Justia Constitutional Law Opinion Summaries

A California resident sought to participate in Maryland’s cannabis business licensing process, which included a “social equity applicant” program designed to address historical inequities in the cannabis industry. To qualify as a social equity applicant, an individual needed to meet one of several criteria, such as having lived in a disproportionately impacted area, attending a public school in such an area, or attending for at least two years a Maryland institution of higher education where at least 40% of students are Pell Grant eligible. The plaintiff, who had never lived in Maryland, claimed eligibility based on her attendance at California State University, Long Beach, but was unable to meet the Maryland-specific higher education criterion. She was ultimately found ineligible for the first round of licensing.The plaintiff filed suit in the United States District Court for the District of Maryland, alleging that the Maryland licensing scheme discriminated against nonresidents in violation of the Dormant Commerce Clause and seeking declaratory and injunctive relief. She moved for a temporary restraining order and preliminary injunction to halt the licensing process. The district court denied her motion, finding she had not demonstrated a likelihood of success on the merits, and denied her request for an injunction pending appeal.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s denial of a preliminary injunction for abuse of discretion. The Fourth Circuit held that the challenged higher education criterion did not discriminate against non-Maryland residents, as it did not require Maryland residency and was equally available to out-of-state applicants who attended qualifying Maryland institutions. The court affirmed the district court’s denial of injunctive relief, concluding that the plaintiff failed to show a likelihood of success on the merits of her Dormant Commerce Clause claim. View "Jensen v. Maryland Cannabis Administration" on Justia Law

In October 2022, law enforcement officers stopped and searched a vehicle in which the defendant was a passenger. During the search, they discovered an Anderson Manufacturing AM-15 machinegun, a .357 caliber Glock handgun, and a “Glock switch” device capable of converting a handgun to fire automatically. Video evidence showed the defendant firing a Glock handgun equipped with the switch, operating as a fully automatic weapon. The defendant was subsequently indicted on two counts of knowingly and unlawfully possessing a machinegun, in violation of 18 U.S.C. § 922(o).The United States District Court for the District of Kansas reviewed the defendant’s motion to dismiss the indictment, which argued that § 922(o) violated the Second Amendment as applied to him. The district court agreed, finding that both the AM-15 machinegun and the Glock switch were “bearable arms” within the plain text of the Second Amendment. The court further concluded that the government had not demonstrated that § 922(o) was consistent with the nation’s historical tradition of firearm regulation, and therefore dismissed the indictment.On appeal, the United States Court of Appeals for the Tenth Circuit reversed the district court’s decision. The Tenth Circuit held that the defendant failed to meet his burden under the first step of the framework established in New York State Rifle & Pistol Ass’n, Inc. v. Bruen. Specifically, the court found that the defendant did not show that the machineguns he possessed were “arms” in “common use” for self-defense by law-abiding citizens, as required by District of Columbia v. Heller and subsequent precedent. As a result, the Tenth Circuit concluded that § 922(o) is constitutional as applied to the defendant, reversed the dismissal of the indictment, and remanded the case for further proceedings. View "United States v. Morgan" on Justia Law

Three Illinois residents who hold concealed carry licenses challenged a provision of the Illinois Firearm Concealed Carry Act that prohibits carrying loaded and accessible firearms on public transportation, such as buses and trains, with exceptions for unloaded and properly stored firearms. The plaintiffs argued that this restriction violated their Second Amendment rights, as they wished to carry firearms for self-defense while using public transit but refrained from doing so due to the law’s threat of arrest and prosecution.The case was first heard in the United States District Court for the Northern District of Illinois, Western Division. The district court found that the plaintiffs had standing, as they faced a credible threat of prosecution under the challenged statute. On the merits, the district court applied the Supreme Court’s test from New York State Rifle & Pistol Ass’n, Inc. v. Bruen and concluded that the public transit firearm restriction was not sufficiently supported by the nation’s historical tradition of firearm regulation. The court granted summary judgment for the plaintiffs, declaring the restriction unconstitutional as applied to them.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit held that Illinois’s restriction on carrying loaded and accessible firearms on public transportation is consistent with the Second Amendment, as it fits within a longstanding tradition of regulating firearms in sensitive and crowded, confined places. The court found that such regulations are analogous to historical restrictions in places like schools, legislative assemblies, and other crowded venues, and that the temporary disarmament required by the law is justified by public safety concerns unique to public transit. The Seventh Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Schoenthal v. O'Neill Burke" on Justia Law

