Justia Constitutional Law Opinion Summaries

The defendant was charged with producing, distributing, and possessing AI-generated images that depicted minors engaged in sexually explicit conduct, as well as transferring such material to a minor. The images were alleged to be created using Stable Diffusion, a text-to-image generative AI program, and did not involve real children. Law enforcement linked the defendant to these images after a report by Meta Platforms, which found the material sent to a minor on Instagram. A search of the defendant’s devices revealed hundreds of similar AI-generated images.In the United States District Court for the Western District of Wisconsin, the defendant moved to dismiss the count charging him with knowing possession of obscene virtual child sexual abuse material (CSAM) in violation of 18 U.S.C. § 1466A(b)(1). The district court granted the motion as to the possession charge, concluding that the statute was unconstitutional as applied in this context. The court reasoned that, under Stanley v. Georgia, individuals have a First Amendment right to possess obscenity in their homes, and that this right extends to virtual CSAM, especially in light of the Supreme Court’s decision in Ashcroft v. Free Speech Coalition, which distinguished virtual CSAM from material involving actual children. The court left the production and distribution charges intact.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The Seventh Circuit held that Supreme Court precedent—specifically Stanley v. Georgia and Ashcroft v. Free Speech Coalition—controls the as-applied challenge. The court found that, because the images did not depict real children, the government’s justifications for banning their possession in the home had been expressly rejected by the Supreme Court. Accordingly, the Seventh Circuit affirmed the district court’s judgment, holding that 18 U.S.C. § 1466A(b)(1) is unconstitutional as applied to the defendant’s in-home possession of obscene virtual CSAM. View "USA v Anderegg" on Justia Law

In this case, the defendant was indicted for murder and related firearm offenses arising from the death of an individual in Indian Country. A key witness, William Lozer, had previously testified at a state preliminary hearing that the defendant confessed to and described details of the crime. Prior to the defendant's federal trial, the government was unable to locate Lozer, who was known to be transient and had not been seen or contacted by his family or attorney for months. The government sought to introduce Lozer's prior testimony, which had been given under oath and subject to cross-examination by defense counsel.The United States District Court for the Eastern District of Oklahoma considered whether the government had made sufficient efforts to locate Lozer and ultimately found that, despite reasonable and good-faith efforts, Lozer was unavailable as a witness. As a result, the court permitted the prior testimony to be read to the jury. At trial, additional evidence against the defendant was introduced, including incriminating statements to other individuals and physical evidence. The defendant was convicted on all counts, and the district court sentenced him to life in prison.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the defendant’s argument that his Sixth Amendment right to confront witnesses was violated by the admission of Lozer’s prior testimony. Applying a de novo standard of review, the Tenth Circuit held that the government’s efforts to locate Lozer were reasonable and made in good faith under the circumstances. Thus, Lozer was properly deemed unavailable, and the admission of his prior, cross-examined testimony did not violate the defendant’s confrontation rights. The Tenth Circuit affirmed the defendant’s convictions. View "United States v. Barker" on Justia Law

After police responded to a theft report at a convenience store in Chesterfield County, Virginia, Markel Trevon Smith and another individual were detained. A search of their vehicle revealed four firearms, including a Glock pistol equipped with a device converting it into a machinegun. This Glock bore three serial numbers: two had been scratched, leaving only partial digits visible, while one serial number remained fully legible. The firearm was traced using the unaltered serial number.Smith was indicted in the United States District Court for the Eastern District of Virginia for possession of a machinegun in violation of 18 U.S.C. § 922(o). He moved to dismiss, arguing that § 922(o) violated the Second Amendment, but the district court denied the motion. Smith then pled guilty. At sentencing, the court adopted the Presentence Report’s recommendation to apply a four-level enhancement under U.S. Sentencing Guidelines § 2K2.1(b)(4)(B)(i), which increases the offense level if any firearm has a serial number modified so that the original information is illegible or unrecognizable to the unaided eye. The district court reasoned that altering any serial number on the firearm warranted the enhancement, and sentenced Smith to 57 months’ imprisonment.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed Smith’s conviction, holding that § 922(o) does not violate the Second Amendment, either facially or as applied to Smith, because machineguns are not in common use for lawful purposes. However, the Fourth Circuit found that the district court erred in applying the serial number enhancement. The court held that the enhancement only applies where modifications render the firearm as a whole untraceable, which was not the case since one serial number remained fully legible. The appellate court therefore reversed the application of the enhancement, vacated Smith’s sentence, and remanded for resentencing without the enhancement. View "US v. Smith" on Justia Law

