Justia Constitutional Law Opinion Summaries

A voter in Sarasota County, Florida, who is not affiliated with any political party, challenged Florida's closed primary election system. He argued that the system forces him to either join a political party to have a meaningful vote or forfeit his right to vote in primary elections, which he claimed was unconstitutional. The district court dismissed his case, concluding that he lacked standing and failed to state a claim for relief.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court found that the voter had standing to sue the Sarasota County Supervisor of Elections because his exclusion from primary elections was traceable to the Supervisor and could be redressed by a court order. However, the court determined that the voter lacked standing to sue the Florida Secretary of State, as the Secretary did not have direct control over the Supervisor's actions.On the merits, the court applied the Anderson-Burdick framework to evaluate the voter's First and Fourteenth Amendment claims. The court concluded that the burdens imposed by Florida's closed primary system on the voter's rights were minimal. The court found that the state's interests in preserving political parties as viable and identifiable interest groups and enhancing candidates' electioneering efforts outweighed the minimal burdens on the voter's rights.The court vacated the district court's order and remanded the case with instructions to dismiss the claims against the Florida Secretary of State without prejudice and to dismiss the claims against the Sarasota County Supervisor of Elections with prejudice. View "Polelle v. Florida Secretary of State" on Justia Law

In 2020, the Vermont Superior Court transitioned to electronic filing and adopted a policy that delayed public access to newly filed civil complaints until a court clerk reviewed them for compliance with technical requirements and the absence of unredacted confidential information. Plaintiffs, consisting of news and media organizations, challenged this practice, claiming it violated their First Amendment right of access to court documents.The United States District Court for the District of Vermont held a bench trial and ruled in favor of the Plaintiffs. The court found that Vermont’s pre-access review process violated the First Amendment and issued a permanent injunction preventing the Defendants from withholding complaints until the completion of the review process. The Defendants, administrators and clerks of the Vermont Superior Court, appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court that Vermont’s practice, as reviewed, violated the Plaintiffs’ First Amendment rights. However, the appellate court found that the terms of the permanent injunction were not supported by the court’s findings. The Second Circuit affirmed the district court’s judgment to the extent it found the practice violated the First Amendment but vacated the permanent injunction. The case was remanded for further proceedings to reconsider the terms of an appropriate injunction. The court also addressed and rejected the Defendants' arguments regarding abstention and mootness. View "Courthouse News Service v. Corsones" on Justia Law

In August 2022, Jamond Rush was charged with possessing an unregistered firearm, specifically an AR-15 rifle with a 7.5-inch barrel, in violation of the National Firearms Act (NFA). Rush moved to dismiss the indictment, arguing that the statute under which he was charged was unconstitutional based on the Supreme Court's decision in N.Y. State Rifle & Pistol Ass’n, Inc. v. Bruen. The government opposed, citing the Supreme Court's earlier decision in United States v. Miller, which upheld similar regulations. The district court denied Rush's motion, holding that Bruen did not affect the constitutionality of regulating unregistered short-barreled rifles. Rush entered a conditional guilty plea, reserving the right to appeal the denial of his motion to dismiss, and was sentenced to 30 months in prison.The United States District Court for the Southern District of Illinois reviewed the case and denied Rush's motion to dismiss, leading to his appeal. The court held that Rush's conduct was not protected by the Second Amendment's plain text or historical understanding.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that the NFA's requirement to register certain firearms, including short-barreled rifles, is constitutional. The court relied on the precedent set by United States v. Miller, which upheld similar regulations, and found that the NFA's provisions are consistent with the historical tradition of firearm regulation. The court concluded that the regulation of short-barreled rifles does not violate the Second Amendment, as these weapons are not typically possessed by law-abiding citizens for lawful purposes like self-defense. The court affirmed Rush's conviction and the denial of his motion to dismiss. View "United States v. Rush" on Justia Law

