Justia Constitutional Law Opinion Summaries

During a shopping trip at Walmart, William Montgomery was stopped by a store employee and subsequently by Officer Armando Cruz, who suspected shoplifting after Montgomery declined to show a receipt. Officer Cruz directed Montgomery to raise his hands, handcuffed him, and proceeded to search his pockets. Without conducting a pat-down, Officer Cruz reached into Montgomery’s pockets, removing a prescription bottle and a wallet, and looked for Montgomery’s driver’s license. Montgomery was detained briefly, but Walmart employees determined he had paid for the items and he was released.Montgomery filed suit in the United States District Court for the District of Colorado, alleging that Officer Cruz violated his Fourth Amendment rights by searching his pockets and wallet without proper justification. Officer Cruz moved for summary judgment on the basis of qualified immunity, arguing that his actions did not violate clearly established law. The district court denied the motion for summary judgment, finding that factual disputes existed regarding whether Officer Cruz had patted Montgomery down before reaching into his pockets and whether Montgomery had consented to the search of his wallet.The United States Court of Appeals for the Tenth Circuit reviewed the denial of summary judgment de novo. The court held that, accepting the district court’s factual conclusions, Officer Cruz’s search of Montgomery’s pockets without a pat-down or arrest constituted a clearly established violation of the Fourth Amendment. The court further concluded that the subsequent search of Montgomery’s wallet was not justified by consent, as any statement made by Montgomery after the illegal search could not retroactively legitimize the search. The Tenth Circuit affirmed the district court’s denial of qualified immunity to Officer Cruz. View "Montgomery v. Cruz" on Justia Law

A Christian ministry in Washington State, organized as a private nonprofit, operates various social service programs such as shelters, health clinics, and meal services, with a central mission to spread the Gospel. The organization requires all employees to adhere to its religious beliefs and practices, including those regarding marriage and sexuality. When hiring for non-ministerial positions (such as IT technician and operations assistant), it screens applicants for agreement with its religious tenets and only hires co-religionists. Anticipating the need to fill numerous non-ministerial roles, the ministry faced applicants who disagreed with its faith-based requirements.After the Washington Supreme Court’s decision in Woods v. Seattle’s Union Gospel Mission, which interpreted the Washington Law Against Discrimination (WLAD) exemption for religious organizations as limited to ministerial positions, the ministry filed a pre-enforcement federal action against the Washington State Attorney General and Human Rights Commission. The Eastern District of Washington initially dismissed the case for lack of standing, but the Ninth Circuit reversed and remanded, finding the ministry had standing. On remand, the district court granted a preliminary injunction, holding the ministry was likely to succeed on its First Amendment claim and enjoining the State from enforcing WLAD against it for hiring only co-religionists in non-ministerial positions. The State appealed.Reviewing the case, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s preliminary injunction. The court held that the church autonomy doctrine, rooted in the First Amendment’s Religion Clauses, protects religious organizations’ decisions to hire co-religionists for non-ministerial roles when those decisions are based on sincerely held religious beliefs. The holding does not extend to discrimination on other grounds and is limited to religious organizations. The Ninth Circuit found all preliminary injunction factors favored the ministry and affirmed the injunction. View "UNION GOSPEL MISSION OF YAKIMA WASHINGTON V. BROWN" on Justia Law

In 2023, Wyoming enacted two laws restricting abortion: the Life is a Human Right Act, which broadly banned abortion procedures with limited exceptions, and a separate statute prohibiting the prescription or use of drugs to induce abortions, also with exceptions. These laws imposed criminal and civil penalties on violators, excluding the pregnant person. After the laws took effect, several plaintiffs—including medical professionals, non-profit organizations, and an individual woman—challenged the statutes in District Court of Teton County, arguing they violated Article 1, Section 38 of the Wyoming Constitution, which guarantees each competent adult the right to make their own health care decisions.The district court granted summary judgment in favor of the plaintiffs, finding that the challenged laws unreasonably and unnecessarily infringed on the constitutional right to make health care decisions, and issued a permanent injunction preventing enforcement of the abortion restrictions. The State of Wyoming appealed directly to the Wyoming Supreme Court.The Wyoming Supreme Court, exercising de novo review, held that the decision to terminate or continue a pregnancy is a health care decision protected by Article 1, Section 38. The Court determined that this provision confers a fundamental right, and that statutes restricting it must satisfy strict scrutiny: the State must show such laws are narrowly tailored to achieve a compelling governmental interest and use the least restrictive means. The majority found that the State failed to present sufficient evidence that the abortion restrictions and their exceptions were the least restrictive means of protecting prenatal life. Accordingly, the Wyoming Supreme Court affirmed the district court’s ruling, holding the 2023 abortion laws unconstitutional under the Wyoming Constitution. View "State of Wyoming v. Johnson" on Justia Law