A religious association that supports abortion as a core tenet challenged Idaho’s laws criminalizing abortion. The organization, which operates a telehealth abortion clinic in New Mexico, alleged that its members in Idaho were harmed by the state’s abortion restrictions. The association claimed that it had members in Idaho who could become involuntarily pregnant and would seek abortions as part of their religious practice, and that it had diverted resources to open its New Mexico clinic in response to Idaho’s and other states’ abortion bans.The United States District Court for the District of Idaho granted the defendants’ motion to dismiss, finding that the association lacked both associational and organizational standing. The district court determined that the association had not identified any specific member in Idaho who was injured or imminently would be injured by the abortion laws, nor had it shown that its organizational activities were directly impeded by the statutes. The district court also addressed the merits of the association’s constitutional claims and dismissed the complaint with prejudice.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal on the grounds of lack of Article III standing. The Ninth Circuit held that the association failed to demonstrate associational standing because it did not identify any member who had suffered or would imminently suffer an injury in Idaho. The court also found no organizational standing, as the association’s diversion of resources to open a clinic in New Mexico and its claim of frustration of mission were insufficient under recent Supreme Court precedent. The Ninth Circuit did not reach the merits of the constitutional claims. The court remanded the case to the district court to determine whether the complaint could be saved by amendment, noting that dismissal for lack of jurisdiction should generally be without prejudice. View "THE SATANIC TEMPLE V. LABRADOR" on Justia Law

Police officers in Oklahoma conducted a warrantless search of a storage unit rented by an individual whose email and payment information were on the rental agreement, though the agreement was signed by another person. Employees of the storage facility initially entered the unit after finding its door ajar, observing what appeared to be drugs and firearms, and then notified police. Upon arrival, officers looked into the unit, with one officer peeking his head inside to observe suspected contraband, and another officer later entering the unit and opening a drawer before a warrant was obtained. The officers then used their observations to obtain a search warrant for the storage unit, which led to the discovery of drugs and firearms. Based on this evidence, they secured a second warrant to search the renter’s home, where additional contraband was found.The United States District Court for the Northern District of Oklahoma denied the defendant’s motion to suppress evidence from both searches, finding no Fourth Amendment violation in the officers’ actions. The defendant entered a conditional guilty plea to drug and firearm charges, reserving the right to appeal the suppression ruling, and was sentenced to 188 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case. It held that the officers’ warrantless entry and search of the storage unit violated the Fourth Amendment. The court determined that, after excising the unconstitutionally obtained information from the search warrant affidavit, the remaining content failed to establish probable cause. The court also found that the good faith exception did not apply because the affidavit was so facially deficient that officers could not reasonably rely on it. Consequently, the evidence from both the storage unit and the home was ordered suppressed. The Tenth Circuit reversed the district court’s denial of the suppression motion, vacated the conviction and sentence, and remanded for further proceedings. View "United States v. Blasdel" on Justia Law

The Environmental Protection Agency (EPA) awarded $16 billion in grants to five nonprofit organizations to support the reduction of greenhouse gas emissions, as part of a larger $27 billion congressional appropriation under the Inflation Reduction Act. The grants were structured through agreements between the nonprofits and EPA, with Citibank acting as a financial agent to hold and disburse the funds. After concerns arose regarding conflicts of interest, lack of oversight, and last-minute amendments to the grant agreements, EPA terminated the grants in early 2025. Citibank, following an FBI recommendation, froze the accounts associated with the grants. The nonprofits sued, seeking to prevent the termination and to restore access to the funds.The United States District Court for the District of Columbia granted a preliminary injunction, ordering EPA and Citibank to continue funding the grants. The district court found it had jurisdiction, concluding the plaintiffs’ claims were not essentially contractual and thus did not need to be brought in the Court of Federal Claims. The court determined the plaintiffs were likely to succeed on their constitutional, regulatory, and arbitrary and capricious claims, and that the balance of harms and public interest favored the injunction.On appeal, the United States Court of Appeals for the District of Columbia Circuit held that the district court abused its discretion in issuing the injunction. The appellate court found that the plaintiffs’ regulatory and arbitrary and capricious claims were essentially contractual, meaning jurisdiction lay exclusively in the Court of Federal Claims, not the district court. The court also held that the constitutional claim was meritless. The equities and public interest, the appellate court concluded, favored the government’s need for oversight and management of public funds. Accordingly, the D.C. Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Climate United Fund v. Citibank, N.A." on Justia Law

A former Navy sailor, Lamar Forbes, was diagnosed with HIV in 2012 and instructed by medical personnel to disclose his status before engaging in sexual activity. Between 2013 and 2015, while stationed in Virginia, Forbes had unprotected sex with four women without informing them of his HIV-positive status. He was charged under several articles of the Uniform Code of Military Justice (UCMJ), including making a false official statement, sexual assault, and violating Article 134 by incorporating Virginia’s infected sexual battery statute through the Assimilative Crimes Act. Forbes pleaded guilty to some charges, and the military judge sentenced him to eight years’ confinement, reduction in paygrade, and a dishonorable discharge.Forbes appealed his sexual assault convictions to the Navy-Marine Corps Court of Criminal Appeals (NMCCA), arguing that his conduct did not constitute sexual assault under the UCMJ and that the statute was unconstitutionally vague. He did not appeal his Article 134 or Article 107 convictions. The NMCCA affirmed, relying on precedent that failure to disclose HIV status vitiates consent, making the sexual act an “offensive touching.” The Court of Appeals for the Armed Forces (CAAF) affirmed, holding that Forbes’s conduct met the definition of sexual assault under Article 120.On supervised release, Forbes petitioned the U.S. District Court for the District of Columbia for habeas relief, arguing that the military courts lacked subject matter jurisdiction and that their interpretation of Article 120 was an unconstitutional ex post facto expansion. The district court denied his petition, finding his challenges nonjurisdictional and procedurally defaulted, and that the military courts had fully and fairly considered his preserved claims.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s judgment. The court held that Forbes’s challenges were nonjurisdictional, subject to procedural default rules, and that the military courts had given full and fair consideration to his preserved claims. View "Forbes v. Phelan" on Justia Law