Several cities, counties, and local agencies across the United States challenged new conditions imposed by the Department of Housing and Urban Development (HUD) and the Department of Transportation (DOT) on federal grants they had already been awarded. These new conditions, added after the grants were awarded, required recipients to certify compliance with federal antidiscrimination laws for all their programs (not just those funded by the grants), acknowledge that such certifications are material for purposes of the False Claims Act, refrain from using grant funds to promote “gender ideology,” “elective abortions,” or “illegal immigration,” and verify the immigration status of individual grant recipients.The United States District Court for the Western District of Washington considered the plaintiffs’ motion for a preliminary injunction. The district court found that the new conditions went beyond merely enforcing existing legal requirements and exceeded the agencies' statutory authority. It enjoined the agencies from enforcing all of the challenged conditions, from withholding grant funds based on those conditions, from requiring certifications of compliance, and from refusing to process grant agreements because of the litigation.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed whether the agencies’ imposition of these grant conditions was lawful under the relevant statutes. The Ninth Circuit affirmed the district court’s preliminary injunction in large part. The court held that: (1) the conditions requiring compliance with antidiscrimination laws are unlawful to the extent they apply to programs or activities not receiving federal funds, but are permissible as to federally funded programs; (2) the conditions making compliance certifications “material” for False Claims Act purposes are not authorized by statute; (3) the restrictions on the use of grant funds for promoting certain ideas or activities exceed statutory authority; and (4) the requirement to use a specific immigration verification system is unauthorized. The appellate court remanded with instructions to narrow the injunction to allow antidiscrimination conditions for federally funded programs, but otherwise affirmed the district court’s injunction. View "COUNTY OF KING V. TURNER" on Justia Law

A police officer in Jonesboro, Arkansas, encountered Jayden Prunty standing in the street holding a plastic bag late at night in an area known for high crime. The officer, identifying himself and stating he was conducting drug interdiction, approached Prunty, claimed to smell marijuana, and repeatedly told him to “come here.” Prunty denied the accusation, became visibly nervous, and walked away. When Prunty began to run, the officer caught him and pushed him to the ground. During the ensuing struggle, a firearm discharged, and the officer was shot in the leg. The officer then drew his own weapon and fatally shot Prunty. Prunty was later pronounced dead at the hospital.The administrators of Prunty’s estate brought a civil rights action in the United States District Court for the Eastern District of Arkansas under 42 U.S.C. § 1983, alleging violations of the Fourth and Fourteenth Amendments. The district court granted summary judgment in favor of the officer, finding that the officer’s actions did not violate clearly established rights and that he was entitled to qualified immunity. The court determined that the officer had reasonable suspicion to detain Prunty based on the odor of marijuana, Prunty’s nervous behavior, and attempted flight, and that his use of force was objectively reasonable under the circumstances.Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the officer did not seize Prunty until applying physical force, at which point reasonable suspicion existed. The court also found the officer’s use of force, including the takedown and subsequent use of deadly force after being shot, was objectively reasonable. Accordingly, the officer was entitled to qualified immunity, and the grant of summary judgment was affirmed. View "Prunty v. Obregon" on Justia Law

Law enforcement officers responded to a report of a possible drug overdose at a residence in Onamia, Minnesota. Upon arrival, they found Jeremy Burton unconscious with drug paraphernalia present. After being revived with Narcan, officers noticed a handgun magazine protruding from Burton’s shorts. During the encounter, another individual tried to prevent officers from retrieving the firearm, but it was ultimately secured. Burton was transported to a hospital and found to have multiple controlled substances in his system. He was charged as a felon in possession of a firearm, with a sentencing enhancement under the Armed Career Criminal Act due to prior convictions.The United States District Court for the District of Minnesota presided over Burton’s trial. The court granted the government’s motion in limine to exclude expert testimony from a pharmacologist regarding the effects of drugs on Burton’s mental state, finding voluntary intoxication was not a defense to the charge. At trial, Burton testified that someone had planted the gun on him while he was unconscious, but the jury found him guilty. The district court sentenced him to 240 months of imprisonment, which was a downward variance from the applicable guidelines range. Burton appealed, arguing error in excluding the expert testimony and that his sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary ruling for abuse of discretion and, where constitutional issues were implicated, de novo. The appellate court held that voluntary intoxication is not a defense to being a felon in possession of a firearm, and thus the exclusion of the expert testimony was proper. The court also found that the sentence was substantively reasonable, given the district court’s consideration of both aggravating and mitigating factors. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Burton" on Justia Law

