Justia Constitutional Law Opinion Summaries

A mobilehome park owner challenged the constitutionality of a California statute that limits annual rent increases for certain mobilehome parks located within the jurisdictions of two or more incorporated cities. The owner argued that the statute is facially unconstitutional because it lacks a procedural mechanism allowing property owners to seek rent increases above the statutory cap to ensure a fair return, which the owner claimed is required by the California and U.S. Constitutions. The owner asserted that the absence of such a mechanism results in a violation of due process, equal protection, and the prohibition against uncompensated takings.The Superior Court of Orange County granted the owner’s motion for judgment on the pleadings, finding that the statute’s failure to provide a process for seeking exceptions to the rent cap violated due process and rendered the statute unconstitutional. The court rejected the owner’s takings argument but concluded that the legal issue was dispositive and denied the State’s request for leave to amend its answer. Judgment was entered in favor of the owner, and the State appealed.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court held that the owner failed to establish that the statute is facially unconstitutional, as the relevant legal precedents do not require a fair return adjustment mechanism in every rent control law. The court also found that the State’s general denial in its answer placed the owner’s standing at issue, precluding judgment on the pleadings. The court reversed the judgment of the trial court, holding that the absence of a fair return adjustment mechanism does not, by itself, render the statute facially unconstitutional, and that the State’s answer raised material issues that should have prevented judgment on the pleadings. View "Anaheim Mobile Estates v. State" on Justia Law

The defendant was previously convicted of transporting child pornography and, after serving most of his sentence, was released to a halfway house. While there, he engaged in a series of text conversations with his preteen daughter, asking her about his past conviction, her views on sex, and whether she thought there was anything wrong with adults or children engaging in sexual acts, as depicted in pictures or videos. He also instructed her to keep their conversations secret. The defendant’s ex-sister-in-law, who had access to the daughter's phone records, became concerned and forwarded the messages to the FBI. A subsequent investigation of the defendant’s phone, despite his attempts to delete its contents, revealed incriminating text messages, bookmarks to websites with suggestive titles, and 163 images sexualizing children, seven of which were alleged to be child pornography.The United States District Court for the Eastern District of Michigan denied the defendant’s pretrial motions to exclude most of the images and the website bookmarks, finding them relevant to knowledge and intent. The court also denied his motion to dismiss the indictment on First Amendment grounds. At trial, the government presented evidence including the images, text messages, and testimony from the investigating agent and the ex-sister-in-law. The defendant argued that others at the halfway house could have accessed his phone and that he only sought “child erotica,” not child pornography. The jury found him guilty of knowing receipt of child pornography and specifically found the seven images met the statutory definition.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the sufficiency of the evidence de novo and held that a rational jury could find the images constituted child pornography. The court also found no error in admitting the website bookmarks or the text messages with the defendant’s daughter, as they were relevant to intent and not unfairly prejudicial. The court rejected both facial and as-applied First Amendment challenges to the statute. The conviction was affirmed. View "United States v. Mercer-Kinser" on Justia Law

A woman from El Salvador, after her husband fled to the United States due to gang threats, was subjected to repeated extortion and threats of violence, including sexual extortion, by gang members who targeted her because she was a woman living alone with her children. Despite seeking help from local police, she was told to comply with the gang or flee. After enduring escalating threats and payments, she eventually fled to the United States with her children.Upon arrival, she retained an attorney to represent her in her asylum proceedings. She informed her attorney of both the financial and sexual extortion she faced, but he failed to include the sexual extortion in her application and proposed a legal theory for asylum based on a particular social group (PSG) that was foreclosed by existing precedent. The immigration judge, sitting in the Immigration Court, found the proposed PSG not cognizable and denied her claim, concluding the gang’s motivation was financial rather than based on group membership. The Board of Immigration Appeals affirmed, adopting the immigration judge’s reasoning and denying her appeal.Represented by new counsel, she moved to reopen her case before the Board of Immigration Appeals, arguing ineffective assistance of counsel (IAC) and proposing alternative, plausible PSGs. The Board denied the motion, finding no IAC and concluding her harm was not due to a protected characteristic. She then petitioned the United States Court of Appeals for the Fourth Circuit for review.The Fourth Circuit held that noncitizens who retain counsel in removal proceedings have a Fifth Amendment right to a fundamentally fair hearing, which can be violated by ineffective assistance of counsel. The court found her original attorney’s performance objectively unreasonable and prejudicial, as alternative PSGs could have led to a different outcome. The court granted the petition for review, reversed the Board’s denial of her motion to reopen, vacated the denial of her asylum and withholding claims, and remanded for a new hearing. View "Guandique-De Romero v. Bondi" on Justia Law

