Justia Constitutional Law Opinion Summaries

In the case involving Katherine Blumenkron, David Blumenkron, and Springville Investors, LLC, versus Multnomah County, the Metro Regional Government, and members of the Oregon Land Conservation and Development Commission, the plaintiffs challenged the designation of their land in Multnomah County, Oregon, as "rural reserves" under the Oregon Land Reserves Statute. They claimed that the statute and regulations facially violate the Equal Protection and Due Process Clauses of the federal constitution, and that the defendants’ rural reserve designations violated their federal procedural due process, substantive due process, and equal protection rights. The U.S. Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal of plaintiffs’ facial and as-applied constitutional challenges to the designation, concluding that the requirements for Burford abstention (a doctrine that allows federal courts to refrain from deciding a case in deference to state courts) were met for each of the as-applied claims. The court also held that the district court did not abuse its discretion by abstaining from exercising jurisdiction over the claims in their entirety, including plaintiffs’ claims for damages. The court concluded that plaintiffs had abandoned their facial constitutional claims on appeal and therefore affirmed the district court’s dismissal of these claims for failure to state a claim as a matter of law. View "BLUMENKRON V. MULTNOMAH COUNTY" on Justia Law

In the case before the Supreme Court of Wyoming, State Representatives Rachel Rodriguez-Williams and Chip Neiman, and Right to Life of Wyoming, Inc., attempted to intervene in a lawsuit challenging the constitutionality of two Wyoming laws restricting abortion. The district court denied their motion to intervene, and they appealed that decision. The Supreme Court of Wyoming affirmed the lower court's decision, holding that the proposed intervenors did not meet the requirements for intervention as of right. The court found that the proposed intervenors did not demonstrate a significant protectable interest in the lawsuit. The court also found that the State of Wyoming, represented by the Attorney General, adequately represented the proposed intervenors' interests in defending the challenged laws. Additionally, the court found that allowing the proposed intervenors to participate in the lawsuit would unduly delay and prejudice the case's adjudication. Therefore, the court also denied the proposed intervenors' motion for permissive intervention. View "Rodriguez-Williams v. Johnson" on Justia Law

In a case before the Supreme Court of the State of Utah, the petitioner, Elbert John Paule, was charged with murder, obstruction of justice, reckless endangerment, and assault following a fatal shooting incident involving a friend. The jury acquitted Paule on all charges except obstruction of justice. Paule challenged his conviction, arguing that the obstruction of justice conviction was legally inconsistent with the jury’s determination that he was not guilty of the other crimes. The Utah Court of Appeals affirmed the conviction. On certiorari review, the Supreme Court of the State of Utah affirmed the lower court's ruling.The Supreme Court held that to be convicted of obstruction of justice, a defendant need only perform an obstructive act with the requisite intent. Proof of a separate crime is not necessary. The court concluded that because a violation of Utah’s obstruction of justice statute requires only that a defendant act with the requisite intent—it does not require proof of a separate criminal offense—the jury’s verdict was not legally impossible. Furthermore, the court found that Paule's counsel was not constitutionally ineffective in failing to seek a more detailed unanimity instruction. View "State v. Paule" on Justia Law

In 2022, Oregon voters approved Ballot Measure 113, amending the state constitution to disqualify any state legislator who accumulates 10 or more unexcused absences during a legislative session from holding office "for the term following the election after the member’s current term is completed." The Secretary of State interpreted this to mean that the disqualification applies to a legislator’s immediate next term. However, a group of legislators challenged this interpretation, arguing that the disqualification should apply one term later.The Supreme Court of the State of Oregon held that the measure's disqualification applies to the legislator’s immediate next term of office. The Court found that the text of the amendment was capable of supporting the Secretary's interpretation. This interpretation was also supported by the ballot title and the voters’ pamphlet, which repeatedly described the disqualification as occurring immediately following the legislator’s current term. The Court concluded that voters would have understood the amendment in light of these materials. Therefore, the Court upheld the Secretary's rules implementing the amendment. View "Knopp v. Griffin-Valade" on Justia Law

Four Iranian nationals, who had previously completed mandatory military service in Iran's Islamic Revolutionary Guard Corps (IRGC), were denied visas to enter the United States. Their family members, three U.S. citizens and one lawful permanent resident, filed a suit against the President and several federal officials responsible for visa applications. They alleged that the defendants unlawfully deprived visa applicants the opportunity to establish eligibility for terrorism-related inadmissibility grounds (TRIG) exemptions, violating their rights under the Administrative Procedure Act and the Fifth Amendment’s Due Process Clause. The district court dismissed the case under the doctrine of consular nonreviewability, which bars judicial review of consular decisions. The Plaintiffs appealed, and the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court held that the doctrine of consular nonreviewability applied, and that the plaintiffs failed to show any evidence of bad faith that could overcome this doctrine. The court also held that the applicants were not entitled to any more explanation for their visa denials than the citation to the section of the law on which the denial was based. View "Pak v. Biden" on Justia Law

