Justia Constitutional Law Opinion Summaries

Two days after a double homicide occurred in Bernalillo County, New Mexico, a vehicle registered in New Mexico was stopped in Wheeler County, Texas, for an equipment violation. The defendant was a passenger in the vehicle. During the stop, the Texas deputy sheriff questioned the driver, who eventually admitted there was marijuana in the car. The deputy conducted a probable cause search, detained the defendant, and discovered a handgun, later linked to the New Mexico homicides.The defendant was indicted in New Mexico on charges related to the homicides and other crimes. He moved to suppress the physical evidence and statements obtained during the Texas stop, arguing the search violated both the U.S. Constitution and Article II, Section 10 of the New Mexico Constitution. The State argued Texas law should govern the admissibility of the evidence, as the search occurred in Texas and was lawful there. The District Court of Bernalillo County disagreed, applying New Mexico’s exclusionary rule and suppressing the evidence, relying on New Mexico cases concerning evidence gathered by federal agents within New Mexico.The Supreme Court of the State of New Mexico reviewed whether the district court correctly applied New Mexico’s constitutional exclusionary rule to evidence obtained in another state, where the search complied with that state’s law but would violate New Mexico’s constitution. The court held that Article II, Section 10 of the New Mexico Constitution governs the admissibility of evidence in New Mexico courts, regardless of whether the evidence was obtained by out-of-state law enforcement in compliance with their own laws. Evidence gathered in violation of Article II, Section 10 is inadmissible in New Mexico courts. The court affirmed the district court’s order suppressing the evidence. View "State v. Causey" on Justia Law

A special education administrator was employed by a Wisconsin state agency that facilitated educational services across multiple school districts. After a couple years, her supervisors, following directives from the Wisconsin Department of Public Instruction, pushed staff to adopt an “equity mindset,” which involved examining personal biases and working to disrupt systems influenced by white supremacy. The administrator disagreed with the perceived ideological requirements and refused to fully embrace the equity mindset, leading to concerns from the Department of Public Instruction, pressure on the agency, and her eventual demotion to a lower-paying job.The administrator filed suit in the United States District Court for the Eastern District of Wisconsin, alleging violations of Title VII and the Equal Protection Clause, claiming discrimination and retaliation based on her race. She also asserted a First Amendment claim, alleging retaliation based on her speech and beliefs. The district court granted summary judgment to the defendants on the Title VII and Equal Protection claims, finding no evidence that race was a motivating factor in her demotion, as the ideological requirements were applied to employees of all races. The court rejected her First Amendment claims regarding her speech and insufficiently pleaded her beliefs-based claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the district court’s summary judgment on the Title VII and Equal Protection claims, holding that no reasonable jury could find her race was the cause of her demotion and that she did not engage in an objectively reasonable protected activity for retaliation purposes. However, the Seventh Circuit determined she adequately pleaded a First Amendment claim based on retaliation for her beliefs and remanded that claim for further proceedings. View "Spengler v Cooperative Educational Service Agency 7" on Justia Law

The defendant was investigated after law enforcement used a specialized tool called Freenet Roundup, which is a modified version of a peer-to-peer software called Freenet. Freenet allows users to share files anonymously, but its Opennet mode warns users that their identity could be discovered and their IP address is visible to strangers. Freenet Roundup, available only to law enforcement, logs requests for known child sexual abuse material (CSAM) and uses a formula to help identify whether a request came from an original source or was simply relayed. After Freenet Roundup flagged requests associated with the defendant’s IP address for CSAM, the FBI obtained a search warrant for his residence, finding devices containing child pornography.The defendant was charged in the United States District Court for the District of Massachusetts with possession of child pornography. Before trial, he moved to suppress the evidence, arguing that law enforcement’s use of Freenet Roundup constituted an unlawful Fourth Amendment search, as he claimed a reasonable expectation of privacy in his Freenet transmissions. The district court denied the motion, reasoning that because the defendant voluntarily used Freenet’s Opennet mode, which warns of identity risks and connections with strangers, he lacked a reasonable expectation of privacy in the relevant activity. The court distinguished this case from Carpenter v. United States, finding that law enforcement’s actions did not amount to wholesale surveillance or use of technology not in general public use. The defendant then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s findings for clear error and its legal conclusions de novo. The First Circuit held that a defendant lacks a reasonable expectation of privacy in activity voluntarily shared on publicly-available peer-to-peer networks like Freenet’s Opennet mode. The court affirmed the district court’s denial of the suppression motion. View "US v. Johnson" on Justia Law

