Alexander v. City of Syracuse

Court: U.S. Court of Appeals for the Second Circuit

Docket: 21-3075

Opinion Date: March 14, 2025

Judge: Beth Robinson

Areas of Law: Civil Rights, Constitutional Law

On October 24, 2016, Syracuse Police Department officers entered Troy Alexander's home without a warrant after receiving a report of a sexual assault. They searched the home for 12.5 hours before obtaining a warrant, during which they also towed Alexander's cars. After obtaining the warrant, they found narcotics in Alexander's bedroom. Alexander was arrested and faced multiple charges, including burglary, narcotics, and sexual assault. He posted bail twice but was not immediately released. Eventually, all charges were dropped.

Alexander filed a lawsuit alleging violations of his constitutional rights and state law by the City of Syracuse, County of Onondaga, and Detective Rory Gilhooley. He claimed the warrantless entry and prolonged seizure of his home violated his Fourth Amendment rights, that he was falsely arrested, maliciously prosecuted, and improperly detained after posting bail. The United States District Court for the Northern District of New York granted summary judgment to the defendants on all claims.

The United States Court of Appeals for the Second Circuit reviewed the case. The court found that Alexander's claims regarding the warrantless entry, search, and seizure of his home, as well as his false arrest and malicious prosecution claims related to the burglary charges, presented triable issues of fact. The court also found gaps in the evidentiary record regarding Alexander's state law claims of continued detention after posting bail, precluding summary judgment for the City and County on these claims. The court vacated and remanded the judgment on these claims but affirmed the judgment in all other respects.

Doe v. Charter Communications

Court: U.S. Court of Appeals for the Fifth Circuit

Docket: 24-50121

Opinion Date: March 14, 2025

Judge: James Graves

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

John Doe was found not guilty by reason of insanity (NGRI) for an offense in Arlington County, Virginia, in 2014 and was committed to a state hospital in 2015. After his first job offer was rescinded due to his arrest and commitment, he changed his legal name and moved to Texas in 2020. In 2022, he was arrested based on a Virginia bench warrant for failure to appear but was released when Virginia declined extradition. In 2023, Doe received a job offer from Charter Communications, pending a background check by HireRight. HireRight reported that Doe had a criminal record and an active warrant, leading Charter to rescind the job offer.

Doe filed a pro se civil rights action under 42 U.S.C. § 1983 against Charter, HireRight, and Paul Ferguson, Clerk of the Circuit Court of Arlington County, Virginia, alleging violations of the Fair Credit Reporting Act (FCRA), the Americans with Disabilities Act (ADA), and the Fourteenth Amendment. The United States District Court for the Western District of Texas dismissed Doe’s claims, finding that his FCRA claim against Charter was barred as there is no private right of action against users of consumer reports, and his Fourteenth Amendment claim against Ferguson was duplicative of a previously litigated case in Virginia.

The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court agreed that Doe’s constitutional claims against Ferguson were duplicative and therefore frivolous. It also upheld the dismissal of Doe’s FCRA claim against Charter, interpreting 15 U.S.C. § 1681m(h)(8) to bar private enforcement of section 1681m in its entirety. The court found that Doe’s FCRA claim against HireRight and ADA claim against Charter were based on the allegation that the warrant was unlawful or inaccurate, which had already been addressed in the Virginia litigation.

Hoffman v. Westcott

Court: U.S. Court of Appeals for the Fifth Circuit

Docket: 25-70006

Opinion Date: March 14, 2025

Judge: James C. Ho

Areas of Law: Constitutional Law, Criminal Law

Jessie Hoffman was convicted of first-degree murder for the kidnapping, rape, and murder of Mary "Molly" Elliot in 1998 and sentenced to death. After exhausting all state and federal post-conviction remedies, his execution was delayed due to the unavailability of lethal injection drugs. In 2024, Louisiana adopted nitrogen hypoxia as a method of execution. Hoffman challenged this new method, arguing it violated the Eighth Amendment.

