Justia Constitutional Law Opinion Summaries

Arkansas Act 629 criminalized many previously legal hemp products. A coalition of affected businesses sued state officers, alleging that Act 629 is unconstitutional. The district court granted the plaintiffs' motion for a preliminary injunction and denied the state's motion to dismiss the Governor and Attorney General.The United States District Court for the Eastern District of Arkansas found that the plaintiffs were likely to succeed on the merits of their Supremacy Clause and due process claims. The court concluded that the 2018 Farm Bill likely preempted Act 629 and that the Act was likely void for vagueness. The court also found that the Governor and Attorney General were not entitled to sovereign immunity because they were sufficiently connected to the enforcement of Act 629.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the 2018 Farm Bill did not expressly preempt Act 629 because the Act's savings clause allowed for the continuous transportation of hemp through Arkansas. The court also found that Act 629 did not conflict with the 2018 Farm Bill's purpose of legalizing hemp production, as the federal law allows states to regulate hemp production more stringently. Additionally, the court concluded that Act 629 was not unconstitutionally vague, as the terms "continuous transportation," "synthetic substance," and "psychoactive substances" were sufficiently clear.The court further held that the Governor and Attorney General were entitled to sovereign immunity because they did not have a sufficient connection to the enforcement of Act 629. The court vacated the preliminary injunction, reversed the order denying the motion to dismiss the Governor and Attorney General, and remanded the case for further proceedings. View "Bio Gen LLC v. Sanders" on Justia Law

Allen Turner died from surgical complications, leading his daughter, Norkesia Turner, to sue Drs. William Thompson and Heather Nolan, and their employer, the Medical Center of Central Georgia, Inc. (MCCG), for medical malpractice and wrongful death. The jury awarded Turner approximately $7.2 million in noneconomic damages for wrongful death. MCCG moved to reduce this award to the statutory cap of $350,000 under OCGA § 51-13-1 (b) and (c), but the trial court denied the motion, citing the Georgia Supreme Court's decision in Atlanta Oculoplastic Surgery, P.C. v. Nestlehutt, which found such caps unconstitutional.MCCG appealed to the Court of Appeals, which affirmed the trial court's decision, reasoning that the Nestlehutt decision foreclosed MCCG's argument. The Court of Appeals held that the $7.2 million award did not need to be reduced to the statutory cap. MCCG then petitioned the Supreme Court of Georgia for a writ of certiorari, which was granted to address whether the Court of Appeals properly applied the precedent regarding the constitutional right to trial by jury.The Supreme Court of Georgia did not decide whether the application of OCGA § 51-13-1’s caps to the $7.2 million award would violate Turner’s constitutional right to a jury trial. Instead, it found that the lower courts had not applied the correct analytical framework from Nestlehutt to the wrongful death claim. The Supreme Court clarified that the holding in Nestlehutt was specific to medical malpractice claims and did not control the issue in this case. Consequently, the Supreme Court vacated the decision of the Court of Appeals and remanded the case for further proceedings consistent with its opinion. View "THE MEDICAL CENTER OF CENTRAL GEORGIA, INC. v. TURNER" on Justia Law

Luis Martinez Jr. died in February 2021, and his body was taken by the Wayne County Medical Examiner’s Office (WCMEO). Despite identifying his next of kin, the WCMEO did not contact them. The family hired a social worker who located Luis Jr.'s body in April 2021, by which time it was severely decomposed and had to be cremated. The family sued Wayne County and various officials under § 1983 for a Fourteenth Amendment procedural due process violation, a Monell liability claim, and state-law claims.The United States District Court for the Eastern District of Michigan granted the defendants' motion to dismiss. The court found that the alleged conduct did not constitute a clearly established constitutional violation and that the Monell claim failed due to a lack of supporting facts. The court declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that the defendants' conduct did not violate a clearly established constitutional right, as existing precedent did not address delayed notification leading to natural decomposition. The court also found that the Monell claim failed because the complaint did not allege sufficient facts to show a policy or custom of unconstitutional conduct or a failure to train. The court concluded that without a clearly established constitutional violation, the Monell claim could not succeed. View "Martinez v. Wayne Cnty., Mich." on Justia Law

