Justia Constitutional Law Opinion Summaries

David and Catherine Floam, residents of Cobb County, Georgia, sought a declaratory judgment against the Cobb County Commission, arguing that the Commission had unconstitutionally altered district boundaries that had been established by the General Assembly in 2022. The Floams argued that the Commission's amendment, which changed their voting district, exceeded the County's Home Rule powers under the Georgia Constitution. The trial court ruled in favor of the Floams, finding that the Commission's amendment did indeed exceed its Home Rule powers.On appeal, the Supreme Court of Georgia reversed the trial court's decision. The Supreme Court found that while the Floams had constitutional standing to challenge the Commission's amendment, they did not demonstrate any uncertainty regarding their future conduct that warranted declaratory relief. The court concluded that the Floams' claim was an attempt to enforce accrued rights and guide the future conduct of the defendants, which is insufficient to state a claim for declaratory relief. Therefore, the Supreme Court reversed the trial court's decision, without reaching the merits of the constitutional arguments. View "COBB COUNTY v. FLOAM" on Justia Law

The case involves James Joseph Lanpher, Jr., who pleaded guilty to two counts of aggravated assault against a law enforcement officer and admitted to being a habitual offender. The charges stemmed from a dangerous high-speed chase during which Lanpher repeatedly fired weapons at pursuing officers. The circuit court sentenced Lanpher to serve two concurrent life sentences to run consecutively to sentences he was already serving for other offenses. Lanpher appealed, claiming his sentence was cruel and unusual in violation of the Eighth Amendment and was an abuse of the circuit court’s discretion.The case was previously reviewed by the circuit court of the Third Judicial Circuit, Lake County, South Dakota. The court found Lanpher guilty and sentenced him to two concurrent life sentences, to be served consecutively to sentences he was already serving for other offenses.The Supreme Court of the State of South Dakota reviewed the case and affirmed the decision of the lower court. The court found that Lanpher's sentence did not constitute cruel and unusual punishment in violation of the Eighth Amendment. The court also found that the circuit court did not abuse its discretion in the imposition of Lanpher’s sentence. The court noted that Lanpher's violent criminal history and demonstrated disregard for human life justified the severity of his sentence. View "State v. Lanpher" on Justia Law

The case involves Damon L. Taylor, who was charged with felony murder in the adult court after the juvenile court found probable cause to believe that Taylor was complicit in a murder. The adult court convicted Taylor of felony murder, but the Tenth District Court of Appeals vacated the conviction, arguing that the adult court lacked jurisdiction to convict Taylor of felony murder as the juvenile court had not found probable cause for that specific offense. The appellate court also ruled that Taylor's statements to the police should have been suppressed as his Sixth Amendment right to counsel had been violated.The Supreme Court of Ohio disagreed with the appellate court's decision. The Supreme Court held that the adult court did have jurisdiction over the felony-murder charge against Taylor. The court reasoned that the felony-murder charge was rooted in the same acts and events as the complicity-to-commit-murder charge, which was the subject of the juvenile complaint. Therefore, under former R.C. 2151.23(H), the adult court had jurisdiction over the felony-murder charge.Regarding Taylor's Sixth Amendment right to counsel, the Supreme Court held that this right did not attach until a criminal prosecution had commenced, which occurred after the police interrogated Taylor. Therefore, the state did not violate Taylor's Sixth Amendment right to counsel when it interviewed him in the absence of his attorney. Even if the Sixth Amendment right to counsel had attached, Taylor validly waived it when he relinquished his Fifth Amendment right to counsel after he received the Miranda warnings.The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the matter to that court for further proceedings. View "State v. Taylor" on Justia Law

