Justia Constitutional Law Opinion Summaries

A U.S. citizen, Maalik Alim Jones, pleaded guilty to terrorism-related charges for his involvement with al-Shabaab, an Islamist military organization in Kenya and Somalia. The district court accepted his plea and sentenced him to 25 years of imprisonment. Jones challenged his plea agreement and sentence, arguing that a prior mandate of the court precluded the government from charging him in a superseding indictment, that the language of his plea agreement was ambiguous and inapplicable to him, and that his sentence was based on erroneous factual findings and constitutionally impermissible factors.Jones was initially indicted on five counts related to his support and training with al-Shabaab. He later consented to a superseding information, which reduced the charges to three counts. Jones pleaded guilty to these charges and was sentenced to 35 years of imprisonment. However, following a Supreme Court ruling that found a section of the law under which Jones was charged to be unconstitutionally vague, Jones appealed his conviction on one of the counts. The court vacated this conviction and remanded for resentencing on the remaining counts. On remand, the district court denied the government's motion to reinstate the initial indictment but did not preclude the government from seeking a superseding indictment. The government subsequently filed a superseding indictment, which Jones moved to dismiss.The United States Court of Appeals for the Second Circuit rejected Jones's arguments and affirmed the judgment of the district court. The court found that the mandate did not preclude a superseding indictment, and that the plea agreement unambiguously allowed for new charges if a conviction was vacated. The court also found that Jones's sentence was not based on erroneous factual findings or constitutionally impermissible factors, and that his challenges were barred by the appeal waiver in the plea agreement. View "United States v. Jones" on Justia Law

The case involves a challenge to the provisions of the Bipartisan Safer Communities Act of 2022, which expanded background checks for firearm purchases by individuals aged 18 to 20. The plaintiffs, Ethan McRorey, Kaylee Flores, Gun Owners of America, Inc., and Gun Owners Foundation, argued that the government failed to show a historical analogue for the Act's expanded background checks for this age group. They filed a lawsuit requesting a preliminary injunction after their attempts to purchase shotguns were delayed due to the National Instant Criminal Background Check System (NICS) protocols.The United States District Court for the Northern District of Texas denied the plaintiffs' request for a preliminary injunction. The court reasoned that while adults aged 18 to 20 are protected by the Second Amendment, laws barring the mentally ill and felons from possessing firearms are constitutional, and restrictions to further those ends are presumptively lawful. Therefore, the plaintiffs lacked a substantial likelihood of success on the merits and were not entitled to preliminary relief.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The appellate court held that background checks preceding firearm sales are presumptively constitutional, and the plaintiffs failed to rebut that presumption. The court also found that the plaintiffs had not shown that the challenged regulations had been put towards abusive ends or had otherwise rebutted the presumption of lawfulness. The court concluded that a period of 10 days for background checks does not qualify as being put towards abusive ends or as a de facto prohibition on possession. View "McRorey v. Garland" on Justia Law

The case involves a medical student at Indiana University–Purdue University Indianapolis, referred to as John Doe, who was accused of physical abuse by a fellow student, Jane Roe. The University’s Office of Student Conduct found Doe culpable and suspended him for one year. Doe applied to the University’s MBA program and described his suspension as an exoneration. This led to an investigation by the University’s Prior Misconduct Review Committee, which concluded that Doe had withheld pertinent information and gave false or incomplete information to the business school. Dean Hess of the medical school, without inviting further response from Doe, expelled him from the medical school. Doe accused the University of violating both the Due Process Clause of the Constitution’s Fourteenth Amendment and Title IX of the Education Amendments Act of 1972.The district court granted summary judgment to the defendants. The court found that the record did not support an inference of sex discrimination. The court also found that the University’s delay in launching an investigation into Doe’s complaint that Roe hit him on occasion did not contribute to the ultimate decision, and it was justified by the fact that Doe elected not to pursue this charge against Roe.The United States Court of Appeals for the Seventh Circuit found that Doe’s constitutional argument was stronger. The court held that Doe had a legitimate claim of entitlement to remain a student unless he transgressed a norm, which is a property interest in constitutional lingo and requires some kind of hearing. The court vacated the judgment and remanded the case to the district court. If Doe elects to continue with the suit, his true name must be disclosed to the public, and the district court must decide what remedy is appropriate for Dean Hess’s failure to allow Doe an opportunity to present his position before expelling him. If Doe elects not to reveal his name, the complaint must be dismissed. View "Doe v. Trustees of Indiana University" on Justia Law

