Justia Constitutional Law Opinion Summaries

Milder Escobar-Temal, a Guatemalan national, unlawfully entered the United States in 2012, living and working in Nashville, Tennessee. In October 2022, Nashville police responding to a domestic incident found three firearms at his residence. He was charged with unlawful possession of a firearm under 18 U.S.C. § 922(g)(5)(A), which prohibits possession of firearms by individuals unlawfully present in the United States. Escobar-Temal had no prior criminal convictions except a dismissed charge for driving without a license.The United States District Court for the Middle District of Tennessee denied Escobar-Temal’s motion to dismiss the indictment, in which he argued that § 922(g)(5)(A) violated the Second Amendment both facially and as applied. The district court reasoned that, while the Second Amendment’s protections may extend to unlawfully present persons, historical tradition supported disarming those who had not sworn allegiance to the state. After denying the motion, Escobar-Temal pleaded guilty but reserved the right to appeal the constitutional issue.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The Sixth Circuit held that the Second Amendment does protect individuals unlawfully present in the United States if they have developed sufficient connections to the national community. However, it further held that there is a longstanding historical tradition of disarming groups lacking a formal relationship with the government, such as unlawfully present noncitizens, due to regulatory difficulties rather than inherent dangerousness. Therefore, the court concluded that § 922(g)(5)(A) does not violate the Second Amendment, either on its face or as applied to Escobar-Temal, and affirmed his conviction and sentence. View "United States v. Escobar-Temal" on Justia Law

Police in Wilmington, Delaware, were monitoring social media when a detective saw a video on Instagram that appeared to show Marvin Swanson, a person legally prohibited from possessing firearms, mimicking shooting motions and possibly displaying what looked like a gun magazine in his waistband. Shortly after, a confidential informant, known to be reliable, sent the detective the same video and claimed to have personally observed Swanson in the area with a firearm. The police responded to the location, saw Swanson in the described clothing, conducted a pat down that did not reveal a weapon, but found a loaded handgun in a recycling bin about 25–30 feet away. Swanson was handcuffed and transported to the police station, where he voluntarily provided a DNA sample. DNA testing later matched Swanson to the gun, leading to his arrest for possession of a firearm and ammunition by a person prohibited.The Superior Court of the State of Delaware denied Swanson’s motion to suppress the DNA evidence, finding that officers had reasonable suspicion for the initial stop and that the continued detention and transport to the station were reasonable, necessary, and related to the investigation. A jury later convicted Swanson.On appeal, the Supreme Court of the State of Delaware found that while the officers had reasonable suspicion for the initial stop based on the informant’s tip and corroborating observations, the subsequent transport of Swanson to the police station amounted to a de facto arrest. The Court held that this arrest was not supported by probable cause because the evidence linking Swanson to the gun was insufficient at the time of the arrest. As a result, the Court reversed the judgment of the Superior Court, holding that the motion to suppress should have been granted. View "Swanson v. State" on Justia Law

Police investigating a fatal drive-by shooting in Philadelphia identified several suspects, including T.C., and obtained an arrest warrant for him. Detectives used multiple databases, including CLEAR and police records, to determine T.C.’s last known address, which pointed to 4838 Stenton Avenue. Believing T.C. resided there, detectives and a SWAT team executed the warrant early one morning. Instead of finding T.C., officers encountered Richard Miller and Tonya Crawley, who had lived at the residence for two years and were not connected to T.C. The officers detained Miller and Crawley briefly and then left after learning T.C. was not present. T.C. was later located and cleared of wrongdoing.Miller and Crawley sued the involved officers and the City of Philadelphia in the United States District Court for the Eastern District of Pennsylvania under 42 U.S.C. § 1983, alleging that the officers lacked probable cause and violated the Fourth Amendment, and that the City failed to train or supervise its officers. The District Court dismissed the municipal-liability claim for failure to state a claim and granted summary judgment to the officers on the unlawful-entry claim, holding that they had probable cause to enter the residence.On appeal, the United States Court of Appeals for the Third Circuit reviewed both the dismissal and summary judgment de novo. The court held that, although the District Court incorrectly invoked the good-faith exception, the error was harmless because the officers had probable cause to believe T.C. lived at the address and would likely be home at the early hour. The court also held that the plaintiffs failed to allege facts sufficient to establish municipal liability, as there was no pattern of similar constitutional violations or plausible basis for single-incident liability. The Third Circuit affirmed the District Court’s decisions. View "Miller v. City of Philadelphia" on Justia Law

