Justia Constitutional Law Opinion Summaries

Ten nonprofit organizations that received federal grants through the U.S. Citizenship and Immigration Services’ “Citizenship and Integration Grant Program” filed suit after the Department of Homeland Security (DHS) froze and subsequently terminated their grant funding. The freeze and termination followed an executive order issued by the incoming President in January 2025 directing DHS to pause and review grants that funded services to undocumented immigrants, with the aim of ensuring compliance with law and preventing waste, fraud, or abuse. DHS notified grantees of the freeze in February 2025 and terminated the grants in March 2025, prompting the plaintiffs to seek a preliminary injunction to restore the program and funding.The United States District Court for the District of Maryland denied the plaintiffs’ motion for a preliminary injunction. The court determined that the plaintiffs’ claims were essentially contractual—seeking disbursement of funds based on grant agreements—and thus fell under the exclusive jurisdiction of the United States Court of Federal Claims pursuant to the Tucker Act. The court also found that the plaintiffs had not identified a reviewable “final agency action” under the Administrative Procedure Act (APA). Additionally, it concluded that the plaintiffs had failed to provide adequate legal authority for their ultra vires and separation-of-powers claims.Reviewing the appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The Fourth Circuit held that the relief sought by the plaintiffs was materially indistinguishable from relief denied in recent Supreme Court cases, Department of Education v. California and National Institutes of Health v. Public Health Association. It concluded that claims seeking to enforce contractual obligations to pay money must be brought in the Court of Federal Claims and that the plaintiffs had not shown a likelihood of success on their alternative constitutional or statutory claims. The district court’s denial of the preliminary injunction was therefore affirmed. View "Solutions in Hometown Connections v. Noem" on Justia Law

A man was convicted in California of first-degree murder and sentenced to death for the killing of a homeowner during a burglary in 1985. The prosecution established that the defendant entered the victim’s home, stole property, and shot the victim in the back as he was fleeing. The case against the defendant was supported by fingerprint evidence, eyewitnesses, and testimony about his actions and statements before and after the crime. At trial, the defense argued alternative theories, including that another individual was the actual killer and that the shooting lacked intent. During the penalty phase, the prosecution presented evidence of the defendant’s prior felonies, while the defense offered extensive mitigating evidence regarding his abusive childhood and mental health issues.On direct appeal, the Supreme Court of California affirmed the conviction and death sentence. The defendant subsequently filed state and federal habeas petitions, raising claims about his competency to stand trial, the effectiveness of his counsel, and alleged jury coercion. The California Supreme Court summarily denied these claims, and the United States District Court for the Central District of California denied his federal habeas petition.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. Applying the deferential standard required by the Anti-Terrorism and Effective Death Penalty Act (AEDPA), the court held that the California Supreme Court could have reasonably concluded the evidence did not sufficiently support the defendant’s claims of incompetence or ineffective assistance of counsel. The Ninth Circuit also found no basis to conclude the trial court coerced the jury’s verdict or that California’s death penalty statute was unconstitutional. The Ninth Circuit affirmed the district court’s denial of habeas relief. View "Beeler v. Broomfield" on Justia Law

Two correctional officers witnessed the defendant physically assaulting two women outside a convenience store and intervened to stop the attack. Police arrived shortly thereafter and arrested the defendant. He was charged with three counts of aggravated battery, a felony. From the outset, there were questions about the defendant’s fitness to stand trial, leading to repeated delays as the court attempted, unsuccessfully at first, to obtain a fitness evaluation. Ultimately, the defendant was found fit, his counsel withdrew at his request, and he proceeded to represent himself. The court arraigned him, set bond, and scheduled a jury trial, at which he was convicted of aggravated battery.Prior to trial, the defendant never received a preliminary hearing to determine probable cause, nor was he indicted by a grand jury, as required by the Illinois Constitution for felony charges. The defendant did not object to this omission before or during trial, nor did he raise it in a posttrial motion. On appeal, the Illinois Appellate Court, Fifth District, concluded that the absence of a preliminary hearing or indictment was a structural error reviewable as second-prong plain error, and it reversed the defendant’s convictions outright.The Supreme Court of the State of Illinois reviewed whether the trial court’s failure to provide a prompt preliminary hearing constituted second-prong plain error. The court held that, while the trial court’s failure to provide a preliminary hearing was clear error, it did not amount to a structural error or deprive the defendant of a fair trial, given that his guilt was established beyond a reasonable doubt at trial. Therefore, the error was subject to harmless error analysis and was not reviewable as second-prong plain error. The Supreme Court reversed the appellate court’s judgment and affirmed the convictions and sentence imposed by the circuit court. View "People v. Chambliss" on Justia Law

