Justia Constitutional Law Opinion Summaries

In this case, Utah voters passed Proposition 4 in 2018, a citizen initiative designed to reform the state’s redistricting process and address partisan gerrymandering. Before the next redistricting cycle, the Utah Legislature repealed Proposition 4 and replaced it with Senate Bill 200 (S.B. 200), which eliminated the key reforms established by the initiative. Several organizations and individuals challenged this legislative action, arguing that the repeal violated Utahns’ constitutional right to alter or reform their government through the initiative process.The Third District Court initially dismissed the plaintiffs’ claim that the Legislature’s repeal of Proposition 4 was unconstitutional. On interlocutory appeal, the Supreme Court of Utah held that the people’s right to reform their government via initiative is constitutionally protected and remanded the case for further proceedings. On remand, the district court granted summary judgment to the plaintiffs, finding that S.B. 200 unconstitutionally impaired the reforms enacted by Proposition 4 and was not narrowly tailored to serve a compelling state interest. The court declared Proposition 4 to be the law, enjoined the use of the 2021 Congressional Map enacted under S.B. 200, and established a remedial process for creating a compliant map. The Legislature’s request to stay the injunction on the 2021 map during the remedial process and any appeals was denied by the district court.The Supreme Court of the State of Utah reviewed the Legislature’s emergency petition for extraordinary relief, which challenged only the district court’s denial of the stay. The Supreme Court held that the Legislature had not shown the district court abused its discretion in denying the stay, as their arguments focused on the remedial process rather than the legal standard for granting a stay. The petition for extraordinary relief was therefore denied. View "State Legislature v. League of Women Voters" on Justia Law

A man was shot and killed outside a convenience store in Wilmington, Delaware. Surveillance footage captured the masked shooter’s movements before and after the incident, and police identified several witnesses, including Darnella Spady, who was present at the scene. During a police interview, Spady identified the shooter as “Gunner,” later determined to be Kevin Berry, and described her interactions with him. However, at trial, Spady was uncooperative, claimed memory loss due to drug use, and stated she could not recall the shooting or her prior statement to police. The prosecution sought to admit Spady’s out-of-court statement as substantive evidence under 11 Del. C. § 3507.The Superior Court of the State of Delaware conducted a bench trial after Berry waived his right to a jury. The court admitted Spady’s prior statement over Berry’s objection, finding that the State had established the necessary foundation under Section 3507 and that the statement was voluntary. The court found Berry guilty of first-degree murder and related weapons charges, and sentenced him to life plus ten years. Berry appealed, arguing that the trial court erred in admitting Spady’s statement and urging the Delaware Supreme Court to overturn its recent precedent in McCrary v. State, which clarified the foundational requirements for admitting such statements.The Supreme Court of the State of Delaware reviewed the case and affirmed the Superior Court’s decision. The Court held that there was no urgent reason or clear error warranting a departure from McCrary v. State, and that the trial court did not abuse its discretion in admitting Spady’s statement. The Court concluded that the State’s questioning satisfied the statutory requirements, and Berry’s confrontation rights were not violated. The convictions were affirmed. View "Berry v. State" on Justia Law

A car leasing company leased a vehicle to an individual who defaulted on payments soon after the lease began. Despite having the right to repossess the car, the company did not do so. Two years later, the lessee was stopped by police in Butler, New Jersey, for driving with a suspended license, suspended registration, and no insurance. The police seized the car and had it towed by a contractor, Malanga’s Automotive. The lessee was informed of the tow but did not retrieve the vehicle. The towing company did not notify the leasing company that it possessed the car until nearly a year later, at which point it demanded payment of towing and storage fees before releasing the vehicle.The leasing company filed suit in the Superior Court of New Jersey against the towing company, later adding the Borough of Butler as a defendant and asserting claims under 42 U.S.C. § 1983 for violations of the Fourteenth Amendment’s Due Process Clause, the Fourth Amendment, and the Fifth Amendment. The case was removed to the United States District Court for the District of New Jersey, which granted summary judgment to Butler on all claims. The District Court found that the company had a property interest in the vehicle but concluded that Butler’s policies provided sufficient notice and opportunity to be heard, and that the seizure and retention of the vehicle were reasonable and did not constitute a taking.On appeal, the United States Court of Appeals for the Third Circuit held that Butler’s policies violated the Fourteenth Amendment’s Due Process Clause because they failed to require prompt notice to all holders of property rights in seized vehicles and did not provide an opportunity for a hearing to challenge the lawfulness of the tow or the fees. The court reversed and remanded the due process claim. However, it affirmed the District Court’s judgment on the Fourth and Fifth Amendment claims, finding no unreasonable seizure or unconstitutional taking. View "Honda Lease Trust v. Malanga's Automotive" on Justia Law

