Justia Constitutional Law Opinion Summaries

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

The Supreme Court of Texas reviewed a case involving a new law that prohibits certain medical treatments for children if administered for the purpose of transitioning a child's biological sex or affirming the child's perception of their sex if it is inconsistent with their biological sex. Several parents of children with gender dysphoria, along with physicians and groups that would be affected by the law, sued to enjoin its enforcement, alleging that it is facially unconstitutional. The trial court concluded that the law likely violates the Texas Constitution and temporarily enjoined the law's enforcement.The Supreme Court of Texas disagreed with the trial court's decision. The court held that the plaintiffs failed to establish a probable right to relief on their claims that the prohibition of certain treatments for children suffering from gender dysphoria violates the Texas Constitution. The court emphasized that while parents have a fundamental interest in directing the care, custody, and control of their children, this interest is not absolute. The court concluded that the Legislature made a permissible, rational policy choice to limit the types of available medical procedures for children, particularly in light of the relative nascency of both gender dysphoria and its various modes of treatment. The court also concluded that the law does not unconstitutionally deprive parents of their rights or physicians or health care providers of an alleged property right in their medical licenses or claimed right to occupational freedom. The court further concluded that the law does not unconstitutionally deny or abridge equality under the law because of sex or any other characteristic asserted by plaintiffs. The court therefore reversed and vacated the trial court's order. View "STATE OF TEXAS v. LOE" on Justia Law

This case involves a dispute over a provision in a collective bargaining agreement between the City of Austin and the Austin Firefighters Association. The provision, known as Article 10, grants 5,600 hours of "Association Business Leave" (ABL) annually for firefighters to conduct union-related activities. The petitioners, including the State of Texas and several individuals, argued that Article 10 violates the "Gift Clauses" of the Texas Constitution, which prohibit governmental entities from making gifts of public resources to private parties. They contended that the ABL provision improperly benefits the union by allowing firefighters to use paid time off for union activities, some of which they alleged were misused for improper purposes.The case was initially dismissed under the Texas Citizens Participation Act (TCPA), with the trial court granting relief to the Association, including the award of fees and sanctions. On appeal, the trial court's findings of fact went unchallenged, and the focus was primarily on whether the agreement itself violated the Gift Clauses.The Supreme Court of Texas held that Article 10 does not violate the Gift Clauses. The court found that the provision is not a gratuitous gift but brings a public benefit, serves a legitimate public purpose, and the government retains control over the funds to ensure that the public purpose is achieved. The court emphasized that the ABL must be used for activities that directly support the mission of the Fire Department or the Association and are consistent with the Association’s purposes. The court also reversed the trial court's order granting the Association's TCPA motion to dismiss and its award of sanctions and fees against the original plaintiffs. View "BORGELT v. AUSTIN FIREFIGHTERS ASSOCIATION, IAFF LOCAL 975" on Justia Law

The case involves Dianne Hensley, a justice of the peace in Texas, who announced that due to her religious beliefs, she would not perform weddings for same-sex couples but would refer them to others who would. The State Commission on Judicial Conduct issued her a public warning for casting doubt on her capacity to act impartially due to the person's sexual orientation, in violation of Canon 4A(1) of the Texas Code of Judicial Conduct. Hensley did not appeal this warning to a Special Court of Review (SCR) but instead sued the Commission and its members and officers for violating the Texas Religious Freedom Restoration Act (TRFRA) and her right to freedom of speech under Article I, Section 8 of the Texas Constitution. The trial court dismissed her claims for lack of jurisdiction, and the court of appeals affirmed.The Supreme Court of Texas held that Hensley's suit was not barred by her decision not to appeal the Commission’s Public Warning or by sovereign immunity. The court affirmed the part of the court of appeals’ judgment dismissing one of Hensley's declaratory requests for lack of jurisdiction, reversed the remainder of the judgment, and remanded to the court of appeals to address the remaining issues on appeal. The court found that the SCR could not have finally decided whether Hensley is entitled to the relief sought in this case or awarded the relief TRFRA provides to successful claimants. View "HENSLEY v. STATE COMMISSION ON JUDICIAL CONDUCT" on Justia Law