The United States District Court for the Middle District of Louisiana granted Hoffman's motion for a preliminary injunction, preventing his execution by nitrogen hypoxia. The court concluded that Hoffman had exhausted his administrative remedies under the Prison Litigation Reform Act (PLRA) and found that nitrogen hypoxia posed a substantial risk of superadding pain and suffering. The court suggested that execution by firing squad would be a reasonable alternative that would reduce the risk of severe pain.

The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that Hoffman had indeed exhausted his administrative remedies. However, it disagreed with the district court's conclusion regarding the Eighth Amendment. The Fifth Circuit held that nitrogen hypoxia is painless and that the district court erred in suggesting that the Eighth Amendment requires a more painful method of execution, such as a firing squad. The court emphasized that the Eighth Amendment does not guarantee a painless death and that Hoffman failed to show that nitrogen hypoxia presented a substantial risk of severe pain compared to other methods.

The Fifth Circuit vacated the preliminary injunction, allowing Louisiana to proceed with Hoffman's execution by nitrogen hypoxia.

McClain v. Delgado

Court: U.S. Court of Appeals for the Fifth Circuit

Docket: 23-50879

Opinion Date: March 20, 2025

Areas of Law: Civil Rights, Constitutional Law, Criminal Law, Government & Administrative Law

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.

The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.

The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity.

St. Juliana v. Oxford Community School District

Court: U.S. Court of Appeals for the Sixth Circuit

Docket: 23-1561

Opinion Date: March 20, 2025

Judge: Raymond Kethledge

Areas of Law: Civil Rights, Constitutional Law

On November 30, 2021, a 15-year-old student, E.C., brought a gun to Oxford High School in Michigan and shot ten students and one teacher, resulting in four student deaths. E.C. pled guilty to first-degree murder and is serving a life sentence. His parents were also convicted of manslaughter. Victims of the shooting filed multiple lawsuits in state court against school and law enforcement officials, alleging various tort claims. The consolidated federal cases here involve claims that school officials violated the plaintiffs' constitutional rights to due process.

The United States District Court for the Eastern District of Michigan largely dismissed the plaintiffs' claims, holding that the plaintiffs had not alleged facts sufficient to support an inference that the school officials' actions were so outrageous as to shock the conscience. However, the court allowed one claim to proceed, finding that a statement made by a school counselor, Shawn Hopkins, to E.C.'s parents about contacting Child Protective Services if they did not get counseling for E.C. within 48 hours, could potentially support a constitutional claim.

The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal of most claims. The appellate court agreed that the plaintiffs had not plausibly alleged that the school officials' actions were so egregious as to violate due process. The court found that the actions of returning E.C.'s backpack and failing to inform other officials about the risk did not constitute affirmative acts that increased the danger to the plaintiffs. The court also held that Hopkins' statement to E.C.'s parents did not demonstrate reckless or callous indifference. Consequently, the Sixth Circuit reversed the district court's decision to allow the claim based on Hopkins' statement to proceed and remanded the case with instructions to dismiss all claims.

Taylor v. Schwarzhuber

Court: U.S. Court of Appeals for the Seventh Circuit

Docket: 23-3151

Opinion Date: March 17, 2025

Judge: Candace Jackson-Akiwumi

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

In December 2015, sixteen-year-old Isaiah Taylor was stopped by Milwaukee police officers Justin Schwarzhuber and Jasen Rydzewski while running through his neighborhood to deliver a turkey. The officers frisked him, searched his bag, and detained him in their police car to check for outstanding warrants and recent robberies. Taylor later sued the officers under 42 U.S.C. § 1983, claiming an unreasonable search and seizure in violation of the Fourth Amendment and racial profiling in violation of the Equal Protection Clause of the Fourteenth Amendment.

The United States District Court for the Eastern District of Wisconsin granted qualified immunity and summary judgment to the officers on Taylor’s Fourteenth Amendment claim and on the Fourth Amendment claim regarding the initial stop and frisk. However, the court denied qualified immunity on the issue of Taylor’s continued detention, sending it to trial. The jury found the officers not liable, and the court denied Taylor’s motion for post-trial relief under Federal Rule of Civil Procedure 59.