Anthony Browne was convicted in Iowa in 1991 of willful injury causing serious injury, a Class C forcible felony, and criminal gang participation, a Class D felony. After completing his sentence in 1998 and maintaining a law-abiding life, Browne sought to possess firearms for hunting, target shooting, and home defense. Iowa law prohibits felons, especially those convicted of forcible felonies, from possessing firearms or obtaining a permit to acquire a handgun, and does not allow restoration of firearms rights for such individuals except through a gubernatorial pardon.Browne filed suit in state court against the Governor of Iowa and the Sheriff of Johnson County, arguing that the statutory prohibition on restoration of firearms rights for forcible felons violates the Second Amendment as applied to him. The defendants removed the case to the United States District Court for the Southern District of Iowa. Browne requested a declaratory judgment that the statute is unconstitutional, and injunctions against enforcement and denial of a handgun permit without an individualized determination of dangerousness. The district court dismissed Browne’s federal claim for failure to state a claim, finding the statute constitutional, and remanded his state constitutional claim to state court.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The appellate court held that Browne had standing because applying for restoration or a permit would be futile under current law. On the merits, the court affirmed the district court’s dismissal, holding that Iowa’s lifetime prohibition on firearm possession by forcible felons, subject to the possibility of a gubernatorial pardon, is consistent with the Nation’s historical tradition of firearms regulation and does not violate the Second Amendment. The judgment of the district court was affirmed. View "Browne v. Reynolds" on Justia Law

Arron and Arthur Benedetti, along with the Estate of Willie Benedetti, challenged a provision in Marin County’s amended local coastal program (LCP) that allows owners of certain farmland to build additional residential units only if they record a restrictive covenant. This covenant requires the owner of the new units to be actively and directly engaged in agriculture, either through direct involvement in commercial agriculture or by leasing the property to a commercial agricultural producer. The Benedettis, who inherited farmland and sought to build a second residence, argued that this provision was facially unconstitutional, claiming it violated the nexus and proportionality requirements established in Nollan v. California Coastal Commission and Dolan v. City of Tigard, and infringed upon their substantive due process rights by compelling them to work in a specific occupation.The Marin County Superior Court initially ruled that the Benedettis could not bring a facial takings challenge under Nollan/Dolan and, applying rational basis review, denied their petition and complaint based on their due process theory. The trial court sustained a demurrer to one cause of action and denied relief on the others, leading to the Benedettis’ appeal.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The appellate court held that, contrary to the trial court’s conclusion, the Benedettis could raise a facial Nollan/Dolan claim. However, the court found that the restrictive covenant requirement had a sufficient nexus and rough proportionality to the county’s interest in preserving agricultural land and did not violate substantive due process. The court applied rational basis review and determined the provision was reasonably related to a legitimate legislative goal. The judgment of the Marin County Superior Court was affirmed. View "Benedetti v. County of Marin" on Justia Law

In 2006, Victor Arriaga entered into an oral agreement with Gilbert Torres to repair water-damaged drywall in Torres’s home. The project expanded to include additional repairs and a room addition, with Torres paying Arriaga substantial sums by check and cash. After several weeks, Arriaga and his father, who worked with him, left the job unfinished and removed their tools and materials from the property. Torres was unable to contact Arriaga afterward. The Los Angeles Building and Safety Department later issued a stop-work notice due to unpermitted and non-code-compliant work, and the Contractors State License Board (CSLB) discovered Arriaga was unlicensed. The CSLB referred the matter to the district attorney, who filed a felony complaint in 2007 for wrongful diversion of construction funds. However, there was no evidence that law enforcement attempted to contact Arriaga or inform him of the warrant. Arriaga moved to Nevada, and only learned of the warrant in 2022 after a misdemeanor arrest there. He returned to Los Angeles in 2023 to address the warrant and was arraigned.The Los Angeles County Superior Court held a preliminary hearing in 2023, after which Arriaga was held to answer. In 2024, Arriaga moved to dismiss the information, arguing that the 16-year delay between the complaint and his arraignment violated his state and federal speedy trial rights, causing him prejudice due to lost evidence and the death of his father, a key witness. The trial court denied the motion, finding no actual prejudice and concluding that the People had a legitimate justification for the delay.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. It held that Arriaga’s state speedy trial right was violated by the 16-year post-complaint delay, finding that he made a prima facie showing of prejudice due to the loss of his father’s testimony, and that the prosecution failed to provide a legitimate justification for the delay. The court granted Arriaga’s petition for a writ of prohibition and directed the trial court to dismiss the felony count. View "Arriaga v. Superior Court" on Justia Law