Justia Constitutional Law Opinion Summaries

Gregory Gliner, a dual citizen of the United Kingdom and the United States, sought to identify the anonymous operator of the PoliticalLore.com website and the pseudonymous author of an allegedly defamatory article published on the website. Gliner intended to use this information for a defamation lawsuit in the United Kingdom. He filed an ex parte application under 28 U.S.C. § 1782 to obtain discovery from Dynadot, Inc., a California-based company that provided domain registration and privacy protection services for the website.The United States District Court for the Northern District of California denied Gliner’s application, citing the First Amendment interests of the website operator and the article author. The court did not make any relevant factual findings and did not address the statutory requirements or the Intel factors for granting discovery under § 1782. Gliner subsequently filed a motion to alter or amend the judgment, which the district court also denied.The United States Court of Appeals for the Ninth Circuit reviewed the case and found that the district court abused its discretion. The appellate court held that the First Amendment protections cited by the district court did not apply because there was no evidence that the website operator or the article author were U.S. citizens or present in the United States. Additionally, the court found no indication that the website had a U.S. audience whose First Amendment rights might be implicated. The Ninth Circuit vacated the district court’s order and remanded the case for further consideration of the § 1782 statutory factors and the Intel factors. The district court was instructed to allow Dynadot and any affected parties to contest the subpoenas if issued. View "IN RE EX PARTE APPLICATION OF GLINER" on Justia Law

Clifton Thomas was convicted of two counts of aggravated trafficking of scheduled drugs and one count of criminal forfeiture of property. The charges stemmed from a search of an apartment where Thomas was staying, which uncovered drugs, drug paraphernalia, and a firearm. The search was conducted pursuant to a warrant obtained after Thomas was involved in a domestic violence incident. Thomas challenged the search, arguing that the warrant lacked probable cause for drug-related items and that the evidence was not in plain view.The trial court denied Thomas's motions to suppress the evidence, finding that the search warrant was valid for firearms and a cell phone, and that the drugs were discovered in plain view during a lawful search. The court also denied Thomas's discovery motions regarding missing surveillance video, cell phones, and a coat, concluding that the State did not act in bad faith and that the evidence did not have apparent exculpatory value. Additionally, the court allowed a new chemist to testify about the drug analysis, despite the original chemist not testifying.The Maine Supreme Judicial Court reviewed the case and found that Thomas's confrontation rights were violated by the admission of the new chemist's testimony, which relied on the original chemist's notes and data. The court determined that this violation was not harmless, as the chemist's testimony was crucial to establishing the weight of the drugs, a key element of the charges. Consequently, the court vacated Thomas's conviction and remanded the case for further proceedings. View "State of Maine v. Thomas" on Justia Law

Ammon Edward Bundy was convicted of misdemeanor criminal trespass and misdemeanor resisting and obstructing in two separate cases. In the first case, Bundy was observing a committee meeting at the Idaho State Capitol when the meeting was moved due to a disturbance. The Speaker of the House ordered the Lincoln Auditorium to be cleared, but Bundy refused to leave. He was arrested after going limp and requiring troopers to carry him out. In the second case, Bundy returned to the Capitol the day after his arrest, despite receiving a trespass notice prohibiting him from entering the public areas of the Capitol for one year. He was arrested twice on the same day for entering the building and refusing to leave.The district court affirmed Bundy’s convictions in both cases. The court found that Idaho’s criminal trespass statute was not ambiguous and applied to both public and private property. It also determined that the statute was not unconstitutionally vague or overbroad as applied to Bundy’s conduct. The court rejected Bundy’s arguments that the Speaker of the House and the Director of the Department of Administration had unbridled discretion to revoke access to the Capitol. The court also held that Bundy’s arrest was lawful, and his passive resistance did not provide a defense to the charge of resisting and obstructing.The Idaho Supreme Court reviewed the case and affirmed the district court’s decisions. The Court held that the criminal trespass statute provided adequate notice to Bundy that his conduct was prohibited and did not grant unbridled discretion to law enforcement or other state actors. The Court also found that the trespass notice was clear and not unconstitutionally vague or overbroad. Finally, the Court held that Bundy’s arrests were lawful, and his convictions for resisting and obstructing were supported by substantial evidence. View "State v. Bundy" on Justia Law

