Justia Constitutional Law Opinion Summaries

Safehouse, a Pennsylvania nonprofit corporation, was established in 2018 to address opioid abuse in Philadelphia by providing overdose prevention services, including supervised illegal drug use. Safehouse argues that its activities are motivated by a religious belief in the value of human life and that government intervention substantially burdens its religious exercise.The United States District Court for the Eastern District of Pennsylvania initially determined that Safehouse’s proposed activities did not violate 21 U.S.C. § 856(a)(2). However, the Third Circuit Court of Appeals reversed this decision, holding that Safehouse’s activities would indeed violate the statute. On remand, the District Court dismissed Safehouse’s Religious Freedom Restoration Act (RFRA) and Free Exercise counterclaims, reasoning that non-religious entities are not protected by these provisions. Safehouse appealed this dismissal.The United States Court of Appeals for the Third Circuit reviewed the case and held that the District Court erred in its interpretation. The Third Circuit determined that RFRA and the Free Exercise Clause extend protections to non-natural persons, including non-religious entities like Safehouse. The court emphasized that RFRA’s plain text and Free Exercise doctrine protect any “person” exercising religion, which includes corporations and associations. The court reversed the District Court’s dismissal of Safehouse’s RFRA and Free Exercise counterclaims and remanded the case for further consideration of whether Safehouse has plausibly pleaded these claims. The appeal by José Benitez, President of Safehouse, was dismissed due to lack of appellate standing. View "United States v. Safehouse" on Justia Law

In 2016, California voters approved Proposition 63, which established a background check regime for ammunition sales. This regime, effective from July 1, 2019, requires residents to purchase ammunition through licensed vendors in face-to-face transactions and mandates background checks before each purchase. The plaintiffs, including Olympic shooter Kim Rhode and several other individuals and organizations, challenged this regime on Second Amendment grounds, arguing it infringes on their right to keep and bear arms.The United States District Court for the Southern District of California issued a preliminary injunction against the enforcement of the ammunition background check provisions. After the Supreme Court's decision in New York State Rifle and Pistol Association v. Bruen, the Ninth Circuit vacated the preliminary injunction and remanded the case for further proceedings. On remand, the district court consolidated the hearing on the motion for a preliminary injunction with a trial on the merits and permanently enjoined California from enforcing the ammunition background check provisions, concluding they violated the Second Amendment.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit applied the two-step framework from Bruen, determining that California's ammunition background check regime implicates the plain text of the Second Amendment and that the government failed to show the regime is consistent with the Nation's historical tradition of firearm regulation. The court held that the regime meaningfully constrains the right to keep operable arms and does not survive scrutiny under the Bruen analysis. Consequently, the Ninth Circuit affirmed the district court's grant of a permanent injunction against the enforcement of California's ammunition background check regime. View "Rhode v. Bonta" on Justia Law

Jessica Bates, a devout Christian and widowed mother of five, applied to adopt children through the Oregon Department of Human Services (ODHS). Her application was denied because she could not comply with Oregon Administrative Rule § 413-200-0308(2)(k), which requires prospective adoptive parents to "respect, accept, and support" the sexual orientation, gender identity, and gender expression of children. Bates objected to using preferred pronouns and taking children to medical appointments for gender transitions, citing her religious beliefs. She sued, claiming the policy violated her First Amendment rights to free speech and free exercise of religion.The United States District Court for the District of Oregon denied Bates's motion for preliminary injunctive relief. The court found that the policy was neutral and generally applicable, thus subject to rational basis review, which it survived. The court also concluded that the policy, as applied to Bates, compelled and restricted speech based on content and viewpoint, triggering strict scrutiny. However, it held that the policy was narrowly tailored to serve a compelling state interest in protecting LGBTQ children.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Oregon's application of § 413-200-0308(2)(k) to Bates triggered strict scrutiny for both her free speech and free exercise claims. The court found that the policy restricted and compelled speech based on content and viewpoint and was not neutral or generally applicable. The court concluded that Oregon's policy was not narrowly tailored to serve a compelling state interest, as less restrictive means were available to protect LGBTQ children. The court remanded the case with instructions to enter a preliminary injunction enjoining ODHS from applying the rule to Bates in deeming her ineligible for certification as an adoptive parent. View "Bates v. Pakseresht" on Justia Law

