Justia Constitutional Law Opinion Summaries

A mother, Aurora Regino, filed a complaint against the Chico Unified School District after the district began using her child's new preferred name and pronouns without informing her. Regino claimed that the district's policy, which allows students to be addressed by their preferred names and pronouns without parental notification, violated her substantive and procedural due process rights. She argued that the policy deprived her of her fundamental rights as a parent to make decisions concerning the care, custody, and control of her children.The United States District Court for the Eastern District of California dismissed Regino's complaint, reasoning that she failed to allege the existence of a fundamental right that was clearly established in existing precedent. The court applied a standard similar to that used in qualified immunity cases, requiring that the right be clearly established in existing law.The United States Court of Appeals for the Ninth Circuit vacated the district court's dismissal, holding that the district court applied erroneous legal standards to the substantive and procedural due process claims. The Ninth Circuit clarified that a plaintiff asserting a substantive due process claim does not need to show that existing precedent clearly establishes the asserted fundamental right. Instead, the critical inquiry is whether the asserted fundamental right is deeply rooted in the nation's history and tradition and implicit in the concept of ordered liberty. The Ninth Circuit remanded the case to the district court to conduct the proper analysis, including a careful formulation of the asserted fundamental right and an examination of whether it is deeply rooted in history and tradition.The Ninth Circuit also held that the district court erred in its analysis of Regino's procedural due process claim by requiring her to identify a fundamental right. Procedural due process protects all liberty interests derived from state law or the Due Process Clause itself. The case was remanded for further proceedings consistent with the Ninth Circuit's opinion. View "REGINO V. STALEY" on Justia Law

Luis Gutierrez was arrested in May 2020 after New Mexico state officers found a loaded, stolen pistol in his motel room. He was charged with both federal and state crimes. In October 2021, he pleaded guilty to two counts of aggravated assault with a deadly weapon against a household member in state court and was sentenced to two years of imprisonment. He was released on May 5, 2022. Gutierrez was indicted for being a felon in possession of a firearm on August 11, 2020, while in state custody. However, he was not notified of the federal charge until his release from state custody.The United States District Court for the District of New Mexico denied Gutierrez’s motion to dismiss the indictment for violation of his Sixth Amendment right to a speedy trial. The court found that the delay in the federal case was justified due to complications caused by the COVID-19 pandemic and that Gutierrez failed to show any prejudice caused by the delay. Gutierrez then pleaded guilty to the federal charge, reserving the right to appeal the denial of his Sixth Amendment claim.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court applied the multi-factor test from Barker v. Wingo and found that while the length of the delay and Gutierrez’s assertion of his right favored him, the reason for the delay was neutral, and he failed to show any prejudice. The court held that the Speedy Trial clause does not apply to postconviction sentencing and that Gutierrez’s alleged harm at sentencing was not cognizable under the Sixth Amendment. The court affirmed the district court’s decision and found that Gutierrez’s appellate waiver was enforceable, barring his challenge to the application of U.S.S.G. § 5K2.6 to enhance his sentence. View "United States v. Gutierrez" on Justia Law

California collects a fee from in-state hospitals and uses the revenue, along with federal Medicaid funds, to provide subsidies to California hospitals serving Medicaid beneficiaries. Out-of-state hospitals near the California border, which sometimes serve California Medicaid beneficiaries but do not pay the fee, sought access to these subsidies. They argued that their exclusion violated the dormant Commerce Clause, the Equal Protection Clause, and federal Medicaid regulations.The United States District Court for the District of Columbia rejected the out-of-state hospitals' arguments and granted summary judgment in favor of the Centers for Medicare and Medicaid Services (CMS). The hospitals appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the QAF program does not discriminate against interstate commerce because it does not tax out-of-state hospitals, and the supplemental payments are based on in-state provision of medical care. The court also found that the program does not violate the Equal Protection Clause, as California could rationally decide to target subsidies to in-state hospitals serving a disproportionate share of Medi-Cal beneficiaries. Lastly, the court concluded that the QAF program does not violate federal Medicaid regulations, as the regulation in question pertains to base payments for specific services rendered to beneficiaries, not supplemental subsidies like the QAF payments. View "Asante v. Kennedy" on Justia Law

