Justia Constitutional Law Opinion Summaries
United States v. Lockridge
Daniel Lockridge, a decorated combat Marine, was involved in methamphetamine trafficking after returning to the U.S. in 2009. He initially used methamphetamine to manage his PTSD and later began selling it, eventually becoming a significant supplier in Chattanooga, Tennessee. Lockridge pleaded guilty to aiding and abetting possession with intent to distribute methamphetamine and was sentenced to 210 months in prison followed by three years of supervised release. His supervised release conditions included mandatory mental-health and substance-abuse treatment, as directed by a probation officer.The United States District Court for the Eastern District of Tennessee imposed these conditions, and Lockridge objected, arguing that the court must preauthorize any inpatient treatment and set a frequency for drug testing, rather than delegating these decisions to a probation officer. The district court overruled his objections, leading to Lockridge's appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not relinquish its authority by not specifying the details of the treatment programs at sentencing. Instead, it retained the discretion to make these decisions closer to the time of Lockridge's supervised release, allowing the probation officer to assess his needs and recommend appropriate treatment. The court emphasized that the ultimate authority to modify or enforce the conditions of supervised release remains with the district court, ensuring compliance with Article III of the U.S. Constitution.The Sixth Circuit affirmed the district court's decision, concluding that the delegation of certain responsibilities to the probation officer did not violate constitutional principles, as the district court retained the final decision-making authority. View "United States v. Lockridge" on Justia Law
Reyes v. City of New York
Plaintiff SeanPaul Reyes, who frequently posts videos of his interactions with police on YouTube, challenged a New York City Police Department (NYPD) policy that prohibits video recording inside police facilities. Reyes, who had been arrested twice for recording inside police stationhouses, argued that the policy violated his rights under the First Amendment and the New York State and New York City Right to Record Acts (RTRAs). He sought a preliminary injunction to prevent the City from enforcing the policy and to remove signs stating the policy.The United States District Court for the Southern District of New York granted Reyes a preliminary injunction based on his state and local law claims, despite finding that he was unlikely to succeed on his First Amendment claim. The court concluded that Reyes demonstrated a likelihood of success on the merits of his RTRAs claims, irreparable harm, and that the public interest favored an injunction.The City of New York appealed to the United States Court of Appeals for the Second Circuit, arguing that the district court erred in exercising supplemental jurisdiction over the state and local claims and in finding that Reyes met the requirements for a preliminary injunction. The Second Circuit found no abuse of discretion in the district court's exercise of supplemental jurisdiction or its determination of irreparable harm. However, the court noted that the resolution of whether Reyes is likely to succeed on the merits and whether the public interest favors an injunction depends on the interpretation of the RTRAs.Given the lack of clear guidance from New York courts on whether the RTRAs afford a right to record inside police stationhouses, the Second Circuit certified the following question to the New York Court of Appeals: Does either N.Y. Civ. Rights Law § 79-p or N.Y.C. Admin. Code § 14-189 afford individuals the right to video record law enforcement activities inside public facilities, specifically inside the publicly accessible lobbies of police stationhouses, notwithstanding the NYPD policy forbidding such recording? The decision on the appeal is reserved pending the response from the New York Court of Appeals. View "Reyes v. City of New York" on Justia Law
Jersey City United Against the New Ward Map v. Jersey City Ward Commission
The case involves a challenge to the ward map adopted by the Jersey City Ward Commission following the 2020 federal census. The Commission found a 59% population deviation between the most and least populous wards, which exceeded the maximum allowed by the Municipal Ward Law (MWL). The Commission created a new map with a 1.8% deviation and revised the boundaries of all six wards. Plaintiffs, including individuals and community organizations, argued that the new map failed to meet the MWL’s compactness requirement and violated equal protection principles under the New Jersey Constitution. They also claimed a violation of the New Jersey Civil Rights Act (NJCRA).The trial court concluded that the Commission’s map created sufficiently compact wards under the MWL and dismissed the plaintiffs’ statutory and constitutional claims. The Appellate Division reversed the dismissal of the MWL claims, remanding for factfinding on whether the Commission’s determination of compactness had a rational basis. It affirmed the dismissal of the equal protection and NJCRA claims.The New Jersey Supreme Court reviewed the case, focusing on the MWL, equal protection, and NJCRA claims. The Court held that the Commission’s map was a proper exercise of its discretion under the MWL. It found that the Commission was not required to use mathematical measures of compactness or consider communities of interest in its determination. The Court reversed the Appellate Division’s remand for additional factfinding, reinstating the trial court’s judgment on the MWL claim. The Court also affirmed the dismissal of the equal protection and NJCRA claims, concluding that the Commission’s compliance with the MWL negated the equal protection claim and that no statutory or constitutional violation occurred to support the NJCRA claim. View "Jersey City United Against the New Ward Map v. Jersey City Ward Commission" on Justia Law
Cabrera v. Commonwealth