In 1922, the Territory of Hawai‘i issued a Land Patent for a 3.99-acre property to a trustee for the Church of Jesus Christ of Latter-Day Saints, with a deed restriction requiring the property to be used “for Church purposes only.” If used otherwise, the property would revert to the Territory. Over the years, the property changed hands several times, with each transaction referencing the original deed restriction. The current owners, Hilo Bay Marina, LLC and Keaukaha Ministry LLC, are not religious institutions and sought to have the restriction removed, arguing it was void under Hawai‘i Revised Statutes § 515-6(b), and violated both the Hawai‘i and Federal Establishment Clauses.The Circuit Court of the Third Circuit granted summary judgment for the State of Hawai‘i and its Board of Land and Natural Resources, finding that the deed restriction was a permissible form of early use-zoning, did not violate the cited laws, and was covered by the statutory exemption for religious use. The court also concluded that the restriction did not violate either the Hawai‘i or Federal Establishment Clauses, applying both the Lemon test and the more recent “historical practices and understandings” standard from Kennedy v. Bremerton School District.On appeal, the Supreme Court of the State of Hawai‘i reviewed the case de novo. The court found that the record did not support the lower court’s conclusion that the deed restriction was an early form of use-zoning. It held that the State’s enforcement of the restriction violated the Hawai‘i Establishment Clause, as it required the State to actively police religious use and entangled the government with religious affairs. The court reversed the Circuit Court’s judgment for the State, vacated its ruling on the Federal Establishment Clause, and held that summary judgment should be entered for the plaintiffs. View "Hilo Bay Marina, LLC v. State" on Justia Law

A tenured English professor at a public university in Ohio, who identifies as transgender, became involved in discussions about leading the university’s Center for the Study of Gender and Sexuality during a period of departmental restructuring. Although the professor expressed interest in directing the Center and was considered a strong candidate, the position was not open as the Center had gone dormant. The professor was offered a partial teaching load reallocation to help develop a new gender-studies major, but after a series of profanity-laden and disparaging social media posts targeting colleagues and administrators, the offer was rescinded. The professor also sought a tenure transfer to the main campus, which was denied by faculty committees after considering collegiality and departmental needs, with no discussion of gender identity.The United States District Court for the Northern District of Ohio granted summary judgment for the university and individual defendants on all claims. The court found no genuine dispute of material fact and concluded that the university’s actions were based on legitimate, nondiscriminatory reasons, including the professor’s unprofessional conduct and the department’s academic requirements. The professor appealed, challenging the district court’s rulings on claims of sex discrimination and retaliation under Title VII, First Amendment retaliation under 42 U.S.C. § 1983, and perceived-disability discrimination under the Rehabilitation Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment. The court held that there was no direct or circumstantial evidence of discrimination or retaliation, that the professor’s social media posts did not constitute protected speech on matters of public concern under the First Amendment, and that there was insufficient evidence to support a perceived-disability claim. The court clarified that adverse employment actions under Title VII need only cause some harm, but found the university’s reasons for its decisions were not pretextual. View "GPat Patterson v. Kent State University" on Justia Law

