Justia Constitutional Law Opinion Summaries

The case involves a dispute between Wendell Shane Mackey, a local resident, and Jeff Rising, a real-estate agent who served one term as a part-time City Commissioner for Adrian, Michigan. Mackey posted information about Rising on Facebook that Rising believed to be false. Rising responded by calling Mackey’s mother and allegedly threatened to “hurt” Mackey if he did not delete the post. Mackey sued, arguing that Rising’s threat of physical violence violated the First Amendment because Rising made it in his capacity as a Commissioner to stifle Mackey’s speech.The United States District Court for the Eastern District of Michigan granted summary judgment to Rising, concluding that he had acted as a private citizen when he made the alleged threats. Mackey appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit affirmed the lower court's decision. The court found that Rising, as a legislator, did not have any “authority” to use (or threaten) physical force on behalf of the City of Adrian. His alleged “misuse” of the power, therefore, could not qualify as state action. The court also found that Rising’s acceptance of the City’s insurance for his defense did not conflict with his state-action defense on the merits, and thus, neither waiver nor judicial estoppel applied. View "Mackey v. Rising" on Justia Law

The case revolves around Corey Neal, who was charged with federal gun possession after Shelby County officers, armed with a warrant, discovered three firearms at his residence. Neal challenged the validity of the search under the Fourth Amendment, but his plea was rejected, leading him to plead guilty to the charges. The case was then brought to appeal, where Neal reiterated his Fourth Amendment claim.The District Court for the Western District of Tennessee had previously denied Neal's motion to suppress the evidence found at his residence. The court agreed that the warrant lacked probable cause but invoked the good faith exception to the exclusionary rule from United States v. Leon, which allows evidence obtained in good faith reliance on a search warrant later found to be deficient. Neal pleaded guilty to the second count in the indictment, reserving his right to appeal the ruling, and was sentenced to 92 months' imprisonment.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the affidavit supporting the search warrant established a "minimally sufficient nexus" between the items sought and the place to be searched. The court reasoned that the affidavit provided more than a naked guess that contraband might be found at Neal's residence. It established recent drug trafficking by Neal and evidence of Neal's residency. The court concluded that the affidavit was not so bare bones as to necessitate the application of the exclusionary rule, thereby upholding the lower court's application of the good faith exception to the exclusionary rule. View "United States v. Neal" on Justia Law

Willie Slocum, Jr. appealed the denial of his motion to correct, vacate, or set aside his convictions and sentences based on ineffective assistance of counsel. Slocum was indicted on two counts of drug conspiracy under 21 U.S.C. § 846, but argued that the two charged conspiracies were actually one. He claimed that he was punished twice for the same conspiracy in violation of the Fifth Amendment’s Double Jeopardy Clause, and that his trial counsel rendered ineffective assistance by failing to raise a double jeopardy challenge before the trial court. The district court denied his motion without ordering a response from the government or holding an evidentiary hearing.The United States Court of Appeals for the Fourth Circuit found that the district court erred in its decision. The appellate court determined that Slocum was indeed punished twice for a single conspiracy in violation of the Double Jeopardy Clause. However, the court noted that it was unclear whether trial counsel had a strategic reason for failing to raise a double jeopardy challenge. The court concluded that Slocum was entitled to an evidentiary hearing under 28 U.S.C. § 2255(b) where the performance of his trial counsel could be assessed. Therefore, the court vacated the district court’s denial of Slocum’s § 2255 motion and remanded for an evidentiary hearing on Slocum’s ineffective assistance claim. View "United States v. Slocum" on Justia Law

The case involves former President Donald Trump, who was indicted on four counts for conduct that occurred during his presidency following the November 2020 election. The indictment alleged that Trump conspired to overturn the election by spreading knowingly false claims of election fraud. Trump moved to dismiss the indictment based on Presidential immunity, arguing that a President has absolute immunity from criminal prosecution for actions performed within his official responsibilities. The District Court denied Trump’s motion to dismiss, holding that former Presidents do not possess federal criminal immunity for any acts. The D.C. Circuit affirmed this decision.The Supreme Court of the United States held that under the constitutional structure of separated powers, a former President is entitled to absolute immunity from criminal prosecution for actions within his conclusive and preclusive constitutional authority. He is also entitled to at least presumptive immunity from prosecution for all his official acts. However, there is no immunity for unofficial acts. The Court vacated the judgment of the D.C. Circuit and remanded the case for further proceedings consistent with its opinion. The Court emphasized that the President is not above the law, but under the system of separated powers, the President may not be prosecuted for exercising his core constitutional powers. View "Trump v. United States" on Justia Law

