Justia Constitutional Law Opinion Summaries

The defendant pled guilty to possession of a firearm and ammunition after a felony conviction. At sentencing, the United States District Court for the Eastern District of New York imposed a term of imprisonment followed by supervised release. During the sentencing hearing, the court orally imposed several “special” conditions of supervised release, as recommended in the presentence report, but did not specify or discuss any “standard” or additional discretionary conditions. The court also stated that the defendant would not be required to contribute to the cost of mental health services, contrary to a recommendation in the presentence report. However, the written judgment later included not only the special conditions but also thirteen additional discretionary “standard” conditions of supervised release, as well as a requirement that the defendant contribute to mental health service costs.After sentencing, the defendant appealed, arguing that his constitutional right to be present at sentencing was violated because the thirteen discretionary conditions were not pronounced in his presence, and that the written judgment’s requirement to pay for mental health services contradicted the oral sentence. Both parties agreed that the payment requirement should be eliminated due to this inconsistency.The United States Court of Appeals for the Second Circuit, sitting en banc, reviewed the case de novo. The court overruled its prior precedent in United States v. Truscello, which had allowed non-mandatory “standard” conditions to be added to the written judgment without oral pronouncement. The Second Circuit held that all non-mandatory conditions of supervised release, including those labeled as “standard” in the Sentencing Guidelines, must be pronounced in the defendant’s presence at sentencing. The court vacated the portions of the sentence imposing the thirteen discretionary conditions and the payment requirement, and remanded the case for further proceedings consistent with its opinion. View "United States v. Maiorana" on Justia Law

A group of ten Black men, including the appellant, were conversing on a sidewalk in Ward Four of the District of Columbia when four officers from the Metropolitan Police Department’s Gun Recovery Unit approached them as part of a firearm interdiction operation. The officers, wearing tactical vests and displaying police equipment, approached the group without any specific suspicion of criminal activity. One officer, DelBorrell, approached the appellant from behind and asked if he was carrying a firearm. The appellant denied it and twice lifted his shirt to show his waistband. The officer then asked the appellant to “hike” his pants up, which he did. Another officer then noticed a bulge in the appellant’s groin area, believed it to be a firearm, and after a brief struggle, the officers recovered a gun from the appellant’s pants.The appellant was charged with eight firearm-related offenses. He moved to suppress the firearm and a subsequent statement, arguing they were the result of an unreasonable seizure in violation of the Fourth Amendment. The Superior Court of the District of Columbia denied the motion, finding that the appellant was not seized until after he raised his pants, at which point the officers had reasonable suspicion based on the observed bulge. The appellant was convicted on all counts following a trial on stipulated facts and appealed.The District of Columbia Court of Appeals reviewed the case and held that the appellant was seized within the meaning of the Fourth Amendment when the officer requested that he raise his pants. The court found that, considering the officers’ show of authority, the accusatory and repetitive questioning, and the appellant’s status as a Black man in a highly policed area, a reasonable person in his position would not have felt free to leave. Because the seizure was not supported by reasonable suspicion or probable cause, it was unreasonable. The court vacated the convictions and remanded for further proceedings. View "Carter v. United States" on Justia Law

A law enforcement agency in the District of Columbia, responsible for supervising individuals on supervised release, imposed GPS monitoring on a supervisee without judicial or Parole Commission authorization. The agency’s internal regulations permitted its officers to unilaterally require GPS monitoring as an administrative sanction, and this practice had been applied to thousands of supervisees over two decades. In this instance, the supervisee was placed on GPS monitoring twice, first for a positive drug test and then for submitting questionable urine samples. Subsequently, police investigating an armed robbery used the agency’s GPS data to identify and locate the supervisee, leading to his arrest and the recovery of stolen property and a firearm.The Superior Court of the District of Columbia reviewed the supervisee’s motion to suppress the GPS evidence and its fruits, following the District of Columbia Court of Appeals’ recent decision in Davis v. United States, 306 A.3d 89 (D.C. 2023), which held that the agency lacked statutory authority to impose GPS monitoring absent judicial or Parole Commission approval, rendering such searches unconstitutional. The government conceded the constitutional violation but argued that the good faith exception to the exclusionary rule should apply, as the agency reasonably relied on its own regulations. The trial court rejected this argument and granted the suppression motion.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s ruling. The court held that the exclusionary rule applies because the agency is a law enforcement entity, not a neutral third party like a judge or legislature, and thus should feel the deterrent effect of suppression. The good faith exception does not apply when a law enforcement agency unilaterally authorizes unconstitutional searches based on its own mistaken interpretation of its authority. The court concluded that suppression is warranted to deter systemic constitutional violations. View "United States v. Wells" on Justia Law

