Justia Constitutional Law Opinion Summaries

A group of out-of-state pig farmers and a pork processor challenged a Massachusetts law that prohibits the use of certain confinement methods for breeding pigs (specifically, gestation crates) and bans the sale in Massachusetts of pork products derived from pigs confined in such a manner. The plaintiffs, who operate outside Massachusetts and use these confinement methods, argued that the law discriminates against out-of-state producers and is preempted by federal statutes. The law was enacted by ballot initiative and became enforceable after the Supreme Court’s decision in National Pork Producers Council v. Ross.The United States District Court for the District of Massachusetts dismissed most of the plaintiffs’ claims, including those based on the Privileges and Immunities Clause, preemption by the Federal Meat Inspection Act (FMIA) and the Packers and Stockyards Act (PSA), the Full Faith and Credit Clause, the Due Process Clause, and the Import-Export Clause. The court allowed the dormant Commerce Clause claim to proceed, but ultimately granted summary judgment against the plaintiffs on that claim as well, after severing a provision of the law that it found discriminatory (the “slaughterhouse exemption”). The court found that the remaining provisions of the law did not discriminate against out-of-state interests and did not impose a substantial burden on interstate commerce.The United States Court of Appeals for the First Circuit affirmed the district court’s rulings. The First Circuit held that the Massachusetts law does not discriminate against out-of-state producers in purpose or effect, does not impose a substantial burden on interstate commerce under the Pike balancing test, and is not preempted by the FMIA or PSA. The court also rejected the plaintiffs’ claims under the Privileges and Immunities Clause, Full Faith and Credit Clause, Due Process Clause, and Import-Export Clause. The court found no procedural error in the district court’s handling of the case. View "Triumph Foods, LLC v. Campbell" on Justia Law

In the summer of 2017, an individual and two accomplices committed a series of armed robberies at Walmart stores in Florida, following a consistent pattern of masked, armed entry, coercion of store managers to access cash, and escape in stolen vehicles. The group obtained approximately $100,000 in total. After law enforcement apprehended the accomplices, one of whom was the individual’s cousin, evidence including cell phone data and testimony from a cooperating accomplice implicated the individual. He was indicted on five robbery and firearm charges.The case proceeded to trial in the United States District Court for the Middle District of Florida. The defendant, represented by an attorney who was later disbarred, rejected two plea offers and maintained his innocence, asserting alibis for each incident. His attorney unsuccessfully attempted to secure the cousin’s testimony and sought continuances, which the court denied. At trial, the government presented testimony from the cooperating accomplice and cell phone evidence. The defendant testified in his own defense, denying involvement. The jury convicted him on all counts, and he was sentenced to 319 months’ imprisonment. His direct appeal was affirmed by the United States Court of Appeals for the Eleventh Circuit, which found no arguable issues for review.Subsequently, the defendant filed a motion under 28 U.S.C. § 2255, alleging ineffective assistance of counsel for misadvising him about plea offers and failing to call his cousin as a witness. The district court denied the motion without an evidentiary hearing. On appeal, the United States Court of Appeals for the Eleventh Circuit held that, although counsel’s performance was deficient, the defendant failed to show prejudice as required by Strickland v. Washington. The court affirmed the district court’s denial of relief, concluding there was no reasonable probability that the outcome would have been different absent counsel’s errors. View "Catrell Ivory v. USA" on Justia Law

