Constitutional Law - Justia Case Law Summaries

Jensen v. Utah County

2026-10-05T11:30:38-08:00

Several plaintiffs, including the founder of a religious group called Singularism, used psilocybin as part of their religious ceremonies in Utah, where the drug is classified as a controlled substance. Authorities seized a large quantity of psilocybin from them and notified Singularism’s landlord that the drug use constituted a nuisance. Shortly after, the plaintiffs initiated a state lawsuit, which was removed to the United States District Court for the District of Utah. The federal court issued a temporary restraining order requiring the return of seized items and, after state authorities filed criminal charges, enjoined state prosecution against the religious leader to prevent a potential First Amendment violation. On appeal, the state authorities argued that the federal district court should have abstained from interfering with ongoing state criminal proceedings under the Younger abstention doctrine, and that prosecution did not violate the First Amendment. The United States Court of Appeals for the Tenth Circuit reviewed the district court’s refusal to abstain de novo and found the requirements for abstention were satisfied. The court concluded that the state authorities had not waived the abstention argument through their litigation conduct. The plaintiffs failed to show that the prosecution was brought in bad faith, was harassing, or created a threat of irreparable injury, as required for exceptions to abstention. On the merits, the Tenth Circuit held the district court erred in finding a likely First Amendment violation. The court found Utah law’s regulatory scheme for secular, supervised medical use of psilocybin was not comparable to the unsupervised religious use, and thus did not treat secular activity more favorably than religious activity. The court vacated the injunction and the denial of the motion to dismiss as to preferential treatment for secular use, remanding the issue of individualized exemptions for further district court proceedings, and dismissed the appeal regarding the Fourth Amendment claim for lack of jurisdiction. View "Jensen v. Utah County" on Justia Law

Alsyrawan v. DHS

2026-10-05T09:47:50-08:00

A non-verbal adult male with Down syndrome and autism, residing in Philadelphia with his mother and sister, receives care funded under Pennsylvania’s Consolidated Waiver program for home and community-based services. After the Department of Human Services imposed a “40/60 Rule” limiting compensation for care provided by relatives to 40 hours per week for one caretaker or 60 hours for multiple caretakers, his mother sought a permanent exception, citing religious grounds. She argued that Islamic law prohibits unrelated males from providing personal care and restricts her own interactions with unrelated male aides. Without an exception, she and her daughter would continue to provide care beyond the capped hours without compensation. The Department initially denied the exception, and an Administrative Law Judge dismissed the appeal for lack of jurisdiction. After a remand and settlement for reassessment, the Department again denied the request. The Bureau of Hearings and Appeals upheld the denial, and the mother appealed to the Commonwealth Court. During the COVID-19 pandemic, temporary exceptions permitted full compensation, but after resumption, the request for a permanent religious exemption was again denied. The Commonwealth Court affirmed, finding no substantial burden on religious exercise under the Free Exercise Clause or Pennsylvania’s Religious Freedom Protection Act (RFPA), and concluded that the mother failed to meet her burden of proof. The Supreme Court of Pennsylvania reviewed whether a Free Exercise Clause claim requires evidence of a “substantial burden” on religious exercise. The Court held that only a “burden” is required, not a substantial burden, and that the Commonwealth Court erred by conflating RFPA’s statutory standard with the constitutional standard. The Court reversed the Commonwealth Court’s order and remanded for further proceedings consistent with this holding. View "Alsyrawan v. DHS" on Justia Law

In re Howard

2026-10-05T09:30:06-08:00

A man convicted of murder in Texas and sentenced to death sought to halt his execution, scheduled for October 7, 2026. He argued that newly developed clinical standards for diagnosing intellectual disability, which became available after his first federal habeas petition, would now classify him as intellectually disabled and therefore constitutionally ineligible for execution. He maintained that these new clinical guidelines constituted either a new rule of constitutional law or a new factual predicate, justifying a second federal habeas petition under 28 U.S.C. § 2254. As an alternative, he requested a stay of execution pending a potential relevant decision by the United States Supreme Court. After his 2001 conviction, the Texas Court of Criminal Appeals rejected his Eighth Amendment claim that his mental illness barred execution. His first state and federal habeas petitions were denied, with the federal courts determining in 2017 that he was not intellectually disabled. He later abandoned his initial Atkins v. Virginia claim after the Supreme Court faulted Texas’s standards for such claims in Moore v. Texas. In 2019, the United States District Court for the Eastern District of Texas denied his remaining federal habeas claims, and the United States Court of Appeals for the Fifth Circuit denied a Certificate of Appealability in 2020. Reviewing the case, the United States Court of Appeals for the Fifth Circuit held that the petitioner’s second federal habeas application was barred by the one-year statute of limitations and that he was not entitled to equitable tolling. The court further found that his renewed claim of intellectual disability had already been presented in his prior habeas petition, barring reconsideration under § 2244(b)(1). The court also denied his request for a stay of execution, finding no likelihood of success on the merits and no justification for equitable relief. Both motions were denied. View "In re Howard" on Justia Law

Does v. Flannigan

2026-10-05T07:30:13-08:00

A group of individuals required to register as sex offenders under Missouri’s Sex Offender Registration Act (Mo. SORA), along with their spouses and children, filed suit against Missouri State Highway Patrol officials responsible for enforcing the law. The plaintiffs challenged various aspects of Mo. SORA, including its registration requirements, the lack of individualized risk assessments, the tiered system of registration durations, and reporting obligations for online identifiers. They asserted that these provisions violated their constitutional rights and also caused harm to their family members, who experienced social stigma and other indirect consequences. The United States District Court for the Western District of Missouri dismissed the claims of the family members, finding they were not directly subject to Mo. SORA and that incidental effects on them were irrelevant to the constitutional analysis. The court also rejected the plaintiffs’ Eighth Amendment and Ex Post Facto Clause challenges, concluding that Mo. SORA was not punitive. It found the statute’s requirements regarding online identifiers were not unconstitutionally vague because the registration form specified the information to be provided. The court dismissed the due process and equal protection claims, finding no fundamental rights or suspect classifications were implicated and that the statute was rationally related to legitimate state interests. Regarding the First Amendment, the court held that the prior restraint on use of online identifiers was unconstitutional, and the parties agreed to modify the registration form to remove that requirement. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that (1) Mo. SORA is not punitive for Eighth Amendment or Ex Post Facto purposes, (2) the statute is not unconstitutionally vague regarding online identifiers, (3) no cognizable due process or equal protection claims were stated, (4) the family members lacked standing, and (5) the First Amendment claim was properly resolved by modifying the reporting requirement. View "Does v. Flannigan" on Justia Law

MACDONALD V. OREGON HEALTH AND SCIENCE UNIVERSITY

2026-10-02T08:30:29-08:00

A registered nurse working in a hospital’s Mother Baby Unit requested a religious exemption from her employer’s mandatory COVID-19 vaccination policy. Her request, which cited Christian beliefs regarding the sanctity of life and objections to the use of abortion-derived cell lines in vaccine development and testing, was denied. The hospital had followed an executive order issued by the Oregon governor, requiring all healthcare workers to be vaccinated unless granted a medical or religious exemption. The nurse was subsequently terminated for failure to comply with the vaccination mandate. The nurse filed suit in the United States District Court for the District of Oregon. She alleged a Free Exercise claim under 42 U.S.C. § 1983 against individual members of the hospital’s Board of Directors and Vaccine Exception Review Committee, and a Title VII claim against the hospital for failure to accommodate her religious beliefs. The district court granted the individual defendants’ motion to dismiss the Free Exercise claim on qualified immunity grounds, finding that the right to refuse a state-mandated vaccine on religious grounds was not clearly established in 2021. The court denied the hospital’s motion to dismiss the Title VII claim but later granted summary judgment for the hospital, holding that accommodating the nurse’s request would have imposed undue hardship due to health, safety, operational, and financial risks. The United States Court of Appeals for the Ninth Circuit reviewed the case. It affirmed the district court’s dismissal of the Free Exercise claim, holding that the individual defendants were entitled to qualified immunity because no clearly established law in 2021 recognized a healthcare worker’s religious right to a vaccine exemption under those circumstances. The court also affirmed summary judgment for the hospital on the Title VII claim, concluding that the hospital demonstrated undue hardship in accommodating the nurse without substantial risk to patients and operations. View "MACDONALD V. OREGON HEALTH AND SCIENCE UNIVERSITY" on Justia Law

CASTILLO V. BEAN

2026-10-02T08:00:27-08:00

The case involves William Castillo, who was convicted and sentenced to death for the murder of Isabelle Berndt in Las Vegas, Nevada. Castillo used a key he found while working as a roofer at Berndt’s home to later enter her residence with an accomplice, steal items, and fatally attack Berndt with a tire iron. Subsequently, he returned to the home to set it on fire. Evidence recovered from Castillo’s apartment linked him to the crime. He confessed to the robbery, murder, and arson during police interrogation and was convicted by a jury on multiple counts, including first-degree murder. The penalty phase included testimony regarding his abusive childhood and mental health, but the jury imposed a death sentence. After his conviction, Castillo appealed to the Nevada Supreme Court, which affirmed both the conviction and sentence. His state post-conviction relief (PCR) petition was denied by the trial court and affirmed by the Nevada Supreme Court. Castillo then filed a federal habeas corpus petition in the United States District Court for the District of Nevada. He voluntarily dismissed the petition, but later moved to reopen it. His subsequent amended petitions were dismissed by the district court as untimely or procedurally defaulted. The district court granted a certificate of appealability for four claims and denied it for two others. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that Castillo’s first and second amended habeas petitions were untimely and equitable tolling was not warranted. The court affirmed denial of relief on most claims, including ineffective assistance of trial counsel and the as-applied Eighth Amendment challenge to Nevada’s lethal injection protocol. However, the court reversed the district court’s ruling on two claims, finding that attorney error in state PCR proceedings could excuse procedural default under Martinez v. Ryan and Hogan v. Bean. Those claims were remanded for further proceedings. The court affirmed denial of certificates of appealability for the remaining claims. View "CASTILLO V. BEAN" on Justia Law

United States v. Acevedo

2026-10-02T06:30:03-08:00

Federal agents suspected that an individual was using his auto garage as a front for narcotics distribution. After two controlled purchases of cocaine and ongoing surveillance, agents obtained a warrant to search his house and the surrounding grounds for evidence of drug crimes. The warrant did not specifically list vehicles among the items to be seized. Upon executing the warrant, agents found a blue minivan and a red truck parked in the driveway. Although a search of the vehicles initially revealed no contraband, the agents seized them for civil asset forfeiture, believing the minivan was used to facilitate drug sales and the truck was purchased with drug proceeds. Later, after receiving a tip, agents obtained a separate warrant to search the minivan and discovered cocaine and a firearm hidden in a secret compartment. The United States District Court for the District of Connecticut denied the defendant’s motion to suppress the evidence found in the minivan. The court reasoned that, under Florida v. White, law enforcement does not need a warrant to seize forfeitable vehicles from places where officers are lawfully present, even private driveways. The defendant subsequently pleaded guilty while preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Second Circuit reviewed the case. The Court held that the warrantless seizure of the minivan from the private driveway was reasonable under the Fourth Amendment since the agents had a warrant authorizing them to be present on the property and search its grounds. The Court explained that such a seizure did not constitute an invasion of privacy. The Court distinguished this case from United States v. Lasanta, finding Lasanta inapposite because the agents here had a search warrant for the property, unlike in Lasanta. The judgment of the district court was affirmed. View "United States v. Acevedo" on Justia Law

State v. Elseman

2026-10-02T05:08:26-08:00

The case involves a defendant convicted of first degree murder and use of a deadly weapon to commit a felony. The defendant was part of a group that planned to purchase marijuana but instead decided to rob the victim, resulting in the victim’s death. At trial, the prosecution’s key witness testified that the defendant was the shooter. Another witness identified the perpetrators as three black males, while the defendant is white. The defendant was sentenced to life imprisonment and 25 to 30 years for the respective convictions. His direct appeal, handled by the same attorney as at trial, was unsuccessful. Subsequently, the defendant filed a motion for postconviction relief in the District Court for Douglas County, asserting ineffective assistance of counsel relating to a juror who allegedly exhibited bias during voir dire and was not removed by peremptory challenge or on appeal. He also claimed that the State failed to disclose implied plea agreements with two witnesses, violating his constitutional rights. The district court denied all claims without an evidentiary hearing, finding the juror claims were refuted by the record and the plea agreement claims were either procedurally barred, unsupported by facts, or harmless error. The Nebraska Supreme Court reviewed the case. It affirmed the district court’s denial of an evidentiary hearing regarding all claims about the juror and the claim concerning an implied plea agreement with one witness, finding the record did not support allegations of juror bias, ineffective assistance, or an undisclosed agreement. However, the court reversed in part, holding that the defendant was entitled to an evidentiary hearing on the claim that the State failed to disclose an implied plea agreement with another witness. The court directed that the case be remanded for this limited evidentiary hearing. Thus, the judgment was affirmed in part and in part reversed and remanded with directions. View "State v. Elseman" on Justia Law

Fambrough v. City of E. Cleveland

2026-10-01T12:00:07-08:00

A politically active resident of East Cleveland, Ohio, who had long used a sound truck to broadcast political messages, supported a challenger in a mayoral primary. After this involvement, city officials began enforcing rarely used parking and noise ordinances against him. The plaintiff was warned, cited, had his truck impounded, and was prosecuted for a noise violation. He alleged that these actions were motivated by his support for the challenger and criticism of the administration. The plaintiff, along with his company, brought claims under 42 U.S.C. § 1983 against the city, the mayor, the mayor’s chief of staff, and the police chief, asserting First Amendment retaliation and prior-restraint violations, as well as Fourth and Fourteenth Amendment claims. The United States District Court for the Northern District of Ohio resolved all claims in favor of the defendants. Some claims—including First Amendment retaliation claims against the mayor and chief of staff—were dismissed at the pleading stage, while others were resolved at summary judgment. The court found that the ordinances were facially valid and that the plaintiff had either failed to establish the required elements for his claims or had forfeited certain arguments on appeal. On appeal, the United States Court of Appeals for the Sixth Circuit revived certain First Amendment retaliation claims. It held that the district court erred in applying the probable cause requirement to the retaliation claims against the mayor and chief of staff, reversing their dismissal. The court affirmed summary judgment for the police chief on qualified immunity grounds, finding no clearly established law that would make him liable as a conduit for another’s retaliatory motive. As to the city, the court vacated summary judgment on retaliation, remanding for further proceedings on whether municipal policy directly caused a constitutional violation. The court affirmed the district court on all other claims, including the prior-restraint and Fourth Amendment seizure claims, and noted that the plaintiff had forfeited his selective enforcement arguments on appeal. View "Fambrough v. City of E. Cleveland" on Justia Law

Beagle v. People

2026-10-01T09:22:14-08:00

In this case, the defendant allowed two sixteen-year-old girls who had run away from a treatment facility to stay in his home for ten days. During that period, he provided them with drugs and made repeated sexual advances, subjecting one girl to sexual contact. He later pleaded guilty to attempted sexual assault and distributing a controlled substance to a minor. A Sex Offender Management Board evaluator determined, using the Sexually Violent Predator Assessment Screening Instrument, that the defendant met the criteria of a sexually violent predator (SVP), largely based on his risk assessment score. The district court designated him as an SVP and sentenced him to fifteen years in prison, finding that the SVP designation was not punishment but rather intended to protect the community. The Colorado Court of Appeals affirmed the district court’s decision. The appellate division held that the SVP designation was not “punishment” under the Eighth Amendment, relying on prior precedent and distinguishing a recent case involving juvenile sex offender registration. The division noted some tension between the precedents, but concluded that the previous holding that SVP designation was not punishment remained controlling, as the juvenile case did not expressly overrule it. The Supreme Court of Colorado reviewed whether the SVP designation constitutes criminal punishment under the Eighth Amendment and, if so, whether it is cruel and unusual as applied. The court held that the Colorado General Assembly did not intend the SVP designation to be punitive, and that its effects do not, by the “clearest proof,” outweigh this nonpunitive intent. After analyzing statutory intent and applying the Mendoza-Martinez factors, the court concluded that the SVP designation and its accompanying requirements do not amount to punishment under the Eighth Amendment. Accordingly, the Supreme Court of Colorado affirmed the judgment of the court of appeals. View "Beagle v. People" on Justia Law

People v. Mena

2026-10-01T09:22:13-08:00

The defendant was charged with three counts of sexual assault and pleaded not guilty. During the jury trial, the prosecution submitted instructions for lesser-included attempt offenses, and the court accepted them over the defense’s objection. The jury received verdict forms allowing them to find the defendant not guilty of both the completed and attempted offenses, or guilty of one or the other, but could not indicate acquittal on the main charge while deadlocked on the lesser charge. After several days of deliberation, the jury notified the court in writing that it had reached a unanimous verdict on the main charges but was deadlocked on the lesser-included attempt offenses. The court confirmed the jury’s meaning through clarifying questions. Defense counsel requested revised verdict forms to allow the jury to separately indicate its decisions on the completed and attempted offenses, and also asked to poll the jury. The Larimer County District Court denied both requests and declared a mistrial on all charges. The defendant sought review under Colorado Appellate Rule 21, arguing that an ordinary appellate remedy was inadequate and he would otherwise suffer irreparable harm. The Supreme Court of Colorado, En Banc, reviewed the trial court’s decision for abuse of discretion. It found that the jury’s communication constituted a spontaneous and unequivocal partial verdict—namely, acquittal on the charged offenses. The trial court’s order for a complete mistrial violated the defendant’s right against double jeopardy under the Colorado Constitution. The Supreme Court held that the trial court abused its discretion by failing to accept the partial verdict and instead declared a mistrial as to all offenses. On remand, the defendant may be retried only for the attempt offenses, not for the completed sexual assault charges. View "People v. Mena" on Justia Law

Malcom v. Gray

2026-10-01T07:19:13-08:00

The case arose after the Wyoming Legislature amended the election code to require voters who wished to change their party affiliation before a primary election to do so at least 96 days prior to the primary. Several individuals were affected by this new deadline: some were unable to vote for their preferred candidates in the 2024 primary because they could not change party affiliation after the cutoff, while others, who ran for office, were unsuccessful in their respective primaries. The plaintiffs challenged the constitutionality of the 96-day party affiliation deadline, arguing it violated their rights under the Wyoming Constitution to open, free, and equal elections, untrammeled exercise of suffrage, and equal political rights. The District Court of Laramie County granted summary judgment in favor of the Secretary of State, holding that the statutes establishing the 96-day party affiliation deadline were a valid exercise of legislative authority to regulate elections and did not violate constitutional voting rights or equal protection. The plaintiffs appealed only the district court’s ruling on the party affiliation deadline. The Supreme Court of Wyoming reviewed the case de novo, considering only legal questions as the facts were stipulated. The Court held that the right to vote in Wyoming, including in primary elections, is fundamental, but that the legislature is also constitutionally charged with securing the purity of elections. Employing a balancing approach informed by the Anderson-Burdick standard, the Court found the 96-day deadline imposed only a slight burden on voting rights, justified by the state’s legitimate interest in preventing party raiding and ensuring orderly elections. The Court further held that the deadline did not violate equal protection, as all electors had an equal opportunity to affiliate before the cutoff, and distinctions drawn between new registrants and previously registered voters were not constitutionally impermissible. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Malcom v. Gray" on Justia Law

