Justia Daily Opinion Summaries

Constitutional Law
June 21, 2024

Table of Contents

Moore v. United States

Constitutional Law, Tax Law

US Supreme Court

United States Trustee v. John Q. Hammons Fall 2006, LLC

Bankruptcy, Civil Procedure, Constitutional Law

US Supreme Court

United States v. Carpenter

Constitutional Law, Criminal Law

US Court of Appeals for the Seventh Circuit

United States v. Deng

Constitutional Law, Criminal Law

US Court of Appeals for the Eighth Circuit

Bacon v. Woodward

Constitutional Law, Government & Administrative Law

US Court of Appeals for the Ninth Circuit

USA V. RIVERA-VALDES

Constitutional Law, Immigration Law

US Court of Appeals for the Ninth Circuit

Fowler v. Stitt

Civil Rights, Constitutional Law

US Court of Appeals for the Tenth Circuit

USA v. Harden

Constitutional Law, Criminal Law

US Court of Appeals for the Eleventh Circuit

Musgrave v. Warner

Constitutional Law, Government & Administrative Law

US Court of Appeals for the District of Columbia Circuit

CHEMEHUEVI INDIAN TRIBE v. US

Civil Procedure, Constitutional Law, Native American Law

US Court of Appeals for the Federal Circuit

Legislature of the State of California v. Weber

Constitutional Law, Tax Law

Supreme Court of California

State v. C.

Constitutional Law, Criminal Law

Connecticut Supreme Court

DeSantis v. Dream Defenders

Civil Rights, Constitutional Law, Criminal Law

Florida Supreme Court

Clark v. Attorney General

Constitutional Law, Labor & Employment Law

Massachusetts Supreme Judicial Court

People v. Burkman

Communications Law, Constitutional Law, Criminal Law

Michigan Supreme Court

State v. Lanchantin

Constitutional Law, Criminal Law

Montana Supreme Court

Matter of United Jewish Community of Blooming Grove, Inc. v Washingtonville Cent. Sch. Dist.

Constitutional Law, Education Law

New York Court of Appeals

In re The State of Texas

Constitutional Law, Government & Administrative Law

Supreme Court of Texas

Board of Supervisors v. Leach-Lewis

Constitutional Law, Real Estate & Property Law, Zoning, Planning & Land Use

Supreme Court of Virginia

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Constitutional Law Opinions

Moore v. United States

Court: US Supreme Court

Docket: 22-800

Opinion Date: June 20, 2024

Judge: Brett M. Kavanaugh

Areas of Law: Constitutional Law, Tax Law

The case involves Charles and Kathleen Moore, who invested in an American-controlled foreign corporation, KisanKraft. From 2006 to 2017, KisanKraft generated substantial income but did not distribute it to its American shareholders. At the end of the 2017 tax year, the application of the new Mandatory Repatriation Tax (MRT) resulted in a tax bill of $14,729 on the Moores’ pro rata share of KisanKraft’s accumulated income from 2006 to 2017. The Moores paid the tax and then sued for a refund, claiming that the MRT violated the Direct Tax Clause of the Constitution because it was an unapportioned direct tax on their shares of KisanKraft stock. The District Court dismissed the suit, and the Ninth Circuit affirmed.

The Supreme Court of the United States affirmed the Ninth Circuit's decision. The Court held that the MRT, which attributes the realized and undistributed income of an American-controlled foreign corporation to the entity’s American shareholders, and then taxes the American shareholders on their portions of that income, does not exceed Congress’s constitutional authority. The Court's decision was based on the broad power of Congress to lay and collect taxes, which includes direct taxes—those imposed on persons or property—and indirect taxes—those imposed on activities or transactions. The Court also noted that taxes on income are indirect taxes, and the Sixteenth Amendment confirms that taxes on income need not be apportioned. The Court's holding is narrow and limited to entities treated as pass-throughs.

