Justia Constitutional Law Opinion Summaries

In 1996, Samuel Smithers was hired to maintain a 27-acre property in Plant City, Florida, where two women, Cristy Cowan and Denise Roach, were found murdered near the property’s ponds. Evidence, including DNA and surveillance footage, linked Smithers to the victims. After being questioned by law enforcement, Smithers gave inconsistent statements and ultimately confessed to both murders. At trial, medical testimony established that both victims died from a combination of strangulation and wounds inflicted by a sharp instrument. Smithers testified in his own defense, blaming an unknown man for the crimes, but the jury convicted him of two counts of first-degree murder and unanimously recommended the death penalty for both.The Circuit Court for Hillsborough County sentenced Smithers to death, finding several aggravating factors and weighing mitigating circumstances. The Florida Supreme Court affirmed his convictions and sentences on direct appeal. Smithers subsequently filed multiple postconviction motions and federal habeas petitions, all of which were denied by the respective courts, including the United States Supreme Court’s denial of certiorari. In 2025, after the Governor signed his death warrant, Smithers filed a successive postconviction motion arguing that executing him at age 72 would constitute cruel and unusual punishment due to his advanced age.The Supreme Court of Florida reviewed the summary denial of Smithers’ motion. The court held that his claim was untimely and procedurally barred under Florida Rule of Criminal Procedure 3.851, as none of the rule’s exceptions applied. Additionally, the court concluded that Florida’s conformity clause requires its courts to follow United States Supreme Court precedent, which does not recognize a categorical exemption from execution based on advanced age. Therefore, the Supreme Court of Florida affirmed the circuit court’s summary denial of Smithers’ successive postconviction motion. View "Smithers v. State" on Justia Law

Amy Hadley’s home in South Bend, Indiana, was significantly damaged when law enforcement officers executed a search warrant in pursuit of a murder suspect they believed was inside her residence. The officers, acting on information that the suspect had accessed his Facebook account from Hadley’s IP address, obtained a warrant and forcefully entered the home, causing extensive property damage, including the use of tear gas and destruction of personal items. Hadley, who had no connection to the suspect, was denied compensation by both the City of South Bend and St. Joseph County for the $16,000 in damages.After her request for compensation was denied, Hadley filed suit in Indiana state court, seeking relief under 42 U.S.C. § 1983 for violations of her Fifth and Fourteenth Amendment rights, specifically invoking the Takings Clause. The case was removed to the United States District Court for the Northern District of Indiana, South Bend Division. The defendants moved to dismiss, arguing that Seventh Circuit precedent, particularly Johnson v. Manitowoc County, foreclosed her claim. The district court agreed and dismissed the complaint, finding that the Takings Clause did not entitle her to compensation for property damage resulting from the execution of a lawful search warrant.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that, under its precedent in Johnson v. Manitowoc County, the Fifth Amendment does not require the government to compensate property owners for damage caused by law enforcement executing a valid search warrant. The court declined to overrule Johnson and found that Hadley’s arguments did not warrant revisiting the established rule. View "Hadley v. City of South Bend" on Justia Law

The plaintiffs in this case are homeowners and rental-property supervisors in New Orleans who challenged the City’s regulations governing short-term rentals (STRs), defined as lodging offered for less than thirty days. The City’s regulatory scheme requires permits for both owners and operators of STRs, restricts eligibility to “natural persons,” mandates that operators reside at the property, and imposes specific advertising requirements. The regulations were enacted in response to concerns about neighborhood disruption and loss of affordable housing attributed to the proliferation of STRs. Plaintiffs argued that these regulations violated various constitutional provisions, including the Due Process and Equal Protection Clauses, the First Amendment, and the dormant Commerce Clause.The United States District Court for the Eastern District of Louisiana granted summary judgment largely in favor of the City, upholding the constitutionality of most aspects of the STR regulations. The district court found that the City had authority under state law to regulate STRs and rejected the plaintiffs’ due process and equal protection claims, except for one provision not at issue on appeal. The court also upheld the advertising restrictions and the operator residency requirement, interpreting the latter as not requiring permanent residency.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed in part, reversed in part, and remanded. The Fifth Circuit held that the City’s prohibition on business entities obtaining owner or operator permits violated the Equal Protection Clause, as the distinction was arbitrary and not rationally related to a legitimate government interest. The court also found that the requirement that each STR advertisement list only one dwelling unit violated the First Amendment. However, the court upheld the City’s authority to regulate STRs, the due process analysis, most advertising restrictions, and interpreted the operator residency requirement as not violating the dormant Commerce Clause. View "Hignell-Stark v. City of New Orleans" on Justia Law