The case involves Tommy Kirtdoll, who was under investigation by a multijurisdictional task force in southwest Michigan for leading a drug-trafficking organization. After several undercover drug deals, the task force obtained a search warrant for Kirtdoll's house, which was described in detail in the warrant application. Upon executing the warrant, officers found drugs and distribution equipment, leading to Kirtdoll's indictment on multiple drug offenses.Kirtdoll challenged the validity of the search warrant, citing three errors: the address listed was not his, the tax identification number was incorrect, and the property owner's name was not his. He argued that these mistakes rendered the warrant unconstitutional due to lack of particularity, as required by the Fourth Amendment. The district court denied Kirtdoll's motion, ruling that the warrant's other accurate descriptors were particular enough to satisfy the Fourth Amendment. Kirtdoll pleaded guilty but reserved the right to appeal the district court's decision.The United States Court of Appeals for the Sixth Circuit reviewed the warrant's particularity de novo. The court held that the Fourth Amendment does not require perfection in search warrants, but rather enough detail for the executing officer to identify the intended place with reasonable effort. The court found that despite the errors, the warrant contained three descriptors that indisputably applied only to Kirtdoll's house and clearly identified it as the premises to be searched. These included the house's geographic location, a detailed description of the house, and a unique identifier - a red star affixed to its west side. The court concluded that the warrant for Kirtdoll's house was specific enough to meet the Fourth Amendment's particularity requirement, and thus, the district court properly denied Kirtdoll's motion to suppress. The court affirmed the district court's decision. View "United States v. Kirtdoll" on Justia Law

The plaintiff, Terri Lee Brown, was incarcerated due to an order from Governor Tina Kotek that revoked a previous conditional commutation of one of Brown's sentences. Brown had received the commutation in December 2020 from then-Governor Kate Brown and completed all her sentences by February 2023. Governor Kotek's revocation order was issued in December 2023. Brown petitioned for a writ of habeas corpus, arguing that the Governor lacked authority to revoke the commutation after she had finished serving all her sentences.In the lower courts, the state argued that the Governor had the authority to revoke Brown's commutation after her sentence had expired. The state also contended that Brown, in accepting the previous Governor's conditional commutation, had waived her right to seek habeas relief or otherwise challenge the revocation. Brown countered that the purported waiver in the acceptance agreement she signed was invalid or unenforceable.The Supreme Court of the State of Oregon concluded that when the Governor revoked Brown's conditional commutation, she lacked the authority to do so under the terms of the commutation. The court also rejected the state's argument that Brown waived her right to challenge her present imprisonment. The court found that Brown's imprisonment was unlawful and ordered her immediate release from custody. The court further waived otherwise applicable appellate rules relating to reconsideration and the issuance of the appellate judgment, directing the State Court Administrator to issue the appellate judgment immediately. View "Brown v. Kotek" on Justia Law

Lonnie Billard, a former teacher at Charlotte Catholic High School (CCHS), sued the school for sex discrimination under Title VII after he was fired for his plans to marry his same-sex partner. The district court granted Billard's motion for summary judgment and denied CCHS's motion, which raised several affirmative defenses, both statutory and constitutional.The district court found that CCHS had indeed fired Billard because of his plans to marry his same-sex partner, which amounted to sex discrimination as defined by Title VII. The court rejected CCHS's affirmative defenses, including its interpretation of Title VII's religious exemption, its defense under the Religious Freedom Restoration Act, and its First Amendment defenses. The court also ruled on the ministerial exception, despite CCHS's waiver of that defense, and found that Billard did not satisfy the criteria for the ministerial exception.On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court concluded that because Billard played a vital role as a messenger of CCHS's faith, he falls under the ministerial exception to Title VII. Therefore, the court instructed the district court to enter judgment for CCHS. View "Billard v. Charlotte Catholic High School" on Justia Law

Five registered gun owners in California challenged a state law, Assembly Bill 173 (AB 173), which permits the California Department of Justice (DOJ) to share information from its databases about firearm and ammunition purchasers and concealed carry weapon (CCW) permit holders with accredited research institutions. The plaintiffs argued that the law violated their right to informational privacy under the Fourteenth Amendment, their Second Amendment right to keep and bear arms, and the federal Privacy Act.The district court dismissed the case, finding that the plaintiffs failed to state a claim for violation of the right to informational privacy. The court reasoned that the personal information in the DOJ's databases was not highly sensitive or intimate and that the plaintiffs had no reasonable expectation that such information would never be disclosed. The court also found that AB 173 did not restrict conduct protected by the Second Amendment, as it did not impede the plaintiffs' ability to purchase, keep, carry, or use firearms. The court further held that AB 173 was not unconstitutionally retroactive, as it did not attach new legal consequences to past conduct. Finally, the court rejected the plaintiffs' claim that the Privacy Act preempted two California statutes relating to CCW permit applications, as neither statute required the disclosure of social security numbers.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision, agreeing with its findings and reasoning. The court held that the plaintiffs failed to state a claim for violation of the right to informational privacy, the Second Amendment, or the Privacy Act. View "JANE DOE V. BONTA" on Justia Law