Twenty-three landowners brought suit against Gold Bess Shooting Club, LLC and Caulder Construction, LLC, alleging nuisance due to noise, environmental, and safety concerns from a shooting range established on Caulder’s property in Woodstock, New Hampshire. Gold Bess registered as an LLC and leased land from Caulder, constructing the range and opening it to the public in October 2020. Prior to its opening, the New Hampshire Department of Environmental Services notified the defendants of alleged violations of state wetlands and terrain alteration statutes. The plaintiffs amended their complaint to add noise-related nuisance claims after Woodstock enacted a noise ordinance in April 2021.The Grafton County Superior Court granted summary judgment to the defendants on the plaintiffs’ noise-related nuisance claims, finding the shooting range immune under RSA 159-B:1 and RSA 159-B:2, which provide protection from civil liability related to noise for shooting ranges compliant with noise ordinances in effect when the range was established, constructed, or began operations. The court denied plaintiffs’ motion for partial summary judgment and rejected their argument that alleged environmental law violations precluded immunity under RSA chapter 159-B. The court also granted summary judgment for the defendants on constitutional equal protection claims, and subsequently allowed the plaintiffs to voluntarily discontinue their remaining claims.The Supreme Court of New Hampshire reviewed the statutory interpretation of RSA 159-B:1 and RSA 159-B:2 de novo. It held that these statutes require compliance only with noise ordinances, not with other laws such as wetlands or terrain alteration statutes. The court further determined that the shooting range “began operations” prior to the enactment of Woodstock’s noise ordinance, thereby qualifying for immunity from noise-related legal claims under the statutes. The Supreme Court affirmed the Superior Court’s grant of summary judgment in favor of the defendants. View "Martell v. Gold Bess Shooting Club, LLC" on Justia Law

The case concerns a California statute that makes it a crime to knowingly file a false allegation of police misconduct and requires complainants to sign an advisory warning of potential criminal liability before their complaint is accepted. The Los Angeles Police Protective League sought an injunction compelling the City of Los Angeles to enforce this advisory requirement. The City had previously entered into a consent decree with the federal government prohibiting enforcement of the advisory, and even after the consent decree expired, continued not to require the advisory due to concerns about the statute’s constitutionality.The Superior Court of Los Angeles County, relying on the California Supreme Court’s earlier decision in People v. Stanistreet, granted the injunction and ordered the City to require the statutory advisory. The California Court of Appeal affirmed, adhering to Stanistreet’s reasoning that had upheld the statute’s constitutionality. The City then petitioned to the Supreme Court of California, arguing that subsequent federal decisions—especially Chaker v. Crogan by the Ninth Circuit—cast serious doubt on the continuing validity of Stanistreet and the constitutionality of the statute.Reviewing the case, the Supreme Court of California reconsidered its prior Stanistreet decision in light of more recent U.S. Supreme Court rulings, including United States v. Alvarez and Free Speech Coalition, Inc. v. Paxton. The court held that the statutory scheme—combining criminal penalties with a mandatory and prominently worded advisory—created a consequential risk of chilling truthful or well-intentioned complaints of police misconduct. The court concluded that this risk triggered heightened constitutional scrutiny under the First Amendment. The statute failed intermediate scrutiny because it was not narrowly tailored and burdened substantially more speech than necessary to serve the state’s legitimate interests. The court therefore reversed the judgment of the Court of Appeal. View "L.A. Police Protective League v. City of L.A." on Justia Law

