Justia Constitutional Law Opinion Summaries

In March 2025, the President issued an executive order directing federal officials to eliminate non-statutory functions and reduce statutory functions of three federal agencies: the Institute of Museum and Library Services (IMLS), the Minority Business Development Agency (MBDA), and the Federal Mediation and Conciliation Service (FMCS). These agencies, established and funded by Congress, provide grants and services to states and other entities. Following the executive order, the agencies terminated, reassigned, or placed on leave nearly all employees and canceled numerous grants, which plaintiffs—twenty-one states—alleged caused immediate and ongoing harm, including loss of services, forced layoffs, and canceled programming.The United States District Court for the District of Rhode Island granted a preliminary injunction, finding that the plaintiffs had suffered and would continue to suffer concrete injuries due to the agencies’ actions. The court determined that the agencies’ actions likely violated the Administrative Procedure Act and constitutional provisions, including the Take Care Clause and separation of powers. The injunction barred implementation of the executive order as to the three agencies, required reversal of actions taken to implement the order, restoration of employees, and resumption of grant funding, while allowing for efficiency measures not motivated by the executive order. The district court denied the government’s request for a stay of the injunction pending appeal.The United States Court of Appeals for the First Circuit reviewed only the government’s motion for a stay pending appeal. The court denied the stay, holding that the government failed to make a strong showing of likely success on the merits, particularly because it did not adequately challenge the district court’s constitutional analysis and had not preserved certain arguments. The court also found that the balance of harms and public interest did not favor a stay. View "Rhode Island v. Trump" on Justia Law

A pharmaceutical company challenged provisions of the Inflation Reduction Act of 2022, which established a program requiring the Department of Health and Human Services, through the Centers for Medicare and Medicaid Services (CMS), to negotiate maximum fair prices for certain high-cost prescription drugs covered by Medicare. The company’s drug was selected for the program, and it signed the required agreements to participate. The program imposes significant penalties and an excise tax on manufacturers who do not comply, but allows manufacturers to exit Medicare and Medicaid programs to avoid the tax, a process the company argued was not a realistic option.After its drug was selected, the company filed suit in the United States District Court for the District of New Jersey, alleging that the program violated the Eighth Amendment’s Excessive Fines Clause, the Fifth Amendment’s Takings Clause, and the First Amendment’s Free Speech Clause. The District Court granted summary judgment for the government, holding that participation in the program is voluntary and that the program primarily regulates conduct, not speech. The court also found it lacked jurisdiction over the Eighth Amendment claim due to the Tax Anti-Injunction Act and the Declaratory Judgment Act.On appeal, the United States Court of Appeals for the Third Circuit affirmed. The court held that the company’s Eighth Amendment claim was barred by the Tax Anti-Injunction Act and the Declaratory Judgment Act, as the relief sought would restrain the assessment or collection of a federal tax. The court further held that the program does not violate the Takings Clause or the First Amendment, relying on its recent precedent. The judgment of the District Court was affirmed. View "Novartis Pharmaceuticals Corp v. Secretary Department of Health" on Justia Law

Parents and guardians of students enrolled in independent study programs at two California charter schools requested that the schools purchase and allow the use of sectarian curricular materials for instruction. The schools denied these requests, citing California laws that prohibit the teaching of sectarian or denominational doctrine in public schools, including charter schools. The plaintiffs argued that the independent study programs were essentially homeschooling and that the denial of their requests violated their rights under the Free Exercise and Free Speech Clauses of the First Amendment.The United States District Court for the Eastern District of California dismissed the complaint for failure to state a claim. The court found that charter schools are part of California’s public school system and are permitted to provide strictly secular education. It concluded that the plaintiffs were not being excluded from a generally available public benefit because of their religious exercise, as the case involved state-funded public schools rather than private schools. The court also held that a public school’s curriculum constitutes government speech, which is not subject to scrutiny under the Free Speech Clause.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that, even assuming the funding and materials provided in independent study programs are a generally available public benefit, the programs are sufficiently public to allow California to require the use of secular curricula. The court further held that the curriculum decisions of public schools are government speech and thus not subject to the Free Speech Clause. The judgment of the district court was affirmed. View "WOOLARD V. THURMOND" on Justia Law

