Justia Constitutional Law Opinion Summaries

Wayne Brown, a Tulsa police officer, was terminated after a private citizen, Marq Lewis, brought several of Brown's old Facebook posts to the attention of the City of Tulsa and the Tulsa Police Department. The posts included images and messages that were deemed offensive and in violation of the department's social media policy. Brown filed a lawsuit claiming his termination violated his First Amendment rights and the Equal Protection Clause of the Fourteenth Amendment. He also brought a wrongful discharge claim under Oklahoma law.The United States District Court for the Northern District of Oklahoma dismissed Brown's federal claims under Rule 12(b)(6) and declined to exercise supplemental jurisdiction over his state law claim. The court concluded that the City's interest in maintaining public confidence in the police force outweighed Brown's free speech rights and that Chief Jordan was entitled to qualified immunity. The court also dismissed Brown's Equal Protection claim, determining it was a "class-of-one" theory foreclosed by Supreme Court precedent.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court reversed the dismissal of Brown's First Amendment claim, finding that the district court erred in conducting the Pickering balancing test at the motion to dismiss stage and in granting qualified immunity to Chief Jordan. The court affirmed the dismissal of Brown's Equal Protection claim, agreeing that it was a non-cognizable "class-of-one" claim in the public employment context. The court also reversed the district court's decision to decline supplemental jurisdiction over Brown's state law claim and remanded for further proceedings. View "Brown v. City of Tulsa" on Justia Law

The City of Hillsboro, Missouri, enacted ordinances prohibiting new private wells within city limits and requiring residences to connect to the city water system. The Antoinette Ogilvy Trust, owning a 156-acre property within Hillsboro, claimed these ordinances constituted an uncompensated regulatory taking under the Fifth and Fourteenth Amendments. The trustees, William Becker and Darcy Lynch, argued that the regulations made developing the property financially unfeasible due to the high costs of connecting to the city water system.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the City, rejecting the trustees' claims. The court found that the regulations did not constitute a per se taking, as they did not involve a physical invasion of the property or deprive it of all economic value. The court also determined that the regulations did not fail the Penn Central balancing test for regulatory takings.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the regulations did not mandate a permanent physical invasion of the property, as the trustees were not compelled to build structures or dedicate land to the City. The court also found that the property retained substantial value, thus not constituting a taking under Lucas v. South Carolina Coastal Council. Additionally, the court declined to consider the trustees' exaction claim, as it was not sufficiently raised in the lower court.Under the Penn Central test, the court concluded that the economic impact on the trustees was not significant enough to constitute a taking, and the regulations did not interfere with reasonable investment-backed expectations. The character of the governmental action was deemed a legitimate exercise of the City's police powers to prevent water contamination and protect the aquifer. Therefore, the court affirmed the district court's summary judgment in favor of the City. View "Becker v. City of Hillsboro" on Justia Law

In the early hours of May 11, 2018, Chasrick Heredia, while celebrating his birthday, had a violent encounter with Manchester Police officers, including Officer Michael Roscoe. Heredia filed a complaint alleging excessive force and other constitutional violations. At trial, the jury found Roscoe liable for excessive force and awarded Heredia nominal and punitive damages. The district court denied Roscoe's motions for judgment as a matter of law (JMOL) and for remittitur of the punitive damages award.The United States District Court for the District of New Hampshire presided over the initial trial. The jury found in favor of Heredia on the excessive force claim against Roscoe but in favor of the defendants on all other claims. Roscoe's post-trial motions for JMOL and remittitur were denied by the district court, which concluded that a reasonable juror could find that Roscoe violated Heredia's constitutional rights and that qualified immunity did not apply.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's denial of Roscoe's motions. The appellate court held that a reasonable jury could find that Roscoe used excessive force when he performed a takedown on Heredia after Heredia had submitted to arrest by raising his hands. The court also held that Roscoe was not entitled to qualified immunity because it was clearly established that increasing the use of force after an arrestee had submitted was unconstitutional. Additionally, the court found that the punitive damages awarded were justified based on Roscoe's reckless indifference to Heredia's constitutional rights. View "Heredia v. Roscoe" on Justia Law

