Justia Constitutional Law Opinion Summaries

Robust Missouri Dispensary 3, LLC, operates a dispensary in Florissant, an incorporated city in St. Louis County. After Missouri voters approved a constitutional amendment legalizing non-medical marijuana and allowing local governments to impose a 3 percent sales tax, both Florissant and St. Louis County enacted such a tax. Robust collected and remitted the tax to Florissant but not to St. Louis County. The Missouri Department of Revenue notified Robust that it must also remit the tax to St. Louis County. Robust sought declaratory and injunctive relief, arguing that the constitutional amendment only allows a village, town, or city in an incorporated area to impose the tax, not a county.The Circuit Court of St. Louis County granted summary judgment in favor of St. Louis and St. Charles Counties, finding that the definition of "local government" includes a county in an incorporated area. The court reasoned that excluding counties from the definition would frustrate the amendment's purpose of protecting public health. Robust appealed the decision.The Supreme Court of Missouri reviewed the case de novo and found that the plain language of the constitutional amendment distinguishes between incorporated and unincorporated areas. The court held that in an incorporated area, only a village, town, or city can impose the 3 percent sales tax, while in an unincorporated area, only a county can impose the tax. The court vacated the circuit court's judgment and remanded the case to enter judgment in favor of Robust, ruling that St. Louis County cannot impose the tax on sales within Florissant. View "Robust Missouri Dispensary 3, LLC v. St. Louis County" on Justia Law

In 2020, C.S. pleaded guilty to two charges in the Lafayette County circuit court: possession of a controlled substance for possessing more than 35 grams of marijuana, and unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance. He was sentenced to seven years and four years of imprisonment, respectively, but the execution of his sentence was suspended. After his probation was revoked in 2021, C.S. was incarcerated. Following the approval of Amendment 3 in 2022, which allows expungement for certain marijuana offenses, C.S. filed a petition to expunge both convictions.The Lafayette County circuit court expunged C.S.'s conviction for possession of a controlled substance but denied the petition to expunge the conviction for unlawful use of a weapon. The court reasoned that the unlawful use of a weapon is a "weapons offense" and not eligible for expungement under the Missouri Constitution's article XIV, § 2.10(7)(a)c.The Supreme Court of Missouri reviewed the case and affirmed the circuit court's judgment. The court held that the offense of unlawful use of a weapon for possessing a firearm while knowingly in possession of a controlled substance is not a "marijuana offense" within the meaning of article XIV, § 2 of the Missouri Constitution. The court concluded that the primary purpose of the statute criminalizing unlawful use of a weapon is to prevent conduct that endangers others, and therefore, it is not eligible for expungement under the constitutional provision. View "C.S. v. Missouri State Highway Patrol Criminal Justice Information Service" on Justia Law

In 2016, the Village of Schaumburg enacted an ordinance requiring commercial and multifamily properties to route fire alarm signals directly to a regional emergency-dispatch center. This ordinance aimed to reduce fire department response times and had financial benefits for the Village. Several alarm companies, which previously used a different model for transmitting alarm signals, claimed that the ordinance caused them to lose business and led to more expensive and lower-quality alarm services for customers.The alarm companies sued the Village, alleging that the ordinance violated the Contracts Clause and tortiously interfered with their contracts and prospective economic advantage. The United States District Court for the Northern District of Illinois initially dismissed the federal claims and relinquished jurisdiction over the state-law claims. On appeal, the Seventh Circuit reversed in part, allowing the Contracts Clause claim to proceed. However, on remand, the district court granted summary judgment for the Village, finding that the alarm companies failed to provide evidence that the ordinance caused customers to breach existing contracts or that the Village intended to interfere with their business relationships.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that the alarm companies did not present sufficient evidence to show that the ordinance caused customers to breach contracts or that the Village acted with the intent to harm the alarm companies' businesses. The court also found that the alarm companies' claims of tortious interference with prospective economic advantage failed because the Village's actions were motivated by public safety and financial considerations, not a desire to harm the alarm companies. View "Alarm Detection Systems, Inc. v. Village of Schaumburg" on Justia Law