A group of plaintiffs, including former members of the Montana Board of Regents, faculty organizations, student groups, and individual students, challenged the constitutionality of three bills passed by the Montana Legislature in 2021. The bills in question were HB 349, which regulated student organizations and speech on campus; HB 112, known as the "Save Women's Sports Act," which required sports teams to be designated as male, female, or coed based on biological sex; and § 2 of SB 319, which revised campaign finance laws and regulated the funding of certain student organizations. The plaintiffs argued that these bills infringed on the constitutional authority of the Board of Regents to supervise, coordinate, manage, and control the Montana University System.The District Court of the Eighteenth Judicial District, Gallatin County, granted the plaintiffs' motion for summary judgment, declaring HB 349, HB 112, and § 2 of SB 319 unconstitutional. The court also denied the plaintiffs' request for attorney fees. Both parties appealed this order.The Supreme Court of the State of Montana affirmed the District Court's decision. The court found that the plaintiffs had standing to bring their claims and that the challenged bills were unconstitutional. The court also upheld the District Court's denial of the plaintiffs' request for attorney fees, as the justices could not reach a majority opinion on this issue. View "Barrett v. State" on Justia Law

In 2021, the Colorado state legislature passed The Ballot Measure Fiscal Transparency Act, which required certain language to be included in state-imposed titles of citizen-initiated ballot measures. If the proposal contained a tax change affecting state or local revenues, the measure’s title had to incorporate a phrase stating the change’s impact on state and district funding priorities. In 2023, Advance Colorado proposed two tax reduction measures subject to the provisions of the Act. After Colorado’s Ballot Title Setting Board included the mandated transparency language in each initiative’s title, Advance Colorado filed suit challenging the Act as unconstitutionally compelling its political speech.The United States District Court for the District of Colorado denied Advance Colorado's request for a preliminary injunction, concluding that the titling process qualified as government speech and, therefore, Advance Colorado was not likely to succeed on the merits of its claims. The court considered the factors used for determining the boundary between government and private speech as outlined in Shurtleff v. City of Bos., 596 U.S. 243, 252 (2022). It concluded that the history of the expression, the public’s likely perception as to who is speaking, and the extent to which the government has shaped the expression all indicated Colorado’s titling system was government speech not subject to a First Amendment compelled speech claim.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision, agreeing that the Act’s requirements did not result in improperly compelled speech under the First Amendment of the United States Constitution. The court found that the Colorado initiative titling system squarely qualified as government speech and Advance Colorado had not otherwise shown its own speech was improperly compelled by the government speech. Therefore, it could not demonstrate a substantial likelihood of success on the merits of its claims. View "Advance Colorado v. Griswold" on Justia Law

In 2020, Luke Hogan, a graduate student at Southern Methodist University (SMU), found his final semester disrupted by the COVID-19 pandemic. Like many institutions, SMU shifted to online classes in response to government lockdown orders. Hogan, feeling cheated out of the in-person educational experience he had paid for, sued SMU for breach of contract. He sought a refund of his tuition and fees, arguing that the shift to online learning constituted a breach of SMU's promise of in-person education.The federal district court sided with SMU, and Hogan appealed. The Fifth Circuit then certified a question to the Supreme Court of Texas: Does the application of the Pandemic Liability Protection Act (PLPA) to Hogan’s breach-of-contract claim violate the retroactivity clause in article I, section 16 of the Texas Constitution? The PLPA, enacted in 2021, protects schools from monetary liability for altering their activities in response to the pandemic.The Supreme Court of Texas held that the application of the PLPA to Hogan's claim does not violate the Texas Constitution's prohibition on retroactive laws. The court reasoned that Hogan did not have a settled expectation of recovering damages from SMU under these circumstances. The court noted that the common law has traditionally excused a party from performing a contract when performance is rendered impossible by an act of God or government. The court also pointed out that Hogan voluntarily accepted SMU's offer to complete his degree online without a corresponding offer of tuition refunds or reduced fees. Therefore, any right of recovery that might have existed for Hogan was speculative and untested prior to the PLPA's enactment. The court concluded that the PLPA, enacted to resolve legal uncertainty created by the pandemic, did not upset Hogan's settled expectations and thus did not violate the constitutional prohibition on retroactive laws. View "HOGAN v. SOUTHERN METHODIST UNIVERSITY" on Justia Law

The case involves successors in interest of mineral-rights holders who sued in 2019 to declare a 1999 judgment foreclosing on their predecessors’ property for delinquent taxes as void. They argued that there was constitutionally inadequate notice of the foreclosure suit, rendering the foreclosure judgment and the tax sale that followed both void. The current owners sought traditional summary judgment based on the Tax Code’s command that an action relating to the title to property against the purchaser of the property at a tax sale may not be commenced later than one year after the date that the deed executed to the purchaser at the tax sale is filed of record.The trial court granted the current owners' motion for summary judgment, and the court of appeals affirmed. The majority held that the sheriff’s deed conclusively established the accrual date for limitations, so the burden shifted to the successors to adduce evidence raising a genuine issue of material fact as to whether there was a due-process violation that could render the statute of limitations inoperable. Because the successors relied only on their arguments and presented no evidence of a due-process violation, the majority concluded, the current owners were entitled to summary judgment.The Supreme Court of Texas held that under Draughon v. Johnson, the nonmovant seeking to avoid the limitations bar by raising a due-process challenge bears the burden to adduce evidence raising a genuine issue of material fact about whether the underlying judgment is actually void for lack of due process. Because the nonmovant here adduced no such evidence, the trial court correctly granted summary judgment based on Section 33.54(a)(1). However, the court also noted that the law governing this case has undergone meaningful refinement since the summary-judgment proceedings took place. Given these recent and substantial developments in the relevant law, the court remanded this case to the trial court for further proceedings in the interest of justice. View "GILL v. HILL" on Justia Law