In 1994, Christopher Spreitz was convicted by a jury of first-degree murder, sexual assault, and kidnapping of Ruby Reid. Reid was last seen leaving a bar in Tucson, and her body was found days later in a desert area. Spreitz admitted to hitting Reid with a rock to stop her from yelling. The medical examiner identified multiple injuries on Reid's body, including broken ribs, internal bleeding, and a skull fracture.The trial court found one aggravating circumstance: that Spreitz murdered Reid in an especially cruel manner. The court also considered several non-statutory mitigating factors, such as Spreitz's sub-normal home environment, emotional immaturity, lack of prior felonies, and potential for rehabilitation. The court determined that the aggravating circumstance outweighed the mitigating factors and sentenced Spreitz to death. This sentence was affirmed by the Arizona Supreme Court on direct appeal.Spreitz's petition for habeas corpus was denied by the federal district court, but a divided panel of the Ninth Circuit Court of Appeals reversed in part, concluding that the Arizona Supreme Court had applied an unconstitutional "causal nexus" test and did not properly consider evidence of Spreitz's longstanding alcohol and substance abuse as non-statutory mitigation. The Ninth Circuit remanded the case to the district court with instructions to correct the constitutional error or impose a lesser sentence.The Arizona Supreme Court conducted a new independent review of the entire record, including the mitigation evidence presented at the original sentencing. The court considered the mitigating factors without requiring a causal nexus to the murder and reweighed them against the established especially cruel aggravating circumstance. The court concluded that the mitigation evidence was insufficient to warrant leniency and affirmed the sentence of death. View "State v. Spreitz" on Justia Law

Beata Zarzecki, a Polish national, entered the United States on a six-month tourist visa in 1989 and remained in the country illegally. In 1998, she married a U.S. citizen, and they have a daughter who is also a U.S. citizen. In 2013, removal proceedings were initiated against her, and she applied for adjustment of status based on her marriage. Her application was complicated by a 2005 conviction for felony aggravated driving under the influence, resulting in a fatal accident. She was sentenced to nine years in prison and served over eight years. Additional incidents included a 2003 arrest for aggravated assault and a 2004 charge for driving without insurance.The immigration judge denied her application for adjustment of status, citing the severity of her criminal record and insufficient evidence of addressing her mental health issues. The Board of Immigration Appeals (Board) reviewed the case de novo and upheld the immigration judge's decision, emphasizing the egregious nature of her offense and finding that her mitigating factors did not outweigh the adverse factors.The United States Court of Appeals for the Seventh Circuit reviewed Zarzecki's petition, focusing on whether the Board committed legal or constitutional errors. Zarzecki argued that the Board failed to properly consider her mental health evidence and did not apply the correct standard of review. The court found that the Board did consider her mental health evidence and applied the appropriate standard of review. The court concluded that the Board did not commit any legal or constitutional errors and dismissed Zarzecki's petition for lack of jurisdiction, as discretionary decisions regarding adjustment of status are not subject to judicial review. View "Zarzecki v. Garland" on Justia Law

A service-disabled veteran and his company, MJL Enterprises, LLC, alleged that the Small Business Administration’s (SBA) Section 8(a) Business Development Program discriminated against him based on race. The program uses a race-conscious presumption to determine social disadvantage, which the plaintiffs argued was unconstitutional. They sought a declaration that the program's racial classifications were unconstitutional and an injunction against its enforcement.The United States District Court for the Eastern District of Virginia dismissed the case, ruling it moot due to changes in the 8(a) Program following an injunction in another case, Ultima Services Corp. v. U.S. Department of Agriculture. The district court also found that the plaintiffs lacked standing because they failed to demonstrate economic disadvantage and could not establish social disadvantage without the presumption.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reversed the district court’s ruling on mootness, agreeing with the plaintiffs that the case was not moot because the changes to the 8(a) Program were not final and could be appealed. However, the Fourth Circuit affirmed the district court’s dismissal based on lack of standing. The court held that the plaintiffs failed to demonstrate an injury in fact, as they did not show they were "able and ready" to bid on 8(a) Program contracts due to their inability to meet the program’s social and economic disadvantage requirements. The court also found that the plaintiffs could not establish causation or redressability, as their ineligibility for the program was not solely due to the race-conscious presumption.The Fourth Circuit concluded that the plaintiffs lacked Article III standing to sue and affirmed the district court’s dismissal for lack of subject matter jurisdiction. The case was remanded for further proceedings consistent with the opinion. View "Hierholzer v. Guzman" on Justia Law

The Consumer Financial Protection Bureau (CFPB) brought an action against CashCall, Inc., alleging that CashCall engaged in unfair, deceptive, or abusive practices by attempting to collect interest and fees it was not legally entitled to. The CFPB sought legal restitution for the affected consumers. CashCall argued that the restitution order triggered its Seventh Amendment right to a jury trial.The United States District Court for the Central District of California initially granted partial summary judgment to the CFPB on liability and conducted a bench trial to determine the appropriate remedy. The court imposed a civil penalty but declined to order restitution. Both parties appealed, and the Ninth Circuit Court of Appeals affirmed the finding of liability but vacated the civil penalty and remanded for further proceedings regarding restitution.On remand, the district court ordered CashCall to pay over $134 million in legal restitution. CashCall appealed again, contending that the restitution order violated its Seventh Amendment right to a jury trial. The United States Court of Appeals for the Ninth Circuit assumed, without deciding, that CashCall had a right to a jury trial but concluded that CashCall had waived that right by voluntarily participating in the initial bench trial and not objecting to the second bench trial. The court also held that the district court did not abuse its discretion in concluding that the doctrines of judicial estoppel and waiver did not preclude the CFPB from seeking legal restitution. Additionally, the court found that the district court did not overstate CashCall’s unjust gains and properly used CashCall’s net revenues as a basis for measuring unjust gains. Finally, the court rejected CashCall’s argument that the CFPB’s funding mechanism violated the Appropriations Clause.The Ninth Circuit affirmed the district court’s judgment. View "CONSUMER FINANCIAL PROTECTION BUREAU V. CASHCALL, INC." on Justia Law