CoreCivic, Inc. has contracted with the federal government since 1996 to operate a private immigration detention center in Elizabeth, New Jersey. In 2023, CoreCivic planned to renew its contract, but New Jersey passed a law (AB 5207) prohibiting new, expanded, or renewed contracts for civil immigration detention. CoreCivic sued, arguing that the law violates the Supremacy Clause by infringing on intergovernmental immunity and being preempted by federal law. The United States supported CoreCivic, emphasizing the detention center's critical role in federal immigration enforcement.The United States District Court for the District of New Jersey granted summary judgment in favor of CoreCivic. The court found that AB 5207 interferes with the federal government's discretion in detaining aliens, violating intergovernmental immunity and being preempted by federal law. New Jersey appealed the decision.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit held that AB 5207 directly regulates the federal government by effectively banning contracts for immigration detention, a core federal function. The court emphasized that the law's impact on federal operations is substantial, as it would cripple ICE's ability to detain and remove aliens efficiently. The court concluded that New Jersey's law violates intergovernmental immunity and is unconstitutional as applied to CoreCivic. View "CoreCivic, Inc. v. Governor of New Jersey" on Justia Law

Linda Cabello Garcia, a temporary U visa holder, sought to adjust her status to lawful permanent resident under 8 U.S.C. § 1255(m). USCIS denied her application because she failed to submit the required medical form. Cabello argued that USCIS lacked the authority to request this form and that her severe anxiety prevented her from complying.The United States District Court for the Western District of Washington dismissed Cabello's complaint for lack of jurisdiction, citing 8 U.S.C. § 1252(a)(2)(B)(i), which precludes district courts from reviewing discretionary denials of adjustment of status. Cabello appealed, arguing that her challenge to the medical form requirement was a collateral challenge to a USCIS policy, which should be permissible under Nakka v. United States Citizenship & Immigr. Servs.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The court held that 8 U.S.C. § 1252(a)(2)(B)(i) strips district courts of jurisdiction to review discretionary denials of adjustment of status under 8 U.S.C. § 1255(m). The court rejected Cabello's argument that her claim was a collateral challenge, noting that once an application for adjustment is denied, the claim ceases to be collateral. The court also addressed Cabello's constitutional arguments, concluding that she must pursue her claims through the petition for review process, even if it requires her to remain in the United States unlawfully to be placed in removal proceedings. The court found no constitutional entitlement for Cabello to have her claim reviewed in district court instead of through the established process. View "Cabello Garcia v. Citizenship and Immigration Services" on Justia Law

Plaintiffs Ariana Cortes and Logan Karam, baristas at Starbucks stores in Buffalo and Depew, New York, filed a lawsuit challenging the constitutionality of the statutory tenure protections for members of the National Labor Relations Board (NLRB). They argued that these protections place an impermissible limitation on the President’s executive power. Both plaintiffs had previously filed decertification petitions with the NLRB, which were dismissed due to pending unfair labor practice proceedings against Starbucks.The United States District Court for the District of Columbia dismissed the case for lack of jurisdiction. The court concluded that the plaintiffs lacked standing because their petitions had been dismissed, and they had not sought reinstatement. Additionally, the court agreed with the NLRB that the plaintiffs failed to allege compensable harm, which was necessary for their claim.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. By this time, the plaintiffs had abandoned their claims for injunctive relief and sought only a declaratory judgment that the NLRB members’ tenure protections were unconstitutional. The NLRB, aligning with the Acting Solicitor General, no longer defended the constitutionality of the tenure protections. The court held that there was no longer a live case or controversy because the parties were not sufficiently adverse; both sides agreed on the unconstitutionality of the tenure protections. Consequently, the court affirmed the district court’s judgment dismissing the case for lack of jurisdiction. View "Cortes v. National Labor Relations Board" on Justia Law

Linda Martin filed a class action lawsuit against the FBI, alleging that the Notice of Seizure provided to property owners did not meet the Due Process requirements under the Fifth Amendment. The FBI had seized $40,200 from Martin's safe deposit box and issued a Notice of Seizure, which Martin claimed lacked specific legal or factual bases for the seizure, thus denying her a meaningful opportunity to respond. Martin sought declaratory and injunctive relief for herself and a proposed nationwide class of individuals who had received similar notices.The United States District Court for the District of Columbia dismissed Martin's individual claim as moot after the FBI returned her seized property. The court also dismissed the class action for failure to exhaust administrative remedies and for failure to state a plausible Due Process claim. The court found that Martin had an adequate opportunity to present her Due Process challenge during the administrative proceedings and that her claim was moot because the FBI had returned her property.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the district court's dismissal of Martin's individual claim as moot, as the FBI had returned her property. The court also dismissed the appeal of the class certification judgment for lack of jurisdiction, noting that Martin had not challenged the denial of class certification in her appellate briefs. The court concluded that without a certified class, it lacked jurisdiction to review the district court's merits rulings on the Due Process and exhaustion claims. View "Martin v. FBI" on Justia Law

