Justia Constitutional Law Opinion Summaries

The plaintiff claimed that Michigan had taken custody of between $200 and $600 in unclaimed property belonging to her. She alleged that, under Michigan’s Uniform Unclaimed Property Act, the state would return her property if she requested it but would not pay her any interest earned while the property was in the state’s custody, unless the property was originally interest bearing. Without first submitting a claim to reclaim her property, she brought a suit under 42 U.S.C. § 1983 against officials responsible for Michigan’s unclaimed property program, arguing that the state’s failure to pay interest amounted to an unconstitutional taking in violation of the Fifth Amendment. She sought declaratory and injunctive relief on behalf of herself and a putative class.The United States District Court for the Eastern District of Michigan dismissed her case, concluding that she lacked Article III standing because Michigan law did not grant her a property right to interest earned on her unclaimed property. The district court reasoned that, without such a property right, she could not demonstrate an injury from the state’s retention of interest.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiff had standing, as her complaint alleged a concrete financial injury: the state’s withholding of interest that she claimed was rightfully hers. The court held that the district court improperly conflated the merits of whether she was entitled to interest with the standing inquiry. The Sixth Circuit reversed the district court’s dismissal for lack of standing and remanded for further proceedings, emphasizing that the record was insufficient to resolve the merits of the takings claim at this stage. View "Hendershot v. Stanton" on Justia Law

TwinSpires, an Oregon-based electronic wagering platform, facilitates interstate betting on horseraces. Under the federal Interstate Horseracing Act (IHA), such betting is lawful if the operator obtains consent from both the state where the bet is accepted and the state where the race occurs, as well as the relevant racetrack. Michigan, however, enacted a law requiring additional state-specific licensing for platforms like TwinSpires to accept bets from Michigan residents. After TwinSpires partnered with Michigan’s only racetrack and obtained the requisite license, its license was suspended when the racetrack temporarily lost its own license. Even after the racetrack’s license was restored, Michigan maintained the suspension of TwinSpires’ license, prompting the company to sue, arguing that Michigan’s requirements conflicted with the IHA.The United States District Court for the Western District of Michigan granted a preliminary injunction, preventing Michigan from enforcing its licensing requirements against TwinSpires. The district court found that the IHA preempted Michigan’s additional licensing regime, concluding that TwinSpires was likely to succeed on the merits of its preemption claim and that other injunction factors favored TwinSpires.The United States Court of Appeals for the Sixth Circuit reviewed the preliminary injunction for abuse of discretion, applying de novo review to legal conclusions and clear error review to factual findings. The Sixth Circuit affirmed the district court’s order, holding that the IHA conflict-preempts Michigan’s licensing requirement for interstate wagering platforms. The court concluded that Michigan’s law imposed an additional regulatory hurdle beyond what the IHA requires, interfering with the federal scheme and frustrating Congress’s intended objectives. The court also found that the remaining factors for a preliminary injunction—irreparable harm, balance of equities, and public interest—favored TwinSpires. View "Churchill Downs Tech. Initiatives Co. v. Mich. Gaming Control Bd." on Justia Law

A Michigan State Trooper conducted a traffic stop after observing a vehicle with expired registration. The passenger, Adam Santos, was identified as a convicted felon, currently on probation, and flagged in police databases as possibly armed and dangerous. During the stop, the trooper noticed Santos acting nervously and avoiding searching a cross-body bag when asked for identification. After obtaining the driver’s consent to search the vehicle, the trooper removed both occupants from the car for safety. While frisking Santos, the trooper felt a weight in the bag consistent with a firearm. A struggle ensued when the trooper attempted to open the bag, and a gun was recovered. Santos was indicted for unlawful possession of a firearm by a felon.The United States District Court for the Western District of Michigan denied Santos’s motion to suppress the gun, finding that the officer’s actions were justified by concerns for safety and that the driver voluntarily consented to the vehicle search. The court also found the frisk of Santos and the subsequent search of the bag permissible, given the reasonable suspicion and probable cause developed during the stop.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The appellate court held that the trooper did not violate Santos’s Fourth Amendment rights. The stop was lawfully initiated, and the questions and actions taken by the officer, including the removal of both occupants and the frisk of Santos, were justified by safety concerns based on specific, articulable facts. The court affirmed the district court’s denial of the suppression motion, holding that neither the duration nor the scope of the stop nor the search of Santos’s bag was unconstitutional. View "United States v. Santos" on Justia Law

