Justia Constitutional Law Opinion Summaries

Eric Cohen, experiencing a psychotic episode, attacked his girlfriend and fled into the cold waters of Portland's Back Cove, where he eventually drowned from hypothermia. His estate sued the City of Portland and several members of its police and fire departments, alleging violations of Cohen's substantive due process rights due to a failure to rescue him from a state-created danger and inadequate crisis intervention training.The United States District Court for the District of Maine dismissed the state-created danger claims against two police officers, Sergeants Christopher Gervais and Michael Rand, under Federal Rule of Civil Procedure 12(b)(6). The court found that the officers' actions did not create or enhance the danger to Cohen. After discovery, the court granted summary judgment to a firefighter, Ronald Giroux, and the City of Portland. The court concluded that Giroux's actions did not cause Cohen's death and that the City could not be held liable for failure to train its employees since no individual defendant was found to have violated Cohen's constitutional rights.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that neither Gervais nor Rand's actions constituted an affirmative act that created or enhanced the danger to Cohen. The court also found that Giroux's threat did not factually or legally cause Cohen's death. Finally, the court affirmed the summary judgment in favor of the City of Portland, as there was no predicate constitutional violation by any individual defendant to support a failure-to-train claim. View "Cohen v. City of Portland" on Justia Law

The plaintiff, GEFT Outdoor, LLC, challenged an Evansville, Indiana ordinance that distinguishes between on-premises and off-premises signs, arguing it violated the First Amendment. Initially, the district court agreed, but the Supreme Court's decision in Austin v. Reagan National Advertising of Austin, LLC, led to a remand. GEFT then focused on the ordinance's permit and variance criteria, claiming the City might consider a sign's message. However, the City does not request message information for permits, and the ordinance's criteria do not involve the sign's message. GEFT's variance application was denied due to non-compliance with size and spacing rules, which GEFT argued was unconstitutional.The district court dismissed GEFT's complaint, finding the ordinance's size and placement rules valid and the variance criteria specific enough to avoid content discrimination. The court referenced Leibundguth Storage & Van Service, Inc. v. Downers Grove, which upheld a similar ordinance. GEFT appealed, but the Seventh Circuit's decision in GEFT Outdoor, LLC v. Monroe County, which upheld similar variance criteria, further weakened GEFT's position. GEFT argued potential content discrimination, but the court found no substantial invalidity in the ordinance's application.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that GEFT's facial challenge failed because it did not show that a substantial portion of the ordinance's applications were unconstitutional. GEFT had not contested the size and location rules, effectively conceding their validity. The court noted that GEFT's focus on a variance disqualified it from a facial challenge. The district court's decision was modified to clarify that GEFT lost on the merits, not for lack of standing, and the judgment was affirmed. View "GEFT Outdoor, LLC v. City of Evansville" on Justia Law

The case involves Michelle Gilbank, who lost custody of her daughter, T.E.H., in state court proceedings in Wisconsin. Gilbank alleged that various officials involved in those proceedings violated her federal constitutional rights. The events began when Gilbank, who had a history of drug use, moved into her ex-partner Ian Hoyle's apartment. Following an anonymous tip, police and social workers investigated and found evidence of Gilbank's drug use. On August 21, 2018, Gilbank was arrested for drug possession, and her daughter was temporarily placed with Hoyle. Subsequent state court hearings resulted in the continued placement of T.E.H. with Hoyle until Gilbank regained custody in March 2020.In the United States District Court for the Western District of Wisconsin, the court granted summary judgment for the defendants. The court found that some of Gilbank’s claims were barred by the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court also ruled that the remaining claims failed on the merits, including claims of unreasonable search, denial of due process, and unlawful eviction.The United States Court of Appeals for the Seventh Circuit reviewed the case en banc. The court affirmed the district court's judgment, agreeing that the Rooker-Feldman doctrine barred claims based on injuries caused by state court judgments. The court also affirmed summary judgment on the merits for claims not barred by Rooker-Feldman, including those related to the urinalysis, interrogation without an attorney, and the removal of T.E.H. The court found that Gilbank had consented to the urinalysis, that her Fifth Amendment rights were not violated as her statements were not used in a criminal proceeding, and that there was no seizure of T.E.H. by government actors. The court also rejected the existence of a "fraud exception" to the Rooker-Feldman doctrine. View "Gilbank v. Wood County Department of Human Services" on Justia Law