In 2020, a police officer applied for a criminal complaint in the District Court, alleging that the defendant possessed a loaded firearm while intoxicated. A clerk-magistrate denied the application, finding no probable cause that the defendant had a firearm under his control inside a motor vehicle. No review of this decision was sought. Over two years later, the same officer filed a new application for the same offense with the same facts, and a different clerk-magistrate found probable cause and issued the complaint.The defendant filed a petition for extraordinary relief, arguing that the issuance of the complaint was barred by collateral estoppel and that the delay violated his due process rights. A single justice of the county court reserved and reported the petition to the full court.The Supreme Judicial Court of Massachusetts held that the principles of collateral estoppel did not bar the issuance of the complaint because the initial denial was not a final judgment. The court noted that a District Court determination of no probable cause is not conclusive and does not bar a subsequent indictment for the same offense. The court also found no due process violation, as the defendant did not have a constitutionally protected interest in the finality of a show cause determination, and the delay did not cause severe prejudice to the defendant's ability to mount a defense. The court remanded the case to the county court for entry of a judgment denying the defendant's petition for extraordinary relief. View "Cabrera v. Commonwealth" on Justia Law
BLACK EMERGENCY RESPONSE TEAM v. DRUMMOND
The case involves a challenge to Oklahoma's H.B. 1775, which prohibits mandatory gender or sexual diversity training and restricts the teaching of certain concepts related to race and sex in public schools and higher education institutions. Plaintiffs, including the Black Emergency Response Team and other organizations, argue that the law is unconstitutional under the First and Fourteenth Amendments, claiming it is vague, overbroad, and imposes viewpoint-based restrictions.The United States District Court for the Western District of Oklahoma reviewed the case and certified several questions of state law to the Oklahoma Supreme Court. The district court granted in part and denied in part motions from both plaintiffs and defendants, enjoining certain provisions of the law as unconstitutionally vague. Specifically, the court enjoined the enforcement of the second sentence of § 24-157(A)(1) and parts of § 24-157(B)(1).The Oklahoma Supreme Court addressed the certified questions, determining that the term "requirement" in § 24-157(A)(1) pertains only to orientation requirements and does not apply to classes, courses, or curricular speech. The court declined to answer the remaining certified questions related to § 24-157(B)(1), stating that the terms and phrases in question could be interpreted using their common, ordinary meanings and that the federal court could undertake this task. The court also noted that answering these questions would not avoid or alter the constitutional challenge to the statute and could result in an advisory opinion. View "BLACK EMERGENCY RESPONSE TEAM v. DRUMMOND" on Justia Law
DAMIANO V. GRANTS PASS SCHOOL DISTRICT NO. 7
Two plaintiffs, a middle school teacher and an assistant principal, were employed by a school district in Oregon. They created the "I Resolve" campaign, which included a website and a video uploaded to YouTube, advocating for policies on gender identity, parental rights, and education. They used their own devices and time but also sent emails from their school accounts to district employees with links to the campaign. Following complaints from employees, students, and concerned citizens, and an independent investigator's determination that they violated district policies, the district terminated them but later reinstated them and transferred them to other positions.The United States District Court for the District of Oregon granted summary judgment in favor of the school district and individual defendants on all claims. The plaintiffs alleged that their termination was in retaliation for their protected speech and that they were discriminated against based on their religion and viewpoint. The district court concluded that the defendants' interests in avoiding disruption outweighed the plaintiffs' First Amendment rights and that the individual defendants were entitled to qualified immunity.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed in part and vacated in part the district court's summary judgment. It held that there were genuine disputes regarding the circumstances of the plaintiffs' expressive conduct and the extent of the resulting disruption. The court affirmed the summary judgment for the individual defendants on the First Amendment claim for damages due to qualified immunity but vacated the summary judgment for the district on the First Amendment claim for damages and the related claims for declaratory and injunctive relief. The court also vacated the summary judgment on the plaintiffs' Fourteenth Amendment Equal Protection claim and the Title VII claim, finding genuine issues of material fact regarding the credibility of the district's proffered reasons for the terminations. View "DAMIANO V. GRANTS PASS SCHOOL DISTRICT NO. 7" on Justia Law
State of Maine v. Gleason
Rochelle Gleason was convicted of aggravated trafficking of a scheduled drug that caused the death of a person. In October 2021, Gleason communicated with the decedent about purchasing fentanyl and heroin. On October 16, 2021, the decedent bought drugs from Gleason, consumed them, and died of acute intoxication from fentanyl and kratom. The Maine Office of the Chief Medical Examiner sent a blood sample to a lab, where several employees conducted tests. A forensic toxicologist, Chelsea Deisher, reviewed the data and documentation and developed a toxicology report indicating the presence of fentanyl and kratom in the decedent’s blood.The State charged Gleason on September 28, 2022, and she pleaded not guilty. During the trial, Deisher testified about the test results, although she did not conduct the tests herself. Gleason objected, arguing that her Sixth Amendment right to confront the witnesses against her was violated because she could not cross-examine the actual testers. The trial court allowed Deisher’s testimony, and the jury found Gleason guilty. She was sentenced to eighteen years in prison, with all but eight years suspended, and four years of probation. Gleason appealed the conviction.The Maine Supreme Judicial Court reviewed the case, focusing on the Confrontation Clause issue. The court noted that the U.S. Supreme Court’s decision in Smith v. Arizona, issued during the appeal, rejected the rationale that allowed experts to testify based on out-of-court statements not admitted for their truth. The court found that Deisher’s testimony relied on the truth of the data and documentation generated by others, which Gleason could not cross-examine. The court vacated the judgment and remanded the case for a new trial to determine whether the statements relied upon by Deisher were testimonial. View "State of Maine v. Gleason" on Justia Law