In 2021, Florida and Texas enacted statutes regulating large social-media companies and other internet platforms. The laws curtailed the platforms' ability to engage in content moderation and required them to provide reasons to a user if they removed or altered her posts. NetChoice LLC, a trade association whose members include Facebook and YouTube, brought First Amendment challenges against the two laws. District courts in both states entered preliminary injunctions.The Eleventh Circuit upheld the injunction of Florida’s law, holding that the state's restrictions on content moderation trigger First Amendment scrutiny. The court concluded that the content-moderation provisions are unlikely to survive heightened scrutiny. The Fifth Circuit, however, disagreed and reversed the preliminary injunction of the Texas law. The court held that the platforms’ content-moderation activities are “not speech” at all, and so do not implicate the First Amendment.The Supreme Court of the United States vacated the judgments and remanded the cases, stating that neither the Eleventh Circuit nor the Fifth Circuit conducted a proper analysis of the facial First Amendment challenges to Florida and Texas laws regulating large internet platforms. The Court held that the laws interfere with protected speech, as they prevent the platforms from compiling the third-party speech they want in the way they want, thus producing their own distinctive compilations of expression. The Court also held that Texas's asserted interest in correcting the mix of viewpoints that major platforms present is not valid under the First Amendment. View "Moody v. NetChoice, LLC" on Justia Law

The case involves a defendant, Haadi Bolourchi, who was convicted of driving under the influence of a drug and bribing an executive officer. The defendant was pulled over by Officer Kevin Finerty for vehicle code violations. The officer noticed signs of intoxication and conducted several field sobriety tests, which Bolourchi failed. Bolourchi admitted to smoking cannabis the day before and was arrested. Officer Finerty requested Bolourchi to submit to a blood test, but Bolourchi insisted that a warrant be obtained first. Bolourchi also offered Officer Finerty $1,000 to let him go, which was interpreted as a bribe.In the trial court, Bolourchi was convicted of driving under the influence of a drug and bribing an executive officer. The court suspended the imposition of sentence, placed Bolourchi on three years’ probation, and ordered a jail term of 180 days. Bolourchi appealed, arguing that the court erred by instructing the jury with CALCRIM No. 2130, an instruction that states a defendant’s refusal to submit to a chemical test as required by California’s implied consent statute may show consciousness of guilt.The Court of Appeal of the State of California First Appellate District affirmed the lower court's decision. The court held that a motorist's refusal to cooperate in the taking of a blood test unless a warrant is first obtained can be used as an adverse inference of consciousness of guilt in a DUI trial. The court found no instructional error in the use of CALCRIM No. 2130 and rejected Bolourchi's argument that he had a constitutional right to demand a warrant before submitting to a blood draw. The court concluded that while the Fourth Amendment required police to obtain a warrant to conduct a blood draw, Bolourchi could still face an adverse inference at his trial on a DUI charge as a cost of refusing a blood test. View "People v. Bolourchi" on Justia Law

A former teacher at Hanover High School in Massachusetts, Kari MacRae, was terminated from her position due to controversial memes she posted on her personal TikTok account. The memes, which were posted before she was hired, touched on sensitive topics such as gender identity, racism, and immigration. After her posts became public knowledge, the school district decided to terminate her employment, citing concerns about potential disruption to the learning environment.In the lower courts, MacRae filed a lawsuit against the school district, the school's principal, and the superintendent, alleging that they had unconstitutionally retaliated against her for exercising her First Amendment rights. The district court granted the defendants' motion for summary judgment, concluding that the school district's interest in preventing disruption outweighed MacRae's First Amendment rights.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court applied the Garcetti framework, which balances the interests of a public employee in commenting on matters of public concern against the interest of the state in promoting the efficiency of public services. The court found that while MacRae's posts did touch on matters of public concern, the school district's interest in preventing disruption to the learning environment was reasonable and outweighed MacRae's First Amendment interest. The court also noted that the timing of the posts, the media attention they received, and the controversy they stirred in the community all supported the school district's prediction of disruption. View "MacRae v. Mattos" on Justia Law

