Justia Constitutional Law Opinion Summaries

Several former students and their parents challenged a school district’s policy restricting the length of male students’ hair, alleging that the policy constituted race and sex discrimination and violated constitutional and statutory rights. The school district amended its hair policy during the 2019–2020 school year, removing language that previously allowed certain hairstyles, such as cornrows or locs, if they complied with other requirements. The plaintiffs argued that the enforcement of this policy infringed upon their rights under the Fourteenth Amendment, the First Amendment, Title VI, Title IX, and Texas law.The case was initially heard in the United States District Court for the Southern District of Texas. During discovery, the plaintiffs sought to depose the superintendent and a former board president. The school district moved for a protective order, asserting legislative privilege to prevent inquiries into the subjective motivations of board members regarding the hair policy. The district court partially denied the motion, establishing a procedure where deponents could assert the privilege but would still be required to answer, with disputed portions of testimony marked confidential for later review. The district court declined to rule on the privilege’s applicability until specific questions were asked during depositions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court erred in its handling of the legislative privilege and the protective order. The Fifth Circuit held that none of the appellants—including the school district, the board of trustees, and the individual former officials—had standing to appeal the district court’s order because the privilege holders had not personally invoked the privilege or participated adequately in the proceedings. As a result, the Fifth Circuit dismissed the appeal for lack of jurisdiction and also dismissed the pending motion to stay as moot. View "Arnold v. Barbers Hill Independent School District" on Justia Law

Raymundo Gomez was accused of committing lewd acts against three children at a public swimming pool. The key incidents involved Gomez allegedly bringing a 14-year-old boy’s hand into contact with his genitals and, separately, touching an eight-year-old girl, Katrina, on her buttocks and hip. The prosecution’s case against Gomez relied heavily on Katrina’s prior statements, including her preliminary hearing testimony and a forensic interview, as she did not testify at trial. Katrina’s mother objected to bringing her to court, citing concerns about the emotional impact on her daughter and her reluctance to have Katrina relive the experience in a courtroom setting.The Superior Court of San Diego County found Katrina unavailable to testify after hearing from her mother, who expressed that she did not want Katrina to participate further in the proceedings. The court allowed Katrina’s prior statements to be admitted at trial. The jury convicted Gomez of the offenses against Kane and Katrina but acquitted him of the offense against a third child. Gomez appealed, arguing that the trial court erred in finding Katrina unavailable and admitting her prior statements, thus violating his constitutional rights.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the prosecution failed to establish Katrina’s unavailability as a witness because the record did not show that her mother’s refusal to bring her to court was unequivocal or that all reasonable efforts to secure her testimony had been exhausted. The court found this error prejudicial and concluded that the admission of Katrina’s prior statements violated Gomez’s confrontation rights. As a result, the court reversed the convictions on all three lewd act counts and remanded the case for further proceedings. View "P. v. Gomez" on Justia Law

Huntington Beach, a charter city in Orange County, amended its city charter through Measure A, which authorized the city to require voter identification for municipal elections beginning in 2026. This measure was passed by local voters. In response, the California Legislature enacted Elections Code section 10005, effective January 1, 2025, which prohibits any local government from requiring voter identification for voting unless mandated by state or federal law. The statute was specifically intended to address Huntington Beach’s Measure A.Following the passage of Measure A, the State of California, through the Attorney General and Secretary of State, filed a petition for a writ of mandate in the Superior Court of Orange County, seeking to invalidate the voter identification provision in the city charter. The City of Huntington Beach demurred, arguing the issue was not ripe since the provision had not yet been implemented. The trial court sustained the demurrer, but after procedural developments and further hearings, ultimately denied the state’s petition, finding that the charter provision did not violate the right to vote or implicate the integrity of the electoral process. The state timely appealed.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. Applying the four-part “home rule” test, the court held that Elections Code section 10005 addresses a matter of statewide concern—integrity of the electoral process—and is narrowly tailored to prevent discriminatory barriers to voting. The court concluded that section 10005 preempts the Huntington Beach charter provision. The judgment of the trial court was reversed and remanded with directions to issue a writ of mandate invalidating the charter provision, enter a permanent injunction against its enforcement, and declare it preempted by state law. View "P. ex rel. Bonta v. City of Huntington Beach" on Justia Law