Reginald Robinson, Jr. entered a conditional guilty plea to one count of being a prohibited person in possession of a firearm, preserving his right to appeal the denial of a motion to dismiss the indictment and a motion to suppress. The district court sentenced him to 60 months’ imprisonment followed by 3 years of supervised release. Robinson appealed, arguing that the district court erroneously denied his motion to suppress based on an invalid Miranda waiver and lack of reasonable suspicion, and his motion to dismiss the indictment challenging the constitutionality of 18 U.S.C. § 922(g)(1) and (g)(3).The district court denied Robinson’s motion to suppress, concluding that Officer Siferd did not circumvent Miranda and that Robinson’s waiver of his rights was knowing and voluntary. The court also found that Officer Siferd had reasonable suspicion to detain Robinson based on the Walmart employee’s report and the odor of marijuana. The district court denied Robinson’s motion to dismiss the indictment, relying on Eighth Circuit precedent that upheld the constitutionality of § 922(g)(1) and (g)(3).The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The court found no evidence that Officer Siferd engaged in an orchestrated effort to circumvent Miranda and concluded that Robinson’s waiver of his rights was knowing and voluntary. The court also held that Officer Siferd had reasonable suspicion to detain Robinson based on the shoplifting report and the odor of marijuana. Additionally, the court upheld the constitutionality of § 922(g)(1) and (g)(3), noting that Robinson’s challenges were foreclosed by circuit precedent. The court affirmed the judgment of the district court. View "United States v. Robinson" on Justia Law

A group of plaintiffs, including individuals and community organizations, challenged the constitutionality of Louisiana’s Infrastructure Trespass Statute, arguing that amendments to the statute rendered it unconstitutionally vague and overbroad, violating the Due Process Clause and the First Amendment. The statute criminalizes unauthorized entry into critical infrastructure, including pipelines, and imposes significant penalties for violations.The United States District Court for the Western District of Louisiana granted summary judgment in favor of the defendants, including the Louisiana Attorney General, the District Attorney of the 16th Judicial District, and the Sheriff of St. Martin Parish. The district court dismissed claims against the Attorney General on sovereign immunity grounds and found that the Advocacy and Landowner Plaintiffs lacked standing. The court also dismissed the Arrested Plaintiffs' as-applied claims as moot due to the expiration of the statute of limitations for their alleged violations.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s dismissal of claims against the Attorney General, agreeing that the Ex Parte Young exception to sovereign immunity did not apply. The court also upheld the dismissal of the Advocacy and Landowner Plaintiffs for lack of standing, finding that their alleged injuries were not traceable to or redressable by the remaining defendants. The court agreed that the Arrested Plaintiffs had standing for their facial challenges but affirmed the dismissal of their as-applied claims as moot.On the merits, the Fifth Circuit concluded that the Infrastructure Trespass Statute was neither impermissibly vague nor violative of the First Amendment. The court found that the statute provided sufficient notice of prohibited conduct and did not authorize arbitrary enforcement. The court also determined that the statute was not overbroad, as it served a substantial governmental interest in protecting critical infrastructure and did not substantially burden protected speech. The court affirmed the district court’s grant of summary judgment in favor of the defendants. View "White Hat v. Murrill" on Justia Law

Parents and students in Louisiana challenged a state statute requiring public schools to permanently display the Ten Commandments in every classroom. The statute, House Bill 71 (H.B. 71), mandated that the Ten Commandments be displayed prominently and legibly, with an optional inclusion of other historical documents. Plaintiffs argued that this statute violated the Establishment Clause and Free Exercise Clause of the First Amendment.The United States District Court for the Middle District of Louisiana found the statute facially unconstitutional and issued a preliminary injunction to prevent its enforcement. The court ruled that the statute's primary purpose was religious, not secular, and that it coerced students into religious observance, thus violating the Establishment Clause. Louisiana officials appealed the decision, arguing that the statute had a valid secular purpose and that the plaintiffs lacked standing.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The Fifth Circuit held that the statute was unconstitutional under the Establishment Clause, relying on the precedent set by Stone v. Graham, which struck down a similar statute in Kentucky. The court found that the statute's requirement to display the Ten Commandments in every classroom, without integrating them into an educational curriculum, served no secular educational purpose and was inherently religious.The court also determined that the plaintiffs had standing to challenge the statute, as they would be directly affected by the displays. The court rejected Louisiana's arguments regarding ripeness, standing, and sovereign immunity. The preliminary injunction was upheld, preventing the enforcement of H.B. 71 and requiring Louisiana officials to notify all public schools of the court's ruling. View "Roake v. Brumley" on Justia Law