A member of the Pennsylvania House of Representatives used public funds and the resources of the House Democratic Caucus to send five pre-recorded, automated phone calls to constituents. These calls provided information about public health resources, employment opportunities, and community events. The calls were approved and administered by House staff, who determined that each served a clear legislative purpose and public benefit. The recipient of these calls, Andrew Perrong, filed suit, alleging that the calls violated the Telephone Consumer Protection Act (TCPA), which generally prohibits automated or pre-recorded calls made by “any person.”The United States District Court for the Eastern District of Pennsylvania denied the legislator’s motion for summary judgment. The court held that the legislator was a “person” under the TCPA and could be sued in his individual capacity, even though the calls were made as part of his official duties. The District Court also found that the suit was not barred by Eleventh Amendment sovereign immunity, reasoning that the Commonwealth of Pennsylvania was not the real party in interest, and that qualified immunity did not apply because the statutory prohibition was clear.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory question and the immunity defenses. The Third Circuit held that the TCPA’s use of the term “person” does not clearly and unmistakably include state legislators acting in their official capacity when performing legitimate government functions. The court reasoned that longstanding interpretive presumptions, constitutional federalism principles, and statutory context all support excluding such official acts from the statute’s reach. As a result, the court reversed the District Court’s denial of summary judgment, holding that the TCPA’s robocall restriction does not apply to calls made by state legislators in connection with their legitimate government functions. View "Perrong v. Bradford" on Justia Law

Novo Nordisk, a pharmaceutical manufacturer, challenged the implementation of the Drug Price Negotiation Program established by the Inflation Reduction Act of 2022. The Program requires the Department of Health and Human Services, through the Centers for Medicare and Medicaid Services (CMS), to negotiate prices for certain high-expenditure drugs covered by Medicare. In the first round of selections, CMS grouped six of Novo Nordisk’s insulin aspart products as a single “negotiation-eligible drug” and selected them for price negotiation. Novo Nordisk signed the required agreements to participate but subsequently filed suit, arguing that CMS’s grouping of its products and the procedures used to implement the Program violated statutory and constitutional provisions.The United States District Court for the District of New Jersey granted summary judgment in favor of the government. The court found it lacked subject matter jurisdiction to review CMS’s decision to treat the six products as one drug due to a statutory bar on judicial review. It also held that Novo Nordisk lacked standing to challenge the identification of more than ten drugs for the initial pricing period. The court rejected Novo Nordisk’s claims under the unconstitutional conditions doctrine, the Due Process Clause, the nondelegation doctrine, and the First Amendment, concluding that the Program did not deprive the company of a protected property interest, that Congress provided an intelligible principle to guide CMS, and that the Program primarily regulated conduct rather than speech.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that the statutory bar on judicial review precluded consideration of Novo Nordisk’s challenge to the grouping of its products. The court also held that CMS was authorized to implement the Program through guidance for the initial years without notice and comment rulemaking, that the Act did not violate the nondelegation doctrine or the Due Process Clause, and that Novo Nordisk’s First Amendment claim was foreclosed by precedent. View "Novo Nordisk Inc. v. Secretary US Dept & Health and Human Services" on Justia Law

A transgender inmate serving a lengthy sentence in the Connecticut prison system was diagnosed with gender dysphoria after several years of incarceration. The inmate requested various treatments, including stronger hormone therapy and a vaginoplasty, but was initially denied hormone therapy due to a prison policy that only allowed continuation, not initiation, of such treatment. After a policy change, the inmate received hormone therapy, mental health counseling, antidepressants, and some lifestyle accommodations. Despite these measures, the inmate continued to request additional treatments, including surgery, and expressed dissatisfaction with the care provided, alleging it was inadequate and not delivered by specialists in gender dysphoria.The United States District Court for the District of Connecticut reviewed the inmate’s claims of deliberate indifference to serious medical needs under the Eighth Amendment. The district court found that the corrections officials had deprived the inmate of adequate care by providing mental health treatment from unqualified providers, delaying and inadequately administering hormone therapy, and denying surgical intervention. The court denied the defendants’ motion for summary judgment on qualified immunity grounds, holding that the right to be free from deliberate indifference to serious medical needs was clearly established.On appeal, the United States Court of Appeals for the Second Circuit reversed the district court’s decision. The Second Circuit held that there is no clearly established constitutional right for inmates to receive specific treatments for gender dysphoria or to be treated by gender-dysphoria specialists. The court found that reasonable officials could disagree about the adequacy and legality of the care provided, which included talk therapy, antidepressants, and hormone therapy. The Second Circuit concluded that the defendants were entitled to qualified immunity and remanded the case with instructions to grant summary judgment in their favor. View "Clark v. Valletta" on Justia Law

The defendant was charged with twenty-one felony counts stemming from a fifteen-minute crime spree in February 2019, during which he attempted to break into homes, engaged in a physical altercation, stopped vehicles at gunpoint, and was ultimately apprehended by police. He was arraigned in May 2019 and held on high bail. Over the next several years, the case was delayed by issues including the Commonwealth’s slow production of mandatory discovery, changes in defense counsel, and the defendant’s own motions and requests. The COVID-19 pandemic led to statewide orders suspending jury trials for extended periods, further delaying proceedings.The case was heard in the Hampden Superior Court, where the defendant filed multiple motions to dismiss, arguing that the delay violated both the Massachusetts Rules of Criminal Procedure (rule 36) and his constitutional right to a speedy trial. The Superior Court judge excluded various periods from the speedy trial calculation, including time attributable to COVID-19 orders, delays caused by defense motions, and periods when the defendant changed counsel or requested continuances. The defendant was ultimately convicted on most counts after a bench trial, and he appealed directly to the Supreme Judicial Court.The Supreme Judicial Court of Massachusetts held that delays resulting from its COVID-19 orders do not weigh against the Commonwealth in evaluating constitutional speedy trial claims. The Court further found that, after excluding periods attributable to the pandemic, defense motions, and other justified delays, the remaining delay did not violate rule 36 or the defendant’s constitutional rights under the Sixth Amendment or Article 11 of the Massachusetts Declaration of Rights. The Court affirmed the defendant’s convictions. View "Commonwealth v. Larace" on Justia Law