In response to the COVID-19 pandemic, the Governor of Delaware issued a series of emergency orders that included restrictions on religious services. These restrictions, which were lifted by June 2020, limited in-person worship to ten people and imposed various other mandates. Over 18 months later, two religious leaders filed suit in the Court of Chancery seeking injunctive relief against these restrictions, which were no longer in effect. The Court of Chancery dismissed the case for lack of subject matter jurisdiction, concluding that the plaintiffs could not demonstrate a reasonable apprehension of future harm.The plaintiffs then transferred their action to the Superior Court, seeking declaratory judgment and damages for alleged violations of their constitutional rights. The Superior Court dismissed the claims, ruling that the requests for declaratory relief were not justiciable because the restrictions had been lifted and there was no ongoing controversy. Additionally, the court found that the Governor was immune from the damages claims under the State Tort Claims Act and the doctrine of qualified immunity.On appeal, the Delaware Supreme Court affirmed the lower courts' decisions. The Court agreed that the plaintiffs failed to show a reasonable apprehension of future harm, which is necessary for injunctive relief. The Court also held that the plaintiffs' claims for declaratory judgment were not justiciable because there was no ongoing controversy and the alleged harm could not be redressed by a declaratory judgment. Finally, the Court upheld the Superior Court's finding that the Governor was immune from damages claims, as his actions were discretionary and taken in good faith during an unprecedented public health crisis. View "In re Covid-Related Restrictions on Religious Services" on Justia Law

In February 2023, state detectives in Midland, Texas, arranged a controlled purchase of cocaine from Samuel Barraza-Urias. During a traffic stop, officers found Barraza-Urias and Bay Travon Wilson in a vehicle with 160.6 grams of cocaine and three firearms, including a short barrel AR-15 rifle, a KelTec semi-automatic pistol, and a Ruger semi-automatic pistol with an obliterated serial number. Wilson admitted to possessing the rifle and the KelTec pistol. He pleaded guilty to being a felon in possession of a firearm and possessing an unregistered firearm.The United States District Court for the Western District of Texas assigned Wilson a base offense level of 20 and applied several enhancements: a four-level enhancement for possessing a firearm in connection with another felony offense, a four-level enhancement for possessing a firearm with an obliterated serial number, and a two-level enhancement for possession of three or more firearms. Wilson objected to these enhancements, arguing insufficient evidence. The district court overruled his objections and sentenced him to 97 months’ imprisonment and three years of supervised release on each count, to run concurrently.The United States Court of Appeals for the Fifth Circuit reviewed the case. Wilson argued that his conviction under 18 U.S.C. § 922(g)(1) violated his Second Amendment rights post-Bruen. The court reviewed for plain error and found no clear or obvious error. The court also upheld the district court’s application of the sentencing enhancements, finding sufficient evidence that Wilson was involved in drug trafficking and constructively possessed the Ruger pistol. The Fifth Circuit affirmed the district court’s judgment. View "USA v. Wilson" on Justia Law

Bilal Hankins, a passenger in a car with two other youths, was driving slowly at night looking for a neighbor’s lost dog. Hankins asked Officer Kevin Wheeler, who was on patrol for a local private security district, for assistance in finding the dog. Later, Officer Wheeler and another officer, Officer Ramon Pierre, stopped the car without reasonable suspicion and approached it with guns drawn. Hankins brought claims under Sections 1983 for unreasonable seizure, excessive force, constitutional conspiracy, supervisory liability, and Monell claims, along with related state-law claims.The United States District Court for the Eastern District of Louisiana limited discovery to the issue of qualified immunity. The district court concluded that there was no question of material fact as to whether there was an underlying constitutional violation of either Hankins’ right to be free from an unlawful seizure or his right to be free from excessive, unlawful force. Consequently, the district court granted summary judgment to the defendants on all federal claims, as each federal claim relied on an underlying constitutional violation. The court also declined supplemental jurisdiction over the state-law claims and dismissed those without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that material fact disputes precluded summary judgment on the seizure claim. The court held that the factors relied upon by the district court, such as the car’s registration information, the time of night, and the car driving slowly, did not amount to reasonable suspicion when considered in the totality of the circumstances. The court also noted that Hankins’ testimony that Officer Wheeler said, “you know, three young men, in a nice car, in this neighborhood,” if credited, would undermine the officers’ justification for the stop. The Fifth Circuit reversed the summary judgment on the seizure claim, vacated the summary judgment on the other federal claims, and remanded for further proceedings. View "Hankins v. Wheeler" on Justia Law

Ana Lilia Cardenas, a special education teacher, injured her knee at work, resulting in both a physical impairment to her knee and a secondary mental impairment. The Workers’ Compensation Judge awarded her permanent partial disability (PPD) benefits for her knee injury, limited to 150 weeks as per the Workers’ Compensation Act. The Act also limits the duration of PPD benefits for secondary mental impairments to the maximum period allowable for the initial physical impairment, which in this case was also 150 weeks.Cardenas appealed, arguing that this limitation violated the equal protection clause of the New Mexico Constitution. The New Mexico Court of Appeals agreed, holding that the Act’s provisions for secondary mental impairments were unconstitutional because they treated workers with mental impairments differently from those with subsequent physical impairments. The Court of Appeals noted that subsequent physical impairments are treated as separate injuries with their own benefit durations, unlike secondary mental impairments.The New Mexico Supreme Court reviewed the case to determine the constitutionality of the Act’s provisions. The Court held that the Act’s differential treatment of secondary mental impairments compared to subsequent physical impairments violated the equal protection clause. The Court applied intermediate scrutiny, given that mental disabilities are a sensitive class, and found that the employer failed to demonstrate that the disparate treatment was substantially related to an important governmental interest. Consequently, the Court affirmed the Court of Appeals' decision, ruling that the relevant sections of the Workers’ Compensation Act were unconstitutional. View "Aztec Municipal Schools v. Cardenas" on Justia Law