In 1987, Michael Kitchen, a seventeen-year-old, was sentenced to forty-two to sixty years in prison by a Michigan state court for his involvement in a home invasion. Under Michigan law, Kitchen is not eligible for parole until he completes his minimum sentence, which means he will not be considered for parole until he is nearly sixty. Kitchen filed a pro se § 1983 suit challenging the statute against Michigan’s governor, the Department of Corrections Director, and the chair of the Parole Board. He alleges that Michigan’s parole statute violates his Eighth Amendment rights because it effectively keeps him in prison for life without parole. The district court sided with Kitchen.The district court agreed with Kitchen and ruled against Defendants in an opinion and order on August 16, 2019. The court concluded that, despite the “legal and factual support” for Defendants’ position, “Kitchen is not required to bring his federal constitutional claims via a petition for a writ of habeas corpus,” and he could pursue them under § 1983. The district court thus rejected Defendants’ Heck argument. The Heck issue was not litigated any further.The United States Court of Appeals for the Sixth Circuit disagreed with the district court's decision. The court held that Kitchen's claim, if successful, would necessarily imply the invalidity of his sentence. Therefore, his claim must be brought through habeas corpus, not § 1983. The court reversed the district court's decision and remanded the case for further proceedings. View "Kitchen v. Whitmer" on Justia Law

The case involves Douglas Damon Whitley, who was convicted of Hobbs Act robbery, federal carjacking, and a firearm offense in connection with his theft of a Peloton delivery van and its contents. Whitley was sentenced to concurrent 84-month prison terms for the robbery and carjacking convictions. On appeal, Whitley argued that his convictions and sentences for both offenses violated the Double Jeopardy Clause, as he believed Hobbs Act robbery to be a lesser included offense of carjacking. He also contended that there was insufficient evidence of the specific intent needed to convict him of federal carjacking.The case was first heard in the United States District Court for the Eastern District of Virginia. Whitley and his co-defendant, Kindal Robinson, pleaded not guilty and proceeded to a joint jury trial. The jury found them both guilty of all charges. Whitley then filed a motion for judgment of acquittal, arguing that his convictions for both Hobbs Act robbery and federal carjacking violated the Double Jeopardy Clause. He also argued that the government failed to produce sufficient evidence of his specific intent to cause death or serious bodily harm, an essential element of federal carjacking. The district court denied Whitley’s motion, determining that Hobbs Act robbery is not a lesser included offense of carjacking and that a reasonable jury could have found that Whitley had the specific intent to kill or seriously injure the van driver.The case was then reviewed by the United States Court of Appeals for the Fourth Circuit. The court disagreed with Whitley's arguments and affirmed the district court’s judgment. The court found that the jurisdictional elements of Hobbs Act robbery and federal carjacking differed, meaning that the two offenses were not the same under the Blockburger test. The court also found that there was sufficient evidence to support the jury’s finding that Whitley had the specific intent to cause death or serious bodily harm, thus rejecting Whitley's sufficiency challenge. View "US v. Whitley" on Justia Law

The case revolves around a traffic stop in Wisconsin where police officers used a K-9 unit to sniff a car they suspected was involved in drug trafficking. The dog signaled the presence of drugs, leading to a search of the car and the discovery of almost eleven pounds of methamphetamine. The defendant, Juventino Plancarte, who was in the car during the stop, challenged the district court's denial of his motion to suppress the evidence.The lower courts had indicted Plancarte on two counts related to methamphetamine distribution. He moved to suppress the evidence obtained after the dog's sniff, arguing that the dog could identify both illegal marijuana products and legal products that come from cannabis plants. Therefore, he contended that the sniff violated the Fourth Amendment as it was a warrantless search unsupported by probable cause. However, the district court adopted the magistrate judge's recommendations denying Plancarte's suppression motion, leading to his guilty plea to both drug charges.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that the dog sniff did not constitute a Fourth Amendment search as it did not disrupt any reasonable expectation of privacy. The court noted that the dog sniff occurred outside the home, in a public area, and during a lawful traffic stop, which generally does not implicate legitimate privacy interests. The court also pointed out that the dog's sniff was not designed to disclose any information other than the presence or absence of narcotics. Therefore, the court concluded that the district court appropriately denied Plancarte's motion to suppress. View "United States v. Plancarte" on Justia Law