In 2022, Soohyung Kim and his company, through an affiliate, secured a winning bid to purchase TEGNA, a large broadcast television company. The transaction required regulatory approval from the Federal Communications Commission (FCC) within 450 days, as specified in the merger agreement. The proposal drew objections from several organizations and individuals, including labor unions, public interest groups, and a rival bidder. Amid ongoing objections and extended public comment periods, the FCC’s Media Bureau ultimately failed to approve the license transfer within the required timeframe, resulting in the expiration of the merger agreement and obligating Kim’s group to pay significant break-up fees.After the collapse of the merger, the appellants filed suit in the United States District Court for the District of Columbia against both the FCC and various private parties. They alleged constitutional and statutory violations, including Equal Protection claims, Communications Act violations, federal civil rights and conspiracy claims, and D.C.-law tort claims, asserting that the FCC and private parties conspired to prevent the merger based on race. The District Court dismissed all claims. Regarding the FCC, the court found the appellants lacked standing for prospective relief, as they failed to allege a substantial risk of future injury. The court also dismissed the Communications Act claims for lack of jurisdiction. As to the claims against private parties, the court applied Noerr-Pennington immunity and found no plausible basis for the civil rights or tort claims.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the District Court’s dismissal. The court held that the appellants lacked standing against the FCC due to insufficient allegations of likely future injury. The court further held that the claims against private appellees failed because the complaint did not plausibly allege intentional race discrimination or actionable tortious interference, and thus did not state a claim upon which relief could be granted. View "SGCI Holdings III LLC v. FCC" on Justia Law

The President issued an Executive Order that directed certain federal agencies to take actions related to election integrity, including creating and distributing lists of eligible voters, prioritizing prosecution of officials issuing ballots to ineligible voters, and initiating a rulemaking related to ballot tracking. The Order did not impose any requirements on states or parties outside the Executive Branch, and all actions were subject to feasibility and compliance with existing law. Shortly after the Order was issued, several states and the District of Columbia sued, arguing that the Order unconstitutionally infringed on their authority to administer elections.The United States District Court for the District of Massachusetts agreed with the states and entered a final judgment enjoining the federal government from implementing the challenged provisions of the Order as to the plaintiff states for the upcoming midterm elections. The government sought a stay of this injunction from the United States Court of Appeals for the First Circuit, which was denied, prompting an emergency application to the Supreme Court.The Supreme Court of the United States granted the stay, holding that the government is likely to succeed on its argument that the District Court lacked jurisdiction because the states lacked standing and their claims were not ripe for adjudication. The Court reasoned that the Order was an internal directive that did not cause concrete or imminent harm to the states, and any alleged injury was speculative and dependent on uncertain future events. The Court also found that the government would likely suffer irreparable harm from the injunction, which interfered with the internal workings of the Executive Branch. As a result, the Supreme Court stayed the District Court’s injunction pending further appellate review. View "Trump v. California" on Justia Law

The case concerns a defendant who was convicted of murdering his girlfriend after a violent altercation in their home. The defendant called 911, expressing both an apparent confession and suicidal intent. He was apprehended after returning home the next day. At the police station, he was advised of his rights using the Maui Police Department’s Miranda waiver form, which, at the time, did not include an explicit warning that he could stop answering questions or request an attorney at any time during interrogation. The defendant subsequently confessed during a custodial interview and did not attempt to invoke his right to silence or counsel.Proceedings in the Circuit Court of the Second Circuit were delayed to evaluate the defendant’s mental fitness. After finding him fit, the court denied his motion to suppress statements, concluding he had voluntarily, knowingly, and intelligently waived his Miranda rights, despite his claims of mental distress and the absence of the so-called “fifth Miranda warning.” At trial, the jury found him guilty of second-degree murder, and he was sentenced to life imprisonment with the possibility of parole. On appeal, the Intermediate Court of Appeals affirmed the conviction, holding that the Miranda warnings given were constitutionally sufficient and the waiver voluntary.The Supreme Court of the State of Hawai‘i reviewed the case. It held that, under the Hawai‘i Constitution, law enforcement must henceforth provide not only the traditional four Miranda warnings but also explicitly inform custodial suspects of their right to cease answering questions and request an attorney at any time. However, because this is a new constitutional rule, the court applied it prospectively only, not to the defendant’s case. The court affirmed both the conviction and sentence, holding that the defendant’s waiver was valid under the previous standard. View "State v. Garces" on Justia Law

A tenured law professor at a state university posted an online petition calling for military action against Israel. The university responded by placing the professor on administrative leave and restricting his campus access while it investigated whether his actions violated university policy or law. The investigation included notices to the professor, requests for evidence, and allegations from students, but had not progressed beyond the preliminary fact-finding stage. No formal hearing or charges had been initiated by the university at the time of the lawsuit.The professor filed suit in the United States District Court for the Eastern District of Kentucky, seeking a preliminary injunction to stop the university’s actions. The university moved for abstention under the doctrine established in *Younger v. Harris*, arguing that the ongoing university investigation constituted a state proceeding warranting federal court abstention. The district court agreed with the university and abstained from hearing the case, prompting the professor to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s abstention decision de novo. The Sixth Circuit held that the university’s investigation was still in a preliminary, investigatory stage and did not constitute an ongoing formal proceeding as required under the *Younger* abstention framework. The court distinguished the circumstances from prior cases involving formal disciplinary hearings, noting that no formal charges or hearings had yet been initiated. As a result, the Sixth Circuit reversed the district court’s decision to abstain and remanded the case for consideration of the professor’s motion for a preliminary injunction. View "Woodcock v. Univ. of Kentucky" on Justia Law