A business owner and his company, which provides non-emergency medical transportation, challenged the constitutionality of a Nebraska statute requiring a showing of "public convenience and necessity" to obtain a certificate to operate such services. They argued that the statute violated the Nebraska Constitution's due process, special legislation, and special privileges and immunities clauses. They claimed the requirement protected existing providers from competition and harmed the public by reducing service quality.The district court for Lancaster County rejected their constitutional challenges and dismissed their complaint. The court applied a rational basis test to the due process claim, finding the statute rationally related to a legitimate state interest in preventing destructive competition and ensuring reliable transportation services. The court also found the statute did not create an arbitrary or unreasonable classification or a closed class, thus rejecting the special legislation claim. Finally, the court determined the statute did not grant irrevocable special privileges or immunities, dismissing the special privileges and immunities claim.On appeal, the Nebraska Supreme Court affirmed the district court's rejection of the facial constitutional challenges, agreeing that the statute was rationally related to a legitimate state interest and did not violate the special legislation or special privileges and immunities clauses. However, the Supreme Court vacated the district court's order to the extent it ruled on as-applied challenges, determining that such challenges should be raised in an application for certification and an appeal from any denial by the Public Service Commission. View "N'Da v. Golden" on Justia Law

The case involves the Arizona Abortion Access Act Initiative I-05-2024, which appeared on the November 5, 2024, general election ballot. The Legislative Council prepared an analysis of the initiative, which included a description of existing state law prohibiting abortions after 15 weeks of gestation, except in medical emergencies. The analysis used the term "unborn human being" to describe the existing law, which the initiative's proponents argued was not impartial and requested the term "fetus" be used instead.The Superior Court in Maricopa County ruled in favor of the initiative's proponents, finding that the term "unborn human being" was emotionally and partisanly charged, and ordered the Council to replace it with a neutral term. The Council members appealed the decision, arguing that the analysis was impartial and complied with statutory requirements.The Arizona Supreme Court reviewed the case and reversed the Superior Court's ruling. The Court held that the analysis substantially complied with the statutory requirement for impartiality by accurately describing existing law using the precise terminology found in the statute. The Court emphasized that the term "unborn human being" is used in the existing law and that the analysis provided necessary background information to voters. The Court concluded that the analysis was impartial and did not advocate for or against the initiative. The request for attorney fees and costs by the initiative's proponents was denied. View "ARIZONA FOR ABORTION ACCESS v MONTENEGRO" on Justia Law

Devin Ledbetter was seriously injured by Springfield, Missouri police officer Brandon Helmers. Ledbetter sued Helmers under 42 U.S.C. § 1983, claiming Helmers used excessive force in violation of the Fourth Amendment. The incident occurred when Helmers and his partner responded to a 911 call about a man holding a woman captive in a tent. Ledbetter, who was in the tent, exited holding a knife. The accounts of what happened next differ, with Helmers claiming Ledbetter was non-compliant and threatening, while Ledbetter claimed he immediately dropped the knife and was compliant. Ledbetter sustained severe injuries, including a fractured hip, during the arrest.The United States District Court for the Western District of Missouri denied Helmers's motion for summary judgment based on qualified immunity, noting disputed facts about the threat Ledbetter posed and the amount of force used. The case proceeded to trial, but the jury could not reach a verdict on liability. However, they answered special interrogatories, finding Helmers reasonably believed Ledbetter posed an immediate threat but did not believe Ledbetter was resisting arrest. The district court then granted Helmers's motion for judgment as a matter of law based on qualified immunity, concluding that Helmers did not use excessive force and that his conduct did not violate clearly established law.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a reasonable jury could find Helmers used excessive force, given the evidence and the jury's special findings. However, the court also held that it was not clearly established that Helmers's use of force was excessive under the circumstances, as existing case law did not provide sufficient guidance for the specific situation Helmers faced. Therefore, the court affirmed the district court's judgment granting Helmers qualified immunity. View "Ledbetter v. Helmers" on Justia Law

Muhammad Masood, a licensed physician from Pakistan, came to the United States in 2018 on a non-immigrant visa to work as an unpaid medical researcher. In 2019, he became radicalized by Islamic extremist content and planned to join ISIS. In March 2020, he was arrested at the Minneapolis airport with plans to travel to ISIS-controlled territory. A search revealed military and medical supplies, computers, and digital storage devices containing extremist propaganda. Masood pleaded guilty to attempting to provide material support to a designated foreign terrorist organization.The United States District Court for the District of Minnesota adopted the Presentence Investigation Report (PSR) and sentenced Masood to 216 months imprisonment, varying downward from the statutory maximum of 240 months. Masood appealed, arguing procedural errors in applying the terrorism enhancement, considering the 18 U.S.C. § 3553(a) sentencing factors, and alleged violations of his due process rights and right to allocution.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no procedural error in applying the terrorism enhancement, as the evidence supported that Masood's offense was intended to promote terrorism. The court also found that the district court adequately considered the § 3553(a) factors and provided a sufficient explanation for the sentence. Additionally, the court determined there was no violation of Rule 32(i) or the Due Process Clause, as Masood and his counsel were given opportunities to argue and allocute before the final sentence was imposed. The Eighth Circuit affirmed the district court's judgment. View "United States v. Masood" on Justia Law

