Justia Constitutional Law Opinion Summaries

Atravius Weeks was indicted for first-degree premeditated murder, first-degree domestic abuse murder, and second-degree intentional murder after he confessed to shooting and killing Cortney Henry in Dakota County, Minnesota. The incident occurred in June 2021, and Weeks was apprehended shortly after the crime. At trial, Weeks raised concerns about the racial composition of the jury panel, noting that Black individuals were underrepresented compared to the county’s population. He argued that the jury pool did not reflect a fair cross-section of the community, as required by the Constitution.The Dakota County District Court denied Weeks’s request for a new jury panel and, after a jury found him guilty on all counts, entered convictions for all three murder charges. Weeks’s direct appeal was stayed to allow him to file a postconviction petition, which included an expert affidavit suggesting that the use of voter registration and driver’s license lists for jury selection systematically underrepresents Black people. The district court summarily denied the postconviction petition, finding that Weeks failed to show systematic exclusion of Black jurors under the three-prong test from State v. Williams, and cited prior Minnesota cases holding that the jury selection process does not systematically exclude people of color.The Minnesota Supreme Court reviewed the case and held that the district court abused its discretion by summarily denying the postconviction petition. The Supreme Court found that, when the facts alleged are viewed in the light most favorable to Weeks, the record does not conclusively show he is entitled to no relief, and genuine issues of material fact remain regarding systematic exclusion. The Court also held that the district court violated Minnesota Statutes section 609.04 by entering convictions for both first-degree domestic abuse murder and second-degree intentional murder in addition to first-degree premeditated murder. The Supreme Court reversed and remanded for an evidentiary hearing and ordered the vacation of the lesser murder convictions. View "State of Minnesota vs. Weeks" on Justia Law

A flight attendant employed by an airline and represented by a labor union was terminated after sending graphic anti-abortion images and messages to the union president and posting similar content on social media. The employee, a pro-life Christian and vocal opponent of the union, had previously resigned her union membership but remained subject to union fees. The union’s leadership had participated in the Women’s March, which the employee viewed as union-sponsored support for abortion, prompting her messages. The airline investigated and concluded that while some content was offensive, only certain images violated company policy. The employee was terminated for violating social media, bullying, and harassment policies.Following termination, the employee filed a grievance, which the union represented. The airline offered reinstatement contingent on a last-chance agreement, which the employee declined, leading to arbitration. The arbitrator found just cause for termination. The employee then sued both the airline and the union in the United States District Court for the Northern District of Texas, alleging violations of Title VII and the Railway Labor Act (RLA), among other claims. The district court dismissed some claims, allowed others to proceed, and after a jury trial, found in favor of the employee on several Title VII and RLA claims. The court awarded reinstatement, backpay, and issued a broad permanent injunction against the airline and union, later holding the airline in contempt for its compliance with the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit reversed the judgment for the employee on her belief-based Title VII and RLA retaliation claims against the airline, remanding with instructions to enter judgment for the airline on those claims. The court affirmed the judgment against the airline on practice-based Title VII claims and affirmed all claims against the union. The court vacated the permanent injunction and contempt sanction, remanding for further proceedings, and granted the employee’s motion to remand appellate attorney’s fees to the district court. View "Carter v. Transport Workers Union of America Local 556" on Justia Law

The plaintiff alleged that he was sexually abused by a priest while attending a summer camp in the mid-1970s, which was managed by the defendants. At the time of the alleged abuse, New Hampshire law required minors to bring personal actions within two years after reaching the age of majority. The plaintiff, born in 1966, did not file his complaint before the limitations period expired in 1986. Decades later, the legislature amended the relevant statute, RSA 508:4-g, first to extend and then, in 2020, to remove the statute of limitations for personal actions based on sexual assault. The plaintiff filed his complaint in 2023, seeking to take advantage of the amended law.The Superior Court (Leonard, J.) dismissed the complaint, holding that the claim was time-barred because the statute of limitations had expired in 1986. The court further ruled that applying the 2020 amendment to revive the plaintiff’s claim would violate Part I, Article 23 of the New Hampshire Constitution, which prohibits retrospective laws. The plaintiff’s motion to reconsider was denied, and he appealed.The Supreme Court of New Hampshire reviewed the case de novo. It assumed, without deciding, that the legislature intended the 2020 amendment to apply retroactively, but held that doing so would be unconstitutional. The court reaffirmed longstanding precedent that a defendant acquires a vested right to a statute of limitations defense once the limitations period has expired, and that this right cannot be abrogated by subsequent legislation. The court declined to overrule this precedent or to adopt a balancing test weighing the plaintiff’s right to recover against the defendants’ vested right. The Supreme Court of New Hampshire affirmed the dismissal, holding that the constitutional prohibition against retrospective laws precludes application of the amended statute to revive the plaintiff’s time-barred claim. View "Ball v. Roman Catholic Bishop of Manchester" on Justia Law

