Justia Constitutional Law Opinion Summaries

Eric Smith was the majority owner, chairman, and CEO of Consulting Services Support Corporation (CSSC), which wholly owned CSSC Brokerage Services, Inc. (CSSC-BD), a registered FINRA broker-dealer. Although CSSC-BD was registered, Smith did not personally register with FINRA, claiming an exemption so long as he was not involved in managing the securities business. However, between 2010 and 2015, Smith actively managed CSSC-BD, including overseeing debt offerings, preparing offering documents with false statements, and soliciting investments totaling $130,000 from four investors. A FINRA examination and investor complaints uncovered these activities.Following an investigation, FINRA’s Department of Enforcement filed a complaint against Smith for violations of federal securities laws and FINRA rules. After a disciplinary proceeding, FINRA found against Smith and imposed sanctions, including $130,000 in restitution and a bar from associating with any FINRA member. Smith appealed to the United States Securities and Exchange Commission (SEC), which affirmed FINRA’s findings and sanctions. Smith then sought review in the United States Court of Appeals for the Sixth Circuit, arguing that FINRA lacked jurisdiction over him and that the proceedings violated his rights under Article III and the Seventh Amendment.The United States Court of Appeals for the Sixth Circuit held that FINRA had statutory authority to discipline Smith because, despite not registering, he controlled a FINRA member firm and was therefore a “person associated with a member” under the relevant statute. The court found Smith’s constitutional claims barred because he failed to raise them before the SEC as required by statute, and none of the exceptions to the exhaustion requirement applied. The petition for review was denied. View "Smith v. Securities and Exchange Commission" on Justia Law

The petitioner, a Jamaican national who became a lawful permanent resident of the United States in 1971, was removed from the country in 2007 following a 1996 conviction under New York law for the attempted sale of a “narcotic drug.” Many years later, based on a recent Second Circuit decision—United States v. Minter—that held the relevant New York statute was broader than its federal counterpart, the petitioner filed a motion to reconsider or reopen his removal order, arguing that the legal basis for his removal no longer applied. He filed this motion within thirty days of the Minter decision.The Board of Immigration Appeals (BIA) denied the petitioner’s motion, concluding that he had not demonstrated the due diligence necessary to warrant equitable tolling of the filing deadlines for such motions. The BIA reasoned that an earlier Second Circuit case, Harbin v. Sessions, should have prompted the petitioner to file sooner. The BIA interpreted the petitioner’s arguments as asserting that Harbin constituted a fundamental change in the law sufficient to support his motion, and therefore found his delay unreasonable.On review, the United States Court of Appeals for the Second Circuit found that the BIA mischaracterized the petitioner’s arguments and misunderstood the legal significance of the Harbin and Minter decisions. The court held that the petitioner’s rights to relief did not arise until Minter, and he was not required to file earlier motions based on law that had not yet changed. The Second Circuit therefore held that the BIA abused its discretion, vacated the BIA’s order, granted the petition for review and motion to stay removal, and remanded the case to the BIA for further proceedings consistent with its opinion. View "Ramsay v. Bondi" on Justia Law

The petitioner was charged in Marshall County, West Virginia, with multiple counts of sexual abuse involving two victims, one of whom was a child. Before trial, the circuit court allowed the child victim to testify via live, closed-circuit television, as permitted by state statute. However, the petitioner elected to leave the courtroom during the child’s testimony, after which he was convicted on all counts. Following his conviction, the petitioner sought habeas corpus relief, raising several claims including the constitutionality of the closed-circuit testimony procedure, the validity of his indictments, his absence from certain pretrial hearings, allegations of improper jury communications, and ineffective assistance of counsel.The Circuit Court of Marshall County initially denied habeas relief without a hearing, but the Supreme Court of Appeals of West Virginia remanded for an omnibus evidentiary hearing, particularly on ineffective assistance of counsel and sentencing concerns. On remand, the circuit court granted relief only on the petitioner’s ex post facto sentencing claim, ordering resentencing on certain counts, and denied all other claims, finding that the petitioner either waived them by not raising them on direct appeal or failed to demonstrate ineffective assistance of counsel.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the circuit court’s rulings. The court held that because the petitioner did not raise his constitutional and procedural claims on direct appeal and failed to rebut the presumption of waiver, those claims could only be considered within the framework of ineffective assistance of counsel. The court concluded the petitioner’s counsel was not deficient under the standards set by Strickland v. Washington and State v. Miller, and that none of the challenged actions or omissions prejudiced the outcome of the trial. The court also held that Crawford v. Washington did not overrule Maryland v. Craig, and the statutory closed-circuit testimony procedure remained constitutional. View "Arthur C. v. Frame" on Justia Law