In 2021, a plaintiff filed a complaint against a public school district, alleging that she was repeatedly sexually assaulted by a teacher while attending middle and high school. The complaint asserted that the teacher’s abusive conduct was widely known within the school and that the district either knew or should have known about the abuse but failed to act, allowing the teacher to remain employed. The plaintiff brought claims for negligence and negligent hiring, retention, and supervision, relying on statutory provisions that exempt certain childhood sexual assault claims from the usual requirement to present a claim to the public entity before filing suit.The Superior Court of Los Angeles County reviewed the case after the school district moved for judgment on the pleadings. The district argued that the plaintiff’s claims were only possible due to Assembly Bill 218 (AB 218), which retroactively eliminated the claims presentation requirement for childhood sexual assault claims against public entities. The district contended that AB 218 violated the gift clause of the California Constitution by imposing liability for past acts where no enforceable claim previously existed. The trial court agreed, finding that AB 218 retroactively created liability and constituted an unconstitutional gift of public funds, and dismissed the complaint with prejudice.The California Court of Appeal, Second Appellate District, Division One, reviewed the trial court’s decision de novo. The appellate court held that AB 218 does not violate the gift clause because it did not create new substantive liability; rather, it removed a procedural barrier to enforcing pre-existing liability for negligence and negligent hiring, retention, and supervision. The court reversed the trial court’s order and remanded with directions to deny the school district’s motion for judgment on the pleadings. View "O.B. v. L.A. Unified School Dist." on Justia Law

Three individuals who are lawful gun owners challenged a Fairfax County, Virginia ordinance that prohibits the possession, carrying, or transportation of firearms in certain locations. The two main restrictions at issue are a ban on firearms in county parks and a ban in public spaces where, or near where, a county-permitted event is taking place. The plaintiffs argued that both restrictions violate the Second Amendment, and that the events restriction is unconstitutionally vague under the Fourteenth Amendment.The United States District Court for the Eastern District of Virginia reviewed the case. It denied the plaintiffs’ motion for a preliminary injunction and later granted summary judgment to Fairfax County and its Chief of Police. The district court found that both restrictions were consistent with the Second Amendment’s sensitive places doctrine and that the events restriction was not unconstitutionally vague.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit affirmed the district court’s decision regarding the parks restriction, holding that the ordinance is constitutional in at least some applications, specifically as applied to preschools located within county parks. The court relied on Supreme Court dicta indicating that bans on firearms in schools are presumptively constitutional. However, the Fourth Circuit vacated the district court’s judgment regarding the events restriction, concluding that the plaintiffs lacked Article III standing to challenge it because they did not demonstrate a credible threat of prosecution or a concrete intention to violate the restriction. The case was remanded with instructions to dismiss the claims related to the events restriction without prejudice. View "Lafave v. County of Fairfax" on Justia Law

A 17-year-old defendant was charged with ten serious offenses, including murder and assault, after a violent confrontation at the home of his rivals. The incident stemmed from a feud with a classmate and escalated when the defendant, accompanied by his family, armed himself and attacked the victims’ home. The attack resulted in the death of one individual and severe injuries to others. The defendant, an enrolled member of the Cherokee Nation, was charged under federal law for crimes committed within the Cherokee Nation Indian Reservation.The United States District Court for the Eastern District of Oklahoma first reviewed the case. The government moved to transfer the defendant from juvenile to adult criminal proceedings under the Juvenile Justice and Delinquency Prevention Act. After an evidentiary hearing, the magistrate judge recommended granting the transfer, and the district court adopted this recommendation after conducting a de novo review. The district court weighed the statutory factors, including the defendant’s age, social background, psychological maturity, prior delinquency record, past treatment efforts, and the availability of rehabilitative programs, and found that most factors favored transfer to adult status.On interlocutory appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court did not abuse its discretion in weighing the statutory transfer factors and found no clear error in its factual findings. The court also rejected the defendant’s Eighth Amendment argument that transfer was unconstitutional due to the potential punishments, holding that the challenge was unripe under circuit precedent. The Tenth Circuit affirmed the district court’s order transferring the defendant to adult criminal proceedings. View "United States v. J.D.V., Jr." on Justia Law

A 16-year-old committed a violent home invasion, during which he raped, sodomized, and assaulted his former neighbor at knifepoint, then stole property from her home. He was convicted by a jury in 2002 of multiple counts, including forcible rape, oral copulation, sodomy, sexual battery, robbery, burglary, and related enhancements. His sentence was ultimately modified to a determinate term of 19 years, followed by a consecutive indeterminate term of 25 years to life, resulting in an effective sentence of 44 years to life.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d)(1)(A), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that, under equal protection principles as articulated in People v. Heard, he should be eligible for relief. The trial court denied the petition, finding that a 44-years-to-life sentence was not functionally equivalent to LWOP and thus did not qualify for resentencing under the statute.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which was developed in the Eighth Amendment context, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as required for equal protection claims. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those with lengthy term-of-years sentences that do not guarantee death in prison. The court affirmed the trial court’s denial of the petition, holding that section 1170(d)’s limitation to those sentenced to LWOP does not violate equal protection as applied to a juvenile nonhomicide offender sentenced to 44 years to life. View "People v. Baldwin" on Justia Law

