Justia Constitutional Law Opinion Summaries

A trade association representing the dietary supplement industry challenged a New York law that prohibits the sale of dietary supplements marketed for weight loss or muscle building to individuals under eighteen. The law was enacted in response to concerns about health risks to minors from such supplements. The statute defines covered products based on how they are labeled or marketed, and authorizes the Attorney General to seek injunctions against violators. The association argued that the law violates the First Amendment, is unconstitutionally vague, and is preempted by federal law.The United States District Court for the Southern District of New York denied the association’s motion for a preliminary injunction, finding that the association was unlikely to succeed on the merits of its claims, had not shown irreparable harm, and that the balance of equities and public interest weighed against granting relief. The District Court later dismissed the vagueness and preemption claims but allowed the First Amendment claim to proceed.On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court’s denial of a preliminary injunction. The Second Circuit held that the law satisfies intermediate scrutiny under the Central Hudson test for commercial speech, finding that New York has a substantial interest in protecting minors’ health, that the law directly advances that interest, and that it is not more extensive than necessary. The court also concluded that the age verification requirement does not unconstitutionally compel speech, that the statute is not unconstitutionally vague or overbroad, and that it is not preempted by federal law. The court further found that the association failed to demonstrate irreparable harm or that the public interest favored an injunction. The order denying the preliminary injunction was affirmed. View "Council for Responsible Nutrition v. James" on Justia Law

Susan Boggs and Fouad Rachid reside in a home owned by Fouad, Inc., located in Olmsted Township near the Cleveland-Hopkins International Airport. Boggs alleges that increased air traffic and airport operations, particularly following a runway expansion project, have caused significant noise, vibrations, and emissions, rendering the property unsuitable for residential use and amounting to a governmental taking. Boggs declined Cleveland’s offer to purchase an avigation easement and subsequently filed a mandamus action against the City of Cleveland, seeking to compel the city to initiate appropriation proceedings to determine compensation for the alleged taking.The case was initially removed to federal court, where Boggs pursued administrative remedies with the Federal Aviation Administration (FAA), but her claims were rejected. After further federal litigation, the district court granted summary judgment to Cleveland on federal claims and remanded the state-law claims to the Cuyahoga County Court of Common Pleas. In state court, both parties moved for summary judgment. The trial court granted summary judgment to Cleveland, finding that Boggs lacked standing because Cleveland, as a municipality, lacked authority to appropriate property outside its boundaries. The Eighth District Court of Appeals affirmed, holding that Boggs’s injury was not redressable since Cleveland could not be compelled to initiate appropriation proceedings for property outside its jurisdiction.The Supreme Court of Ohio reviewed the case and reversed the judgment of the Eighth District Court of Appeals. The court held that under Article I, Section 19 of the Ohio Constitution, a landowner whose property has been taken by a foreign municipality has standing to pursue a mandamus action to force the municipality to institute appropriation proceedings for compensation, regardless of whether the property is located within the municipality’s boundaries. The case was remanded for further proceedings, including consideration of the statute-of-limitations issue. View "State ex rel. Boggs v. Cleveland" on Justia Law

After being involved in a head-on collision during a snowstorm, the appellant was detained by police on suspicion of driving while impaired. Law enforcement obtained a search warrant authorizing a blood test, but not a urine test. The appellant refused to submit to both the blood test (for which there was a warrant) and a urine test (for which there was not). He was subsequently charged with first-degree test refusal. The appellant moved to suppress evidence of his refusals and to dismiss the charge, arguing that the statutes required refusal of both tests to sustain a conviction and that, because there was no warrant for a urine test, his prosecution violated the Fourth Amendment.The District Court denied the appellant’s motion, concluding that the relevant statutes did not require warrants for both blood and urine tests to prosecute for test refusal. The appellant waived his right to a jury trial, and the District Court found him guilty of first-degree test refusal based on stipulated facts. On appeal, the Minnesota Court of Appeals affirmed the conviction, holding that the statutory language required only refusal of the test authorized by the warrant and that there was no requirement for law enforcement to obtain warrants for both types of tests.The Minnesota Supreme Court reviewed the case and held that when a warrant authorizes only one type of chemical test—either blood or urine—a person’s refusal to submit to that specific test is sufficient for a conviction under Minn. Stat. §§ 169A.20, subd. 2(2), and 171.177, subd. 2. The Court further held that a conviction for refusing a warranted chemical test does not violate the Fourth Amendment. The decision of the Court of Appeals was affirmed, though on different grounds. View "State of Minnesota vs. Lueck" on Justia Law