In July 2018, Thomas Jones was observing a traffic stop conducted by two deputies outside his home. Jones interacted with the deputies, asking questions about the stop. The deputies responded by arresting Jones, using a taser in the process. Jones was convicted under a Greenville County ordinance for interfering with a county law enforcement officer. He was sentenced to thirty days in jail and a $1,000 fine, which was suspended upon ten days in jail over weekends and a $500 fine. Jones appealed his conviction, arguing that the ordinance was unconstitutionally applied to him and that the ordinance itself was unconstitutional under the First Amendment and the Due Process Clause of the United States Constitution.Jones's case was transferred to the Supreme Court of South Carolina due to the constitutional challenges he raised. The State conceded that the ordinance was improperly applied to Jones under the specific facts of the case and asked the court to reverse his conviction and sentence. The State also requested that the court not address Jones's broader challenges to the ordinance.The Supreme Court of South Carolina agreed with the State's position. The court noted that it generally declines to rule on constitutional issues unless necessary and that facial challenges to statutes are disfavored. The court found that Jones's actions of observing and asking questions were constitutionally protected conduct and could not support a conviction under the ordinance. The court was deeply disturbed by the deputies' behavior in this case but declined to go further than necessary in its ruling. The court reversed Jones's conviction on the narrow grounds that the ordinance was unconstitutionally applied to him and reserved judgment on the broader challenges to the ordinance for another case. View "State v. Jones" on Justia Law

The case revolves around Andrew Higginbotham, who was charged with sixteen counts of endangering the welfare of a child under a specific subsection of New Jersey law. This law makes it a crime to depict a child in a sexually suggestive manner for the purpose of sexual stimulation or gratification, where the depiction lacks serious literary, artistic, political, or scientific value. The charges arose from photographs Higginbotham had distributed of a five-year-old girl, over which he superimposed sexually explicit, obscene text. Higginbotham moved to dismiss the indictment, arguing that the law was unconstitutionally vague and overbroad.The trial court denied Higginbotham's motion, but the Appellate Division reversed the decision, holding that the definitions of "portray a child in a sexually suggestive manner" were unconstitutionally overbroad because they criminalized images that were neither child pornography nor obscenity. The case was then brought to the Supreme Court of New Jersey.The Supreme Court of New Jersey held that the specific subsection of the law under which Higginbotham was charged was unconstitutionally overbroad because it criminalized a large amount of material that was neither obscenity nor child pornography. The court did not reach a decision on whether the law was also unconstitutionally vague. The court did not comment on the validity of other subsections of the law, as Higginbotham was not charged under those subsections and did not challenge them. The court affirmed the Appellate Division's decision as modified and remanded the case to the trial court for further proceedings. View "State of New Jersey v. Higginbotham" on Justia Law

DC Operating, a strip club in El Paso, Texas, and two of its employees, Nuvia Medina and Michelle Corral, challenged the constitutionality of S.B. 315, a Texas law that raised the minimum age of employment at sexually-oriented businesses from 18 to 21. The law was enacted to curb human trafficking. The plaintiffs argued that the law infringed on the employees' constitutional rights to expressive interest in nude dancing and occupational freedom. They also raised a claim of sex discrimination under the Equal Protection Clause for the first time on appeal.The United States District Court for the Western District of Texas upheld the constitutionality of S.B. 315, following similar rulings in other cases. The plaintiffs then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit dismissed the appeal for lack of jurisdiction. The court found that DC Operating lacked standing to bring the appeal because it did not assert any legal interests of its own, only those of its employees. The court noted that a plaintiff must assert its own legal rights and interests and cannot rest its claim to relief on the legal rights or interests of third parties. The court also found that the overbreadth claim brought by DC Operating did not alter the standing analysis because the plaintiff still needed to satisfy Article III requirements.Furthermore, the court found that the appeal was moot as to the two employees, Medina and Corral, because they had turned 21 and were no longer subject to the law they were challenging. The plaintiffs did not argue that the employees' claims remained justiciable or that an exception to mootness applied. Therefore, the court dismissed the appeal for lack of jurisdiction. View "DC Operating v. Paxton" on Justia Law