Justia Constitutional Law Opinion Summaries

The case involves David W. Noble, Jr., a candidate for president in the National Association of Letter Carriers (NALC) election, who sought to publish his campaign material in the NALC's magazine, the Postal Record. The NALC denied Noble's request, citing an internal policy that only allows political advertisements to be run in the magazine's designated election issue. Noble sued NALC, asserting that the Union was required to publish his campaign material under Section 401(c) of the Labor-Management Reporting and Disclosure Act (LMRDA). The district court granted NALC's motion to dismiss the complaint, interpreting the LMRDA to only require a union to coordinate the delivery of a candidate’s standalone, already-printed campaign material to its membership, not to publish a candidate's campaign advertisements.The United States Court of Appeals for the District of Columbia Circuit disagreed with the district court's interpretation of the LMRDA. The appellate court held that the term "distribute" in Section 401(c) of the LMRDA includes the publication of campaign literature in a union magazine. The court also found that the district court misapplied the reasonableness standard by focusing on the reasonableness of NALC's internal policy rather than the reasonableness of Noble's request. The court further held that requiring NALC to publish Noble's campaign material would not constitute compelled speech in violation of the First Amendment. The court reversed the district court's dismissal of Noble's claim and remanded the case for further proceedings. View "Noble v. National Association of Letter Carriers" on Justia Law

The case involves journalist Robert Schilling's attempt to obtain records related to the Committee on Oversight and Reform of the United States House of Representatives' use of outside consultants as part of a congressional investigation. Schilling sought these records under the common law right of access, alleging that the hearings were part of a series of public-private collaborations targeting political opponents of the climate policy agenda. He claimed that the requested records would show that the Committee used unpaid consulting services to prepare for the hearings, in violation of federal law and House rules.The district court dismissed Schilling's petition, ruling that the Constitution's Speech or Debate Clause barred the case. The court held that the Clause acts as an absolute jurisdictional bar to suits seeking compelled disclosure of materials related to legislative activity. Schilling appealed this decision.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court's dismissal, but on different grounds. The appellate court did not address the question of whether the Speech or Debate Clause barred Schilling's claim. Instead, it dismissed the case on the grounds of sovereign immunity. The court found that the documents Schilling sought were not "public records," and thus, there was no duty imposed on Congress to grant Schilling's request. As a result, the Larson-Dugan exception to sovereign immunity did not apply, and Schilling's claim was barred by sovereign immunity. View "Schilling v. United States House of Representatives" on Justia Law

A group of Arkansas landowners sued Lawrence County, alleging that a bridge constructed by the county had caused their farms to flood, constituting an unlawful taking of their properties without just compensation, in violation of the U.S. and Arkansas Constitutions. The landowners claimed that the bridge acted as a dam, forcing excessive water into the Cache River, which then spilled onto their farms. They presented expert testimony to support their claims and sought damages based on the fair rental value of their properties during the period of the alleged taking.The district court upheld a jury award of nearly $350,000 to the landowners but rejected their request for an order to tear down the bridge. The county appealed the damages award, arguing that the landowners had failed to offer sufficient evidence of damages since they did not calculate the value of crops actually lost. The landowners cross-appealed the denial of their request for injunctive relief.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision on the damages award, holding that the evidence permitted the jury to make a fair and reasonable approximation of damages. The court found that the landowners were not obliged to prove damages by providing evidence of the amount of crops they expected to grow versus the amount of crops they actually grew due to increased flooding. Instead, they were entitled to recover the fair rental value of the property during the period of the taking.However, the court vacated the district court's order denying injunctive relief and remanded for the court to give the landowners' request a more focused consideration. The court found that the district court had relied heavily on the law of standing, which was not at issue, and had ventured into areas that had little bearing on a proper evaluation of the request for injunctive relief. View "Watkins v. Lawrence County, Arkansas" on Justia Law

The case involves Angel Cartagena, an inmate in the Virginia Department of Corrections (VDOC) prison system, who challenged the conditions of his 18-month confinement at the River North Correctional Center. Cartagena alleged that his confinement was too restrictive and caused him emotional distress and severe mental anguish, in violation of his First, Eighth, and Fourteenth Amendment rights, as well as statutory prohibitions against discrimination. VDOC officials had determined that Cartagena was seriously mentally ill and unable to function in the general prison population, so they assigned him to the VDOC’s Secure Diversionary Treatment Program (SDT Program) at the River North facility. Cartagena refused to comply with the treatment regimen prescribed for him and complained about the consequential restrictions of the Program.The district court granted the prison officials’ motion to dismiss Cartagena’s complaint, concluding that Cartagena had failed to state plausible claims for relief. The court found that Cartagena had not sufficiently alleged a deliberate indifference by prison officials to his condition, the deprivation of a constitutionally protected liberty interest, or discrimination because of his disability.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that Cartagena failed to demonstrate the required mens rea for an Eighth Amendment violation, as the prison officials had offered him treatment, which he refused. The court also found that Cartagena failed to adequately allege a cognizable liberty interest in his placement in the SDT Program, and therefore, the Due Process Clause requires no process related to his placement in the Program. Finally, the court concluded that Cartagena failed to plausibly allege that he was “otherwise qualified” for the benefits that he seeks and therefore to state a claim for discrimination under the Americans with Disabilities Act and the Rehabilitation Act. View "Cartagena v. Lovell" on Justia Law

