Justia Constitutional Law Opinion Summaries

KalshiEX LLC operates a federally licensed designated contract market (DCM) that allows users to trade event contracts, including those based on sports outcomes. In late 2024, after Kalshi began offering sports-related event contracts similar to those offered by a competitor, New Jersey issued a cease-and-desist letter. The state asserted that Kalshi’s activities violated the New Jersey Constitution and state gambling laws, particularly regarding betting on collegiate sports, and threatened legal action with significant penalties if Kalshi continued its operations within New Jersey.In response, Kalshi initiated proceedings in the United States District Court for the District of New Jersey, seeking a preliminary injunction to prevent enforcement of New Jersey’s gambling laws against its federally regulated contracts. The District Court granted the injunction, finding that Kalshi had a reasonable likelihood of success on the merits, would suffer irreparable harm without relief, and that the public interest favored enjoining enforcement of potentially preempted state law. New Jersey appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error, legal conclusions de novo, and the decision to grant the preliminary injunction for abuse of discretion. The Third Circuit affirmed the District Court’s order. The appellate court held that the Commodity Exchange Act (CEA) grants the Commodity Futures Trading Commission (CFTC) exclusive jurisdiction over swaps, including sports-related event contracts traded on CFTC-licensed DCMs. Both field and conflict preemption principles bar New Jersey from enforcing its gambling laws against these contracts. The court concluded that Kalshi demonstrated a likelihood of success on the preemption claim, irreparable harm in the absence of an injunction, and that the equities and public interest favored injunctive relief. Accordingly, the court affirmed the preliminary injunction. View "Kalshiex LLC v. Flaherty" on Justia Law

Several educators, parents, students, and a nonprofit organization challenged two provisions of an Iowa law affecting public schools. The law restricts classroom instruction on gender identity and sexual orientation for students in kindergarten through sixth grade and requires school officials to notify parents if a student requests accommodations affirming their gender identity, such as using a different pronoun. The plaintiffs, asserting facial constitutional challenges, argued the provisions were overbroad and vague, infringing on First Amendment and due process rights.Previously, the United States District Court for the Southern District of Iowa granted a preliminary injunction against these provisions. The district court found that the terms “program” and “promotion” in the instruction restriction were overly broad and infringed on protected speech, and determined that the parental notification law was impermissibly vague due to the undefined use of “accommodation.” The district court severed what it considered unconstitutional portions of the statutes and enjoined their enforcement.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. It held that the statutes, when read with the canon of constitutional avoidance, could reasonably be interpreted in a way that avoided constitutional problems and that the statutory language was sufficiently clear. The appellate court found the plaintiffs did not demonstrate that unconstitutional applications of the laws substantially outweighed constitutional ones in their facial challenge. It further determined that the term “accommodation” was not unconstitutionally vague. The Eighth Circuit concluded that the district court abused its discretion in granting the preliminary injunction and vacated that injunction as to all challenged provisions, remanding the case for further proceedings on the merits. View "Iowa Safe Schools v. Reynolds" on Justia Law

A group of plaintiffs, including publishers, authors, educators, and a parent of a student, challenged provisions of an Iowa law (Senate File 496) requiring public school libraries to remove books containing “descriptions or visual depictions of a sex act.” The law also imposed penalties on educators who failed to comply. The plaintiffs argued that these provisions violated their First Amendment rights, both as to students’ access to information and as to the right of authors and publishers to communicate with their intended audience.The United States District Court for the Southern District of Iowa initially granted a preliminary injunction, preventing enforcement of the challenged provisions. The court concluded that the plaintiffs were likely to prevail, holding that the unconstitutional applications of the law substantially outweighed constitutional ones. It declined to apply the standard set out in Hazelwood School District v. Kuhlmeier, instead relying on the obscenity standard from Ginsberg v. State of New York and the “substantial and reasonable government interest” test from the plurality in Board of Education, Island Trees Union Free School District No. 26 v. Pico.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. The Eighth Circuit held that the Hazelwood standard—whether the restrictions are “reasonably related to legitimate pedagogical concerns”—applies to school library curation. The court determined that the Iowa law’s book restrictions addressed legitimate pedagogical concerns and were neither amorphous nor unreasonable. Because the plaintiffs could not show a likelihood of success on the merits under the correct standard, the Eighth Circuit vacated the preliminary injunction and remanded the case for further proceedings on the merits. View "Penguin Random House, LLC v. Robbins" on Justia Law

