Justia Constitutional Law Opinion Summaries

The case involves the National Rifle Association (NRA) and Maria Vullo, the former superintendent of the New York Department of Financial Services (DFS). The NRA alleged that Vullo violated their First Amendment rights by pressuring regulated entities to disassociate from the NRA and other gun-promotion advocacy groups. The NRA claimed that Vullo threatened enforcement actions against those entities that refused to disassociate, thereby stifling the NRA's pro-gun advocacy.The District Court initially denied Vullo's motion to dismiss the NRA's First Amendment damages claims, holding that the NRA plausibly alleged that Vullo's actions could be interpreted as a veiled threat to regulated industries to disassociate with the NRA or risk DFS enforcement action. However, the Second Circuit reversed this decision, concluding that Vullo's alleged actions constituted permissible government speech and legitimate law enforcement, not unconstitutional coercion. The Second Circuit also held that even if the complaint stated a First Amendment violation, the law was not clearly established, and so Vullo was entitled to qualified immunity.The Supreme Court of the United States, however, vacated the judgment of the Second Circuit. The Supreme Court held that the NRA plausibly alleged that Vullo violated the First Amendment by coercing DFS-regulated entities to terminate their business relationships with the NRA in order to punish or suppress the NRA's advocacy. The case was remanded for further proceedings consistent with this opinion. View "National Rifle Association of America v. Vullo" on Justia Law

The case involves Conrad Reynolds, Arkansas Voter Integrity Initiative, Inc., and Restore Election Integrity Arkansas (collectively referred to as the petitioners) who filed an original action against John Thurston, in his official capacity as Secretary of State, and the State Board of Election Commissioners (collectively referred to as the respondents). The petitioners submitted two proposed measures to amend the Arkansas Constitution to the Attorney General for approval. One measure would have required elections to be conducted with paper ballots, and the other would have changed absentee-voting procedures. The Attorney General rejected both measures, citing various reasons such as conflicting provisions, unclear language, and redundancy. The petitioners resubmitted the measures to the Attorney General, the Secretary of State, and the State Board of Election Commissioners for certification, but the Secretary and the Board refused to examine the sufficiency of the ballot titles and popular names.The petitioners then filed this original-action complaint, asking the court to independently certify the legal sufficiency of the measures’ ballot titles and popular names and order them placed on the November 2024 ballot. They also asked the court to declare Arkansas Code Annotated section 7-9-107 and section 7-9-126(e) unconstitutional, arguing that these sections violate Article 5, section 1 of the Arkansas Constitution.The Supreme Court of Arkansas dismissed the complaint, ruling that it only has original jurisdiction over the sufficiency of petitions after the Secretary of State has made a sufficiency determination. The court found that the petitioners' request for a declaration that the statutes are unconstitutional falls outside its original jurisdiction. The court also noted that the petitioners could have filed a declaratory-judgment action in the circuit court to determine the constitutionality of the statutes. View "Reynolds v. Thurston" on Justia Law

The case involves Jose Luis Amador-Bonilla, a citizen of Guatemala and Nicaragua, who was charged with violating 8 U.S.C. § 1326, Illegal Reentry After Removal from the United States. Amador-Bonilla had entered the United States without authorization multiple times and had been removed six times. He was arrested in Oklahoma and charged with illegal reentry, an offense for which he had already been convicted twice. He moved to dismiss the indictment, arguing that the illegal reentry provision of the Immigration and Nationality Act violates his right to equal protection under the Fifth Amendment.The United States District Court for the Western District of Oklahoma denied Amador-Bonilla's motion to dismiss the indictment. The court determined that rational basis review applied to Amador-Bonilla’s challenge and that the challenge failed because Amador-Bonilla failed to show there was no “rational relationship between the disparity of treatment and some legitimate governmental purpose.” The court also found that even if the Arlington Heights framework arguably applied, Amador-Bonilla “failed to demonstrate that [8 U.S.C. § 1326] was passed with a discriminatory purpose as a motivating factor.”The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that 8 U.S.C. § 1326 does not violate the Fifth Amendment. The court found that Amador-Bonilla failed to show that Congress enacted the provision in 1952 with a discriminatory purpose as a motivating factor. The court also noted that all parties agreed that the provision otherwise satisfies rational basis review. View "United States v. Amador-Bonilla" on Justia Law

