Justia Constitutional Law Opinion Summaries

Jason Wayne Gowen, a pretrial detainee at the Lynchburg Adult Detention Center, was placed in solitary confinement for 125 days after complaining about hot conditions in his cell and encouraging other inmates to do the same. Gowen filed a lawsuit against several correctional officers, alleging violations of his First Amendment rights due to retaliation for his grievances and his Fourteenth Amendment rights for being placed in solitary confinement without due process.The United States District Court for the Western District of Virginia dismissed Gowen’s First Amendment retaliation claim, stating that he failed to show a causal connection between his grievances and the adverse actions taken against him. The court later granted summary judgment to the officers on Gowen’s Fourteenth Amendment due process claim, concluding that he failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Gowen adequately alleged a First Amendment retaliation claim by showing that he engaged in protected activity, faced adverse action, and established a causal connection through temporal proximity and the officers' awareness of his grievances. The court also determined that Gowen did not forfeit his argument regarding the exhaustion of administrative remedies, as his verified complaint contained sufficient evidence of his attempts to use the grievance process and the officers' failure to respond.The Fourth Circuit reversed the district court’s dismissal of Gowen’s First Amendment retaliation claim and vacated the summary judgment on his Fourteenth Amendment due process claim. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Gowen v. Winfield" on Justia Law

In the spring of 2018, People's Electric Cooperative and Oklahoma Gas and Electric Company (OG&E) submitted competing bids to provide retail electric service to the Tall Oak Woodford Cryo Plant in Coal County, Oklahoma. The Plant is located in People's certified territory, which grants them exclusive rights to provide electricity under the Retail Electric Supplier Certified Territory Act (RESCTA). OG&E's proposal relied on the Large Load exception to RESCTA, which allows a supplier to extend its service into another supplier's territory for large-load customers. OG&E used third-party transmission facilities to provide service to the Plant without extending its own distribution lines.The Oklahoma Corporation Commission enjoined OG&E from serving the Plant, finding that OG&E was not "extending its service" as authorized by RESCTA. The Commission determined that a retail electric supplier may not use third-party transmission lines to extend its service into another supplier's certified territory under the Large Load exception. OG&E appealed the decision.The Supreme Court of the State of Oklahoma reviewed the case and upheld the Commission's determination. The Court held that Article 9, Section 20 of the Oklahoma Constitution requires a limited review of the Commission's order. The Court affirmed the Commission's interpretation that the Large Load exception does not permit a supplier to use third-party transmission lines to extend its service into another supplier's certified territory. The Court's decision applies prospectively only and does not affect existing retail electric services and facilities established under the Large Load exception. View "OKLAHOMA GAS AND ELECTRIC CO. v. STATE" on Justia Law

Jackson Daniel Bowers was convicted in 2019 of possession of heroin with intent to distribute and sentenced to 36 months imprisonment followed by three years of supervised release. In 2023, while on supervised release, Bowers was accused of committing two state crimes: fourth-degree assault and violating a protective order. His probation officer recommended revoking his supervised release. Bowers resolved his state charges by entering a deferral agreement without admitting guilt.The United States District Court for the Eastern District of Washington held a revocation hearing. Bowers requested a jury trial, which the district court denied. The court found by a preponderance of the evidence that Bowers had committed the alleged violations and revoked his supervised release, sentencing him to nine months imprisonment followed by 36 months of supervised release. Bowers appealed, arguing that Article III, Section 2 of the Constitution guarantees the right to a jury trial in revocation proceedings, separate from the Sixth Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Article III’s jury provision and the Sixth Amendment are equivalent in scope. It found that the history and precedent indicate that the Sixth Amendment was meant to complement, not supersede, Article III. Therefore, a right not triggered by the Sixth Amendment cannot be independently triggered by Article III. The Ninth Circuit affirmed the district court’s revocation of Bowers’ supervised release. View "United States V. Bowers" on Justia Law