In the case of City of St. Louis and Heather Taylor (“Appellants”) versus State of Missouri (“State”), the Supreme Court of Missouri analyzed Senate Bill No. 26 (“SB 26”) that was challenged for being unconstitutional. SB 26, introduced in December 2020 and signed into law in July 2021, contained 88 sections related to public safety, including procedures for imposing discipline on law enforcement officers and provisions for the offense of “unlawful traffic interference.”Appellants argued that SB 26 violated the Missouri Constitution on several grounds, including that it violated the original-purpose and single-subject rules, that it created an unfunded mandate, that it imposed additional duties on officers and employees of a constitutional charter city, that it used public funds for private purposes, and that it created unequal treatment between law enforcement officers and other city employees.The Supreme Court of Missouri found that the City had sufficiently pleaded the elements of a Hancock Amendment violation, which prohibits the state from requiring new or expanded activities by counties and other political subdivisions without full state financing. Therefore, the circuit court's judgment was reversed on this point and the case was remanded for further proceedings.However, the court affirmed the judgment with respect to Appellants' other points. It found that SB 26 had the same purpose as enacted as introduced, did not impose new duties on city employees or allocate funds for public purposes, and had a rational basis for treating law enforcement officers differently from other city employees. The court also found that SB 26 did not violate the original-purpose and single-subject rules, did not impose additional duties on officers and employees of a constitutional charter city, did not use public funds for private purposes, and did not create unequal treatment between law enforcement officers and other city employees. View "City of St. Louis v. State" on Justia Law

In this case, Jacob R. Labbe Sr. was convicted by the trial court on one count of domestic violence stalking and two counts of violation of a protective order. Labbe appealed arguing that the stalking statute was unconstitutionally vague, the evidence was insufficient to convict him of domestic violence stalking, the court erred in denying his request to dismiss the charges as de minimis, and the court made several erroneous evidentiary rulings.The Maine Supreme Judicial Court affirmed the conviction. It held that the stalking statute was not unconstitutionally vague. The court found that the statute provided a clear definition of "course of conduct" and enough evidence supported a conviction for domestic violence stalking. It further held that the court did not abuse its discretion in denying Labbe's request to dismiss the charges as de minimis. The court also found no error in the trial court's evidentiary rulings. The court concluded that the First Amendment did not require the State to prove reckless disregard on the part of Labbe for the effect of his statements on the victim, as the charge was not based on the content of Labbe's communications but rather on his persistent unwelcome contact with the victim. Therefore, the court found no error in the trial court's instructions to the jury. The conviction was affirmed. View "State v. Labbe" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, plaintiffs Scott Sonda and Brian Corwin, both mineral rights owners in West Virginia, challenged Senate Bill 694, which amended the State's oil and gas conservation law to permit the unitization of interests in horizontal well drilling units, even for nonconsenting mineral rights owners. The plaintiffs claimed that this law constituted a taking of their property and deprived them of property without due process, in violation of the Fifth and Fourteenth Amendments of the U.S. Constitution. The West Virginia Oil and Gas Conservation Commission filed a motion to dismiss, asserting that the plaintiffs lacked standing, that the Commission was immune under the Eleventh Amendment, and that the complaint failed to state a claim upon which relief could be granted.However, the district court abstained from ruling on the federal constitutional claims, citing the Pullman abstention doctrine, and ordered the proceeding stayed pending the outcome of a state court action that the plaintiffs may file. The Commission appealed the district court's abstention order.The Fourth Circuit Court of Appeals reversed the district court's order and remanded for further proceedings, noting that the district court had erred by applying the Pullman abstention doctrine without first ensuring it had jurisdiction. The court directed the district court to first address the Commission's argument challenging the plaintiffs' Article III standing. The court did not express an opinion about the merits of the standing issue or any others before the district court. View "Sonda v. West Virginia Oil & Gas Conservation Commission" on Justia Law

In Montana, a group of plaintiffs, including Forward Montana, Leo Gallagher, Montana Association of Criminal Defense Lawyers, and Gary Zadick, challenged two amendments to Senate Bill 319 (SB 319) on the grounds that they violated Article V, Section 11 of the Montana Constitution. The amendments, added in the final days of the legislative session without public comment, expanded the bill's scope beyond its initial focus on campaign finance to include regulations on political activities on college campuses and judicial recusal requirements. The District Court found that the amendments violated the Single Subject Rule and Rule on Amendments of the Montana Constitution, and permanently enjoined their enforcement. However, the court declined to award attorney fees to the plaintiffs under the private attorney general doctrine, reasoning that the case was a "garden-variety" constitutional challenge.Upon appeal, the Supreme Court of the State of Montana disagreed, reversing and remanding the decision regarding attorney fees. The court held that the plaintiffs had satisfied all three factors required for attorney fees under the private attorney general doctrine: the societal importance of the public policy vindicated by the litigation (constitutional limitations on legislative power), the necessity for private enforcement and the burden on the plaintiffs, and the large number of people standing to benefit from the decision. Despite the District Court's finding that the case was a "garden-variety" constitutional challenge, the Supreme Court determined that the Legislature's willful disregard of constitutional duties and legislative rules and norms in adopting these amendments justified the award of attorney fees. The case was remanded to the District Court for calculation of attorney fees. View "Forward Montana v. State" on Justia Law

In this case, the City of Laramie, Wyoming, sued the University of Wyoming and its Board of Trustees, challenging the drilling and operation of certain water wells. The city argued that the university was in violation of a 1965 deed covenant prohibiting the drilling of one of the wells and was also in violation of a city ordinance. The city also claimed that legislation exempting the university from this city ordinance was unconstitutional. The district court dismissed some of the city's claims and granted summary judgment in favor of the university on the remaining claims. The Supreme Court of Wyoming affirmed the lower court's decision. The court held that the university was protected by sovereign immunity from the city's attempts to enforce the deed covenant. It also held that the state law exempting the university from the city ordinance was constitutional. The court further noted that the law precluded the city from enforcing its ordinance against the university. View "City of Laramie, Wyoming v. University of Wyoming" on Justia Law