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United States Trustee v. John Q. Hammons Fall 2006, LLC

Court: US Supreme Court

Docket: 22-1238

Opinion Date: June 14, 2024

Judge: Ketanji Brown Jackson

Areas of Law: Bankruptcy, Civil Procedure, Constitutional Law

The case involves the Office of the United States Trustee and a group of Chapter 11 debtors, John Q. Hammons Fall 2006, LLC, et al. The issue at hand is the remedy for a constitutional violation identified in a previous case, Siegel v. Fitzgerald, where a statute was found to violate the Bankruptcy Clause’s uniformity requirement as it allowed different fees for Chapter 11 debtors depending on the district where their case was filed. The government argued for prospective parity as the appropriate remedy, while the debtors argued for a refund.

The Bankruptcy Court found no constitutional violation and did not address the remedial question. The Tenth Circuit reversed this decision, finding that the fee statute permitting nonuniform fees violated the Bankruptcy Clause and ordered a refund of the debtors’ quarterly fees. The U.S. Trustee sought certiorari, which was granted by the Supreme Court.

The Supreme Court reversed the Tenth Circuit's decision. The Court agreed with the government that the appropriate remedy for the constitutional violation is prospective parity. The Court held that requiring equal fees for otherwise identical Chapter 11 debtors going forward aligns with congressional intent, corrects the constitutional wrong, and complies with due process. The Court rejected the debtors' argument for a refund, stating that such a remedy would require undercutting congressional intent and transforming a program that Congress designed to be self-funding into a significant bill for taxpayers. The Court concluded that neither remedial principles nor due process requires such an outcome.

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United States v. Carpenter

Court: US Court of Appeals for the Seventh Circuit

Docket: 23-3295

Opinion Date: June 17, 2024

Judge: SCUDDER

Areas of Law: Constitutional Law, Criminal Law

The case revolves around Seldrick Carpenter, who was serving a six-year term of supervised release after completing a federal sentence for distributing fentanyl. After the death of his mother, Carpenter began using drugs and acting out against his probation officer. When behavioral therapy failed to address these issues, his probation officer petitioned to revoke his supervised release. Carpenter was then suspected of setting a car on fire. The Probation Office alleged that Carpenter committed several supervised release violations, including arson, criminal damage to property, intimidation, and aggravated battery. Before the revocation hearing, Carpenter requested a jury trial under the Sixth Amendment and Article III, § 2, cl. 3. The district court denied the motion and presided over Carpenter’s revocation hearing without a jury. The court found Carpenter guilty of several violations and revoked his supervised release, imposing a revocation sentence of 30 months’ imprisonment.

The United States Court of Appeals for the Seventh Circuit was tasked with determining whether a supervised release revocation proceeding held under 18 U.S.C. § 3583(e)(3) constitutes the “trial of [a] crime” or a “criminal prosecution” within the meaning of either clause. The court agreed with the district court's decision that it does not. The court concluded that neither the Sixth Amendment nor Section 2 of Article III of the U.S. Constitution guarantee a jury trial in a revocation hearing like Carpenter’s. A defendant in Carpenter's situation is entitled only to those procedures dictated by the Federal Rules of Criminal Procedure and the Due Process Clause of the Fifth Amendment. The court also rejected Carpenter's argument that Article III, § 2 can apply to proceedings outside the scope of the Sixth Amendment. The court affirmed the district court's decision.

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United States v. Deng

Court: US Court of Appeals for the Eighth Circuit

Docket: 23-3545

Opinion Date: June 20, 2024

Judge: Kobes

Areas of Law: Constitutional Law, Criminal Law

Mani Panoam Deng was charged with being an unlawful drug user in possession of a firearm, a violation of 18 U.S.C. § 922(g)(3). Deng moved to dismiss the indictment, arguing that the statute violated the Second Amendment and was void for vagueness. He pleaded guilty unconditionally, but appealed, renewing his constitutional challenges and arguing that the court erred by deferring a complete decision on his motion to dismiss.

The United States District Court for the Southern District of Iowa denied Deng's facial Second Amendment challenge and deferred ruling on his other claims, as they were tied to facts about his offense conduct that a jury needed to find. After Deng pleaded guilty, he appealed, renewing his constitutional challenges and arguing that the court erred by deferring a complete decision on his motion to dismiss.