Reed Day and Albert Jacobs, Arizona residents, wanted to ship wine directly from out-of-state retailers who do not have in-state premises in Arizona. Arizona law, however, requires retailers to have a physical presence in the state to ship wine directly to consumers. Plaintiffs filed a civil rights action under 42 U.S.C. § 1983 against Arizona state officials, claiming that this statutory scheme violates the Commerce Clause.The United States District Court for the District of Arizona granted summary judgment in favor of the state officials and the intervenor-defendant, the Wine and Spirits Wholesalers Association of Arizona. The district court found that the plaintiffs likely lacked standing and that, even if they did, the Arizona laws were not discriminatory. The court reasoned that the physical presence requirement applied equally to in-state and out-of-state retailers and was essential to Arizona’s three-tier system for alcohol distribution.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that the plaintiffs had standing because the district court could grant some form of relief. However, the court found that the plaintiffs failed to show that Arizona’s physical presence requirement was discriminatory. The requirement applied even-handedly to all retailers, regardless of their state of origin, and was not so onerous as to be discriminatory. The court noted that out-of-state businesses could and did obtain retail licenses in Arizona, indicating that the laws did not have a discriminatory effect in practice. The court concluded that Arizona’s laws did not violate the dormant Commerce Clause. View "Day v. Henry" on Justia Law

Evelyn-Natasha La Anyane was convicted of driving under the influence (DUI) of alcohol less safe and other traffic offenses. During a traffic stop, she was read the statutory implied-consent warning and consented to a blood test, which revealed a blood alcohol content above the legal limit. La Anyane argued that Georgia’s implied-consent statutory scheme is unconstitutional, claiming it coerces drivers into consenting to blood tests by falsely stating that refusal can be used against them at trial. She also contended that the trial court made evidentiary errors by not allowing her to cross-examine an expert with a study on field sobriety tests and by admitting evidence of her blood alcohol content.The trial court denied La Anyane’s motion to suppress the blood test results and admitted the evidence at trial. The jury found her guilty of all charges. La Anyane appealed, arguing that the implied-consent warning was unconstitutionally coercive and that the trial court made evidentiary errors.The Supreme Court of Georgia reviewed the case and held that the implied-consent warning was not unconstitutionally coercive. The court found that the warning did not state that consent was mandatory and that the statement about refusal being used at trial was not false. The court also determined that La Anyane’s consent to the blood test was freely and voluntarily given, making the search valid under the Fourth Amendment. Consequently, her as-applied and facial challenges to the implied-consent statutory scheme failed.Regarding the evidentiary issues, the court held that the trial court did not abuse its discretion in excluding the study on field sobriety tests due to lack of proper foundation and in admitting evidence of La Anyane’s blood alcohol content, as it was relevant to the DUI less safe charge and not unfairly prejudicial. The Supreme Court of Georgia affirmed the trial court’s judgment. View "LA ANYANE v. THE STATE" on Justia Law

James Christopher Jones was charged with murder after police identified her using cell phone location history obtained through search warrants. The warrants allowed police to get an anonymized list of devices near the victim’s home during the murder and identifying information for relevant devices. Jones moved to suppress this evidence, arguing the warrants violated the Fourth Amendment due to lack of probable cause and particularity. The trial court denied the motion, and Jones appealed.The trial court found the warrants were supported by probable cause and were sufficiently particular. The first warrant was based on evidence that the suspect used a cell phone near the victim’s home, and the second warrant, obtained after analyzing the anonymized data, identified a specific device linked to the suspect. The court concluded that the affidavits provided a fair probability that the location data and identifying information would yield evidence of the crime. The court also found the warrants were particular enough, specifying the crime, date, time, location, and a reasonable 100-meter radius.The Supreme Court of Georgia affirmed the trial court’s decision. The court held that the warrants were supported by probable cause, as the suspect was seen using a cell phone near the crime scene, and the location data was likely to help identify the suspect. The court also found the warrants met the particularity requirement, as they provided specific guidance on the information to be accessed and avoided unfettered discretion. The court rejected Jones’s arguments about overbreadth and lack of particularity, noting that the warrants were appropriately tailored to the investigation and did not authorize a general search. The judgment was affirmed. View "JONES v. THE STATE" on Justia Law