A federal inmate diagnosed with diabetes was initially prescribed medication and given certain accommodations while incarcerated. After being transferred to a new facility, his new medical provider discontinued his diabetes medication and accommodations based on a single blood test result, despite the inmate’s objections that the result was not representative of his condition. The inmate’s health deteriorated, leading to severe diabetic ulcers and ultimately the amputation of his toe. He alleged that medical staff repeatedly denied or delayed necessary care, and that his requests for treatment were falsely documented as refusals. The inmate later filed administrative claims with the Bureau of Prisons (BOP) and, after those were denied or not fully addressed, brought suit alleging deliberate indifference to his medical needs under the Eighth Amendment and also asserted a claim under the Rehabilitation Act.The United States District Court for the District of New Jersey screened the complaint and dismissed the Rehabilitation Act claim. The defendants moved to dismiss the Eighth Amendment claim brought under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics. The District Court granted the motion, reasoning that the case presented a new context from prior Supreme Court precedent because the injuries were not fatal and that the existence of the BOP’s administrative remedy program was a special factor counseling against extending Bivens. The inmate appealed.The United States Court of Appeals for the Third Circuit affirmed. The court held that the availability of the BOP’s administrative remedy program constituted a special factor not present in Carlson v. Green, and thus created a new context under the Bivens analysis. Because an alternative remedial structure existed and was available to the inmate, the court declined to extend a Bivens remedy. The court also affirmed dismissal of the Rehabilitation Act claim, as sovereign immunity barred damages claims against the federal government under that statute. View "Muniz v. United States" on Justia Law

A man living with his partner and her two young children in Indiana was convicted of murdering the children and setting fire to their home. Prior to the incident, he exhibited suspicious behavior, including quitting his job, withdrawing his savings, and making threatening statements. On the night of the crime, he bound one child, gathered belongings, and fled the state. The children’s bodies were found after the house fire, and he was apprehended in Kentucky following a police chase. After being read his rights in the hospital, he gave a brief, largely uninformative statement to police.He was charged with two counts of murder and arson. At trial, the jury found him guilty and recommended the death penalty, which the judge imposed. During the trial, a juror brought a note and cookies from his wife, referencing the victims, but the court found this did not prejudice the jury after questioning them and dismissed the juror. The Indiana Supreme Court affirmed the convictions and sentence. The defendant then sought postconviction relief in Indiana state court, arguing ineffective assistance of counsel, but the trial court denied relief, and the Indiana Supreme Court affirmed, with some justices partially dissenting on the prejudice issue.The defendant filed a federal habeas petition in the United States District Court for the Southern District of Indiana, raising over 30 claims, including ineffective assistance of counsel, juror bias, and evidentiary issues. The district court denied most claims as procedurally defaulted and found the rest without merit, also denying requests for stays and additional funding. On appeal, the United States Court of Appeals for the Seventh Circuit held that most claims were procedurally defaulted, the district court did not abuse its discretion in denying stays or funding, and the Indiana Supreme Court’s decisions were neither unreasonable applications of federal law nor based on unreasonable factual determinations. The Seventh Circuit affirmed the district court’s denial of habeas relief and related motions. View "Weisheit v Neal" on Justia Law