The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The court held that § 922(g)(3) is facially constitutional, citing a previous decision in United States v. Veasley. Deng's as-applied challenge was deemed waived due to his unconditional guilty plea. The court also rejected Deng's vagueness challenge, stating that a criminal statute is void for vagueness under the Fifth Amendment’s Due Process Clause only if it fails to give ordinary people fair notice of the conduct it punishes or is so standardless that it invites arbitrary enforcement. The court found that § 922(g)(3) was not vague as applied to Deng's conduct. Deng's argument that the district court erred by deferring a ruling on his vagueness and as-applied Second Amendment challenges was also dismissed as he had waived this claim by pleading guilty.

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Bacon v. Woodward

Court: US Court of Appeals for the Ninth Circuit

Docket: 22-35611

Opinion Date: June 18, 2024

Judge: Nelson

Areas of Law: Constitutional Law, Government & Administrative Law

A group of firefighters from the City of Spokane filed a lawsuit against the city and state officials, alleging that a COVID-19 vaccination mandate violated their rights under the Free Exercise Clause of the First Amendment. The mandate, issued by Washington Governor Jay Inslee, required all state agency workers to be fully vaccinated, but the firefighters claimed that their requests for religious exemptions were denied. They were subsequently terminated for failing to get vaccinated. The firefighters also alleged that the city used firefighters from neighboring departments, who were granted religious exemptions by their respective departments, to fill the gaps left by their termination.

The United States District Court for the Eastern District of Washington granted judgment on the pleadings to the city and state defendants, dismissing the firefighters' claims. The court held that the city's vaccination requirement survived both strict scrutiny and rational basis review, and that accommodating unvaccinated firefighters would impose an undue hardship.

On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that the firefighters' claims for retrospective and prospective relief were not moot, despite the rescission of the Proclamation. The court found that the city's implementation of the vaccination policy was not generally applicable, as it exempted certain firefighters based on a secular criterion while holding firefighters who objected to vaccination on religious grounds to a higher standard. The court also held that the city's application of the Proclamation was not narrowly tailored to advance the government's compelling interest in stemming the spread of COVID-19. The case was remanded for further proceedings.

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USA V. RIVERA-VALDES

Court: US Court of Appeals for the Ninth Circuit

Docket: 21-30177

Opinion Date: June 17, 2024

Areas of Law: Constitutional Law, Immigration Law

The case involves Leopoldo Rivera-Valdes, a Mexican citizen who unlawfully entered the United States in 1992. In 1994, Rivera-Valdes failed to appear at his deportation hearing and was ordered deported in absentia. He was finally deported in 2006 after being apprehended. After being deported, Rivera-Valdes again unlawfully entered the United States. In 2019, he was charged with illegal reentry under 8 U.S.C. § 1326. He challenged the indictment, alleging that his 1994 in absentia deportation order violated due process. The district court denied the motion, and Rivera-Valdes entered a conditional guilty plea, preserving the right to appeal the constitutional challenge to his deportation.

The district court denied Rivera-Valdes's motion to dismiss the indictment, ruling that his 1994 in absentia deportation order did not violate due process. Rivera-Valdes had argued that immigration authorities violated his due process rights by ordering him deported in absentia despite the notice of the deportation hearing being returned as undeliverable or unclaimed.

The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the deportation in absentia did not violate due process. The court found that whether Rivera-Valdes actually received the notice, the government followed its statutory obligations and reasonably attempted to inform him of the hearing by mailing notice to his last (and only) provided address. The court rejected Rivera-Valdes's argument that additional steps to notify him of his deportation hearing were required under Jones v. Flowers, 547 U.S. 220 (2006). The court concluded that even if Jones's "additional reasonable steps" standard did supersede the constitutional adequacy of notice as recognized in this court’s cases, the government still satisfied due process because no additional reasonable steps existed that were practicable for it to take.

