Justia Constitutional Law Opinion Summaries

The case involves the defendant, Michael C. Hoehn, who was convicted of driving under the influence (DUI) after a motion to suppress evidence from his stop and arrest was denied by the county court. The arresting officer, Officer Matt Rockwell of the Minatare Police Department, had left his primary jurisdiction after receiving a report of a white pickup driving erratically. Rockwell observed the pickup straddling the centerline and trash coming from the driver’s-side window. After the pickup turned into oncoming traffic and down into the grass median, Rockwell stopped the vehicle and identified the driver as Hoehn. Rockwell observed Hoehn had slurred speech, bloodshot, watery eyes, and detected a strong odor of an alcoholic beverage coming from the vehicle. Rockwell administered a preliminary breath test and other field sobriety tests, which Hoehn failed, leading to his arrest for DUI.Hoehn appealed to the district court, arguing that Rockwell did not have jurisdictional authority to perform the traffic stop. The district court affirmed the conviction, interpreting Nebraska Revised Statute § 29-215(3)(c) to mean that when probable cause exists, officers have authority to perform stops and arrests outside of their primary jurisdiction that are solely related to enforcing laws that concern a person operating a motor vehicle under the influence of alcohol or drugs.Hoehn then appealed to the Nebraska Court of Appeals, which disagreed with the district court’s interpretation of § 29-215(3)(c) and found that Rockwell lacked jurisdictional authority to make the stop and arrest. However, the Court of Appeals held that under the good faith exception to the Fourth Amendment’s exclusionary rule, Hoehn’s conviction, based on the evidence from his stop and arrest, did not violate the Fourth Amendment to the U.S. Constitution and article I, § 7, of the Nebraska Constitution. Both Hoehn and the State petitioned for further review by the Nebraska Supreme Court.The Nebraska Supreme Court affirmed the decision of the Court of Appeals, albeit on different grounds. The court held that a law enforcement officer’s jurisdictional power and authority to make a stop or arrest is irrelevant to the admissibility, under the Fourth Amendment and article I, § 7, of the Nebraska Constitution, of the evidence obtained from the stop or arrest. Therefore, the county court did not err in denying Hoehn’s motion to suppress brought under the Fourth Amendment to the U.S. Constitution and article I, § 7, of the Nebraska Constitution. View "State v. Hoehn" on Justia Law

The Supreme Court of Arkansas reviewed four acts passed by the Arkansas General Assembly that were challenged by the League of Women Voters of Arkansas and other appellees. The acts in question were Acts 736, 973, 249, and 728 of 2021, which pertained to various aspects of the election process, including the verification of voter signatures on absentee ballots, the deadline for in-person delivery of absentee ballots, the requirement for voters to present valid photographic identification, and the prohibition of certain activities within 100 feet of a voting location. The circuit court had previously ruled these acts unconstitutional and permanently enjoined their enforcement.The circuit court's decision was based on the argument that the acts violated various provisions of the Arkansas Constitution and would burden lawful, eligible voters in the exercise of their right to vote. The appellants, including John Thurston in his official capacity as Secretary of State for the State of Arkansas and members of the Arkansas State Board of Election Commissioners, appealed this decision.The Supreme Court of Arkansas reversed the circuit court's decision, holding that the acts were not clearly incompatible with the sections of the Arkansas Constitution as alleged by the appellees. The court found that the acts were neutral on their face and did not contain any discriminatory classifications. The court also found that the acts did not add voter qualifications beyond those contained in the constitution, nor did they violate the free and equal election clause of the Arkansas Constitution. The court concluded that the circuit court erred in its application of strict scrutiny to the acts and in its finding that the acts violated various constitutional provisions. The court's decision resulted in the reversal and dismissal of the circuit court's ruling. View "THURSTON V. THE LEAGUE OF WOMEN VOTERS OF ARKANSAS" on Justia Law

The case involves the Consumer Financial Protection Bureau (CFPB) and its funding mechanism. The CFPB, unlike most federal agencies, has a standing source of funding outside the ordinary annual appropriations process. Congress authorized the CFPB to draw from the Federal Reserve System an amount that its Director deems “reasonably necessary to carry out” the Bureau’s duties, subject only to an inflation-adjusted cap. Several trade associations representing payday lenders and credit-access businesses challenged this funding mechanism, arguing that it violates the Appropriations Clause of the Constitution.The Fifth Circuit Court of Appeals agreed with the associations, ruling that the CFPB's funding mechanism violates the Appropriations Clause. The court reasoned that the Appropriations Clause requires both Chambers of Congress to periodically agree on an agency’s funding, which ensures that each Chamber reserves the power to unilaterally block those funding measures through inaction. The CFPB's funding mechanism, the court argued, allows it to draw funds indefinitely unless both Chambers of Congress step in and affirmatively prevent the agency from doing so.The Supreme Court of the United States, however, reversed the Fifth Circuit's decision. The Supreme Court held that Congress’ statutory authorization allowing the Bureau to draw money from the earnings of the Federal Reserve System to carry out the Bureau’s duties satisfies the Appropriations Clause. The Court reasoned that under the Appropriations Clause, an appropriation is a law that authorizes expenditures from a specified source of public money for designated purposes. The statute that provides the Bureau’s funding meets these requirements. Therefore, the Court concluded that the Bureau’s funding mechanism does not violate the Appropriations Clause. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Consumer Financial Protection Bureau v. Community Financial Services Assn. of America, Ltd." on Justia Law