Lars Jensen, a math professor at Truckee Meadows Community College (TMCC), voiced concerns about a policy change to the math curriculum standards. He criticized the new co-requisite policy, which placed students needing remedial instruction in college-level classes, arguing it lowered academic standards. Following his criticism, Jensen faced several adverse actions, including reprimands, negative performance reviews, and a termination hearing.The United States District Court for the District of Nevada dismissed Jensen’s claims, including First Amendment retaliation, procedural due process, and equal protection violations. The court held that Jensen’s First Amendment claim was barred by qualified immunity and that his official capacity claim was barred by sovereign immunity. The court also found that Jensen failed to identify a protected interest for his due process claim and did not allege membership in a discrete class for his equal protection claim. The court dismissed all claims with prejudice and denied leave to amend.The United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal of Jensen’s First Amendment retaliation claim. The appellate court held that Jensen’s criticism of the curriculum changes addressed a matter of public concern and was protected speech related to scholarship or teaching. The court found that the adverse actions against Jensen were motivated by his speech and that the state had not shown a substantial disruption to outweigh his First Amendment rights. The court also held that the Administrators were not entitled to qualified immunity and that Jensen’s official capacity claim for prospective relief was not barred by sovereign immunity. The court affirmed the dismissal of Jensen’s due process and equal protection claims but reversed the denial of leave to amend, remanding for further proceedings. View "JENSEN V. BROWN" on Justia Law

Edward Gibbs was indicted in August 2018 for conspiracy to possess with intent to distribute and to distribute 500 grams or more of methamphetamine mixture. He pleaded guilty in November 2020 and was sentenced to 200 months of imprisonment and 5 years of supervised release. Gibbs appealed the sentence, and the case was remanded for resentencing due to a sentencing error. Before resentencing, the United States Probation Office recommended twenty-one conditions of supervised release, including conditions "m" and "r."The United States District Court for the Southern District of Indiana, Evansville Division, resentenced Gibbs to 180 months of imprisonment and 5 years of supervised release. During the resentencing hearing, Gibbs confirmed that he had reviewed the proposed conditions of supervision with his attorney and had no objections. He also waived a formal reading of the conditions. The district court entered an amended final judgment on September 1, 2023.The United States Court of Appeals for the Seventh Circuit reviewed the case. Gibbs argued for the first time on appeal that two conditions of his supervised release were unconstitutionally vague and overbroad. The court determined that Gibbs had waived his objections to these conditions by affirmatively stating at the resentencing hearing that he had no objections and by waiving the formal reading of the conditions. The court held that this waiver precluded appellate review of his claims. Consequently, the Seventh Circuit affirmed the judgment of the district court. View "USA v Gibbs" on Justia Law

The case involves two petitions for a writ of quo warranto filed against certain members of the Minnesota House of Representatives. The petitions claim that at the start of the legislative session on January 14, 2025, the House did not have a quorum to transact business. Secretary of State Steve Simon, who has statutory responsibilities in the House at the start of the legislative session, brought one petition. Representatives Melissa Hortman, Jamie Long, and Athena Hollins brought the other petition. The issue arose because, following a district court ruling that a DFL member did not meet the residency requirement, the House had 67 members from each of the two major political parties, and only the Republican members were present.The Minnesota Supreme Court consolidated the cases and determined that Secretary of State Simon's petition was justiciable, thus not needing to address the justiciability of the other petition. The court held that the quorum clause in Article IV, Section 13, of the Minnesota Constitution requires a majority of the total number of seats of which each house may consist to constitute a quorum. Under current statute, the total number of seats in the Minnesota House of Representatives is 134, so a quorum is 68 members.The Minnesota Supreme Court concluded that the quorum clause's requirement of a majority of each house refers to the total number of seats prescribed by law, which is currently 134 for the House of Representatives. Therefore, a quorum requires 68 members. The court assumed that the parties would conform to this opinion without the necessity of issuing a formal writ. View "Simon v. Demuth" on Justia Law

Robin M. McNabb, a former Municipal Court Judge for Lenoir City, filed an election contest against Gregory H. Harrison, who won the election for the same position in 2022. McNabb argued that Harrison was ineligible to serve because he had not resided within the Lenoir City corporate limits for the year preceding the election, as required by Article VI, Section 4 of the Tennessee Constitution.The Chancery Court for Loudon County found that the term "district" in Article VI, Section 4 referred to the modern-day judicial district. Since Harrison resided in the Ninth Judicial District, the court ruled him eligible to serve. The Court of Appeals affirmed the trial court's decision but modified the judgment, stating that "district" referred to Loudon County, not the Ninth Judicial District, because the Lenoir City Municipal Court has concurrent jurisdiction with the Loudon County General Sessions Court.The Supreme Court of Tennessee reviewed the case and disagreed with the lower courts. It held that Article VI, Section 4 requires a candidate for a municipal judgeship to be a resident of the same municipality to which they will be assigned. Therefore, Harrison needed to reside in Lenoir City for one year prior to the election. The Supreme Court reversed the judgment of the Court of Appeals and remanded the case to the Chancery Court for further proceedings consistent with this opinion. View "McNabb v. Harrison" on Justia Law