The case revolves around Abel Gomez Medina, who was convicted of sexual abuse and indecent contact with a minor. The minor, identified as Dorothy, was his stepdaughter. She reported the abuse to her school counselor, stating that it had been ongoing since she was eleven years old. Dorothy's stepbrother, Frank, also testified that he had witnessed inappropriate behavior between Medina and Dorothy. The defense presented witnesses who claimed they had never seen anything inappropriate between Medina and Dorothy.Prior to the trial, the State moved to permit Dorothy and Frank to testify via closed-circuit television, citing the potential trauma caused by in-person testimony. The district court granted this for Dorothy but denied it for Frank. During the trial, Dorothy turned eighteen and Medina objected to her continuing to testify via closed-circuit television, arguing that the statute permitting such testimony only applied to minors. The district court overruled this objection, citing a different paragraph of the statute that allowed for closed-circuit testimony for victims or witnesses with mental illnesses, regardless of age.Medina appealed his conviction, arguing that allowing Dorothy to testify via closed-circuit television violated both the Iowa Code and the Confrontation Clause of the United States Constitution. The court of appeals affirmed Medina's convictions, holding that permitting Dorothy’s closed-circuit testimony satisfied constitutional requirements while she was a minor, and that by meeting the requirements under Iowa Code after she turned eighteen, Medina’s claim of a Confrontation Clause violation similarly failed. Medina then filed an application for further review of the court of appeals ruling, which was granted by the Supreme Court of Iowa.The Supreme Court of Iowa affirmed the decisions of the lower courts. It concluded that Medina had failed to preserve error on his Confrontation Clause argument concerning Dorothy’s testimony after she turned eighteen. The court also found that the district court had properly applied the statute to permit Dorothy’s closed-circuit testimony, based on the evidence presented at the pretrial hearing. The court let the court of appeals decision stand on Medina's arguments that the district court abused its discretion by allowing the prosecutor to comment during closing argument and by excluding 911 call logs. View "State v. Medina" on Justia Law

In 2017, the City of Greenville, North Carolina, installed traffic cameras at its most dangerous intersections as part of its Red Light Camera Enforcement Program (RLCEP). The program was funded through a cost-sharing agreement with the Pitt County Board of Education (Board), which received 100% of the collected red light penalties and then reimbursed the City for the actual costs of maintaining the program. In 2018, plaintiffs Eric Fearrington and Craig Malmrose received citations for red light violations captured by RLCEP cameras and challenged their citations in court, arguing that the RLCEP violated Article IX, Section 7 of North Carolina’s Constitution, which promises public schools the “clear proceeds” of all penalties, forfeitures, and fines.The trial court ruled in favor of the Board and City, but the Court of Appeals reversed the dismissal of plaintiffs’ claim and remanded for entry of summary judgment in their favor. The Board and City then petitioned the Supreme Court of North Carolina for discretionary review.The Supreme Court of North Carolina affirmed the Court of Appeals decision on plaintiffs’ taxpayer standing but limited the available remedies to injunctive and declaratory relief, not a “refund.” On plaintiffs’ constitutional challenge, however, the court reversed the Court of Appeals. The court held that the Interlocal Agreement and the Local Act authorizing it did not countermand the constitutional provision’s text or purpose. The court did not discern a “plain and clear” constitutional violation, and thus reversed the award of summary judgment to plaintiffs on their constitutional claim, and remanded the case to the Court of Appeals for further remand to the trial court for entry of summary judgment in favor of Greenville and the Board. View "Fearrington v. City of Greenville" on Justia Law

Cory Sessler, a religious preacher, and his group were preaching loudly at a commercial festival in Davenport, Iowa. The festival was held in a fenced-off area of the city's downtown streets and sidewalks, which were typically considered a "traditional public forum". However, during the festival, pedestrian access was controlled and vendors had rented spaces to sell goods. Sessler and his group, who were not paying vendors, were asked by police officers to relocate outside the fences due to complaints from nearby vendors. Sessler later sued the officers and the city, alleging a violation of his First Amendment rights.The district court denied Sessler's request for a preliminary injunction, a decision which was affirmed by the appellate court. After discovery, the district court granted summary judgment to the defendants, concluding that the officers did not violate Sessler's rights and that they were protected by qualified immunity. The court also granted summary judgment to the city on the official-policy claims.The United States Court of Appeals for the Eighth Circuit agreed that qualified immunity applied to the claims against the officers. The court found that it was unclear whether the fenced-off city streets and sidewalks remained a "traditional public forum" or served as a less-protected "limited public forum" during the festival. The court also found that no reasonable trier of fact could conclude that the officers' actions were anything but content neutral or that such actions were unreasonable. The court affirmed the judgment of the district court. View "Sessler v. City of Davenport, Iowa" on Justia Law