The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the grant of summary judgment on Taylor’s Fourteenth Amendment claim, finding insufficient evidence of racial profiling. However, it vacated the summary judgment on the Fourth Amendment claims related to the initial stop and frisk, concluding that the officers lacked reasonable suspicion for the stop and frisk based on clearly established law. The court also vacated the jury verdict on the continued detention issue, as it was intertwined with the initial stop's constitutionality, and remanded the case for a new trial on all Fourth Amendment claims.

CAHILL V. NIKE, INC.

Court: U.S. Court of Appeals for the Ninth Circuit

Docket: 24-2199

Opinion Date: March 18, 2025

Judge: Lawrence VanDyke

Areas of Law: Civil Procedure, Constitutional Law, Labor & Employment Law

Plaintiffs filed a class action lawsuit against Nike, Inc., alleging gender discrimination and hostile workplace claims. During discovery, a collection of internal workplace complaints, known as the Starfish complaints, was produced under a protective order. Three media organizations, including The Oregonian, intervened in the case to gain access to these documents. Plaintiffs' attorney inadvertently sent confidential documents to a reporter from The Oregonian, who refused to return or destroy them upon request.

The United States District Court for the District of Oregon initially granted a motion to intervene by the media organizations. However, when the inadvertent disclosure occurred, the magistrate judge ordered The Oregonian to return or destroy the documents. The district court vacated this order, reasoning that it lacked authority to compel a non-party to return the documents. The magistrate judge then denied the motion, and the district court affirmed this decision.

The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the district court had the inherent authority to order The Oregonian, as an intervenor and thus a party to the case, to return or destroy the confidential documents. The court determined that The Oregonian did not have a First Amendment right to withhold the documents because pretrial discovery proceedings are not public components of the judicial process. The court applied relaxed First Amendment scrutiny and concluded that the district court's exercise of its inherent authority over discovery furthered a substantial government interest unrelated to the suppression of expression. The Ninth Circuit vacated the district court's order and remanded the case for further proceedings consistent with its opinion.

Flynt v. Bonta

Court: U.S. Court of Appeals for the Ninth Circuit

Docket: 22-16376

Opinion Date: March 14, 2025

Judge: Daniel Bress

Areas of Law: Constitutional Law, Gaming Law

Plaintiffs, who are California residents and cardroom operators, challenged the constitutionality of California Business and Professions Code §§ 19858(a) and 19858.5. These statutes make a person ineligible for a California cardroom license if they own more than a 1% financial interest in a business that engages in casino-style gambling or if they have control over such a business. Plaintiffs argued that these provisions violate the dormant Commerce Clause by discriminating against interstate commerce, regulating extraterritorially, and unduly burdening interstate commerce.

The United States District Court for the Eastern District of California initially dismissed the complaint as untimely, but the Ninth Circuit reversed that decision. On remand, the district court rejected plaintiffs' dormant Commerce Clause claims, concluding that the statutes did not discriminate against interstate commerce, did not regulate extraterritorially, and did not unduly burden interstate commerce. Plaintiffs appealed this decision.

The United States Court of Appeals for the Ninth Circuit affirmed the district court's judgment. The court held that the cardroom licensing restrictions do not violate the dormant Commerce Clause. The court found that the statutes are not facially discriminatory, do not have a discriminatory purpose or effect, and do not favor in-state economic interests. The court also concluded that the statutes do not regulate extraterritorially because they condition a state license for conducting in-state activities on plaintiffs foregoing certain business interests, whether within or outside the state. Finally, the court determined that plaintiffs failed to demonstrate a significant or substantial burden on interstate commerce under the Pike balancing test. Therefore, the court affirmed the district court's judgment in favor of the California officials.