A worker was severely injured while operating a bulldozer during a nighttime firefighting operation on a fire line managed by the Oregon Department of Forestry. At the time, he was employed by a private company under contract with the state and received workers’ compensation benefits for his injuries. He also filed a lawsuit alleging that two state employees supervising the site had negligently directed operations, resulting in his injuries. The complaint sought damages from the employees and the State of Oregon, which was alleged to be vicariously liable.The Jackson County Circuit Court dismissed the plaintiff’s claims against the individual state employees based on a provision of the Oregon Tort Claims Act, ORS 30.265(3), making the state the sole defendant. The court also dismissed the claims against the state under ORS 30.265(6)(a), which grants immunity to public bodies and their employees against tort claims when the injured party is covered by workers’ compensation. However, the court allowed the plaintiff’s wife’s loss of consortium claim to proceed. On appeal, the Oregon Court of Appeals affirmed the dismissal, holding that the statutory immunity barred the plaintiff’s claims and did not violate the remedy clause of the Oregon Constitution.The Supreme Court of the State of Oregon reviewed the case and reversed the decisions of the Court of Appeals and the circuit court. The court held that the statutory immunity provision in ORS 30.265(6)(a), which entirely bars a common-law negligence action by a privately employed worker injured by a negligent state employee, exceeds the limits imposed by Article I, section 10, of the Oregon Constitution. The court concluded that this statutory immunity unconstitutionally denies such injured persons a substantive right to a remedy by due course of law and remanded the case for further proceedings. View "Crandall v. State of Oregon" on Justia Law

Daniel Gantnier was convicted by a jury in 2006 of unlawful sexual contact, a sex offense that, under Maine law at the time, required lifetime registration as a sex offender. However, when the court imposed his sentence in 2007, the judgment and commitment form mistakenly indicated that he was obligated to register for only ten years instead of life. After Gantnier completed the ten-year term, the State Bureau of Identification reviewed his case, identified the error, and in 2019 notified him that his registration requirement was corrected to require lifetime registration. Gantnier did not comply with this requirement, and in 2022 the State charged him with failure to comply with the Sex Offender Registration and Notification Act of 1999 (SORNA of 1999).Following his not guilty plea, Gantnier moved to dismiss the complaint in the trial court (Kennebec County), arguing that retroactively imposing a lifetime registration requirement violated the Ex Post Facto Clause of the United States Constitution and that the State’s correction should have been pursued under Rule 35(a), which governs correction of illegal sentences. The trial court (Daniel Mitchell, J.) denied his motion, finding that, due to a 2004 legislative amendment, SORNA of 1999 registration was not part of a criminal sentence for offenses like Gantnier’s. The court found that the correction was regulatory, not punitive, and thus not subject to ex post facto protections. After his motion for reconsideration was also denied, Gantnier entered a conditional guilty plea, reserving his right to appeal.On appeal, the Maine Supreme Judicial Court reviewed the case and affirmed the judgment. The Court held that because Gantnier’s registration requirement was not part of his sentence, the retroactive correction to lifetime registration did not violate the Ex Post Facto Clause. The Court also determined that the State acted properly under 34-A M.R.S. § 11222(1), and was not required to proceed under Rule 35(a). The judgment was affirmed. View "State of Maine v. Gantnier" on Justia Law