A healthcare provider, Neurological Surgery Practice of Long Island, PLLC, provides out-of-network medical services governed by the No Surprises Act. This Act requires out-of-network providers to seek compensation from the patient’s healthcare plan rather than billing patients directly. If a provider and a healthcare plan cannot agree on a compensation amount, an independent dispute resolution (IDR) process is used. Neurological Surgery alleges that a backlog of disputes has resulted in unpaid or delayed reimbursements due to the Departments of Health and Human Services, Treasury, and Labor failing to implement the Act properly, violating the Administrative Procedure Act (APA) and the Due Process Clause of the Fifth Amendment.The United States District Court for the Eastern District of New York dismissed Neurological Surgery’s claims. The court concluded that the claims were moot due to the reopening of the IDR portal, Neurological Surgery lacked standing to compel the Departments to enforce the Act’s deadlines on third parties, and the claims regarding the Departments’ failure to certify a sufficient number of arbitrators and provide guidance on New York’s surprise billing law were foreclosed by the APA.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court’s judgment, agreeing that the challenge to the pause of the IDR portal was moot since the portal was operational. The court also held that Neurological Surgery lacked standing to compel the Departments to enforce deadlines on healthcare plans and IDR entities, as the injury was caused by third parties, not the Departments. Additionally, the court found that the challenge to the Departments’ failure to certify a sufficient number of IDR entities was foreclosed by the APA, as the Act did not specify discrete actions required by the Departments. Lastly, the court held that the challenge to the Departments’ failure to issue guidance on New York’s surprise billing law failed to state a claim under the APA. View "Neurological Surgery v. Department of Health & Human Services" on Justia Law

In 2012, the appellant was charged with DUI and resolved the charge through acceptance into an Accelerated Rehabilitative Disposition (ARD) program. In 2020, he was again charged with DUI and convicted based on a guilty plea. The Pennsylvania Department of Transportation (PennDOT) received notice of his conviction and suspended his license for one year under Section 3804(e) of the Vehicle Code, which mandates a suspension for DUI convictions unless the individual has no prior offenses, including ARD acceptances within the past ten years.The appellant appealed the suspension to the Cumberland County Court of Common Pleas, which upheld the suspension despite the Superior Court's ruling in Commonwealth v. Chichkin, which disapproved of enhanced criminal sentencing based on an earlier ARD. The county court reasoned that the license suspension was a civil penalty and did not implicate the constitutional safeguards applicable in criminal matters. The Commonwealth Court affirmed this decision, agreeing that the suspension was a civil consequence and should be upheld as long as PennDOT acted in accordance with the law.The Supreme Court of Pennsylvania reviewed the case to determine whether the license suspension violated due process, given that the appellant's prior ARD acceptance was not a criminal conviction. The court held that the suspension did not violate due process. It reasoned that the suspension was based on the 2020 DUI conviction, not the prior ARD acceptance, and that the legislative scheme was rationally related to the state's interest in deterring drunk driving and ensuring public safety. The court affirmed the Commonwealth Court's order, upholding the one-year license suspension. View "Ferguson v. Dept. of Transportation" on Justia Law

The defendant was convicted of three first-degree murders and several related offenses, including rape and sexual penetration with a foreign object, committed between 1988 and 1998 in Stockton and Oakland, California. The prosecution’s case relied heavily on DNA evidence linking the defendant to the victims, as well as ballistics evidence connecting the same firearm to multiple murders. The victims were found in isolated areas, often bound, and killed by gunshots to the head. The defendant was also convicted of the rape and kidnapping of another woman, Yvette R., who survived and testified. The defense presented no evidence at the guilt phase but, during the penalty phase, offered expert testimony about the defendant’s abusive childhood and mental health issues, including sexual sadism.The San Joaquin County Superior Court jury found the defendant guilty on all counts, found true the special circumstance allegations (multiple murders and murder during rape), and returned death verdicts for each murder. The court imposed a death sentence and additional terms for the noncapital offenses. The defendant’s appeal to the Supreme Court of California was automatic.The Supreme Court of California reviewed numerous claims, including alleged instructional errors, challenges to the constitutionality of special circumstances, claims of prosecutorial misconduct, and issues related to victim impact evidence and penalty phase instructions. The court held that there was no substantial evidence to support instructions on voluntary manslaughter or that the victims were dead at the time of sexual assault, and found no reversible error in the instructions given. The court also rejected challenges to the constitutionality of California’s death penalty scheme and the admission of victim impact evidence. The court found harmless any error in failing to redefine reasonable doubt at the penalty phase and in the response to a jury question about parole eligibility. The judgment was affirmed in its entirety, with a minor correction to the firearm enhancement terms. View "People v. Choyce" on Justia Law