A man with two prior felony convictions crashed his car late at night in 2023. When law enforcement arrived, he admitted to drinking. Officers found a vodka bottle and a loaded handgun with a magazine on the ground near the vehicle, as well as a second magazine in the car’s front seat. Both magazines matched the firearm, which had been reported stolen. The man’s criminal record included a violent robbery and a prior conviction for possession of a firearm by a felon, among other offenses. Based on these events, he was charged in the Middle District of North Carolina with being a felon in possession of a firearm and ammunition under 18 U.S.C. § 922(g)(1).In the United States District Court for the Middle District of North Carolina, the defendant moved to dismiss the indictment, claiming that § 922(g)(1) violated the Second Amendment. The district court rejected this argument. The defendant then pleaded guilty while reserving his right to appeal the constitutional issue. At sentencing, the Presentence Report determined that the offense involved a semiautomatic firearm capable of accepting a large capacity magazine, setting his base offense level accordingly. The defendant did not object to the report and confirmed his agreement in open court. The district court adopted the report and sentenced him to 66 months in prison.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed his constitutional and sentencing challenges. The court held that circuit precedent foreclosed both his facial and as-applied Second Amendment challenges to § 922(g)(1). The court also held there was no error in applying the “large capacity magazine” sentencing enhancement, and that the sentence was both procedurally and substantively reasonable. The Fourth Circuit affirmed the judgment of the district court. View "US v. Holman" on Justia Law

An inmate in an Arkansas maximum-security unit, who is Muslim, challenged a change in prison policy regarding meals served during Ramadan. Previously, fasting Muslims received a “double-portion” dinner after sunset and a standard breakfast before dawn. In 2023, the prison discontinued the double-portion dinner, providing only standard portions for both meals, but continued to serve them at the appropriate times for religious observance. The meals together provided at least 2,000 calories per day. The inmate often skipped the provided breakfast during Ramadan, preferring to eat commissary food instead, which he could easily obtain.The United States District Court for the Eastern District of Arkansas, Central Division, granted summary judgment to the prison officials, concluding that the new meal policy did not violate the inmate’s rights under the Eighth Amendment or the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the inmate’s allegations of hunger and physical symptoms were not corroborated by medical evidence, and that the inmate’s ability to supplement with commissary food meant he was not denied adequate nutrition.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the prison’s policy did not impose a substantial burden on the inmate’s religious exercise under RLUIPA. The court emphasized that the inmate’s claimed need for 3,000 calories was not rooted in religious belief, but rather based on the institution’s general meal plan. The record showed that the meals provided were nutritionally adequate and that the inmate voluntarily skipped breakfast, supplementing from the commissary. Because the inmate failed to show a genuine dispute of material fact regarding a substantial burden on his religious exercise, the Eighth Circuit affirmed the district court’s judgment. View "Holt v. Payne" on Justia Law

Peace officers developed probable cause to believe that controlled substances were being distributed from a house in Des Moines. After conducting multiple controlled buys, officers obtained a premises search warrant for the house. On the morning the warrant was executed, Andrew Porter arrived at the house carrying a backpack. About forty minutes later, officers entered and found Porter in the living room; the backpack was in a corner, not within his immediate reach. During the search, Porter repeatedly denied ownership of or knowledge about the backpack, both when questioned outside and inside the house. Officers searched the backpack and found methamphetamine, marijuana, and drug paraphernalia. Porter was arrested and charged with several drug offenses.Porter filed a motion to suppress the evidence obtained from his backpack, arguing that the search violated his constitutional rights under the Fourth Amendment and the Iowa Constitution. The Iowa District Court for Polk County denied the motion after reviewing evidence, including bodycam footage. Porter sought and was granted discretionary review to challenge this ruling.The Supreme Court of Iowa addressed whether the federal or state constitutional right to be free from unreasonable searches prohibits officers executing a search warrant from searching a container on the premises, such as a backpack, capable of holding evidence described in the warrant, when the container is not in a person’s physical possession. The court held that the search of the backpack was within the scope of the premises warrant because it was not in Porter’s physical possession at the time of the search and was a plausible repository for the evidence sought. The court further found that Porter’s repeated denials of any connection to the backpack constituted abandonment, negating any privacy interest. The court affirmed the district court’s denial of the motion to suppress. View "State v. Porter" on Justia Law

In 2018, a juvenile wardship petition alleged that E.J. committed several offenses, including assault with a deadly weapon other than a firearm. E.J. admitted to that charge as part of a negotiated disposition, and the juvenile court found the allegations true, dismissed the remaining counts, declared E.J. a ward of the court, and placed him on probation. In 2019, the court reduced the offense to a misdemeanor, terminated probation, discharged E.J. as a ward, and sealed the record. Despite these actions, E.J. remained subject to a statutory firearm prohibition until age 30 under Penal Code section 29820.In 2025, E.J. filed a motion in the Superior Court of San Bernardino County to terminate the firearm prohibition. The juvenile court denied the motion. E.J. appealed, arguing that Penal Code section 29820 was facially unconstitutional under the Second and Fourteenth Amendments, claiming it failed to align with the nation’s historical tradition of firearm regulation, improperly used age as a proxy for dangerousness, and did not provide a mechanism for individualized assessment regarding dangerousness.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that section 29820 is not facially unconstitutional. It found that firearm prohibitions based on juvenile adjudications for certain offenses are consistent with the historical tradition of firearm regulation and that the statute’s application based on prior adjudication—not age alone—does not offend the Second Amendment. The court also held that due process does not require an individualized assessment of dangerousness when the statute’s application is triggered solely by a prior adjudication. The court further found that any as-applied challenge was forfeited because it was not raised in the trial court or in E.J.’s opening brief. The order was affirmed. View "In re E.J." on Justia Law