Pyle v. S.D. Division Of Criminal Investigation

2026-10-01T07:18:23-08:00

Brian Pyle sought a writ of mandamus to compel several South Dakota law enforcement agencies and officials to provide him with investigative records regarding the disappearance and death of his son, Ryan. Ryan was reported missing in August 2020, and his remains were found in November 2020 near the Snake Creek Recreation Area. Pyle alleged that he had made numerous requests for medical records and investigative reports, but had not received any documents. He cited Marsy’s Law in the South Dakota Constitution, asserting that as a victim or relative of a victim, he was entitled to these records. The Circuit Court of the First Judicial Circuit, Charles Mix County, initially issued a peremptory writ requiring the respondents to answer. The State, representing all respondents, moved to quash the writ, arguing that the requested records contained confidential criminal justice information exempt from disclosure by law, and that Pyle had not exhausted administrative remedies for accessing such records. The State also contended that, since law enforcement found no evidence of foul play and concluded no crime had occurred, Marsy’s Law did not apply. After a hearing, in which no testimony or evidence was presented, the circuit court granted the State's motion, quashed the writ, and denied Pyle's application, finding Pyle was not a victim under Marsy’s Law and that no mandatory duty existed to disclose the records. On appeal, the Supreme Court of the State of South Dakota reviewed the circuit court’s decision for abuse of discretion and questions of law de novo. The Supreme Court held that Marsy’s Law requires a crime to have occurred for someone to be considered a victim and to invoke its rights. Because law enforcement determined no crime had been committed, Pyle was not entitled to the records under Marsy’s Law. Further, the Supreme Court found that South Dakota statutes exempt criminal investigative records from mandatory disclosure. The circuit court’s decision was affirmed. View "Pyle v. S.D. Division Of Criminal Investigation" on Justia Law

CARVALHO VS. STATE

2026-10-01T07:09:11-08:00

The case concerns a fatal incident following an argument among Katrina Carvalho, her sister Regina, and Regina’s boyfriend, Vintell Johnson. After dinner, the three argued in Johnson’s apartment complex parking lot. Witnesses testified that Johnson shoved both sisters, and Carvalho was seen pointing a gun at Johnson and another bystander. Moments later, gunshots were heard, and Johnson was fatally wounded. The prosecution charged Carvalho with first-degree murder with the use of a deadly weapon. At trial, Carvalho’s defense was that another person, specifically Regina, may have fired the shots, and she highlighted weaknesses in the police investigation and the possibility of alternative suspects. The Second Judicial District Court, Washoe County, presided over the second trial after a mistrial was declared in the first due to late evidence disclosure. During closing arguments, the district court repeatedly interrupted, admonished, and ultimately sanctioned defense counsel for arguing that the evidence equally implicated Regina. The court instructed the jury not to consider Regina’s guilt or speculate about her involvement, effectively preventing the defense from fully presenting its alternative-suspect theory. The jury found Carvalho guilty, and she was sentenced to life in prison with the possibility of parole after 28 years. The Supreme Court of the State of Nevada reviewed the appeal. It held that the district court abused its discretion by foreclosing Carvalho’s opportunity to present an alternative-suspect defense, violating her due process right to a meaningful opportunity to present a complete defense. The court ruled that while a jury should not be asked to determine the guilt of someone other than the defendant, it is permissible for the defense to argue that reasonable doubt exists because the evidence supports an alternative suspect. The Supreme Court reversed the conviction and remanded the case for a new trial before a different department. View "CARVALHO VS. STATE" on Justia Law

MOTT v. STATE OF ARKANSAS

2026-10-01T07:02:18-08:00

On February 13, 2024, law enforcement found the body of Teangela Tate, who had died from gunshot wounds, near an interstate ramp in North Little Rock, Arkansas. Nearby, two young children were discovered: one deceased (MV1) from blunt-force trauma and environmental exposure, and another (MV2) alive but barely responsive. Evidence at the scene and subsequent investigation linked Willie Leon Mott, Jr. to the victims, including blood and shell casings in Mott’s house and his mother’s car, cell phone records showing travel to and from the crime scene, and DNA tests. Mott was arrested later that day, and during his incarceration, he attempted to have his mother destroy his cell phone. The Pulaski County Circuit Court presided over Mott’s trial. After the prosecution rested, Mott moved for directed verdicts, arguing insufficient evidence for each count and challenging the constitutional validity of a portion of Arkansas’s capital-murder statute. The circuit court denied these motions, finding the evidence sufficient and the statute not vague. Mott rested without presenting witnesses and renewed his motions, which were again denied. He received life sentences for first-degree murder, capital murder, and attempted capital murder. The Supreme Court of Arkansas reviewed the appeal. Applying the substantial evidence standard, the court determined that the jury’s verdicts were supported by the evidence, including circumstantial evidence and Mott’s actions to conceal his involvement. The court also reaffirmed prior decisions that the statutory language “under circumstances manifesting extreme indifference to the value of human life” is not unconstitutionally vague. The court affirmed the circuit court’s rulings and Mott’s convictions and sentences. View "MOTT v. STATE OF ARKANSAS" on Justia Law

Freilich v. SEPTA

2026-10-01T06:15:37-08:00

A pedestrian was severely injured when struck by a Southeastern Pennsylvania Transportation Authority bus while crossing an intersection in Philadelphia. The injuries required a partial left foot amputation and extensive ongoing medical care. The plaintiff retained counsel on the understanding that they would challenge the constitutionality of the statutory cap limiting damages recoverable from Commonwealth parties, set at $250,000 under Pennsylvania’s Sovereign Immunity Act. The complaint alleged negligence by SEPTA, which admitted liability; the parties then stipulated to a jury verdict with damages totaling $7 million, but SEPTA moved to reduce the award to the statutory cap. The Court of Common Pleas of Philadelphia County granted SEPTA’s motion to mold the verdict to $250,000 and denied delay damages, finding itself bound by prior Pennsylvania Supreme Court precedent, specifically Zauflik v. Pennsbury School District, which had upheld similar caps. The plaintiff appealed to the Commonwealth Court, which affirmed the trial court in an unpublished opinion. The Commonwealth Court reasoned that the damages cap did not violate the right to a jury trial or the constitutional right to a remedy, holding that the cap affected only the ultimate recovery, not the ability to prosecute the claim or access a jury trial. The Supreme Court of Pennsylvania, Eastern District, reviewed the case, focusing on whether the damages cap violates the Pennsylvania Constitution’s right to a jury trial or to a remedy. The court held that, as applied in this case, the statutory cap does not violate either constitutional right. The cap limits the remedy but does not restrict access to a jury trial or the process itself. The court affirmed the Commonwealth Court’s order, concluding that the legislature has authority to set such liability limits and that the cap is constitutional, even if it results in little or no recovery for the plaintiff. View "Freilich v. SEPTA" on Justia Law

Krasner v. Sunday

2026-10-01T06:15:37-08:00

The case concerns a challenge brought by the District Attorney of Philadelphia against Act 40 of 2023, which created the position of a special prosecutor to investigate and prosecute crimes occurring within the Southeastern Pennsylvania Transportation Authority (SEPTA). Act 40 gives the special prosecutor concurrent jurisdiction with district attorneys in counties served by SEPTA, except in Philadelphia, where the special prosecutor has exclusive authority, able to preempt the Philadelphia District Attorney at their sole discretion. The Act also limits the ability of criminal defendants to challenge the special prosecutor’s authority and prescribes procedures for local law enforcement and funding related to prosecutions. The District Attorney filed a petition for review in the Commonwealth Court of Pennsylvania, seeking declaratory and injunctive relief, arguing that Act 40 unconstitutionally infringed upon his powers and jurisdiction, constituted an impermissible special law, violated equal protection and procedural notice requirements, and improperly restricted criminal defendants’ rights. The Commonwealth Court, in a split en banc opinion, rejected these constitutional challenges, finding that the General Assembly has broad authority to regulate the powers and duties of home rule municipalities and their officers, including district attorneys, and that Act 40 did not violate the Pennsylvania Constitution. Concurring and dissenting opinions argued that Act 40 was unconstitutionally vague, restricted criminal defendants’ rights, and improperly divested the District Attorney of his jurisdiction. On direct appeal, the Supreme Court of Pennsylvania affirmed the Commonwealth Court’s order. The Supreme Court held that Act 40 does not violate the Pennsylvania Constitution, finding no constitutional source for exclusive prosecutorial powers and confirming the General Assembly’s authority to prescribe the duties of city officers. The Court also held that Act 40 does not constitute an impermissible local or special law, nor violate equal protection, and that the District Attorney lacked standing to raise the rights of criminal defendants under Act 40. View "Krasner v. Sunday" on Justia Law

Commonwealth. v. Jenkins

2026-10-01T05:41:18-08:00

On the night of February 14, 2017, the victim and her boyfriend, along with their children, dined with the appellant, Ronald Jenkins, a longtime friend. After returning to their apartment and consuming alcohol and marijuana, the victim felt unwell and asked Jenkins to leave. Jenkins refused and then violently assaulted the victim, causing her to lose memory of the remainder of the evening. Surveillance footage later showed Jenkins carrying the unconscious victim into his motel room. The victim awoke the next morning, partially undressed and confused, with signs of injury. Medical and forensic evidence established the presence of Jenkins’s semen in the victim. Jenkins denied any wrongdoing during police interviews, including a conversation conducted with his attorney present. The criminal trial took place in the Dauphin County Court of Common Pleas. During the Commonwealth’s closing argument, the prosecutor referenced Jenkins’s retention of counsel during his interview with police, suggesting it reflected consciousness of guilt. Jenkins’s counsel objected and moved for a mistrial, arguing the prosecutor’s remarks improperly prejudiced the jury. The trial court denied the mistrial but issued a prompt curative instruction, emphasizing the right to counsel and directing the jury not to draw adverse inferences. Jenkins was convicted and sentenced. On appeal, the Superior Court affirmed, finding the prosecutor’s remarks improper but concluding the curative instruction and overwhelming evidence rendered any error harmless. One judge dissented, asserting the error was incurable. The Supreme Court of Pennsylvania addressed whether the prosecutor’s reference to Jenkins’s pre-arrest retention of counsel violated his right to a fair trial and whether such error was structural or subject to harmless error analysis. The Court held that the prosecutor’s comment was improper and impacted Jenkins’s due process right, but not a structural error requiring automatic reversal. Considering the timely curative instruction and overwhelming evidence, the error was harmless beyond a reasonable doubt. The judgment of the Superior Court was affirmed. View "Commonwealth. v. Jenkins" on Justia Law

State of Minnesota vs. Brown

2026-10-01T01:15:17-08:00

After a fatal shooting in a shared Minneapolis apartment, the defendant was charged with first-degree murder while committing domestic abuse with a past pattern of domestic abuse, as well as being a prohibited person in possession of a firearm. The defendant and the victim had been in a relationship and lived together; on the day of the incident, the victim had communicated to others her intention to end their relationship. Later that day, following an argument, the defendant called 911 twice to report a shooting, providing inconsistent information about his location. When police arrived at the apartment, they found the victim dead from a gunshot wound. At trial, the State presented evidence of the defendant’s prior abusive conduct toward several other romantic partners, as well as expert testimony on the dynamics of domestic violence. The Hennepin County District Court conducted the jury trial. During jury selection, the State used a peremptory strike on the only remaining Black venire member, prompting a Batson challenge by the defense, which was denied. The district court allowed the State’s domestic violence expert testimony, over defense objections. The jury found the defendant guilty on all counts, and the district court entered convictions for first-degree murder and firearm possession, sentencing the defendant to life with the possibility of release after 30 years. On direct appeal to the Minnesota Supreme Court, the defendant raised four main issues: the denial of his Batson challenge, the admission of domestic violence expert testimony, alleged prosecutorial misconduct during closing arguments, and the absence of a specific-unanimity jury instruction regarding the domestic abuse element. The Minnesota Supreme Court held that the district court did not clearly err in denying the Batson challenge, did not abuse its discretion in admitting the expert testimony, and that the prosecutor’s statements did not constitute misconduct. Furthermore, it found that any instructional error did not affect the defendant’s substantial rights. The court affirmed the convictions. View "State of Minnesota vs. Brown" on Justia Law

In re Petition for the Coordination of Individual Plaintiffs Maui Fire Cases

2026-09-30T15:31:39-08:00

Following the devastating 2023 Lahaina wildfires in Maui, which caused significant loss of life and property, numerous victims initiated litigation against various parties including Hawaiian Electric, the State of Hawaiʻi, the County of Maui, and others. To manage the complex and large-scale proceedings, the Circuit Court of the Second Circuit established a special coordination proceeding, appointed liaison counsel, and ultimately oversaw a $4.037 billion global settlement. A major issue arose regarding attorney fees: the court issued an order capping contingency fees, creating a $222 million Common Benefit Fund for attorneys whose collective efforts benefited all claimants, and appointing a Common Fee Review Board to allocate the fund. Prior to this appeal, the Circuit Court of the Second Circuit managed the coordination, administered discovery, approved the settlement, and issued the attorney fee order. Claimant Michael Bates and attorneys Anthony Ranken, Alex Edrenkin, and John Thickstun challenged the court’s authority to issue the fee order, arguing it was void due to lack of jurisdiction, violated constitutional rights, and improperly limited review of fee awards. They appealed to the Intermediate Court of Appeals and petitioned the Supreme Court of Hawaiʻi for extraordinary writs. The Supreme Court of Hawaiʻi, after accepting transfer, determined it had jurisdiction under the collateral order doctrine and HRS § 602-5(a)(6). The court held that the Circuit Court had authority to issue the fee order based on the ongoing special proceeding and the equitable common fund doctrine. However, three provisions that barred or penalized appeals of fee awards were vacated as they violated statutory and constitutional rights to review. The remainder of the fee order—including the creation of the Common Benefit Fund, the tiered fee schedule, and the processes for fee awards—was affirmed. The constitutional and abuse of discretion challenges were rejected, and the case was remanded for further proceedings consistent with the opinion. View "In re Petition for the Coordination of Individual Plaintiffs Maui Fire Cases" on Justia Law

People v. Barraza

2026-09-30T11:31:15-08:00

The case involves an incident in which Alberto Jorge Barraza confronted Nikko G., a man known for his long hair and pride in his Native American heritage. Nikko had expressed plans to sell his hair to a company making wigs. After Barraza and associates perceived Nikko had stolen from them, they discussed cutting off his hair as punishment. Barraza approached Nikko while he was asleep in a car, attempted to cut off his hair with a knife, and when Nikko resisted, stabbed him in the leg, resulting in Nikko’s death due to a severed artery. Following these events, a jury in the Superior Court of San Diego County convicted Barraza of first degree felony murder, with the underlying felony being robbery, as well as assault with a deadly weapon. The jury found several enhancements true, including personal use of a deadly weapon and infliction of great bodily injury. The trial court sentenced Barraza to 25 years to life for murder, plus a consecutive term for the weapon enhancement, while staying the sentence for the assault conviction and related enhancements. On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reviewed whether the evidence supported the felony murder conviction, specifically whether forcibly cutting attached hair constitutes robbery under Penal Code section 211. The court held that growing human hair, still attached to a person’s head, is part of the human body and not personal property as required for robbery. Therefore, forcibly cutting attached hair does not satisfy the legal definition of robbery, and the evidence did not establish robbery or attempted robbery. The court reversed Barraza’s conviction for first degree felony murder. View "People v. Barraza" on Justia Law

Tate v. Warden GDCP

2026-09-30T11:00:55-08:00

In December 2001, a 21-year-old man and his two younger brothers planned and carried out the murders of a woman, Chrissie Williams, and her three-year-old daughter, Katelyn, in Georgia. The crime involved home invasion, use of weapons, and acts of extreme violence and sexual assault. After fleeing the state and being apprehended, the brothers entered plea agreements: the two younger brothers received life sentences with parole eligibility, while the petitioner, after initially negotiating for a similar deal, ultimately rejected a plea offer and decided to plead guilty, influenced by religious beliefs that demanded confession and acceptance of the death penalty. The Superior Court of Paulding County accepted the petitioner’s guilty plea and, following a bench sentencing trial at his request, imposed the death penalty. The Georgia Supreme Court affirmed his convictions and sentences on direct appeal. After a failed “next friend” habeas attempt by a brother, the petitioner filed his own state habeas petition, arguing ineffective assistance of counsel and other constitutional violations. While the state habeas court initially granted relief on the sentencing, the Georgia Supreme Court reversed, reinstating the death sentence. The petitioner then pursued federal habeas relief in the United States District Court for the Northern District of Georgia, which denied relief but granted a certificate of appealability on selected claims. The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the Georgia Supreme Court’s denial of the petitioner’s claims was not an unreasonable application of clearly established federal law or an unreasonable determination of the facts. The court found that trial counsel’s recommendation to waive a jury for sentencing was reasonable, that no prejudice resulted from counsel’s alleged failure to investigate mitigating evidence due to the petitioner’s own instructions, and that the prosecution’s use of alternative theories in codefendants’ proceedings did not violate constitutional rights. The district court’s denial of habeas relief was affirmed. View "Tate v. Warden GDCP" on Justia Law

AMERICANS FOR PROSPERITY V. MEYER

2026-09-30T08:30:36-08:00

Arizona voters approved Proposition 211, the Voters’ Right to Know Act, to address “dark money” in elections by requiring disclosure of the original sources of major campaign media spending, including contributions passed through intermediaries. The law applies to individuals and entities that spend significant amounts on campaign media, mandating public disclosure of donors who directly or indirectly contribute more than $5,000 per election cycle. It also includes recordkeeping requirements, opt-out provisions for donors, and enforcement by the Citizens Clean Elections Commission. Plaintiffs, Americans for Prosperity and its Foundation, alleged that these compelled disclosures and requirements violate their First Amendment rights by chilling speech and association, and they sought to enjoin the law. The case was first heard in the United States District Court for the District of Arizona. The plaintiffs advanced both facial and as-applied constitutional challenges. The district court applied the Supreme Court’s exacting scrutiny standard and dismissed all claims, finding Proposition 211 substantially related to Arizona’s strong informational interest, imposing only modest administrative burdens, and being narrowly tailored. The court noted the opt-out provision protected donors and that plaintiffs did not allege sufficient facts for an as-applied challenge. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that Proposition 211’s disclosure requirements were substantially related to Arizona’s important governmental interest in electoral transparency, imposed modest burdens, and were narrowly tailored. The appellate court rejected the plaintiffs’ facial challenge, finding they did not demonstrate a substantial number of unconstitutional applications. The as-applied challenge failed for lack of specific allegations of harm. The court also affirmed the dismissal of compelled association claims, finding no unconstitutional compulsion. The disposition by the Ninth Circuit was to affirm the district court’s dismissal of all claims. View "AMERICANS FOR PROSPERITY V. MEYER" on Justia Law