The case involves a dispute between the Walton family and the Neskowin Regional Sanitary Authority over the installation of sewer lines on the Walton's property. The Waltons claimed that the installation constituted a "taking" under the Oregon Constitution and the Fifth Amendment of the U.S. Constitution, for which they were entitled to "just compensation". The Sanitary Authority argued that the claim was time-barred under Oregon law, as it was not brought within the six-year limitations period.The trial court granted the Sanitary Authority's motion for summary judgment, ruling that the claim was indeed time-barred. The Waltons appealed, but the Court of Appeals affirmed the trial court's decision. The Waltons then petitioned for review by the Supreme Court of the State of Oregon.The Supreme Court of the State of Oregon affirmed the decisions of the lower courts. The court held that the Waltons' claim was subject to the six-year limitations period established by Oregon law. The court further held that the claim accrued when the sewer lines were installed, which was no later than 1995, and therefore, the six-year limitations period expired in 2001, sixteen years before the Waltons filed their complaint. Consequently, the court concluded that the Waltons' claim was time-barred. View "Walton v. Neskowin Regional Sanitary Authority" on Justia Law

The case involves Joshua Lyle Creller, who was charged with resisting an officer without violence and possession of a controlled substance, methamphetamine, following a 2018 traffic stop. Creller refused to comply with a K-9 officer’s command to exit his vehicle during the traffic stop for officer safety. After his arrest, methamphetamine was found on his person. Creller moved to suppress the evidence of its discovery.The trial court denied Creller’s motion to suppress, finding the State’s evidence credible. The court concluded that the officer's request for Creller to exit the vehicle was for officer safety and did not violate the Fourth Amendment’s prohibition of unreasonable searches and seizures. Creller was subsequently convicted by a jury. However, the Second District Court of Appeal reversed the conviction, holding that Creller was unlawfully seized in violation of the Fourth Amendment when the initial traffic stop transformed into a narcotics investigation for which no prior probable cause existed. The court certified conflict with the Fifth District Court of Appeal in State v. Benjamin, which reached the opposite conclusion.The Supreme Court of Florida disagreed with the Second District Court of Appeal's interpretation. The court held that the Fourth Amendment allows a K-9 officer to order a driver to exit a vehicle during a lawful traffic stop for officer safety reasons. The court concluded that the K-9 officer's command to Creller to exit the vehicle was reasonable and did not transform the traffic stop into a narcotics investigation. Therefore, the court quashed the decision of the Second District Court of Appeal and approved the decision of the Fifth District Court of Appeal in State v. Benjamin. View "State of Florida v. Creller" on Justia Law

The case involves Marklyn Brown, who was arrested and indicted for a shooting that resulted in the death of Ms. Berta Pereira-Roldan. During his seven-hour interrogation at the Providence Police Department, Brown consistently maintained his innocence and expressed his desire to speak with his mother. After three hours of questioning, the police allowed Brown to speak with his mother. The conversation between Brown and his mother was recorded and listened to by the police without their knowledge.The Superior Court heard Brown's motions to suppress the statements he made during the interrogation and the recorded conversation with his mother. Brown argued that his Fifth Amendment right against self-incrimination, his Sixth Amendment right to counsel, and his right under article 1, section 13 of the Rhode Island Constitution against self-incrimination were violated. He also argued that the surreptitious recording violated the Fourth Amendment to the United States Constitution, the Rhode Island Constitution, and constituted an unauthorized wiretap pursuant to G.L. 1956 § 11-35-21. The trial justice suppressed both the interrogation and Brown's entire conversation with his mother, determining that Brown had a reasonable expectation of privacy when he spoke to his mother in the interview room.The Supreme Court of Rhode Island affirmed the order of the Superior Court. The court concluded that Brown had a reasonable expectation of privacy when he spoke with his mother in the interview room, and that the police violated Brown's Fourth Amendment rights as well as his rights pursuant to article 1, section 6 of the Rhode Island Constitution when they recorded his conversation with his mother. The court rejected the state's arguments that Brown did not possess a reasonable expectation of privacy because he did not ask for a private, unrecorded conversation, and that he lacked a reasonable expectation of privacy in a police interrogation room. View "State v. Brown" on Justia Law