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Fowler v. Stitt

Court: US Court of Appeals for the Tenth Circuit

Docket: 23-5080

Opinion Date: June 18, 2024

Judge: McHUGH

Areas of Law: Civil Rights, Constitutional Law

The case involves three transgender individuals, Rowan Fowler, Allister Hall, and Carter Ray, who sued the Governor of Oklahoma, the Commissioner of Health for the Oklahoma State Department of Health, and the State Registrar of Vital Records. The plaintiffs challenged an executive order issued by the Governor that directed the Oklahoma State Department of Health to stop amending sex designations on birth certificates. The plaintiffs, who had obtained court orders directing that their sex designations on official documents be amended, had their applications for amended birth certificates denied by the Department of Health, citing the Governor's executive order.

The plaintiffs filed a lawsuit alleging that the policy violated the Equal Protection and Due Process Clauses of the Fourteenth Amendment. The district court dismissed the case, ruling that the plaintiffs failed to state a claim. The plaintiffs appealed the decision.

The United States Court of Appeals for the Tenth Circuit reversed the district court's dismissal of the equal protection claim, but affirmed the dismissal of the plaintiffs' substantive due process claim. The court found that the policy of denying sex-designation amendments on birth certificates was not rationally related to any legitimate state interest and therefore violated the Equal Protection Clause. However, the court affirmed the dismissal of the plaintiffs' substantive due process claim, concluding that the plaintiffs failed to allege that their involuntary disclosures of their transgender status amounted to state action.

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USA v. Harden

Court: US Court of Appeals for the Eleventh Circuit

Docket: 20-14004

Opinion Date: June 18, 2024

Judge: Luck

Areas of Law: Constitutional Law, Criminal Law

The case revolves around a warrantless search of a probationer's home, which was also occupied by a non-probationer. The probationer, Tremayne Linder, was on probation for burglary and attempted armed robbery. His probation conditions included a clause that allowed for warrantless searches of his residence. The non-probationer, Lakesia Harden, was Linder's girlfriend and was aware of his probation status. The police, suspecting marijuana use, conducted a warrantless search of Linder's home and found drugs in a shared closet. Harden was subsequently arrested and charged with possession of marijuana and methamphetamine with intent to distribute.

The case was first heard in the United States District Court for the Southern District of Georgia. Harden moved to suppress the drugs and her post-arrest statements as fruits of the allegedly unlawful search. However, the district court denied the suppression motions. At trial, the government admitted the drugs and Harden's statements into evidence, and the jury found her guilty as charged in the indictment. Harden appealed the denial of her suppression motions.

The case was then reviewed by the United States Court of Appeals for the Eleventh Circuit. The court held that a warrantless search of a probationer's home, based on reasonable suspicion and a probation condition allowing warrantless searches, is not rendered unreasonable because the home was occupied by another person who knew about the probation. The court affirmed the district court's decision, ruling that the search was reasonable and did not violate the Fourth Amendment.

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Musgrave v. Warner

Court: US Court of Appeals for the District of Columbia Circuit

Docket: 22-5252

Opinion Date: June 18, 2024

Judge: PILLARD

Areas of Law: Constitutional Law, Government & Administrative Law

A freelance journalist, Shawn Musgrave, sought access to a classified congressional committee report on the CIA's use of detention and interrogation following the September 11, 2001, terrorist attacks. When the committee failed to respond to his request for a copy of the full report, Musgrave filed a lawsuit invoking a common law right of access to the committee report. The district court dismissed the complaint, ruling that the defendants were protected by sovereign immunity and that the Constitution's Speech or Debate Clause prevents compelled disclosure of the report.

The district court also denied Musgrave's request for discovery about the report's purpose and the Committee's communications with the Executive Branch about the report. Musgrave appealed the decision, arguing that the district court lacked subject-matter jurisdiction under the doctrine of sovereign immunity and the Speech or Debate Clause.