A dual citizen of the United States and Pakistan, the defendant traveled from the U.S. to Pakistan in 2009, along with four others, with the intent to join jihad in Afghanistan. Upon arrival, the group attempted to make contact with terrorist organizations and made efforts to cross into Afghanistan. Pakistani authorities arrested them in Sargodha, Pakistan, and subsequently tried and convicted them on terrorism-related offenses. The defendant served approximately ten years in a Pakistani prison. After completing his sentence, he was extradited to the United States, where he faced federal charges arising from the same underlying conduct.The United States District Court for the Eastern District of Virginia arraigned the defendant and, after he waived his Speedy Trial Act rights, considered his motion to dismiss the indictment on Sixth Amendment speedy trial grounds. The motion argued that the government’s delay in seeking his extradition and prosecution in the U.S. violated his constitutional rights. The district court denied the motion, finding that, although the length of the delay was significant, the government made reasonably diligent and good-faith efforts to secure his return, and the remaining factors weighed against finding a violation. The defendant entered a conditional guilty plea, reserving his right to appeal the speedy trial ruling.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying the four-factor balancing test from Barker v. Wingo. The appellate court agreed that only the length of the delay favored the defendant, but reasoned that the government’s efforts, the defendant’s own conduct in resisting extradition, and the absence of actual prejudice outweighed that factor. The court held there was no Sixth Amendment speedy trial violation and affirmed the conviction. View "US v. Chaudhry" on Justia Law

In this case, two federally recognized tribes in Madera County, California, were involved in a dispute over the authorization of a casino. One tribe, North Fork, sought to build and operate a large off-reservation casino on a 305-acre site near State Route 99. To do so, North Fork obtained a favorable “two-part determination” from the Secretary of the U.S. Department of the Interior, followed by a concurrence from the Governor of California, and the negotiation of a tribal-state compact. The compact was ratified by the Legislature. However, a statewide referendum (Proposition 48) resulted in California voters rejecting the ratification statute. The other tribe, Picayune-Chukchansi, which operated its own on-reservation casino, challenged the validity of the Governor’s concurrence, arguing it was rendered void by the voters’ rejection.Prior to this appeal, the matter was litigated in multiple forums. In the Madera County Superior Court, Picayune-Chukchansi sought declaratory relief to have the Governor’s concurrence declared void ab initio. Proceedings were stayed pending appellate decisions in related cases, including United Auburn Indian Community of Auburn Rancheria v. Newsom by the California Supreme Court, which recognized the Governor’s implied authority to concur, and Stand Up for California! v. State of California (Stand Up II) by the Court of Appeal, which held that the people retained the power to annul the Governor’s concurrence through a referendum. The trial court ultimately granted summary judgment in favor of Picayune-Chukchansi, declaring the Governor’s concurrence void from the outset.On appeal, the California Court of Appeal, Fifth Appellate District, affirmed the trial court’s judgment. The court held that the people of California, by rejecting Proposition 48, exercised their retained power to annul the Governor’s concurrence, and that this annulment rendered the concurrence void ab initio—meaning it never took effect and is not in effect. The court also found that the dispute was not moot and that the Governor’s authority to concur is subject to the electorate’s overriding power under California constitutional law. View "Picayune Rancheria v. North Fork Rancheria" on Justia Law