The case involves Jeffery S. Armstrong, who was charged with carrying a concealed weapon, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony after police discovered a handgun under the passenger seat of a vehicle in which he was sitting. Corporal Treva Eaton claimed she approached the vehicle because she smelled marijuana emanating from it. Armstrong moved to suppress the gun as evidence, arguing it was obtained through a search that violated the Fourth Amendment.The Wayne Circuit Court ruled that Armstrong was seized when officers surrounded the vehicle and that probable cause was required before ordering him out. The court concluded that the smell of marijuana alone did not establish probable cause to search or justify removing Armstrong from the vehicle and ruled that the plain-view exception did not apply. Consequently, the trial court granted Armstrong’s motion to suppress and dismissed the case.The prosecution appealed, and the Michigan Court of Appeals affirmed the trial court’s decision. The appellate court held that the rule from People v. Kazmierczak, which allowed the smell of marijuana alone to establish probable cause, was superseded by the Michigan Regulation and Taxation of Marihuana Act (MRTMA). The court concluded that the smell of marijuana is no longer necessarily indicative of unlawful activity and that the trial court did not clearly err in finding that the gun was not discovered in plain view.The Michigan Supreme Court reviewed the case and held that the Kazmierczak rule is no longer valid in light of the MRTMA. The court ruled that the smell of marijuana is one factor in the probable-cause determination but is insufficient on its own to support a search. The court affirmed the lower courts' decisions, upholding the suppression of the evidence and the dismissal of the charges against Armstrong. View "People Of Michigan v. Armstrong" on Justia Law

The City of Bakersfield operates multiple weirs on the Kern River to divert water for its use and for several water agencies, including the North Kern Water Storage District (NKWSD) and the Buena Vista Water Storage District. Environmental groups, including Bring Back the Kern (BBTK) and Water Audit California (WAC), sought and obtained a preliminary injunction from the Superior Court of Kern County. The injunction prohibited Bakersfield from operating the weirs in a manner that reduced Kern River flows below the volume sufficient to keep fish downstream in good condition. The trial court refused to consider the potential harm to the City or the water agencies in determining the applicability of the injunction.The water agencies filed motions for reconsideration, arguing that the injunction and the subsequent order setting a flow rate were issued without proper consideration of their interests. The trial court stayed the flow rate order and modified the injunction, but the water agencies appealed the injunction and the order setting a flow rate.The California Court of Appeal, Fifth Appellate District, held that under the self-executing provisions of article X, section 2 of the state Constitution, courts must always consider the reasonableness of water use when adjudicating such cases. The court found that the trial court's failure to consider the reasonableness of the water use it was ordering in the injunction was a constitutional error. Consequently, the appellate court reversed the injunction and the order setting a flow rate and remanded the case for further proceedings. The appellate court also addressed issues related to the bond requirement and the due process rights of the water agencies, concluding that the trial court erred in setting a nominal bond and in issuing an implementation order that affected the water agencies without their agreement. View "Bring Back the Kern v. City of Bakersfield" on Justia Law

Two plaintiffs, Beth Cummings and Dena Burnham Johnson, filed a petition to annul or void an election that provided additional funds for the Great Falls Public Library. They alleged discrepancies in the election process, including a mathematical error in the ballot and a lack of clear information provided to voters. The election, held in June 2023, resulted in the approval of a mill levy increase to support the library.The Eighth Judicial District Court of Montana dismissed the plaintiffs' petition under Rule 12(b)(6) for failure to state a legally cognizable claim. The court found that the plaintiffs' allegations did not demonstrate a violation of their constitutional rights to suffrage or due process. The court also noted that the mathematical error on the ballot was minor and did not mislead voters to the extent that it would invalidate the election results. Additionally, the court determined that the plaintiffs' claims of election law violations were not applicable to the mill levy election.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision. The court held that the plaintiffs' right of suffrage was not violated, as they were not prevented from voting and were not misled by the ballot language. The court also concluded that the due process claim was unfounded, as the election process and materials provided sufficient information to voters. Furthermore, the court agreed with the lower court that the plaintiffs' claims under state election laws were not relevant to the mill levy election.The Supreme Court also upheld the lower court's denial of the plaintiffs' motion to amend their petition, finding that the proposed amendments would be futile and would cause substantial prejudice to the defendants. The court concluded that the plaintiffs' additional legal arguments did not present a valid controversy and that the defendants had already expended significant resources in the case. View "Cummings v. Kelly" on Justia Law