In this case, a group consisting of an alumni association and several descendants of Serranus Clinton Hastings challenged the enactment of Assembly Bill 1936, which changed the name of “Hastings College of the Law” to “College of the Law, San Francisco” and eliminated a statutory requirement that a seat on the College’s board of directors be reserved for an heir or representative of S.C. Hastings. The plaintiffs argued that the original 1878 Act establishing the College constituted a binding contract between the State and S.C. Hastings and his descendants, and that the new legislation violated constitutional protections, including the Contract Clauses, the prohibition on bills of attainder and ex post facto laws, and the California Constitution’s provision regarding collegiate freedom.The Superior Court of the City and County of San Francisco sustained the defendants’ demurrer without leave to amend, finding that the plaintiffs failed to establish that the 1878 Act was a contract rather than an exercise of legislative power. The court also determined that Assembly Bill 1936 did not constitute a bill of attainder or ex post facto law, and that the changes to the College’s name and governance did not violate the California Constitution, particularly since the College’s board had requested the name change.The California Court of Appeal, First Appellate District, Division Four, reviewed the case de novo and affirmed the trial court’s judgment. The appellate court held that the State could not contract away its sovereign authority to manage a public institution, including the power to change the College’s name or governance structure. The court further concluded that Assembly Bill 1936 was not punitive and did not violate constitutional prohibitions on bills of attainder or ex post facto laws. The court also found no violation of the California Constitution’s collegiate freedom provision, as the changes were initiated by the College’s board. The judgment in favor of the State and College defendants was affirmed. View "Hastings College Conservation Committee v. State" on Justia Law

Two inmates in Virginia, each serving sentences for attempted aggravated murder, were initially informed by the Department of Corrections that they would be released in July 2022 due to a new state law expanding sentence credits for good behavior. This law, H.B. 5148, allowed certain inmates to earn more credits and thus reduce their incarceration time. However, after a change in the Attorney General’s office, the new Attorney General issued an advisory opinion stating that inmates convicted of inchoate offenses related to aggravated murder were not eligible for the enhanced credits. As a result, the Department reversed its earlier decision and kept the inmates incarcerated for an additional year, until the Supreme Court of Virginia later clarified that such inmates were indeed eligible for the credits and ordered their release.The inmates then filed a lawsuit in the United States District Court for the Eastern District of Virginia, seeking damages under 42 U.S.C. § 1983. They alleged that the Attorney General and the Director of Corrections violated their Eighth and Fourteenth Amendment rights by acting with deliberate indifference to their over-incarceration. The district court dismissed the complaint, finding that both officials had acted reasonably in interpreting an unsettled question of state law and that their conduct did not rise to the level of deliberate indifference or conscience-shocking behavior.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the officials’ actions did not constitute deliberate indifference under the Eighth Amendment, nor did they shock the conscience under the Fourteenth Amendment. The court emphasized that federal courts should not hold state officials personally liable for reasonable legal interpretations of unsettled state law, especially when those interpretations are made in good faith and with conventional legal reasoning. View "Swart v. Miyares" on Justia Law

Several individuals and a firearms association challenged provisions of New York’s Concealed Carry Improvement Act (CCIA) that require ammunition sellers to conduct background checks on purchasers, pay a $2.50 fee per check, and register with the Superintendent of the New York State Police. The plaintiffs alleged that these requirements deterred them from purchasing or selling ammunition, and that one plaintiff was unable to complete a purchase due to a system failure. They also claimed that dealers were passing the background check fee onto purchasers, and that the registration requirement deterred private sales.The United States District Court for the Western District of New York found that the association lacked standing but that the individual plaintiffs did have standing to challenge the provisions. The district court denied a preliminary injunction, concluding that the plaintiffs were unlikely to succeed on the merits of their Second Amendment claims because the state had shown that the provisions were consistent with the nation’s historical tradition of firearm regulation, as required by the framework set out in New York State Rifle & Pistol Ass’n, Inc. v. Bruen.On appeal, the United States Court of Appeals for the Second Circuit agreed that the individual plaintiffs had standing. However, the Second Circuit affirmed the denial of a preliminary injunction on different grounds. The court held that the plaintiffs failed to show that the background check, fee, and registration provisions meaningfully constrained their ability to “keep” or “bear” arms under the first step of the Bruen framework. Because the plaintiffs did not meet this threshold, the court did not address the historical analysis. The Second Circuit affirmed the district court’s order and remanded for further proceedings. View "N.Y. State Firearms Ass'n v. James" on Justia Law

The case concerns a man who lived with his father in Barrow County, Georgia, and was accused of killing a family friend who often stayed at their home. After the friend’s disappearance, the accused made suspicious statements to his father, and the friend’s body was later found in the trunk of his own car, having been shot multiple times. The accused was apprehended after fleeing from law enforcement, and during post-arrest interviews, he admitted to the killing and provided details that were corroborated by physical evidence. At trial, he testified that he shot the victim after a confrontation related to past sexual abuse and introduced evidence about his methamphetamine use and its effects.A Barrow County grand jury indicted the accused on multiple charges, including malice murder, felony murder, aggravated assault, firearm possession during a felony, concealing a death, and methamphetamine possession. After a jury trial in the Superior Court of Barrow County, he was found guilty on all counts. The court sentenced him to life plus eighteen years in prison, with certain counts merging or being vacated as a matter of law. The defendant’s motion for a new trial was denied, and he appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed three main claims: the failure to give a jury instruction on voluntary intoxication, the admission of prior-act evidence under Georgia’s Rule 404(b), and the admission of his post-arrest statements. The Court held that the trial court properly declined the requested intoxication instruction because it misstated the law, any error in admitting the prior-act evidence was harmless given the overwhelming evidence of guilt, and the admission of the defendant’s statements did not violate due process because there was no evidence of police coercion. The Supreme Court of Georgia affirmed the convictions. View "WOSCHULA v. THE STATE" on Justia Law