A city owned shares in a mutual water company that were appurtenant to land it held. After a dispute regarding the city’s right to inspect corporate records, the water company cancelled the city’s shares, citing Corporations Code section 14300, which requires mutual water companies to cancel appurtenant shares held by public entities. The city argued that this statute violated its rights under article XVI, section 17 of the California Constitution, which allows public entities to acquire and hold shares in mutual water companies for furnishing water for public, municipal, or governmental purposes.The Superior Court of Lake County initially issued a temporary restraining order invalidating a board election and later granted the city’s request for a preliminary injunction. The injunction required the water company to re-issue the cancelled shares to the city, concluding that Corporations Code section 14300 was unconstitutional because it conflicted with section 17 of the state constitution. The trial court found that the city’s operation of a public facility, such as a splash pad, constituted a valid public purpose under section 17 and determined that the city was likely to suffer harm without the injunction.On appeal, the Court of Appeal of the State of California, First Appellate District, Division One, reviewed the constitutionality of Corporations Code section 14300 de novo, applying a presumption in favor of the statute’s validity. The appellate court interpreted section 17 as permitting public entities to hold shares only when acting as a water purveyor for their territory, not merely as a landowner receiving water for its own parcels. The court held that section 14300 does not violate section 17, as the statute can reasonably be construed to exclude appurtenant shares from the constitutional exception. Accordingly, the Court of Appeal reversed the trial court’s order granting the preliminary injunction and remanded the case for further proceedings. View "City of Clearlake v. Highlands Mutual Water Co." on Justia Law

A semi-truck driver was stopped in Illinois after state police received a tip from another law enforcement agency that the truck was carrying a large amount of narcotics. Two K9 troopers, not on routine patrol, waited on the side of the highway in the early morning hours to intercept the vehicle. The stated purpose for the stop was to conduct an administrative Level 3 inspection under Illinois’s commercial trucking regulatory scheme, involving checks of driver and vehicle documents. During the stop, the trooper noticed several signs he considered suspicious, including an odor of air freshener and irregularities with the driver’s route and cargo. A dog sniff of the truck led to the discovery of narcotics, and the driver was arrested.The United States District Court for the Central District of Illinois heard the defendant’s suppression motion, in which he argued the stop was a pretextual administrative inspection aimed solely at investigating criminal activity, thus violating the Fourth Amendment. The district court denied the motion, reasoning that the officer’s subjective intent was irrelevant so long as the stop was authorized under Illinois’s regulatory scheme.On appeal, the United States Court of Appeals for the Seventh Circuit held that, in the context of administrative inspections, an officer’s actual motivation for conducting the stop is relevant. The court found that the evidence showed the stop was undertaken solely to further a criminal investigation, not to enforce administrative regulations. It further held that the government had failed to demonstrate the stop was justified in its inception under the administrative inspection exception to the warrant requirement. The court concluded that the evidence obtained as a result of the stop must be suppressed and that the good faith exception to the exclusionary rule did not apply. The Seventh Circuit reversed the district court’s denial of the suppression motion and remanded for further proceedings. View "USA v. Martinez" on Justia Law

Several individuals who hold concealed-carry pistol licenses issued by the District of Columbia challenged a local law prohibiting licensed carriers from possessing firearms on public transportation, including the Metro system. Fearing prosecution if they carried their pistols on the Metro, these plaintiffs avoided using public transit and instead paid for more expensive private transportation. They alleged that this criminal statute violated their Second and Fifth Amendment rights and sought declaratory, injunctive, and monetary relief against the District and several officials in both their official and personal capacities.The United States District Court for the District of Columbia initially denied the plaintiffs’ motion for injunctive relief, citing circuit precedent that required them to demonstrate a special law enforcement priority or heightened risk of prosecution. When the plaintiffs amended their complaint to include allegations of increased transportation costs and added defendants, the District Court dismissed the case for lack of standing. Specifically, it found the plaintiffs had not alleged facts indicating a credible and imminent threat of prosecution, and it rejected their economic injury as insufficient for standing. The court also dismissed damages claims against individual defendants, which plaintiffs abandoned.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. It held that the plaintiffs had standing for their claims for declaratory and injunctive relief against all defendants (except one official capacity claim not appealed), as well as for damages against the District, because their ongoing economic injury—incurred by complying with the Metro Ban—constituted a concrete, imminent, and traceable harm. The Court affirmed the dismissal of damages claims against individual defendants, reversed the dismissal of the remaining claims, and remanded for further proceedings. View "Angelo v. DC" on Justia Law

Florida enacted a law prohibiting public university professors from endorsing or promoting certain ideas related to race, color, sex, and national origin in classroom instruction. The law, known as the Individual Freedom Act, identifies eight specific concepts that professors are barred from espousing, such as claims of moral superiority based on race or sex, inherent racism or oppression, and the idea that virtues like merit or colorblindness are themselves racist or sexist. The law allows professors to discuss these concepts in a neutral way, but not to advocate for them, and imposes severe penalties on both individual professors and universities for violations, including the loss of significant funding and potential termination of employment.Groups of professors and students from several Florida public universities filed lawsuits in the United States District Court for the Northern District of Florida, arguing that the Act violated their First Amendment rights by restricting viewpoint-based expression and was unconstitutionally vague. The district court granted preliminary injunctions in both cases, enjoining enforcement of the Act’s classroom restrictions against the plaintiffs, finding that at least one plaintiff had standing to challenge each prohibited concept. The court concluded the Act was likely unconstitutional as applied to public university professors.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of a preliminary injunction. The Eleventh Circuit affirmed, holding that the Act’s restrictions amount to unconstitutional viewpoint discrimination in violation of the First Amendment. The court distinguished between permissible curricular control by universities and the broad, legislative ban imposed by the state’s political branches. It concluded that neither public-employee speech doctrine nor government speech doctrine justified the law’s suppression of disfavored ideas in the university classroom, and that the Act impermissibly infringed on academic freedom and open inquiry. The preliminary injunction was affirmed. View "Pernell v. Commissioner of the FL State Board of Education" on Justia Law