A federal grand jury charged the defendant with possessing methamphetamine with intent to distribute and being a felon in possession of a firearm. Task force officers at a bus station in Omaha, Nebraska identified the defendant’s suitcase as suspicious and removed it from the bus’s luggage compartment. After the defendant claimed and approached his bag, an officer questioned him about his travel plans and requested permission to search the suitcase, which the defendant consented to. The defendant then fled, prompting officers to detain him and search his belongings, ultimately discovering firearms and controlled substances.The defendant moved to suppress the evidence obtained from his suitcase, backpack, and person, arguing that the officers’ actions constituted unlawful searches and seizures under the Fourth Amendment. A magistrate judge recommended denying the suppression motion, concluding that the suitcase was not seized, the initial encounter was consensual, the consent to search was valid, and reasonable suspicion supported the later detention. The United States District Court for the District of Nebraska adopted the recommendation and denied the motion to suppress. At trial, a jury acquitted the defendant of possession with intent to distribute but found him guilty of simple possession and the firearms offense. The district court imposed consecutive sentences totaling 144 months’ imprisonment and a $2,500 fine, the latter without findings about the defendant’s ability to pay.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of the suppression motion, holding there was no Fourth Amendment seizure of the suitcase, the initial encounter was consensual, the defendant’s consent to search was voluntary, and reasonable suspicion justified the post-flight detention. The court also affirmed the custodial sentence as substantively reasonable but vacated the fine, remanding for proper findings on the defendant’s ability to pay. View "United States v. Clay" on Justia Law

Congress enacted a law in 2025 that withholds Medicaid funding for one year from certain abortion providers that meet four criteria, which in effect covers most Planned Parenthood affiliates and two other organizations. The statute also withholds funding from subsidiaries, successors, clinics, and “affiliates” of such entities, even if those affiliates do not themselves meet all four criteria. Some Planned Parenthood entities qualified for defunding under the law (“Qualifying Members”), while others did not (“Non-Qualifying Members”), but the latter still risked losing funding due to the ambiguous “affiliate” provision. Concerned about the impact on their ability to provide healthcare, Planned Parenthood Federation of America, a Qualifying Member, and a Non-Qualifying Member sued to enjoin enforcement, alleging the law was an unconstitutional bill of attainder, imposed unconstitutional conditions on their right of association, and violated equal protection.The United States District Court for the District of Massachusetts granted a temporary restraining order and then preliminary injunctions, finding that the plaintiffs were likely to succeed on all three claims. The court reasoned that the law punished Planned Parenthood in violation of the Bill of Attainder Clause, impermissibly conditioned Medicaid funding on disassociation from other affiliates in violation of the First Amendment, and failed equal protection review because it targeted Planned Parenthood for its associations. The government appealed these orders.The United States Court of Appeals for the First Circuit vacated the district court’s orders. The court held that the statute did not inflict punishment as understood in bill of attainder case law, but instead established new conditions prospectively on Medicaid funding. The court also held that the “affiliate” provision is best read to cover only entities under common corporate control, avoiding constitutional problems, and thus does not burden associational rights. Finally, the court found that the law is subject only to rational basis review and is rationally related to Congress’s objectives. The preliminary injunctions were vacated and the case remanded. View "Planned Parenthood Federation of America, Inc. v. Kennedy" on Justia Law

In March 1997, James Garrey was involved in a fatal altercation at a bar in Franklin, Massachusetts, where he stabbed and killed Corey Skog following a dispute. Garrey, who is white, was later convicted of first-degree murder by a Massachusetts jury and sentenced to life imprisonment. During jury selection, the prosecution exercised a peremptory strike to remove a minority-race juror, Juror 6-7. Garrey objected, arguing the strike was improper and motivated by race, referencing Batson v. Kentucky and Powers v. Ohio. The trial judge allowed the strike after the prosecutor cited the juror’s occupation as a guidance counselor as the reason, not her race.Garrey appealed his conviction to the Massachusetts Supreme Judicial Court (SJC), asserting that the trial judge erred by accepting the prosecutor’s justification and by referencing the lack of minority participants in the trial. The SJC affirmed the conviction, finding the prosecutor’s explanation sufficient and not pretextual, and that the trial judge did not improperly rely on racial considerations. Garrey’s subsequent motions for a new trial in state court were denied.He then petitioned the United States District Court for the District of Massachusetts for habeas corpus relief under 28 U.S.C. § 2254, alleging Batson and Powers errors and unreasonable factual findings by the SJC. The District Court denied relief, concluding the SJC’s application of federal law and findings were not unreasonable.On appeal, the United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the District Court. The First Circuit held that the SJC did not unreasonably determine the facts or misapply clearly established federal law under Batson or Powers, and found the prosecutor’s rationale and the trial court’s process constitutionally sufficient. The judgment denying habeas relief was affirmed. View "Garrey v. Kelly" on Justia Law

