Justia Constitutional Law Opinion Summaries

In December 2019, Zackey Rahimi, the respondent, had a violent altercation with his girlfriend, C. M., who is also the mother of his child. Rahimi grabbed C. M., dragged her back to his car, and shoved her in, causing her to hit her head. When a bystander witnessed the incident, Rahimi retrieved a gun from his car. C. M. managed to escape, and Rahimi fired his gun, though it is unclear whether he was aiming at C. M. or the witness. Following this incident, C. M. sought a restraining order against Rahimi, which was granted by a state court in Texas. The order included a finding that Rahimi had committed “family violence” and posed “a credible threat” to the “physical safety” of C. M. or their child. The order also suspended Rahimi’s gun license for two years. Despite the order, Rahimi violated it by approaching C. M.’s home and contacting her through social media. He was later charged with aggravated assault with a deadly weapon for threatening another woman with a gun.Rahimi was indicted for possessing a firearm while subject to a domestic violence restraining order, in violation of 18 U. S. C. §922(g)(8). Rahimi moved to dismiss the indictment, arguing that Section 922(g)(8) violated his Second Amendment right to keep and bear arms. The District Court denied his motion, and Rahimi pleaded guilty. On appeal, he again raised his Second Amendment challenge, which was denied. Rahimi petitioned for rehearing en banc.The Supreme Court of the United States held that when a restraining order contains a finding that an individual poses a credible threat to the physical safety of an intimate partner, that individual may—consistent with the Second Amendment—be banned from possessing firearms while the order is in effect. The Court found that since the founding, the nation's firearm laws have included provisions preventing individuals who threaten physical harm to others from misusing firearms. As applied to the facts of this case, Section 922(g)(8) fits comfortably within this tradition. The Court reversed the judgment of the Court of Appeals for the Fifth Circuit and remanded the case for further proceedings consistent with its opinion. View "United States v. Rahimi" on Justia Law

Paul Erlinger pleaded guilty to being a felon in possession of a firearm, a violation of 18 U.S.C. §922(g). At sentencing, the judge found Erlinger eligible for an enhanced sentence under the Armed Career Criminal Act (ACCA), which increases the penalty for a §922(g) conviction from a maximum of 10 years to a mandatory minimum of 15 years when the defendant has three or more qualifying convictions for offenses committed on different occasions. The Seventh Circuit later ruled that two of the offenses used for Erlinger’s sentence enhancement no longer qualified as ACCA predicate offenses. The District Court vacated Erlinger’s sentence and scheduled resentencing. At the resentencing hearing, prosecutors pursued an ACCA sentence enhancement based on a new set of 26-year-old convictions for burglaries committed by Erlinger over several days. Erlinger argued that the burglaries were part of a single criminal episode and did not occur on separate occasions, as required by ACCA. He also argued that the Fifth and Sixth Amendments required that a jury make that assessment. The District Court rejected Erlinger’s request for a jury and issued a 15-year enhanced sentence. On appeal, the government confessed error, admitting that the Constitution requires a jury to decide unanimously and beyond a reasonable doubt whether Erlinger’s prior offenses were committed on different occasions.The Supreme Court of the United States held that the Fifth and Sixth Amendments require a unanimous jury to make the determination beyond a reasonable doubt that a defendant’s past offenses were committed on separate occasions for ACCA purposes. The Court noted that the Sixth Amendment promises that in all criminal prosecutions, the accused has the right to a speedy and public trial, by an impartial jury. The Fifth Amendment further promises that the government may not deprive individuals of their liberty without due process of law. The Court has repeatedly cautioned that trial and sentencing practices must remain within the guardrails provided by these two Amendments. The Court vacated the judgment of the Court of Appeals for the Seventh Circuit and remanded the case for further proceedings consistent with its opinion. View "Erlinger v. United States" on Justia Law

The case involves Sandra Muñoz, an American citizen, and her husband Luis Asencio-Cordero, a citizen of El Salvador. The couple sought to obtain an immigrant visa for Asencio-Cordero to live in the United States. After several interviews, a consular officer denied Asencio-Cordero's application, citing a provision that renders inadmissible a noncitizen whom the officer believes seeks to engage in unlawful activity. Asencio-Cordero and Muñoz sued the Department of State, claiming that it had abridged Muñoz’s constitutional liberty interest in her husband’s visa application by failing to give a sufficient reason why Asencio-Cordero is inadmissible under the “unlawful activity” bar.The District Court granted summary judgment to the State Department, but the Ninth Circuit vacated the judgment, holding that Muñoz had a constitutionally protected liberty interest in her husband’s visa application and that the State Department was required to give Muñoz a reason for denying her husband’s visa. The court further held that by declining to give Muñoz more information earlier in the process, the State Department had forfeited its entitlement to insulate its decision from judicial review under the doctrine of consular nonreviewability.The Supreme Court of the United States reversed the Ninth Circuit's decision, holding that a citizen does not have a fundamental liberty interest in her noncitizen spouse being admitted to the country. The Court noted that while Congress has extended special treatment to marriage in immigration matters, it has never made spousal immigration a matter of right. The Court also noted that the assertion of a procedural due process right in someone else's legal proceeding would have unsettling collateral consequences. The case was remanded for further proceedings consistent with the Court's opinion. View "Department of State v. Munoz" on Justia Law