Law enforcement received anonymous tips in 2021 and 2022 alleging that a Wilmington resident was selling drugs and possessing firearms at his home, which also operated as an unlicensed barbershop. The tips included specific details about the individual’s activities and identifying information. After receiving the July 2022 tip, police corroborated aspects of the information through surveillance, database checks, and two traffic stops involving individuals seen leaving the residence—one was found with marijuana allegedly purchased from the suspect and another fled from police after acting suspiciously. Based on this investigation, police obtained and executed a search warrant, recovering drugs, cash, and a firearm. The individual, a previously convicted felon, was indicted on drug and firearm charges, including possession of a firearm by a person prohibited.The Superior Court of the State of Delaware denied the defendant’s motion to suppress the evidence, finding that the affidavit supporting the search warrant established probable cause through the combination of the July 2022 tip and corroborating police investigation. At trial, a police officer referred to information from the National Crime Information Center (NCIC) identifying the recovered firearm as stolen. The defense did not object to this testimony. The defendant was convicted of multiple offenses, including firearm and drug charges, and sentenced to seventeen years of incarceration.On appeal to the Supreme Court of the State of Delaware, the defendant raised claims of hearsay and Confrontation Clause violations due to the NCIC testimony, challenged the denial of his suppression motion, and argued that the statute prohibiting felons from possessing firearms was unconstitutional. The Supreme Court applied plain error review to most issues because they were not raised below, and affirmed the convictions. The Court held that there was no plain error in admitting the NCIC evidence, that the search warrant was supported by probable cause, and that the firearm prohibition statute was not plainly unconstitutional, either on its face or as applied to the defendant. The judgment of the Superior Court was affirmed. View "Johns v. State" on Justia Law

Jose Antonio Duque-Ramirez, born in Mexico, entered the United States unlawfully as a child and lived in Oklahoma City for over two decades. He married a U.S. citizen, has U.S.-citizen children, and attempted but failed to adjust his immigration status through various legal avenues. In October 2023, he was stopped by law enforcement while driving with security gear and firearms in his vehicle. He was found to be unlawfully present in the U.S. and subsequently indicted for violating 18 U.S.C. § 922(g)(5)(A), which prohibits firearm possession by noncitizens unlawfully in the country.The United States District Court for the Western District of Oklahoma first rejected his facial challenge to the statute, assuming without deciding that he was among “the people” protected by the Second Amendment. After pleading guilty, withdrawing his plea, and raising a new as-applied Second Amendment challenge (relying on recent Supreme Court precedent, including United States v. Rahimi), the district court again denied his motion to dismiss, reasoning that historical laws supported disarming those who had not demonstrated allegiance to the sovereign.The United States Court of Appeals for the Tenth Circuit reviewed the case. The Tenth Circuit assumed, without deciding, that Duque-Ramirez was among those protected by the Second Amendment. Applying the framework from New York State Rifle & Pistol Ass’n v. Bruen and Rahimi, the court held that § 922(g)(5)(A) is consistent with the nation’s historical tradition of firearm regulation, specifically citing founding-era laws that disarmed persons who had not demonstrated allegiance. The court concluded that an individualized determination of dangerousness was not required and affirmed the conviction, rejecting Duque-Ramirez’s as-applied Second Amendment challenge. View "United States v. Duque-Ramirez" on Justia Law