An 11-year-old child, L.D., was placed in foster care with Trina Mae Johnson. Over a period of fifteen months, Johnson inflicted severe abuse on L.D., including physical torture, starvation, denial of medical care, and psychological torment. The abuse resulted in significant weight loss, untreated injuries, and lasting trauma. Johnson concealed the abuse, enlisted others in her household to participate, and intimidated L.D. into silence. The abuse came to light when Johnson brought L.D. to a youth shelter, prompting an investigation by child services and the FBI.Johnson and several co-defendants were indicted on charges of child torture, child neglect, child endangerment, and assaulting a minor with a dangerous weapon in both federal and Minnesota state law violations. Some co-defendants pleaded guilty, while Johnson’s sister went to trial. Johnson was unable to accept a plea agreement because it was contingent on both sisters pleading guilty. She ultimately pleaded guilty without an agreement. The United States District Court for the District of Minnesota sentenced Johnson to 216 months in prison, after considering the relevant sentencing factors and victim impact statements. The sentence was below the government’s recommendation but above the prior plea offer.On appeal to the United States Court of Appeals for the Eighth Circuit, Johnson argued that the district court judge’s direct, sympathetic comments to L.D. at sentencing demonstrated judicial bias and violated her due process right to an impartial tribunal. The Eighth Circuit applied plain error review, noting Johnson did not object to the judge’s comments at sentencing or seek recusal. The court held that the judge’s empathetic remarks to the victim did not display deep-seated favoritism or antagonism that would make fair judgment impossible. Finding no plain error or due process violation, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Johnson" on Justia Law

On the evening of April 2, 2019, Thedarious Mitchell was shot and killed at a motel in DeKalb County. Security footage captured two men entering Mitchell’s room, followed by a violent altercation and Mitchell’s attempt to flee. As he ran, one of the men shot him in the back. Witness R.W., present during the incident, testified that the shooter was known to her as “Baldhead” or “Chris,” later identifying Christopher Sellers both in a photo lineup and at trial. Another witness, Calvin Leslie, recounted that while incarcerated, Sellers admitted to shooting a man in a Georgia motel. Evidence found at the scene and testimony at trial supported the prosecution’s theory that Sellers was the shooter.A DeKalb County grand jury indicted Sellers on multiple charges, including malice murder and firearm offenses. Following a jury trial in the Superior Court of DeKalb County, Sellers was found guilty on all counts. The court sentenced him to life imprisonment without parole for malice murder, with additional consecutive sentences for firearm offenses. Sellers’ motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.Reviewing the case, the Supreme Court of Georgia affirmed both Sellers’ conviction and his sentence. The Court held that the evidence was constitutionally sufficient to support the malice murder conviction, as a rational jury could have found Sellers guilty beyond a reasonable doubt. The trial court did not plainly err in instructing the jury on parties to a crime, as there was at least slight evidence supporting such a theory. Finally, the sentence of life without parole was not found to be cruel and unusual punishment under the Eighth and Fourteenth Amendments, nor grossly disproportionate to the crime, and thus was affirmed. View "SELLERS v. THE STATE" on Justia Law