The case involves the Sixth Amendment's Confrontation Clause, which guarantees a criminal defendant the right to confront the witnesses against him. The defendant, Jason Smith, was charged with various drug offenses after law enforcement officers found him with a large quantity of what appeared to be drugs and drug-related items. The seized items were sent to a crime lab for scientific analysis. Analyst Elizabeth Rast ran forensic tests on the items and concluded that they contained usable quantities of methamphetamine, marijuana, and cannabis. Rast prepared a set of typed notes and a signed report about the testing. However, Rast stopped working at the lab prior to trial, so the State substituted another analyst, Greggory Longoni, to provide an independent opinion on the drug testing performed by Rast. At trial, Longoni conveyed to the jury what Rast’s records revealed about her testing, before offering his “independent opinion” of each item’s identity. Smith was convicted. On appeal, he argued that the State’s use of a substitute expert to convey the substance of Rast’s materials violated his Confrontation Clause rights. The Arizona Court of Appeals rejected Smith’s challenge.The Supreme Court of the United States held that when an expert conveys an absent analyst’s statements in support of the expert’s opinion, and the statements provide that support only if true, then the statements come into evidence for their truth. The Court vacated the judgment of the Arizona Court of Appeals and remanded the case for further proceedings. The Court clarified that the Confrontation Clause still allows forensic experts to play a useful role in criminal trials. However, a state may not introduce the testimonial out-of-court statements of a forensic analyst at trial, unless she is unavailable and the defendant has had a prior chance to cross-examine her. The Court concluded that the State used Longoni to relay what Rast wrote down about how she identified the seized substances, and thus Longoni effectively became Rast’s mouthpiece. If the out-of-court statements were also testimonial, their admission violated the Confrontation Clause. View "Smith v. Arizona" on Justia Law

The case involves the Iowaska Church of Healing (the "Church"), an organization whose religious practices involve the consumption of Ayahuasca, a tea containing the hallucinogenic drug dimethyltryptamine (DMT), which is regulated under the Controlled Substances Act (CSA). The Church had applied for tax-exempt status under 26 U.S.C. § 501(c)(3) but was denied by the Internal Revenue Service (IRS) on the grounds that the Church's religious use of Ayahuasca was illegal. The Church challenged this decision in the District Court, arguing that the IRS's determination was based on an incorrect assumption of illegality and that the denial of tax-exempt status violated the Religious Freedom Restoration Act of 1993 (RFRA).The District Court denied the Church's motion and granted the Government's motion for summary judgment. The court held that the Church lacked standing to assert its RFRA claim and that the lack of standing also undermined its tax-exemption claim. The court found that the Church's religious use of Ayahuasca was illegal without a CSA exemption, and the IRS had no authority to assess whether the Church's proposed Ayahuasca use warranted a religious exemption from the CSA.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the District Court's judgment. The Court of Appeals held that the Church lacked standing to assert its RFRA claim because the economic injury it claimed was neither an injury-in-fact nor redressable. Without a cognizable RFRA claim, the Church's tax-exemption claim also failed. The Court of Appeals found that the Church could not proffer evidence of a CSA exemption to show it passed the organizational and operational tests for tax-exempt status. View "Iowaska Church of Healing v. Werfel" on Justia Law

The case involves Irvin Abreu, who pleaded guilty to one count of sexual exploitation of a child. The district court sentenced him to 315 months in prison, applying an enhanced mandatory minimum sentence of 300 months due to his prior state-law conviction for enticement of a child under the age of sixteen. Abreu appealed, arguing that his prior state-law conviction should not trigger the twenty-five-year minimum for his federal crime.Previously, the district court had determined during pre-trial proceedings that Abreu's prior conviction did trigger the twenty-five-year mandatory minimum under § 2251(e). Abreu subsequently changed his plea to guilty, and at sentencing, the district court considered a U.S. Sentencing Guidelines range of 300 to 327 months due to the mandatory minimum sentence.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court agreed with the district court's ruling that the enhancement does apply, concluding that the Massachusetts child-enticement statute is divisible and that Abreu's prior offense is related to the generic crimes listed in § 2251(e). The court also rejected Abreu's argument that § 2251(e) is unconstitutionally vague under the Fifth Amendment's Due Process Clause. View "US v. Abreu" on Justia Law