The case revolves around Justin Keener, who operated under the name JMJ Financial. Keener's business model involved purchasing convertible notes from microcap issuers, converting those notes into common stock, and selling that stock in the public market at a profit. This practice, known as "toxic" or "death spiral" financing, can harm microcap companies and existing investors by causing the stock price to drop significantly. Keener made over $7.7 million in profits from this practice. However, he never registered as a dealer with the Securities and Exchange Commission (SEC).The SEC filed a civil enforcement action against Keener, alleging that he operated as an unregistered dealer in violation of the Securities Exchange Act of 1934. The United States District Court for the Southern District of Florida granted summary judgment for the SEC, enjoining Keener from future securities transactions as an unregistered dealer and ordering him to disgorge the profits from his convertible-note business.In the United States Court of Appeals for the Eleventh Circuit, Keener appealed the district court's decision. He argued that he did not violate the Securities Exchange Act because he never effectuated securities orders for customers. He also claimed that the SEC violated his rights to due process and equal protection.The Court of Appeals affirmed the district court's decision. It held that Keener operated as an unregistered dealer in violation of the Securities Exchange Act. The court rejected Keener's argument that he could not have been a dealer because he never effectuated securities orders for customers. It also dismissed Keener's claims that the SEC violated his rights to due process and equal protection. The court upheld the district court's imposition of a permanent injunction and its order for Keener to disgorge his profits. View "Securities and Exchange Commission v. Keener" on Justia Law

Sanjay Tripathy, a former inmate in the New York correctional system, filed a lawsuit against state prison officials. He claimed that they forced him to enroll in a sex-offender program that required him to accept responsibility for his crimes, which he argued violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the First Amendment. He also claimed that he was assigned to a more intensive tier of the program in violation of his due process rights, and that he was retaliated against after he challenged the program by filing grievances and this lawsuit.The United States District Court for the Western District of New York dismissed Tripathy's claims. The court ruled that his claim for damages under RLUIPA was barred by precedent that the statute does not permit individual-capacity damages. The court also found that his demands for injunctive and declaratory relief became moot when his state convictions were vacated and he was released from prison. Regarding his constitutional claims, the court concluded that Tripathy’s free exercise claim under the First Amendment was barred by qualified immunity, that he lacked standing to seek damages for his due process claim under the Fourteenth Amendment, and that he failed to state a claim for retaliation in violation of the First Amendment.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The appellate court agreed that Tripathy's claim for damages under RLUIPA was barred by precedent, that his demands for injunctive and declaratory relief were moot due to his release from prison, and that his constitutional claims were properly dismissed by the district court. View "Tripathy v. McKoy" on Justia Law

Ricardo Sturkey was convicted of malice murder and other crimes related to the shooting death of Albert White. The crimes occurred in February 2009, and Sturkey was indicted by a Macon County grand jury in July 2010. In December 2010, a jury found Sturkey guilty on all counts, and he was sentenced to life in prison for malice murder, along with additional concurrent and consecutive terms for other crimes. Sturkey filed a motion for a new trial, which was denied by the trial court in January 2022.The Supreme Court of Georgia reviewed the case in 2024. Sturkey raised two claims of trial court error and argued that his trial counsel provided constitutionally ineffective assistance. The first claim was that the trial judge expressed an opinion on Sturkey's guilt during the questioning of a witness, violating Georgia law. The court found no error, as the judge's questions focused on the witness's methodology and did not express an opinion on the credibility of the witness or the facts of the case.Sturkey's second claim was that the trial court erred in its statements about the potential admissibility of polygraph evidence. The court found no error, as the trial court had not made a definitive ruling on the admissibility of the polygraph evidence, and the evidence was not admitted at trial.Finally, Sturkey argued that his trial counsel was ineffective for discontinuing cross-examination of a principal investigator and for failing to present the testimony of a witness who could provide evidence of additional suspects. The court found no merit in these claims, as Sturkey failed to demonstrate that his counsel's performance was deficient or that he was prejudiced as a result. The court affirmed Sturkey's conviction. View "STURKEY v. THE STATE" on Justia Law

The case involves Darious Jones, who was convicted for felony murder in 2016, related to the beating death of Faith Parke. Jones arranged to meet Parke at the location where she was found dead. His DNA and fingerprints were found at the crime scene, including on a doorstop bar near Parke's body. Parke had injuries matching the pattern on the end of the doorstop bar. Jones challenged his conviction, arguing that the evidence was constitutionally insufficient, that the trial court erred by allowing him to decide whether to testify without further inquiry due to his mental condition, and that the trial court erred in refusing to give voluntary manslaughter-related instructions that he requested.Jones was indicted for malice murder, felony murder, and aggravated assault by a DeKalb County grand jury in 2015. In 2016, the jury found him not guilty of malice murder but guilty of felony murder and aggravated assault. He was sentenced to life in prison without the possibility of parole for felony murder. Jones filed a timely motion for a new trial, which was denied by the trial court in 2023. He then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the lower court's decision. The court found that the evidence was sufficient to uphold Jones' conviction. The court also ruled that Georgia law does not require a trial court to advise a defendant concerning his right to testify or to make the type of inquiry that Jones asserts the trial court should have made. The court further held that the trial court properly refused to give Jones' requested instructions regarding voluntary manslaughter because no evidence supported them. Lastly, the court dismissed Jones' argument that the trial court erred in sentencing him to life without parole. View "JONES v. THE STATE" on Justia Law