**Summary:**The case involves the Planned Parenthood Association of Utah (PPAU) challenging Senate Bill 174 (SB 174), a law enacted by the Utah Legislature that prohibits abortion at any stage of pregnancy except in three specific circumstances. PPAU argues that SB 174 violates several rights guaranteed by the Utah Constitution and sought a preliminary injunction to halt the law's enforcement while its constitutionality was litigated. The district court granted the preliminary injunction after an evidentiary hearing.The State of Utah petitioned for interlocutory review, presenting two primary arguments: that PPAU lacks standing to challenge the law and that the district court abused its discretion in granting the preliminary injunction. The State argued that PPAU did not have a personal stake in the dispute and that the district court erred in its application of the preliminary injunction standard.The Utah Supreme Court reviewed the case and affirmed the district court's decision. The court held that PPAU has standing to challenge SB 174, satisfying both traditional and third-party standing requirements. The court found that PPAU demonstrated a distinct and palpable injury, including the threat of criminal prosecution and economic harm, which would be redressed by enjoining the law. The court also concluded that PPAU could assert the rights of its patients due to the close relationship between PPAU and its patients and the genuine obstacles patients face in asserting their own rights.The court further held that the district court did not abuse its discretion in granting the preliminary injunction. The court determined that PPAU raised serious issues concerning the constitutionality of SB 174, which should be the subject of further litigation. The district court acted within its discretion in concluding that PPAU would suffer irreparable harm without an injunction, that the balance of harms favored an injunction, and that an injunction would not be adverse to the public interest. The preliminary injunction remains in place while PPAU litigates its claims. View "Planned Parenthood Association v. State" on Justia Law

The case involves a dispute over the issuance of medical marijuana dispensary licenses in the city of Warren. In 2019, the Warren City Council adopted an ordinance to regulate these licenses, which involved a Review Committee scoring and ranking applications. The Review Committee held 16 closed meetings to review 65 applications and made recommendations to the city council, which then approved the top 15 applicants without further discussion. Plaintiffs, who were denied licenses, sued, alleging violations of the Open Meetings Act (OMA) and due process.The Macomb Circuit Court found that the Review Committee violated the OMA and invalidated the licenses issued by the city council. The court held that the Review Committee was a public body subject to the OMA and that the city council's approval process was flawed. Defendants and intervening defendants appealed, and the Michigan Court of Appeals reversed the trial court's decision. The appellate court held that the Review Committee was not a public body under the OMA because it only had an advisory role, and the city council retained final decision-making authority. The appellate court also upheld the trial court's dismissal of the plaintiffs' due process claims.The Michigan Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that the Review Committee was a public body subject to the OMA because it effectively decided which applicants would receive licenses by scoring and ranking them, and the city council merely adopted these recommendations without independent consideration. The court emphasized that the actual operation of the Review Committee, rather than just the language of the ordinance, determined its status as a public body. The case was remanded to the Court of Appeals to consider whether the open meetings held by the Review Committee cured the OMA violations and to address other preserved issues. View "Pinebrook Warren LLC v. City Of Warren" on Justia Law

In 2018, Michigan's Legislature received initiative petitions proposing the Improved Workforce Opportunity Wage Act and the Earned Sick Time Act. The Legislature adopted these initiatives without changes, preventing them from appearing on the ballot. However, during the lame duck session after the election, the Legislature significantly amended both laws, effectively nullifying their original intent.The plaintiffs challenged these amendments in the Court of Claims, arguing they were unconstitutional under Article 2, § 9 of the Michigan Constitution. The Court of Claims agreed, ruling that the Legislature could not adopt and then amend an initiative in the same session. The court declared the amendments void and reinstated the original initiatives. The state appealed, and the Court of Appeals reversed the decision, holding that the Legislature could amend an initiative in the same session since the Constitution did not explicitly prohibit it.The Michigan Supreme Court reviewed the case and held that Article 2, § 9 provides the Legislature with only three options upon receiving a valid initiative petition: adopt it without change, reject it, or propose an alternative to be voted on alongside the original. The Court ruled that adopting and then amending an initiative in the same session violated the people's right to propose and enact laws through the initiative process. Consequently, the amendments were declared unconstitutional. The Court ordered that the original initiatives would go into effect 205 days after the opinion's publication, with adjustments for inflation and a revised schedule for minimum wage increases. The Court of Appeals' judgment was reversed. View "Mothering Justice v. Attorney General" on Justia Law