A police officer stopped a rental pickup truck driven by the defendant after observing a traffic violation and noticing the vehicle’s dark window tint. Upon approaching, the officer detected the odor of marijuana and learned that the defendant had previously waived his Fourth Amendment rights as part of a plea agreement. After both occupants exited the vehicle, a search revealed marijuana shake and bags containing suspected narcotics. The officer then searched the defendant’s person, finding large amounts of cash and, during a pat-down over the defendant’s underwear, felt a hard object between the defendant’s buttocks and underwear. The defendant resisted as the officer attempted to retrieve the item, which was ultimately removed and found to contain cocaine and crack cocaine. At no point were the defendant’s genitals or buttocks exposed to the public.The defendant moved to suppress the evidence, arguing the search was an impermissible, warrantless body cavity search under the Fourth Amendment. The Circuit Court of the City of Norfolk denied the motion, finding probable cause and exigent circumstances due to the potential danger of fentanyl and risk of evidence destruction. The defendant was convicted of possession with intent to distribute cocaine. The Court of Appeals of Virginia vacated the conviction, holding that the search was unreasonably intrusive and not justified by exigent circumstances, and that the evidence should have been suppressed.The Supreme Court of Virginia reviewed the case and reversed the Court of Appeals. It held that the search was reasonable under the Fourth Amendment, given the probable cause for arrest, the manner and location of the search, the risks posed by possible fentanyl exposure, and the need to prevent destruction of evidence. The Court found the search did not constitute a manual body cavity search and was justified as a search incident to arrest. The defendant’s conviction was reinstated. View "Commonwealth v. Hubbard" on Justia Law

Robert Miller died at his home in Cape Cod in 2019 following an encounter with Barnstable police officers Sean Roycroft and Spencer Jackson. The officers responded to a 911 call from Miller’s girlfriend, who requested a psychiatric evaluation but did not report any crime. Upon arrival, a struggle ensued as the officers attempted to handcuff Miller, who ended up face-down on the floor with Roycroft’s arm pinned beneath him. During the struggle, Jackson delivered two punches to Miller in an effort to facilitate handcuffing. Miller’s girlfriend witnessed one of the officers drive a knee into Miller’s back and heard Miller say, “I can’t breathe” and “Amy, help me.” After Miller was handcuffed, he became unresponsive and was later pronounced dead. The medical examiner attributed the death to cardiac dysrhythmia in the setting of excited delirium, while the plaintiff’s expert opined that Miller died from prone restraint cardiac arrest due to pressure on his back.The plaintiff, Miller’s son, brought a federal excessive force claim under 42 U.S.C. § 1983 against the officers in the United States District Court for the District of Massachusetts. After discovery, the officers moved for summary judgment on qualified immunity grounds. The district judge denied summary judgment, finding that there were genuine disputes of material fact regarding whether the officers used excessive force, particularly after Roycroft freed his arm and Miller was restrained. The judge concluded that clearly established law prohibited kneeling on a restrained person’s back and that a reasonable jury could find the officers’ conduct violated Miller’s constitutional rights.On appeal, the United States Court of Appeals for the First Circuit reversed the denial of qualified immunity for the officers’ conduct while Roycroft’s arm was pinned (Phase One), affirmed the denial for conduct after Miller was restrained and a knee was placed on his back (Phase Two), and dismissed the appeal in part for fact-based arguments not suitable for interlocutory review. The case was remanded for further proceedings. View "Miller v. Roycroft" on Justia Law