Andrew Grimm parked his car on a downtown street in Portland, Oregon, and paid for parking through a mobile app for a limited time. He left the car there for seven days, during which City parking enforcement officers issued multiple parking citations and placed them on the car’s windshield. After five days, an officer added a red slip warning that the car would be towed if not moved. Grimm did not move the car, and two days later, the car was towed.Grimm sued the City of Portland, claiming that the City’s procedures for notifying him of the impending tow were deficient under the Fourteenth Amendment’s Due Process Clause. The United States District Court for the District of Oregon granted summary judgment in favor of the City, holding that the City’s notice procedures were reasonable. The court found that although the accumulation of citations might have indicated that Grimm did not receive notice, no other form of notice was practicable.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The Ninth Circuit held that the City’s notice, which included a red warning slip placed on the car’s windshield two days before the tow, was reasonably calculated to inform Grimm of the impending tow, satisfying the requirements of the Fourteenth Amendment. The court further held that the City did not have actual knowledge that its attempt to provide notice had failed simply because the citations and warning slip remained undisturbed on the car’s windshield. Therefore, the City was not required to take additional steps to notify Grimm. The court affirmed the district court’s grant of summary judgment to the City. View "GRIMM V. CITY OF PORTLAND" on Justia Law

In January 2020, Detective Josh Winter of the Clinton, Iowa, Police Department stopped Johnathon Lawrence Rose for having heavily-tinted windows, which violated Iowa law. During the stop, Rose's behavior made Winter nervous, prompting him to request a canine unit. The drug-detection dog alerted to the presence of drugs, leading to a search of Rose's car, where officers found drug paraphernalia and suspected drug residue. Rose was arrested, and further searches at the police department and his residence revealed more drugs, ammunition, and firearms. Rose was indicted for possessing methamphetamine with intent to distribute and unlawfully possessing a firearm as a felon.The United States District Court for the Southern District of Iowa held an evidentiary hearing and denied Rose's motion to suppress the evidence. Rose entered a conditional guilty plea, reserving his right to appeal the denial of the motion to suppress. The district court determined Rose was a career offender and sentenced him to 210 months of imprisonment. Rose appealed, and the United States Court of Appeals for the Eighth Circuit affirmed his sentence. Rose then filed a motion for relief under 28 U.S.C. § 2255, alleging ineffective assistance of counsel. The district court agreed, vacated his sentence, and reimposed it, allowing Rose to appeal again.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's denial of the motion to suppress, finding no constitutional violations in the traffic stop, searches, or Rose's incriminating statements. However, the court reversed Rose's sentence, agreeing with the government's concession that the case must be remanded for resentencing in light of a recent decision in United States v. Daye, which impacted the classification of Rose as a career offender. The case was remanded for further proceedings consistent with this opinion. View "United States v. Rose" on Justia Law

Jayson O’Neill requested to examine certain documents from the Office of the Governor of Montana, specifically 2021 Agency Bill Monitoring Forms (ABMs) and related emails. The Governor’s office denied the request, citing attorney-client privilege. O’Neill argued that the documents should be produced with redactions and a detailed privilege log. The Governor’s office maintained that the documents were entirely privileged but offered to provide a privilege log and documents for in camera review if directed by a court.O’Neill filed a complaint seeking an order to produce the requested documents under Article II, Section 9, of the Montana Constitution. The Governor asserted executive and deliberative process privileges. Both parties moved for summary judgment. The First Judicial District Court partially granted O’Neill’s motion, holding that Montana law did not recognize executive or deliberative process privileges and required in camera review to determine the applicability of attorney-client privilege and privacy exceptions. The Governor’s subsequent motion for relief from judgment was deemed denied.The Supreme Court of the State of Montana reviewed the case. The court held that Montana law does recognize a form of gubernatorial privilege rooted in the state’s constitutional history, allowing the Governor to receive candid advice necessary for executing constitutional duties. However, this privilege is not absolute and must be assessed through in camera review to determine if the information is essential and if its disclosure would chill future candor. The court reversed the lower court’s ruling that no form of executive privilege is recognized in Montana but affirmed the need for in camera review to evaluate the claims of privilege. The case was remanded for further proceedings consistent with this opinion. View "O'Neill v. Gianforte" on Justia Law