A law-abiding resident of Siskiyou County, California, who wished to openly carry a firearm for self-defense, challenged California’s laws that prohibit open carry in counties with populations over 200,000. As a result of these statutes, approximately 95% of California’s population cannot lawfully open carry, while those in less populous counties may theoretically apply for an open-carry license valid only within their county of residence. The plaintiff, after being informed by local authorities that open-carry licenses would not be issued in his county, filed suit against the California Attorney General, raising claims under the Second and Fourteenth Amendments. The complaint contested both the urban open-carry ban and the rural county licensing scheme.Initially, the United States District Court for the Eastern District of California denied the plaintiff’s motion for preliminary injunction and ultimately granted summary judgment to the Attorney General. The district court concluded that the Second Amendment did not protect the plaintiff’s desired conduct and that California’s regulatory scheme was consistent with the nation’s historical firearm tradition. The district court also dismissed as-applied challenges to the rural licensing scheme for lack of standing.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. Applying the historical tradition test outlined in New York State Rifle & Pistol Ass’n v. Bruen, the court held that California’s ban on open carry in urban counties is inconsistent with the Second Amendment, as there is no historical tradition justifying such a broad prohibition. The court reversed the district court’s grant of summary judgment on the urban open-carry ban, remanding with instructions to enter judgment for the plaintiff on that issue. The panel affirmed the district court’s judgment as to the rural licensing scheme, finding that the as-applied challenge was waived and the facial challenge failed under Bruen’s recognition of shall-issue licensing regimes. The district court’s judgment was thus affirmed in part, reversed in part, and remanded. View "BAIRD v. BONTA" on Justia Law

Several individuals and organizations sought to circulate a petition to place a campaign finance ordinance on Houston’s ballot, but the city’s charter at that time required petition circulators to be both residents and registered voters of Houston. The plaintiffs did not meet these requirements. They notified the city of their intent to circulate petitions and challenge the constitutionality of the residency and voter registration requirements. The city initially did not clarify its position but later stated it would not enforce the challenged provisions. Despite this, the plaintiffs filed suit in federal court, seeking injunctive and declaratory relief, arguing that the requirements were unconstitutional under Supreme Court precedent.The United States District Court for the Southern District of Texas first granted the plaintiffs a temporary restraining order barring enforcement of the requirements. After the petition circulation period ended, the court dismissed the claims as moot following a stipulation by the parties. The plaintiffs moved to alter or amend the judgment, which was denied. On appeal, the Fifth Circuit reversed, holding that the plaintiffs had standing and that the case was not moot, and remanded for further proceedings. On remand, the district court granted the plaintiffs declaratory relief and, after the city repealed the challenged provisions, awarded the plaintiffs attorneys’ fees as prevailing parties. However, in a subsequent appeal, a different Fifth Circuit panel concluded there was no case or controversy because all parties agreed the provisions were unconstitutional, vacated the judgment, and remanded for dismissal.On remand, the district court vacated the attorneys’ fees award and ordered reimbursement to the city. The United States Court of Appeals for the Fifth Circuit affirmed this ruling, holding that after the prior appellate decision vacated the underlying merits judgment for lack of a case or controversy, there was no basis for a fee award under Rule 60(b)(5). The court also clarified that the city was not required to appeal the fee award directly, and the plaintiffs’ claims of prejudice were unavailing. View "Pool v. City of Houston" on Justia Law

Plaintiffs, which are corporate entities owned by Kenneth Gay, challenged cannabis dispensary licensing schemes in Washington State and the City of Sacramento. Both jurisdictions require applicants to have been residents of the respective area for a specified period to be eligible for a dispensary license, or to receive priority in licensing. Plaintiffs applied for licenses in both places, but their applications were rejected solely for failing to meet the residency requirements, despite fulfilling all other criteria. Plaintiffs then filed lawsuits, alleging that these residency preferences violate the dormant Commerce Clause by discriminating against out-of-state economic interests in the cannabis market.In the Western District of Washington and the Eastern District of California, the district courts dismissed the actions at the Rule 12(b)(6) stage and denied preliminary injunctions. Both courts found that the dormant Commerce Clause does not apply to residency requirements for cannabis dispensaries because marijuana remains illegal under federal law. They reasoned that the constitutional protection of interstate commerce does not extend to a market Congress has expressly prohibited.The United States Court of Appeals for the Ninth Circuit reviewed the consolidated appeals. It affirmed both district courts’ dismissals, holding that the dormant Commerce Clause does not apply to state or local laws restricting licensing in a market (cannabis) that Congress has deemed illegal. The Ninth Circuit declined to extend dormant Commerce Clause protections to interstate commerce in a federally prohibited drug market, noting that Supreme Court precedent counsels “extreme caution” before exercising implied authority in this area. The panel found insufficient basis to use the judge-made dormant Commerce Clause to create a constitutional right to interstate cannabis commerce that is unlawful under federal law. Thus, both judgments were affirmed. View "PERIDOT TREE WA, INC. v. WASHINGTON STATE LIQUOR AND CANNABIS CONTROL BOARD" on Justia Law