After a mass shooting in Lewiston, Maine in October 2023, which resulted in significant loss of life, the state enacted a law requiring a seventy-two-hour waiting period before a firearm seller may deliver a purchased firearm to the buyer. The law’s purpose was to reduce suicides and homicides associated with impulsive gun purchases. The statute contains exceptions for law enforcement officers, certain security personnel, family transactions, collectors, antiques, and cases where background checks are not required. Several individuals and firearms businesses challenged the law in federal court, alleging it violated their Second Amendment rights, both facially and as applied.The United States District Court for the District of Maine granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on the merits of their facial Second Amendment claim. The court applied the two-step framework from New York State Rifle & Pistol Ass’n, Inc. v. Bruen, first finding that the law implicated conduct covered by the plain text of the Second Amendment, and then determining that the state had not shown that the law was consistent with the nation’s historical tradition of firearms regulation. The district court also found that the other factors for granting a preliminary injunction were present.On appeal, the United States Court of Appeals for the First Circuit reviewed the matter de novo. The appellate court concluded that the seventy-two-hour waiting period regulates conduct antecedent to “keeping” or “bearing” arms, and thus does not directly implicate the plain text of the Second Amendment. The court found that the law imposes, at most, a presumptively lawful condition on the commercial sale of firearms, akin to “shall-issue” licensing regimes, and is constitutional unless shown to be abusive. The court determined that the plaintiffs had not shown the law was abusive toward Second Amendment rights. Accordingly, the First Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Beckwith v. Frey" on Justia Law

Law enforcement officers in Albuquerque arrested the defendant in February 2022 after observing him exit the driver's seat of a truck reported stolen. The truck contained two passengers, one of whom fled. A search uncovered an unopened vacuum-sealed bundle of methamphetamine weighing 445 grams and an unloaded revolver beneath the driver's seat. An assault rifle with a loaded magazine was found in the passenger seat, and a Ziploc bag containing 84 grams of methamphetamine was located in the back-seat area. The defendant later admitted to moving from the back seat. Evidence at trial included expert testimony regarding the function of the firearms, the value and distribution quantity of the drugs, and the common practice of drug traffickers possessing firearms for protection. Text messages demonstrated the defendant sought firearms after being robbed of drugs and a gun.The United States District Court for the District of New Mexico convicted the defendant of multiple offenses, but only the conviction for possessing firearms in furtherance of a drug-trafficking crime under 18 U.S.C. § 924(c) was at issue in this appeal. The defendant argued that the evidence was insufficient to support the conviction and that the “in furtherance of” language in the statute was unconstitutionally vague as applied to him.The United States Court of Appeals for the Tenth Circuit reviewed the appeal. The court held that, under its precedent, there was sufficient evidence for a rational jury to find that the defendant possessed firearms in furtherance of his drug-trafficking offense. The court also concluded that the statutory language was not unconstitutionally vague as applied. The Tenth Circuit affirmed the conviction, rejecting both the sufficiency and vagueness challenges. View "United States v. Jimenez-Marquez" on Justia Law

A law firm and one of its clients challenged Maine’s Interest on Lawyers’ Trust Accounts (IOLTA) program, which requires attorneys to deposit certain client funds into pooled, interest-bearing accounts. The interest generated is collected by a nonprofit, the Maine Justice Foundation, and distributed to organizations supporting access to justice in Maine. The plaintiffs argued that being compelled to participate in the program forced them to subsidize advocacy with which they disagreed, violating their First and Fourteenth Amendment rights.The United States District Court for the District of Maine dismissed the claims against the Chief Justice of the Maine Supreme Judicial Court and the State Court Administrator on the merits, concluding that the plaintiffs failed to state a claim. Specifically, the District Court found that, under Maine’s rules, only client funds that could not generate net interest for the client (due to the amount or duration) are required to be deposited in IOLTA accounts, and the plaintiffs did not plausibly allege otherwise. The claim against the Maine Justice Foundation was dismissed for lack of jurisdiction, as the Foundation neither promulgates nor enforces the challenged rule.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rulings. The appellate court held that the plaintiffs failed to plausibly allege they were compelled to deposit funds that would have generated net interest for the client, as required to make out a compelled-speech claim under controlling precedent. The court also found that any appeal of the dismissal against the Maine Justice Foundation was moot, since the complaint was fatally deficient regardless of the defendant. Thus, the First Circuit affirmed the judgment of the District Court. View "Wescott v. Stanfill" on Justia Law

Police discovered the bodies of two men, both shot in the head, in a burning car in Jackson County, Michigan. Barbara Mercer lived with her boyfriend, Richard Janish, and her friend, Jessica Campbell. Mercer had recently tricked one of the victims, Thomas, into giving her crack cocaine without payment, resulting in threatening messages from Thomas. The night of the killing, Mercer and Janish discussed the threats, and Janish ultimately shot and killed both victims. Mercer and Janish then attempted to destroy evidence by burning the bodies in the victims’ car. Both were arrested, and their statements to police, as well as Campbell’s testimony, formed the basis of the prosecution’s case. Mercer was convicted by a jury of two counts of second-degree murder, tampering with evidence, and arson.The Michigan Court of Appeals affirmed Mercer’s convictions, rejecting her claims that the trial court erred by denying a defense-of-others jury instruction, that her counsel was ineffective, and that the prosecutor committed misconduct during closing arguments. The Michigan Supreme Court denied further review. Mercer then filed a federal habeas petition in the United States District Court for the Eastern District of Michigan. The district court granted habeas relief on the ground that Mercer’s due process rights were violated when the trial court failed to give a defense-of-others instruction, but denied relief on her other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s grant of habeas relief on the jury-instruction claim, holding that Mercer’s claim did not satisfy the requirements for relief under the Antiterrorism and Effective Death Penalty Act. The Sixth Circuit affirmed the district court’s denial of relief on Mercer’s remaining claims regarding ineffective counsel and prosecutorial misconduct, finding that the state court’s decisions were not contrary to or unreasonable applications of clearly established federal law. View "Mercer v. Stewart" on Justia Law