ROE V. CRITCHFIELD

Court: U.S. Court of Appeals for the Ninth Circuit

Docket: 23-2807

Opinion Date: March 20, 2025

Judge: Morgan Christen

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

A transgender student, Rebecca Roe, and the Sexuality and Gender Alliance (SAGA) at Boise High School challenged Idaho Senate Bill 1100 (S.B. 1100), which mandates that public school students use restrooms and changing facilities corresponding to their "biological sex." They argued that the law violates the Equal Protection Clause, Title IX, and the right to informational privacy. Roe and SAGA sought a preliminary injunction to prevent the law from being enforced.

The United States District Court for the District of Idaho denied the preliminary injunction, concluding that SAGA was unlikely to succeed on the merits of its claims. The court found that the State's interest in protecting student privacy was an important governmental objective and that S.B. 1100 was substantially related to achieving that objective. The court also determined that SAGA did not show that the State had clear notice that Title IX prohibited segregated access to facilities based on transgender status. Additionally, the court found that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy.

The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit agreed that SAGA did not establish a likelihood of success on the merits of its equal protection claim, as the State's interest in protecting bodily privacy was deemed important and the means chosen were substantially related to that objective. The court also held that SAGA failed to show that the State had clear notice that Title IX prohibited the exclusion of transgender students from facilities corresponding to their gender identity. Lastly, the court concluded that SAGA did not demonstrate that S.B. 1100 violated the right to informational privacy, as the statute did not necessarily disclose a student's transgender status.

Yukutake v. Lopez

Court: U.S. Court of Appeals for the Ninth Circuit

Docket: 21-16756

Opinion Date: March 14, 2025

Judge: Daniel P. Collins

Areas of Law: Constitutional Law

Two plaintiffs, Todd Yukutake and David Kikukawa, challenged two provisions of Hawaii's firearms laws, arguing they violated the Second Amendment. The first provision, Hawaii Revised Statutes § 134-2(e), required that a handgun be acquired within a narrow time window (originally 10 days, later amended to 30 days) after obtaining a permit. The second provision, § 134-3, mandated that gun owners physically bring their firearms to a police station for inspection within five days of acquisition as part of the registration process.

The United States District Court for the District of Hawaii granted summary judgment in favor of the plaintiffs, ruling that both provisions were facially unconstitutional under the Second Amendment. The court permanently enjoined the enforcement of these provisions. The State of Hawaii appealed, arguing that recent legislative amendments to the challenged provisions rendered the case moot. However, the Ninth Circuit Court of Appeals denied the State's motion to dismiss the appeal as moot, finding that the amended versions of the provisions were sufficiently similar to the previous versions.

The Ninth Circuit Court of Appeals affirmed the district court's judgment. The court held that the short timeframe for completing a firearms purchase after obtaining a permit was unconstitutional under the Second Amendment. The court reasoned that the purchase and acquisition of firearms are protected by the Second Amendment, and the State failed to justify the short temporal limit on firearms acquisition permits. The court also affirmed the district court's conclusion that the in-person inspection requirement violated the Second Amendment, noting that the government did not provide sufficient evidence that the requirement materially advanced the objectives of the registration system. The case was remanded to the district court to revise its permanent injunction in light of the recent amendments to the challenged provisions.

Luethje v. Kyle

Court: U.S. Court of Appeals for the Tenth Circuit

Docket: 24-1257

Opinion Date: March 19, 2025

Judge: Carolyn McHugh

Areas of Law: Civil Rights, Constitutional Law

The case involves Plaintiff Tyler Luethje, who filed a § 1983 complaint against Defendants Travis Kyle and Scott Kelly, both employed by the Douglas County Sheriff’s Office. On February 11, 2022, the deputies responded to a 911 call about a broken window at Luethje’s residence. Upon arrival, they sent a police canine, Sig, into the house without announcing themselves. Sig bit Luethje, who was in bed, and continued to bite him while the deputies questioned him. Luethje was then handcuffed and taken to the hospital. He was not charged with any crime.