Blackman v. Substack

2026-09-29T15:01:44-08:00

The plaintiff, who was the CEO of a private company with government contracts and a security clearance, was arrested in December 2021 for felony domestic violence. Although no charges were filed, police prepared an investigative report. In February 2022, the San Francisco Superior Court ordered the arrest and related records sealed under California Penal Code sections 851.91 and 851.92. Despite this, the police department released the incident report to a third party without restriction, and it was later sent anonymously to an independent journalist who published articles about the plaintiff’s arrest online, including the report. The plaintiff sought to have the posts removed and subsequently sued the journalist, the platform hosting the articles, and another entity associated with the journalist, alleging multiple causes of action including privacy violations and statutory breaches. The San Francisco County Superior Court reviewed anti-SLAPP motions filed by all defendants, which argued the suit arose from constitutionally protected activity and was barred by the First Amendment and the Communications Decency Act (CDA). The court found that the plaintiff’s claims were based on the defendants’ speech—specifically, online publication in a public forum about a matter of public interest, given the plaintiff’s role and the company's government work. It also determined that statutory protections for sealing did not override constitutional protections, and rejected the argument that defendants’ actions were illegal as a matter of law. The court granted the anti-SLAPP motions and awarded attorney fees to the defendants. The Court of Appeal of the State of California, First Appellate District, Division Four affirmed the trial court’s orders. The main holding was that the First Amendment protects the lawfully obtained, truthful publication of information of public significance, even if the information was originally subject to statutory sealing, and that section 230(c)(1) of the CDA bars claims against interactive computer service providers for hosting such content. The attorney fee award was also affirmed. View "Blackman v. Substack" on Justia Law

FOWLER v. STITT

2026-09-29T07:10:00-08:00

Three transgender individuals sought to amend the sex designations on their Oklahoma birth certificates to align with their gender identities. They obtained state court orders directing these changes, but when presented to the Oklahoma State Department of Health, the applications were denied. The denial was based on an executive order issued by the Governor, which instructed the agency to cease amending birth certificates in ways not explicitly permitted by Oklahoma law. Plaintiffs filed suit in the United States District Court for the Northern District of Oklahoma, raising equal protection and due process claims against state officials. The District Court granted the defendants’ motion to dismiss, and plaintiffs appealed to the United States Court of Appeals for the Tenth Circuit. The Tenth Circuit affirmed dismissal of the due process claim but reversed on the equal protection claim. Defendants sought certiorari in the United States Supreme Court, which issued a Grant, Vacate, Remand order directing the Tenth Circuit to reconsider in light of United States v. Skrmetti, 605 U.S. 495 (2025). Subsequently, the Tenth Circuit certified three questions of Oklahoma law to the Supreme Court of Oklahoma. The Supreme Court of the State of Oklahoma held that Oklahoma Statute 63 O.S. § 1-321, as amended by § 1-321(H), prohibits changes to the sex designation on an Oklahoma birth certificate. The court further determined that neither current nor prior versions of the statute have ever permitted such changes, whether based on gender identity or otherwise. The answers to the certified questions were: 1) yes, the statute prohibits changes; 2) no, it has never permitted such changes; and 3) no, it does not now nor has ever permitted changes based on gender identity. View "FOWLER v. STITT" on Justia Law

Edwards v. Randolph County Sheriff

2026-09-28T12:31:00-08:00

A woman was arrested in Randolph County, Alabama, under a system that required arrestees to pay a predetermined bail amount based on the charged offense for immediate release. Those unable to pay had to wait until an initial appearance, which could take up to three days, and frequently did not result in a release determination. Instead, release decisions were often deferred until a preliminary hearing up to four weeks later. The plaintiff, unable to afford bail, filed a class action alleging that the county’s bail practices discriminated against indigent individuals and violated their constitutional rights. The United States District Court for the Middle District of Alabama initially granted a temporary restraining order, releasing the plaintiff. While the case was pending, Randolph County adopted a new, more permissive bail policy. Defendants moved to dismiss the case as moot, arguing the new policy ended the challenged conduct. The district court certified a class of arrestees unable to pay secured bail, but after the Supreme Court denied certiorari in a similar case, Schultz v. Alabama, the district court dismissed most claims as moot, limiting plaintiffs to facial challenges against the new policy, and concluded those remaining claims failed to state a plausible claim for relief. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal. The court held that the voluntary cessation doctrine precludes defendants from mooting the case simply by changing the bail policy during litigation. The class may proceed with facial and as-applied challenges to the prior bail practices, as well as as-applied challenges to the current bail practices. However, the court affirmed the district court’s dismissal of facial challenges to the current bail policy. The case was remanded for further proceedings consistent with these holdings. View "Edwards v. Randolph County Sheriff" on Justia Law

TC Telephone v. Pub. Utilities Com.

2026-09-28T11:01:42-08:00

TC Telephone participated as a provider in California’s LifeLine program, offering measured-rate telephone service to low-income customers. This service allowed subscribers 60 untimed local calls per month, for which TC Telephone incurred per-minute charges from other carriers. To recoup its costs, TC Telephone sought and received reimbursement from the California Public Utilities Commission (the Commission) based on the total minutes used, rather than per-call. Over several years, Commission staff approved these per-minute reimbursement claims and provided guidance that was ambiguous about the proper method for calculating reimbursements. The Commission began investigating TC Telephone’s reimbursement practices after concerns arose regarding claim amounts. In March 2020, the Commission issued a resolution clarifying that LifeLine providers should seek reimbursement on a per-call basis, not per-minute, and specified that this clarification applied prospectively. However, the Commission subsequently initiated proceedings to determine whether TC Telephone’s prior per-minute reimbursement claims violated program rules. In its initial decision, the Commission found that TC Telephone had improperly sought per-minute reimbursement and ordered it to repay over $8 million in funds received between January 2018 and March 2020, plus interest. TC Telephone’s petition for rehearing was denied. The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the Commission’s decisions. The court held that prior to the Commission’s resolution, the reimbursement rules were unconstitutionally vague and failed to provide TC Telephone with fair notice that per-minute reimbursement was prohibited. Because even Commission staff did not know whether per-minute reimbursement was allowed, punishing TC Telephone for its claims violated due process. The court annulled the Commission’s decisions and remanded the matter for further proceedings. View "TC Telephone v. Pub. Utilities Com." on Justia Law

Mason v. Talley

2026-09-28T10:30:43-08:00

The plaintiff, a convicted inmate at Riverside Regional Jail, was placed in restrictive housing after being found with contraband, and later spent five months in the Restrictive Housing Unit (RHU) due to repeated infractions and misconduct. During this period, he experienced varying levels of confinement and privileges, including periods of isolation, limited access to recreation, and additional restrictions following disciplinary incidents. He was also shackled to a telephone on two occasions for several hours, during which he alleged suffering humiliation and physical discomfort. The United States District Court for the Eastern District of Virginia granted summary judgment to the jail officials, both before and after limited discovery. The court dismissed all but two defendants and ordered production of any surveillance video related to the incidents. After reviewing the available evidence, including video footage, the district court rejected the plaintiff’s claims regarding conditions of confinement and due process violations. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The panel held that the district court did not abuse its discretion in granting summary judgment before discovery, as the plaintiff failed to show that additional evidence would have affected the outcome. Reviewing de novo, the Fourth Circuit concluded that the plaintiff’s placement in restrictive housing did not implicate a protected liberty interest under the Fourteenth Amendment because the conditions, duration, and review process did not constitute atypical and significant hardship. The court also found that the conditions of confinement—including the telephone shackling incidents—did not rise to the level of “extreme deprivation” required for an Eighth Amendment violation, and even if they had, the officials would be entitled to qualified immunity because no clearly established right was violated. The judgment of the district court was affirmed. View "Mason v. Talley" on Justia Law

DIEMERT V. CITY OF SEATTLE

2026-09-28T08:00:33-08:00

A white male employee of Seattle’s Human Services Department alleged that the City’s Race and Social Justice Initiative (RSJI) classified employees according to race, and that a series of workplace incidents—including racially aligned affinity groups, race-specific trainings, and racially offensive remarks from coworkers and supervisors—created a hostile work environment. He asserted that the RSJI and workplace conduct led to discrimination, retaliation, constructive discharge, and violation of his equal protection rights. After resigning in September 2021, he filed suit alleging claims under Title VII, the Washington Law Against Discrimination (WLAD), and the Equal Protection Clause. The United States District Court for the Western District of Washington dismissed as time-barred certain Title VII and WLAD claims based on acts predating statutory limitations periods. It granted summary judgment to the City on the remaining claims, finding insufficient evidence of actionable discrimination, retaliation, hostile work environment, constructive discharge, or equal protection violations. The court partially granted the City’s evidentiary objections to exhibits offered by the plaintiff. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s summary judgment de novo. The appellate court affirmed summary judgment for the City on the constructive discharge, disparate treatment, and retaliation claims, and also affirmed summary judgment on the Equal Protection Clause claim for lack of Article III standing. However, viewing the evidence in the light most favorable to the plaintiff, the Ninth Circuit reversed summary judgment on the hostile work environment claims under Title VII and WLAD, holding that there was a genuine issue of material fact as to whether the plaintiff was subjected to a racially hostile work environment. The case was remanded for further proceedings consistent with this determination. View "DIEMERT V. CITY OF SEATTLE" on Justia Law

People Not Politicians v. Onder

2026-09-28T05:15:04-08:00

Missouri enacted a congressional redistricting map in 2022 and then adopted a new map in 2025. Under the Missouri Constitution, a newly enacted law like the 2025 map does not become effective until approved by voters in a referendum, provided enough signatures are collected for such a petition. The Missouri Supreme Court held in September 2026 that the 2025 map “is not the law and has never been the law” and would not take effect unless approved in the 2026 election referendum, so the 2022 map remained in force for the upcoming election. After the Missouri Supreme Court’s ruling, a group of voters and candidates filed suit in federal court, arguing that the U.S. Constitution required Missouri to use the 2025 map in the 2026 election. The U.S. District Court for the Eastern District of Missouri issued a temporary restraining order on September 8, effectively requiring the use of the 2025 map. However, this order was stayed by the Supreme Court of the United States on September 10. Despite this, the U.S. Court of Appeals for the Eighth Circuit subsequently ordered the District Court to enter a permanent injunction requiring use of the 2025 map, prompting further review. The Supreme Court of the United States granted a stay of the District Court’s September 21 and 22 injunctions and the Eighth Circuit’s mandate and order, maintaining the prior stay, and prohibiting any federal court orders requiring use of the 2025 map in the 2026 election. The Court held that the 2022 map must be used in the ongoing election, given Missouri law and the Purcell principle, which discourages altering election rules during an ongoing election. The Supreme Court’s stay will remain unless further order is issued. View "People Not Politicians v. Onder" on Justia Law

United States v. Walker

2026-09-25T12:00:08-08:00

Walker was involved in a scheme with two others to distribute cocaine. He arranged for cocaine to be mailed from a supplier near the U.S.-Mexico border, using one co-conspirator to send the packages and a postal worker whom he paid to deliver them along his mail routes. Law enforcement intercepted two cocaine packages, observed Walker conducting drug sales from his girlfriend’s home, and later searched that residence, finding drugs, paraphernalia, and Walker’s phone. Walker confessed to drug activities after the search. The United States District Court for the Western District of Michigan denied Walker’s motion to suppress evidence from the residence, finding probable cause for the search warrant and, alternatively, that the good-faith exception applied. At trial, the jury convicted Walker on all counts related to the drug conspiracy, and he was sentenced to 360 months’ imprisonment. Walker appealed to the United States Court of Appeals for the Sixth Circuit, raising three main issues. First, he argued that the evidence from the search should have been suppressed. The Sixth Circuit found the warrant affidavit was sufficient to establish probable cause and, even if not, that the officers' reliance on the warrant was objectively reasonable under the good-faith exception. Second, Walker challenged the admission of statements he made during a proffer session, asserting protection under Federal Rule of Evidence 410. The appellate court held that Walker, through counsel, had waived this argument by conceding that certain statements were admissible due to their inconsistency with his trial defense. Third, Walker argued a violation of his Confrontation Clause rights regarding a co-defendant’s testimony. The court found this right was also waived when Walker and his counsel agreed to a curative instruction for the jury to disregard the testimony. The Sixth Circuit affirmed the convictions. View "United States v. Walker" on Justia Law

KalshiEX LLC v. Schuler

2026-09-25T12:00:08-08:00

A financial services company operating a designated contract market began offering sports-event contracts, which allowed users to buy and sell positions based on the outcome of various sporting events. These offerings attracted the attention of Ohio and Tennessee state gambling regulators, who asserted that the company was violating state gambling laws by operating without appropriate licenses and by allowing underage users to participate. Both states sent cease-and-desist letters to the company, demanding it stop offering sports-event contracts to their residents. The company, which claimed to be federally authorized under the Commodity Exchange Act (CEA), argued that federal law preempted state regulation of its activities. In Ohio, the company filed suit in the United States District Court for the Southern District of Ohio, seeking a preliminary injunction to prevent enforcement of state gambling laws against it. The district court denied the injunction, finding the company had not demonstrated that its sports-event contracts were “swaps” subject to exclusive jurisdiction of the Commodity Futures Trading Commission (CFTC) and, even if they were, had not established federal preemption. The company appealed. In Tennessee, a similar suit was filed in the United States District Court for the Middle District of Tennessee, which granted a preliminary injunction, holding the company was likely to succeed because the contracts constituted “swaps” and conflict preemption applied. Tennessee officials appealed. The United States Court of Appeals for the Sixth Circuit reviewed both cases together. It held that the company’s sports-event contracts did not satisfy the statutory definition of a “swap” under the CEA and thus did not fall within CFTC exclusive jurisdiction. The court further held that, even assuming the contracts were swaps, the CEA neither expressly nor impliedly preempted Ohio’s or Tennessee’s gambling laws. The Sixth Circuit affirmed the denial of the preliminary injunction in Ohio, vacated the grant of the injunction in Tennessee, and remanded for further proceedings. View "KalshiEX LLC v. Schuler" on Justia Law

USA v Howard

2026-09-25T11:30:08-08:00

A man who served as a confidential informant for the Department of Homeland Security became involved in criminal activity by continuing to deal drugs while cooperating with law enforcement. He developed a corrupt relationship with his handler, a special agent, who was later convicted of federal corruption charges. The informant’s unauthorized criminal conduct was uncovered when he became the target of two separate narcotics sting operations. Following his arrest, law enforcement searched his home and cell phone, and he was charged with multiple drug-related crimes. In proceedings before the United States District Court for the Northern District of Illinois, the defendant moved to suppress his post-arrest statements and evidence obtained from the warrantless searches of his home and cell phone. The district court suppressed his post-arrest statements as involuntary but denied suppression of the physical evidence, holding it admissible under the inevitable discovery doctrine. The court also denied his motions to dismiss for vindictive prosecution, sever various counts for trial, and quash a subpoena to his former handler, who invoked his Fifth Amendment right against self-incrimination. The case proceeded to a jury trial, where the defendant was convicted on three drug counts but acquitted on one. His post-trial motions for acquittal or a new trial were denied, and he was sentenced to 156 months in prison. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not abuse its discretion in quashing the subpoena, that the inevitable discovery doctrine applied to the search evidence, and that the evidence was sufficient to support the convictions. The court also determined that the defendant’s other claims were either waived or without merit, and it found no abuse of discretion in the sentence imposed. View "USA v Howard" on Justia Law

MEDRANO V. ACOSTA

2026-09-25T08:30:30-08:00

Two police officers attempted to execute a felony arrest warrant for a man believed to be affiliated with a local gang. The officers were aware of a recent incident in which the man had fled a traffic stop and believed he was an active fugitive wanted for serious drug-related offenses. Although the warrant had been recalled days before, the police database had not been updated, and the officers were unaware of this development. They located the man in a backyard, approached from ten to twenty feet away with their guns drawn, and ordered him to climb a fence and submit to arrest. The man claims both officers aimed their guns at his head, causing him fear and shock, but he complied without incident. After the arrest, the man was detained and later released when it was confirmed the warrant was no longer active. He filed a lawsuit in the United States District Court for the Central District of California, alleging the officers used excessive force in violation of his Fourth Amendment rights. The district court denied the officers’ motion for summary judgment, finding that a reasonable juror could conclude they used excessive force by aiming their weapons at the man’s head, and that this conduct was a clear violation of an established constitutional right. Reviewing the case, the United States Court of Appeals for the Ninth Circuit reversed the district court’s decision. The appellate court held that, under the circumstances, the officers did not violate the Fourth Amendment by approaching with weapons drawn, given their reasonable belief that the man was a serious and potentially dangerous fugitive who might resist or flee. The court further found that, even if excessive force had been used, there was no clearly established law making the officers’ conduct unlawful in these circumstances. The case was remanded with instructions to enter judgment for the officers. View "MEDRANO V. ACOSTA" on Justia Law

Anthropic PBC v. United States Department of War

2026-09-25T07:01:01-08:00

A technology company developed an artificial intelligence system and imposed contractual and technical restrictions to prevent its use for fully autonomous lethal military operations and mass domestic surveillance. The company had previously adapted its product to meet some government needs but refused to remove these two key restrictions when the Department of War (formerly the Department of Defense) sought contractual terms allowing all lawful uses of the AI system. This disagreement coincided with a dispute over the product’s use in a sensitive military operation and previous incidents where the AI’s restrictions prevented it from fulfilling government requests. As a result, the Secretary of War determined that continued use of the AI posed a national security risk and ordered its removal from the Department’s supply chain under the Federal Acquisition Supply Chain Security Act of 2018. The Department promptly notified the company, offered an opportunity for reconsideration, and began implementing the exclusion. The company petitioned the United States Court of Appeals for the District of Columbia Circuit for review and raised statutory and constitutional challenges, arguing that the exclusion was arbitrary, beyond statutory authority, and violated due process and First Amendment rights. The company also sought a stay, which was denied, and later requested rescission, which was also denied by the Secretary. The United States Court of Appeals for the District of Columbia Circuit held that it had jurisdiction under the statute to review the procurement action. The court found the Department’s determination reasonable, concluding that the company’s ability and willingness to restrict the AI’s use posed a covered “supply chain risk” under the statute, even without evidence of malicious intent. The court also held that less intrusive measures were not reasonably available, and that any procedural deficiencies in notice did not prejudice the company. The court further held that the exclusion did not violate the Fifth or First Amendments. The petitions for review were denied. View "Anthropic PBC v. United States Department of War" on Justia Law