The case revolves around Dylan Ostrum, who was under investigation for drug dealing and possession of firearms. During a search of his home, Ostrum revealed that he had moved his belongings, including his car, to his father's house. However, the car, which was reported stolen by a rental company, was found nearby with Ostrum's belongings inside, including a gun, methamphetamine, and marijuana, all stashed in two safes. The key issues on appeal were whether Ostrum had standing to challenge the search of the stolen car and whether the search violated his Fourth Amendment rights.The investigation into Ostrum began after law enforcement agents found text messages between him and another individual, Ricky Blythe, showing that they repeatedly sold each other methamphetamine and marijuana. Based on this evidence and information from confidential informants, law enforcement obtained a valid warrant to search Ostrum’s residence. However, the search turned up little, and Ostrum informed the officers that he had moved his belongings to his father's house. The officers later located the car, which was reported stolen, and discovered the safes inside.Ostrum was charged with multiple counts related to drug possession and distribution, and being a felon in possession of a firearm. He moved to suppress the evidence found inside the car, arguing that it was the fruit of an illegal search. The district court denied the motion, finding that Ostrum lacked standing to challenge the search because the car was stolen, and that the search was valid under the automobile exception to the Fourth Amendment’s warrant requirement. Ostrum was convicted on all counts and received a 240-month sentence.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Ostrum failed to meet his burden on standing and that the existence of probable cause justified the search under the automobile exception to the Fourth Amendment’s warrant requirement. The court concluded that Ostrum had no reasonable expectation of privacy in the stolen car or its contents, and thus no standing to object to its search. View "USA v. Ostrum" on Justia Law

The case revolves around a defendant, Cid Franklin, who was arrested following a road rage incident that involved a firearm. The police searched the basement of Franklin's home, which he shared with his son and stepmother, and found a gun in a closet containing items belonging to both Franklin and his stepmother. Franklin was interviewed by an employee of the Criminal Justice Agency (CJA) while in Queens central booking prior to arraignment. The CJA employee recorded Franklin's address as the basement of his home. This information was central to the prosecution's case at trial, as no DNA or fingerprints were discernable on the gun, and no other direct proof was provided that Franklin lived in the basement.The trial court admitted the CJA form as either "a public document" or "a business record," rejecting the defense's objections that it was hearsay and violated Franklin's Sixth Amendment right of confrontation. Franklin was convicted of one count of second-degree criminal possession of a weapon. The Appellate Division reversed the decision, holding that the introduction of the report violated Franklin's Confrontation Clause rights.The Court of Appeals of New York, however, reversed the Appellate Division's decision. The court held that the primary purpose of the CJA interview report was administrative, not to create an out-of-court substitute for trial testimony, and thus it was not testimonial. The court noted that the CJA report was introduced as a business or public record, and the pedigree information collected, including the defendant's address, was pertinent to establishing community ties; it was only incidentally relevant in this case. Therefore, the introduction of the CJA interview report did not violate the defendant's right of confrontation. The case was remitted to the Appellate Division for consideration of the facts and issues raised but not determined on appeal to that Court. View "People v Franklin" on Justia Law

The Ute Indian Tribe of the Uintah and Ouray Indian Reservation brought a suit against the United States, alleging various claims concerning water rights and water-related infrastructure. The Tribe claimed that the United States breached duties of trust by mismanaging water rights and infrastructure held by the United States and operated for the Tribe, breached contracts with the Tribe, and effected unconstitutional takings of the Tribe’s property. The Claims Court dismissed all the breach of trust claims, held that one breach of contract claim was barred by a 2012 settlement agreement, and found the remaining breach of contract and takings claims time barred.The United States Court of Appeals for the Federal Circuit affirmed in part and vacated and remanded in part the Claims Court's decision. The Court of Appeals held that the Winters doctrine and the 1899 Act did not sufficiently establish trust duties to support Indian Tucker Act jurisdiction with respect to the Tribe’s claims that the United States has a duty to construct new infrastructure and secure new water for the Tribe. However, the Court found that the 1906 Act imposes trust duties on the United States sufficient to support a claim at least with respect to management of existing water infrastructure. The Court also affirmed the dismissal of one breach of contract claim, vacated and remanded another, and affirmed the dismissal of the takings claims. View "UTE INDIAN TRIBE OF THE UINTAH & OURAY INDIAN RESERVATION v. US" on Justia Law