Justia Constitutional Law Opinion Summaries

Roger Esteban Real, a native and citizen of Colombia, participated in protests in his home country, leading to his arrest and mistreatment by police. Fearing for his safety, he fled to the United States with his family in March 2022. Upon arrival, he surrendered to immigration authorities, who did not issue him a Notice to Appear (NTA) or inquire about his fear of returning to Colombia. He was instructed to attend a court hearing in 2025 and to check in regularly using a cell phone provided by the authorities.Real was later arrested for crimes related to a domestic dispute, and two months after this arrest, the Department of Homeland Security (DHS) issued him an NTA. An Immigration Judge (IJ) found him removable and, in July 2023, Real applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The IJ granted him withholding of removal but denied his asylum application, citing his failure to meet the one-year filing deadline and lack of extraordinary circumstances to excuse the delay. The Board of Immigration Appeals (BIA) dismissed his appeal, agreeing with the IJ's findings.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the government's failure to notify Real of the one-year asylum application deadline did not constitute a due process violation. Additionally, the court determined that it lacked jurisdiction to review Real's claim of extraordinary circumstances excusing his late filing, as such determinations are discretionary and not subject to judicial review. Consequently, the court denied the petition in part and dismissed it in part. View "Real v. Attorney General" on Justia Law

In 1996, California voters enacted Proposition 218, adding article XIII D to the California Constitution, which includes section 6(b)(3). This section mandates that governmental fees or charges imposed on property must not exceed the proportional cost of the service attributable to the parcel. Plaintiffs, representing a class of single-family residential (SFR) customers of the City of San Diego, challenged the City's tiered water rates, claiming they violated section 6(b)(3) by exceeding the proportional cost of delivering water.The Superior Court of San Diego County ruled in favor of the plaintiffs, finding that the City's tiered rates did not comply with section 6(b)(3). The court concluded that the City failed to show that its tiered rates were based on the actual cost of providing water at different usage levels. The court found that the City's tiered rates were designed to encourage conservation rather than reflect the cost of service, and that the City's use of peaking factors and other methodologies lacked supporting data.The Court of Appeal of the State of California, Fourth Appellate District, Division Two, reviewed the case. The court affirmed the lower court's decision, holding that the City did not meet its burden of proving that its tiered rates complied with section 6(b)(3). The appellate court found that substantial evidence supported the trial court's findings that the City's tiered rates were not cost-proportional and that the City's methodologies were not adequately supported by data. The court also addressed the issue of class certification, finding that the class was properly certified and that the plaintiffs had a common interest in challenging the City's rate structure.The appellate court directed the trial court to amend the judgment to allow the City to satisfy the refund award pursuant to newly enacted Government Code section 53758.5, which requires agencies to credit refund awards against future increases in or impositions of the property-related charge. The court denied the plaintiffs' request for attorney fees on appeal without prejudice, allowing the trial court to determine the entitlement to such fees. View "Patz v. City of S.D." on Justia Law

In the early months of the COVID-19 pandemic, Ohio ordered the closure of "non-essential businesses." A group of dance-studio owners filed a lawsuit in federal court, alleging that various state and local officials had violated their constitutional rights by issuing these orders. The district court dismissed the complaint for failure to state a claim, and the United States Court of Appeals for the Sixth Circuit affirmed this dismissal on August 22, 2022. The appellate court held that the plaintiffs lacked standing against all defendants except former Ohio Director of Public Health Amy Acton and that the plaintiffs' substantive-due-process and equal-protection claims failed under rational-basis review. The court also affirmed the district court's rejection of the plaintiffs' takings claim.After the appellate court affirmed the dismissal, the district court issued a sanctions order against the plaintiffs' attorneys, Thomas B. Renz and Robert J. Gargasz, for their extensive legal failings throughout the case. The attorneys appealed the sanctions order. The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision to impose sanctions. The appellate court agreed that the attorneys had violated Rule 11 by presenting a complaint that was haphazard, incomprehensible, and littered with factual and legal errors. The court also upheld the imposition of sanctions under 28 U.S.C. § 1927, finding that the attorneys had unreasonably and vexatiously multiplied the proceedings with frivolous claims.The appellate court concluded that the district court did not abuse its discretion in granting sanctions and awarding attorney's fees and costs. The court emphasized that the attorneys' conduct fell short of the obligations owed by members of the bar and that the extreme sanction of attorney's fees was warranted given the egregious nature of their legal failings. The appellate court affirmed the district court's holding that the attorneys violated Rule 11 and section 1927 and upheld the grant of attorney's fees and costs. View "Bojicic v. DeWine" on Justia Law

