Justia Constitutional Law Opinion Summaries

Defendants Jibril Adamu and Jean-Claude Okongo Landji were involved in an international narcotics trafficking conspiracy, using a private aircraft to transport cocaine from South America to Africa and Europe. Landji owned an aviation charter business and Adamu was his co-pilot. They were arrested in Croatia in 2018 after flying a test shipment of cocaine. Their cell phones, containing incriminating evidence, were seized. Both defendants were extradited to the United States and charged with conspiracy to distribute and possess with intent to distribute cocaine.The United States District Court for the Southern District of New York convicted both defendants following a jury trial. They were sentenced to 120 months’ imprisonment and five years’ supervised release. The defendants appealed, arguing that the government lacked jurisdiction under 21 U.S.C. § 959, violated their Sixth Amendment rights by using privileged information, and erred in admitting data extracted from their cell phones.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that 21 U.S.C. § 959 applies extraterritorially, affirming the government’s jurisdiction. It also found no Sixth Amendment violation, as the district court correctly determined that the government did not use privileged information in its prosecution. The court concluded that the cell phone data was properly authenticated and its admission did not violate the Confrontation Clause. The court noted that any potential error in admitting the cell phone data was harmless given the overwhelming evidence of guilt.The Second Circuit affirmed the judgment of the district court, upholding the convictions and sentences of both defendants. View "United States v. Adamu" on Justia Law

The case involves the Trump administration's "Remain in Mexico" policy, also known as the Migrant Protection Protocols (MPP), which required asylum seekers arriving at the U.S. southern border to stay in Mexico while their claims were processed. The policy was first implemented in 2019, causing significant hardships for asylum seekers, including unsafe living conditions and limited access to legal representation. The Biden administration terminated the policy in 2021, but the second Trump administration sought to reimplement it in January 2025.The Central District of California reviewed the case and granted an emergency stay of the policy's reimplementation, citing violations of the Administrative Procedure Act (APA) and constitutional rights. The district court found that the policy severely impeded asylum seekers' access to legal representation and created dangerous conditions for them in Mexico. The government appealed the stay, arguing that it interfered with its discretionary authority to manage immigration and foreign policy.The United States Court of Appeals for the Ninth Circuit reviewed the appeal. The court denied the plaintiffs' motion to dismiss the appeal and partially granted the government's motion for a stay pending appeal. The Ninth Circuit limited the district court's stay to apply only to the current and future clients of the Immigrant Defenders Law Center (ImmDef), allowing the government to reimplement the policy for other asylum seekers. The court found that ImmDef had standing to challenge the policy and that the reimplementation likely violated the APA by infringing on asylum seekers' statutory rights to apply for asylum with the assistance of counsel. View "Immigrant Defenders Law Center v. Noem" on Justia Law

In early 2025, the National Institutes of Health (NIH) and the Department of Health and Human Services (HHS) implemented a new policy prohibiting NIH from funding certain categories of scientific research grants. Two groups of plaintiffs, including private research organizations, individual researchers, and several states, sued, alleging that the new policy and the resulting grant terminations violated the Administrative Procedure Act (APA) and the U.S. Constitution. They argued that the policy was arbitrary and capricious, as the prohibited research categories were undefined and the rationale for discontinuing the research was circular.The United States District Court for the District of Massachusetts held a trial on the merits and ruled in favor of the plaintiffs, finding the agencies' actions to be "breathtakingly arbitrary and capricious." The court set aside the new policy and related grant terminations as illegal under the APA. The court found that the decisions were based on circular reasoning, lacked a rational connection to the facts, and ignored significant reliance interests. The government then moved for a stay of the district court's order pending appeal, which the district court denied.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the district court had jurisdiction to review the agency action under the APA and to grant declaratory relief. The court found that the district court's orders did not enforce a contractual obligation to pay money but rather provided declaratory relief that set aside agency actions as arbitrary and capricious. The court also determined that the grant terminations were reviewable under the APA and that the Department had failed to show a likelihood of success on the merits. The court denied the Department's motion for a stay, concluding that the balance of equities and the public interest favored the plaintiffs. View "American Public Health Assn v. National Institutes of Health" on Justia Law

