Justia Constitutional Law Opinion Summaries

Kenneth Karwacki was convicted by a special court martial of delivering peyote to fellow soldiers and received a bad-conduct discharge from military service. Later, he applied for a permit to carry a concealed firearm in Wisconsin. The state denied his application under Wis. Stat. §941.29(1m)(b), which bars firearm possession by anyone convicted of a crime elsewhere that would be a felony if committed in Wisconsin. Although the military court labeled his offense a misdemeanor, Wisconsin classified his conduct as a felony under its own laws.Karwacki brought a federal lawsuit, arguing that Wisconsin’s decision to treat his military misdemeanor conviction as a state-law felony violated the Full Faith and Credit Clause of the U.S. Constitution and his Second Amendment rights. The United States District Court for the Eastern District of Wisconsin entered judgment in favor of the state, rejecting Karwacki’s claims.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that the Full Faith and Credit Clause does not apply to federal court martial convictions because such proceedings are not “judicial Proceedings of any other State,” nor has Congress prescribed any effect for court martial judgments in the states. The court also concluded that Wisconsin did not fail to give effect to the court martial’s judgment, as it imposed only collateral consequences under state law. Addressing the Second Amendment, the Seventh Circuit reasoned that neither the federal nor Wisconsin’s statutory scheme is facially invalid, and that individuals convicted of distributing illegal drugs are not entitled to as-applied relief from firearms disabilities. Therefore, the judgment was affirmed. View "Karwacki v Kaul" on Justia Law

Fifth Generation, Inc., a Texas-based liquor manufacturer and subchapter S corporation known for producing Tito’s Vodka, supplied increasing quantities of vodka to Maine between 2011 and 2017 without filing Maine pass-through-entity withholding or income tax returns. The company did not own real estate or hold itself out as doing business in Maine but shipped its products to a Maine state-operated bailment warehouse, as required by state law. Fifth Generation retained title to the goods in the warehouse until they were sold to the Maine Bureau of Alcoholic Beverage and Lottery Operations, and its out-of-state employees and broker occasionally accessed the warehouse.Maine Revenue Services conducted an audit and assessed over $748,000 in withholding, interest, and penalties against Fifth Generation. The company appealed to the Maine Board of Tax Appeals, which found no income tax nexus and canceled the assessment. The State Tax Assessor then sought de novo review in the Maine Superior Court (Kennebec County), which granted summary judgment for the Assessor, reinstating the assessment. Fifth Generation subsequently appealed to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court held that Fifth Generation was not exempt from state income tax during the audit period. The Court found that, under Maine law, Fifth Generation had a sufficient nexus with Maine because it owned tangible property in the state and sold it there. The Court also concluded that neither federal law (15 U.S.C. § 381(a)), the Commerce Clause, nor any constitutional provision barred the tax, as Maine’s regulatory scheme served a legitimate state purpose and was applied equally to in-state and out-of-state businesses. The Court further held that Fifth Generation did not have “substantial authority” to justify waiving penalties. The Superior Court’s judgment was affirmed. View "State Tax Assessor v. Fifth Generation, Inc." on Justia Law