The United States District Court for the District of Colorado reviewed the case and denied the deputies' motion to dismiss based on qualified immunity. The court held that the deputies violated Luethje’s Fourth Amendment rights regarding unlawful entry and search, unlawful arrest, and excessive force. The court found that the law clearly established these rights.

The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that the deputies were not entitled to qualified immunity. The court held that the deputies’ actions violated Luethje’s constitutional rights and that these rights were clearly established. The court found that the deputies lacked an objectively reasonable belief in an ongoing emergency to justify the warrantless entry, did not have probable cause for the arrest, and used excessive force by allowing the canine to continue biting Luethje after he was subdued.

Stirling v. North Slope Borough School District

Court: Alaska Supreme Court

Docket: S-18853

Opinion Date: March 14, 2025

Judge: Jennifer S. Henderson

Areas of Law: Constitutional Law, Education Law, Labor & Employment Law

A school principal used the school's printer after hours to create a coaster as a retirement gift for a friend. The coaster design contained the School District's official logo but altered the District's motto in a disrespectful manner. A custodian took pictures of the coaster, which were shared on social media, leading to public outrage. The principal left the community the next day. The District proposed to terminate him for incompetence and violating anti-harassment policies. After a brief pretermination hearing, the District terminated the principal. The principal appealed, and the Board upheld the termination following an additional hearing.

The principal then appealed to the superior court, which also affirmed his termination. The court found that the District had grounds to terminate the principal due to substantial noncompliance with District rules and regulations and that the community's reaction to the coaster was reasonable. The court also rejected the principal's free speech arguments, stating that his speech was not protected under the First Amendment. The court acknowledged that the pretermination hearing process was flawed but deemed the error harmless due to the subsequent post-termination hearing.

The Supreme Court of the State of Alaska reviewed the case. The court held that the Board had a reasonable basis to terminate the principal for incompetency under AS 14.20.170(a)(1) due to his inability to perform his duties effectively after the incident. The court also concluded that the principal's termination did not violate his free speech rights under AS 14.20.095 or the First Amendment. However, the court found that the pretermination hearing process did not provide sufficient due process, as the principal was not informed of his right to call witnesses. The court affirmed the termination but reversed the superior court's decision denying back pay, awarding back pay through the date of the Board's post-termination hearing decision.

People v. Batten

Court: California Courts of Appeal

Docket: A169597(First Appellate District)

Opinion Date: March 17, 2025

Judge: Tracie L. Brown

Areas of Law: Constitutional Law, Criminal Law

Annette Gaylene Batten, who was convicted of first-degree murder in 1996 and sentenced to life in prison, was released on parole in August 2017. In December 2023, she admitted to two parole violations: driving under the influence and failing to inform her parole agent of her arrest. Consequently, the trial court revoked her parole and remanded her to the custody of the California Department of Corrections and Rehabilitation (CDCR) and the jurisdiction of the Board of Parole Hearings for future parole consideration.

The trial court's decision was based on Penal Code section 3000.08, subdivision (h), which mandates remand to the CDCR for parolees who violate conditions of lifetime parole. Batten argued that a statute enacted in 2020, which limits parole to three years for those released after July 2020, should apply to her, and that the disparity in treatment violates equal protection principles. The trial court, however, followed the existing law applicable to her case.

The California Court of Appeal, First Appellate District, reviewed the case. The court held that rational basis review, rather than strict scrutiny, applies to Batten's equal protection challenge. The court found that there is a rational basis for treating inmates released before July 2020 differently from those released after that date. The Legislature could have reasonably decided that changing the terms of parole retroactively would undermine the Board's parole determinations. Therefore, the court affirmed the trial court's decision to remand Batten to the CDCR.

People v. Tafoya

Court: California Courts of Appeal

Docket: E079488(Fourth Appellate District)

Opinion Date: March 17, 2025

Judge: Manuel Ramirez

Areas of Law: Constitutional Law, Criminal Law, Family Law

Over a five-year period, Robert Michael Tafoya stalked and harassed E.R. in various ways. He frequently appeared at her workplace, left flowers on her car, followed her while shopping, made numerous Facebook posts claiming to be involved with her and the father of her children, and fraudulently applied for custody and visitation orders. Despite restraining orders, his behavior continued unabated, including attempts to pick up her children from school.