Tyler Jarel Thomas was indicted for the murder of Ashley Brown in February 2014. Prior to his indictment, law enforcement obtained Thomas's phone records, including cell site location information (CSLI), through a court order. At the time, no appellate precedent in Georgia required a warrant for such records. However, Thomas moved to suppress the CSLI, arguing it was obtained in violation of the Fourth Amendment. The trial court granted his motion, relying partly on an Eleventh Circuit decision that later reversed its stance on the necessity of a warrant for CSLI.The State asked the trial court to reconsider its suppression order in light of the Eleventh Circuit's reconsideration. Thomas argued that the end-of-term rule prohibited the trial court's reconsideration. The trial court agreed with Thomas, stating that the end-of-term rule divested it of the authority to reconsider its own prior interlocutory ruling. Thomas was found guilty of malice murder and related crimes, but a new trial was granted due to a Brady violation by the State.Upon remand to the trial court, the State again moved for reconsideration of the CSLI suppression order. This time, the trial court agreed with the State, vacated the earlier suppression order, and held that the CSLI could be tendered at trial. Thomas appealed this decision.The Supreme Court of Georgia affirmed the trial court's decision. The court held that when a new trial has been granted, trial courts are not prohibited from reconsidering their previous orders. Therefore, because the final judgment in this case was vacated by the grant of a new trial, the trial court could reconsider rulings from earlier terms. View "THOMAS v. THE STATE" on Justia Law

John David Panasuk was pulled over by Officer Riediger and Lieutenant Frank Martell for towing a trailer without trailer plates. After Panasuk was unable to initially provide his license, registration, and proof of insurance, Riediger asked him to exit his vehicle. The other occupants, Camilla TalksDifferent and Dustin Hickman, were also asked to exit. Riediger and Martell knew TalksDifferent as a drug user, but they did not know Panasuk or Hickman. When Hickman produced a North Dakota driver’s license, Riediger contacted the Williams County Task Force in North Dakota and was told Hickman had a history of being a drug dealer and user. Riediger also recalled a previous incident where Panasuk was suspected of selling methamphetamine. TalksDifferent gave consent to search her purse, where Riediger found two syringes. She also told Riediger there was methamphetamine in Panasuk’s vehicle. Riediger seized the vehicle and applied for a search warrant. Law enforcement recovered 6.4 grams of methamphetamine from the vehicle’s center console after searching the vehicle. Panasuk was charged with criminal possession of dangerous drugs and drug paraphernalia.The District Court denied Panasuk’s motion to suppress the evidence, noting Panasuk’s previous incident and that TalksDifferent had said there was methamphetamine in the vehicle. The court found that law enforcement had sufficient particularized suspicion to expand the scope of a traffic stop to a drug investigation.The Supreme Court of the State of Montana reversed the District Court's decision. The Supreme Court found that the initial detention was unconstitutionally extended beyond what was necessary to effectuate the initial purpose of the stop. The court concluded that there were no articulable facts, other than prior suspected criminal histories, which were offered as justification to expand the search into a drug investigation. The court held that knowledge of a person’s prior criminal involvement is alone insufficient to give rise to the requisite reasonable suspicion. The court remanded the matter for further proceedings consistent with its opinion. View "State v. Panasuk" on Justia Law

An Alabama inmate, Jamie Mills, who was scheduled for execution on May 30, 2024, for committing two murders in 2004, appealed the denial of his motion for a preliminary injunction. Mills claimed that the State's practice of restraining its condemned prisoners on a gurney before execution would violate his constitutional rights to access the courts, to counsel, to due process, and against cruel and unusual punishment.Mills's case had been reviewed by multiple courts. His death sentence was affirmed by the Alabama Court of Criminal Appeals and the Supreme Court of Alabama. The Supreme Court of the United States denied certiorari. Mills also sought postconviction relief under Alabama Rule of Criminal Procedure 32, which was denied by the trial court and affirmed by the Alabama Court of Criminal Appeals and Supreme Court of Alabama. His federal petition for a writ of habeas corpus was denied by the district court in 2020. This Court denied a certificate of appealability in 2021, and the Supreme Court denied certiorari in 2022.The United States Court of Appeals for the Eleventh Circuit denied Mills's motion for a stay of execution. The court found that Mills had not established that he was substantially likely to succeed on the merits of his appeal or that the equities favor a stay of execution at this late stage. The court rejected Mills's arguments that he was likely to succeed on the merits of his claims under the Sixth, Eighth, and Fourteenth Amendments. The court also found that Mills's delay in seeking a preliminary injunction and a stay was "unnecessary and inexcusable," and that other equities weighed against a stay. View "Mills v. Hamm" on Justia Law