The United States Court of Appeals for the District of Columbia Circuit affirmed the judgment of the district court. The court held that the Speech or Debate Clause imposes a privilege against Musgrave's requests for discovery and compelled disclosure of the report. The court also affirmed the district court's denial of Musgrave's request for discovery, concluding that the district court's error was not material as Musgrave had not shown that any requested discovery could produce information that would affect the Speech-or-Debate analysis.

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CHEMEHUEVI INDIAN TRIBE v. US

Court: US Court of Appeals for the Federal Circuit

Docket: 21-1366

Opinion Date: June 18, 2024

Judge: Hughes

Areas of Law: Civil Procedure, Constitutional Law, Native American Law

The Chemehuevi Indian Tribe filed a complaint against the United States, alleging mismanagement of funds and breach of trust. The Tribe sought an accounting and damages for the alleged mismanagement of the Parker Dam compensation funds, the Indian Claims Commission (ICC) Judgment funds, and the suspense accounts. The Tribe also claimed that the U.S. government's failure to approve a proposed lease of its water rights constituted a Fifth Amendment taking and a breach of trust.

The United States Court of Federal Claims dismissed the Tribe's complaint, ruling that it lacked subject-matter jurisdiction. The court found that the Tribe was essentially seeking an accounting to discover potential claims against the government, rather than asserting a right to be paid a certain sum. The court also dismissed the Tribe's claims related to the proposed water rights lease, stating that the claim was outside the six-year statute of limitations.

On appeal, the United States Court of Appeals for the Federal Circuit affirmed the lower court's dismissal of the Tribe's complaint for lack of subject-matter jurisdiction. The appellate court agreed that the Tribe was seeking an accounting to discover potential claims, rather than asserting a right to be paid a certain sum. The court also affirmed the dismissal of the Tribe's claim related to the proposed water rights lease, agreeing that it was outside the statute of limitations. However, the appellate court vacated the lower court's dismissal of the Tribe's claim for failure to state a takings claim, stating that the Tribe's decision to lease the water off-reservation could fulfill the purpose of the reservation.

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Legislature of the State of California v. Weber

Court: Supreme Court of California

Docket: S281977

Opinion Date: June 20, 2024

Judge: Goodwin Liu

Areas of Law: Constitutional Law, Tax Law

The Supreme Court of California ruled that the Taxpayer Protection and Government Accountability Act (TPA), a proposed initiative measure, could not be placed on the November 2024 general election ballot. The TPA sought to revise the California Constitution by requiring voter approval for any new or increased state or local tax, and by expanding the definition of "tax" to include a wider range of government charges. The petitioners, the Legislature of the State of California, Governor Gavin Newsom, and former Senate President Pro Tempore John Burton, argued that the TPA was invalid because it attempted to revise the California Constitution via citizen initiative, and because it would seriously impair essential government functions.

The court agreed with the petitioners, finding that the TPA would substantially alter the basic governmental framework set forth in the California Constitution. The court noted that the TPA would eliminate the Legislature's ability to levy taxes without prior voter approval, shift power between the executive and legislative branches, and transform local revenue-raising by requiring that exempt charges go through legislative rather than administrative processes. The court concluded that these changes were so significant that they amounted to a revision of the Constitution, which could not be enacted by initiative. The court therefore issued a writ of mandate directing the Secretary of State to refrain from placing the TPA on the November 2024 election ballot.

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State v. C.

Court: Connecticut Supreme Court

Docket: SC20692

Opinion Date: June 18, 2024

Judge: Mullins

Areas of Law: Constitutional Law, Criminal Law

A man convicted of sexual assault and risk of injury to a child appealed his conviction, arguing that he was entitled to access the content of handwritten journals authored by the complainant. The complainant had revealed the existence of these journals during the trial, stating that they were created as part of her therapy following the abuse and contained details about her relationship with the defendant and the abuse he had inflicted. The defendant claimed that these journals constituted a "statement" under relevant rules of practice and that his rights were violated as the prosecutors did not personally review the journals for exculpatory information.