In March 2016, thirteen-year-old J.R. Gustafson was accidentally shot and killed by his fourteen-year-old friend at a residence in Mt. Pleasant, Pennsylvania. J.R.'s parents, Mark and Leah Gustafson, filed a lawsuit against Springfield Armory, the manufacturer of the firearm, and Saloom Department Store, the retailer that sold the firearm. They alleged defective design, negligent design and sale, and negligent warnings and marketing. The trial court dismissed the complaint with prejudice, citing the Protection of Lawful Commerce in Arms Act (PLCAA), which bars certain civil actions against firearms manufacturers and sellers.The Gustafsons appealed, and the Superior Court reversed the trial court's decision, remanding the case for further proceedings. The Superior Court's en banc panel issued a per curiam order, with no single rationale garnering majority support. Some judges found the PLCAA barred the claims but was unconstitutional, while others found the PLCAA did not bar the claims or was constitutional. The Superior Court's order was challenged, leading to the current appeal.The Supreme Court of Pennsylvania reviewed the case and determined that the PLCAA barred the Gustafsons' action. The court found that the action constituted a "qualified civil liability action" under the PLCAA, as it was a civil action against a manufacturer and seller of a qualified product for damages resulting from the criminal or unlawful misuse of a firearm. The court also concluded that the product liability exception did not apply because the discharge of the firearm was caused by a volitional act that constituted a criminal offense.The court further held that the PLCAA was a valid exercise of Congress's Commerce Clause authority and did not violate the Tenth Amendment or principles of federalism. Consequently, the Supreme Court of Pennsylvania vacated the Superior Court's order and remanded the case for reinstatement of the trial court's dismissal of the Gustafsons' complaint. View "Gustafson v. Springfield, Inc." on Justia Law

During the COVID-19 pandemic, Apple Studios LLC offered Brent Sexton a film role on the condition that he get vaccinated. Sexton refused vaccination and sued Apple when it withdrew its offer and cast a different actor. Apple filed an anti-SLAPP motion, arguing that its casting decision was protected activity in furtherance of free speech on public issues, including the vaccination controversy and the portrayal of a historical figure. The trial court denied Apple’s motion, finding that Apple’s interest in mandatory vaccination was not compelling and that Sexton had shown a probability of prevailing on his claims.The Superior Court of Los Angeles County denied Apple’s anti-SLAPP motion, concluding that while Apple’s casting decision was protected activity, Sexton had demonstrated minimal merit in his claims. The court found that Apple’s interest in mandatory vaccination was not compelling and that Sexton had provided sufficient evidence to show he was qualified for the role with daily COVID-19 testing.The California Court of Appeal, Second Appellate District, Division Eight, reversed the trial court’s decision. The appellate court held that Apple’s casting decision was protected activity under the anti-SLAPP statute because it contributed to public discourse on vaccination policy and the portrayal of a historical figure. The court found that Sexton’s privacy claim failed because he had no reasonable expectation of privacy, and his discrimination claims failed because he was unqualified for the job due to his refusal to get vaccinated. The court granted Apple’s request for judicial notice and remanded the case for entry of judgment in favor of Apple and for a determination of the fees and costs owed by Sexton to Apple. View "Sexton v. Apple Studios LLC" on Justia Law

The case involves the State of Alaska's statutes that allow local school districts to operate correspondence study programs and provide public funds for educational expenses. Parents of public school students sued the State, arguing that these statutes violated the Alaska Constitution by allowing public funds to be used for private school tuition, which they claimed was unconstitutional.The Superior Court of Alaska ruled that the statutes were facially unconstitutional and invalidated them entirely. The court did not address the narrower question of whether the statutes were unconstitutional when applied to allow public funds to be used for private school tuition. The decision was appealed to the Supreme Court of Alaska.The Supreme Court of Alaska reviewed the case and determined that the Superior Court's ruling went too far. The Supreme Court noted that the statutes allowed for a substantial number of constitutionally valid uses of allotment funds, such as purchasing books, supplies, and other educational materials. The court emphasized that even if using allotment funds for private school tuition were unconstitutional, it would not justify invalidating the entire statutes.The Supreme Court vacated the Superior Court's judgment and remanded the case for further proceedings. The court instructed that the proper parties must be joined, and the Superior Court must first determine whether the statutes actually permit the use of allotment funds for private school tuition before addressing the constitutionality of such use. The Supreme Court did not decide whether using allotment funds for private school tuition is constitutional, leaving that question open for further consideration. View "State of Alaska, Dept. of Education & Early Development v. Alexander" on Justia Law

A group of foster children challenged the Office of Children’s Services (OCS) for using their federal Social Security benefits to reimburse itself for foster care costs. The children claimed this practice violated their due process and equal protection rights under the Alaska Constitution and sought restitution. The Superior Court of Alaska found a due process violation and ordered OCS to notify foster children about its practice regarding Social Security benefits. However, the court rejected the equal protection and restitution claims, deeming them preempted by federal law.The Superior Court held that OCS violated due process by not informing foster children about their Social Security benefits and the potential financial advantages of having a private representative payee. The court ordered OCS to provide notices explaining the concept of a representative payee, the consequences of OCS being the payee, and the possibility of proposing an alternative payee. OCS argued that complying with the notice order would violate federal privacy laws, but the court modified its order to address these concerns.The Supreme Court of Alaska reviewed the case and affirmed the Superior Court’s conclusions. The Supreme Court held that the due process claim and the court’s notice order were not preempted by federal law. The court determined that foster children have a property interest in knowing about their Social Security benefits and the ability to nominate a private payee. The court found that OCS’s systematic practice of using benefits to reimburse itself without notice created a high risk of depriving children of their rights.The Supreme Court also held that the equal protection claim was preempted because it would conflict with federal regulations governing the use of Social Security benefits. The court concluded that OCS’s practice of using benefits for foster care costs was permissible under federal law. Finally, the court rejected the proposed remedies of disgorgement and creating a trust, as they would constitute impermissible attachments on federal benefits and were preempted by federal law. View "State of Alaska, Department of Health and Social Services v. Z. C." on Justia Law