Al-Baluchi v. Hegseth
Ammar al-Baluchi, a Pakistani national, has been detained at the U.S. naval base in Guantánamo Bay since 2006. He is accused of supporting the September 11, 2001, attacks as a senior member of al-Qaeda. In 2008, al-Baluchi filed a habeas corpus petition in federal district court. In 2022, he moved to compel the government to convene a Mixed Medical Commission to assess his eligibility for repatriation due to alleged torture and resulting serious health issues. The district court denied his request, ruling that detainees captured during non-international armed conflicts are not entitled to such examinations under the Third Geneva Convention or Army Regulation 190-8.The United States District Court for the District of Columbia initially stayed al-Baluchi’s habeas case pending the outcome of his military commission trial. After temporarily lifting the stay to consider his motion for a Mixed Medical Commission, the court denied the motion, leading al-Baluchi to appeal the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court determined that it lacked jurisdiction to review the district court’s nonfinal order. The court found that al-Baluchi did not demonstrate that the denial of his motion had the practical effect of denying injunctive relief or that it caused serious or irreparable harm requiring immediate review. The court noted that even if a Mixed Medical Commission found al-Baluchi eligible for repatriation, the government retained discretion to delay repatriation until the completion of his military commission proceedings. Consequently, the appeal was dismissed for lack of jurisdiction. View "Al-Baluchi v. Hegseth" on Justia Law
Commonwealth v. Hunte
The case involves a facial constitutional challenge to Section 3755 of the Pennsylvania Vehicle Code, which authorizes warrantless blood draws from individuals requiring emergency medical treatment after a motor vehicle accident if there is probable cause to suspect DUI. Larry Wardell Hunte was involved in a serious car accident, and while unconscious at the hospital, a state trooper requested a blood draw under Section 3755, which revealed the presence of alcohol and controlled substances. Hunte was charged with multiple offenses, including homicide by vehicle while DUI.The Cumberland County Court of Common Pleas found Section 3755 unconstitutional, holding that it violated the Fourth Amendment and Article I, Section 8 of the Pennsylvania Constitution. The court reasoned that the statute authorized warrantless searches without any recognized exception to the warrant requirement, such as exigent circumstances or voluntary consent.The Supreme Court of Pennsylvania affirmed the lower court's decision. The court held that Section 3755 is facially unconstitutional because it mandates warrantless blood draws based solely on probable cause, without requiring a search warrant or demonstrating any exception to the warrant requirement. The court emphasized that the Fourth Amendment requires a warrant for such searches unless a valid exception applies, and statutory "implied consent" does not constitute such an exception. The court also rejected arguments that the statute could be applied constitutionally in certain circumstances, such as when a warrant is later obtained or exigent circumstances are present, noting that these scenarios do not involve actual applications of the statute. The court concluded that Section 3755 violates both the Fourth Amendment and the Pennsylvania Constitution. View "Commonwealth v. Hunte" on Justia Law
Posted in:
Constitutional Law, Supreme Court of Pennsylvania
Kratovil v. City of New Brunswick
A journalist, Charles Kratovil, learned through a records request that Anthony Caputo, the New Brunswick Police Director, had a voting address in Cape May. Kratovil, editor of New Brunswick Today, began investigating Caputo's residence, suggesting it was too far from New Brunswick for him to effectively perform his duties. After disclosing Caputo's address to local officials, Caputo informed Kratovil that he was protected under Daniel’s Law and requested that Kratovil refrain from republishing his exact home address. Kratovil then filed a lawsuit seeking declaratory and injunctive relief, claiming that Daniel’s Law violated his constitutional rights to freedom of speech and the press.The trial court dismissed Kratovil’s complaint, ruling that while Kratovil could publish that Caputo lived in Cape May, he could not publish Caputo’s precise home address. The court found that Daniel’s Law was narrowly tailored to serve a state interest of the highest order. The Appellate Division affirmed this decision, agreeing that the statute did not violate constitutional guarantees and that it was narrowly tailored to protect public officials.The Supreme Court of New Jersey reviewed the case, applying First Amendment principles from Smith v. Daily Mail Publishing Co. and Florida Star v. B.J.F. The Court held that Caputo’s home address was truthful information, lawfully obtained, and related to a matter of public concern. The Court agreed that Daniel’s Law served a state interest of the highest order and was narrowly tailored to achieve that interest. The Court affirmed the Appellate Division’s judgment as modified, concluding that Daniel’s Law did not violate constitutional protections of free speech and the press. View "Kratovil v. City of New Brunswick" on Justia Law
Posted in:
Constitutional Law, Supreme Court of New Jersey