Justia Constitutional Law Opinion Summaries

Benjamin Tariri was charged with multiple counts of embezzlement and larceny, allegedly misappropriating nearly $2 million from clients while working as an attorney. He was arrested at Logan International Airport attempting to board a one-way flight to Iran, where he had recently spent six months. Tariri had longstanding ties to the United States but also significant connections to Iran. After his arraignment in the Boston Municipal Court, he was released on cash bail and required to submit to GPS monitoring with an inclusion zone restricting his movements to certain areas, primarily to mitigate his risk of flight.Following indictment and arraignment in the Superior Court, the bail and GPS conditions were maintained, with the inclusion zone expanded to cover additional areas. Tariri moved to modify or vacate the GPS condition, arguing that it hindered his ability to work and prevented him from visiting his wife and child in East Boston. The motion judge expanded the inclusion zone to address employment concerns but otherwise denied further relief. Tariri then filed a petition under G. L. c. 211, § 3, in the county court, which a single justice denied, finding no abuse of discretion or error of law in the trial court’s order.The Supreme Judicial Court of Massachusetts reviewed the single justice’s denial for clear error of law or abuse of discretion. The court held that GPS monitoring with an inclusion zone, imposed as a condition of pretrial release, was a reasonable and constitutional search under art. 14 of the Massachusetts Declaration of Rights, given the particularized risk of flight and the legitimate governmental interest in ensuring Tariri’s appearance in court. The judgment of the single justice was affirmed. View "Tariri v. Commonwealth" on Justia Law

During the COVID-19 pandemic, an employee in Nevada worked for a large retailer that required workers to undergo COVID-19 testing before each shift, following state emergency orders and workplace safety recommendations. The company did not pay employees for the time spent on these pre-shift tests. The employee filed a putative class action in the United States District Court for the District of Nevada, alleging violations of Nevada’s wage-hour statutes and the state constitution, including failure to pay for all hours worked, minimum wage, overtime, and timely payment upon termination.The United States District Court for the District of Nevada denied the employer’s motion to dismiss, which had argued that the time spent on COVID-19 testing was not compensable “work” under the federal Portal-to-Portal Act (PPA). The district court held that Nevada law had not incorporated the PPA, and thus the pre-shift screenings were compensable. The court then certified a question to the Supreme Court of Nevada, asking whether Nevada law incorporates the PPA’s exceptions to compensable work.The Supreme Court of Nevada reviewed the certified question and determined that Nevada’s wage-hour statutes do not incorporate the PPA’s broad exceptions to compensable work. The court found that Nevada law provides only narrow, specific exceptions to work compensation, unlike the PPA’s general exclusions for preliminary and postliminary activities. The court concluded that the Nevada Legislature did not intend to adopt the PPA’s exceptions, as reflected in the statutory language and legislative history. Therefore, the Supreme Court of Nevada answered the certified question in the negative, holding that Nevada’s wage-hour laws do not incorporate the PPA’s exceptions to compensable work. View "AMAZON.COM SERVS., LLC VS. MALLOY" on Justia Law

A citizen of Cleburne County submitted a petition for a local ballot initiative, titled the “Hand Marked, Hand Counted Paper Ballot Ordinance of 2024,” to the county clerk for inclusion in the 2024 general election. The county clerk rejected the petition, determining that there were insufficient valid signatures because some paid canvassers were not Arkansas residents as required by law. The canvassers later submitted supplemental affidavits listing Arkansas addresses, but the clerk still refused to count those signatures.The petitioner then filed suit in the Cleburne County Circuit Court, seeking a writ of mandamus and an injunction to compel the clerk to count the disputed signatures and certify the petition if it met the signature requirements. After an expedited hearing, the circuit court granted both the writ and the injunction, ordering the clerk to count all signatures, including those “cured” by the supplemental affidavits, and to certify the petition if it was sufficient.On appeal, the Supreme Court of Arkansas reviewed whether the circuit court could require the county clerk to certify a local ballot initiative that was not timely filed under the Arkansas Constitution. The Supreme Court held that Article 5, section 1 of the Arkansas Constitution sets the exclusive timeline for filing local initiative petitions—no sooner than ninety days and no later than sixty days before the election. The petition in question was filed too early for the 2024 election and, by operation of statute, would have been certified for the 2026 election, but it was also untimely for that election under the constitutional timeline. The Supreme Court held that the relevant statutory provisions were unconstitutional to the extent they conflicted with the constitutional timeline. The court reversed the circuit court’s order and dismissed the case, holding that a circuit court cannot require certification of an untimely initiative. View "EVANS v. HARRISON" on Justia Law