In this case, José M. Rojas-Tapia appealed the denial of his 28 U.S.C. § 2255 petitions for post-conviction relief, which he filed in the District of Puerto Rico. Rojas's convictions and sentences stem from his October 2000 guilty pleas to charges related to two separate post office robberies. The first indictment involved the Levittown Post Office, and the second involved the Sabana Seca Post Office. Both indictments included charges under 18 U.S.C. § 2114(a) for assaulting postal employees with intent to rob, and under 18 U.S.C. § 924(c) for using a firearm during a crime of violence. Additionally, Rojas was charged under 18 U.S.C. § 922(g) for being a felon in possession of a firearm.Rojas did not challenge his convictions or sentences on direct appeal. However, in 2017, he filed two habeas petitions challenging his § 924(c) convictions and the application of the Armed Career Criminal Act (ACCA) to his § 922(g) convictions. He argued that his § 924(c) convictions could not stand under Johnson v. United States (2015) and United States v. Davis (2019), as his underlying offenses did not qualify as crimes of violence. He also contended that his ACCA-enhanced sentences were improper because his prior convictions did not qualify as violent felonies or serious drug offenses.The United States District Court for the District of Puerto Rico denied both petitions. The court concluded that Rojas's federal mail robbery convictions under § 2114(a) qualified as crimes of violence under the force clause of § 924(c). Additionally, the court found that Rojas's prior convictions for attempted murder, second-degree murder, and armed carjacking under Puerto Rico law qualified as violent felonies under the ACCA.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court held that Rojas's convictions for aggravated mail robbery under § 2114(a) qualified as crimes of violence under § 924(c)'s force clause. The court also rejected Rojas's argument that his aiding and abetting convictions did not qualify as crimes of violence, reaffirming that aiding and abetting liability under 18 U.S.C. § 2 does not alter the application of the categorical approach. The court did not address Rojas's ACCA-related arguments, as his request for a Certificate of Appealability on those claims had been denied. View "Rojas-Tapia v. United States" on Justia Law

Ryan Smith was shot and killed by Seattle police officers Christopher Myers and Ryan Beecroft during a response to a 911 call from Smith's girlfriend, Katy Nolan, who reported that Smith was threatening to kill both himself and her with a knife. When the officers arrived, they kicked in the door to Smith's apartment, and within 5.87 seconds, they shot Smith, who was holding a pocketknife. Smith raised his right arm across his chest and took a step forward before being shot. The officers did not issue any warnings before using deadly force.The United States District Court for the Western District of Washington denied the officers' motion for partial summary judgment based on qualified immunity. The district court found that there were factual disputes regarding whether a reasonable officer would have believed Smith posed an immediate threat and whether less drastic measures were feasible. The court concluded that the law was clearly established that officers may not use deadly force against suspects who do not pose an immediate threat.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The Ninth Circuit held that it had jurisdiction over the interlocutory appeal and that, viewing the evidence in the light most favorable to the plaintiffs, the officers were not entitled to qualified immunity. The court determined that a reasonable juror could conclude that Smith did not pose an immediate threat to the officers or others, and that the use of deadly force was not justified. The court emphasized that it was clearly established law that a fatal shooting under these circumstances violated the Fourth Amendment. The Ninth Circuit affirmed the district court's denial of qualified immunity. View "JOHNSON V. MYERS" on Justia Law

The case involves the Consumer Product Safety Commission's (CPSC) second attempt to regulate small, high-powered magnets that pose serious health risks to children when ingested. These magnets, used in various consumer products like jewelry and puzzles, can cause severe internal injuries or death if swallowed. The CPSC's first attempt to regulate these magnets was struck down by the Tenth Circuit in 2016 due to inadequate data supporting the rule. The CPSC then revised its approach and issued a new rule, which is now being challenged by industry groups.The industry groups petitioned for review of the CPSC's new rule, arguing that the CPSC's cost-benefit analysis was flawed and that the rule was promulgated by an unconstitutionally structured agency. They contended that the CPSC's data on magnet ingestions was unreliable, that the CPSC failed to consider the impact of its own enforcement efforts, and that the rule was underinclusive and arbitrary. They also argued that existing voluntary standards were sufficient to address the risks posed by the magnets.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the CPSC's rule was supported by substantial evidence, noting that the CPSC had adequately addressed the shortcomings identified in the previous case and had conducted a thorough cost-benefit analysis. The court also held that the CPSC's structure, which includes removal protections for its commissioners, was constitutional, reaffirming its previous decision in Leachco, Inc. v. Consumer Product Safety Commission.The Tenth Circuit denied the petition for review, upholding the CPSC's rule regulating small, high-powered magnets. The court concluded that the rule was necessary to address the significant health risks posed by these magnets and that the CPSC had acted within its authority in promulgating the rule. View "Magnetsafety.org v. Consumer Product Safety Commission" on Justia Law

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law