The case revolves around Raymond Bailey, a probationer who signed a waiver allowing law enforcement to conduct warrantless searches of his person, residence, and vehicle. In June 2020, North Little Rock Police observed Bailey engaging in suspicious activities indicative of illegal drug transactions. They discovered that Bailey was on probation and had signed a search waiver. Upon detaining Bailey, they found a key to a motel room, which they subsequently searched, finding heroin and drug paraphernalia. Bailey was charged, but he moved to suppress the evidence, arguing that the police did not have probable cause to believe that the motel room was his residence.The Pulaski County Circuit Court granted Bailey's motion to suppress, ruling that law enforcement must have probable cause to believe that the place to be searched is the probationer's residence. The court found that the police did not have probable cause to believe that the motel room was Bailey's residence, and therefore, the warrantless search violated the Fourth Amendment. The State of Arkansas appealed this decision.The Supreme Court of Arkansas disagreed with the lower court's ruling. The Supreme Court held that the correct legal standard requires law enforcement to have a reasonable suspicion, based on the totality of the circumstances, to believe the place to be searched is the probationer's residence if conducting a search under that provision. The court found that the police had a reasonable suspicion that Bailey was residing in the motel room, making the search permissible under the statute and consistent with the Fourth Amendment. Therefore, the Supreme Court reversed the decision to suppress the evidence and remanded the case back to the circuit court. View "STATE OF ARKANSAS v. BAILEY" on Justia Law

The Supreme Court of Arkansas reviewed a case involving four acts passed by the Arkansas General Assembly concerning the election process. The League of Women Voters of Arkansas and other appellees challenged the constitutionality of these acts, which were subsequently deemed unconstitutional by the circuit court and permanently enjoined. The appellants, including John Thurston in his official capacity as Secretary of State for the State of Arkansas and members of the Arkansas State Board of Election Commissioners, appealed this decision.The circuit court had ruled that the acts violated various provisions of the Arkansas Constitution and would burden lawful, eligible voters in the exercise of their right to vote. The appellants argued that the acts were enacted to protect the integrity of Arkansas elections by preventing fraudulent voting and to promote public confidence in election security. The circuit court applied strict scrutiny to the acts, finding that they failed to advance a compelling government interest or were not the least-restrictive infringement on the rights guaranteed by the Arkansas Constitution.The Supreme Court of Arkansas reversed the circuit court's decision, holding that the acts were not clearly incompatible with the sections of the Arkansas Constitution as alleged by the appellees. The court found that the acts were neutral on their face and did not contain any discriminatory classes, thus not invoking equal protection. The court also found that the acts did not violate the free and equal election clause, the voter qualifications clause, or the free speech and free assembly clauses of the Arkansas Constitution. The court concluded that the circuit court had erred in its application of strict scrutiny and in its findings that the acts violated these constitutional provisions. The case was dismissed. View "THURSTON V. THE LEAGUE OF WOMEN VOTERS OF ARKANSAS" on Justia Law

Eight men convicted of sexual offenses between 1982 and 1994 challenged the constitutionality of the 2004 Tennessee Sexual Offender and Violent Sexual Offender Registration, Verification, and Tracking Act (“the Act”) and its subsequent amendments. The Act required them to comply with various reporting requirements and geographical restrictions imposed on all sex offenders. The plaintiffs argued that the laws violated the Constitution’s Ex Post Facto Clause.The United States District Court for the Middle District of Tennessee agreed with the plaintiffs and issued an injunction prohibiting Governor Lee and Director Rausch from enforcing the entire Tennessee code against the plaintiffs. The court also issued a declaratory judgment against unnamed parties who might also enforce the Act.The case was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court disagreed with the district court's decision. The court found that the plaintiffs lacked standing to sue Governor Lee and ordered the lower court to dismiss him from the suit. The court also found that the district court's injunction was overly broad and unjustified. The appellate court reversed in part the district court’s judgment that the Act violates the Ex Post Facto Clause and remanded the case with orders to vacate the declaratory judgment, dissolve the injunction against Governor Lee, dismiss Governor Lee from the suit based on a lack of standing, and to modify the injunction against Director Rausch consistent with its opinion. View "John Doe #1 v. Lee" on Justia Law