A man committed several felonies in New York and Virginia between 2000 and 2001. After serving his prison sentences, he was subject to both state and federal post-release supervision. He repeatedly violated the terms of his supervision, resulting in multiple periods of reincarceration. In 2006, the United States Court of Appeals for the Second Circuit held in Earley v. Murray that New York’s practice of administratively imposing post-release supervision without a judicial pronouncement was unconstitutional. The state legislature responded in 2008 by authorizing corrections officials to initiate resentencing proceedings. The plaintiff was incarcerated in New York from June 2007 to February 2008 for violating post-release supervision, and again in 2010, before being resentenced without post-release supervision.The United States District Court for the Eastern District of New York dismissed the plaintiff’s claims for damages related to his 2010 incarceration, finding the defendants acted reasonably at that time, but allowed claims related to the 2007-08 incarceration to proceed to trial. At trial, the defendants were barred from introducing evidence that legal and administrative obstacles prevented them from initiating resentencing for the plaintiff during 2007-08. The jury awarded the plaintiff $100,000 in compensatory and $750,000 in punitive damages. The district court denied the defendants’ motion for a new trial and rejected their qualified immunity defense for the 2007-08 period.The United States Court of Appeals for the Second Circuit held that the district court abused its discretion by excluding evidence of impediments to resentencing and erred in denying a new trial for the 2007-08 period. The court reversed the denial of a new trial for that period, vacated the dismissal of the 2010 claims on qualified immunity grounds, and remanded for further proceedings. The court also held that qualified immunity was properly denied for both periods under existing precedent. View "Santiago v. Fischer" on Justia Law

A high school senior in New York posted a photo on social media after school hours and off school grounds, depicting a friend kneeling on his neck with the caption “Cops got another.” The image resembled the murder of George Floyd, and although the student claimed he did not intend this resemblance, he removed the post within minutes after receiving negative reactions. However, another student took a screenshot and shared it more widely, leading to public outcry, in-school discussions, a student demonstration, and a school investigation. The school superintendent suspended the student and barred him from extracurricular activities for the rest of the school year.The student initially filed suit in New York State Supreme Court, alleging that the school’s disciplinary actions violated his First Amendment rights. After the state court granted limited injunctive relief allowing him to attend graduation, the defendants removed the case to the United States District Court for the Southern District of New York. Following discovery, the district court granted summary judgment for the school district, finding that the student’s off-campus speech caused substantial disruption in school and thus was not protected by the First Amendment.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision. Applying the standards from Tinker v. Des Moines Independent Community School District and Mahanoy Area School District v. B.L., the Second Circuit held that the school’s disciplinary actions violated the student’s First Amendment rights. The court found that the off-campus nature of the speech, its lack of threatening content, and the school’s interests did not justify the punishment imposed. The Second Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Leroy v. Livingston Manor Central School District" on Justia Law

A state trooper stopped a vehicle for speeding in Waller County, Texas. The driver and passenger appeared nervous, and the trooper noticed strong odors of food and cigarillo smoke, with a possible faint smell of marijuana. After the occupants denied consent to search, a backup officer arrived with a drug-detection dog. During an open-air sniff, the dog’s handler directed the dog to various parts of the vehicle. The dog repeatedly jumped up and stuck its nose through the open passenger window into the car’s interior. After the third intrusion, the dog alerted, and officers searched the vehicle, finding a large quantity of pills. The driver was charged with possession of a controlled substance.The 506th District Court of Waller County initially denied the defendant’s motion to suppress, finding that the totality of the circumstances provided reasonable suspicion and that the dog’s alert provided probable cause. Upon reconsideration, however, the trial court granted the motion to suppress, concluding that the dog’s nose entering the vehicle constituted a trespass and an unlawful search under the Fourth Amendment, and that the evidence found should be excluded. The Fourteenth Court of Appeals affirmed, holding that the dog’s intrusion into the vehicle’s interior was an unreasonable search.The Texas Court of Criminal Appeals reviewed the case and affirmed the court of appeals’ decision. The court held that the repeated physical intrusion of the drug-detection dog’s nose into the interior of the vehicle during an open-air sniff constituted a search under the Fourth Amendment. Because this search was conducted without probable cause, the trial court properly suppressed the evidence obtained as a result. The court clarified that such an intrusion is distinct from a routine exterior sniff and is subject to constitutional protections. View "STATE OF TEXAS v. ORGAN" on Justia Law

The case concerns an individual who was stopped by a Harris County Sheriff’s Deputy for a traffic violation. The individual, who was a convicted felon with an active warrant for a parole violation, was driving a car borrowed from his sister and was armed with her handgun. During the stop, the individual lied about his identity and, after his passenger left the scene, shot and killed the deputy at close range while the deputy was standing by his patrol car. The individual fled, disposed of the weapon, and was later apprehended at a nearby shopping center. At trial, he admitted to the shooting but claimed it was accidental, asserting he was attempting a citizen’s arrest.The 230th Judicial District Court of Harris County tried the case. The jury found the individual guilty of capital murder and, after considering evidence of his extensive criminal history and lack of remorse, answered the special issues in a manner that resulted in a death sentence. The individual represented himself at trial after waiving his right to counsel, but later unsuccessfully sought to withdraw that waiver and have counsel reappointed. He raised several points of error on appeal, including challenges to the sufficiency of the evidence, the denial of his request to withdraw his waiver of counsel, the admission of certain punishment-phase evidence, and the constitutionality of Texas’s death penalty statute.The Texas Court of Criminal Appeals reviewed the case on direct appeal. The court held that the evidence was legally sufficient to support both the conviction for capital murder and the jury’s finding of future dangerousness. It found no abuse of discretion in the trial court’s denial of the request to withdraw the waiver of counsel, nor in the admission of the challenged evidence. The court also determined that the constitutional challenges to the death penalty statute were not preserved for review and, in any event, lacked merit. The conviction and sentence of death were affirmed. View "SOLIS v. STATE OF TEXAS" on Justia Law