Daniel Orozco was involved in a drive-by shooting in Los Angeles, where he and three other members or associates of the Varrio Norwalk gang entered rival Chivas gang territory. During two separate incidents about twenty minutes apart, a shooter in Orozco’s car used Orozco’s gun to wound one man and kill another, who was not a gang member. Police quickly connected the car to Orozco, found the group at his home, and recovered the weapon and other evidence. Orozco was arrested along with the others. At trial, Orozco’s defense centered on his alleged intoxication, arguing he was too drunk to form criminal intent.At the preliminary hearing in the Superior Court of Los Angeles County, the magistrate suppressed a confession by the shooter, Martinez Garibo, due to a Miranda violation. Despite this, the magistrate found sufficient evidence to hold Orozco to answer for murder and attempted murder, but not for conspiracy to commit murder, as there was no evidence of an agreement to kill. On the day of trial, the prosecution moved to add a conspiracy charge, which the trial court allowed over Orozco’s objection. The jury convicted Orozco of all three charges, and he was sentenced to consecutive terms for murder and attempted murder, with a stayed sentence for conspiracy.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It held that the conspiracy conviction must be reversed because the evidence at the preliminary hearing did not support that charge, and Orozco was not given proper notice. The court affirmed the convictions for murder and attempted murder, finding no merit in Orozco’s other arguments, including ineffective assistance of counsel and alleged prosecutorial error. The court also held that Orozco forfeited his challenge to the attempted murder sentence by failing to object and having adequate notice. The case was remanded for further proceedings consistent with the opinion. View "People v. Orozco" on Justia Law

Rockwood Auto Parts, Inc. and Rockwood Towing, Inc., along with their owner, Jacques Poli, had longstanding business relationships with the Monroe County Sheriff’s Office, performing vehicle maintenance and towing services. After Troy Goodnough was elected sheriff in 2020, Monroe County initiated a competitive bidding process for fleet maintenance, ultimately awarding the contract to Gerweck Nissan instead of Rockwood Auto. Goodnough also revised the county’s towing rotation, reducing Rockwood Towing’s share of business. Additionally, Goodnough and Sergeant Michael Preadmore conducted warrantless audits of Rockwood’s premises and Poli’s property to inventory county assets, which led to a state police investigation but no criminal charges.The plaintiffs filed suit in the United States District Court for the Eastern District of Michigan, alleging violations of their Fourth Amendment rights due to the warrantless searches, and asserting equal protection and due process claims under the Fourteenth Amendment related to the loss of contracts and towing business. They also sought to impose municipal liability on Monroe County. The district court granted summary judgment to the defendants on all claims, finding no genuine disputes of material fact and concluding that the searches were consensual, the contract decisions had rational bases, and no protected property interest existed in the bidding process.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment de novo. The Sixth Circuit affirmed the district court’s judgment, holding that the searches were conducted with valid consent, the changes to contracts and towing lists were supported by rational bases and did not constitute unconstitutional discrimination, and the plaintiffs lacked a protected property interest in the fleet-maintenance contract. The court also found no basis for municipal liability under Monell, as no underlying constitutional violation was established. View "Rockwood Auto Parts, Inc. v. Monroe County" on Justia Law

Two Maryland residents challenged a state law that allows Maryland to take custody of property deemed “abandoned” after a period of owner inactivity, such as unclaimed bank accounts or stocks. Before 2004, owners who reclaimed such property from the state received both the principal and any interest accrued while the property was in state custody. After a 2004 amendment, claimants could only recover the principal, not the interest. The lead plaintiff, who had not yet filed a claim with the state, argued that Maryland’s failure to pay interest constituted an unconstitutional taking under the Fifth Amendment and sought a declaratory judgment and injunction requiring the state to pay just compensation, including interest, when he eventually filed a claim.The United States District Court for the District of Maryland denied the Comptroller’s motion to dismiss, finding that the plaintiff had standing, the claim was ripe, and the complaint stated a facial challenge to the statute. The court also held that the claim was not barred by Eleventh Amendment sovereign immunity, reasoning that the relief sought was prospective and thus fell within the Ex parte Young exception, which allows federal courts to enjoin ongoing violations of federal law by state officials.The United States Court of Appeals for the Fourth Circuit reviewed only the sovereign immunity issue. The Fourth Circuit held that the Eleventh Amendment bars federal courts from ordering Maryland to pay interest that accrued before any federal court judgment, as such relief is retroactive and constitutes a claim for money damages. However, the court held that to the extent the plaintiff seeks prospective relief—specifically, interest that would accrue after a federal court judgment—such a claim may proceed under the Ex parte Young doctrine. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Albert v. Lierman" on Justia Law