Several trusts and entities purchased properties in Nevada that were subject to deeds of trust held by Fannie Mae or Freddie Mac. After unsuccessful attempts in state court to extinguish the deeds of trust and quiet title, each property remained encumbered. Between 2022 and 2024, foreclosure proceedings were initiated on these properties, with Fannie Mae and Freddie Mac acting through their conservator, the Federal Housing Finance Agency (FHFA). In response, the plaintiffs brought suit against the FHFA and its Director, seeking to prevent foreclosure and challenging the constitutionality of the FHFA’s funding mechanism under the Appropriations Clause and the nondelegation doctrine.The United States District Court for the District of Nevada reviewed the case. The district court denied the plaintiffs’ motions for preliminary relief, then dismissed their amended complaint with prejudice, finding that the FHFA’s funding structure was constitutional. The court determined that the Recovery Act, which created the FHFA and provides for its funding via regulatory assessments rather than Congressional appropriations, met constitutional standards by specifying both a source and purpose for the funds. The court also found that the Recovery Act’s limitation to “reasonable costs” provided an intelligible principle, satisfying the nondelegation doctrine. Leave to amend was denied as futile.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The appellate court held that the plaintiffs had Article III standing, but rejected their arguments on the merits. It concluded that the FHFA’s funding mechanism, as established by the Recovery Act, does not violate the Appropriations Clause because it identifies a source and purpose for expenditures, consistent with the Supreme Court’s decision in Consumer Financial Protection Bureau v. Community Financial Services Association of America, Limited. It further held the mechanism does not violate the nondelegation doctrine, as the statute provides an intelligible principle. The judgment of dismissal was affirmed. View "DAISEY TRUST v. FEDERAL HOUSING FINANCE AGENCY" on Justia Law

Thomas Sanderson, a registered sex offender in Missouri, challenged a statutory provision requiring all registered sex offenders to post a sign at their residence on Halloween stating, “No candy or treats at this residence.” Sanderson had a history of elaborate Halloween displays, but after his 2006 conviction and imprisonment, he was informed by police that he was “grandfathered in” and could continue participating in Halloween festivities. This changed in 2022 when Hazelwood police arrested and convicted him for violating the statute, specifically the sign mandate. Sanderson then brought a facial challenge under the First Amendment, arguing that the mandate compelled speech.The United States District Court for the Eastern District of Missouri first granted a preliminary injunction, finding Sanderson was likely to succeed on the merits. After a bench trial, the court found that the sign mandate was unconstitutional compelled speech under the First Amendment and issued a permanent injunction barring enforcement of the mandate statewide. The State appealed, contesting both the constitutional ruling and certain evidentiary decisions made during the trial.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error, applying heightened scrutiny to facts relevant to the First Amendment claim. The appellate court held that the sign mandate compelled speech and thus required strict scrutiny. While the State’s interest in protecting children on Halloween was compelling, the court found the sign mandate was not narrowly tailored to achieve that interest. The evidence failed to show the signs provided any additional protection beyond existing restrictions, and no justification was presented for their necessity. The Eighth Circuit affirmed the district court’s holding that the sign mandate facially violates the First Amendment, vacated the injunction due to recent Supreme Court precedent, and remanded for reconsideration of the scope of injunctive relief. View "Sanderson v. Hanaway" on Justia Law