The case concerns an incident in which the defendant was accused of engaging in sexual intercourse without consent with the complainant, K.R., who had spent the afternoon and evening drinking at several bars. The two were acquaintances and exchanged messages on Facebook, with K.R. inviting the defendant to her home. K.R. later testified that she did not remember the events after leaving the bar, including her communications with the defendant, driving home, or leaving her door unlocked. She recalled regaining awareness during a sexual encounter at her home, at which point she told the man to stop. The defendant asserted that he did not know K.R. was unable to consent, pointing to her actions and communications as evidence that she appeared functional.The Second Judicial District Court of Montana presided over the trial. The court excluded evidence of K.R.’s past alcohol use and denied the defense’s request to present expert testimony on the effects of regular alcohol consumption. The court also instructed the jury that the defendant could be found guilty if he was aware of a “high probability” that K.R. was unable to consent, rather than requiring actual knowledge. The jury found the defendant guilty, and he was sentenced to twenty years in prison, with five years suspended.On appeal, the Supreme Court of the State of Montana reviewed whether the district court’s jury instruction on the mental state required for conviction and its exclusion of certain evidence constituted reversible error. The Supreme Court held that the district court erred by giving a result-based instruction for “knowingly,” which lowered the State’s burden of proof and violated the defendant’s due process rights. The court also found no abuse of discretion in excluding evidence of K.R.’s past drinking habits or the expert testimony as offered. The conviction was reversed and the case remanded for a new trial. View "State v. Pierce" on Justia Law

The petitioner was indicted on multiple charges, including first-degree robbery and child neglect, in Kanawha County, West Virginia. After concerns about his competency arose during arraignment, the Circuit Court of Kanawha County ordered psychological evaluations. The petitioner was found incompetent to stand trial but likely to regain competency within ninety days, leading to his commitment to a state hospital for competency restoration. While initially participating in treatment, the petitioner later refused both group sessions and prescribed medication, prompting the hospital to seek court approval for involuntary medication to restore competency.The Circuit Court of Kanawha County held an evidentiary hearing, considering expert testimony and the petitioner’s objections. The court found that involuntary medication was necessary and appropriate, relying on the four-part test from Sell v. United States, 539 U.S. 166 (2003). The court granted the hospital’s request, authorizing involuntary administration of medication if the petitioner continued to refuse treatment. The petitioner then sought a writ of prohibition from the Supreme Court of Appeals of West Virginia, arguing that the state constitution provided greater protections than the federal standard and challenging the court’s authority to order involuntary medication.The Supreme Court of Appeals of West Virginia reviewed the statutory framework and the constitutional arguments. It held that West Virginia law authorizes circuit courts to order involuntary medication for competency restoration and adopted the Sell test as the governing standard. The court further held that the State must prove the Sell factors by clear and convincing evidence. Although the circuit court applied a lower standard, the Supreme Court found the evidence sufficient under the higher standard and denied the writ of prohibition, affirming the lower court’s order permitting involuntary medication for competency restoration. View "State of West Virginia ex rel. Urban v. The Honorable David Hardy" on Justia Law

On June 4, 2022, a Parkersburg police officer arrested Michael Keith Allman pursuant to an outstanding warrant. At the time of arrest, Mr. Allman was carrying a backpack, which he set down before being handcuffed. After backup officers arrived and secured the scene, police searched the backpack and discovered drugs, digital scales, and ammunition. These items formed the basis for multiple charges against Mr. Allman, including felony possession of controlled substances with intent to deliver, possession of a firearm by a prohibited person, and related offenses.Following indictment by a Wood County Grand Jury, Mr. Allman moved to suppress the evidence found in the backpack, arguing that the warrantless search violated his rights under the Fourth Amendment and the West Virginia Constitution. The Circuit Court of Wood County held a suppression hearing, where the arresting officer testified about the circumstances of the arrest and search. The circuit court denied the motion to suppress, finding that the search was lawful as incident to arrest and justified by concerns for officer safety and preservation of evidence. Mr. Allman was subsequently convicted by a jury on all counts and sentenced.The Supreme Court of Appeals of West Virginia reviewed the case and reversed the circuit court’s denial of the motion to suppress. The high court held that, although the seizure of the backpack was lawful, the warrantless search was not justified as a search incident to arrest because Mr. Allman was handcuffed and the backpack was not within his immediate control at the time of the search. The court found no applicable exception to the warrant requirement and concluded that the search violated Mr. Allman’s reasonable expectation of privacy. The court vacated Mr. Allman’s drug-related convictions and remanded the case for further proceedings consistent with its opinion. View "State of West Virginia v. Allman" on Justia Law

A violent home invasion occurred in Huntington, Cabell County, West Virginia, on November 22, 2020, when Nathan Dolen attacked Ronald and Orlinda Adkins, robbing them, inflicting serious injuries, and restraining them with handcuffs. Dolen stole firearms and other property, including a truck that he later burned. Both victims required hospitalization and rehabilitation. Dolen was indicted on thirteen felony counts, including kidnapping, robbery, assault, and arson. At trial, the State introduced cell site data and a PowerPoint mapping the locations of a phone associated with Dolen, which became a focus of the appeal. The jury convicted Dolen on all counts except one malicious assault charge.The Circuit Court of Cabell County presided over the trial. During trial, Dolen’s counsel objected to the admission of the PowerPoint, arguing it was not disclosed in discovery and that expert testimony about it violated Dolen’s confrontation rights because the testifying expert did not create the presentation. The court found that Dolen had received the underlying AT&T data and had time to review the PowerPoint before its admission, and allowed the expert to testify, finding no prejudice. Dolen also moved for acquittal on the kidnapping charges, arguing insufficient evidence and lack of intent for ransom, reward, or concession, but the court denied the motion. Dolen did not argue that the kidnapping was incidental to the robbery until appeal.The Supreme Court of Appeals of West Virginia reviewed the case. It held that the circuit court did not abuse its discretion in admitting the PowerPoint and expert testimony, finding no discovery violation or Confrontation Clause breach, as the expert independently verified the data. The court also found sufficient evidence for the kidnapping convictions and declined to review the “incidental to robbery” argument, as it was not preserved below. The convictions and sentence were affirmed. View "State of West Virginia v. Dolen" on Justia Law