In early 2023, police responded to a disturbance at a residence in Odessa, Texas, where Deimon Nolan Simpson, who had recently been evicted, attempted to enter the house he believed was still his. After being blocked by the new tenant, Simpson retrieved a firearm from his car, entered through a window, and shot the tenant’s dog. Simpson, a convicted felon with prior convictions including possession of a controlled substance, evading arrest or detention with a vehicle, and being a felon in possession of a firearm, was charged with violating 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms.The United States District Court for the Western District of Texas denied Simpson’s motion to dismiss the indictment. Simpson then pleaded guilty, admitting to the relevant prior felony convictions. On appeal, Simpson challenged the constitutionality of § 922(g)(1) as applied to him under the Second Amendment, and also raised facial and Commerce Clause challenges, which he acknowledged were foreclosed by existing Fifth Circuit precedent.The United States Court of Appeals for the Fifth Circuit reviewed the constitutional challenge de novo. The court held that the felon-in-possession statute is constitutional as applied to Simpson because his predicate felony—evading arrest or detention with a vehicle—involved violent conduct, and there is a historical tradition of disarming individuals who pose a credible threat of violence. The court found that both historical and contemporary laws support permanent disarmament in such circumstances, and that the statute does not broadly restrict firearm rights but targets those with demonstrated threats to public safety. Accordingly, the Fifth Circuit affirmed the district court’s denial of the motion to dismiss. View "USA v. Simpson" on Justia Law

After the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, which struck down New York’s “proper cause” requirement for public handgun carry, New Jersey enacted Chapter 131. This law removed its own “justifiable need” standard but imposed new licensing requirements, increased permit fees, mandated liability insurance for handgun carriers, and designated numerous “sensitive places” where firearms are prohibited, such as parks, entertainment venues, healthcare facilities, and private property without express consent. Two groups of plaintiffs, including individuals and gun rights organizations, challenged these provisions under 42 U.S.C. § 1983, arguing they violated the Second Amendment.The United States District Court for the District of New Jersey consolidated the cases and allowed legislative leaders to intervene as defendants. The District Court preliminarily enjoined enforcement of several “sensitive place” restrictions, the vehicle carry ban, the liability insurance requirement, and the private property default rule, finding these likely unconstitutional under Bruen’s historical tradition test. The State and some plaintiffs appealed, and the Third Circuit Court of Appeals granted a partial stay, allowing most of the law to take effect pending appeal.The United States Court of Appeals for the Third Circuit reviewed the District Court’s preliminary injunction, applying de novo review to the underlying Second Amendment questions. The Third Circuit held that most of New Jersey’s “sensitive place” restrictions—such as those covering parks, entertainment venues, healthcare facilities, libraries, museums, and places serving alcohol—are likely constitutional, finding them consistent with a historical tradition of regulating firearms in locations set aside for civic, educational, or recreational purposes. However, the court affirmed the injunction against the liability insurance mandate, the portion of the permit fee allocated to the Victims of Crime Compensation Office, the private property default rule as applied to places open to the public, and the ban on carrying operable firearms in private vehicles, holding these provisions likely violate the Second Amendment. The court vacated the injunction as to film sets and certain hunting regulations for lack of standing or mootness, and remanded for further proceedings consistent with its opinion. View "Koons v. Attorney General New Jersey" on Justia Law