Law enforcement officers with the Kansas Highway Patrol observed a black Jeep Grand Cherokee traveling eastbound on I-70 with a temporary registration tag that appeared to be unsecured and “flapping or blowing up,” rather than lying flat against the vehicle. The officers believed this constituted a violation of Kansas law regarding license plate attachment. Upon stopping the vehicle, they noted the driver, Miguel Munoz, appeared abnormally nervous and immediately volunteered that he and his wife were traveling to a funeral in Kansas, providing vague details. During the stop, an officer also noticed an image of Jesus Malverde, which the officers associated with drug trafficking, hanging inside the Jeep. After further questioning, Munoz consented to a search, leading to the discovery of fentanyl tablets and a firearm.Munoz was charged in the United States District Court for the District of Colorado with conspiracy to distribute and possess with intent to distribute controlled substances. He moved to suppress the evidence obtained from the traffic stop, arguing that the stop was not justified at its inception and was unreasonably extended. The district court held a suppression hearing, found the officers’ testimony credible, and denied the motion. The court concluded the stop was justified by reasonable suspicion of a violation of Kansas Statutes Annotated § 8-133(c) (requiring license plates to be securely fastened) and that the officers had reasonable suspicion to briefly extend the stop based on Munoz’s conduct and the items observed.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s findings for clear error and legal conclusions de novo. The appellate court held that the initial stop was justified by reasonable suspicion of a violation of § 8-133(c), as interpreted by the Kansas Supreme Court, and that the extension of the stop was supported by reasonable suspicion of criminal activity. The Tenth Circuit affirmed the district court’s denial of Munoz’s motion to suppress and his conviction and sentence. View "United States v. Munoz" on Justia Law

The plaintiff was hired as a “Full Time Jewish Educator” at a religious institution and was responsible for teaching in religious classrooms, planning and attending religious events, and supporting the synagogue’s mission to develop a strong Jewish identity. Soon after starting her job, the plaintiff was confronted by a rabbi about her co-authorship of a blog post that was critical of Israel and Zionism. Although she assured the rabbi she would not share her personal views at work and was told her teaching abilities were not in question, she was terminated less than a week later.The plaintiff filed suit in New York Supreme Court, alleging that her dismissal violated Labor Law § 201-d(2)(c), which prohibits employers from taking adverse action against employees for engaging in legal recreational activities outside of work. The defendants moved to dismiss, arguing the claim failed because the activity was not protected, there was a material conflict with the employer’s interests, and the ministerial exception barred the claim. The Supreme Court granted the motion to dismiss, holding that the complaint failed to state a cause of action because the termination was for the content of the blog post, not the act of blogging itself, and did not address the other grounds for dismissal. The Appellate Division affirmed on the same basis and declined to reach the alternative arguments.The New York Court of Appeals affirmed the Appellate Division’s order, but on a different ground. The Court of Appeals held that, regardless of whether the plaintiff’s activity was protected under Labor Law § 201-d, the ministerial exception—which bars application of employment discrimination laws to the employment relationship between a religious institution and its ministers—applied. The plaintiff’s offer letter conclusively established that her core duties were religious in nature, and thus her claim was barred as a matter of law. View "Sander v. Westchester Reform Temple" on Justia Law

Congress enacted a law requiring certain business entities to report information about their beneficial owners to the Department of the Treasury, aiming to address financial crimes facilitated by anonymous corporate ownership. The law applies to corporations, LLCs, and similar entities, excluding certain organizations like banks, nonprofits, and large businesses. Reporting companies must disclose identifying information about their owners and applicants. The law contains several exemptions for inactive or specific types of entities and allows for regulatory exemptions. The plaintiffs, a business association and a small business owner, challenged the law, arguing it exceeded Congress’s powers and violated constitutional rights.In the United States District Court for the Northern District of Alabama, the plaintiffs moved for summary judgment, asserting that the law was not justified under the Commerce Clause, Taxing Clause, Necessary and Proper Clause, or Congress’s national security and foreign affairs powers. The district court agreed, finding that the law regulated the act of incorporation—a noncommercial activity—and that the connection to interstate commerce was too remote. As a result, the court held the law exceeded Congress’s enumerated powers and did not address the constitutional rights claims.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and reversed the district court’s decision. The Eleventh Circuit held that the law facially regulates economic activity by targeting the ownership and operation of business entities, which are inherently commercial. The court found that Congress had a rational basis for concluding that anonymous business dealings have a substantial aggregate effect on interstate commerce. Additionally, the court held that the law’s uniform reporting requirements do not facially violate the Fourth Amendment, as they are reasonable, limited, and accompanied by privacy protections. The case was remanded for further proceedings. View "National Small Business United v. U.S. Department of the Treasury" on Justia Law