The Appellate Court affirmed the conviction, concluding that the defendant had waived his claim to the journals and that the prosecutors were not constitutionally required to personally review the journals. The defendant appealed to the Supreme Court of Connecticut, which agreed with the state's alternative argument that the journals were not subject to disclosure because they did not constitute a statement that was adopted or approved by the complainant. The court also concluded that the Brady review of the journals by a nonlawyer member of the state’s attorney’s office was constitutionally adequate. Therefore, the court affirmed the judgment of the Appellate Court.

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DeSantis v. Dream Defenders

Court: Florida Supreme Court

Docket: SC2023-0053

Opinion Date: June 20, 2024

Judge: Couriel

Areas of Law: Civil Rights, Constitutional Law, Criminal Law

The Supreme Court of Florida was asked to interpret Florida’s law prohibiting riot, section 870.01(2), Florida Statutes (2021). The question was whether the law applies to a person who is present at a violent protest, but neither engages in, nor intends to assist others in engaging in, violent and disorderly conduct. The court ruled that it does not.

The case originated from a lawsuit filed by a group of plaintiffs against Governor Ron DeSantis, three Florida sheriffs, and Attorney General Ashley Moody in the U.S. District Court for the Northern District of Florida. The plaintiffs argued that the statute was vague and overbroad in violation of the Fourteenth Amendment. The district court agreed and enjoined the enforcement of the statute. On appeal, the U.S. Court of Appeals for the Eleventh Circuit found that the central constitutional question was the statute’s scope and certified the question to the Supreme Court of Florida.

The Supreme Court of Florida concluded that a "violent public disturbance" under section 870.01(2) is characterized by harm to persons or property, and not by peacefulness. To "willfully participate" in a "violent public disturbance," a defendant must have "intentionally, knowingly, and purposely" chosen to be part of it. Therefore, to be guilty of the crime of riot, one must "engage in," or at least "intend to assist others in engaging in, violent and disorderly conduct." The court found that the statute was not ambiguous and returned the case to the U.S. Court of Appeals for the Eleventh Circuit.

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Clark v. Attorney General

Court: Massachusetts Supreme Judicial Court

Docket: SJC-13560

Opinion Date: June 13, 2024

Judge: KAFKER

Areas of Law: Constitutional Law, Labor & Employment Law

A group of Massachusetts registered voters challenged the Attorney General's certification of Initiative Petition 23-12, which proposed "a Law Requiring the Full Minimum Wage for Tipped Workers with Tips on Top." The plaintiffs argued that the petition violated the requirement under art. 48 of the Amendments to the Massachusetts Constitution that initiative petitions contain only related or mutually dependent subjects. The petition proposed two changes: first, it would require employers to pay the full minimum wage to tipped employees, and second, it would permit tip pooling among both tipped and non-tipped employees.

The plaintiffs commenced this action in the county court, claiming that the Attorney General's certification of the petition was in error because the petition did not contain only related or mutually dependent subjects. The single justice reserved and reported the case to the full court.

The Supreme Judicial Court for the county of Suffolk affirmed the Attorney General's certification of the petition as in proper form to be submitted to voters. The court concluded that the petition, which would require that employers pay the full minimum wage to tipped employees and would permit tip pooling among both tipped and non-tipped employees, forms a "unified statement of public policy on which the voters can fairly vote 'yes' or 'no.'" The court found that the two provisions of the petition were closely related and shared a well-defined common purpose related to ending the existing compensation system common to tipped industries.

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People v. Burkman

Court: Michigan Supreme Court

Docket: 164638

Opinion Date: June 13, 2024

Judge: CLEMENT

Areas of Law: Communications Law, Constitutional Law, Criminal Law

John M. Burkman and Jacob A. Wohl were charged with bribing or intimidating voters, conspiracy to bribe or intimidate voters, and two counts of using a computer to commit a crime. The charges stemmed from a robocall they designed and financed in 2020, which targeted voters in Michigan areas with significant Black populations. The robocall claimed that voting by mail would result in the voter’s personal information becoming part of a public database used by the police to track down old warrants, by credit card companies to collect debt, and potentially by the Centers for Disease Control and Prevention to track people for mandatory vaccines. The district court found probable cause to believe that the defendants had committed the charged offenses and bound them over for trial. The defendants moved to quash the bindovers, arguing that the robocall was not a “menace” or “other corrupt means or device” under the relevant statute and that the statute was unconstitutional. The circuit court denied the motions.