Police officers encountered a man at a playground in a public park while he was with his daughter and partner. The officers were conducting a patrol and had observed a group they suspected of smoking marijuana. The man had walked away from the group to rejoin his family. Five armed, uniformed officers approached and encircled him, with two officers standing within arm's reach and three others positioned nearby. One officer asked if the man had a firearm, and he admitted that he did; officers then frisked him and recovered a gun from his waistband.The Superior Court of the District of Columbia held a hearing on a motion to suppress the firearm. The trial court found that the defendant was not seized until after he admitted to possessing a firearm and officers physically restrained him. The court emphasized the officers’ cordial tone, the brief nature of the encounter, and the public setting, and denied the motion to suppress. The case proceeded to trial, and a jury convicted the defendant of unlawful possession of a firearm, carrying a pistol without a license, and possession of an unregistered firearm.The District of Columbia Court of Appeals reviewed the case. It held that the defendant was seized for Fourth Amendment purposes before he admitted to possessing a firearm—specifically, when five officers encircled and focused exclusively on him, blocking his exits and asking accusatory questions. The court concluded that this seizure was unsupported by reasonable articulable suspicion and thus unlawful. It reversed all convictions, holding that the firearm should have been suppressed as the fruit of the unlawful seizure, and remanded the case for further proceedings. View "Ervin v. United States" on Justia Law

In July 2023, law enforcement responded to an incident in which James Jacobs allegedly discharged a firearm during a dispute with his girlfriend at his home. During a subsequent search, officers discovered two firearms. Jacobs, who has a prior felony conviction and a previous misdemeanor conviction for domestic battery in West Virginia, admitted to knowing he was prohibited from possessing firearms. As a result, a grand jury in the Northern District of West Virginia indicted him for possessing firearms after a felony conviction under 18 U.S.C. § 922(g)(1) and after a misdemeanor crime of domestic violence under § 922(g)(9).The United States District Court for the Northern District of West Virginia granted Jacobs’ motion to dismiss both counts of the indictment. The district court, employing the framework from New York State Rifle & Pistol Association v. Bruen, found that the government failed to demonstrate a historical tradition of disarming individuals like Jacobs—nonviolent felons and domestic violence offenders. The court concluded that both statutes were unconstitutional as applied to Jacobs and dismissed the charges without reaching the facial challenges.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s rulings de novo. The Fourth Circuit held that recent decisions—including United States v. Rahimi, United States v. Canada, United States v. Hunt, and United States v. Nutter—foreclose Jacobs’ facial and as-applied challenges to § 922(g)(1) and his facial challenge to § 922(g)(9). Accordingly, the court reversed the district court’s dismissal of the § 922(g)(1) charge and barred Jacobs from reviving those challenges. However, the Fourth Circuit determined that further proceedings were necessary regarding Jacobs’ as-applied challenge to § 922(g)(9), vacated the district court’s ruling on that count, and remanded for additional factfinding and analysis. View "United States v. Jacobs" on Justia Law

A telehealth company developed software that enables individuals to determine their refractive eye error using a computer or smartphone without an in-person visit to an optometrist or ophthalmologist. This technology, approved by the FDA and available in many states, was offered in South Carolina until the enactment of the Eye Care Consumer Protection Law in 2016. The law prohibits eye doctors from prescribing spectacles or contact lenses based solely on information from automated equipment, including kiosks or online applications, and requires a valid prescription from a provider following an in-person examination.After the law was enacted, the company ceased providing its service in South Carolina, as local eye doctors were no longer willing to issue prescriptions based solely on remote test results. The company challenged the constitutionality of the law, arguing it violated equal protection and due process guarantees under the South Carolina Constitution. The Circuit Court for Richland County initially granted summary judgment for the defendants, finding the law’s purpose was to protect public health and that its provisions were reasonably related to maintaining the standard of care for medical professionals.Upon direct appeal, the Supreme Court of South Carolina reviewed the case. The Court applied the rational basis test and held that the legislature’s decision to require in-person examinations before prescribing corrective lenses was rationally related to the legitimate government interest of protecting public health. The Court found the classification created by the Act was reasonable and did not violate equal protection, as it treated similarly situated eye doctors alike and addressed unique risks in eye care. The Supreme Court of South Carolina affirmed the circuit court’s grant of summary judgment, upholding the constitutionality of the law. View "Opternative v. South Carolina Optometric Physicians Association" on Justia Law