Following a jury trial in the Superior Court of Riverside County, Tafoya was convicted of stalking, perjury, attempted child abduction, and filing false documents. He was sentenced to 25 years and eight months in prison. Tafoya appealed the convictions, arguing that his Facebook posts were protected by the First Amendment, there was insufficient evidence for the attempted child abduction conviction, and the perjury and false document convictions lacked false statements. He also appealed the restitution order, claiming the court used the wrong standard and lacked proper verification.

The Court of Appeal of the State of California, Fourth Appellate District, Division Two, reviewed the case. The court held that Tafoya’s Facebook posts were not protected activity as they were part of a pattern of conduct that constituted a credible threat. The court found substantial evidence supporting the attempted child abduction conviction, noting that the visitation order was obtained by fraud and thus void. The court affirmed the convictions for stalking, attempted child abduction, and filing false documents. However, the court reversed the perjury conviction related to the restraining order (count 10) due to the lack of a false statement under penalty of perjury and remanded for resentencing. The restitution order was upheld, as the need for relocation expenses was justified by the record.

Arnold v. Alexander

Court: Supreme Court of Georgia

Docket: S24O1335

Opinion Date: March 18, 2025

Judge: Michael P. Boggs

Areas of Law: Civil Procedure, Constitutional Law

Petitioner Deandre Arnold, an indigent pro se litigant, attempted to file a civil complaint with an affidavit of indigence through the Fulton County Superior Court’s mandatory e-filing system. His complaint was rejected because it lacked an order authorizing him to file using a waiver payment account. The Clerk’s office informed him that he needed to obtain an order authorizing indigent status by presenting the complaint in person before a superior court judge. Arnold, unable to travel the 25 miles to the Clerk’s office, argued that the Clerk’s policy violated OCGA § 9-15-2 and his constitutional rights.

The Supreme Court of Georgia reviewed the case after Arnold filed a petition for a writ of mandamus against the Clerk. Arnold contended that he had no adequate remedy other than filing an original petition in the Supreme Court because he could not appear in person to present a writ of mandanus and affidavit of indigence, and the Clerk would not accept such a filing by mail.

The Supreme Court of Georgia concluded that it lacked original jurisdiction to grant the relief Arnold sought, as its authority to issue writs of mandamus is limited to matters related to its appellate jurisdiction. The Court determined that the case did not fall within its appellate jurisdiction and transferred the petition to the Court of Appeals for resolution. The Court of Appeals has the authority to grant writs of mandamus in aid of its jurisdiction and will decide whether to require the Clerk to accept Arnold’s affidavit of indigence and civil complaint by mail.

Fossella v Adams

Court: New York Court of Appeals

Citation: 2025 NY Slip Op 01668

Opinion Date: March 20, 2025

Judge: Rowan Wilson

Areas of Law: Constitutional Law, Election Law

On December 9, 2021, the New York City Council passed a bill amending the New York City Charter to allow lawful permanent residents to vote in municipal elections. The bill became effective on January 9, 2022, as Local Law 11, after both outgoing Mayor Bill de Blasio and incoming Mayor Eric Adams neither signed nor vetoed it. Local Law 11 permitted certain noncitizens to vote in elections for New York City offices such as Mayor, Public Advocate, Comptroller, Borough President, and City Council Member.

Plaintiffs, including current and former elected officials and New York City registered voters, filed a lawsuit against the New York City Council, Mayor Eric Adams, and the New York City Board of Elections. They sought to declare Local Law 11 null and void, arguing it violated the New York State Constitution, the New York State Election Law, and the Municipal Home Rule Law. The Supreme Court granted summary judgment in favor of the plaintiffs on all grounds, declaring Local Law 11 unconstitutional and enjoining its implementation. The Appellate Division modified the judgment regarding the Election Law claim but otherwise affirmed the decision, with one justice dissenting. The City Council and intervenors appealed to the Court of Appeals.