Jessica Nelson discovered errors in the informational section of her credit report from Experian, including an incorrect spelling of her maiden name, addresses to her mother’s home and attorney’s office, and a variation of her social security number. She spent time and money attempting to correct these errors by sending letters to Experian, which directed her to contact the furnishers of the information. Despite her efforts, some errors remained uncorrected, and Experian did not inform her of the corrections made.Nelson sued Experian in Alabama state court under the Fair Credit Reporting Act, alleging that Experian failed to conduct a reasonable reinvestigation into her information. Experian removed the case to federal court and sought judgment in its favor. The district court denied Experian’s motion for judgment on the pleadings, concluding that Nelson had standing based on her out-of-pocket expenses and time spent correcting the information. However, the district court later granted summary judgment in Experian’s favor on the merits of Nelson’s claim. Nelson appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case and focused on whether Nelson had standing under Article III. The court held that spending money and time to correct errors on a credit report that has not been published to a third party or otherwise affected the plaintiff does not satisfy the standing requirements of Article III. The court found that Nelson’s efforts to correct the information were self-imposed and did not constitute a concrete injury. Additionally, the court rejected Nelson’s argument that the errors increased her risk of identity theft, finding it too speculative to constitute an imminent harm.The Eleventh Circuit vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Nelson v. Experian Information Solutions Inc." on Justia Law

Matthew Warman, a former graduate student at Mount St. Joseph University (MSJU), objected to taking the COVID-19 vaccine on religious grounds. When MSJU required all students and employees to be vaccinated, Warman applied for a religious exemption. He was allegedly detained by two MSJU Police Department officers who attempted to convince him to get vaccinated and disparaged his religious beliefs. Warman later sued MSJU, MSJPD, and several individual employees.The United States District Court for the Southern District of Ohio dismissed Warman’s complaint. The court dismissed his free exercise, equal protection, and disability discrimination claims with prejudice and dismissed MSJPD from all counts with prejudice. Warman appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of Warman’s free exercise, equal protection, and disability discrimination claims. However, the court found that Warman plausibly pleaded that the two officers who detained him violated his Fourth Amendment rights. Consequently, the court reversed the district court’s dismissal of Warman’s wrongful detention claim and reinstated the claim against those defendants. The court also vacated the district court’s declination of supplemental jurisdiction over Warman’s state-law claims and remanded for reconsideration.In summary, the Sixth Circuit affirmed the dismissal of most of Warman’s claims but reinstated his Fourth Amendment wrongful detention claim against the two officers and remanded the state-law claims for further consideration. View "Warman v. Mount St. Joseph University" on Justia Law

A Virginia statute established procedures for internet broadband service providers to access railroad property and lay cable across tracks. The Association of American Railroads (AAR) challenged the statute, arguing it was preempted by federal law and violated the Takings Clause of the U.S. Constitution. The district court dismissed the case, ruling that AAR lacked standing to bring the claims because they required the participation of individual member railroads.The United States District Court for the Eastern District of Virginia held that AAR lacked associational standing for both its preemption and Takings Clause claims. The court found that the preemption claim required a fact-intensive inquiry into whether the statute unreasonably burdened rail transportation, necessitating individual member participation. Similarly, the Takings Clause claim required individualized proof of inadequate compensation for each crossing, which also required member participation.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that AAR had standing to pursue its preemption claims, as these could be litigated without the participation of individual members. The court reasoned that the preemption claims involved general judgments about the statute's nature and operation, not specific operations of individual railroads. However, the court affirmed the district court's ruling on the Takings Clause claim, agreeing that it required individualized proof of compensation for each crossing, necessitating member participation.The Fourth Circuit thus affirmed the district court's judgment in part, reversed it in part, and remanded the case for further proceedings consistent with its opinion. View "Association of American Railroads v. Hudson" on Justia Law

The State filed a petition alleging that A.K., a three-year-old child, was in need of care. Both parents entered no contest statements, and the court found A.K. to be a child in need of care. The father later died, leaving the mother as the sole subject of the termination proceedings. The State filed a motion to terminate the mother's parental rights, and during a pretrial conference, the mother did not appear, but her attorney did. The court set a date for a "proffer trial" under K.S.A. 38-2248(f). At the proffer trial, the mother was absent, and her attorney objected to proceeding by proffer, leading the court to set a full trial date. The mother did not appear at the trial, and her substitute counsel did not object to proceeding by proffer. The court terminated the mother's parental rights based on the State's proffer of evidence.The Johnson District Court terminated the mother's parental rights based on the State's proffer of evidence. The mother appealed, arguing that the court had no authority to proceed by proffer because she had instructed her counsel to object. She also argued that K.S.A. 38-2248(f) violated procedural due process. The Court of Appeals affirmed the district court's decision, rejecting the mother's claims.The Kansas Supreme Court reviewed the case and held that the district court misapplied K.S.A. 38-2248(f) by terminating the mother's parental rights based on a proffer alone. The court clarified that while K.S.A. 38-2248(f) permits a proffer against an absent party who has not instructed their counsel to object, it does not allow the district court to make a finding of unfitness or terminate parental rights based solely on the proffer. The court reversed the judgments of both the Court of Appeals and the district court and remanded the case for further proceedings. View "In re A.K. " on Justia Law