The case arose from a dispute over property ownership following the death of a homeowner who did not leave a will. The defendant, who had lived in the home with his children and grandmother, refused to leave after her death despite an eviction order. When sheriff’s deputies arrived to enforce the eviction, the defendant resisted leaving and was arrested. As a result, he was charged with trespassing and two counts of resisting or obstructing a police officer. The defendant maintained throughout that he believed he had a right to remain in the home and thus was not trespassing.After a jury trial in Emmet Circuit Court, the defendant was convicted on all counts. He moved for a new trial, arguing that his Sixth Amendment rights were violated when his counsel conceded guilt on the trespassing charge during closing argument without consulting him or securing his consent. At the evidentiary hearing, trial counsel testified that the defendant had consistently maintained his innocence before trial and was not informed of the plan to concede guilt. The trial court denied the motion, reasoning that the defendant failed to cooperate with counsel and did not object to the concession. The Court of Appeals affirmed, finding that counsel acted within his discretion given the lack of communication.The Michigan Supreme Court reviewed the case and held that under McCoy v. Louisiana, a criminal defendant has the right to decide the objective of the defense, including maintaining innocence. The Court found that defense counsel’s unilateral concession of guilt, despite the defendant’s insistence on innocence and without consultation, violated this right. The Court clarified that a defendant is not required to contemporaneously object to preserve this claim. The structural error required automatic reversal. The judgment of the Court of Appeals was reversed, the convictions vacated, and the case remanded for a new trial on all charges. View "People Of Michigan v. Klungle" on Justia Law

Several pharmaceutical manufacturers and a trade association challenged a Louisiana statute enacted in 2023, which prohibits drug manufacturers and distributors from interfering with the acquisition or delivery of discounted drugs—purchased under the federal Section 340B Drug Pricing Program—to pharmacies contracted by certain healthcare providers. The 340B Program requires drug manufacturers participating in Medicaid and Medicare to provide discounted outpatient drugs to designated healthcare providers serving low-income and rural populations. Many of these providers lack in-house pharmacies and use external contract pharmacies. In response to manufacturer-imposed limits on contract pharmacy use, Louisiana enacted Act 358 to preserve covered entities’ ability to use such pharmacies.The plaintiffs, including AbbVie, AstraZeneca, and the Pharmaceutical Research and Manufacturers of America, filed separate lawsuits in the United States District Court for the Western District of Louisiana against the Louisiana Attorney General, arguing that Act 358 is preempted by federal law, constitutes an unconstitutional taking, impairs contracts in violation of the Contracts Clause, and is unconstitutionally vague. The district court consolidated the cases, granted summary judgment for Louisiana and the Louisiana Primary Care Association (an intervenor), and rejected all of the manufacturers’ claims.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that Act 358 is not preempted by federal law, as the federal 340B Program does not regulate drug distribution logistics or the use of contract pharmacies, and thus leaves room for state regulation. The court further concluded that Act 358 does not effect a taking under the Fifth Amendment, does not substantially impair contractual obligations under the Contracts Clause, and is not unconstitutionally vague under the Due Process Clause. The Fifth Circuit thus upheld summary judgment for Louisiana on all claims. View "AbbVie v. Murrill" on Justia Law

A former superintendent of a California school district, who later became an elected member of the district’s Board of Trustees, was subject to a workplace violence restraining order (WVRO) requested by the district on behalf of three employees. These employees, who worked closely with the superintendent, reported that he engaged in a persistent course of conduct that included angry outbursts, threats of termination, intrusive and inappropriate text messages, stalking behaviors, and unsolicited photographs. The conduct caused substantial emotional distress and fear among the employees, leading them to seek mental health treatment and report his actions to the police. After his termination, the superintendent continued to interact with the employees in ways they perceived as intimidating, including the placement of campaign signs near their homes and the publication of internal documents on social media.The Superior Court of San Bernardino County granted a temporary restraining order and, after a multi-day hearing, issued a WVRO prohibiting the superintendent from harassing, disturbing the peace of, or contacting the three employees. The WVRO imposed restrictions on his proximity to the employees and their workplace, allowed his attendance at board meetings only under specific conditions, and included a provision barring him from commenting on the WVRO at board meetings. The order was set to last four years, subject to early termination if he was no longer associated with the district.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that an employer’s right to seek a WVRO on behalf of employees is unwaivable under Civil Code section 3513, rejected arguments concerning insufficient evidence and violation of parental rights, and found sufficient evidence of a future threat of harassment. However, it determined that the WVRO’s prohibition on comments at board meetings was overbroad and violated First Amendment rights, and that the order’s four-year duration exceeded the statutory maximum. The court modified the order to remove the speech restriction and limit its duration to three years, then affirmed the WVRO as modified. View "Adelanto Elementary Sch. Dist. v. Krause" on Justia Law