After entering a no contest plea to charges including willful infliction of corporal injury and dissuading a witness, the petitioner was sentenced to four years’ probation and 60 days in county jail. She was referred to a work release program in lieu of serving her jail time. While participating, she discovered she was pregnant and could not complete her work assignment due to morning sickness. After providing proof of her pregnancy, the sheriff advised her not to return to the worksite because no light duty was available, and her case was sent back to the trial court for further action.The Contra Costa County Superior Court later considered her situation. At a hearing, the court found that she had not willfully violated the terms of the work release program but concluded that the alternative sentence was no longer feasible. The court ordered her to serve the remainder of her jail term in custody, denying her requests for re-referral to the program or a delayed surrender. The petitioner subsequently filed a habeas corpus petition with the California Court of Appeal, First Appellate District, Division Three, asserting that her due process rights had been violated.The California Court of Appeal, First Appellate District, Division Three, held that individuals enrolled in work release programs in lieu of jail time possess a conditional liberty interest that cannot be revoked without due process. The court found that the trial court’s decision to remand the petitioner into custody was based on a factual finding—her unfitness for the program—that was unsupported by the evidence. As a result, the appellate court reversed the trial court’s order and remanded the matter with instructions to re-refer the petitioner to the work release program to complete any remaining days owed. View "In re Riley" on Justia Law

A man was apprehended after leading police on a high-speed chase in a stolen vehicle. When the vehicle was stopped, law enforcement found an AR-style firearm with an overall length of less than 30 inches on the passenger-side floorboard. The man was charged with several offenses, including driving or taking a vehicle without consent, fleeing a police officer while driving recklessly, possession of a firearm by a felon, and possession of an assault weapon. The information also alleged several aggravating factors related to his criminal history and conduct.In Contra Costa County Superior Court, a jury found the defendant guilty of all charges except receiving a stolen vehicle. The court, after a hearing, found true several aggravating factors and sentenced him to three years and four months, including concurrent terms for some offenses. The sentence for possession of an assault weapon was stayed under Penal Code section 654.The California Court of Appeal, First Appellate District, Division Five, reviewed three issues raised by the defendant: whether California’s ban on assault weapon possession violated the Second Amendment; whether sentences for taking a vehicle without consent and fleeing an officer should have been stayed as based on the same act; and whether the abstract of judgment accurately reflected custody credits. The court held that Penal Code section 30605 does not violate the Second Amendment because there was no evidence in the record that assault weapons covered by the statute are in common use by law-abiding citizens, as required by relevant Supreme Court precedent. The court also held that the two vehicle-related offenses involved separate criminal objectives and thus did not require a stay under section 654. However, the court agreed that the custody credits were miscalculated and directed the trial court to correct the abstract of judgment accordingly. The judgment was otherwise affirmed. View "People v. Crenshaw" on Justia Law

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

During a traffic stop in Hidalgo County, Texas, a sheriff’s deputy pulled over Gerardo Villarreal for driving with a partially obscured license plate. The deputy discovered Villarreal did not have a driver’s license or insurance. After a canine sniff alerted to an item in the vehicle, officers searched the car, finding a handgun and a small amount of cocaine. Villarreal was later indicted for being a felon in possession of a firearm under federal law. He moved to suppress the handgun as evidence, arguing the search violated his Fourth Amendment rights.The United States District Court for the Southern District of Texas held a hearing on the motion to suppress. The court heard testimony from the arresting deputy, who explained that department policy generally required impounding vehicles when the driver lacked a license or insurance, with certain exceptions. The deputy testified he would have impounded Villarreal’s vehicle and performed an inventory search, which would have revealed the handgun. Villarreal attempted to impeach this testimony, referencing another incident where the deputy did not impound a vehicle under similar circumstances, but the deputy explained possible exceptions. The district court found the deputy credible and denied the motion to suppress, applying the inevitable-discovery doctrine.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Fifth Circuit held that the inevitable-discovery doctrine applied because the government showed by a preponderance of the evidence that an inventory search, conducted pursuant to standard department policy, would have discovered the handgun. The court found that the impounding and inventory search were imminent before any alleged misconduct, and the department’s policy sufficiently limited officer discretion. The Fifth Circuit affirmed the district court’s judgment, upholding denial of the motion to suppress. View "USA v. Villarreal" on Justia Law