Mary Timmins worked as general counsel and litigation counsel for the Green Mountain Water and Sanitation District in Colorado. During her employment, she discovered that certain members of the District’s Board were engaging in conduct she believed to be corrupt and potentially unlawful, including violating open meetings laws, improperly communicating with a state-employed attorney, and destroying public records relevant to ongoing litigation. After repeatedly warning the Board internally without effect, Timmins disclosed her concerns to reporters and private citizens, alleging that the Board members were acting against the interests of the District and its residents. She was subsequently terminated from her position.Timmins filed suit in the United States District Court for the District of Colorado against the District and three Board members, asserting a claim under 42 U.S.C. § 1983 for First Amendment retaliation. The district court dismissed her claim under Federal Rule of Civil Procedure 12(b)(6), concluding that her speech was not protected by the First Amendment because it was made pursuant to her official duties as a public employee. The court reasoned that her statements to the press and private citizens were essentially identical to those made in her official capacity and stemmed from her work responsibilities.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the dismissal de novo. The Tenth Circuit held that Timmins’s speech to reporters and private citizens was not made pursuant to her official duties, as her job did not ordinarily require her to make such disclosures outside the chain of command. The court reversed the district court’s dismissal of Timmins’s amended complaint and remanded the case for further proceedings, declining to address alternative grounds for affirmance at this stage. View "Timmins v. Plotkin" on Justia Law

A security services company and its sole shareholder, who is also its president and CEO, provided security services to two Iowa cities under separate contracts. After the shareholder published a letter criticizing media coverage of law enforcement responses to protests, a local newspaper published articles highlighting his critical comments about protestors and the Black Lives Matter movement. Subsequently, a city council member expressed concerns about the shareholder’s views, and the city council voted unanimously to terminate the company’s contract. The council member also pressured officials in the other city to end their contract with the company. Facing negative publicity, the company voluntarily terminated its second contract to avoid harm to a pending business transaction.The plaintiffs filed suit in the United States District Court for the Southern District of Iowa against the city, the council member, and other council members, alleging First Amendment retaliation, tortious interference with business contracts, and defamation. The district court granted the defendants’ motion to dismiss all claims under Rule 12(b)(6). It found that the shareholder lacked standing to assert a First Amendment retaliation claim for injuries to the corporation, and that the corporation failed to state a retaliation claim because only the shareholder engaged in protected speech. The court dismissed the tortious interference claim for lack of sufficient factual allegations and because the contract was terminated voluntarily. The defamation claim was dismissed for failure to identify any actionable statements by the defendants.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the dismissal of the shareholder’s First Amendment retaliation and defamation claims, but directed that these dismissals be without prejudice. The court reversed the dismissal of the corporation’s First Amendment retaliation and tortious interference claims, finding that the complaint alleged sufficient facts to survive a motion to dismiss, and remanded those claims for further proceedings. View "Conley v. City of West Des Moines" on Justia Law

A professor at a public university alleged that several university administrators violated his First Amendment rights. The professor, known for his outspoken criticism of university policies and administrators on social media and in public forums, claimed that university officials attempted to silence him. He asserted that they threatened his job security, pay, research opportunities, and academic freedom, and that a university employee requested police surveillance of his speech. The professor stated that these actions caused him to self-censor, including making his social media account private and ceasing to post, out of concern for potential retaliation.The United States District Court for the Western District of Texas reviewed the case after the professor filed suit under 42 U.S.C. § 1983, alleging both retaliation for protected speech and the existence of an unwritten speech code that chilled his speech. The district court dismissed the retaliation claim, finding that the professor had not sufficiently alleged an adverse employment action, and granted summary judgment on the chilled-speech claim for the same reason. The court also dismissed the claim regarding the unwritten speech code, concluding that the professor had not adequately alleged a facial or as-applied First Amendment violation. Additionally, the court resolved two discovery disputes in favor of the university.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the professor had standing to bring his claims but could not prevail on the merits. The court determined that, under established Fifth Circuit precedent, a First Amendment retaliation claim requires an adverse employment action, which the professor did not experience. The court also found that the chilled-speech claim was not distinct from the retaliation claim and failed for the same reason. The court further held that the allegations regarding an unwritten speech code were too conclusory to state a plausible claim. The court upheld the district court’s discovery rulings, finding no abuse of discretion or prejudice. The judgment was affirmed. View "Lowery v. Mills" on Justia Law

Several individuals whose livelihoods depended on interacting with spinner dolphins challenged a federal regulation that restricted human proximity to these dolphins. The regulation, known as the Approach Rule, was issued by the National Marine Fisheries Service under the authority of the Marine Mammal Protection Act. The plaintiffs included a psychotherapist who used dolphin encounters in therapy, a boat captain who operated dolphin swim tours, and a dolphin guide and photographer. They argued that the regulation was unconstitutional because it was signed and promulgated by an official who, they claimed, was not properly appointed under the Appointments Clause of the U.S. Constitution.The United States District Court for the District of Maryland reviewed the case after the plaintiffs filed suit seeking to invalidate the regulation and enjoin its enforcement. During the litigation, Dr. Richard Spinrad, the Senate-confirmed NOAA Administrator and a principal officer, ratified the regulation, affirming that he independently evaluated and approved it. The district court found that this ratification cured any potential Appointments Clause defect and granted summary judgment in favor of the government. The plaintiffs appealed this decision.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court held that, under established principles of agency law, a principal officer’s ratification of a regulation can cure any constitutional defect arising from its initial promulgation by a non-principal officer. The court found that Dr. Spinrad’s ratification was valid and not impermissibly retroactive, as it did not impose new liabilities for past conduct but merely confirmed the regulation’s validity from the time of its original publication. Accordingly, the Fourth Circuit affirmed the district court’s dismissal of the suit. View "Wille v. Lutnik" on Justia Law