After being convicted of second-degree sexual assault in Garland County, Arkansas, Harl Garrett was sentenced to 20 years in prison. Garrett requested his attorney, Ben Hooten, to file an appeal, but instead, Hooten moved to withdraw as counsel without filing the notice of appeal. Garrett was not informed of the withdrawal order until after the 30-day window for filing a direct appeal had expired. Garrett attempted to file a pro se notice of appeal and later submitted motions for a belated appeal and to proceed in forma pauperis, but these were denied by both the Garland County Circuit Court and the Arkansas Supreme Court. Garrett subsequently filed a state postconviction petition, which was also denied as untimely.Garrett then filed a federal habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the Eastern District of Arkansas, raising the claim that he was denied his constitutional right to a direct appeal due to counsel and court failures. The district court denied the petition as time-barred under the one-year statute of limitations set by the Antiterrorism and Effective Death Penalty Act (AEDPA), finding that the limitations period began when Garrett learned of his attorney’s abandonment and expired before the federal petition was filed. However, the district court granted a certificate of appealability on whether Garrett’s motion for a belated appeal tolled the AEDPA limitations period under 28 U.S.C. § 2244(d)(2).The United States Court of Appeals for the Eighth Circuit reviewed the case and held that a motion for belated appeal in Arkansas constitutes “collateral review” under AEDPA, thus tolling the statute of limitations while the motion is pending. The court reversed the district court’s judgment and remanded the case for further proceedings, concluding that Garrett’s federal habeas petition was timely. View "Garrett v. Payne" on Justia Law

A group of fourteen taxpayers, all out-of-state owners, operators, or lessees of multifamily housing developments in the City of Tuscaloosa, challenged a city ordinance that amended the business-license fee structure. The ordinance, effective April 2022, imposed a 3% business-license fee on rents received from student-oriented housing developments (SOHDs) with more than 200 bedrooms, while other rental properties remained subject to a 1% fee. The SOHD designation is determined by the city’s zoning officer based on a non-exhaustive list of characteristics and factors. The taxpayers alleged that the ordinance unfairly targeted out-of-state owners and was vague in its application.The taxpayers filed suit in the Tuscaloosa Circuit Court, seeking a declaration that the ordinance was invalid and a refund of taxes paid. They raised claims under the Equal Protection and Due Process Clauses, the dormant Commerce Clause, and argued that the ordinance was essentially a zoning ordinance adopted without following statutory notice requirements. The trial court granted the City’s motion to dismiss under Rule 12(b)(6), finding the complaint insufficient to state a claim.On appeal, the Supreme Court of Alabama reviewed whether the complaint alleged sufficient facts to survive dismissal. The court held that the taxpayers’ claims under the Equal Protection Clause, Due Process Clause (vagueness), and dormant Commerce Clause were sufficiently pleaded to withstand a motion to dismiss, as the allegations, if proven, could entitle the taxpayers to relief. However, the court affirmed the dismissal of the claim that the ordinance was a zoning ordinance subject to statutory notice requirements, finding the ordinance did not regulate property use in the manner of zoning laws. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Campus Crest at Tuscaloosa LLC v. City of Tuscaloosa" on Justia Law

Ann Tierney Smith owned real property in West Virginia but failed to pay the assessed real estate taxes for 2016. As a result, the Mercer County Sheriff sold a tax lien on the property to Ed Boer. Boer sought a tax deed and provided the West Virginia State Auditor’s Office with a list of individuals to be notified about the right to redeem the property, including Smith. However, Boer did not include Smith’s current mailing address, which was available in county records. Notices sent by mail were returned as undeliverable, and attempts at personal service were unsuccessful, leading to notices being posted at the property and other addresses. After the redemption deadline passed, G. Russell Rollyson, Jr., an employee of the State Auditor’s Office, issued a tax deed to Boer. Smith learned of the deed in late 2020.Smith, and later her estate representatives, sued Rollyson and Boer under 42 U.S.C. § 1983, alleging deprivation of property without due process. The United States District Court for the Southern District of West Virginia granted summary judgment to Rollyson, finding him entitled to qualified immunity. The court determined that while Rollyson could have directed Boer to search county records for Smith’s address after the mailed notices were returned, the duty to do so was not clearly established at the time. The estate representatives appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment and qualified immunity rulings de novo. The Fourth Circuit held that it was not clearly established on April 1, 2019, that Rollyson was required to have Boer search county records anew for Smith’s address after the mailed notices were returned. The court found that existing precedent did not prescribe a specific follow-up measure and that Rollyson’s actions did not violate clearly established law. The judgment of the district court was affirmed. View "Ann deWet v. G. Russell Rollyson, Jr." on Justia Law