The case concerns a defendant who was indicted for murder and attempted murder following a shooting incident in Kona, Hawaii. The indictment included sentencing enhancements under Hawaii Revised Statutes (HRS) § 706-660.1, which allows for mandatory minimum sentences if a firearm is possessed, used, or its use is threatened during the commission of a felony. The indictment did not specify a state of mind (mens rea) for the sentencing enhancement, though it did for the underlying offenses. At trial, the defendant was convicted on several counts, and the jury found the firearm enhancement applied. The defendant was sentenced accordingly.After the initial conviction, the Intermediate Court of Appeals (ICA) vacated the conviction on certain counts due to evidentiary errors and remanded for a new trial. On remand, the defendant, for the first time, challenged the sufficiency of the indictment, arguing that the sentencing enhancement was an element of the offense and thus required a state of mind to be alleged. The Circuit Court agreed and struck the enhancements from the indictment, finding that the omission of a state of mind violated due process and the requirements set forth in prior case law.The State appealed, and the ICA reversed the Circuit Court’s order, holding that the sentencing enhancement under HRS § 706-660.1 is not an element of the underlying offense and does not require a state of mind to be pled in the indictment. The Hawaii Supreme Court reviewed the case and affirmed the ICA’s decision. The Court held that sentencing enhancements under HRS § 706-660.1 are not elements of the offense and that due process is satisfied if the defendant is notified that the enhancement will be sought and the indictment contains sufficient factual allegations. The Court remanded the case for further proceedings. View "State v. Smith" on Justia Law

Brandon Glen Jackson was indicted in Arizona for a state-law felony related to possessing a short-barreled rifle. While released on bail and with the felony charge still pending, Jackson lawfully acquired a handgun and traveled from Arizona to Maryland, bringing the handgun with him. In Maryland, he was arrested for carrying the gun without a permit. Upon discovering his pending Arizona felony indictment, federal prosecutors charged him under 18 U.S.C. § 922(n), which prohibits individuals under felony indictment from transporting firearms in interstate commerce.The United States District Court for the District of Maryland denied Jackson’s motion to dismiss the indictment on Second Amendment grounds. Jackson then entered a conditional guilty plea, preserving his right to appeal the constitutional issue. He was sentenced to time served, and subsequently appealed the district court’s denial of his motion to dismiss.The United States Court of Appeals for the Fourth Circuit reviewed the case and applied the Supreme Court’s “text-and-history” standard from New York State Rifle & Pistol Association v. Bruen, 597 U.S. 1 (2022). The Fourth Circuit held that Jackson’s conduct—transporting a handgun across state lines while under felony indictment—was presumptively protected by the Second Amendment. However, the court found that the government met its burden to show that § 922(n), as applied to Jackson, was consistent with the nation’s historical tradition of firearm regulation. The court relied on historical surety laws and the tradition of disarming dangerous persons, as well as its own precedent in United States v. Hunt, 123 F.4th 697 (4th Cir. 2024), to conclude that temporary disarmament of those under felony indictment is constitutionally permissible. The Fourth Circuit affirmed the district court’s judgment. View "US v. Jackson" on Justia Law

Two nonprofit organizations challenged the constitutionality of a North Carolina statute that made it a felony for individuals with felony convictions to vote before their rights were restored, regardless of whether those individuals mistakenly believed they were eligible. The statute, originally enacted in the late 19th century, was shown to have been motivated by racial animus and to have a disproportionate impact on Black North Carolinians. In 2023, the North Carolina General Assembly amended the statute to add a requirement that a person must “know” their rights had not been restored to be prosecuted, effective January 1, 2024.The United States District Court for the Middle District of North Carolina considered the plaintiffs’ claims under the Equal Protection and Due Process Clauses. After the statute was amended, a magistrate judge recommended dismissal for lack of standing, but the district court found the case was not moot because prosecutions under the old statute for pre-2024 conduct could still occur, potentially chilling voter participation and requiring the plaintiffs to divert resources. The district court granted summary judgment for the plaintiffs, holding the statute unconstitutional and enjoining its enforcement.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the case was not moot because prosecutions under the prior version of the statute could still proceed, and the plaintiffs retained a concrete interest in the outcome. On the merits, the Fourth Circuit affirmed the district court’s ruling that the challenged statute violated the Equal Protection Clause. The court found that the statute’s original enactment and reenactment were motivated by racial discrimination, and that subsequent legislative changes did not “cleanse” the statute of its discriminatory origins, as the statute itself had not been substantively reenacted or amended in a way that would warrant a presumption of legislative good faith. The court affirmed the district court’s judgment. View "A. Philip Randolph Institute v. North Carolina State Board of Elections" on Justia Law