In 2009, after a history of domestic violence and threats, the defendant killed his wife and five young children by cutting their throats and then fled to Haiti, where he was apprehended and confessed. He attributed his actions to “bad spirits” and voodoo spells. Upon return to Florida, he pled guilty to six counts of first-degree murder, waived his right to a penalty-phase jury, and declined to present mitigation evidence. Throughout the proceedings, his competency to stand trial was repeatedly evaluated, with findings alternating between competent and incompetent, but ultimately he was found competent at the time of his plea and sentencing. His defense team, which included both public defenders and later court-appointed attorneys, conducted extensive mitigation investigations, including mental health and cultural background assessments, despite the defendant’s lack of cooperation.The Circuit Court for Collier County imposed six death sentences, finding multiple aggravating factors and twelve mitigating factors, including some evidence of mental illness. On direct appeal, the Supreme Court of Florida affirmed the convictions and sentences, rejecting claims regarding self-representation, aggravator duplication, and the constitutionality of the death penalty. The defendant then filed a motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, raising claims of ineffective assistance of counsel related to competency and mitigation, and challenging restrictions on access to public records. The circuit court denied all claims after an evidentiary hearing.The Supreme Court of Florida reviewed the appeal from the denial of postconviction relief and a related habeas corpus petition. The court held that claims regarding competency were procedurally barred, as they could have been raised on direct appeal, and that the defendant failed to show ineffective assistance of counsel under the Strickland standard. The court also found no abuse of discretion in the denial of public records requests and rejected the habeas petition alleging ineffective assistance of appellate counsel. The court affirmed the denial of postconviction relief and denied habeas corpus relief. View "Damas v. State of Florida" on Justia Law

Juan Alaniz was convicted of possessing a firearm and ammunition as a convicted felon, in violation of 18 U.S.C. § 922(g)(1). Alaniz had prior state felony convictions for illegally possessing a controlled substance and for burglary. He challenged his conviction on constitutional grounds, arguing that the statute exceeded Congress’s authority under the Commerce Clause, violated the Second Amendment on its face, and violated the Second Amendment as applied to him.The United States District Court for the Southern District of Texas reviewed the case and entered a conviction against Alaniz. On appeal, Alaniz raised the same constitutional arguments before the United States Court of Appeals for the Fifth Circuit. He specifically argued that only his controlled substance conviction should be considered as the predicate for his § 922(g)(1) conviction, and that his burglary conviction should not be relevant to the constitutional analysis.The United States Court of Appeals for the Fifth Circuit rejected Alaniz’s Commerce Clause and facial Second Amendment challenges, citing circuit precedent. The court reviewed his as-applied Second Amendment challenge de novo and held that the government may consider Alaniz’s entire criminal record, including his burglary conviction, when evaluating the constitutionality of § 922(g)(1) as applied to him. The court found that founding-era laws support the constitutionality of disarming individuals convicted of burglary. Therefore, Alaniz’s as-applied challenge was foreclosed by circuit precedent, and the Fifth Circuit affirmed the judgment of the district court. View "United States v. Alaniz" on Justia Law

Dewayne Keith Parker faced criminal charges in both Fresno and Napa counties, including murder, burglary, and assault. He was found incompetent to stand trial in Fresno County and admitted to Napa State Hospital. While hospitalized, Parker allegedly assaulted another patient, leading to new charges in Napa County. The Napa County Superior Court found him incompetent to stand trial and committed him to the Department of State Hospitals. After Parker was restored to competency, he was discharged to Fresno County due to his primary commitment there. More than a year later, after being arrested on a Napa County bench warrant, Parker was returned to Napa County, where the court again found him incompetent to stand trial.The Napa County Superior Court held a restoration hearing and, relying on equitable tolling, paused the two-year maximum commitment period for Parker’s Napa County charges during the time he was involved in proceedings in Fresno County. Parker argued that this tolling was unauthorized by statute and violated his due process and equal protection rights. The court rejected these arguments, denied his request for release or conservatorship, and set a new commitment expiration date based on the tolled period.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court held that, although the statutory scheme for competency commitments does not expressly address tolling, courts have inherent equitable powers to pause the running of the commitment period when a defendant is unavailable due to proceedings in another jurisdiction. The court found that the delay caused by Parker’s simultaneous proceedings in Fresno County constituted good cause for tolling. The appellate court affirmed the Napa County Superior Court’s order, concluding that the tolling did not violate Parker’s constitutional rights. View "People v. Parker" on Justia Law