The Michigan Supreme Court held that the Court of Appeals erred in determining that the defendants’ conduct fell within the term “menace” as used in the relevant statute. However, the Court of Appeals correctly concluded that the defendants’ conduct fell within the statutory catchall term “other corrupt means or device.” The Supreme Court also held that the defendants’ conduct was not excluded from constitutional free-speech protections under the true-threat exception, but erred by holding that the defendants’ conduct was excluded from constitutional free-speech protections under the speech-integral-to-criminal-conduct exception. The Supreme Court adopted a limiting construction of the statute’s catchall provision and remanded the case to the Court of Appeals for further proceedings.

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State v. Lanchantin

Court: Montana Supreme Court

Citation: 2024 MT 129

Opinion Date: June 18, 2024

Judge: Shea

Areas of Law: Constitutional Law, Criminal Law

The case revolves around Neil Lanchantin, who was charged with felony DUI and four misdemeanor offenses after being pursued and arrested by a Montana Highway Patrol Trooper on private property. The property, where Lanchantin was residing with his girlfriend, was marked with a "No Trespassing" sign. Lanchantin appealed the First Judicial District Court's order denying his motion to suppress evidence obtained when law enforcement officers entered the private property without a warrant.

The District Court denied Lanchantin's motion to suppress on the basis that he did not have a reasonable expectation of privacy at the location of the stop. Lanchantin pled guilty to the DUI charge but reserved his right to appeal the District Court’s order. The State argued that Lanchantin had no privacy interest in the property because he did not live there, and that the "No Trespassing" signs were inadequate to convey an expectation of privacy because they were tacked to trees along the side of the road.

The Supreme Court of the State of Montana reversed the District Court's decision, holding that Lanchantin had a reasonable expectation of privacy in the driveway of the property where he was residing with his girlfriend. The court found that the "No Trespassing" signs were sufficient to manifest an actual expectation of privacy that society recognizes as reasonable. The court concluded that law enforcement cannot enter onto private property without a warrant, even in the case of a misdemeanant fleeing, unless there are exigent circumstances. The case was remanded for further proceedings consistent with the court's opinion.

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Matter of United Jewish Community of Blooming Grove, Inc. v Washingtonville Cent. Sch. Dist.

Court: New York Court of Appeals

Citation: 2024 NY Slip Op 03377

Opinion Date: June 20, 2024

Judge: Garcia

Areas of Law: Constitutional Law, Education Law

The case involves a group of petitioners, including parents with children in nonpublic schools, who sought to compel a local school district to transport children to their private schools on days when the public schools were closed. The petitioners requested that the Washingtonville Central School District provide transportation for children attending nonpublic schools on 20 days when public schools were closed. The District denied these requests, citing its policy that it is not required to provide transportation to nonpublic schools on days when the District's schools are not in session. This policy aligns with guidance published by the State Education Department. The petitioners then initiated a hybrid CPLR article 78 proceeding and declaratory judgment action, seeking a declaration that the District must transport students to nonpublic schools on all days those schools are open and that the State Education Department's contrary guidance is invalid.

The Supreme Court ruled in favor of the petitioners, concluding that the language of Education Law § 3635 (1) (a) required the District to transport nonpublic school students on all days their schools were open. The court granted the petitioners' motion for summary judgment on their request for declaratory relief, issued a permanent injunction, and denied the State Education Department's cross motion for summary judgment. However, the Appellate Division reversed this decision, finding that the language in Education Law § 3635 (1) (a) was ambiguous. After reviewing the provision's legislative history, the Appellate Division held that the law "permits, but does not require, school districts outside New York City to transport nonpublic school students to and from school on days when the public schools are closed."