United States v. Ceasar

2026-09-25T07:00:10-08:00

The case involves a defendant who, after pleading guilty to conspiring to provide material support to ISIS, was released on bail but later violated release conditions, including absconding from supervision and failing to appear at a court-ordered status conference. Her conduct included removing an electronic monitoring device and attempting to flee, resulting in her rearrest. She later entered into a plea agreement, waiving indictment and pleading guilty to failure to appear under 18 U.S.C. § 3146, as well as agreeing to an enhancement under 18 U.S.C. § 3147 for committing the offense while on release. In exchange for her plea, the government agreed not to pursue additional charges carrying potentially higher penalties. After her guilty plea but before sentencing, the defendant moved to withdraw her plea, arguing her conduct did not fall within the scope of § 3146 because she was not released under the Bail Reform Act. The United States District Court for the Eastern District of New York denied her motion, finding a factual basis for her plea, rejecting her arguments, and sentencing her to 230 months’ imprisonment, including consecutive sentences for failure to appear and the § 3147 enhancement. On appeal to the United States Court of Appeals for the Second Circuit, the defendant argued the district court erred in denying her plea withdrawal and that applying the § 3147 enhancement violated the Double Jeopardy Clause. The Second Circuit held that the defendant’s appellate waiver, which expressly foreclosed challenges that her conduct was outside the statute’s scope, barred her first claim. The court further held that applying the § 3147 enhancement to a § 3146 conviction does not violate the Double Jeopardy Clause, as Congress clearly intended cumulative punishments. The Second Circuit therefore dismissed the appeal in part and otherwise affirmed the district court’s judgment. View "United States v. Ceasar" on Justia Law

AZHAR v. CHOUDHRI

2026-09-25T06:10:21-08:00

A husband and wife, both originally from Pakistan, married there in 2008 before moving to Houston, Texas, where they accumulated substantial community assets during their marriage. The wife alleges she suffered ongoing abuse from the husband. In 2012, the husband sent the wife back to Pakistan under the pretext of renewing her visa, and in early 2013, he divorced her without her knowledge via a unilateral Islamic talaq proceeding in Pakistan. The wife was not informed of the proceedings, was not served with process, and only learned of the divorce two years later. Upon returning to Houston, she filed for divorce and sought a division of marital property in Texas. The 295th District Court of Harris County dismissed the wife’s divorce petition for lack of jurisdiction, granting comity to the Pakistani divorce judgment. The trial court found that under Pakistani law, the wife was precluded from further property claims, and since Pakistan does not recognize community property, the court rendered a take-nothing judgment against her. The Court of Appeals for the First District of Texas affirmed this judgment, agreeing that the Pakistani proceedings were conclusive. The Supreme Court of Texas reviewed the case and reversed the lower courts’ decisions. It held that the notice provided to the wife—five days of publication in a small Pakistani newspaper—was constitutionally inadequate when the husband could have easily provided direct notice. The court determined that such notice failed to satisfy fundamental principles of due process and natural justice, and that Texas courts may not afford comity to a foreign judgment obtained through procedures that violate constitutional guarantees. The case was remanded to the trial court for further proceedings consistent with this opinion. View "AZHAR v. CHOUDHRI" on Justia Law

Welty v. Dunaway

2026-09-24T13:00:07-08:00

After the Supreme Court’s Dobbs decision, Tennessee enacted a near-total abortion ban and later passed the Underage Abortion Trafficking Act, which included the “Recruitment Provision.” This provision criminalizes intentionally recruiting an unemancipated minor for an abortion that would be illegal in Tennessee, even if the procedure is legal where performed. Two advocates for abortion rights, Welty and Behn, regularly provide counseling and information to minors about obtaining legal abortions, including out-of-state options. Concerned that the new law would criminalize their advocacy and speech, they filed a pre-enforcement suit against several district attorneys general, alleging First Amendment violations. The case was first reviewed by the United States District Court for the Middle District of Tennessee. After a preliminary injunction hearing and cross-motions for summary judgment, the district court granted summary judgment in favor of Welty and Behn, holding that the Recruitment Provision is both unconstitutional as applied and facially overbroad under the First Amendment. The district court issued an injunction preventing enforcement of the Recruitment Provision by the defendants, but rejected the plaintiffs’ claim that the law was unconstitutionally vague. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s rulings de novo. The Sixth Circuit affirmed the lower court’s holding, concluding that the Recruitment Provision constitutes unconstitutional viewpoint discrimination and is substantially overbroad, thus facially violating the First Amendment. The court determined that the statute impermissibly restricts protected speech regarding legal abortions and cannot survive strict scrutiny. The court also affirmed the scope of the district court’s injunction, which barred enforcement of the Recruitment Provision. View "Welty v. Dunaway" on Justia Law

People v. Cortez

2026-09-24T12:31:11-08:00

The defendant was convicted after jury trials in 2011 and 2012 of attempted murder, evading an officer, unlawfully taking a vehicle, and shooting at an inhabited dwelling. Each count included enhancements for gang involvement and firearm use, and he was sentenced to a total of 46 years and eight months to life in prison. Following direct appeal, the judgment was modified to reflect life with the possibility of parole on two counts, with a minimum parole eligibility of 15 years, and otherwise affirmed. Years later, the defendant filed a petition for recall and resentencing under California Penal Code section 1170, subdivision (d)(1), arguing that as a juvenile at the time of the offense and having served over 15 years, his lengthy sentence was effectively a life without parole (LWOP) term. He relied on appellate decisions holding that juvenile offenders sentenced to de facto LWOP terms should be eligible for relief under section 1170, subdivision (d)(1), on equal protection grounds. The Los Angeles County Superior Court reviewed the petition, considered recent appellate decisions and parties’ arguments, and denied the petition. The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. Applying de novo review, it held that the defendant’s sentence did not constitute the functional equivalent of LWOP, as he was eligible for youthful offender parole under section 3051 at age 41. The court determined that section 1170, subdivision (d)(1) only applies to explicit LWOP sentences for juveniles and does not violate equal protection by excluding those sentenced to lengthy indeterminate terms. It affirmed the trial court’s denial of the petition. View "People v. Cortez" on Justia Law

Cervantes v. Bianco

2026-09-24T09:01:52-08:00

A group of Riverside County residents, having voted in the November 2025 special election on Proposition 50, challenged the actions of the county sheriff’s department. The sheriff, responding to claims by a community group of a significant discrepancy between unofficial poll worker ballot intake logs and the Registrar of Voters’ final certified count, obtained search warrants and seized approximately 650,000 voted ballots. The Registrar of Voters maintained any discrepancy was minimal and within normal bounds, and no party disputed that the alleged discrepancy could not have changed the election outcome. After the sheriff’s department seized and began examining the ballots, the voters filed a petition for a writ of mandate directly in the Supreme Court of California. They argued the sheriff’s actions violated the Elections Code’s strict rules regarding the custody of ballots and requested the court order the immediate return of the ballots to the Registrar. The Registrar did not oppose this relief, and both the Secretary of State and Attorney General supported the petitioners’ position. The sheriff argued his actions were lawful as part of a criminal investigation supported by search warrants. The Supreme Court of California held that the seizure and removal of the ballots from the Registrar’s custody was unlawful under Elections Code section 15551, subdivision (d). The Court explained that the Elections Code specifically requires that voted ballots remain in the custody of the elections official at all times and that this rule applies even during criminal investigations. The Court issued a peremptory writ of mandate directing the sheriff to return all packages containing voted ballots to the Registrar and to refrain from further handling of the ballots, but denied the request for additional relief regarding non-ballot election materials and chain-of-custody reporting. The Court’s order superseded the previously issued superior court search warrants to the extent of any conflict. View "Cervantes v. Bianco" on Justia Law

People v. Benson

2026-09-24T06:03:43-08:00

The defendant was charged with reckless discharge of a firearm, unlawful possession of a weapon by a felon (UPWF), and misdemeanor domestic battery after an incident in his Chicago apartment. He had a prior felony conviction for aggravated unlawful use of a weapon, specifically for possessing a firearm without a valid Firearm Owners Identification (FOID) card. Evidence at trial showed he possessed and fired a handgun during a domestic dispute. The circuit court of Cook County, after a bench trial, found him guilty on all counts. On direct appeal to the Illinois Appellate Court, the defendant challenged the constitutionality of the UPWF statute under the Second Amendment, arguing both facially and as applied to him in light of New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The appellate court rejected both challenges, holding that Bruen’s standards did not apply to felons and that sufficient historical precedent supported felon firearm bans. The appellate court also considered and rejected the defendant’s as-applied challenge, despite the State’s argument that the issue was forfeited because it was not raised before the circuit court. The Supreme Court of the State of Illinois reviewed the appellate court’s judgment regarding the as-applied constitutional challenge. The court held that an as-applied challenge requires a developed factual record, which was lacking because the defendant did not raise the issue in the circuit court for an evidentiary hearing. The court vacated the part of the appellate court judgment that considered the merits of the as-applied challenge, affirmed the remainder of the appellate court’s judgment, and affirmed the defendant’s UPWF conviction. The main holding is that an as-applied constitutional challenge to the UPWF statute cannot be decided without a factual record developed in the trial court. View "People v. Benson" on Justia Law

STALEY v. STATE OF TEXAS

2026-09-24T04:32:03-08:00

A two-year-old child was discovered deceased in the home of the appellant, who had been dating the child’s mother. Police, suspecting foul play based on blood found at the scene, obtained a search warrant for electronic devices in the home. The search revealed videos of the appellant abusing the child, disturbing text messages, and evidence of file deletion software use. At trial, extensive forensic and medical evidence indicated the child was smothered, not killed by a fall, and DNA linked the appellant to a bloody pillow found in the crib. The appellant was convicted of capital murder and sentenced to life without parole. The Second Court of Appeals reviewed the case, focusing on the appellant’s claim that the search of electronic devices violated the Fourth Amendment because the warrant’s supporting affidavit lacked sufficient facts to establish probable cause. The court found the search unconstitutional and conducted a constitutional harm analysis, concluding that admission of the incriminating evidence from the devices was harmful. The court reversed the conviction, finding the GoPro video particularly prejudicial and determining that the other evidence was not overwhelming. The Court of Criminal Appeals of Texas reviewed the case on the State’s petition for discretionary review. The court assumed error in admitting the evidence and addressed only harm, holding that the court of appeals applied the wrong harm standard. Because the police acted in good faith reliance on the warrant, exclusion was required only under Texas’s statutory rule, so the nonconstitutional harm standard applied. The court found that, given the overwhelming medical, forensic, and DNA evidence, any error in admitting the videos and file deletion evidence was harmless. The judgment of the court of appeals was reversed and the trial court’s conviction was affirmed. View "STALEY v. STATE OF TEXAS" on Justia Law

FOMB v. SIG Structured Products, LLC

2026-09-23T13:30:03-08:00

A financial trustee acting on behalf of bondholders filed a proof of claim for $8.5 billion in the Commonwealth of Puerto Rico’s bankruptcy-like restructuring proceedings. The claim was based on allegations that the Commonwealth had impaired statutory and constitutional rights that were intended to protect bondholders in connection with revenue bonds issued by the Puerto Rico Electric Power Authority (PREPA), a public utility corporation. The Commonwealth had enacted laws that, according to the trustee, limited PREPA’s ability to set rates and satisfy its bond obligations, thereby breaching a statutory covenant not to impair PREPA’s ability to repay the bonds. The trustee characterized these statutory protections as a material inducement for investors to purchase the bonds. The United States District Court for the District of Puerto Rico, acting as the Title III court under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), had previously confirmed the Commonwealth’s Plan of Adjustment. This Plan created separate classes of claims, including one (Class 64) for claims subordinated under 11 U.S.C. § 510(b), which covers damages “arising from the purchase or sale” of a debtor’s security. The trustee’s claim was classified in Class 64, which receives no distribution, rather than as a general unsecured claim (Class 58), which would have allowed a partial recovery. The district court held that the trustee’s claim was properly subordinated under § 510(b). The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court’s judgment, holding that § 510(b) applies to the trustee’s claim because the damages sought arose from the purchase of PREPA’s revenue bonds, induced by the alleged statutory protections. The court also rejected procedural and constitutional avoidance arguments, and found that any challenge to the level of subordination was waived. View "FOMB v. SIG Structured Products, LLC" on Justia Law

CODONI V. PORT OF SEATTLE

2026-09-23T08:30:41-08:00

Several individuals living within a five-mile radius of the Seattle-Tacoma Airport sued two major airlines and the Port of Seattle. They alleged that pollution from aircraft takeoffs and landings caused harm to their health and property, particularly from particulate matter and other pollutants released by aircraft engines and fuselages. Plaintiffs claimed the defendants had knowledge of studies linking these pollutants to negative health outcomes and property devaluation but failed to remediate or prevent further pollution. The affected community was described as disproportionately composed of minority, immigrant, and low-income residents. The plaintiffs initially brought their case in King County Superior Court, but the defendants removed it to the United States District Court for the Western District of Washington. The plaintiffs advanced state tort and constitutional claims, seeking various remedies including damages, injunctive relief, and remediation. The defendants moved to dismiss, arguing that the claims were a collateral attack on federal agency actions, were expressly and impliedly preempted by federal law, and failed to state a claim. The district court denied the motions, finding that the complaint did not directly challenge any specific agency order and that preemption was not clearly established at this stage. The district court certified its order for interlocutory appeal. Reviewing the case on interlocutory appeal, the United States Court of Appeals for the Ninth Circuit held that the district court properly exercised jurisdiction because the collateral attack doctrine did not apply; defendants could not identify any specific agency orders inescapably implicated by the plaintiffs’ claims. However, the court held that the claims were expressly preempted by Section 233 of the Clean Air Act, which bars states from enforcing any emission standards for aircraft pollutants unless identical to federal standards. The court reversed the district court’s order denying the motion to dismiss and remanded the case. View "CODONI V. PORT OF SEATTLE" on Justia Law

Marshall v. Guerrero

2026-09-22T15:30:05-08:00

In this case, the petitioner was convicted of capital murder and sentenced to death following a 2003 armed robbery in Houston, Texas, during which a restaurant employee was killed. Key evidence included eyewitness testimony, statements from co-defendants and jailhouse informants, and information about the petitioner’s criminal history and conduct in prison. The prosecution’s case centered on the petitioner being the sole gunman, though there was conflicting testimony about whether a second person entered the restaurant. The Texas Court of Criminal Appeals affirmed the conviction and sentence on direct appeal and denied state habeas relief, finding the petitioner’s subsequent and additional habeas claims to be procedurally barred as an abuse of the writ. The petitioner then sought federal habeas relief in the United States District Court for the Southern District of Texas, raising thirteen claims, including allegations of false evidence, inconsistent prosecutorial theories, Brady violations, ineffective assistance of counsel, and racial bias. The district court denied relief on the merits where permitted and found the remaining claims procedurally barred due to default under Texas law, ruling that the petitioner had not shown cause, actual prejudice, or a fundamental miscarriage of justice to excuse the default. On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether a certificate of appealability (COA) should issue for the claims dismissed as procedurally barred. The court held that the petitioner failed to show that jurists of reason could debate the district court’s procedural rulings. The court concluded that the claims were subject to an adequate and independent state procedural bar, and the petitioner had not demonstrated cause and prejudice or actual innocence to overcome that bar. The Fifth Circuit therefore denied the application for a certificate of appealability. View "Marshall v. Guerrero" on Justia Law

State v. Crawford

2026-09-22T14:05:48-08:00

The case concerns Del Orrin Crawford, who was involved in a deadly altercation outside the South Fork Saloon in Martin City, Montana, on August 26, 2022. After a dispute regarding a golf cart escalated, Crawford fired a handgun, resulting in the death of Whisper Sellers and serious injury to Douglass Crosswhite. Crawford fled the scene, called 911 multiple times claiming self-defense, and was later apprehended by law enforcement. Upon arrest, Crawford surrendered unarmed, and the firearm he used was not immediately recovered. Law enforcement questioned Crawford about the firearm’s location and conducted further interrogation after transporting him to the sheriff’s office. The Eleventh Judicial District Court in Flathead County presided over Crawford’s jury trial. Crawford moved to suppress two sets of statements made to law enforcement after he invoked his right to counsel. The court denied most of his motion, suppressing only statements related to his alcohol consumption before his second Miranda advisement. Crawford was subsequently convicted by the jury of Deliberate Homicide, Attempted Deliberate Homicide, Assault with a Weapon, and Tampering with Physical Evidence, and sentenced to 100 years in prison. On appeal, the Supreme Court of the State of Montana reviewed whether the district court erred in admitting Crawford’s statements regarding the firearm’s location after he requested counsel and whether it was correct in finding that Crawford reinitiated conversation and knowingly waived his right to counsel before making further statements. The Supreme Court held that even if admitting the statements about the firearm’s location was erroneous, any error was harmless beyond a reasonable doubt due to cumulative admissible evidence. The Court further held that Crawford voluntarily reinitiated conversation and validly waived his right to counsel before providing additional statements. The judgment of conviction was affirmed. View "State v. Crawford" on Justia Law

State v. Pein

2026-09-22T13:35:40-08:00

The case concerns a defendant who was charged with abusing his elderly stepfather, resulting in both mental injury and physical harm. The elderly victim, who had declining health and required assistance, was subjected to several years of verbal threats, intimidation, and, on at least one occasion, physical assault when the defendant struck him in the face. The victim’s daughter and other family members observed concerning behavior, including an incident where the defendant shook the victim in a manner described as threatening. The victim, before passing away, gave a recorded deposition detailing the abuse, his fear, and its emotional toll. The charges included abuse of an elderly person and first-offense partner or family member assault. Prior to trial, the defendant sought to enforce an alleged plea agreement, but the District Court found no such agreement had been accepted, following a hearing. Although a jury trial was scheduled, the defendant requested a bench trial, and the Tenth Judicial District Court, Fergus County, confirmed that he knowingly and voluntarily waived his right to a jury trial, albeit orally rather than in writing. After a two-day bench trial, the court found the defendant guilty on both counts and imposed a prison sentence. The defendant appealed, arguing insufficient evidence due to a lack of expert testimony on mental injury, an improper waiver of jury trial, and that the elder abuse statute was unconstitutionally vague and overbroad. The Supreme Court of the State of Montana held that expert testimony is not required to establish “mental injury” under the relevant statute, as a reasonable person standard applies and lay testimony was sufficient. The court found no manifest miscarriage of justice in accepting the oral waiver of a jury trial. The court also rejected the facial constitutional challenges, as the defendant’s conduct was clearly proscribed by statute. The judgment of the District Court was affirmed. View "State v. Pein" on Justia Law

Beasley v. State

2026-09-22T12:02:07-08:00

The appellant was convicted of first-degree murder, robbery, and grand theft after brutally beating and killing a woman with whom he was temporarily staying. Evidence at trial established the appellant stole cash and the victim’s car, fled the state, and used an alias before being apprehended in Alabama and returned to Florida for prosecution. The jury convicted him and recommended the death penalty by a 10-2 vote. The trial court found aggravating factors including murder during a robbery and that the crime was especially heinous, atrocious, or cruel, outweighing mitigating circumstances, and imposed a sentence of death. The Supreme Court of Florida previously affirmed the convictions and sentence on direct appeal. The appellant later filed multiple unsuccessful postconviction motions in state and federal courts, including a motion based on the Florida Supreme Court’s decision in Hurst v. State, which was denied due to lack of retroactivity. After the Governor signed a death warrant, the appellant filed a successive motion for postconviction relief and a stay of execution in the Circuit Court for Polk County, raising claims regarding his age and cognitive decline, warrant timing, the warrant process, and the nonunanimous jury recommendation. The Supreme Court of Florida reviewed the circuit court’s summary denial of postconviction relief de novo. The Court affirmed the summary denial, holding the appellant’s claims were either procedurally barred or meritless. Specifically, it ruled there is no constitutional prohibition against executing elderly prisoners experiencing cognitive decline, the expedited warrant period does not violate due process or equal protection, the Governor’s discretion in signing death warrants is not unconstitutional, and a nonunanimous jury recommendation of death does not violate the Fifth, Sixth, or Eighth Amendments. The Court also denied the appellant’s request for a stay of execution. View "Beasley v. State" on Justia Law