Samuel Scott Copeland was convicted by a jury of attempting to prevent or dissuade a witness from giving testimony, in violation of Penal Code section 136.1, subdivision (a)(2). The conviction was based on allegations that Copeland withheld rent to pressure his friend and landlord, Madelyn Wagner, from testifying in a civil dispute involving their mutual friend, Trina West. The trial court sentenced Copeland to two years of formal probation and imposed but stayed a sentence of 365 days in custody, pending successful completion of probation.The Superior Court of San Diego County declined to reduce the charge to a misdemeanor. Copeland appealed, arguing that substantial evidence did not support the finding that Wagner was a “witness” within the meaning of section 136, subdivision (2) at the time of the alleged intimidation, that the jury instruction improperly expanded the definition of “witness,” and that the prosecution violated his First Amendment right to free speech.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court concluded that the term “witness” as defined in section 136, subdivision (2) does not include potential future witnesses to a civil dispute. Therefore, there was not substantial evidence that Wagner was a “witness” as used in the statute of conviction. Additionally, the court found that the model instruction given to the jury misstated the law in a prejudicial manner by improperly expanding the definition of “witness” to include potential future witnesses.As a result, the Court of Appeal reversed the judgment, holding that the conviction was not supported by substantial evidence and that the jury instruction contained a prejudicial misstatement of the law. View "P. v. Copeland" on Justia Law

Defendant-Appellant Kenston Harry was convicted of possessing controlled substances with intent to distribute and conspiracy to distribute the same. The case centers on the use of a stationary pole camera by the Drug Enforcement Administration (DEA) to monitor the exterior of Harry's business, Action Audio, for approximately 50 days without a warrant. The camera captured footage of the business's exterior, parking lot, and occasionally the interior when the garage door was open. Harry was arrested after investigators found narcotics and firearms at Action Audio and his residence.The United States District Court for the District of Connecticut denied Harry's motion to suppress the pole-camera evidence, which was introduced at trial. The jury convicted Harry, and the district court sentenced him to ten years for the fentanyl- and cocaine-related charges, including conspiracy, and five years for the marijuana charge, to run concurrently. The court also denied Harry's request for safety-valve relief from the mandatory minimum sentence under 18 U.S.C. § 3553(f).The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the use of the stationary pole camera did not constitute a Fourth Amendment search, as Harry did not have a reasonable expectation of privacy in the publicly visible areas of his business. The court also found that the district court did not err in denying Harry safety-valve relief, as he failed to prove that the firearms found were not connected to his drug-trafficking activities. The Second Circuit affirmed the judgment of the district court. View "United States v. Harry" on Justia Law

Gray Television, a broadcaster in Alaska, sought review of a final forfeiture order by the Federal Communications Commission (FCC). The FCC had imposed the maximum forfeiture penalty on Gray for violating the prohibition on owning two top-four stations in a single designated market area (DMA). Gray acquired the CBS network affiliation of KTVA-TV for its own station, KYES-TV, which resulted in Gray owning two top-four stations in the Anchorage DMA. Gray did not seek a waiver from the FCC for this transaction.The FCC issued a Notice of Apparent Liability for Forfeiture (NAL) against Gray, proposing a penalty of $518,283, the statutory maximum. Gray responded, arguing that the transaction did not violate the rule because KYES was already a top-four station according to Comscore ratings data. Gray also contended that the FCC failed to provide fair notice of its interpretation of the rule and that the enforcement action violated the First Amendment and the Communications Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the FCC's determination that Gray violated the rule, finding that the FCC reasonably relied on Nielsen ratings data, which showed that KYES was not a top-four station at the time of the transaction. The court also held that the FCC's interpretation of the rule was reasonable and that Gray had fair notice of the rule's application to its transaction.However, the court vacated the forfeiture penalty and remanded for further proceedings. The court found that the FCC failed to provide adequate notice to Gray that the proposed penalty was based on a finding of egregiousness, which violated due process. Additionally, the court held that the FCC did not adequately explain its consideration of Gray's good faith in determining the penalty amount. View "Gray Television, Inc. v. Federal Communications Commission" on Justia Law