A group of students, their parents or guardians, and local school boards from several low-wealth and urban school districts in North Carolina brought suit against the State and the State Board of Education in 1994. They claimed that the State’s method of funding education deprived students in their districts of their constitutional right to the opportunity for a sound basic education, focusing on perceived inadequacies in the implementation and funding of the Basic Education Program (BEP) as it then existed. The plaintiffs did not allege that the statewide education system was unconstitutional on its face, but rather that it was unconstitutional as applied to their specific districts due to disparities in resource allocation.After various procedural developments, including intervention by additional parties and the dismissal of some claims, the case reached the Supreme Court of North Carolina, which previously clarified that the right at issue belonged only to students, not school boards. The Supreme Court held in Leandro v. State that the constitution guarantees every child the opportunity for a sound basic education, and remanded the case for as-applied determinations regarding whether that right was denied in the named districts. In Hoke County Board of Education v. State, the Supreme Court affirmed a trial court finding that at-risk students in Hoke County had been deprived of their right, but otherwise found the statewide education system generally constitutional as then structured. The Supreme Court remanded for further as-applied proceedings in the other named districts, but no further trials occurred.Over time, the case’s subject matter shifted, and the trial court, with the parties’ acquiescence, began addressing a statewide, facial challenge to the current education system, including ordering the implementation of a statewide remedial plan without a new or amended complaint raising such a claim. The Supreme Court of North Carolina, reviewing an order entered on 17 April 2023, held that the trial court lacked subject matter jurisdiction to adjudicate a facial challenge to the statewide education system, since no party had properly invoked jurisdiction over such a claim by amending the pleadings or following the statutory procedure. The Court vacated the trial court’s order and dismissed the action with prejudice, concluding that any orders entered after 24 July 2017, when the litigation’s nature changed, were void for lack of subject matter jurisdiction. View "Hoke Cnty. Bd. of Educ. v. State" on Justia Law

A man whose only prior felony conviction had been expunged by a Missouri state court was arrested by a Missouri State Highway Patrol trooper for possessing a firearm as a convicted felon. The trooper had accessed his criminal history report, which still listed the expunged conviction with a notation indicating it was “Closed Pursuant to Chapter 610 RSMo.” However, the Missouri State Highway Patrol did not train officers to understand this notation meant the conviction was expunged and could not serve as a basis for arrest. The man informed the trooper of his expungement at the scene, but she stated she had to rely on the report’s information.Following his arrest, the plaintiff filed suit under 42 U.S.C. § 1983 in Missouri state court, asserting claims for damages and prospective relief against the Highway Patrol’s superintendent and others. The case was removed to the United States District Court for the Western District of Missouri. The superintendent moved to dismiss the official-capacity claim on sovereign immunity grounds and the individual-capacity failure-to-train claim on qualified immunity grounds. The district court denied both motions, prompting the defendants to file an interlocutory appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of immunity de novo. The appellate court held that the current superintendent was a proper Ex parte Young defendant for purposes of prospective relief, as he had sufficient connection to the dissemination practices that risked future constitutional violations. The court also held that the plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train. Accordingly, the Eighth Circuit affirmed the district court’s denial of sovereign and qualified immunity. View "Cunningham v. Olson" on Justia Law

After an argument at an apartment, Deon Andre Jennings was charged with the murder of Willie Houston. During the confrontation, Houston asked Jennings to leave several times, but Jennings refused. When Houston stepped outside, Jennings attempted to lock him out, but Houston forced his way back in, ending up on top of Jennings. While on the floor, Jennings struck Houston in the back multiple times with an object. Houston left the apartment, sought help, and later died from deep stab wounds. Jennings claimed self-defense, asserting he struck Houston only to get him off, not to kill him, and that he did not know what object he used.The Third District Court, Salt Lake County, conducted a pretrial justification hearing under Utah Code section 76-2-309, which allows for an evidentiary hearing on self-defense before trial. Jennings argued that a written proffer of facts was sufficient to make a prima facie claim of justification, while the State contended evidence was necessary. The district court found that a proffer alone was not enough; it considered both Jennings’ proffer and his attached exhibits. The court determined that Jennings’ evidence did not support a claim that he reasonably believed force was necessary to defend himself, and found that Houston had not threatened or physically assaulted Jennings.The Supreme Court of the State of Utah affirmed the district court’s ruling. It held that, to make a prima facie claim of justification under the statute, a defendant must present evidence at the hearing that, if believed, would be legally sufficient to satisfy each element of a justification defense. This is a burden of production, not of proof. Because Jennings failed to present evidence indicating he subjectively believed the force he used was necessary for self-defense, the denial of his motion to dismiss was affirmed. View "State v. Jennings" on Justia Law