The case concerns a defendant who, after a contentious visit to San Antonio Police Department headquarters regarding a child custody issue, returned later that day and fatally shot a police detective who was sitting in his patrol car. The defendant was apprehended the following day by a SWAT team, and during and after his arrest, he made several incriminating statements to law enforcement, a detention officer, and a mental health assessor. At trial, the defendant challenged the admissibility of these statements, arguing they were involuntary or obtained in violation of his rights. He also raised issues regarding jury selection, the presence of alternate jurors during deliberations, and the constitutionality of certain aspects of Texas’s capital sentencing scheme.The 379th District Court of Bexar County conducted the trial. The jury convicted the defendant of capital murder for killing a peace officer in the line of duty and, based on their answers to special sentencing issues, imposed a sentence of death. The defendant raised multiple points of error on direct appeal, including claims that his statements should have been suppressed, that the State’s peremptory strike of a Black venireperson was racially motivated, that the presence of alternate jurors during deliberations violated statutory and constitutional rights, and that the Texas capital sentencing statute is unconstitutional.The Texas Court of Criminal Appeals reviewed the case on automatic direct appeal. The court held that the trial court did not err in admitting the defendant’s statements, as they were either voluntary or not the product of custodial interrogation. The court found no clear error in the trial court’s rejection of the Batson challenge, concluding the State’s reasons for the peremptory strike were race-neutral. The court determined that the presence of alternates during deliberations, while a statutory violation, was harmless error. The court also rejected the constitutional challenges to the sentencing scheme. The conviction and death sentence were affirmed. View "MCKANE v. STATE OF TEXAS" on Justia Law

A group of voters in Tarrant County, Texas, challenged the county’s decision to redraw the boundaries of its four commissioners precincts in 2025, a process that occurred outside the usual post-census redistricting cycle. The new map, adopted by a narrow 3–2 vote, shifted a significant number of voters—disproportionately Black, Latino, and Democratic—into precincts that would not hold commissioner elections until 2028, effectively postponing their opportunity to vote for a county commissioner by two years. The plaintiffs, who are racially diverse, argued that the redistricting was intended to harm racial minorities and Democratic voters, and that the mid-cycle timing unlawfully disenfranchised certain residents.The United States District Court for the Northern District of Texas denied the plaintiffs’ request for a preliminary injunction to block the use of the new map in the 2026 election. The district court dismissed the First Amendment claims as nonjusticiable under Supreme Court precedent, but allowed the race discrimination and vote postponement claims to proceed, ultimately finding that the plaintiffs had not shown a likelihood of success on the merits.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s denial of a preliminary injunction. The Fifth Circuit held that claims of partisan gerrymandering are nonjusticiable in federal court, even when staggered elections result in some voters’ ballots being postponed. The court further held that the plaintiffs had not demonstrated that race was a motivating factor in the adoption of the new map, applying the Arlington Heights framework and finding no clear error in the district court’s assessment of the evidence. Finally, the court concluded that postponement of voting opportunities due to redistricting in a staggered election system does not violate the Constitution, as there is no right to vote on a particular schedule. View "Jackson v. Tarrant County" on Justia Law

In this case, police in Denver were investigating a shooting that occurred early in the morning. They identified a suspect described as a light-skinned Black male with a bald head, thick beard, and muscular build, and circulated a photo of him. Later that day, officers surveilled a vehicle believed to be connected to the suspect. When a group, including a Black male with some similar clothing but not matching the suspect’s physical description, arrived in a different car and then left in a third vehicle, officers decided to stop that vehicle at a gas station. During the stop, officers detained Noah Huerta, a passenger, and conducted a patdown, finding a firearm magazine on him. A subsequent search of the vehicle, after obtaining the driver’s consent, revealed a handgun near Huerta’s seat.The United States District Court for the District of Colorado denied Huerta’s motion to suppress the evidence, finding that the officers had reasonable suspicion to believe he was armed and dangerous, and also ruled that the firearm would have been inevitably discovered. The court also denied Huerta’s motion to dismiss the indictment, which challenged the constitutionality of the felon-in-possession statute under recent Supreme Court precedent.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the denial of the motion to suppress de novo. The court held that the officers lacked reasonable suspicion to believe Huerta was armed and dangerous, as the connection between the group and the shooting suspect was tenuous and based on a mere hunch, and the conduct of the vehicle’s occupants was innocuous. The court also found that the inevitable discovery doctrine did not apply. However, the Tenth Circuit affirmed the district court’s denial of the motion to dismiss the indictment, as binding circuit precedent foreclosed Huerta’s constitutional challenge. The court reversed the denial of the motion to suppress and remanded for further proceedings. View "United States v. Huerta" on Justia Law