Travis Rockhill was charged with the murder of Gary Matthews, who was shot outside a friend’s home and later died from his injuries. The prosecution presented evidence that Rockhill had a dispute with Matthews over a scooter sale and was angry with him prior to the shooting. The defense argued that another individual, Louie (“Primo”), was involved and that Rockhill was not the shooter. During Rockhill’s first trial, he made incriminating statements to the courtroom bailiff, but the prosecution did not introduce this evidence. The jury deadlocked, resulting in a mistrial.In the second trial, presided over by Judge Emily Cole, Rockhill testified in his own defense. After both sides rested, Judge Cole sent ex parte text messages to a former colleague at the District Attorney’s office, questioning why the prosecutor was not calling the bailiff as a rebuttal witness and suggesting someone should speak to the prosecutor about it. The prosecution did not act on this suggestion, and Rockhill was convicted of first-degree murder with a firearm enhancement. After the verdict, the prosecution disclosed Judge Cole’s ex parte communications to the defense. Judge Cole recused herself, acknowledging the impropriety but maintaining she had been impartial. Rockhill moved for a new trial based on judicial bias, but Judge Denise McLaughlin-Bennett of the Superior Court of Los Angeles County denied the motion, finding no intent to intervene in the proceedings and no impact on the verdict.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court held that Judge Cole’s ex parte communications constituted a due process violation and structural error, as they demonstrated an unconstitutional probability of actual judicial bias. The court reversed the judgment and remanded the case for a new trial, directing the lower court to grant Rockhill’s motion for a new trial. View "P. v. Rockhill" on Justia Law

A police union sought an injunction requiring the City of Los Angeles to comply with a state law mandating that anyone filing a complaint of police misconduct must first read and sign an advisory warning that knowingly filing a false complaint is a crime. The law, Penal Code section 148.6(a), singles out complaints against peace officers for this treatment, and its legislative history shows it was enacted to address concerns about reputational and professional harm to officers from false complaints, as well as the administrative burden of investigating such claims.Previously, the Los Angeles County Superior Court granted the injunction, finding itself bound by the California Supreme Court’s earlier decision in People v. Stanistreet, which had upheld the constitutionality of section 148.6(a). The California Court of Appeal affirmed, also relying on Stanistreet, despite several federal court decisions—including Chaker v. Crogan and Hamilton v. City of San Bernardino—holding that the statute violated the First Amendment.The Supreme Court of California reviewed the case and reconsidered its prior holding in light of subsequent U.S. Supreme Court decisions, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that section 148.6(a) is a content-based regulation within a proscribable category of speech (defamation) but, as drafted, it incidentally burdens protected speech by deterring truthful or well-intentioned complaints of police misconduct. Applying intermediate scrutiny, the court found the statute was not narrowly tailored to serve the government’s interests and burdened substantially more speech than necessary. The Supreme Court of California reversed the Court of Appeal’s judgment and remanded the case for further proceedings. View "L.A. Police Protective League v. City of L.A." on Justia Law

A 12-year-old boy was killed by police officers during an attempt to rescue him from a neighbor who had already killed the boy’s mother and housekeeper, gravely wounded his sister, and was holding the boy hostage in a vehicle. The officers responded to multiple 911 calls, surrounded the vehicle, and attempted to negotiate with the hostage-taker, who was armed and making threats against the child’s life. After the hostage-taker was shot and killed by an officer, other officers fired additional shots, which resulted in the boy’s death.The boy’s father, siblings, and estate filed a lawsuit in the United States District Court for the District of Nevada against the city, police department, and individual officers. They alleged violations of the Fourth Amendment (excessive force), Fourteenth Amendment (substantive due process), a Monell claim for failure to train, and state law claims. The district court dismissed the federal claims with prejudice, finding that the officers had not seized the boy for Fourth Amendment purposes, had not acted with deliberate indifference or intent to harm for Fourteenth Amendment purposes, and that the Monell claim failed in the absence of a constitutional violation.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that the officers did not violate the boy’s Fourth Amendment rights because their actions during the active hostage situation did not constitute a seizure, and even if a violation had occurred, qualified immunity would apply as the right was not clearly established. The court also found no Fourteenth Amendment violation, as the officers’ actions did not shock the conscience or demonstrate deliberate indifference, and qualified immunity would apply. The Monell claim failed due to the absence of an underlying constitutional violation. View "HAWATMEH V. CITY OF HENDERSON" on Justia Law