Shannon Hightower pleaded guilty to dependent adult abuse and theft in the second degree. She later appealed, arguing that there were defects in her guilty plea, her sentencing, and the conditions set for her appeal bond. Hightower also contended that Iowa Code section 814.29, which regulates judicial review of challenges to a guilty plea, was unconstitutional.The district court had found Hightower guilty based on her plea and sentenced her to concurrent prison terms. One of the court's reasons for the sentence was Hightower's failure to pay restitution prior to sentencing. After sentencing, Hightower filed a motion asking the court to order a stay of the sentence and to set a hearing to review concerns about her guilty plea. Alternatively, she asked the court to set an appropriate appeal bond. The court denied Hightower's request for a hearing about her guilty plea and set an appeal bond in the amount of $17,000 cash only.The Supreme Court of Iowa found that Hightower's guilty plea was defective due to the absence of an accurate advisory as to the maximum punishment she faced by pleading guilty. However, the court concluded that section 814.29 prevented it from vacating Hightower's plea. The court also agreed with Hightower that resentencing was required because the district court relied on an improper sentencing factor. Furthermore, the court agreed with Hightower that the district court erred by ordering unauthorized forfeiture requirements for Hightower’s appeal bond. The court affirmed Hightower’s conviction, vacated her sentence, and reversed the forfeiture requirements. The case was remanded for resentencing and for lawful disbursement of funds paid for Hightower’s release during the appeal. View "State of Iowa v. Hightower" on Justia Law

The Supreme Court of California ruled that the Taxpayer Protection and Government Accountability Act (TPA), a proposed initiative measure, could not be placed on the November 2024 general election ballot. The TPA sought to revise the California Constitution by requiring voter approval for any new or increased state or local tax, and by expanding the definition of "tax" to include a wider range of government charges. The petitioners, the Legislature of the State of California, Governor Gavin Newsom, and former Senate President Pro Tempore John Burton, argued that the TPA was invalid because it attempted to revise the California Constitution via citizen initiative, and because it would seriously impair essential government functions.The court agreed with the petitioners, finding that the TPA would substantially alter the basic governmental framework set forth in the California Constitution. The court noted that the TPA would eliminate the Legislature's ability to levy taxes without prior voter approval, shift power between the executive and legislative branches, and transform local revenue-raising by requiring that exempt charges go through legislative rather than administrative processes. The court concluded that these changes were so significant that they amounted to a revision of the Constitution, which could not be enacted by initiative. The court therefore issued a writ of mandate directing the Secretary of State to refrain from placing the TPA on the November 2024 election ballot. View "Legislature of the State of California v. Weber" on Justia Law

The case involves Charles and Kathleen Moore, who invested in an American-controlled foreign corporation, KisanKraft. From 2006 to 2017, KisanKraft generated substantial income but did not distribute it to its American shareholders. At the end of the 2017 tax year, the application of the new Mandatory Repatriation Tax (MRT) resulted in a tax bill of $14,729 on the Moores’ pro rata share of KisanKraft’s accumulated income from 2006 to 2017. The Moores paid the tax and then sued for a refund, claiming that the MRT violated the Direct Tax Clause of the Constitution because it was an unapportioned direct tax on their shares of KisanKraft stock. The District Court dismissed the suit, and the Ninth Circuit affirmed.The Supreme Court of the United States affirmed the Ninth Circuit's decision. The Court held that the MRT, which attributes the realized and undistributed income of an American-controlled foreign corporation to the entity’s American shareholders, and then taxes the American shareholders on their portions of that income, does not exceed Congress’s constitutional authority. The Court's decision was based on the broad power of Congress to lay and collect taxes, which includes direct taxes—those imposed on persons or property—and indirect taxes—those imposed on activities or transactions. The Court also noted that taxes on income are indirect taxes, and the Sixteenth Amendment confirms that taxes on income need not be apportioned. The Court's holding is narrow and limited to entities treated as pass-throughs. View "Moore v. United States" on Justia Law

Mani Panoam Deng was charged with being an unlawful drug user in possession of a firearm, a violation of 18 U.S.C. § 922(g)(3). Deng moved to dismiss the indictment, arguing that the statute violated the Second Amendment and was void for vagueness. He pleaded guilty unconditionally, but appealed, renewing his constitutional challenges and arguing that the court erred by deferring a complete decision on his motion to dismiss.The United States District Court for the Southern District of Iowa denied Deng's facial Second Amendment challenge and deferred ruling on his other claims, as they were tied to facts about his offense conduct that a jury needed to find. After Deng pleaded guilty, he appealed, renewing his constitutional challenges and arguing that the court erred by deferring a complete decision on his motion to dismiss.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The court held that § 922(g)(3) is facially constitutional, citing a previous decision in United States v. Veasley. Deng's as-applied challenge was deemed waived due to his unconditional guilty plea. The court also rejected Deng's vagueness challenge, stating that a criminal statute is void for vagueness under the Fifth Amendment’s Due Process Clause only if it fails to give ordinary people fair notice of the conduct it punishes or is so standardless that it invites arbitrary enforcement. The court found that § 922(g)(3) was not vague as applied to Deng's conduct. Deng's argument that the district court erred by deferring a ruling on his vagueness and as-applied Second Amendment challenges was also dismissed as he had waived this claim by pleading guilty. View "United States v. Deng" on Justia Law