P. v. Cruz

2026-09-22T09:31:19-08:00

In 2003, Samuel Anthony Cruz and several other members of the 7th Street gang were involved in two separate shooting incidents that resulted in the deaths of rival gang members. Cruz was charged with two counts of murder but entered a plea agreement in which he pleaded guilty to two counts of voluntary manslaughter, along with enhancements and gang participation. He was sentenced to a negotiated term of 21 years and eight months. Many years later, Cruz filed a petition under California Penal Code section 1172.6, seeking to vacate his manslaughter convictions and be resentenced on the grounds that legal standards for murder liability had changed. The Superior Court of Orange County issued an order to show cause and held an evidentiary hearing. At this hearing, the prosecution introduced transcripts from the 2007 trial of Cruz’s codefendant, Juan Becerra. Cruz objected to the use of these transcripts on due process grounds but did not challenge the factual findings or dispute this court’s prior opinions allowing such evidence. The trial court denied Cruz’s petition, finding he was an actual shooter in one killing and a direct aider and abettor in the other. Upon appeal, the California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the trial court’s consideration of a codefendant’s trial testimony violated Cruz’s right to due process. The court held that admission of this testimony did not violate procedural due process because Cruz had a full and fair opportunity to contest the evidence: he could have subpoenaed witnesses, testified on his own behalf, or introduced new evidence. The court affirmed the trial court’s order denying Cruz’s petition for vacatur and resentencing. View "P. v. Cruz" on Justia Law

YUKUTAKE V. LOPEZ

2026-09-22T08:00:31-08:00

Two Hawaii residents challenged two aspects of the state's “shall-issue” firearm licensing regime. The first challenged provision required that a handgun acquisition permit be used within thirty days of issuance or else the applicant must restart the process. The second provision required that, after purchasing a firearm, certain owners must bring it to a police station for inspection and registration in specific circumstances. Plaintiffs alleged that these requirements imposed undue burdens on their ability to acquire firearms, in violation of the Second Amendment. The United States District Court for the District of Hawaii granted summary judgment to the plaintiffs. The district court found both requirements facially unconstitutional under the Second Amendment, applying intermediate scrutiny as was then the circuit precedent. The court permanently enjoined the state from enforcing the challenged provisions. After this ruling, the Supreme Court decided New York State Rifle & Pistol Ass’n v. Bruen, which changed the standard for Second Amendment claims to a “text, history, and tradition” test. On appeal, the United States Court of Appeals for the Ninth Circuit, sitting en banc, considered the impact of Bruen and subsequent Supreme Court cases. The Ninth Circuit noted that Bruen distinguished between “may-issue” and “shall-issue” licensing regimes and, in footnote 9, characterized objective, non-abusive “shall-issue” regimes as presumptively constitutional. The court concluded that the two challenged Hawaii requirements were objective, non-discretionary, and did not amount to abusive practices that would deny ordinary citizens their Second Amendment rights. At most, the provisions imposed only modest, procedural burdens and did not materially impede firearm acquisition. The Ninth Circuit therefore reversed the district court’s injunction and remanded for further proceedings, holding that Hawaii’s “shall-issue” regime, as applied here, comports with the Second Amendment. View "YUKUTAKE V. LOPEZ" on Justia Law

State of Maine v. Desrosiers

2026-09-22T07:07:21-08:00

Desroisiers was stopped by police while driving a Chevrolet Trailblazer with her mother as a passenger. The vehicle lacked an inspection sticker, prompting a police sergeant to initiate a traffic stop. The vehicle was registered but not to Desroisiers, who was on pre-conviction bail requiring her to commit no criminal act. During the encounter, Desroisiers resisted requests for documentation, accused the officer of harassment, and refused to comply with commands to be handcuffed. She crossed her arms, attempted to pull away, dropped to the ground after being handcuffed, and later stuck her foot outside the cruiser door, requiring officers to push it in. Footage showed her thrashing inside the cruiser. The Aroostook County Superior Court held a jury trial and admitted relevant evidence, including body camera footage. Desroisiers moved for judgments of acquittal on the charge of refusing to submit to arrest or detention, arguing the evidence showed only passive resistance, not physical force. The court denied the motions. The jury convicted her of refusing to submit to arrest or detention by using physical force against a law enforcement officer, operating an unregistered vehicle, and violating a condition of release. Desroisiers subsequently renewed her acquittal motions, which were again denied, and she timely appealed. The Maine Supreme Judicial Court reviewed the case. It interpreted the statutory phrase “uses physical force against a law enforcement officer” to include any muscular effort directed toward an officer’s attempt to detain, not just violent or injurious acts. The court held that Desroisiers’s crossing her arms, pulling away, and obstructing the cruiser door constituted physical force under the statute, affirming her convictions for refusing to submit to arrest and violating a condition of release. However, the court found insufficient evidence that Desroisiers was the current owner required to register the vehicle, vacating her conviction for operating an unregistered vehicle. View "State of Maine v. Desrosiers" on Justia Law

Mahoney v. United States Capitol Police Board

2026-09-22T07:01:04-08:00

A minister sought to hold a small prayer event on the lower section of the Eastern Steps of the United States Capitol, advocating for various causes including opposition to federal funding of abortion. Under federal regulations, public demonstrations on these Steps are generally prohibited unless sponsored by a member of Congress, with violations carrying criminal penalties. The minister, unable to secure sponsorship, faced the threat of arrest and had previously been arrested for similar conduct. After protracted litigation and partial settlement, the parties stipulated to key facts and proceeded to cross-motions for summary judgment in the United States District Court for the District of Columbia. That court ruled in favor of the minister on his First Amendment claim, holding that the lower section of the Eastern Steps was a traditional public forum and that the regulations at issue suppressed more speech than necessary. The district court entered a permanent universal injunction, barring enforcement of the regulations against anyone wishing to demonstrate on the lower Steps. The Capitol Police Board appealed, and the district court later limited the injunction to the minister and up to 14 others pending appeal. The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo regarding summary judgment and for abuse of discretion as to the injunction. The appellate court disagreed with the district court’s forum classification, holding that the Eastern Steps constitute a nonpublic forum because of their specialized function and physical integration with the Capitol. Nevertheless, the court held that the regulation’s requirement of congressional sponsorship for demonstrations was unreasonable, as it granted unbridled discretion to members of Congress, violating First Amendment protections. The court affirmed summary judgment for the minister but vacated the universal injunction, remanding for the district court to determine the proper scope of injunctive relief in light of recent Supreme Court guidance limiting universal injunctions. View "Mahoney v. United States Capitol Police Board" on Justia Law

State v. Al-Mafrachi

2026-09-22T06:32:41-08:00

A man was stopped by law enforcement while riding as a passenger in a car due to a traffic infraction. During the stop, officers identified him and found that he was on felony probation. The officers searched a backpack at his feet, which contained a significant quantity and variety of illegal narcotics, as well as items suggestive of drug distribution. The man denied ownership of the backpack, claiming it belonged to his girlfriend. Subsequent investigation revealed that he was subject to a probation agreement that included both waiver of his Fourth Amendment rights and consent to searches by law enforcement. He was charged in two separate cases with various drug-related offenses, including possession with intent to deliver and possession of drug paraphernalia. The cases were consolidated in the District Court of the Fourth Judicial District, Ada County. He moved to suppress the evidence found in the backpack, arguing that the search was unconstitutional. The district court denied his motion, finding that he lacked standing to challenge the search due to the express waiver of his Fourth Amendment rights in his probation agreement. After trial, a jury found him guilty on multiple counts, and he was sentenced to a unified fifteen-year term, with five years fixed. On appeal to the Supreme Court of the State of Idaho, he argued that the district court erred in treating his waiver as a categorical bar to standing, particularly since officers did not know of the waiver at the time of the search. The Supreme Court of the State of Idaho affirmed the district court’s denial of the motion to suppress. The Court held that an express waiver of Fourth Amendment rights in a probation agreement extinguishes any legitimate expectation of privacy and therefore precludes standing to challenge the search, overruling its prior decision in State v. Maxim, 165 Idaho 901, 454 P.3d 543 (2019), to the extent it held otherwise. View "State v. Al-Mafrachi" on Justia Law

Hocker v. Albence

2026-09-21T11:02:17-08:00

Two candidates for public office in the November 2026 Delaware general election challenged the constitutionality of the state’s permanent absentee voting statute. They argued that the statute unlawfully expanded absentee voting beyond the categories permitted by the Delaware Constitution and that the Department of Elections failed to adequately verify the continued eligibility of permanent absentee voters, thereby enabling ineligible individuals to vote by absentee ballot. Previously, the Court of Chancery of the State of Delaware considered cross-motions for summary judgment. The plaintiffs sought declaratory and injunctive relief to prevent use of the permanent absentee voting process for the 2026 election. The Court of Chancery found that the statute did not expand the constitutionally enumerated categories of absentee voters but rather limited permanent absentee status to a subset of those groups. The court further held that the statute did not permit voting by those ineligible to vote absentee and that the Department’s procedures for maintaining the permanent absentee list, though not perfect, did not render every application of the statute unconstitutional. The Court of Chancery thus granted summary judgment to the defendants. On appeal, the Supreme Court of the State of Delaware reviewed the case de novo and affirmed the decision of the Court of Chancery. The Supreme Court held that the permanent absentee voting statute neither expanded absentee voting eligibility beyond the categories set by the Delaware Constitution nor permitted ineligible individuals to vote by absentee ballot. The Court also held that the plaintiffs failed to meet the high burden required for a facial constitutional challenge, as the statute could be applied constitutionally. Therefore, the Supreme Court affirmed the judgment upholding the statute. View "Hocker v. Albence" on Justia Law

Montes v. Superior Court

2026-09-21T10:31:03-08:00

The case involves a defendant who was convicted of first degree murder and other crimes in 1996, with the jury finding special circumstances and imposing a death sentence. During jury selection at trial, the prosecutor used peremptory challenges to strike several Black and Latino jurors. The defendant’s counsel objected to these strikes, raising claims of racial discrimination under Batson v. Kentucky and People v. Wheeler. The trial court found a prima facie case of discrimination for most challenges, required race-neutral justifications from the prosecutor, and ultimately denied the motions. On direct appeal, the California Supreme Court affirmed the trial court’s rulings. Years later, the defendant sought postconviction discovery under Penal Code section 1054.9, including the prosecution’s jury selection notes. The Superior Court for the County of Riverside denied production of these notes, citing prior case law that required a prima facie showing of a Batson/Wheeler violation for postconviction access to jury selection notes. Shortly after this ruling, Assembly Bill No. 1036 was enacted, amending section 1054.9 to expressly include jury selection notes as discoverable material and shifting the burden to the prosecution to show good cause for withholding or redacting these notes. The California Court of Appeal, Fourth Appellate District, Division Two, held that the recent legislative amendments eliminate the requirement for a defendant to make a prima facie case of racial bias to obtain jury selection notes postconviction. Instead, a request for these notes now shifts the burden to the prosecution to demonstrate good cause for shielding or redacting the notes. The appellate court granted the petition for writ of mandate, directing the trial court to adjudicate the defendant’s request in accordance with the current law. View "Montes v. Superior Court" on Justia Law

PADILLA V. UNITED STATES IMMIGRATION AND CUSTOMS ENFORCEMENT

2026-09-21T08:00:32-08:00

A group of asylum seekers who entered the United States without admission or parole were apprehended, screened for expedited removal, and found to have a credible fear of persecution or torture. As a result, they were transferred from expedited to regular removal proceedings to have their asylum claims adjudicated. However, due to their initial placement in expedited removal, they were subject to mandatory detention under 8 U.S.C. § 1225(b)(1)(B)(ii), which, as interpreted in Jennings v. Rodriguez, does not permit bond hearings or individualized determinations regarding detention. The plaintiffs, forming a certified class, argued that the lack of such hearings violated their rights under the Fifth Amendment’s Due Process Clause. Initially, the United States District Court for the Western District of Washington granted class certification and issued a preliminary injunction requiring bond hearings. After the Attorney General issued a decision, Matter of M-S-, which aligned with Jennings and eliminated the statutory right to bond hearings, the plaintiffs amended their complaint to challenge the constitutionality of mandatory detention. The district court again granted relief, but the government appealed. The United States Court of Appeals for the Ninth Circuit initially affirmed, but the Supreme Court vacated and remanded for reconsideration in light of Department of Homeland Security v. Thuraissigiam. Upon remand, the district court, after further proceedings, denied the government’s motion to dismiss, holding that it had jurisdiction and that the due process claim was not foreclosed by Thuraissigiam. On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of the government’s motion to dismiss. The court held that none of the jurisdiction-stripping provisions of 8 U.S.C. § 1252(a)(2)(A) or § 1252(e)(3) barred judicial review of the class’s due process claim. The court also held that Thuraissigiam did not eliminate the due process rights of noncitizens apprehended well within the United States, distinguishing the case from those at the “threshold of initial entry.” The Ninth Circuit affirmed that these individuals may pursue constitutional due process claims regarding their detention. View "PADILLA V. UNITED STATES IMMIGRATION AND CUSTOMS ENFORCEMENT" on Justia Law

Marshfield v. Commonwealth

2026-09-21T04:05:37-08:00

A town and its select board challenged a state law enacted to address the Massachusetts housing crisis. The law requires municipalities served by the Massachusetts Bay Transportation Authority to have at least one district where multifamily housing is permitted as of right. The town attempted to adopt compliant zoning amendments, but town meeting voters rejected these proposals. The select board subsequently decided not to pursue further compliance steps. After being notified by the state agency responsible that it was noncompliant and at risk of losing state grant funding, the town and board filed a lawsuit seeking declaratory and injunctive relief. The action was filed in the Superior Court Department. The Commonwealth and the Executive Office of Housing and Livable Communities moved to dismiss for lack of subject matter jurisdiction and failure to state a claim. The Superior Court judge granted the motion, finding the plaintiffs failed to plausibly allege that the law imposed an unfunded local mandate or unlawfully interfered with the town’s zoning authority. The plaintiffs appealed, and the Supreme Judicial Court of Massachusetts allowed direct appellate review. The Supreme Judicial Court of Massachusetts affirmed the dismissal. It held that the complaint did not sufficiently allege that the law imposed an unfunded local mandate because the costs described were either incidental local administration expenses or voluntarily incurred. The Court also held that the town and board lacked standing to assert constitutional voting rights claims on behalf of town meeting voters. Addressing the public importance of the issue, the Court concluded that the law is a valid general law and does not violate the Home Rule Amendment or conflict with the Zoning Act. The judgment dismissing the complaint was affirmed. View "Marshfield v. Commonwealth" on Justia Law

Elite Precision v. ATF

2026-09-18T15:30:06-08:00

Several plaintiffs, including a federally licensed firearm dealer in Texas and two law-abiding residents of Arizona and New Mexico, challenged federal statutes that prohibit the direct sale and transfer of handguns across state lines. The statutes in question, collectively called the Nonresident Handgun Purchase Ban, make it unlawful for unlicensed persons to buy or sell handguns to residents of other states and restrict licensed dealers from directly selling handguns to nonresidents, subject to limited exceptions. While a workaround exists—requiring transfers through an intermediary licensed dealer in the buyer’s home state—this process is not automatic, incurs additional fees, and results in delays. The plaintiffs argued that, but for the Ban, they would engage in interstate handgun sales and purchases. The United States District Court for the Northern District of Texas reviewed the case. The government moved to dismiss, and the plaintiffs moved for summary judgment. With no disputed facts, the court determined the issue was purely a question of law: whether the Ban violates the Second Amendment. The district court upheld the Ban, granting the government’s motion and dismissing the plaintiffs’ claims. Plaintiffs appealed the decision. The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. Applying the framework from N.Y. State Pistol & Rifle Ass’n v. Bruen, the court found that the Ban implicates conduct covered by the Second Amendment’s plain text and is therefore presumptively unconstitutional. The government failed to identify a sufficient historical tradition to justify the Ban. The Fifth Circuit held that the Ban is inconsistent with the nation’s tradition of firearms regulation under the Second Amendment, reversed the district court’s dismissal, and rendered judgment for the plaintiffs. View "Elite Precision v. ATF" on Justia Law

Irvine v. Irvine

2026-09-18T13:31:42-08:00

After divorcing in 2022, Eric and Tiare experienced escalating harassment and abuse beginning in late 2023. Tiare repeatedly sent manipulative and threatening messages, made suicide threats, and harassed Eric’s new girlfriend. The harassment intensified, culminating in Tiare entering Eric’s property, physically attacking him, and being arrested for battery and unauthorized entry. Various protective orders were issued, including a temporary restraining order (TRO), an emergency protective order, and a criminal protective order. Despite these, Tiare violated the orders and continued contacting Eric. The Marin County Superior Court initially granted Tiare three continuances for the hearing on Eric’s petition for a domestic violence restraining order, citing reasons such as giving Tiare time to respond, her attorney’s absence, and her participation in residential treatment. At the fourth hearing, Tiare requested another continuance, arguing her Fifth Amendment right to remain silent due to pending criminal charges. The trial court denied this request, found that Eric had proven acts of abuse, and issued a three-year restraining order protecting both Eric and his girlfriend. The Court of Appeal of the State of California, First Appellate District, Division Three, reviewed the trial court’s denial of the fourth continuance. The appellate court held that respondents in Domestic Violence Prevention Act proceedings who intend to assert their Fifth Amendment right are not automatically entitled to a continuance. The trial court must balance the respondent’s Fifth Amendment interests against other interests, including those of the petitioner, judicial efficiency, nonparties, and the legislative purpose of prompt resolution. The appellate court found the trial court had properly weighed these competing interests and did not abuse its discretion in denying the request. Accordingly, the judgment was affirmed. View "Irvine v. Irvine" on Justia Law

Berkey International, LLC v. Environmental Protection Agency

2026-09-18T13:30:03-08:00

A Puerto Rico limited liability company, Berkey International, LLC, manufactures water filters known as Black Berkey Filters, which contain silver—a substance recognized as a pesticide. Berkey distributed these filters without EPA registration, claiming the silver was intended only to protect the filters themselves, not for pesticidal purposes. Inspections by the Environmental Protection Agency (EPA) revealed that Berkey and associated distributors made claims on product labels and websites indicating the filters could remove viruses, bacteria, and other pathogens, suggesting pesticidal intent. As a result, the EPA issued a Stop Sale, Use, or Removal Order prohibiting Berkey and other distributors from selling or distributing these filters. Reviewing the matter, the United States District Court for the District of Puerto Rico considered Berkey’s request for a preliminary injunction to halt enforcement of the EPA’s order. The district court evaluated the administrative record, held hearings, and reviewed extensive briefing. The court found that Berkey had not substantiated its claims that the silver was not intended for pesticidal use and denied Berkey’s motion for preliminary injunctive relief. Berkey’s subsequent motion for reconsideration was also denied, prompting Berkey to file an interlocutory appeal. The United States Court of Appeals for the First Circuit reviewed the district court’s denial of preliminary injunctive relief for abuse of discretion. Applying a highly deferential standard to the EPA’s technical determinations, the appellate court concluded that Berkey had not shown a likelihood of success on the merits of its claims under the Administrative Procedure Act, including its assertions of arbitrary and capricious agency action and violations of notice-and-comment and due process requirements. The First Circuit affirmed the district court’s order, holding that the EPA had reason to believe Berkey’s filters were unregistered and misbranded pesticidal products under federal law. View "Berkey International, LLC v. Environmental Protection Agency" on Justia Law