Muhammad Arif, the owner of convenience stores in Arkansas, was accused of soliciting a fifteen-year-old girl, the daughter of his handyman, to engage in sexual acts in exchange for money on two occasions in 2019. Both incidents occurred while Arif was driving the girl home in his vehicle. The girl declined his advances, recorded the conversations, and later reported the incidents to her parents and the police. Arif was initially prosecuted under Arkansas state law, but the federal government took over, charging him under 18 U.S.C. § 1591(a)(1), which criminalizes commercial sex trafficking of a minor “in or affecting interstate or foreign commerce.”The United States District Court for the Eastern District of Arkansas presided over the trial. After the jury found Arif guilty, he moved for a judgment of acquittal, arguing that the government failed to prove the required element that his conduct affected interstate commerce. The district court agreed, granting the motion and concluding that merely driving a car manufactured out of state and giving money to the victim did not constitute an actual effect on interstate commerce as required by precedent.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo, considering whether the evidence was sufficient to establish the interstate commerce element of the federal statute. The appellate court held that the government’s evidence—Arif’s use of a car manufactured in another state, the transfer of $20, and the use of local roadways—was insufficient to show an actual effect on interstate commerce. The court distinguished this case from others where use of the internet, interstate travel, or communications had a clear impact on commerce. The Eighth Circuit affirmed the district court’s judgment of acquittal. View "United States v. Arif" on Justia Law

Matthew Smith was charged with first degree murder following a shooting outside the Press Box bar in August 2012. Multiple eyewitnesses identified Smith as the shooter, both in police lineups and at trial. The lineups included fillers who differed from Smith in age and hairstyle, and in the second lineup, Smith wore a distinctive red and white shirt that witnesses had described the shooter as wearing. Physical evidence included shell casings and a revolver found in a vehicle from which Smith fled, as well as a photograph of Smith in the bar wearing the same shirt. Smith’s mother was excluded from the courtroom during parts of the trial because she was listed as a potential witness.The Cook County Circuit Court denied Smith’s motions to suppress the lineup identifications and to exclude the photograph, and after a jury trial, Smith was convicted and sentenced to 30 years in prison. On appeal, the Illinois Appellate Court reversed the conviction and remanded for a new trial, finding that excluding Smith’s mother violated his right to a public trial. The appellate court also found errors regarding the suggestiveness of the second lineup, a discovery violation in the gunshot residue expert’s testimony, improper closing arguments by the prosecution, and error in sending the photograph to the jury.The Supreme Court of Illinois reviewed the case and held that excluding Smith’s mother did not violate his right to a public trial, as the courtroom remained open to other family members, spectators, and the media. The court further found that the second lineup was not unduly suggestive, the discovery violation regarding the gunshot residue expert did not warrant reversal, the trial court did not abuse its discretion in allowing the jury to view the photograph, and the challenged prosecutorial comments did not constitute reversible error. The Supreme Court reversed the appellate court’s judgment, affirmed the conviction, and remanded for consideration of any remaining unresolved issues. View "People v. Smith" on Justia Law

Plaintiffs, which are self-insured health and welfare trust funds, challenged a statutory requirement under the Patient Protection and Affordable Care Act (ACA) that obligated them to pay contributions to the Transitional Reinsurance Program (TRP) for the 2014, 2015, and 2016 benefit years. They argued that these mandatory payments constituted a taking of their property under the Fifth Amendment, claiming a protected property interest in the specific funds held in their trust accounts, which are maintained solely for providing health and welfare benefits to covered individuals.The United States Court of Federal Claims reviewed the case and granted the Government’s motion for partial summary judgment on the Fifth Amendment takings claim. The Claims Court found that the plaintiffs did not possess a cognizable property interest in the TRP payments, as the obligation was merely to pay money, not to surrender specifically identifiable funds. The court rejected the argument that the trust agreements created a property interest in the sums paid, and also dismissed the alternative claim that the trust accounts themselves were the specific funds at issue. The Claims Court further held that a taking would only occur if the government appropriated the entire fund, which did not happen here. Plaintiffs’ motion for reconsideration was denied.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the grant of summary judgment de novo. The Federal Circuit affirmed the Claims Court’s decision, holding that the statutory obligation to pay TRP contributions did not constitute a taking under the Fifth Amendment because it was an obligation to pay money, not an appropriation of a specific, identifiable fund. The court clarified that a mere requirement to pay money, even from a trust account, does not give rise to a takings claim. The Federal Circuit also found harmless error in the Claims Court’s alternative reasoning regarding appropriation of funds in toto. The judgment was affirmed. View "ELECTRICAL WELFARE TRUST FUND v. US " on Justia Law