A university revoked a student’s bachelor’s degree in social work after being informed by a state agency that, during her internship, she accessed confidential information in a state database without authorization. The university retroactively changed her grade for the internship course to failing, notified her that her degree and diploma were invalid, and initiated disciplinary proceedings. The student, who had already graduated and obtained a social work license, challenged the university’s actions, arguing that her procedural and substantive due process rights under the Fourteenth Amendment were violated.The United States District Court for the District of Idaho dismissed the student’s complaint for failure to state a claim. The court found that she did not have a protected property interest in her degree, grade, or the disciplinary process, and that, even if such an interest existed, the university provided adequate process. The court also concluded that she failed to plausibly allege that she was unable to pursue a career in social work, and held that the defendants were entitled to qualified immunity because any rights at issue were not clearly established.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the student’s university degree is a property interest protected by the Fourteenth Amendment and that the university failed to provide adequate process before revoking it. Specifically, the court found that the student plausibly alleged she was denied sufficient time to present her defense and was not allowed to cross-examine university-affiliated witnesses at her conduct hearing. The court reversed the district court’s dismissal of the procedural due process claim on these grounds and remanded for further proceedings. The court affirmed the dismissal of the substantive due process claim and the grant of qualified immunity to the defendants for monetary relief. The appeal of the denial of a preliminary injunction was dismissed as moot. View "DUDLEY V. BOISE STATE UNIVERSITY" on Justia Law

A group of Latino voters from Washington State’s Yakima Valley challenged the state’s legislative district map, arguing that the configuration of one district diluted their votes and denied them an equal opportunity to elect candidates of their choice, in violation of Section 2 of the Voting Rights Act. The state’s bipartisan redistricting commission had drawn the map following the 2020 Census, but the plaintiffs contended that the map “cracked” their community, undermining their voting power. After a bench trial, the United States District Court for the Western District of Washington agreed with the plaintiffs, enjoined the enacted map, and, when the commission declined to draw a new map, imposed its own remedial map.Three Yakima Valley voters, who had intervened in the district court, appealed. They challenged both the district court’s finding of a Section 2 violation and the remedial map, arguing that the new map violated the Equal Protection Clause and Section 2, and that the district court lacked jurisdiction because a three-judge panel was not convened.The United States Court of Appeals for the Ninth Circuit held that the district court had jurisdiction, ruling that 28 U.S.C. § 2284 requires a three-judge court only for constitutional, not statutory, challenges to legislative apportionment. The court found that the intervenors lacked standing to appeal the Section 2 liability finding and to challenge the remedial map under Section 2, as they failed to show traceable or redressable injuries or vote dilution. However, one intervenor had standing to bring an equal protection challenge to the remedial map.On the merits, the Ninth Circuit concluded that the remedial map did not constitute an unconstitutional racial gerrymander, as race was not the predominant factor in its design. The court dismissed the appeals for lack of jurisdiction except for the equal protection claim, which it affirmed, upholding the district court’s remedial map. View "PALMER V. TREVINO" on Justia Law

The plaintiff, a Nebraska resident, received Medicaid benefits administered by the Nebraska Department of Health and Human Services (NDHHS). In April 2024, she was sent a notice stating her Medicaid eligibility was ending due to income exceeding program standards. The notice informed her of her rights to request a conference or appeal and outlined the process for a fair hearing. She did not appeal the termination, and her coverage ended on May 1, 2024. Subsequently, she filed a federal lawsuit on behalf of herself and similarly situated individuals, alleging that the termination notices failed to meet due process requirements and seeking class certification, declaratory and injunctive relief, including reinstatement of benefits until proper notice was provided.The United States District Court for the District of Nebraska considered only her individual claims, as she did not challenge the court’s decision to exclude class claims on appeal. The district court denied her request for a temporary restraining order, finding she was unlikely to succeed because her claims sought retroactive relief barred by sovereign immunity and because the notices likely satisfied due process. The court then dismissed her complaint for lack of subject matter jurisdiction, concluding she had not alleged an ongoing violation of federal law and was not seeking prospective relief, as required to invoke the Ex parte Young exception to Eleventh Amendment immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The Eighth Circuit held that the plaintiff’s alleged due process violation was a discrete past event—the issuance of the notice and termination of benefits—not an ongoing violation. The court further held that the relief sought was retrospective, not prospective, and thus barred by the Eleventh Amendment. The court concluded that the Ex parte Young exception did not apply, and affirmed the dismissal. View "Filyaw v. Corsi" on Justia Law