State ex rel. Kidd v. Clinton Cty. Bd. of Elections

2026-09-18T13:00:04-08:00

Two individuals filed an initiative petition with Wilmington city officials, proposing a new ordinance to regulate data centers and their campuses. The ordinance would set standards for noise, lighting, emissions, generator-testing, water use, and heat generation, among other things. A key feature of the proposed ordinance was the creation of a “private right of action,” allowing residents within certain distances of a data center to sue its owner or operator for alleged violations of these standards, with the possibility of injunctive relief, penalties, and attorney’s fees. After the petition was filed and signatures validated, the Wilmington city auditor certified its sufficiency and validity, but did not opine on whether it was within the city’s initiative power. The Clinton County Board of Elections declined to certify the petition for the ballot, determining that the ordinance was not within the municipality’s power because it sought to create a new private cause of action. The board reaffirmed this decision after a hearing requested by one petitioner. The Supreme Court of Ohio reviewed the mandamus action seeking to compel the board to certify the petition. The court held that the proposed ordinance was outside the municipal initiative power because it would create a new cause of action, which municipalities are not authorized to do. The court relied on its prior decisions, including State ex rel. Bolzenius v. Preisse and State ex rel. Flak v. Betras, and rejected arguments that the ordinance merely restated existing statutory remedies. The court also rejected a First Amendment challenge, finding no unconstitutional prior restraint. The Supreme Court of Ohio denied the writ of mandamus, upholding the board’s decision not to certify the initiative for the ballot. View "State ex rel. Kidd v. Clinton Cty. Bd. of Elections" on Justia Law

MEDINA V. BLANCHE

2026-09-18T08:00:37-08:00

The case concerns an individual who entered the United States without inspection and was placed in removal proceedings after being detained by immigration authorities. While in custody, he was properly served with a Notice to Appear and provided the detention center address as his location. Shortly before his release, his relatives posted a bond and filled out a bond form with his residential address and telephone number, but not his mailing address. The relatives were unaware that the individual received mail via a P.O. Box and not at his residential address. After release, the government sent a hearing notice to the residential address listed on the bond form, but the notice was returned as undeliverable since mail could not be received at that address. An Immigration Judge ordered the individual removed in absentia after he failed to appear at the hearing, relying on the assumption that he had received written notice. The individual, who did not know about the hearing, promptly moved to reopen the proceedings, providing his correct mailing address and explaining, via sworn statements, that he had notified the court of his address for receiving notices and had lived at the same location since release. The Immigration Judge denied the motion to reopen, applying a presumption of delivery based on regular mail. The Board of Immigration Appeals affirmed, concluding that the government had complied with statutory notice requirements by sending notice to the last known address and rejecting the argument that he was entitled to actual notice. The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the government violated the petitioner’s due process rights by relying solely on a residential address provided by third parties on a bond form, which was not reasonably calculated to provide notice. The court granted the petition for review, vacated the removal order, and remanded for further proceedings. The court dismissed a later petition for review as moot. View "MEDINA V. BLANCHE" on Justia Law

USA V. STATE OF IDAHO

2026-09-18T08:00:36-08:00

After the Snake River Basin Adjudication (SRBA) confirmed thousands of federal stockwater rights on federal land, Idaho enacted a series of statutes known as the “stockwater amendments.” These amendments altered water rights rules, including procedures for forfeiture and appurtenance, and imposed new requirements specifically affecting federal stockwater rights. The United States challenged several provisions, arguing that they were intended to divest it of SRBA-decreed stockwater rights and unlawfully discriminated against the federal government. Two groups—the Idaho Legislature and ranching interests—intervened as defendants. The United States District Court for the District of Idaho rejected jurisdictional challenges based on Rooker-Feldman, prior exclusive jurisdiction, Burford abstention, and claim preclusion, holding it could hear the case. On the merits, the district court found Idaho Code § 42-224 constitutional as applied to the United States, but held Idaho Code §§ 42-113(2)(b), 42-502, and 42-504 were facially unconstitutional under the Supremacy Clause. The United States appealed the ruling on § 42-224, while the State Defendants and Ranchers cross-appealed the jurisdictional holdings and the ruling on § 42-113(2)(b). The United States Court of Appeals for the Ninth Circuit affirmed the district court’s jurisdictional holdings, concluding that neither the doctrine of prior exclusive jurisdiction nor Burford abstention applied. The panel reversed the district court’s finding that § 42-224 was constitutional as applied, holding that it is part of a statutory scheme that unlawfully discriminates against the United States and jeopardizes its SRBA-decreed rights. The panel affirmed the district court’s holding that § 42-113(2)(b) is facially unconstitutional because it singles out the United States for unfavorable treatment by changing appurtenance rules only for rights associated with federal land. Thus, the Ninth Circuit affirmed in part and reversed in part, awarding costs to the United States. View "USA V. STATE OF IDAHO" on Justia Law

Rash v. Lafayette County

2026-09-17T15:30:06-08:00

A university professor in Oxford, Mississippi sought to host a nighttime art exhibition on the grounds of the local courthouse, which is frequently used by the public for varied activities, including political protests and social gatherings. The county had implemented a Facility Use Policy requiring permits for use of courthouse grounds, including a ban on nighttime events, advance notice, security fees, insurance, and granting discretionary authority to deny permits based on the nature of the event. The professor’s permit request was denied due to the curfew provision, prompting him to file suit alleging violations of the First Amendment. The United States District Court for the Northern District of Mississippi held a bench trial and permanently enjoined enforcement of the curfew provision against the professor, finding it an unreasonable restriction on speech. However, the court dismissed the professor’s other claims for lack of standing, concluding he had not suffered sufficient injury to challenge the remaining policy provisions or to bring a vagueness challenge. The United States Court of Appeals for the Fifth Circuit reviewed the case. It affirmed the injunction against the curfew provision, holding that the ban was not narrowly tailored to serve a significant government interest and burdened more speech than necessary. The court rejected the county’s argument that subsequent policy amendments mooted the case, finding the amended curfew provision still posed the same fundamental issues. The Fifth Circuit reversed the district court’s dismissal of the professor’s facial challenges to the other policy provisions, holding he had standing to challenge them under the First Amendment, though not on vagueness grounds. The case was remanded for further proceedings, requiring the professor to demonstrate that unconstitutional applications of the policy substantially outweigh constitutional ones. View "Rash v. Lafayette County" on Justia Law

S.D. V. REESE

2026-09-17T09:00:44-08:00

Two inmates who identify as transgender women brought a class action against the Oregon Department of Corrections and related officials, alleging Eighth Amendment violations for purportedly exposing transgender women inmates to substantial risk of harm by housing them in men’s prisons. The plaintiffs sought a preliminary mandatory injunction on behalf of a class of all current and future transgender women in Oregon prison facilities, requesting that they be presumptively assigned to the state’s women’s prison and given additional protections. A magistrate judge in the United States District Court for the District of Oregon granted the motion for a preliminary injunction and provisionally certified the class. The injunction required Oregon to presumptively assign transgender women inmates to the women’s prison unless a specific security justification was documented, along with other measures for safety and privacy. Defendants moved for reconsideration, and the district court amended but largely maintained the injunction. Defendants appealed and obtained a stay of the injunction pending appeal. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s order, applying an abuse-of-discretion standard to the injunction and de novo review to underlying legal issues. The Ninth Circuit found the district court committed clear error by basing its injunction on an unsupported finding that the defendants employed a default presumption of housing transgender women in men’s prisons. The appellate court determined that the record showed individualized assessments for inmate placement and that the plaintiffs failed to demonstrate a likelihood of success on the merits, irreparable harm, or commonality for class certification. The Ninth Circuit vacated the preliminary injunction, ordered the class to be decertified, and remanded the case. The mandate was issued forthwith. View "S.D. V. REESE" on Justia Law

USA v. Gibbs

2026-09-17T08:31:01-08:00

A software company managing cloud storage accounts detected that a user had uploaded material suspected to be child sexual abuse content. As required by federal law, the company reported this to the National Center for Missing and Exploited Children (NCMEC), which in turn forwarded a CyberTip containing the information, including the suspect’s phone number, to law enforcement. A detective from the Tallahassee Police Department reviewed the CyberTip and submitted an affidavit to a Florida state court judge to obtain a warrant to search the suspect’s cloud account. The affidavit referenced the reliability of NCMEC’s processes and the detective’s experience, but did not describe the alleged illicit images. The warrant was granted, and the subsequent search uncovered child sexual abuse images. Further investigation led to the identification of a victim and the arrest of the suspect, who was later charged federally. The defendant moved in the United States District Court for the Northern District of Florida to suppress the evidence, arguing that the search warrant affidavit lacked probable cause and that the good faith exception to the exclusionary rule did not apply. The district court agreed, finding that the affidavit was too vague and conclusory, lacking sufficient details to support probable cause or reasonable reliance. As a result, the court suppressed all evidence obtained from the searches. On appeal, the United States Court of Appeals for the Eleventh Circuit considered whether the good faith exception to the exclusionary rule applied, assuming without deciding that the affidavit was deficient in establishing probable cause. The court held that the affidavit contained enough indicia of probable cause, particularly due to the general trustworthiness of NCMEC’s CyberTip program and the detective’s reasonable reliance on established procedures. Therefore, the court reversed the district court’s suppression order and remanded for further proceedings. View "USA v. Gibbs" on Justia Law

State v. Lawyer

2026-09-17T08:14:34-08:00

The defendant was charged with several serious crimes, including second-degree murder and aggravated assault, following an incident in which he allegedly attacked his parents with a baseball bat, killing his father and injuring his mother, before fleeing in a vehicle and colliding with a game warden's truck. After his arrest, the court ordered a neutral psychiatric examiner to conduct a competency examination to determine whether the defendant was fit to stand trial. The examiner interviewed the defendant multiple times but concluded that further psychometric testing was necessary. The examiner stated that defense counsel must be excluded from the testing, citing copyright and professional ethics concerns, and warned that she would otherwise submit a report without a competency finding. The defendant objected, asserting that his attorney had a constitutional right to be present during the competency examination, referencing both the Sixth Amendment and Article 10 of the Vermont Constitution. The State argued that the competency examination was not a critical stage of the prosecution, and thus the right did not attach. The Superior Court, Franklin Unit, Criminal Division denied the defendant's motion, holding there was no constitutional right to counsel’s presence during the examination. The defendant sought and was granted an interlocutory appeal. The Vermont Supreme Court reviewed the trial court’s decision de novo for constitutional questions and for abuse of discretion on procedural rulings. The Court held that a competency examination is not a critical stage of criminal proceedings where the Sixth Amendment right to counsel attaches, citing United States Supreme Court precedent and the practices of numerous jurisdictions. The Court further held that Vermont law and the Fifth Amendment adequately protect defendants’ rights during such examinations. Finding no abuse of discretion in the trial court’s decision to exclude counsel, the Vermont Supreme Court affirmed the trial court’s ruling. View "State v. Lawyer" on Justia Law

Murphy v. Deml

2026-09-17T08:13:23-08:00

An inmate serving a sentence for second-degree murder in Vermont challenged the constitutionality of a statutory amendment affecting earned-time credits. The original law allowed inmates to earn sentence reductions for good behavior, and this petitioner received such credits for several months in early 2021. However, a 2021 amendment excluded inmates convicted of second-degree murder and other serious offenses, if they were sentenced on or before January 1, 2021, from earning further reductions after April 26, 2021. The petitioner, who falls into this category, retained credits earned before the amendment but was prohibited from earning future credits. The petitioner initially filed a pro se complaint in the Superior Court, Washington Unit, Civil Division, seeking declaratory relief to continue earning sentence reductions. After a parallel federal case, Baird v. Deml, decided in favor of the Department of Corrections, the petitioner amended his complaint to assert violations of his due process rights and the Common Benefits Clause of the Vermont Constitution. Both parties sought summary judgment, and the civil division adopted the reasoning of Baird, granting summary judgment to the Department of Corrections. The Vermont Supreme Court reviewed the case de novo and affirmed the lower court’s decision. The Court held that procedural due process requirements do not apply to legislative actions such as statutory amendments, and the legislative process provided all the process that was due. Regarding substantive due process, the Court found that the law did not implicate a fundamental constitutional right and was rationally related to a legitimate government purpose—protecting victims’ expectations about offenders’ sentences. The Court also held that the statute did not violate the Common Benefits Clause, concluding that the exclusion of certain inmates from earned-time credits was reasonably and justly related to the legislative purpose. The judgment was affirmed. View "Murphy v. Deml" on Justia Law

MCDONALD v. STATE OF TEXAS

2026-09-17T07:28:59-08:00

The case involved a defendant who killed her two young daughters by asphyxiation, believing she was protecting them from imagined abuse and exploitation by family members. The defendant had a documented history of severe mental illness, including schizoaffective disorder with both schizophrenic and bipolar symptoms, and had experienced increasing paranoia and delusions in the months before the offenses. After the killings, she drove to the police station, called 911, and confessed. Prior to the incident, she had made several reports to police, which were investigated and determined to be unfounded, and she was involuntarily hospitalized months before the offenses. The children were returned to her care following her treatment, and the killings occurred two months later. Following her arrest, questions arose regarding her competency to stand trial and potential insanity at the time of the offense. A defense-retained expert initially found her incompetent, but after further evaluation, both the defense and a State-retained expert agreed she was competent. The trial court later appointed the State’s expert as a “disinterested” expert for the insanity evaluation. At trial, the defense challenged the admissibility of the State’s expert’s testimony, arguing that the expert violated the defendant’s Fifth Amendment rights during the competency exam by inquiring about her mental state at the time of the offense, and that the expert was not a disinterested party as required by statute. The trial court overruled the objection. The jury found the defendant guilty of capital murder, and she was sentenced to life without parole. The Fifth District Court of Appeals initially held the defendant had failed to preserve her complaints for review but alternatively found that, even if error occurred, there was no substantial harm. The Texas Court of Criminal Appeals found that the defendant had preserved her claims. However, it held that even if the appointment of the expert was error, it did not affect the defendant’s substantial rights because the expert’s testimony did not have a substantial and injurious effect on the verdict. The court also concluded there was no constitutional error under the Fifth Amendment, as none of the allegedly improper statements were introduced by the State at trial. The judgment of the court of appeals was affirmed. View "MCDONALD v. STATE OF TEXAS" on Justia Law

The State of Wyoming v. Wyoming Education Association

2026-09-17T07:11:23-08:00

Wyoming’s Constitution requires the legislature to provide a thorough and efficient education for all students. Historically, public education was funded by local property taxes, resulting in significant disparities between districts. Decades of litigation and legislative reform led to a statewide, cost-based funding model for school operations and facilities. This model, known as the legislative model (LM), was intended to ensure equal educational opportunities by using a block grant system based on the estimated cost of an adequate education (the “basket of goods and services”). Periodic recalibrations and annual adjustments for inflation were required to keep the model current. The plaintiffs, including the Wyoming Education Association and several school districts, sued in 2022, alleging that the legislature’s funding model was no longer cost-based, wasn’t properly adjusted for inflation, and lacked funding for certain innovations such as elementary school counselors, nutrition services, and school resource officers. They also claimed the State’s facilities oversight was inadequate. The District Court of Laramie County, after a bench trial, found in favor of the plaintiffs on all issues, concluding that the legislature failed to fund actual costs, address inflation, and include necessary innovations, and that the State’s facilities process was constitutionally deficient. The Supreme Court of Wyoming reviewed the case. The Court affirmed the district court’s findings that the legislature violated students’ equal protection rights by failing to fund the true cost of teacher salaries and by not properly adjusting for inflation. However, it reversed the requirement to fund a one-to-one technology ratio, nutrition services, and school resource officers, finding insufficient evidence that these innovations required statewide funding. The Court also reversed the order requiring statewide assessment of educational suitability for facilities, holding the State’s administrative process was constitutionally adequate. The Court ended the lower court’s retention of jurisdiction, assuming the legislature would act in good faith to comply with constitutional requirements. View "The State of Wyoming v. Wyoming Education Association" on Justia Law

Climate Sols. v. State

2026-09-17T07:11:16-08:00

A group of organizations and individuals challenged the constitutionality of a statewide initiative approved by Washington voters in November 2024. The initiative, known as I-2066, enacted broad changes to energy regulation, including requirements for utilities and local governments to ensure natural gas access, restrictions on local air quality regulators, removal of zero-emission goals from state law, amendments to the Decarbonization Act, and limitations on the state building code council’s authority regarding gas usage and transitions away from fossil fuels. The King County Superior Court reviewed the case following cross-motions for summary judgment by the parties. The court declared I-2066 unconstitutional in its entirety, finding that it violated three constitutional requirements: it impermissibly encompassed more than one subject, failed to include its subjects in the title, and failed to set forth the laws it amended. This judgment was appealed directly to the Supreme Court of the State of Washington. The Supreme Court of the State of Washington reviewed the superior court’s ruling de novo. The court held that I-2066 violated the single-subject requirement of article II, section 19 of the Washington Constitution. It found that the initiative combined several distinct subjects with separate regulatory effects, lacking the necessary rational unity among its provisions. The court concluded that the provisions introducing distinct subjects were not severable and thus rendered the entire initiative unconstitutional. The Supreme Court affirmed the superior court’s judgment on the narrower ground of the single-subject violation and did not address the other constitutional arguments raised. View "Climate Sols. v. State" on Justia Law

State of Maine v. Marichal

2026-09-17T06:35:33-08:00

On October 1, 2021, Heather Marichal was involved in a car accident in Auburn, Maine, after driving on the wrong side of the road and crashing into another vehicle, then striking a snowplow. Marichal admitted to an officer that she had consumed alcohol at a brew fest and was the sole driver. She submitted to an Intoxilyzer test that showed a blood-alcohol content of .21 grams per 210 liters of breath. Marichal was charged with criminal operating under the influence (OUI), a Class D offense. The Androscoggin County Unified Criminal Docket handled the case, with multiple continuances throughout 2022, 2023, and 2024. Marichal sought to secure the appearance of a defense witness who allegedly would testify that someone else was driving. She served a subpoena and moved for a writ of capias ad respondendum when the witness ignored the subpoena. The court issued a civil warrant for the witness, but he did not appear for the December 2024 trial. Marichal filed motions in limine to admit hearsay statements from the witness and requested another arrest warrant. The trial court denied both the motion to continue and the motion in limine, finding Marichal had not demonstrated due diligence or likelihood of securing the witness, and that the hearsay exception was not met. The Maine Supreme Judicial Court reviewed the appeal following Marichal’s conditional guilty plea. The Court held that the trial court did not abuse its discretion in denying the motion to continue, as Marichal had not shown due diligence in securing the witness nor a likelihood that a continuance would procure the witness’s attendance. The Court also determined that Marichal’s constitutional rights to compulsory process and due process were not violated, as the witness’s absence was not attributable to State action or omission. The judgment of conviction was affirmed. View "State of Maine v. Marichal" on Justia Law