Owners of developed commercial and residential properties in Athens-Clarke County challenged the county’s stormwater utility charge, arguing that it was an unconstitutional tax rather than a fee. The charge, established by county ordinances in 2004, funds stormwater management services required by federal law, with the amount assessed based on impervious surface area and land-use classification. The ordinance exempts certain properties, such as public roads and sidewalks, and offers credits for on-site stormwater management. The funds collected are used for flood prevention, pollution minimization, and compliance with federal regulations.Previously, the Superior Court of Athens-Clarke County granted summary judgment to the county, finding that the stormwater utility charge was a fee, not a tax, and thus not subject to the Georgia Constitution’s taxation uniformity provision. This decision relied on the Georgia Supreme Court’s earlier ruling in Homewood Village, LLC v. Unified Government of Athens-Clarke County, which had addressed the same ordinance and held it imposed a fee rather than a tax. The appellants also pursued related claims in federal court, but those were dismissed on abstention grounds.On appeal, the Supreme Court of Georgia affirmed the trial court’s decision. The court held that its prior decision in Homewood Village, LLC v. Unified Government of Athens-Clarke County controlled, reaffirming that the stormwater utility charge is a fee and not a tax, and therefore the uniformity provision does not apply. The court also rejected the appellants’ arguments that the charge constituted an unconstitutional taking under the Georgia and United States Constitutions, finding no basis for such a claim. Finally, the court found that the trial court had properly applied the summary judgment standard and had not improperly resolved factual disputes. The judgment in favor of the county was affirmed. View "HOMEWOOD ASSOCIATES INC. v. UNIFIED GOVERNMENT OF ATHENS-CLARKE COUNTY" on Justia Law

Two middle school students in Michigan wore sweatshirts displaying the phrase “Let’s Go Brandon” to school, intending to express disapproval of then-President Joe Biden. School administrators asked the students to remove the sweatshirts, interpreting the phrase as a euphemism for a vulgar anti-Biden chant. The students complied but, through their mother, later sued the school district and two administrators, alleging a violation of their First Amendment rights.The United States District Court for the Western District of Michigan granted summary judgment to the school district and administrators. The court found that the school’s dress code permitted the prohibition of apparel reasonably interpreted as profane or vulgar, and that the administrators’ interpretation of the phrase as vulgar was reasonable. The court concluded that the students’ constitutional rights were not violated, and dismissed all claims with prejudice.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The Sixth Circuit held that school administrators may prohibit student speech that is reasonably understood as vulgar, even if the speech is political in nature and uses euphemism rather than explicit profanity. The court found that the administrators’ interpretation of “Let’s Go Brandon” as vulgar was reasonable given its widely understood meaning. The court further held that, under Supreme Court precedent, the school’s interest in prohibiting vulgar speech outweighs the student’s interest in political expression in this context. The Sixth Circuit affirmed the district court’s judgment in favor of the school district and administrators. View "B. A. v. Tri-County Area Schools" on Justia Law

Two men were apprehended by the United States Coast Guard in international waters south of Puerto Rico after being observed jettisoning bales of cocaine from a vessel that lacked any indication of nationality. The Coast Guard recovered approximately 306 kilograms of cocaine and eventually transported the men, including the appellant, to St. Thomas in the U.S. Virgin Islands. The government asserted that the men were never brought to Puerto Rico, though the appellant disputed this. A grand jury in the District of the Virgin Islands indicted the appellant on multiple drug trafficking charges under the Maritime Drug Law Enforcement Act (MDLEA), as well as related offenses.The appellant moved to dismiss the indictment for improper venue, arguing that the MDLEA’s “any district” venue provision was unconstitutional and that venue was proper in Puerto Rico, where he claimed he was first brought. He also sought a pretrial evidentiary hearing on venue and the issuance of subpoenas for Coast Guard witnesses. The United States District Court of the Virgin Islands denied these motions, holding that the MDLEA’s venue provision was constitutional and that the Virgin Islands was a proper venue. The court also found that mere passage through Puerto Rico’s territorial waters did not constitute being “first brought” there under 18 U.S.C. § 3238, and denied the request for an evidentiary hearing, finding no colorable factual dispute that would affect the outcome.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit held that the MDLEA’s “any district” venue provision is constitutional, both facially and as applied, for offenses committed on the high seas. The court also found that the District Court did not abuse its discretion in denying a pretrial evidentiary hearing on venue. Accordingly, the Third Circuit affirmed the District Court’s orders. View "USA v. Cuevas-Almonte" on Justia Law