Giovani Fuster Melendez moved from Puerto Rico to Arizona in 2017 and became acquainted with the victim, A.G., through a church connection. In 2019, Melendez returned to his former apartment complex, encountered A.G., and fired multiple shots at him, missing each time. Melendez was taken into custody shortly after the incident. During his police interview, he was read his Miranda rights twice and initially chose not to speak. However, in a subsequent interview, he deferred answering some questions but eventually confessed to the shooting, claiming self-defense.The Superior Court in Maricopa County convicted Melendez of aggravated assault and five counts of endangerment, sentencing him to concurrent prison terms. On appeal, the Arizona Court of Appeals found that the State's references to Melendez's selective silence during his police interview violated his constitutional rights, constituting fundamental prejudicial error.The Arizona Supreme Court reviewed the case to determine if the State violated Melendez's due process rights by commenting on his post-Miranda statements and temporary deferrals during the trial. The Court held that the State could use a defendant’s post-Miranda statements and temporary deferrals for impeachment purposes if the defendant did not unambiguously invoke his Miranda rights and ultimately spoke on the substantive matters. The Court concluded that Melendez did not unequivocally invoke his right to remain silent and that his deferrals were tactical rather than an invocation of his rights. Therefore, the prosecutor's comments did not violate Melendez's due process rights. The Arizona Supreme Court affirmed Melendez's convictions and sentences and vacated the Court of Appeals' opinion. View "STATE OF ARIZONA v MELENDEZ" on Justia Law

Faytima Howard failed to pay her property taxes, leading Macomb County, Michigan, to seize and sell her property in 2023. Howard sued, claiming the county violated the Takings Clause of the Fifth Amendment by keeping proceeds exceeding her tax debt. Previously, Michigan's foreclosure regime was found unconstitutional for not compensating property owners for the surplus from foreclosure sales. However, Michigan amended its law in 2020 to allow property owners to claim any surplus value from foreclosed properties. Howard did not utilize this process.The United States District Court for the Eastern District of Michigan dismissed Howard's complaint for failure to state a claim. The court noted that Michigan's amended law provided a procedure for property owners to claim surplus proceeds, which Howard did not follow. The district court concluded that because Howard did not take advantage of the process, her claim was invalid.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Michigan's procedure for claiming surplus proceeds from foreclosure sales complies with the Takings Clause, as it provides property owners with a reasonable opportunity to claim any surplus. The court distinguished this case from others where no such process was available, emphasizing that Howard's failure to follow the state procedure meant no taking occurred. The court also rejected Howard's arguments that the process was overly burdensome and that the lack of interest and attorney's fees constituted a taking. The court concluded that Michigan's procedures are constitutionally sound and do not violate the Fifth Amendment. View "Howard v. Macomb Cnty., Mich." on Justia Law

Fathiree Ali, a Muslim inmate, requested the Michigan Department of Corrections to provide him with a halal diet, which is required by his religion. The prison chaplain directed him to apply for the vegan meal option, but another official rejected his application after discovering that Ali had purchased over one hundred non-halal items from the prison commissary. Ali then sued the chaplain, the special activities coordinator, the warden, and the Michigan Department of Corrections under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the Free Exercise Clause, and 42 U.S.C. § 1983.The United States District Court for the Western District of Michigan dismissed Ali’s claims against the Department of Corrections and granted summary judgment in favor of the officials. Ali appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and dismissed Ali’s appeal in part for lack of jurisdiction and affirmed the rest of the district court’s decision. The court held that RLUIPA does not authorize money-damages claims against officials sued in their official or individual capacities. The court also found that Ali’s claims for injunctive relief against the chaplain and warden were moot because they no longer had the power to adjust his meal plan after his transfer to a different prison. Additionally, the court held that Ali’s claim for injunctive relief against the special activities coordinator was moot because the coordinator no longer worked for the Department of Corrections.The court concluded that Ali did not have a cognizable claim for injunctive or declaratory relief under RLUIPA because he had alternatives to access halal meat and could reapply for the vegan meal plan. The court also found that Ali failed to state a claim against the Michigan Department of Corrections as he did not identify a policy that violated RLUIPA. Finally, the court held that the officials were entitled to qualified immunity on Ali’s Free Exercise Clause claims under § 1983. View "Ali v. Adamson" on Justia Law