John Seiwert, who had a long history of daily heroin and crack cocaine use, was found in possession of firearms at his home in Illinois shortly after his father’s death. Law enforcement, investigating Seiwert’s drug dealer, observed frequent contact between the two and recovered firearms and drug paraphernalia from Seiwert’s residence. Seiwert admitted to using crack cocaine just hours before police arrived and to being a daily user for twenty years. He was charged with two counts of possessing a firearm as an unlawful user of, or addict to, a controlled substance under 18 U.S.C. § 922(g)(3).The United States District Court for the Northern District of Illinois, Eastern Division, denied Seiwert’s pretrial motions to dismiss the indictment, which argued that § 922(g)(3) was unconstitutionally vague and violated the Second Amendment, both before and after the Supreme Court’s decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen. At trial, the government presented evidence of Seiwert’s drug use and firearm possession, and the jury convicted him on both counts. The district court denied Seiwert’s post-trial motions and sentenced him to concurrent terms of imprisonment and supervised release.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed Seiwert’s arguments that § 922(g)(3) violated the Second Amendment, was unconstitutionally vague, and that the evidence was insufficient. The court held that, under the Bruen framework, § 922(g)(3) does not violate the Second Amendment as applied to Seiwert, finding it analogous to historical laws disarming the intoxicated and mentally ill. The court also found that its prior decision in United States v. Cook foreclosed Seiwert’s vagueness challenge, and that the evidence overwhelmingly supported the conviction. The Seventh Circuit affirmed the district court’s judgment. View "USA v Seiwert" on Justia Law

Several individuals and a firearms instruction company challenged various aspects of New York’s Concealed Carry Improvement Act (CCIA) and the way the Suffolk County Police Department (SCPD) implements the law. The individual plaintiffs, all Suffolk County residents, objected to requirements for obtaining a handgun license, including a “good moral character” standard, an in-person interview, disclosure of household members and character references, a list of social media accounts, and completion of eighteen hours of firearms training. They also alleged that the SCPD’s process for scheduling interviews and issuing licenses could take years, far exceeding statutory timelines. Additionally, the plaintiffs, including firearms instructors, challenged an alleged SCPD policy of arresting unlicensed individuals participating in live-fire training, despite a state law exemption for such training.The United States District Court for the Eastern District of New York denied the plaintiffs’ motion for a preliminary injunction. The court found that the individual applicants lacked standing to challenge the CCIA’s requirements because they had not completed the application process, and that none of the plaintiffs had standing to challenge the SCPD’s arrest policy due to a lack of credible threat of enforcement. The district court did not address the challenge to the SCPD’s processing delays.The United States Court of Appeals for the Second Circuit held that the applicants did have standing to challenge the CCIA’s requirements and the SCPD’s processing delays, but affirmed the denial of a preliminary injunction because the plaintiffs were unlikely to succeed on the merits of their facial Second Amendment challenges, except for the social media disclosure requirement, which was already preliminarily enjoined in another case, rendering that issue moot. The court also found that at least one plaintiff had standing to challenge the SCPD’s arrest policy and vacated the district court’s ruling on that issue, remanding for further proceedings. The disposition was affirmed in part, vacated in part, and remanded. View "Giambalvo v. Suffolk Cnty." on Justia Law