In 2017, the Saginaw County Sheriff’s Office seized fourteen firearms during a domestic-violence investigation involving Benjamin Heinrich. Heinrich's uncle, Gerald Novak, and distant cousin, Adam Wenzel, claimed ownership of the firearms and sought their return. Sheriff William Federspiel refused to return the firearms, arguing that Novak and Wenzel had not proven ownership. Novak and Wenzel then sued Federspiel under 42 U.S.C. § 1983 and Michigan law, asserting various federal constitutional and state claims.The United States District Court for the Eastern District of Michigan granted summary judgment to Federspiel on all claims and denied Novak and Wenzel’s motion for partial summary judgment. The court found that qualified immunity protected Federspiel in his personal capacity and that Novak and Wenzel had not established constitutional violations. It also held that Michigan law does not recognize a cause of action to sue municipal officials for constitutional torts and that Novak and Wenzel could not establish the elements of claim and delivery.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment to Federspiel on the individual-capacity takings claims, procedural-due-process claims, substantive-due-process claims, Fourth Amendment claims, and inverse-condemnation claims. However, it vacated the grant of summary judgment on the official-capacity and injunctive-relief takings claims, official-capacity Second Amendment claims, and the claim-and-delivery action. The court remanded these claims for further proceedings, noting that Novak and Wenzel’s affidavits created a genuine issue of material fact regarding ownership of the firearms, and that the district court should address whether Federspiel’s actions were consistent with historical firearm regulation. View "Novak v. Federspiel" on Justia Law

The case involves two separate lawsuits filed in the United States District Court for the Southern District of New York under the Antiterrorism Act of 1990 (ATA). The plaintiffs, American citizens injured or killed in terror attacks, sued the Palestine Liberation Organization (PLO) and Palestinian Authority (PA). The plaintiffs alleged that the PLO and PA engaged in conduct that triggered jurisdiction under the Promoting Security and Justice for Victims of Terrorism Act (PSJVTA), which deems these entities to have consented to personal jurisdiction in ATA cases under certain conditions.The United States District Court for the Southern District of New York found evidence that the PLO and PA engaged in conduct sufficient to satisfy the PSJVTA's jurisdictional predicates. However, the court ruled that exercising jurisdiction under the PSJVTA was unconstitutional. The Second Circuit Court of Appeals affirmed this decision, holding that the PSJVTA could not establish personal jurisdiction over the PLO or PA consistent with constitutional due process requirements.The Supreme Court of the United States reviewed the case and held that the PSJVTA's personal jurisdiction provision does not violate the Fifth Amendment's Due Process Clause. The Court reasoned that the statute reasonably ties the assertion of jurisdiction over the PLO and PA to conduct involving the United States and implicating sensitive foreign policy matters within the prerogative of the political branches. The Court reversed the Second Circuit's judgment and remanded the case for further proceedings consistent with its opinion. View "Fuld v. Palestine Liberation Organization" on Justia Law

Karyn Stanley, a firefighter for the City of Sanford, Florida, since 1999, was forced to retire in 2018 due to a disability. When she was hired, the City provided health insurance until age 65 for retirees with 25 years of service or those who retired due to disability. In 2003, the City revised its policy, limiting health insurance to 24 months for those retiring due to disability. Stanley, who retired under the revised policy, received only 24 months of health insurance.Stanley sued the City, alleging that the revised policy violated the Americans with Disabilities Act (ADA) by discriminating against those who retire due to disability. The district court dismissed her ADA claim, stating that the alleged discrimination occurred after her retirement, making her not a "qualified individual" under Title I of the ADA, as she no longer held or sought a job with the City. The Eleventh Circuit affirmed the district court's decision.The Supreme Court of the United States reviewed the case and affirmed the lower courts' decisions. The Court held that to prevail under §12112(a) of the ADA, a plaintiff must prove that they held or desired a job and could perform its essential functions with or without reasonable accommodation at the time of the alleged discrimination. The Court concluded that the ADA's protections do not extend to retirees who neither hold nor seek a job. The judgment of the Eleventh Circuit was affirmed, upholding the dismissal of Stanley's ADA claim. View "Stanley v. City of Stanford" on Justia Law

Plaintiffs, including individuals and organizations, challenged California's "one-gun-a-month" law, which restricts the purchase of more than one firearm within a 30-day period. They argued that this law violates the Second Amendment. The law, initially targeting concealable handguns, was expanded over time to include all firearms. Plaintiffs sought to purchase multiple firearms within the restricted period, claiming the law infringed on their constitutional rights.The United States District Court for the Southern District of California granted summary judgment in favor of the plaintiffs, holding that the law facially violates the Second Amendment. The court found that the law imposes a meaningful constraint on the right to acquire firearms, which is protected by the Second Amendment. The court also determined that the law is not supported by historical precedent.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that the Second Amendment protects the right to possess multiple firearms and the ability to acquire them without meaningful constraints. The court applied the framework from New York State Rifle & Pistol Association v. Bruen, which requires historical precedent to justify modern firearm regulations. The court found that California's law lacks historical support, as there is no tradition of similar regulations. The court concluded that the law is facially unconstitutional and affirmed the district court's summary judgment in favor of the plaintiffs. View "Nguyen v. Bonta" on Justia Law