In 2020, Mujera Benjamin Lung’aho threw Molotov cocktails that damaged or destroyed three police cars belonging to state and municipal police departments. He was indicted under 18 U.S.C. § 844(f)(1) for maliciously destroying law enforcement vehicles possessed by local police departments receiving federal financial assistance. Lung’aho moved to dismiss the indictment, arguing that the statute was unconstitutional as applied to him.The United States District Court for the Eastern District of Arkansas denied Lung’aho’s motion to dismiss. The court held that while the Property Clause did not apply because the police cars were not federal property and were not bought with federal financial assistance, the prosecution was constitutional under the Spending Clause coupled with the Necessary and Proper Clause.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss de novo. The court held that Lung’aho’s conduct fell within the plain meaning of 18 U.S.C. § 844(f)(1) and that the statute was constitutional as applied to him. The court reasoned that under the Spending Clause and the Necessary and Proper Clause, Congress has the authority to ensure that federal funds are spent for the general welfare, and criminalizing the arson of police cars from departments receiving federal funding is a rational means of safeguarding federal dollars. The court affirmed the district court’s judgment, concluding that § 844(f)(1) was constitutionally applied to Lung’aho. View "United States v. Lung'aho" on Justia Law

The case involves the Stored Communications Act, which allows the government to subpoena electronic communication service providers for user records and seek court orders to prohibit disclosure of such subpoenas. The government requested and obtained a court order allowing it to prohibit disclosure of any subpoena related to a particular investigation for one year, provided the government determined that disclosure would risk one of the harms specified in the Act. The government then served a subpoena on X Corp. with the nondisclosure order attached. X Corp. moved to vacate the nondisclosure order, arguing it did not comply with the Act. The district court denied X Corp.'s motion.The United States District Court for the District of Columbia issued the nondisclosure order and denied X Corp.'s motion to vacate it. X Corp. appealed the decision, arguing that the order did not comply with the Stored Communications Act and violated the First Amendment. The district court relied on ex parte evidence in its decision, which X Corp. also challenged.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and reversed the district court's decision. The appellate court held that the nondisclosure order did not conform to the Stored Communications Act because the court did not find "reason to believe" that disclosure of the subpoena would risk a statutory harm. The court emphasized that the statute requires the court, not the government, to make this determination. The appellate court did not address X Corp.'s First Amendment argument or the issue of the district court's reliance on ex parte evidence, as the statutory ruling was sufficient to resolve the case. View "In re Sealed Case" on Justia Law

Jose E. Amstutz, a police officer employed by Harris County Precinct 6, was terminated after his wife filed a police report alleging domestic abuse. Amstutz was placed on leave and later terminated following an internal investigation that found he violated several policies. Amstutz claimed his wife had a history of making false allegations and had informed his supervisors about this potential. After his termination, Amstutz struggled to find other law enforcement employment, which he attributed to the General Discharge noted in his F-5 report.The United States District Court for the Southern District of Texas dismissed Amstutz’s Age Discrimination in Employment Act (ADEA) claims for failure to exhaust administrative remedies and for not responding to the timeliness challenge. The court also dismissed his 42 U.S.C. § 1983 claims, finding that he had not pleaded a protected property interest in his at-will employment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s dismissal of the ADEA claims, agreeing that Amstutz failed to address the timeliness challenge, thus waiving opposition to that argument. The court also affirmed the dismissal of the § 1983 claims, concluding that Amstutz did not identify any independent source of law that would create a property interest in his employment. The court found that Amstutz’s employment was at-will and that he did not have a legitimate claim of entitlement to continued employment. Consequently, the court also dismissed Amstutz’s Monell claim against Harris County, as there was no underlying constitutional violation. The court affirmed the district court’s denial of leave to amend, finding no abuse of discretion. View "Amstutz v. Harris County" on Justia Law