A criminal complaint was filed against an individual in July 2024, alleging multiple counts of lewd acts, forcible lewd acts, and continuous sexual abuse of four minors, all of whom are his grandchildren. The prosecution also alleged a multiple victim enhancement. At an initial arraignment, the magistrate court set bail and imposed protective orders. Later, the prosecution moved to have the defendant held without bail, citing the danger he posed to the community. At a Humphrey hearing, the prosecution presented testimony and evidence suggesting repeated sexual abuse over many years, including admissions by the defendant. The magistrate court found this evidence reliable and determined that nonfinancial conditions of release would not protect the public or victims, ordering the defendant held without bail.The defendant challenged the no-bail order in the Superior Court of Fresno County through a petition for writ of habeas corpus. He argued the magistrate court abused its discretion, particularly in considering the prosecution’s request for remand without bail absent a change in circumstances, and asserted there was insufficient evidence to support a finding of substantial likelihood of great bodily harm. The superior court issued an order to show cause on these specific issues but ultimately denied the petition after considering the parties’ responses.Upon further review, the California Court of Appeal, Fifth Appellate District, was directed by the California Supreme Court to address whether Penal Code section 292 constitutes an impermissible legislative extension of the constitutional terms “acts of violence” and “great bodily harm,” and whether, absent section 292, clear and convincing evidence supported denial of bail. The appellate court held that section 292 is a valid legislative implementation, not an invalid extension, of the bail exception in article I, section 12 of the California Constitution. The court further found that substantial evidence supported the finding that the defendant’s release would pose a substantial likelihood of great bodily harm, and denied the petition for writ of habeas corpus. View "In re Bergstrom" on Justia Law

Four women incarcerated at the Huron Valley Correctional Facility in Michigan suffered from persistent, painful rashes between 2016 and 2019. Despite repeated complaints, medical staff—contracted through Corizon Health—failed to diagnose scabies, instead providing ineffective treatments and attributing the condition to environmental factors like improper laundering. It was only after an outside dermatologist intervened that scabies was correctly identified, prompting prison-wide treatment efforts. However, these efforts were delayed and, in some cases, inadequate, resulting in prolonged suffering for the affected inmates.After their experiences, the four women filed suit in the United States District Court for the Eastern District of Michigan against multiple defendants, including high-level Michigan Department of Corrections officials and Wayne State University medical officers, alleging Eighth Amendment violations and state-law negligence. The district court found that the women’s complaint plausibly alleged “clearly established” Eighth Amendment violations by all defendants and denied the officials’ request for qualified immunity. The court also rejected a claim of state-law immunity, finding that the officials could be the proximate cause of the inmates’ injuries under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denials. The Sixth Circuit held that existing precedent did not “clearly establish” that the non-treating prison officials’ reliance on contracted medical providers was so unreasonable as to violate the Eighth Amendment. Thus, it reversed the district court’s denial of qualified immunity on the federal damages claims. However, the appellate court affirmed the denial of state-law immunity, finding the plaintiffs adequately pleaded proximate cause under Michigan law. The case was remanded for further proceedings consistent with these holdings. View "Machelle Pearson v. MDOC" on Justia Law

Several women incarcerated at a Michigan prison developed painful, persistent rashes between 2016 and 2019. Their complaints were largely ignored by prison staff, and medical providers initially misdiagnosed the condition, ruling out scabies, a highly contagious skin infestation. The prison’s contracted health care provider, Corizon Health, and its infectious disease coordinator were tasked with managing infectious diseases but failed to control the outbreak. Only after an outside dermatologist diagnosed scabies did prison officials begin widespread treatment and quarantine measures, though these efforts were not immediately effective. Four inmates who suffered from these conditions filed suit, seeking damages and injunctive relief against both the medical providers and high-level prison officials who had not directly treated them.The United States District Court for the Eastern District of Michigan denied motions for judgment on the pleadings by the Michigan Department of Corrections and Wayne State Officials. The district court held that the inmates had plausibly alleged that all defendants, including non-treating prison officials, committed clearly established Eighth Amendment violations and were not entitled to qualified immunity. The court also found that the gross negligence claims could proceed under Michigan law, as the complaint adequately alleged that the officials proximately caused the harms.On appeal, the United States Court of Appeals for the Sixth Circuit determined that, under existing precedent, non-treating prison officials’ reliance on contracted medical providers did not clearly constitute an Eighth Amendment violation. The court reversed the district court’s denial of qualified immunity on the inmates’ federal damages claims against these officials, finding no clearly established law requiring them to override medical judgments. However, the court affirmed the denial of state-law immunity, concluding that proximate cause under Michigan law could not be resolved at the pleading stage. The case was remanded for further proceedings consistent with these rulings. View "BLC Lexington SNF, LLC v. Townsend" on Justia Law