Justia Constitutional Law Opinion Summaries

Seth Hettena, an investigative journalist, submitted a Freedom of Information Act (FOIA) request to the Central Intelligence Agency (CIA) for a report on the death of an Iraqi national, Manadel al-Jamadi, who died in CIA custody at Abu Ghraib prison in 2003. The CIA disclosed parts of the report but redacted most of it, including the Office of Inspector General's (OIG) conclusions and recommendations. Hettena sued the CIA, arguing that the redactions did not comply with FOIA.The United States District Court for the District of Columbia reviewed the case and granted summary judgment in favor of the CIA, concluding that the redactions were justified under FOIA exemptions. The court found that the redacted information pertained to the CIA's intelligence activities, sources, and methods, which are protected under FOIA Exemptions 1 and 3.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court's decision de novo. The appellate court agreed that most of the redactions were justified, as they contained information about CIA covert personnel, intelligence methods, and locations of Agency facilities. However, the court found that the CIA had not adequately justified the redactions related to the OIG's findings on potential obstruction by CIA officers. The court noted that the CIA's declaration and Vaughn index did not address these findings, and it was unclear why disclosing them would reveal protected information.The appellate court also found that factual questions remained regarding whether the redactions contained information that the CIA had already officially acknowledged, such as references to a "hood" or "head cover." The court vacated the district court's judgment and remanded the case for further proceedings, allowing the CIA another opportunity to explain its redactions and potentially develop the record further. View "Hettena v. CIA" on Justia Law

Plaintiffs, including Mike Yoder and his company Drone Deer Recovery, LLC (DDR), along with hunter Jeremy Funke, challenged a Michigan law that bans the use of drones to hunt or collect downed game. DDR uses drones equipped with infrared cameras to locate downed game and provide hunters with GPS coordinates. Plaintiffs argued that the law prevents DDR from operating in Michigan, violating their First Amendment rights to create, disseminate, and receive information.The United States District Court for the Western District of Michigan dismissed the complaint, holding that Plaintiffs lacked standing and failed to state a claim. The court found that the law did not prohibit the dissemination of location information but only the use of drones to locate game, which it deemed non-speech conduct. The court also concluded that the alleged injury was not redressable because the law would still prohibit drone use even if the requested injunction was granted.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that Plaintiffs had standing but failed to state a claim. The court determined that Plaintiffs' intended conduct of using drones to create and share location information was arguably affected with a constitutional interest and that there was a credible threat of enforcement under the Michigan law. However, the court applied intermediate scrutiny, finding the law content-neutral and justified by substantial governmental interests in conservation and fair-chase hunting principles. The court concluded that the law was narrowly tailored to achieve these interests and did not violate the First Amendment.The Sixth Circuit affirmed the district court's dismissal of the complaint, holding that Plaintiffs failed to state a claim on which relief could be granted. View "Yoder v. Bowen" on Justia Law

Federal agents discovered that an individual was sharing files containing child pornography over a peer-to-peer network. After obtaining a search warrant, law enforcement searched his residence and seized several digital devices. Forensic analysis revealed that he had downloaded and shared over 300 images and 150 videos depicting minors engaged in sexually explicit conduct. He was indicted in the United States District Court for the Middle District of Florida on one count of possessing and accessing with intent to view child pornography involving a minor under twelve years of age. The defendant waived his right to a jury trial and proceeded to a bench trial based on stipulated facts, after which the district court found him guilty.Prior to sentencing, the United States Probation Office prepared a Presentence Investigation Report, which calculated his total offense level as 30, including a five-level enhancement for offenses involving 600 or more images. The calculation treated each video as equivalent to 75 images, based on Sentencing Commission commentary. The defendant objected, arguing that the guideline’s text did not support this interpretation, but the district court overruled the objection and imposed a sentence of 97 months’ imprisonment and 15 years of supervised release. The court also ordered restitution of $3,000 to each of thirteen victims, totaling $39,000, and denied the defendant’s request for a jury to determine restitution. The written judgment included standard conditions of supervised release, which were not individually enumerated at sentencing.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court held that the sentencing guideline unambiguously requires each video frame containing child pornography to be counted as one image, but since the defendant conceded that his conduct exceeded the threshold for the highest enhancement, the sentence was affirmed. The court also held that neither the Fifth nor Sixth Amendments require a jury to determine restitution amounts, and that the district court was not required to disaggregate losses caused by the initial abuse. Finally, the court found no error in the district court’s pronouncement of supervised release conditions. View "USA v. Kluge" on Justia Law