The case involves Delta Air Lines, Inc. and PacifiCorp, both of which are centrally assessed businesses in Oregon. Under Oregon law, centrally assessed businesses are taxed on their intangible property, unlike locally assessed businesses. Delta and PacifiCorp challenged this tax, arguing it violated the state and federal constitutions by not being uniform and by violating equal protection and privileges clauses.The Oregon Tax Court addressed both cases in a single opinion, ruling in favor of Delta by finding the tax on intangible property unconstitutional for air transportation businesses. However, it ruled against PacifiCorp, upholding the tax for utilities. The Tax Court concluded that there were no genuine differences between the intangible property of centrally assessed air transportation businesses and locally assessed businesses, but found differences for utilities.The Oregon Supreme Court reviewed the case, focusing on whether the tax classifications were rationally related to a legitimate governmental purpose. The court reversed the Tax Court's decision regarding Delta, holding that the tax on intangible property for centrally assessed businesses is constitutional. The court found that the legislature's decision to tax intangible property of centrally assessed businesses, but not locally assessed ones, was rationally related to legitimate purposes such as administrative efficiency, expertise in valuation, and balancing revenue against resources. The court also affirmed the Tax Court's decision regarding PacifiCorp in a separate opinion, maintaining the tax's constitutionality for utilities. The case was remanded to the Tax Court for further proceedings. View "Delta Air Lines, Inc. v. Dept. of Revenue" on Justia Law

Kyle M. Fitzgerald was stopped by Maine State Police on Interstate 295 for not wearing a seatbelt and driving significantly below the speed limit. During the stop, Fitzgerald and her passengers gave inconsistent and confusing answers about their destination and how long they had known each other. One passenger was particularly anxious, another was standoffish, and a third pretended to be asleep. The police officer, Trooper Young, requested a drug detection dog, which arrived seventy-seven minutes after the stop began. The dog indicated the presence of drugs, leading to a search that uncovered a substantial quantity of illegal drugs.The trial court (Cumberland County) granted Fitzgerald’s motion to suppress the evidence obtained from the search, finding that the officers lacked probable cause. The court determined that the reasonable suspicion justifying the initial stop had been resolved well before the dog arrived, and there was no reasonable suspicion of illegal drug activity to justify prolonging the detention.The Maine Supreme Judicial Court reviewed the case and affirmed the trial court’s decision. The court held that the duration of Fitzgerald’s detention exceeded the constitutional limit once the officer confirmed the identity of one of the passengers, which was thirty-four minutes before the drug detection dog arrived. The court concluded that the officer’s suspicion of illegal drug activity was based on a general hunch rather than an articulable and objectively reasonable suspicion. Therefore, the prolonged detention violated the Fourth Amendment, and the evidence obtained from the search was rightly suppressed. View "State v. Fitzgerald" on Justia Law

Markhel D’John Harris-Franklin was charged with being an armed career criminal in possession of ammunition, violating 18 U.S.C. §§ 922(g)(1) and 924(e). He moved to dismiss the indictment, alleging a violation of the Speedy Trial Act and that 18 U.S.C. § 922(g)(1) is unconstitutional under the Second Amendment. The district court denied his motions, and he was found guilty by a jury.The United States District Court for the District of Minnesota initially handled the case. Harris-Franklin made multiple motions to extend the time for filing pretrial motions, which the court granted, finding that the ends of justice served by the continuances outweighed the best interests of the public and Harris-Franklin in a speedy trial. After a competency evaluation and the appointment of new counsel, Harris-Franklin moved to dismiss the indictment for violation of the Speedy Trial Act and challenged the constitutionality of 18 U.S.C. § 922(g)(1). The magistrate judge recommended denying the motions, and the district court adopted this recommendation. Harris-Franklin did not renew his motion to dismiss before trial, and he was convicted.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Harris-Franklin’s rights under the Speedy Trial Act were not violated, as the district court properly excluded certain periods of delay from the 70-day calculation. The court also found that circuit precedent foreclosed Harris-Franklin’s Second Amendment argument, affirming the district court’s denial of his motions to dismiss. The court concluded that the ends-of-justice continuances granted by the district court were reasonable and necessary to allow new counsel time to prepare for trial. View "United States v. Harris-Franklin" on Justia Law

Raymond Antonio Lewis was convicted by a jury of being a felon in possession of a firearm and possession of methamphetamine with intent to distribute. The incident occurred on December 20, 2018, when Officer John Buford responded to a report of shots fired and encountered Lewis, who was found with firearms and methamphetamine. Lewis was identified as a felon and arrested.The United States District Court for the Eastern District of Arkansas handled the case. Lewis was indicted in May 2021, with a superseding indictment in November 2022. His trial was delayed multiple times due to continuance requests by his counsel and other procedural matters. Lewis filed motions to suppress Officer Buford’s testimony and to sever the trial, both of which were denied by the district court. The jury found Lewis guilty on two counts but acquitted him on a third count of possessing firearms in furtherance of drug distribution. He was sentenced to 156 months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Lewis argued that the district court erred in denying his pretrial motions, that the preindictment delay violated his Fifth Amendment rights, that the delay between indictment and trial violated his Sixth Amendment rights, and that the evidence was insufficient to support his conviction. The Eighth Circuit affirmed the district court’s decisions, holding that the exclusionary rule did not apply to the officer’s testimony despite the policy violation, that the denial of the motion to sever was not an abuse of discretion, that the preindictment delay did not violate due process, and that the delay in trial did not violate the Sixth Amendment. The court also found the evidence sufficient to support the convictions. View "United States v. Lewis" on Justia Law