United States v. Alisigwe

2026-09-17T06:30:04-08:00

Chinwendu Alisigwe, a lawful permanent resident, was suspected by international law enforcement agencies of using fraudulent passports and identification documents to open bank accounts in the names of real individuals. Between 2017 and 2020, he opened thirty-six accounts, deposited millions from fraudulent schemes, transferred money to disguise its origins, and sent funds abroad. In 2019 and again in 2021, officers at John F. Kennedy International Airport stopped Alisigwe, manually searched his cellphone, and found evidence of identity theft and communications with co-conspirators. The United States District Court for the Southern District of New York denied Alisigwe’s motion to suppress evidence from the cellphone searches, reasoning that such searches require reasonable suspicion, and finding that law enforcement had reasonable suspicion both times due to ongoing investigations and evidence linking Alisigwe to fraudulent documents. The district court also imposed sentencing enhancements: an eighteen-point enhancement for intended loss under U.S.S.G. § 2B1.1(b)(1)(J), and a two-point enhancement for obstruction of justice under § 3C1.1 based on Alisigwe’s testimony at a duress hearing, which the court found to be fabricated. The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The main holding is that no suspicion is required before the government searches a traveler’s cellphone at the border; routine border searches of property, including cellphones, are reasonable under the Fourth Amendment. The court further held that the First Amendment does not impose an independent warrant requirement for border searches of cellphones. The court also upheld the district court’s application of sentencing enhancements for both intended loss and obstruction of justice. View "United States v. Alisigwe" on Justia Law

T.D. v. Wrigley

2026-09-17T05:38:41-08:00

The case centers on a challenge to a state law enacted in 2023, which prohibits health care providers from administering certain types of gender-affirming medical treatments to minors, including puberty blockers and cross-sex hormones, for the purpose of aligning a minor’s sex with their gender perception when inconsistent with their biological sex. Exceptions exist for minors with medically verifiable disorders of sex development and for those already receiving such treatments prior to the law’s effective date. Three minors, their parents, and a physician, Dr. Casas, who treats minors with gender dysphoria, initiated legal proceedings seeking declaratory and injunctive relief, arguing the law violates the North Dakota Constitution. The District Court of Burleigh County reviewed the case. It dismissed the minor plaintiffs and their parents for lack of standing, based on its interpretation that the law did not apply to minors receiving treatment before the effective date. The court found Dr. Casas had standing to pursue certain claims, including equal protection and personal autonomy on behalf of his patients, but not parental rights claims. After a seven-day trial and extensive evidence, the court concluded the law responded to legitimate concerns regarding the risks and effectiveness of gender-affirming treatments for minors and determined the statute did not violate constitutional guarantees of equal protection or personal autonomy. The court denied declaratory and injunctive relief, but clarified the law’s exception for ongoing treatment. On appeal, the Supreme Court of North Dakota addressed only whether the statute’s prohibition on gender-affirming medication for minors violates Article I, §§ 1 or 21 of the state constitution. The court held that minors do not have a fundamental right to a particular course of medical treatment under Article I, § 1. It further found the law does not classify based on sex or transgender status and is subject to rational basis review. The statute was deemed rationally related to the state’s legitimate interest in protecting minors’ health and welfare. The court affirmed the district court’s denial of relief. View "T.D. v. Wrigley" on Justia Law

Delgado v. United States

2026-09-17T05:31:44-08:00

The defendant was living with his romantic partner, C.P., when an argument escalated into physical and verbal abuse. During the incident, he forcibly cut C.P.’s hair, took her designer handbags and jewelry, threatened to harm her and her family if she reported him to police, forced her to withdraw cash from an ATM, and left with her possessions and car. C.P. reported the incident roughly a week later. The Superior Court of the District of Columbia indicted the defendant on eleven counts, but the jury convicted him of only two: first-degree theft and threatening to injure or kidnap a person. The court sentenced him to concurrent terms of twenty-eight months’ imprisonment, followed by three years’ supervised release, and ordered restitution of $3,638.60 for stolen property. The court also imposed assessments of $1,000 for each conviction under the Victims of Violent Crime Compensation Act (VVCCA). The defendant did not object to the VVCCA assessments at sentencing but timely appealed, arguing that the assessments constituted excessive fines in violation of the Eighth Amendment. The District of Columbia Court of Appeals reviewed the case. Applying the gross disproportionality standard articulated by the Supreme Court in United States v. Bajakajian, the court considered the nature and gravity of the offenses, the statutory penalties, the defendant’s culpability, and the harm suffered by the victim. The court concluded that the $2,000 in VVCCA assessments was not grossly disproportional to the gravity of the defendant’s offenses, especially given the statutory maximum fines and the significant harm caused. The court therefore held the assessments were constitutional and affirmed the judgment of the Superior Court. View "Delgado v. United States" on Justia Law

US v. Levasseur

2026-09-16T12:30:04-08:00

The defendant, a Maine resident with multiple prior felony convictions, was arrested after a state trooper observed him at a gas station and detained him based on an active felony warrant. During the arrest, Levasseur admitted to possessing a hunting rifle in his truck, which was loaded, and to having methamphetamine in the vehicle. He later stated he intended to hunt deer for food, although he lacked a hunting license, and disclosed a daily methamphetamine addiction. His criminal history included three illegal firearm possession convictions and other felonies, including drug possession and bail violations. A grand jury indicted Levasseur for possessing a firearm as a felon under 18 U.S.C. § 922(g)(1). He moved to dismiss the indictment in the United States District Court for the District of Maine, arguing the statute was unconstitutional as applied to him under the Second Amendment, referencing New York State Rifle & Pistol Ass’n v. Bruen and later United States v. Rahimi. The district court denied both his initial and renewed motions, ruling that his felony conviction for methamphetamine possession rendered him sufficiently dangerous to be disarmed under the Second Amendment, based on historical analogues of disarming categories of dangerous individuals. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s legal rulings de novo. The First Circuit assumed, without deciding, that the Second Amendment could apply to individuals with felony convictions and entertained Levasseur’s as-applied challenge. The court held that Levasseur failed to demonstrate error in the district court’s determination that he could constitutionally be disarmed due to posing a special danger of misusing firearms. Accordingly, the First Circuit affirmed his conviction, holding that 18 U.S.C. § 922(g)(1) is constitutional as applied to him. View "US v. Levasseur" on Justia Law

Beatty v. Gardner

2026-09-16T09:00:05-08:00

Police officers observed a man and his girlfriend in a car at a location known for drug trafficking. After smelling marijuana and spotting evidence of its use in the vehicle, the officers approached the man inside a store, where he consented to a pat-down search that yielded nothing. Outside the store, the couple initially consented to a search of the car but later revoked consent, leading the officers to arrest and handcuff the man. He was searched again on the hood of the car, with no contraband found. The officers then transported him to the police station, where they conducted a strip search solely for evidence, but nothing was recovered. The U.S. District Court for the Middle District of Pennsylvania reviewed the man’s federal civil-rights claims under 42 U.S.C. § 1983, challenging the stop, arrest, and three searches as unreasonable under the Fourth Amendment and retaliatory under the First Amendment. The District Court granted summary judgment to the officers on all federal claims, finding the initial stop, arrest, and first two searches reasonable, and the strip search protected by qualified immunity. It dismissed the state-law claims for lack of supplemental jurisdiction. The United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that while the initial stop, arrest, and two searches were reasonable, the search-incident-to-arrest doctrine does not justify strip searches outside of a jail or prison without a warrant, exigent circumstances, or consent. A warrant supported by probable cause is required for strip searches in such contexts. However, because this legal limitation was not clearly established at the time, the officers were entitled to qualified immunity. The court also concluded that the First Amendment retaliation claim was barred by qualified immunity. View "Beatty v. Gardner" on Justia Law

O'Bryant v. DCP&P

2026-09-16T09:00:05-08:00

Three individuals alleged that New Jersey child protection caseworkers violated their constitutional rights during investigations into suspected child abuse. The caseworkers entered the plaintiffs’ home without a warrant, pressured them to sign family agreements under threat of child removal, and ultimately removed the children from parental custody without prior court authorization. The removal was based on concerns about one parent’s alleged past violence, home conditions, and another parent’s mental health history. The plaintiffs claimed these actions violated their Fourth Amendment rights and their substantive and procedural due process rights under the Fourteenth Amendment. The United States District Court for the District of New Jersey dismissed the complaint, finding the defendants were entitled to qualified immunity. The court relied on facts outside the complaint, including allegations from a child abuse report and statements from caseworkers, to support its ruling. The District Court also dismissed claims for money damages against the Division and its employees in their official capacities and found one plaintiff lacked standing. On appeal, the United States Court of Appeals for the Third Circuit reviewed the dismissal de novo, considering only the facts alleged in the complaint and not external materials. The Third Circuit affirmed the dismissal of most claims, including the substantive and procedural due process claims, holding that the law was not clearly established to put the defendants on notice that their conduct violated constitutional rights. However, the court reversed the dismissal of the Fourth Amendment claim against the caseworker who entered the home without a warrant. The court held that the plaintiffs plausibly alleged a violation of clearly established Fourth Amendment law, and that qualified immunity did not shield the caseworker from liability on this claim. The case was remanded for further proceedings on the Fourth Amendment claim. View "O'Bryant v. DCP&P" on Justia Law

United States v. Hayes

2026-09-15T11:00:08-08:00

The defendant engaged in repeated threatening communications directed at two members of Congress, including violent voicemails and explicit threats to harm and kill them. These actions occurred over a period from 2022 to 2024, escalating in severity, culminating in a particularly violent message in July 2024. The defendant pleaded guilty to transmitting a threat in interstate commerce based on the July 2024 voicemail. The United States District Court for the Eastern District of Tennessee sentenced the defendant to twenty-four months’ imprisonment and one year of supervised release. As a condition of supervised release, the court imposed a broad ban prohibiting any contact with all members of Congress, directly or indirectly, including through third parties and social media, regardless of the nature or purpose of the communication. The district court stated the condition was necessary to protect the public and deter similar conduct. The defendant did not object at sentencing but timely appealed, arguing the condition was overly broad and infringed his First Amendment rights. The United States Court of Appeals for the Sixth Circuit reviewed the supervised release condition for plain error, due to the lack of objection below. The court found that the district court’s condition was overly broad and constituted error, as it imposed a greater deprivation of liberty than was reasonably necessary and burdened constitutional rights, including the right to petition Congress. However, the Sixth Circuit concluded that the error was not obvious or clear under existing law, since there was no binding precedent directly addressing such a broad restriction in this specific context. Therefore, the court affirmed the district court’s decision, holding that while the supervised release condition was erroneous, it did not meet the stringent requirements for plain error reversal. View "United States v. Hayes" on Justia Law

Harward v. City of Austin

2026-09-15T09:30:11-08:00

Several owners of shoreline properties along Lake Austin challenged a 2019 ordinance enacted by the City of Austin. The ordinance declared that their properties had always been within Austin’s full-purpose jurisdiction, repealed a 1986 ordinance that had previously classified the properties as limited-purpose (which restricted taxation until city services were provided), and subjected the properties to full taxation. The plaintiffs alleged that Austin taxed their properties as if they were full-purpose residents but provided fewer municipal services than other full-purpose residents, raising federal and state law claims. Initially, the United States District Court for the Western District of Texas dismissed all claims under the Tax Injunction Act. On appeal, the United States Court of Appeals for the Fifth Circuit reversed the dismissal of all but two claims and remanded the case. Upon remand, the City reasserted several grounds for dismissal, including the political-question doctrine, Pullman abstention, Burford abstention, and failure to state a claim. The magistrate judge recommended Pullman abstention, which the district court adopted, dismissing the claims without prejudice and entering final judgment. The plaintiffs appealed again. The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision and held that the case was not moot, as recent state legislation neither refunded taxes nor automatically disannexed the properties. The Fifth Circuit concluded that Pullman abstention was inappropriate because the plaintiffs’ federal equal protection claim did not hinge on any uncertain or disputed question of Texas law. Accordingly, the Fifth Circuit reversed the district court’s judgment and remanded the case for consideration of the City’s remaining grounds for dismissal, expressly declining to reach those grounds itself. View "Harward v. City of Austin" on Justia Law

USA v. Walker

2026-09-15T09:30:06-08:00

Police officers investigating a suspicious package at a UPS facility in Pennsylvania found it to be heavily taped, sent by next-day air, and addressed to a likely fake recipient. A drug-sniffing dog alerted to the presence of drugs, and a subsequent search warrant revealed six pounds of methamphetamine inside the box. To identify the intended recipient, officers sought and obtained a GPS tracker order and a search warrant for Apartment 2 at the delivery address. The officer’s affidavit also requested permission to secure the package at any secondary location, but neither the warrant nor the tracker order explicitly authorized entry into other residences. When the package was delivered, Davone Walker took it into Apartment 1, a different apartment in the same building. Officers waited but did not see the box opened. Eventually, they entered Apartment 1 without a warrant specific to that location, secured the scene, and applied for a new warrant, which permitted a search of Apartment 1. The search uncovered substantial quantities of methamphetamine, fentanyl, cocaine, and drug paraphernalia. Walker was charged with drug offenses and moved to suppress the evidence, arguing the original warrant did not cover Apartment 1 and the tracker order gave no authority for entry. The United States District Court for the Eastern District of Pennsylvania denied Walker’s suppression motion. It found that the officer’s belief he was authorized to enter Apartment 1 was unreasonable, but concluded the mistake was isolated negligence, not grossly negligent or deliberate misconduct warranting exclusion. The United States Court of Appeals for the Third Circuit reviewed the facts for clear error and legal conclusions de novo. It held that suppression is reserved for deliberate, reckless, or grossly negligent misconduct, not isolated mistakes. Finding Trooper Montz’s error to be, at most, isolated negligence, the court affirmed both the denial of Walker’s suppression motions and his conviction. View "USA v. Walker" on Justia Law

Jensen v. Minn. Bd. of Medical Practice

2026-09-15T07:30:14-08:00

During the COVID-19 pandemic, Dr. Scott Jensen, a physician and former Minnesota state senator, publicly voiced opposition to vaccine mandates and business closures. As a Republican candidate for governor in 2022, he became the subject of 18 complaints alleging he spread misinformation and endangered public health. The Minnesota Board of Medical Practice initiated four investigations, each requiring Jensen to respond and cooperate fully, including providing documents and hiring legal counsel. One investigation lasted over a year and demanded an in-person conference. Jensen claims these investigations caused him to spend substantial time and money, self-censor his public statements, and decline speaking engagements due to fear of professional repercussions. The United States District Court for the District of Minnesota dismissed Jensen’s amended complaint for lack of standing, finding his allegations “too conclusory” and lacking specific instances of chilled speech or imminent enforcement threats. The court determined he did not demonstrate injury sufficient to invoke federal jurisdiction, thus preventing further review of his constitutional claims seeking damages and injunctive relief. The United States Court of Appeals for the Eighth Circuit reviewed the dismissal. It found that Jensen’s general factual allegations of time, money spent, and self-censorship—the chilling effect—were sufficient to establish standing at the pleading stage. The court concluded that both monetary harms and reasonable self-censorship due to credible threats of enforcement constituted concrete and particularized injuries. The appellate court held that Jensen had standing to pursue his claims for damages and injunctive relief. The judgment of the district court was reversed and the case remanded for further proceedings on the merits. View "Jensen v. Minn. Bd. of Medical Practice" on Justia Law

Defending Education v. Croton-Harmon Union Free School District

2026-09-15T06:30:10-08:00

An association composed of parents, students, and concerned citizens filed suit under 42 U.S.C. § 1983, challenging student speech policies adopted by a New York school district. The association claimed that these policies violated the First and Fourteenth Amendment rights of its members’ children by chilling their ability to express certain social and political views in school. The association sought a preliminary injunction against enforcement of the challenged policies, arguing that the speech codes were impermissibly overbroad, vague, and compelled students to affirm views with which they disagreed. The United States District Court for the Southern District of New York denied the motion for a preliminary injunction and dismissed the action for lack of subject matter jurisdiction. The district court relied on Aguayo v. Richardson, 473 F.2d 1090 (2d Cir. 1973), which held that associations lack standing to sue on behalf of their members under § 1983. The association appealed to the United States Court of Appeals for the Second Circuit, but, acknowledging Aguayo, moved for summary affirmance, which the Second Circuit granted. Subsequently, the association petitioned for reconsideration en banc, asking the Court to overrule Aguayo. The United States Court of Appeals for the Second Circuit, after circulating the opinion to all active judges and receiving no objection, overruled Aguayo’s bar on associational standing under § 1983. The Court adopted the Supreme Court’s rule from Hunt v. Washington State Apple Advertising Commission, 432 U.S. 333 (1977): a membership organization has standing to sue on behalf of its members under § 1983 if (1) members have standing to sue in their own right; (2) the interests are germane to the organization's purpose; and (3) individual member participation is unnecessary. The Second Circuit reversed the district court’s dismissal and remanded for further proceedings. View "Defending Education v. Croton-Harmon Union Free School District" on Justia Law

Martin v. Commissioner, Alabama Department of Corrections

2026-09-14T08:01:16-08:00

A former Alabama State Trooper was accused of murdering his wife, allegedly staging a car accident to collect life insurance proceeds. The prosecution's case was circumstantial, relying heavily on witness testimony and evidence suggesting financial motive. After initially failing to indict, the Alabama Attorney General’s Office pursued the case, resulting in the trooper’s conviction and a sentence of death. However, a lengthy series of postconviction proceedings revealed that the prosecution had committed several Brady violations, including withholding exculpatory evidence that implicated alternative suspects and supported the defense’s theory. This led to the trial court granting a new trial and later dismissing the indictment with prejudice due to willful prosecutorial misconduct, a decision eventually reversed by the Supreme Court of Alabama, which ordered a second trial. During the second trial, the new trial judge issued a preclusion order barring mention of prior prosecutorial misconduct or the procedural history. The defendant argued this order violated his constitutional rights, specifically the Confrontation Clause and his right to present a complete defense. He was again convicted of capital murder for pecuniary gain and sentenced to life without parole. The Alabama Court of Criminal Appeals affirmed, and the Supreme Court of Alabama denied certiorari. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of habeas relief. The court held that, although Alabama’s misconduct was egregious, the limitations imposed by the Antiterrorism and Effective Death Penalty Act (AEDPA) prevented granting habeas relief. The Eleventh Circuit found no procedural default, but ruled that neither the preclusion order nor the sufficiency of the evidence claim warranted relief under AEDPA’s standards. The district court’s judgment denying habeas relief was affirmed. View "Martin v. Commissioner, Alabama Department of Corrections" on Justia Law