Kyle Evans was charged with felony possession of a stolen vehicle in January 2024. He was not arrested but was summoned to appear for arraignment, where he pleaded not guilty and was released on personal recognizance with certain conditions. The State sought to administratively book Evans to collect his fingerprints and other identifying information, which involved patting down, handcuffing, and detaining him in a jail cell. Evans challenged this process, arguing it violated his constitutional rights under article I, section 7 of the Washington Constitution.In the King County Superior Court, Judge Johanna Bender ruled in favor of Evans, finding that the administrative booking process violated his rights by intruding on his private affairs without the necessary authority of law. Judge Bender allowed the State to collect Evans' fingerprints but prohibited the use of handcuffs, pat-downs, and detention in a cell. This decision conflicted with a ruling by Judge Melinda Young in a similar case, where the process was deemed constitutional under the Fourth Amendment.The Supreme Court of the State of Washington reviewed the case and held that King County's administrative booking process violated article I, section 7 of the Washington Constitution. The court found that the process intruded on the private affairs of pretrial releasees and that the State failed to justify this intrusion with the necessary authority of law. The court emphasized that pretrial releasees do not have diminished privacy rights simply because they have been accused of a crime. The court affirmed the trial court's order and remanded the case for further proceedings consistent with its opinion. View "State v. Evans" on Justia Law

The case involves a defendant who pleaded guilty to charges of attempted possession of heroin and unlawful use of a vehicle (UUV) in Lake County Circuit Court. The court imposed a departure sentence of 24 months' supervised probation for the UUV offense. While on probation, the defendant was involved in a serious automobile accident in Jefferson County, leading to multiple charges. The defendant pleaded guilty to two counts of failure to perform the duties of a driver (FPDD) and was sentenced to 75 months in prison.The Lake County court then revoked the defendant's probation for the UUV offense and imposed an 18-month prison term, to be served consecutively to the Jefferson County sentences. The defendant objected, arguing that the sentencing guidelines did not authorize consecutive sentences in this context. The trial court disagreed and imposed the consecutive sentence. The Court of Appeals affirmed the trial court's decision in a nonprecedential opinion.The Oregon Supreme Court reviewed the case to determine whether the trial court had the authority to impose a consecutive sentence after revoking the defendant's probation. The court held that Article I, section 44(1)(b) of the Oregon Constitution, which states that no law shall limit a court's authority to sentence a criminal defendant consecutively for crimes against different victims, supersedes any sentencing guidelines that would prevent such a consecutive sentence. The court concluded that the trial court did not err in imposing the consecutive sentence and affirmed the decisions of the Court of Appeals and the circuit court. View "State v. Logston" on Justia Law

Officer Mason Roth shot and killed Bobby Jo Klum, who was walking through a residential neighborhood with a gun to his head, evading arrest, and ignoring officer commands to drop the weapon. Klum’s spouse and mother sued Officer Roth and the City of Davenport under 42 U.S.C. § 1983, alleging a violation of Klum’s Fourth Amendment right against unreasonable seizure. The district court granted qualified immunity to Officer Roth and concluded the City of Davenport was not liable under Monell v. Department of Social Services.The United States District Court for the Southern District of Iowa granted summary judgment to Officer Roth and the City of Davenport on all claims. The court concluded that Klum’s Fourth Amendment right against unreasonable seizure was not violated and that Klum did not possess a clearly established right against seizure by deadly force under the circumstances. Plaintiffs appealed the district court’s grant of summary judgment based on qualified immunity as to their excessive force claim against Officer Roth and the City of Davenport.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that any right was not clearly established at the time, and therefore, Officer Roth was entitled to qualified immunity. The court found that the totality of the circumstances, including Klum’s non-compliance, evasion, and proximity to bystanders, justified the use of deadly force. The court also upheld the district court’s grant of summary judgment on the Monell claim, concluding that Plaintiffs failed to raise a genuine issue as to whether the City of Davenport had a policy that directly caused the use of deadly force. View "Klum v. City of Davenport" on Justia Law

A law firm, Sutter & Gillham PLLC, and its partners were involved in a contentious wrongful-death lawsuit in Arkansas, representing the family of a teenage boy who died from a gunshot wound. The family suspected foul play, while the boy's friends claimed it was suicide. The state court dismissed the case with prejudice, citing misconduct by the family and its attorneys. Although the firm had withdrawn from the case, it felt unfairly maligned by the court's order. One partner's attempt to intervene and seek recusal of the judge was denied, and no appeal was filed. The family successfully overturned the dismissal, and the case remains pending.The firm faced related litigation, including a state court lawsuit by the wrongful-death defendants against the firm and its partners for alleged misconduct. The firm also filed a federal lawsuit alleging constitutional violations by the wrongful-death defendants and their attorneys, claiming they conspired with the state trial judge. The United States District Court for the Eastern District of Arkansas dismissed the case under the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that the Rooker-Feldman doctrine did not apply because the federal lawsuit did not seek to overturn the state court judgment but rather targeted the actions of the defendants and their attorneys. The court emphasized that the doctrine only applies when a federal action is essentially an appeal of a state court decision. The Eighth Circuit vacated the district court's dismissal and remanded the case for further proceedings, allowing the plaintiffs to pursue their claims. View "Sutter & Gillham PLLC v. Henry" on Justia Law

