing higher rates on non-residential properties and lower rates on residential ones.After the reassessment, school boards set new tax rates and issued tax warrants, and the County mailed revised tax bills. The plaintiffs filed suit in the Delaware Court of Chancery against the State, county officials, and school boards, arguing that HB242 and its implementation were unconstitutional and violated state law on several grounds, including the Uniformity Clause of the Delaware Constitution, statutory requirements for tax referenda, fair market value assessment, due process, and HB242’s own revenue neutrality provision.The Court of Chancery reviewed the plaintiffs’ constitutional and statutory claims. It held that HB242’s temporary split-rate system did not violate the Uniformity Clause, as reasonable classification between residential and non-residential properties is permitted. The court found that HB242 did not constitute a retroactive personal income tax, nor did it violate due process, given the availability of post-deprivation remedies for property reclassification. Statutory claims regarding referenda, fair market value, and revenue neutrality were also rejected, as HB242’s specific provisions and timing superseded general statutory requirements. Judgment was entered for the defendants on all counts. View "Newark Property Association v. State" on Justia Law

The dispute centers on a Delaware law, House Bill 242 (HB242), which permits New Castle County school districts to set different property tax rates for residential and non-residential properties for the 2025-2026 school year. This legislation was enacted after a county-wide property reassessment revealed a significant shift in the tax base, resulting in higher taxes for residential properties. In response to public concern, HB242 allowed school districts to implement a split-rate system, reducing residential rates and increasing non-residential rates, with the stipulation that non-residential rates could not exceed twice the residential rate and that total projected revenue could not surpass the amount projected under the original tax warrant. Subsequent corrections to property classifications led to a net increase in projected tax revenue.The plaintiffs, four property-related associations, challenged HB242 in the Court of Chancery, arguing that it violated the Uniformity Clause of the Delaware Constitution and a “revenue neutrality” requirement in the statute. The Court of Chancery rejected these claims, finding that the General Assembly has the authority to create reasonable property classifications for tax purposes and that the statute’s use of “projected” rather than “actual” revenue allowed for adjustments due to classification corrections.On appeal, the Supreme Court of Delaware reviewed the constitutionality of HB242 and the statutory interpretation issues de novo. The Court held that the Uniformity Clause does not prohibit reasonable legislative classifications of property for taxation, provided tax rates are uniform within each class. The Court also determined that HB242’s revenue limitation applies to projected, not actual, revenue, and that corrections to property classifications do not violate the statute. The Supreme Court of Delaware affirmed the judgment of the Court of Chancery. View "Newark Property Association v. State" on Justia Law

New South Media Group, LLC, along with other plaintiffs, sought to construct four types of signs—flags, artwork, political messages, and event notices—on private property in Rainbow City, Alabama. The city denied their permit applications, determining that the proposed signs were billboards, which are prohibited under Section 214 of the city’s sign ordinance. The plaintiffs believed their signs qualified for exemptions under Section 213, but the city’s definition of “billboard” encompassed their proposed signs. After receiving the denial, New South requested variances, which were also denied by the city’s zoning board.Following these denials, New South appealed in state court and brought federal and state constitutional challenges, which were dismissed in state court and then refiled in federal court. In the United States District Court for the Northern District of Alabama, New South alleged that several city sign regulations violated the First Amendment and the Alabama Constitution by imposing content-based restrictions, lacking time limits for permit decisions, and granting unbridled discretion to city officials. The district court granted summary judgment to Rainbow City, finding that New South lacked standing because the injury—the denial of the applications—was caused by the unchallenged billboard prohibition, not the provisions New South contested.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s decision de novo. The Eleventh Circuit held that New South lacked standing to challenge the constitutionality of the non-billboard regulations because the injury was not traceable to those provisions and a favorable decision would not redress the harm caused by the billboard prohibition. The court affirmed the district court’s order granting summary judgment to Rainbow City and dismissing the case without prejudice for lack of jurisdiction. View "New South Media Group, LLC v. City of Rainbow City" on Justia Law

A cannabis cultivation business was licensed to operate in Vermont but became the subject of regulatory action after laboratory testing detected myclobutanil, a prohibited pesticide, in its products. The business had previously entered into a corrective action plan with the regulatory board following similar violations in 2023, agreeing to remediation, penalties, and compliance measures. In 2024, after further detections of myclobutanil in both retail and on-site samples, the regulatory board issued a notice of violation with immediate effect, including a stop-sale order for all of the business’s products, a recall requirement, and a proposed license revocation.The business contested the notice and requested a hearing before the Cannabis Control Board. At the hearing, it raised several arguments, including challenges to the Board’s authority under the Vermont Constitution, claims of bias by the Board chair, and alleged due process violations. The Board chair denied a motion for recusal, and after hearing testimony and reviewing evidence, the Board found that the business had violated its corrective action plan and used unauthorized pesticides. The Board dismissed one violation as duplicative but upheld others, ultimately revoking the business’s license. The business appealed to an appellate officer, who affirmed the Board’s decision.The Vermont Supreme Court reviewed the case, applying a standard that precludes reweighing factual findings unless clearly erroneous or affected by legal error. The Court held that the Board acted within its statutory authority in issuing a stop-sale order for all products, that the Board’s interpretation of its regulations was reasonable, and that the business failed to preserve or adequately brief its constitutional and evidentiary arguments. The Court also found no due process violation regarding the impartiality of the Board chair, as the business did not make an evidentiary record to support its claims. The Supreme Court affirmed the revocation of the business’s license. View "In re Holland Cannabis, LLC" on Justia Law