A firefighter in Forrest City, Arkansas, was terminated after posting a provocative anti-abortion image on his personal Facebook page. The image, intended to express his pro-life views, was interpreted by some as racially insensitive, particularly because it included the caption “I can’t breathe!”—a phrase associated with protests following George Floyd’s death. After complaints from a retired fire supervisor and others, the firefighter deleted the post. However, the mayor placed him on administrative leave and, following a brief investigation, fired him, citing the public outcry and concerns about the city’s ability to provide public services. The firefighter, who had served over four years without prior incident, learned of his termination through a press release.The firefighter filed suit in the United States District Court for the Eastern District of Arkansas, alleging First Amendment retaliation against the mayor in both his individual and official capacities, and against the city for an alleged unwritten policy allowing officials to censor employee speech. The district court granted summary judgment for the defendants, holding that the mayor was entitled to qualified immunity and that there was no evidence of an unwritten policy justifying the official-capacity and policy-based claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the firefighter’s Facebook post addressed a matter of public concern and was made as a private citizen. The court found insufficient evidence of actual or reasonably predicted disruption to the fire department’s operations to justify summary judgment for the defendants. The court reversed the district court’s grant of summary judgment on the First Amendment retaliation claims against the mayor and the city, affirmed the dismissal of the unbridled-discretion claim, and remanded for further proceedings. View "Melton v. City of Forrest City, Arkansas" on Justia Law

The case concerns the executive branch’s decision to freeze foreign aid funds that Congress had appropriated for fiscal year 2024. On January 20, 2025, the President issued an executive order directing the State Department and USAID to pause foreign assistance spending, pending a review of those programs. This led to the suspension or termination of thousands of grant awards and significant restructuring within the agencies. Organizations that were recipients of these funds, many of which relied heavily on such funding, challenged the executive order, arguing that the freeze unlawfully impounded funds that Congress had directed to be spent.The United States District Court for the District of Columbia initially granted a temporary restraining order, and later a preliminary injunction, against the executive branch (excluding the President personally). The district court found that the plaintiffs had standing due to financial harm, and that they were likely to succeed on their claims that the executive branch’s actions violated the separation of powers, the Take Care Clause, the Impoundment Control Act (ICA), the Anti-Deficiency Act, and the Administrative Procedure Act (APA). The court ordered the government to make available the full amount of appropriated funds.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and vacated the district court’s preliminary injunction. The appellate court held that the plaintiffs lacked a cause of action to pursue their claims. Specifically, it found that the plaintiffs could not bring a freestanding constitutional claim when the alleged violations were statutory in nature, that the ICA precludes APA review by private parties (reserving enforcement to the Comptroller General), and that the plaintiffs could not reframe their claims as ultra vires actions. The court concluded that, although the plaintiffs had standing, they were not entitled to the preliminary injunction because they were unlikely to succeed on the merits. View "Global Health Council v. Trump" on Justia Law

The case concerns a man convicted in New York state court of attempted second-degree murder, attempted first-degree robbery, and criminal possession of a weapon, following an incident in which he attempted to rob a man and then fired at both the intended victim and responding police officers. During jury selection, the prosecution used peremptory challenges to strike several Black prospective jurors. Defense counsel objected, arguing that these strikes were racially discriminatory under Batson v. Kentucky. The trial court appeared to agree that two of the strikes violated Batson, but due to an administrative error, the dismissed jurors could not be recalled. Defense counsel did not object to the lack of a Batson remedy, and the trial proceeded with the selected jury.On direct appeal, the Appellate Division of the New York Supreme Court found that the Batson claim was unpreserved for appellate review because defense counsel had not objected to the absence of a remedy at trial. The court also rejected the argument that counsel was constitutionally ineffective. The New York Court of Appeals denied leave to appeal.The petitioner then sought federal habeas relief in the United States District Court for the Eastern District of New York, arguing that his counsel’s failure to seek a Batson remedy constituted ineffective assistance. The district court denied the petition, holding that the claim was procedurally defaulted and that counsel’s performance was not constitutionally deficient.The United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The court held that the petitioner failed to show ineffective assistance of counsel because he did not meet his burden of demonstrating that his trial counsel lacked strategic reasons for not seeking a Batson remedy. The court declined to require defense counsel to pursue Batson remedies at the expense of their client’s strategic interests. The judgment denying habeas relief was affirmed. View "Carew v. Morton" on Justia Law