Liquid Hospitality, LLC, doing business as Windbreak Saloon, holds a liquor license from the City of Fargo. On August 18, 2023, Windbreak staff removed an intoxicated patron who later drove away and was involved in a single-vehicle accident. The patron had a blood alcohol concentration of 0.291 and was arrested for driving under the influence. The Fargo Police Department investigated and reviewed surveillance footage, which showed the patron being served multiple drinks and exhibiting signs of intoxication. The Windbreak was notified of a hearing before the Liquor Control Board for a possible violation of Fargo Municipal Code (F.M.C.) § 25-1509.2, which prohibits serving alcohol to intoxicated or impaired persons.The Liquor Control Board held a hearing on October 24, 2023, and determined that the Windbreak violated F.M.C. § 25-1509.2, recommending a $500 administrative penalty. The Windbreak appealed to the Board of City Commissioners of the City of Fargo, which upheld the Liquor Control Board's decision. The Windbreak then appealed to the district court.The district court requested additional briefing on the constitutionality of F.M.C. § 25-1509.2 and ultimately found the ordinance unconstitutionally vague, reversing the Commission's order. The court did not address whether the Commission acted arbitrarily, capriciously, or unreasonably, or whether their decision lacked substantial evidence. The Commission appealed to the North Dakota Supreme Court.The North Dakota Supreme Court reviewed the case de novo and concluded that F.M.C. § 25-1509.2 is not unconstitutionally vague. The court found that the ordinance provides adequate warning of prohibited conduct and creates minimum guidelines for enforcement. The court also determined that the Commission's decision was supported by substantial evidence and was not arbitrary, capricious, or unreasonable. The district court's judgment was reversed. View "Liquid Hospitality v. Bd. of City Commissioners of the City of Fargo" on Justia Law

Plaintiffs-Appellants, owners of bonds issued by the Puerto Rico Sales Tax Financing Corporation (COFINA), sued the United States, alleging a taking of their property under the Fifth Amendment due to the enactment of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). They claimed that the restructuring of COFINA's debts under PROMESA resulted in a significant loss of the principal and interest value of their bonds and their security interest.The United States Court of Federal Claims determined it had subject matter jurisdiction over the case but dismissed it for failure to state a claim. The court found that the enactment of PROMESA by Congress did not constitute sufficient federal government action to support a takings claim. The court reasoned that the actions of the Puerto Rico Oversight Board, which was created by PROMESA and acted autonomously, could not be attributed to the United States as coercive or as an agency relationship.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the decision of the Claims Court. The Federal Circuit held that PROMESA did not displace Tucker Act jurisdiction, as there was no clear congressional intent to withdraw the Tucker Act remedy. The court also agreed with the Claims Court that the United States did not exert coercive control over the Oversight Board's actions, which were necessary to establish a taking. The court concluded that the plaintiffs could not establish that the United States was liable for the alleged taking of their property. The court also found no abuse of discretion in the Claims Court's decision to deny the plaintiffs' request to amend their complaint. View "DINH v. US " on Justia Law

Brandon Fulton alleged that Fulton County took his horses without justification and without paying for them, violating the Fifth Amendment's Takings Clause. He initially sought relief under 42 U.S.C. § 1983 but could not establish that the County acted under an official policy or custom, as required by Monell v. Department of Social Services of New York City.The United States District Court for the Northern District of Georgia dismissed Fulton’s § 1983 claim and denied his motion to amend his complaint to sue directly under the Takings Clause. The district court reasoned that plaintiffs must sue under § 1983 for constitutional takings claims against municipalities and that Fulton failed to allege an official policy or custom causing the violation.The United States Court of Appeals for the Eleventh Circuit reviewed the case and concluded that the Takings Clause of the Fifth Amendment directly authorizes a suit for "just compensation" in federal court. The court held that the Takings Clause is self-executing and guarantees a monetary remedy when the government takes private property. The court emphasized that the Takings Clause provides a direct cause of action independent of § 1983, especially when no other adequate remedy exists. The court vacated the district court's order and remanded the case for further proceedings, allowing Fulton to amend his complaint to sue directly under the Takings Clause. View "Brandon Fulton v. Fulton County Board of Commissioners" on Justia Law