Police responded to a domestic disturbance at a home shared by the defendant, his partner, and their children. During the incident, officers found a rifle in the living room. The defendant admitted ownership of the firearm and acknowledged he was on probation. Several months earlier, he had pled guilty to misdemeanor domestic battery, a conviction that, under Kansas law, prohibited him from possessing a firearm for five years. The defendant was charged with felony criminal use of a weapon for knowingly possessing a firearm within five years of his domestic violence conviction.In the Sedgwick District Court, the defendant moved to dismiss the charge, arguing that the statute prohibiting firearm possession by those convicted of misdemeanor domestic violence offenses violated the Second Amendment. The district court denied the motion, and the defendant was convicted by a jury. On appeal, the Kansas Court of Appeals affirmed the conviction, holding that the statute was constitutional and that sufficient evidence supported the verdict.The Supreme Court of the State of Kansas reviewed the case to address the Second Amendment challenge. The court held that the Kansas statute, which temporarily disarms individuals convicted of misdemeanor domestic violence offenses, is consistent with the nation’s historical tradition of firearm regulation. The court reasoned that early American laws, such as surety and “going armed” laws, allowed for the disarmament of individuals who posed a threat of violence, and that a recent conviction for domestic violence is sufficient to establish such a threat. The court concluded that the statute imposes a narrow, temporary restriction and is constitutional both on its face and as applied. The Supreme Court of Kansas affirmed the decisions of both the Court of Appeals and the district court. View "State v. McCray " on Justia Law

A two-year-old child, M.B., was placed with foster parents who are members of an Old Order Amish community shortly after his birth. The foster parents had previously adopted M.B.’s three biological sisters, who also reside in their home. Concerns were raised by M.B.’s guardian ad litem regarding the suitability of this placement, primarily because the Amish foster parents would limit M.B.’s formal education to eighth grade, consistent with their religious beliefs. Additional concerns included the lack of regular pediatric care, limited vaccination, restricted exposure to technology, and the potential for racial non-acceptance within the Amish community, as M.B. is biracial.The Circuit Court of Kanawha County reviewed a motion by the guardian ad litem to remove M.B. from the foster home. The court considered evidence and testimony, including the foster father’s statements about education, medical care, and community acceptance. The court also reviewed a special commissioner’s report, which acknowledged the loving and stable environment provided by the foster parents but noted potential limitations related to education, healthcare, and cultural exposure. Ultimately, the circuit court denied the motion to remove M.B., finding that the foster home was stable, loving, and in the child’s best interests, and that the court could not discriminate against the family based on religion or lifestyle.The Supreme Court of Appeals of West Virginia affirmed the circuit court’s decision. The court held that the Foster Child Bill of Rights does not mandate removal from a placement solely because one or more statutory rights may be limited, but instead requires a best-interest-of-the-child analysis considering all relevant factors. The court found that the circuit court’s findings were supported by the record and that M.B.’s placement with the Amish foster parents did not violate his statutory or constitutional rights. View "In re M.B." on Justia Law

A resident of University Heights, Ohio, who practices Orthodox Judaism, sought to use his home for group prayer sessions due to religious obligations and restrictions on travel during the Sabbath. After inviting neighbors to participate in these gatherings, a neighbor complained to city officials, prompting the city’s law director to send a cease-and-desist letter, warning that using the home as a place of religious assembly violated local zoning laws. The resident then applied for a special use permit to operate a house of worship but withdrew his application before the city’s Planning Commission could reach a decision, stating he did not wish to operate a house of worship as defined by the ordinance. Despite withdrawing, he later filed a federal lawsuit against the city and several officials, alleging violations of federal and state law, including constitutional and statutory claims.The United States District Court for the Northern District of Ohio granted summary judgment for the city and its officials. The court found that the plaintiff’s claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the First and Fourteenth Amendments, and the Ohio Constitution were unripe because there was no final decision by the relevant local authorities regarding the application of the zoning ordinance to his property. The court also rejected his Fourth Amendment and Freedom of Access to Clinic Entrances Act (FACE Act) claims on the merits and declined supplemental jurisdiction over a state public records claim.The United States Court of Appeals for the Sixth Circuit affirmed. The court held that most of the plaintiff’s claims were unripe because he withdrew his application before any final decision was made by the city’s zoning authorities, and thus there was no concrete dispute for federal review. The court also held that his facial challenges to the ordinance were forfeited and, in any event, failed as a matter of law. The court further concluded that the Fourth Amendment and FACE Act claims failed on the merits and found no abuse of discretion in declining supplemental jurisdiction over the state law claim. View "Daniel Grand v. City of University Heights, Ohio" on Justia Law