Evy Orellana suffered serious injuries when a tactical canine bit her leg as a U.S. Marshals fugitive task force executed an arrest warrant for her boyfriend, Eric Trinidad. Orellana, Trinidad, and their baby lived in the basement of Trinidad’s mother’s home. The officers breached a sealed door to access the basement, and the dog bit Orellana during the search. Orellana sued the officers under Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, claiming a violation of her Fourth Amendment rights due to unreasonable search and seizure.The United States District Court for the District of Maryland denied the officers' motion to dismiss, reasoning that the case was similar enough to Bivens to apply its cause of action. The court also denied the officers' motion for summary judgment on the grounds of qualified immunity.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The appellate court held that this case presented a new context for Bivens because the officers were part of a specialized federal-state task force operating under a warrant. The court emphasized that the Supreme Court has cautioned against extending Bivens to new contexts, particularly when Congress is better suited to create a cause of action. The court concluded that special factors, including federalism concerns and the existence of alternative remedial procedures, counseled against extending Bivens in this situation. Therefore, the appellate court reversed the district court's decision, denying Orellana a Bivens remedy. View "Orellana v. Deputy United States Marshal Godec" on Justia Law

An 18-year-old defendant assisted his employer, a drug dealer, in abducting a drug addict at gunpoint. The victim, who had previously sold drugs for the dealer under threat, was lured to a parking lot, forcibly taken to the dealer’s home, and subjected to prolonged violence and threats in an attempt to extort $100,000. The victim was beaten, tied up, threatened with death, forced to ingest or absorb drugs, and ultimately locked in a closet with the door screwed shut. After approximately 28 hours, a SWAT team rescued the victim. The defendant was present throughout the ordeal, actively participated in the violence, and threatened the victim and his family.A jury in the Superior Court of Orange County convicted the defendant of aggravated kidnapping with bodily harm and a firearm enhancement. The court imposed a mandatory sentence of life without the possibility of parole (LWOP) plus a 10-year firearm enhancement, and also imposed a $300 parole revocation fine. The defendant appealed, arguing that the LWOP sentence was unconstitutional as applied to 18-year-olds under both the Eighth Amendment of the United States Constitution and the California Constitution, and that the parole revocation fine was improper because he was ineligible for parole.The California Court of Appeal, Fourth Appellate District, Division Three, held that binding precedent from the United States Supreme Court and the California Supreme Court does not extend the constitutional protections against LWOP sentences for juveniles to offenders who were 18 at the time of the crime. The court also found that the sentence was not grossly disproportionate under the California Constitution, given the defendant’s conduct and criminal history. However, the court agreed that the parole revocation fine was improper and ordered it stricken. The judgment was affirmed as modified. View "P. v. Christensen" on Justia Law

Michael Kleinman and his business, Auspro Enterprises, L.P., were charged with multiple violations of Cedar Park Code of Ordinances, resulting in Class C misdemeanor convictions in municipal court. They appealed for a trial de novo in the Williamson County Court at Law No. 5, posting appellate bonds totaling $64,881.72. They also filed pretrial applications for writs of habeas corpus, challenging the constitutionality of the ordinances on vagueness grounds. The county court at law denied relief on the merits, but acknowledged that the appellants were restrained by the cash appeal bonds.The Third Court of Appeals affirmed the county court at law’s denial of habeas relief, but did not address the merits of the appellants' arguments. Instead, it concluded that pretrial habeas relief was not available to applicants charged with fine-only offenses who were not in custody or released on bond. The court of appeals reasoned that the potential for re-arrest due to non-payment of fines was too speculative to constitute sufficient restraint.The Court of Criminal Appeals of Texas reviewed the case and disagreed with the court of appeals' conclusion. The higher court held that the appellants were indeed restrained within the meaning of the habeas corpus statutes due to the combination of the complaints, preliminary convictions, and the appellate bonds requiring their appearance in court. The court emphasized that the statutory definition of "restraint" is broad and includes any control that subjects a person to the general authority and power of the state. Consequently, the Court of Criminal Appeals reversed the judgment of the court of appeals and remanded the case for further proceedings consistent with its opinion. View "EX PARTEAUSPRO ENTERPRISES, L.P." on Justia Law

Michael Kleinman and his business, Auspro Enterprises, L.P., were charged with multiple violations of Cedar Park Code of Ordinances, operating a "head shop," which are Class C misdemeanors. Both were convicted in municipal court and sought a trial de novo in the Williamson County Court at Law No. 5. They posted appellate bonds totaling $64,881.72 and filed pretrial applications for writs of habeas corpus, challenging the constitutionality of the ordinances on vagueness grounds. The county court at law denied relief on the merits, finding that the appellants were restrained in their liberty due to the cash appeal bonds.The Third Court of Appeals affirmed the county court at law's denial of relief but did not address the merits. Instead, it concluded that pretrial habeas relief was not available to applicants charged with a fine-only offense who were not in custody or released from custody on bond. The court of appeals found that the potential for re-arrest was too speculative to constitute a sufficient restraint to justify habeas relief.The Court of Criminal Appeals of Texas reviewed the case and reversed the court of appeals' judgment. The court held that the appellants were indeed restrained within the meaning of the habeas corpus statutes due to the combination of the complaints filed against them, their preliminary convictions, and the appellate bonds they posted. The court emphasized that the definition of "restraint" under Texas law is broad and includes any control that subjects a person to the general authority and power of the state. The case was remanded to the court of appeals for further proceedings consistent with this opinion. View "EX PARTE KLEINMAN" on Justia Law