Two individuals, Mario Cabral and Vanessa Mora, were shot and killed in their home in March 2018. The defendant, who had a child with Cabral and was involved in a contentious custody dispute, was accused of hiring a hitman, Edward Alonso, to kill Cabral. Alonso testified that the defendant offered him money and provided details about Cabral’s residence, but he ultimately did not carry out the murder. The prosecution presented circumstantial evidence, including testimony about the defendant’s acquisition of a .45-caliber gun, photographs of Cabral’s home found on her phone, and statements suggesting her boyfriend, Flores, might commit the murder if Alonso did not. The defendant denied involvement, but the jury convicted her of first-degree murder of Cabral, conspiracy to commit first-degree murder, and criminal solicitation of first-degree murder.The case was tried in the District Court of Doña Ana County, where the defendant objected to the prosecution’s cross-examination about her six-month-old child’s positive methamphetamine test, arguing lack of notice and relevance. The district court allowed limited questioning on this topic. The jury acquitted the defendant of Mora’s murder but convicted her on the other charges.On direct appeal, the Supreme Court of the State of New Mexico reviewed the evidentiary ruling and found that the district court abused its discretion by admitting the inquiry into the child’s drug test, as it was inadmissible under the relevant evidence rules and not justified as rebuttal character evidence. The error was deemed not harmless, given its impact on the defendant’s credibility. The Supreme Court reversed all convictions and remanded for a new trial. The court also held that the convictions for conspiracy and solicitation did not violate double jeopardy and that sufficient evidence supported the murder conviction. Additionally, the court emphasized the public’s First Amendment right to access criminal trials, criticizing the district court’s prohibition of notetaking by observers. View "State v. Cardenas" on Justia Law

A Nigerian citizen who became a lawful permanent resident of the United States in 2005 was placed in removal proceedings after being convicted of conspiracy to commit passport fraud. He had lived in the U.S. for many years, had a long-term partner, and was the father of four U.S. citizen children. His conviction stemmed from a scheme to obtain fraudulent U.S. passports for noncitizens, for which he was sentenced to 27 months in prison. After serving his sentence and briefly fleeing to Canada, he was returned to the U.S. and charged as inadmissible for committing a crime involving moral turpitude. In removal proceedings, he applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), claiming past persecution and fear of future harm in Nigeria due to his former union activities and threats from a militia group.An Immigration Judge (IJ) found him inadmissible, denied all forms of relief, and determined that his conviction constituted a particularly serious crime, barring asylum and withholding. The IJ also found his and his partner’s testimony not credible and denied CAT relief, concluding he had not shown a likelihood of torture with government acquiescence. The Board of Immigration Appeals (BIA) affirmed, agreeing with the IJ’s findings and further holding that the absence of an interpreter did not violate due process, that the conviction was a particularly serious crime, and that he was not eligible for a waiver of inadmissibility.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the BIA misapplied the legal standard for determining a particularly serious crime by failing to consider the elements of the underlying substantive offense in the conspiracy conviction. The court also found that the BIA did not properly analyze the CAT claim under the required legal framework and failed to consider eligibility for a waiver of inadmissibility. The court denied the due process claim but vacated the BIA’s decision and remanded for further proceedings, ordering a stay of removal pending the outcome. View "Amos v. Attorney General United States of America" on Justia Law