A group of parents in Montgomery County, Maryland, challenged the local school board's decision to include LGBTQ-inclusive books in the English Language Arts curriculum without providing parents notice or the option to opt their children out of exposure to these books. The parents, who held various religious beliefs, argued that the board's decision violated their rights under the Free Exercise and Due Process Clauses of the U.S. Constitution.The United States District Court for the District of Maryland denied the parents' motion for a preliminary injunction, which would have required the board to provide notice and an opt-out option. The parents appealed this decision to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit affirmed the district court's decision. The court found that the parents had not shown a likelihood of success on the merits of their claims, a necessary requirement for a preliminary injunction. Specifically, the court found that the parents had not provided sufficient evidence to show that the board's decision coerced them or their children to act or believe contrary to their religious faith. The court also found that the parents had not shown that their due process rights were likely to be violated. The court noted that the parents still had the right to instruct their children on their religious beliefs and to discuss the topics raised in the books with their children. View "Mahmoud v. McKnight" on Justia Law

Chamma K. Brandon, an inmate in the custody of the New York State Department of Corrections and Community Supervision, filed a lawsuit against three prison officials. Brandon alleged that the officials violated his First Amendment right to the free exercise of religion by denying him a special meal in celebration of Eid al-Adha. He also claimed that one of the officials, Mark Royce, violated his Eighth Amendment right to be free from cruel and unusual punishment by ordering that his housing block be constantly illuminated.The United States District Court for the Southern District of New York granted the defendants' motion for summary judgment on Brandon's First Amendment claim and denied Brandon's request to reopen discovery for a second time to permit expert testimony on his Eighth Amendment claim. Following a trial, a jury found that Royce had not violated Brandon's Eighth Amendment right.On appeal, the United States Court of Appeals for the Second Circuit agreed with Brandon that the district court erred in granting summary judgment to the defendants on his First Amendment claim. The court found that there was a genuine dispute of material fact regarding whether Brandon had an alternative means of exercising his right to the free exercise of religion. The court also found that the penological concerns raised by the defendants did not support granting judgment as a matter of law in their favor. However, the court found no error in the district court's denial of Brandon's motion to reopen discovery. The court therefore vacated in part and affirmed in part the district court's decision. View "Brandon v. Royce" on Justia Law

The defendant, William Jerome Carnes, was arrested on suspicion of driving under the influence of alcohol or drugs. He was charged with felony DUI for a fourth or subsequent offense, misdemeanor resisting arrest, and misdemeanor driving without a valid liability insurance policy in effect. Carnes failed to appear for his final pretrial conference, leading to an arrest warrant being issued. He was later arrested in Nevada for fleeing the scene of an accident and was sentenced to 24 to 72 months in the Nevada Department of Corrections.Carnes filed a pro se motion for a speedy trial or dismissal for lack of speedy trial and timely prosecution, citing the Sixth Amendment to the United States Constitution and Nevada Revised Statutes. The State argued that Carnes did not follow procedure as contemplated by statute to make a request for final disposition. The District Court agreed with the State and denied Carnes’s motion. Carnes then filed a motion to dismiss the case for the State’s failure to comply with the Interstate Agreement on Detainers, which was also denied by the District Court.In the Supreme Court of the State of Montana, Carnes appealed the order denying his motion to dismiss and the subsequent judgment on his plea of guilty to an amended charge of criminal endangerment pursuant to a plea agreement with the State. The court concluded that Carnes failed to preserve his right to appeal the District Court’s denial of his motion to dismiss. The court held that a defendant who voluntarily and knowingly pleads guilty to an offense waives all non-jurisdictional defects and defenses, including claims of constitutional rights violations which occurred prior to the plea. The court found that Carnes’s plea agreement contained no language reserving the right to appeal after his guilty plea and he did not comply with the statutory requirements to reserve the right to appellate review of the adverse pretrial ruling. Therefore, the judgment of the District Court was affirmed. View "State v. Carnes" on Justia Law

The case involves the Jibril family, who alleged that they were wrongfully placed on the U.S. Government’s terrorist watchlist, known as the "Selectee List." The family claimed that this placement resulted in extensive and intrusive security screenings and significant delays during their domestic and international travels. They filed a lawsuit against the Secretary of the Department of Homeland Security and other federal officials, alleging violations of the Fourth and Fifth Amendments and the Administrative Procedure Act.The District Court initially dismissed the case for lack of standing, as the Government neither confirmed nor denied the Jibrils’ Selectee List status. The Court of Appeals reversed this decision in part, holding that the Jibrils had plausibly alleged that they were on a terrorist watchlist and faced imminent risk of undue Government actions sufficient to support most of their claims for prospective relief.On remand, the Government filed a renewed motion to dismiss, this time submitting an ex parte declaration to the District Court for in camera review. Based on this submission, the District Court again dismissed the case, holding that the Jibrils lacked standing to pursue their complaint for prospective relief.The Court of Appeals affirmed the District Court's decision, agreeing that the Jibrils lacked standing to seek forward-looking relief. The court also held that the District Court did not abuse its discretion in relying on the Government’s ex parte submission to address matters implicating national security concerns. Finally, the court found no error in the District Court’s denial of the Jibrils’ motion for leave to amend their complaint. View "Jibril v. Mayorkas" on Justia Law