The defendant was indicted under a federal statute that prohibits individuals convicted of crimes punishable by more than one year of imprisonment from possessing firearms. The defendant’s criminal history included prior convictions for armed robbery and aggravated battery, and the conduct leading to the present prosecution involved using a firearm to threaten passengers on public transportation and possessing a loaded semi-automatic weapon in a location where firearms were explicitly prohibited.The United States District Court for the Northern District of Illinois, Eastern Division, dismissed the indictment. The district court concluded that the statute in question, 18 U.S.C. §922(g)(1), was invalid on its face under the Second Amendment, meaning that it was unconstitutional in every possible application. The government appealed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court considered Supreme Court precedents regarding the Second Amendment, including District of Columbia v. Heller, McDonald v. Chicago, New York State Rifle & Pistol Association, Inc. v. Bruen, and United States v. Rahimi. The appellate court noted that, while there is disagreement among courts about the statute’s application in some circumstances, all courts of appeals have agreed that §922(g)(1) is valid in many applications and cannot be declared unconstitutional in all cases. The Seventh Circuit held that the statute cannot be found facially invalid and reserved judgment on whether it might be unconstitutional as applied to individuals whose prior convictions do not suggest they are dangerous. In this case, because the defendant’s convictions and conduct indicated a risk of dangerousness, the court reversed the district court’s dismissal and remanded the case for further proceedings. View "USA v Prince" on Justia Law

A group of prisoners in Illinois sued the state’s Department of Corrections, alleging that they were provided with inadequate medical and dental care, which they claimed violated the Eighth Amendment. The class was certified, and the parties reached a settlement that led to the entry of a consent decree. This decree required the Department to prepare an implementation plan, with oversight and recommendations from an independent monitor, to address the systemic deficiencies identified. Over time, disagreements arose regarding the adequacy and specificity of the Department’s proposals, and the monitor’s recommendations were largely adopted by the court after finding the Department in contempt for noncompliance.The United States District Court for the Northern District of Illinois, Eastern Division, approved and amended the consent decree, eventually adopting the implementation plan as part of it. The Department then filed several motions under Rule 60(b) to modify the consent decree, including requests to remove stipulations about compliance with the Prison Litigation Reform Act (PLRA) and to excise or terminate the implementation plan. The court denied these requests, but did acknowledge changed circumstances and amended the decree to clarify that the implementation plan would only be enforceable if the court made findings required by the PLRA. The court also extended the term of the consent decree due to the Department’s lack of substantial compliance.On appeal, the United States Court of Appeals for the Seventh Circuit found it lacked jurisdiction to review some orders, such as the denial of the motion to strike the stipulation and the extension of the decree, as these did not substantially alter the parties’ legal relationship. The court affirmed the lower court’s decisions regarding the implementation plan, holding that its terms are not enforceable unless and until the district court makes the factual findings required by 18 U.S.C. § 3626(a)(1)(A) of the PLRA. The case was remanded for further proceedings. View "Lippert v Hughes" on Justia Law

In this case, the defendant was indicted under federal law for possessing firearms after having been previously convicted of felony offenses, including possession of cocaine with intent to distribute and being a firearm user while using controlled substances. The case arose when police, investigating a shooting, traced evidence to the defendant through witness statements, storage unit searches, and DNA samples. The defendant challenged both the admissibility of DNA evidence and the constitutionality of the federal statute prohibiting felons from possessing firearms as applied to him.The United States District Court for the Eastern District of Wisconsin denied the defendant’s motions to dismiss the indictment and to suppress the DNA evidence. The court found that the DNA collected by federal authorities was obtained independently of any potentially unlawful prior collection by state authorities, and that there was a sufficient evidentiary basis for the federal warrant. The defendant subsequently pleaded guilty but preserved his right to appeal the denial of his motions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the legal conclusions de novo and factual findings for clear error. The Seventh Circuit affirmed the district court’s rulings. It held that the DNA evidence was admissible under the independent-source doctrine, as the federal warrant was based on evidence untainted by any prior illegality. The court also held that 18 U.S.C. § 922(g)(1), as applied to the defendant’s conviction for a dangerous felony (possession of cocaine with intent to distribute), did not violate the Second Amendment. The court reasoned that disarmament of individuals convicted of dangerous felonies is consistent with the nation’s historical tradition and supported by both categorical disarmament of dangerous groups and the historical imposition of severe penalties for such offenses. The judgment was affirmed. View "USA v Watson" on Justia Law