Angel Diaz, a prisoner in the custody of the New York State Department of Corrections and Community Supervision (DOCCS), filed a pro se petition for a writ of habeas corpus in the Southern District of New York. Diaz argued that due to the COVID-19 pandemic, the State could not provide him with constitutional conditions of confinement at any of its facilities, necessitating his release. He claimed that his high blood pressure and morbid obesity put him at severe risk of serious harm or death from COVID-19 and that DOCCS had no plan to protect medically vulnerable inmates like himself.The District Court referred the case to a magistrate judge, who recommended denying the petition on the grounds that Diaz's claim was not cognizable in habeas and should be brought under 42 U.S.C. § 1983 instead. The District Court adopted this recommendation, holding that Diaz's complaints about the conditions of his confinement did not challenge the validity or duration of his confinement. Diaz's request for a certificate of appealability was initially denied by the District Court but later granted by the United States Court of Appeals for the Second Circuit.The United States Court of Appeals for the Second Circuit reviewed the case and held that Diaz's claim was indeed cognizable under habeas corpus because he alleged violations of the Constitution that would require his release from all available facilities. However, the court found that Diaz failed to provide sufficient factual support to make his claim plausible. As a result, the Second Circuit affirmed the District Court's decision to dismiss the petition. View "Diaz v. Kopp" on Justia Law

James Gould was involuntarily committed to mental health facilities four times between May 2016 and July 2019. In February 2022, police found him in his West Virginia home with a twelve-gauge shotgun. A grand jury indicted him for violating 18 U.S.C. § 922(g)(4), which makes it unlawful for anyone who has been committed to a mental institution to possess a firearm. Gould pleaded guilty but appealed, arguing that the Second Amendment renders the statute facially unconstitutional.The United States District Court for the Southern District of West Virginia rejected Gould’s challenge, concluding that there is a historical basis for disarming individuals determined to be dangerous to themselves or the public. The court found that § 922(g)(4) is constitutional on its face. Gould then changed his plea to guilty and was sentenced to time served and three years of supervised release.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that § 922(g)(4) is consistent with the nation’s historical tradition of firearm regulation. The court noted that historically, legislatures incapacitated those suffering from mental illness when they posed a danger to themselves or others. Additionally, the court found that legislatures had the authority to disarm groups of people considered dangerous. The court emphasized that disarmament under § 922(g)(4) is not categorically permanent, as individuals can petition for relief to restore their firearm rights. The court concluded that § 922(g)(4) is facially constitutional because it can be applied in situations consistent with the Second Amendment. The Fourth Circuit affirmed Gould’s conviction. View "United States v. Gould" on Justia Law

Sun Valley Orchards, a New Jersey farm, was accused by the U.S. Department of Labor (DOL) of breaching an employment agreement under the H-2A nonimmigrant visa program. The DOL alleged that Sun Valley failed to provide adequate housing, meal plans, transportation, and guaranteed work hours to its workers, as stipulated in the job order. The DOL imposed civil penalties and back wages totaling hundreds of thousands of dollars through administrative proceedings.The case was first reviewed by an Administrative Law Judge (ALJ), who affirmed most of the DOL's findings but slightly modified the penalties and back wages. Sun Valley then appealed to the Administrative Review Board, which upheld the ALJ's decision. Subsequently, Sun Valley challenged the DOL's decision in the United States District Court for the District of New Jersey, arguing that the administrative proceedings violated Article III of the Constitution, among other claims. The District Court dismissed Sun Valley's claims, holding that the DOL's actions fit within the public-rights doctrine and that the agency had statutory authority to impose penalties and back wages.The United States Court of Appeals for the Third Circuit reviewed the case and held that Sun Valley was entitled to have its case decided by an Article III court. The court found that the DOL's enforcement action resembled a common law breach of contract suit, which traditionally would be heard in a court of law. The court also determined that the case did not fit within the public rights exception to Article III adjudication, as the H-2A labor certification regulations primarily concern domestic employment law rather than immigration control. Consequently, the Third Circuit reversed the District Court's decision and remanded the case with instructions to enter judgment in favor of Sun Valley. View "Sun Valley Orchards LLC v. United States Department of Labor" on Justia Law