Shareholders of Fannie Mae and Freddie Mac, acting derivatively on behalf of these entities, challenged the federal government’s actions following the 2008 financial crisis. After the housing market collapse, Congress passed the Housing and Economic Recovery Act of 2008 (HERA), creating the Federal Housing Finance Agency (FHFA) and authorizing it to act as conservator for the Enterprises. The FHFA placed both entities into conservatorship, and the U.S. Treasury entered into agreements to provide financial support in exchange for senior preferred stock and other rights. In 2012, a “net worth sweep” was implemented, redirecting nearly all profits from the Enterprises to the Treasury, effectively eliminating dividends for other shareholders. The plaintiffs, as preferred shareholders, alleged that this arrangement constituted an unconstitutional taking under the Fifth Amendment.The United States Court of Federal Claims previously reviewed the case and granted the government’s motion to dismiss. The Claims Court relied on the Federal Circuit’s prior decision in Fairholme Funds, Inc. v. United States, which held that, under HERA, the Enterprises lost any cognizable property interest necessary to support a takings claim because the FHFA, as conservator, had broad authority over the Enterprises’ assets. The Claims Court found the plaintiffs’ claims indistinguishable from those in Fairholme and dismissed them accordingly.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the dismissal de novo. The court affirmed the Claims Court’s decision, holding that claim preclusion barred the plaintiffs’ derivative takings claims because the issues had already been litigated in Fairholme. The court rejected arguments that the prior representation was inadequate or that the Supreme Court’s subsequent decision in Tyler v. Hennepin County fundamentally changed takings law. The Federal Circuit concluded that Fairholme remained binding precedent and affirmed the dismissal. View "FISHER v. US " on Justia Law

After Hurricane Harvey caused significant flooding at the Arbor Court apartment complex in Houston in 2017, the property’s owner, DM Arbor Court, Limited (DMAC), sought permits from the City of Houston to repair the damage. The City denied these permits, invoking a provision of its flood control ordinance that had not previously been used for such denials. The City determined that a majority of the complex’s buildings had sustained “substantial damage,” requiring costly elevation before repairs could proceed. As a result, DMAC was unable to repair or redevelop the property, which led to the loss of tenants and the property sitting idle.DMAC filed suit in the United States District Court for the Southern District of Texas, alleging that the City’s denial of repair permits constituted an unconstitutional taking under the Fifth Amendment. The district court dismissed the case as unripe, but the United States Court of Appeals for the Fifth Circuit reversed, finding the case ripe once the City’s Director of Public Works formally denied the permit application. On remand, after a bench trial, the district court rejected DMAC’s takings claim, concluding that the property retained some economic value and that DMAC was not deprived of all economically beneficial use. The court also found that the City’s actions were justified under the Penn Central framework, emphasizing the public interest in flood management.On appeal, the United States Court of Appeals for the Fifth Circuit held that the City’s denial of the repair permit deprived DMAC of all economically viable use of Arbor Court, constituting a categorical taking under Lucas v. South Carolina Coastal Council, 505 U.S. 1003 (1992). The Fifth Circuit reversed the district court’s judgment and remanded the case for further proceedings, holding that the City’s regulatory action amounted to a per se taking requiring just compensation. View "DM Arbor Court v. City of Houston" on Justia Law