The case involves several states and individual plaintiffs challenging an executive order issued by President Trump, which denies citizenship to children born in the United States to parents who are temporarily or unlawfully present. The district court issued a universal preliminary injunction to prevent the implementation of the executive order. The defendants appealed, arguing that the states lack standing, the preliminary injunction was improperly issued, and its scope was too broad.The United States District Court for the Western District of Washington granted a temporary restraining order and later a preliminary injunction, concluding that the states had standing and that the executive order likely violated both the Constitution and the Immigration and Nationality Act (INA). The court found that the states would suffer irreparable harm without the injunction and that the balance of equities and public interest favored the plaintiffs. The district court issued a universal injunction, determining that a geographically limited injunction would not provide complete relief to the states.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The court held that the executive order was unconstitutional as it contradicted the Fourteenth Amendment, which grants citizenship to all persons born in the United States and subject to its jurisdiction. The court found that the states had standing due to the economic harm they would suffer from the loss of federal reimbursements and the administrative burden of complying with the executive order. The court also concluded that the universal preliminary injunction was necessary to provide complete relief to the states, as a geographically limited injunction would not address the administrative and financial burdens imposed by the executive order. View "Washington v. Trump" on Justia Law

Terrence Hammock, a detainee at the Baltimore County Detention Center (BCDC), filed a lawsuit alleging severe violations of his constitutional rights. He claimed that BCDC served him rotten and unsafe food, causing him to get sick multiple times and lose weight. Additionally, Hammock, a practicing Muslim, alleged that he was denied the ability to attend Jum’ah services, a central practice of Islam, throughout his detention from September 2019 to at least March 2022.The United States District Court for the District of Maryland dismissed Hammock’s claims. The court found that his allegations regarding the food did not meet the standard of a “serious deprivation of a basic human need” under the Eighth and Fourteenth Amendments. It also held that the denial of Jum’ah services was justified by legitimate penological interests, particularly during the COVID-19 pandemic. The court denied Hammock’s motion for appointed counsel, stating that the case had not yet proceeded to discovery or trial.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court erred in dismissing Hammock’s claims. The appellate court held that Hammock sufficiently pleaded a claim of deliberate indifference based on the conditions of confinement, specifically the provision of rotten and mice-bitten food. The court also found that Hammock adequately pleaded a First Amendment claim, as the defendants did not present a penological interest to justify the denial of Jum’ah services for the entire period in question. The Fourth Circuit reversed the district court’s dismissal of Hammock’s claims and remanded the case for further proceedings, including the appointment of counsel for Hammock. View "Hammock v. Watts" on Justia Law

Zachary Hebb challenged a municipal ordinance in Asheville, North Carolina, that prohibited the use of amplified sound within 150 feet of a medical clinic during its operating hours. Hebb, who regularly protested outside a Planned Parenthood clinic, argued that the ordinance infringed on his First and Fourteenth Amendment rights. He preferred using a sound amplifier to communicate his message without yelling. After being cited for violating the ordinance, Hebb filed a lawsuit under 42 U.S.C. § 1983, seeking declaratory relief, a permanent injunction, nominal damages, and attorneys' fees.The United States District Court for the Western District of North Carolina initially granted Hebb a preliminary injunction, finding that the ordinance likely violated his First Amendment rights and was unconstitutionally vague under the Fourteenth Amendment. The court denied Asheville's motions to dismiss and later granted Hebb's motion for summary judgment, permanently enjoining the ordinance and awarding nominal damages for the due process claim.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's denial of Asheville's motions to dismiss Hebb's First Amendment claim but reversed the summary judgment in Hebb's favor, finding that there were disputed factual and legal questions that warranted further consideration. The court held that the ordinance was content-neutral and served a significant government interest in protecting patients from harmful noise. However, it concluded that the entry of summary judgment was premature.Regarding Hebb's due process claim, the Fourth Circuit held that the 2021 version of the ordinance was not unconstitutionally vague as applied to prevent Hebb from using a plastic cone. The court found that the ordinance provided adequate notice of what conduct was prohibited and included sufficient standards to prevent arbitrary enforcement. Consequently, the court reversed the district court's decision on the due process claim and remanded with instructions to dismiss it. View "Hebb v. City of Asheville" on Justia Law