A sitting district court judge in Kentucky faced potential discipline from the state Judicial Conduct Commission (JCC) after making statements to a newspaper during her reelection campaign. The statements concerned her prior suspension for inappropriate comments about an attorney accused of diverting funds from her husband’s law firm. The JCC claimed her remarks to the newspaper were false or misleading, implicated her opponent, and downplayed the seriousness of her misconduct. The Commission sent her a proposed agreed public reprimand order, which she refused to sign. Believing the JCC’s actions chilled her speech and threatened enforcement under three specific judicial conduct rules, the judge sued JCC officials, alleging violations of her First Amendment rights.The United States District Court for the Eastern District of Kentucky partially granted and partially denied the judge’s claims. It granted her summary judgment and a permanent injunction on her as-applied challenge to Rule 4.1(A)(11), which prohibits judicial candidates from knowingly making false statements of material fact, finding the JCC’s enforcement against her statements unconstitutional. However, the district court denied her as-applied challenges to Rules 1.2 and 2.4(B), which address judicial independence and the influence of personal relationships, as well as her facial challenges to all three rules.The United States Court of Appeals for the Sixth Circuit found the judge had standing to sue and that the district court properly granted her an injunction under Rule 4.1(A)(11). However, the appellate court held that the district court erred in denying her as-applied challenges to Rules 1.2 and 2.4(B), as the JCC’s enforcement was not supported by evidence of false statements. The Sixth Circuit affirmed the injunction as to Rule 4.1(A)(11), reversed as to Rules 1.2 and 2.4(B), and remanded for entry of a permanent injunction against enforcement of all three rules as applied to the judge’s statements. View "Dutton v. Shaffer" on Justia Law

Two individuals challenged the Puerto Rican electoral commission and its acting president, arguing that restrictions on early and absentee voting during the 2020 general election unlawfully burdened the right to vote for citizens over sixty, especially considering the COVID-19 pandemic. In August 2020, they brought suit under 42 U.S.C. § 1983, seeking relief on constitutional grounds. The district court promptly issued a preliminary injunction, then a permanent injunction, allowing voters over sixty to vote early by mail. After judgment, the plaintiffs were awarded nearly $65,000 in attorneys’ fees under 42 U.S.C. § 1988.While the fee motion was pending, Puerto Rico’s government was in the process of debt restructuring under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The restructuring plan, confirmed in January 2022, discharged claims against Puerto Rico arising before the plan’s effective date unless creditors filed proof of claim by a set deadline. Defendants argued in the U.S. District Court for the District of Puerto Rico that the attorneys’ fees award was subject to the plan’s discharge and enjoined from collection, because the plaintiffs had not filed a timely administrative expense claim. The district court rejected this, finding the fee award unrelated to the bankruptcy case.On appeal, the United States Court of Appeals for the First Circuit concluded that the claim for attorneys’ fees, though arising from post-petition litigation, related to events before the plan’s effective date. The court held that because the plaintiffs had actual knowledge of the restructuring proceedings but did not file a timely proof of claim, their fee claim was discharged under the confirmed plan and enjoined from collection. The First Circuit reversed the district court’s order, holding that the discharge injunction applied to the attorneys’ fee award. View "Ocasio v. Comision Estatal de Elecciones" on Justia Law