Legacy Housing Corporation purchased several hundred vacant lots in Horseshoe Bay, Texas, intending to develop manufactured housing. The lots were subject to zoning restrictions, including a cap on speculative housing permits, contractor requirements, utility hookup fees, and setback rules. Legacy also acquired adjacent land in the city’s extraterritorial jurisdiction (ETJ) to build a road connecting the lots to a nearby highway, but this land was restricted to agricultural and residential use. Despite these limitations, Legacy constructed a road over the ETJ property, a greenbelt strip, and some development lots, advertising it as a shortcut and access to planned amenities. The City and other defendants opposed the road, citing violations of existing restrictions. Legacy alleged a conspiracy among the City, the property owners’ association (POA), and developers to prevent its development.The United States District Court for the Western District of Texas addressed multiple claims and counterclaims. It denied Legacy’s motion to dismiss the City’s counterclaims, granted the City’s motion to dismiss most claims against it, and granted summary judgment to all defendants on the remaining claims, including regulatory takings, Section 1983 violations, civil conspiracy, breach of fiduciary duty, negligence, and a strips and gores claim. Legacy’s own motion for partial summary judgment was denied, and final judgment was entered.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s rulings, with one modification. The appellate court held that Legacy’s regulatory takings claim regarding the two-permit cap was not prudentially ripe and should be dismissed without prejudice. The court otherwise affirmed summary judgment for the defendants, finding no genuine dispute of material fact and concluding that Legacy did not have property rights to build the road, nor did the defendants breach any legal duties or restrictive covenants. View "Legacy Hsing v. City of Horseshoe Bay" on Justia Law

An Oregon nonprofit organization, whose board members are guided by sincerely held religious beliefs, challenged a state law requiring most employers to provide insurance coverage for abortion and contraceptive services. The organization’s governing documents and public statements reflect a commitment to traditional Judeo-Christian ethics, including opposition to abortion based on religious grounds. Although the law contains exemptions for certain religious employers, the organization does not qualify for any of these exceptions, a point not disputed by the state. The organization sought relief, arguing that being compelled to provide such coverage violates its rights under the First and Fourteenth Amendments.The United States District Court for the District of Oregon denied the organization’s request for a preliminary injunction and dismissed its complaint. The district court found there was doubt as to whether the organization’s opposition to abortion was genuinely religious in nature. It further concluded that the law was neutral and generally applicable, subject only to rational basis review, which it satisfied.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal and vacated the denial of a preliminary injunction. The Ninth Circuit held that the organization’s beliefs are religious and sincerely held, and that the district court erred by not accepting these allegations as true at the motion to dismiss stage. The appellate court remanded the case for the district court to reconsider, in light of the Supreme Court’s decision in Catholic Charities Bureau, Inc. v. Wisconsin Labor & Industry Review Commission, whether the selective denial of a religious exemption to the organization violates the First Amendment. The Ninth Circuit expressed no opinion on the ultimate constitutional question, leaving it for the district court to address in the first instance. View "OREGON RIGHT TO LIFE V. STOLFI" on Justia Law

A candidate for Congress, who holds both a medical degree and a law degree but is not licensed to practice medicine, referred to himself as “Dr. Gonzalez” and a “physician” during his campaign. The Texas Medical Board (TMB) received a complaint alleging that these statements constituted the unlicensed practice of medicine and improper use of professional titles. After an investigation and hearing, TMB determined that the candidate had violated the Medical Practice Act and the Healing Art Identification Act, issuing a cease-and-desist order prohibiting him from using the titles “doctor,” “physician,” or “Dr.” without clarifying his lack of a medical license. The candidate challenged the order, arguing both statutory and constitutional grounds, including that the statutes violated his free speech rights.The Travis County District Court dismissed all of the candidate’s claims for lack of jurisdiction. The Court of Appeals for the Third District of Texas affirmed the dismissal of most claims, holding that the redundant-remedies doctrine barred his ultra vires and as-applied constitutional claims because he could have sought relief through the Administrative Procedure Act (APA). However, the appellate court remanded his facial constitutional challenge to the district court for further proceedings.The Supreme Court of Texas reviewed the case and held that the redundant-remedies doctrine did not bar the candidate’s ultra vires and as-applied constitutional claims, because the relief he sought—declaratory and injunctive relief against future enforcement—went beyond what the APA could provide. The court affirmed the dismissal of his substantial-evidence claim for lack of jurisdiction, as there was no statutory basis for judicial review outside the APA. The Supreme Court of Texas reversed in part, affirmed in part, and remanded for further proceedings on the facial constitutional, as-applied constitutional, and ultra vires claims. View "GONZALEZ v. TEXAS MEDICAL BOARD" on Justia Law