The Court of Appeals of New York affirmed the decision of the Appellate Division. The court held that Education Law § 3635 (1) (a) does not require school districts to provide transportation to nonpublic schools on days when public schools are closed. The court found that the phrase "sufficient transportation facilities" in the statute is ambiguous and could be interpreted in various ways. After examining the legislative history of the statute, the court concluded that the Legislature did not intend to require school districts to provide transportation to nonpublic schools on days when public schools are closed. The court also rejected the petitioners' arguments that the District's policy and the State Education Department's interpretation of Education Law § 3635 (1) (a) denied nonpublic school students equal protection of the law and that the State Education Department exceeded its statutory authority under Education Law § 3635 (1) (a).

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In re The State of Texas

Court: Supreme Court of Texas

Docket: 24-0325

Opinion Date: June 14, 2024

Judge: BLACKLOCK

Areas of Law: Constitutional Law, Government & Administrative Law

The case revolves around a program proposed by Harris County, Texas, known as "Uplift Harris." The program aimed to provide $500 monthly cash payments to 1,928 Harris County residents for 18 months, with recipients chosen by lottery from applicants with income below 200% of the federal poverty line living in certain zip codes. The State of Texas challenged the program, arguing that it violated the Texas Constitution’s prohibition on gratuitous payments to individuals.

The State sued the County, seeking an injunction to block the implementation of the program. The district court denied the State's request for a temporary injunction, leading the State to appeal this decision and request a stay of payments under the Uplift Harris program while the appeal was ongoing. The court of appeals denied this request, prompting the State to seek mandamus relief in the Supreme Court of Texas.

The Supreme Court of Texas granted the State's motion for temporary relief, prohibiting all payments under the Uplift Harris program pending further order of the court. The court found that the State had raised serious doubt about the constitutionality of the program, and that potential violation of the Texas Constitution could not be remedied if payments were to commence while the underlying appeal proceeded. The court also noted that once the funds were distributed to individuals, they could not feasibly be recouped if it was later determined they were paid in violation of the Texas Constitution. The court concluded that temporarily preventing the expenditure of these funds while the State's appeal proceeded ensured public funds were not irrecoverably spent in violation of the Texas Constitution. The State's appeal of the denial of a temporary injunction remains pending in the court of appeals.

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Board of Supervisors v. Leach-Lewis

Court: Supreme Court of Virginia

Docket: 230491

Opinion Date: June 20, 2024

Judge: McCullough

Areas of Law: Constitutional Law, Real Estate & Property Law, Zoning, Planning & Land Use

The case revolves around a dispute between the Board of Supervisors of Fairfax County and Rita M. Leach-Lewis, trustee of the Rita M. Leach-Lewis Trust, which owns several homes in Fairfax County. These homes are used by members of the New World Church of the Christ, including Leach-Lewis, for activities such as handling correspondence, preparing spiritual teachings, and storing files and boxes. The homes are located in a residential-conservation zone, which prohibits office uses. After a zoning official conducted a search of the residences, a notice of violation of the zoning ordinance was issued, stating that the homes were being used as an "office."

The notice of violation was appealed to the Board of Zoning Appeals (BZA), which upheld the zoning administrator's decision. Leach-Lewis then filed a petition for a writ of certiorari challenging the BZA's decision, arguing that the residences were not being used as an "office" and that the notice of violation was based on an improper search under the Fourth Amendment. The circuit court upheld the BZA's decision, and Leach-Lewis appealed to the Court of Appeals of Virginia.

The Court of Appeals reversed the circuit court's decision, holding that the BZA had a duty to interpret and apply a provision of the zoning ordinance that states that no part of the ordinance may be construed to authorize an unconstitutional inspection or search. The Court of Appeals remanded the case to the BZA to determine whether the zoning ordinance was violated by the search of the church's property.

The Supreme Court of Virginia disagreed with the Court of Appeals' decision. It held that the BZA was not required to examine the constitutionality of the search underlying the notice of violation. The court also concluded that the residences were being used as an "office" as defined in the zoning ordinance. Therefore, the court reversed the judgment of the Court of Appeals and entered final judgment in favor of the Board of Supervisors of Fairfax County.

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