The case involves Michael Donnell Lee, who was charged with murder and related offenses following the shooting death of Aaron James Grant. After his arrest, Lee underwent a custodial interrogation by Detective Charles Sendling of the Atlanta Police Department, during which Lee made incriminating statements. Prior to making these statements, Lee invoked his rights to counsel and to remain silent after being read his Miranda rights. The detective, after a brief pause and some procedural activity, re-engaged Lee in conversation, during which Lee ultimately agreed to talk and then made several incriminating statements during the ensuing interview.Before trial, the State moved to admit Lee’s statements, but the Superior Court of Fulton County excluded them, ruling that they were inadmissible under Miranda v. Arizona and Edwards v. Arizona because Lee had invoked his constitutional rights and had not reinitiated communication with the police. The trial court also found the statements to be involuntary as a matter of due process, citing Lee’s limited education and potential intellectual disability, and the detective’s conduct during the interrogation.The Supreme Court of Georgia reviewed the State’s interlocutory appeal. It agreed with the lower court that Lee did not reinitiate communication after invoking his rights, and that the detective’s subsequent interrogation was improper under Miranda and Edwards. The court clarified that Lee’s follow-up questions were mere clarifying inquiries and not an indication of a desire to discuss the investigation. However, the Supreme Court of Georgia disagreed with the trial court’s finding that the statements were involuntary under due process principles, finding no evidence of coercive police activity. The court affirmed the suppression of Lee’s statements for the prosecution’s case-in-chief but reversed their exclusion for impeachment purposes if Lee testifies. View "STATE v. LEE" on Justia Law

A United States citizen originally from Yemen filed family-based visa petitions (Form I-130) in 2002 on behalf of several relatives, including his stepdaughter. The immigration authorities sent a notice of intent to deny these petitions and a subsequent denial letter to the address provided on the petition. The petitioner did not respond, and the petitions were denied. Twenty years later, the petitioner sued, asserting that he never received the notices because the agency had mistakenly sent them to an address where he did not live, and that this lack of notice violated the Due Process Clause and the Administrative Procedure Act. He attached a redacted version of his petition to his complaint, omitting the address at issue.The United States District Court for the Northern District of Illinois, Eastern Division, initially denied the government’s motion to dismiss, finding that the complaint plausibly supported the application of the discovery rule or equitable tolling and otherwise stated a claim. However, when the government moved for judgment on the pleadings and submitted an unredacted copy of the I-130 petition showing that the petitioner himself had listed the very address to which the notices were sent, the court found this document dispositive. The petitioner did not meaningfully contest the authenticity or content of the unredacted petition, failed to appear at the hearing, and did not object to the government’s supporting affidavit.On appeal, the United States Court of Appeals for the Seventh Circuit held that the unredacted I-130 petition conclusively refuted the petitioner’s factual claims. The court held that when a plaintiff’s own incorporated documents contradict the complaint’s allegations, those documents control. The court affirmed the district court’s entry of judgment for the government, finding that the due process and APA claims failed as a matter of law. View "Muthana v Mullin" on Justia Law

During the summer of 2025, protests erupted in Southern California in response to federal immigration raids. Protesters, legal observers, and journalists alleged that officers of the Department of Homeland Security (DHS), including agents from Immigration and Customs Enforcement, the Federal Protective Services, and Customs and Border Protection, used crowd control weapons indiscriminately against them. Multiple individuals, including members of the press and protesters, suffered significant physical injuries during these events, even when they were complying with police orders or were not near disruptive protest activity.Several individual journalists, legal observers, protesters, and two press organizations filed suit in the United States District Court for the Central District of California. They alleged violations of their First Amendment rights, specifically the right to be free from retaliation for engaging in protected activities and the right of public access to protests. The district court issued a preliminary injunction to protect the rights of protesters, journalists, and legal observers, finding that the defendants’ conduct chilled First Amendment activity. The government appealed, arguing that the injunction was overly broad and legally unsound.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s decision. The Ninth Circuit held that the plaintiffs were likely to succeed on their First Amendment retaliation claims, that both individual and organizational plaintiffs had standing, and that the other requirements for a preliminary injunction were met. However, the court found that the scope of the injunction was overbroad because it extended relief to non-parties and included provisions not narrowly tailored to the specific harms alleged. The Ninth Circuit affirmed the district court’s decision to issue a preliminary injunction but vacated and remanded the case for the district court to craft a narrower injunction consistent with its opinion. View "LOS ANGELES PRESS CLUB V. NOEM" on Justia Law