The New York Court of Appeals held that Article II, Section 1 of the New York State Constitution restricts voting to citizens, thus invalidating Local Law 11. The court found that the Constitution's language and historical context clearly limit the right to vote to U.S. citizens. The court rejected arguments that Article IX of the Constitution, which grants home rule powers to local governments, overrides this restriction. Consequently, the Court of Appeals modified the Appellate Division's order and, as modified, affirmed the decision, maintaining the invalidation of Local Law 11.

Roussel v. State

Court: Utah Supreme Court

Citation: 2025 UT 5

Opinion Date: March 20, 2025

Judge: Diana Hagen

Areas of Law: Civil Procedure, Constitutional Law, Environmental Law

Several young Utah residents filed a lawsuit challenging statutory provisions and government actions related to fossil fuel development. They claimed that these provisions and actions were designed to maximize fossil fuel development in Utah, which they argued endangered their health and shortened their lifespans by exacerbating climate change. They sought a declaration from the district court that these provisions and actions violated their rights under the Utah Constitution.

The government defendants moved to dismiss the case, arguing that the requested relief would not redress the alleged injuries. The Third District Court, Salt Lake County, agreed and dismissed the claims with prejudice, concluding that the plaintiffs lacked standing because their claims were not redressable.

The Utah Supreme Court reviewed the case and affirmed the dismissal on the ground that the district court lacked subject-matter jurisdiction. The court found that the challenge to the energy policy provision was moot because the legislature had significantly amended the statute since the complaint was filed. The plaintiffs lacked standing to challenge the remaining statutory provisions because success on those challenges would not provide relief likely to redress their injuries. The court noted that the challenged provisions did not limit the government defendants' discretion in making decisions about fossil fuel development, and thus, striking these provisions would not necessarily lead to less fossil fuel development.

The court also held that the challenges to the government defendants' conduct were not justiciable because they were not supported by a concrete set of facts. The plaintiffs had identified general categories of conduct without tying their claims to any specific government actions. The court instructed the district court to modify its ruling to reflect that the dismissal was without prejudice, allowing the plaintiffs the opportunity to refile their claims if they could address the jurisdictional deficiencies.

Patterson v. State

Court: Wyoming Supreme Court

Citation: 2025 WY 30

Opinion Date: March 20, 2025

Judge: Kari Jo Gray

Areas of Law: Constitutional Law, Criminal Law

William Patterson was convicted of sexually abusing his girlfriend’s four-year-old niece. The incident occurred on September 15, 2019, when Patterson was watching the child and her twin sister. The children later reported the abuse to their mother, who contacted the police. The children were interviewed, and one disclosed the abuse. However, the district attorney initially decided not to charge Patterson. Three years later, the children provided more details, leading to charges against Patterson. He was convicted by a jury of second and third-degree sexual abuse of a minor.

The District Court of Natrona County sentenced Patterson to 14-20 years in prison for second-degree sexual abuse of a minor, noting that the same act formed the basis for both convictions. Patterson appealed, arguing that the prosecutor improperly commented on his right to remain silent during the trial. The district court had denied Patterson’s motion for a mistrial, concluding that the prosecutor’s statement was not an improper comment on his right to remain silent and that any potential prejudice was mitigated by the court’s curative actions.

The Supreme Court of Wyoming reviewed the case and determined that the prosecutor’s statement during opening arguments, which mentioned Patterson’s refusal to speak with law enforcement, was an impermissible comment on his constitutional right to remain silent. The court reaffirmed that such comments are prejudicial per se under the Wyoming Constitution and require reversal of the conviction. The court overruled previous case law that allowed for a distinction between a “comment” and a “reference” to silence, clarifying that any improper comment on the right to silence is prejudicial per se. Consequently, the Supreme Court of Wyoming reversed Patterson’s conviction and remanded the case for a new trial.