United States v. Jackson

2026-09-14T08:01:14-08:00

Police officers in Colorado observed an SUV parked in a lot adjacent to a closed check-cashing store and inactive bus stop at approximately 1:50 a.m., a location known for drug activity. The vehicle was reverse-parked, and three or four individuals were standing nearby. As officers approached, some individuals dispersed and the defendant, Mr. Jackson, was seen making furtive movements inside the vehicle. Officers requested Mr. Jackson exit the SUV, conducted a pat-down, and found a firearm in his pants. He was subsequently charged with unlawful possession of a firearm and ammunition under 18 U.S.C. § 922(g)(1). Mr. Jackson moved in the United States District Court for the District of Colorado to suppress evidence of the gun, arguing that the stop and pat-down were made without reasonable suspicion of criminal activity. The district court held an evidentiary hearing, during which both officers testified. The district court found that the officers had reasonable suspicion based on the location, time, reverse-parking, presence and dispersal of individuals around the SUV, and Mr. Jackson’s furtive movements prior to the stop. The court denied the motion to suppress. On appeal to the United States Court of Appeals for the Tenth Circuit, the court reviewed the district court’s factual findings for clear error and legal conclusions de novo. It concluded that the district court’s findings regarding the presence of individuals and observations of Mr. Jackson’s furtive movements were not clearly erroneous, even in light of conflicting written statements and body-camera footage. The Tenth Circuit held that, considering the totality of the circumstances, the officers had reasonable suspicion to justify the investigatory stop. Accordingly, the Tenth Circuit affirmed the district court’s denial of the motion to suppress and upheld Mr. Jackson’s conviction. View "United States v. Jackson" on Justia Law

CEDAR PARK ASSEMBLY OF GOD OF KIRKLAND, WASHINGTON V. KUDERER

2026-09-14T08:00:41-08:00

A church in Washington State challenged the validity of two state laws: the Reproductive Parity Act, which requires health insurance carriers to include coverage for all federally approved contraceptives and, if maternity care is covered, for abortions; and a longstanding conscience statute, which allows employers to object to purchasing coverage for specific healthcare services on religious or moral grounds. The church, as an employer providing health insurance to its employees, argued that these laws forced it to provide, pay for, or facilitate access to abortion and certain contraceptives in violation of its religious beliefs and right to religious autonomy. The United States District Court for the Western District of Washington found that the church had standing to sue, but granted summary judgment in favor of the state defendants on the merits, concluding that the challenged laws did not violate the Free Exercise Clause or church autonomy doctrine. Both sides appealed. Previously, the Ninth Circuit vacated the district court’s judgment for lack of standing, but after the Supreme Court’s decision in Diamond Alternative Energy, LLC v. EPA, 606 U.S. 100 (2025), it vacated its own opinion and reheard the case. The United States Court of Appeals for the Ninth Circuit held that the church had Article III standing, as the laws caused it to facilitate abortion indirectly. Assuming, without deciding, that the laws burdened the church’s religious exercise, the court concluded that the laws are neutral and generally applicable. Therefore, rational basis review applied, and the church conceded the laws met that standard. The court affirmed summary judgment for the state defendants, holding that the laws do not violate the Free Exercise Clause or the church autonomy doctrine. View "CEDAR PARK ASSEMBLY OF GOD OF KIRKLAND, WASHINGTON V. KUDERER" on Justia Law

United States v. Stafford

2026-09-11T12:30:07-08:00

A 59-year-old Navy employee began communicating with a 15-year-old boy, M.V., on an online dating site where M.V. falsely listed his age as 18, the minimum allowed by the site. Over several months in 2023, the two exchanged messages, met in person multiple times, and, according to M.V., engaged in sexual acts. The minor’s parents eventually discovered the relationship, notified law enforcement, and participated in a sting operation that resulted in the adult’s arrest. Police recovered evidence from the defendant’s belongings, including items suggesting sexual intent. A grand jury in the United States District Court for the Western District of Michigan indicted the defendant on one count of coercion and enticement of a minor under 18 U.S.C. § 2422(b), and two counts of interstate travel with intent to engage in illicit sexual conduct under 18 U.S.C. § 2423(b). Before trial, the district court excluded sexually explicit portions of the minor’s dating profile under Federal Rule of Evidence 412 and denied a proposed affirmative defense related to reasonable belief of the victim’s age for Counts 2 and 3. The jury convicted the defendant on all counts, and he was sentenced to 156 months in prison. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the conviction on Count 1, holding that the district court’s jury instructions accurately reflected the law and that sufficient evidence supported the conviction. The court found no abuse of discretion in excluding evidence under Rule 412. However, regarding Counts 2 and 3, the court held that the government must prove the defendant intended to engage in a sexual act with a person under 16, not merely under 18, when § 2243(a) is the predicate offense. The convictions on Counts 2 and 3 were vacated and remanded for a new trial with proper jury instructions. View "United States v. Stafford" on Justia Law

Debbane v. City and County of San Francisco

2026-09-11T12:01:14-08:00

The case involves a challenge to Proposition M, a San Francisco measure approved by voters in 2022 that imposed an annual “Empty Homes Tax” on owners of certain residential units kept vacant for more than 182 days in buildings with more than two units. The stated aim was to discourage prolonged vacancies and increase available housing. Plaintiffs included individuals and associations representing property owners, who argued that Proposition M violated statutory and constitutional protections, including property rights and familial relations, and was preempted by the Ellis Act, which protects property owners’ right to withdraw accommodations from the rental market. The San Francisco City & County Superior Court reviewed cross-motions for summary judgment. Plaintiffs submitted declarations detailing how Proposition M would force them to either rent out units against their wishes or pay substantial taxes, potentially resulting in financial hardship or effective eviction. The City argued plaintiffs lacked standing and that their legal claims failed as a matter of law. After briefing and a hearing, the Superior Court granted summary judgment for plaintiffs, holding that Proposition M violated the Takings Clause, was preempted by the Ellis Act, burdened fundamental liberty interests in familial relations, violated equal protection, and infringed upon the constitutional right to privacy. The court entered judgment prohibiting the City from administering or enforcing Proposition M. The Court of Appeal of the State of California, First Appellate District, Division One, reviewed the City’s appeal. The appellate court analyzed the measure’s conflict with the Ellis Act and concluded that Proposition M imposed a “prohibitive price” on owners’ right not to offer property for rent, directly contravening the Act’s protections. The court found that the Ellis Act preempts Proposition M and affirmed the trial court’s judgment, without reaching additional constitutional claims. The judgment prohibiting enforcement of Proposition M was thus upheld. View "Debbane v. City and County of San Francisco" on Justia Law

State v. Satterfield

2026-09-11T07:02:30-08:00

A parole commission issued an arrest warrant for an individual who had absconded. The warrant authorized various law enforcement officers to detain the individual. A Nampa City police officer located the individual in Caldwell, Idaho, and arrested him, despite being outside his jurisdiction and without satisfying any of the statutory exceptions for extraterritorial arrests. After the arrest, officers searched the individual’s vehicle and discovered narcotics and a stolen firearm, leading to charges including unlawful possession of a firearm and possession of drug paraphernalia. The matter was reviewed by the District Court of the Third Judicial District, Canyon County. The defendant moved to suppress evidence, arguing that his arrest was unconstitutional under both federal and Idaho constitutional provisions due to the officer’s violation of Idaho Code section 67-2337(2). The district court denied the motion, concluding that the officer’s violation of the statute did not amount to a constitutional violation. The defendant entered a conditional guilty plea, reserving his right to appeal. The Idaho Court of Appeals affirmed the district court’s decision. The Supreme Court of the State of Idaho granted review. The Court applied a bifurcated standard of review, examining factual findings for clear error and freely reviewing constitutional questions. The Court held that a violation of Idaho Code section 67-2337(2) by a peace officer does not constitute a constitutional violation requiring suppression of evidence, absent a showing that the Idaho Constitution, state precedent, or unique state interests demand a different analysis from federal law. The Court affirmed the district court’s denial of the suppression motion and the judgment of conviction. View "State v. Satterfield" on Justia Law

Kuehn v. Pillen

2026-09-11T05:06:51-08:00

An individual Nebraska resident, voter, and taxpayer sought declaratory and injunctive relief challenging the constitutionality of two medical cannabis laws enacted by voter-approved initiatives in the November 2024 general election. He named as defendants the Governor, other state officials, members of the Nebraska Medical Cannabis Commission, and the sponsors of the initiatives. The plaintiff alleged the laws violated the federal Supremacy Clause, improperly delegated regulatory authority in violation of Nebraska’s separation of powers, and were otherwise unconstitutional. He further claimed public officials and agencies would expend state funds and resources to implement these laws, and that this expenditure was unlawful. Previously, before the laws passed, the same individual brought a preelection challenge to the legal sufficiency of the initiative petitions in the District Court for Lancaster County. That challenge was rejected, and the Nebraska Supreme Court affirmed. After the election, he filed a new action in the same district court, seeking to enjoin the Governor from certifying the measures. The district court denied his request for a temporary restraining order. Once the laws were certified and enacted, he amended his complaint several times, ultimately alleging taxpayer standing, standing for a matter of great public concern, and standing under a Nebraska statute governing initiative challenges. The defendants moved to dismiss, contending he lacked standing. The Nebraska Supreme Court reviewed the district court’s dismissal de novo. The Supreme Court held that the plaintiff lacked standing to bring the suit. Specifically, it concluded he did not have taxpayer standing, as his allegations of incidental expenditures and government employee time spent implementing the laws did not amount to illegal expenditures sufficient to confer standing under Nebraska law. The Court also found he did not qualify for any exception for matters of great public concern. The order dismissing his complaint without prejudice was affirmed. View "Kuehn v. Pillen" on Justia Law

Mary D. v. McCauley

2026-09-10T14:31:13-08:00

A woman brought a civil lawsuit against her uncle and godfather, alleging years of sexual abuse that began when she was a minor. The defendant was previously convicted in a criminal court for related offenses and was incarcerated. After his conviction, the plaintiff filed the civil suit seeking compensatory and punitive damages for personal injuries resulting from the abuse. The defendant initially had legal representation using personal funds, but those funds became inaccessible due to a blocked account ordered by a family court during concurrent divorce proceedings. When his accessible funds were depleted, the defendant began representing himself. He sought access to the blocked funds to retain new counsel but experienced significant delays in obtaining a family court order to release the money. The Superior Court of Alameda County presided over the civil trial, during which the defendant appeared remotely from prison. Despite repeated requests for continuances to secure counsel after finally gaining access to some funds, the trial court denied these requests. The trial proceeded, and a jury found the defendant liable for several torts, awarding the plaintiff substantial compensatory and punitive damages. Upon appeal, the California Court of Appeal, First Appellate District, Division Four, determined that the trial court abused its discretion and violated the defendant’s constitutional rights by denying his continuance requests, given his indigency, incarceration, and the fundamental right to meaningful access to the courts. The appellate court reversed the judgment and remanded the case for a new trial on all issues, including punitive damages. The court clarified that the plaintiff is entitled to retry all issues. The court did not address other trial errors or the excessiveness of damages due to its disposition. The appellate court also explained that the trial court did not err in admitting school photographs of the plaintiff, which may be relevant upon retrial. View "Mary D. v. McCauley" on Justia Law

Lopez Garcia v. Guadian

2026-09-10T12:30:13-08:00

Two individuals who had lived in the United States for many years after entering without inspection were detained by Immigration and Customs Enforcement in October 2025. Both were apprehended while living and working in the Washington, D.C. area, and had established significant ties to the community. Removal proceedings were initiated against them on the basis that they had entered the country without authorization. Following their detention, neither was given an opportunity for a bond hearing, a process that, prior to July 2025, would have typically been available to noncitizens in their circumstances unless they posed certain risks or had committed specific crimes—none of which applied to these individuals. After the Department of Justice adopted a new interpretation of the relevant immigration statute in July 2025, mandating detention for all noncitizens who entered without inspection under 8 U.S.C. § 1225(b)(2)(A), the individuals filed habeas petitions in the United States District Court for the Eastern District of Virginia. They argued that they were entitled to bond hearings under 8 U.S.C. § 1226(a) and that their continued detention violated due process. The district court agreed, granting habeas relief and ordering bond hearings under § 1226(a). During these hearings, immigration judges found neither individual posed a danger or flight risk, and both were released on bond. The government appealed, and the cases were consolidated. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of habeas relief de novo. The Fourth Circuit held that § 1226, not § 1225, governs the detention of noncitizens who have been present in the United States for years, regardless of their manner of entry. The court concluded that the statutory text, structure, history, and longstanding interpretation all supported this reading, and that detaining such individuals without bond hearings raised significant constitutional concerns. The court affirmed the district court’s grant of habeas relief, requiring bond hearings for the petitioners. View "Lopez Garcia v. Guadian" on Justia Law

Edwards v. Witherspoon

2026-09-10T12:30:13-08:00

While incarcerated at a North Carolina women’s correctional facility, the plaintiff learned she was pregnant and, due to her history of opioid use disorder, was prescribed medication for opioid withdrawal (MOUD) under a prison policy that restricted such treatment to pregnant inmates. When she went into labor, she was transported to the hospital and was shackled at various stages during labor, delivery, and her return to prison. After giving birth, the facility denied her further MOUD because she was no longer pregnant, instead providing a short course of alternative pain medication. She experienced significant withdrawal symptoms as a result. The plaintiff brought claims against various prison officials, alleging violations of the Eighth Amendment for the shackling and for denial of MOUD, as well as disability discrimination under the Americans with Disabilities Act and the Rehabilitation Act. The United States District Court for the Eastern District of North Carolina granted summary judgment to all defendants, finding no constitutional violations and that qualified immunity protected the officials. It also concluded that the plaintiff was not discriminated against under federal disability law because the MOUD program was limited to pregnant inmates. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed in part, vacated in part, and remanded. The Fourth Circuit held that, as to certain officials, there was a genuine dispute of fact regarding whether shackling the plaintiff during labor and postpartum, without evidence of a security or flight risk, violated the Eighth Amendment. The court also held that the denial of MOUD following pregnancy, pursuant to a categorical policy, could constitute deliberate indifference to serious medical needs under the Eighth Amendment, and that summary judgment was inappropriate for the medical officials involved. The court further vacated the lower court’s disposition of the plaintiff’s ADA and Rehabilitation Act claims, remanding for further proceedings. Summary judgment for other defendants was affirmed. View "Edwards v. Witherspoon" on Justia Law

Frazier v. United States

2026-09-10T06:01:30-08:00

A police officer in Washington, D.C., recovered a loaded handgun from the waistband of an individual during a patrol in a high-crime area. The officer initiated a pat-down after observing an unexplained L-shaped bulge in the individual's groin area, which he suspected to be a firearm based on his training, experience, and prior knowledge of the individual’s history with firearm-related arrests. The officer’s interaction began as a casual conversation, and several people present walked away freely. The officer noted the bulge after the individual sat, and subsequent questioning led to evasive responses before the officer conducted the frisk and discovered the firearm. The Superior Court of the District of Columbia reviewed the individual’s motion to suppress the evidence, which argued that the pat-down violated Fourth Amendment protections. After an evidentiary hearing, the trial court found the officer credible and concluded that the L-shaped bulge observed and the individual’s evasive behavior provided reasonable articulable suspicion to justify the frisk. The court also determined that there was no seizure prior to the officer’s observation of the bulge, as the individual was not physically restrained, blocked, or subjected to threatening or accusatory questioning. Following denial of the suppression motion, a second Superior Court judge convicted the individual on three firearm-related charges. The District of Columbia Court of Appeals reviewed the case, applying de novo review to the Fourth Amendment issues while deferring to the trial court’s factual findings unless clearly erroneous. The court held that the officer’s observation of an L-shaped bulge, its concealed location, the individual’s evasive responses, and contextual factors including prior arrests and recent criminal activity supported reasonable articulable suspicion for a frisk. The appellate court affirmed the trial court’s denial of the suppression motion and the convictions. View "Frazier v. United States" on Justia Law

Black Emergency Response Team v. Drummond

2026-09-09T12:01:03-08:00

Several teachers, students, parents, and their organizations challenged Oklahoma’s H.B. 1775, specifically subsection B, which restricts public school employees from making certain “discriminatory concepts” a required part of courses. These concepts include assertions about inherent superiority, moral character, responsibility, and psychological distress based on race or sex, among others. If violated, educators could face suspension or revocation of their teaching credentials. Plaintiffs argued that subsection B was unconstitutionally vague under the Fourteenth Amendment and violated students’ First Amendment right to receive information. The United States District Court for the Western District of Oklahoma reviewed the case. It granted judgment on the pleadings against the plaintiffs on their First Amendment claims, finding no protected right in curricular speech and no plausible right-to-receive-information claim. The court partially granted a preliminary injunction, finding that the use of “require” and two of the prohibited concepts (those using “treatment” and “treat”) were likely unconstitutionally vague, and enjoined enforcement of those parts. The court denied injunctive relief for the remaining language, and both parties appealed. The Oklahoma Supreme Court later declined to answer certified questions regarding the statute’s interpretation. The United States Court of Appeals for the Tenth Circuit reviewed the injunction. The court held that the District Court abused its discretion in finding vagueness in subsection B. It interpreted the statute as prohibiting teaching or requiring teaching of the listed discriminatory concepts as correct principles, not banning abstract discussion or instruction about related history or figures. The court determined that the statute’s language was sufficiently clear and not likely vague. It vacated the preliminary injunction, affirmed in part, reversed in part, and remanded for further proceedings. The court declined to address the First Amendment right-to-receive-information claims due to lack of appellate jurisdiction. View "Black Emergency Response Team v. Drummond" on Justia Law

Lackey v. Hurley

2026-09-09T12:00:18-08:00

Kevin Lackey was convicted in 1993 by a Michigan jury of criminal sexual conduct and breaking and entering after he was accused of sexually assaulting an eleven-year-old girl in her home. The incident involved an assailant who allegedly entered through a window, abducted the victim from her bedroom, and assaulted her on the back porch before fleeing. Police quickly responded, gathered statements, and relied on a police dog that tracked from the crime scene to Lackey’s nearby residence. Lackey matched the physical description given by the victim and her mother. After serving 22 years in prison, his convictions were vacated due to significant issues with the dog-tracking evidence, and the prosecutor chose not to retry the case. Following the vacatur of his convictions, Lackey filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan. He alleged that several investigating officers fabricated evidence, maliciously prosecuted him, and suppressed exculpatory material, thereby violating his constitutional rights. The district court granted summary judgment in favor of the officers, finding them entitled to qualified immunity, and Lackey settled his remaining claims against another defendant before final judgment was entered. The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that Lackey failed to show the officers violated clearly established constitutional rights. The court found no genuine dispute as to material fact that would defeat qualified immunity on claims of fabrication of evidence, malicious prosecution, or suppression of exculpatory evidence. Specifically, the court concluded there was probable cause supporting Lackey’s arrest and prosecution, and no evidence that the officers withheld material information or fabricated evidence in a way that affected the outcome of the trial. The judgment in favor of the officers was therefore affirmed. View "Lackey v. Hurley" on Justia Law

USA v. Olson

2026-09-09T10:31:10-08:00

Police officers in Miami-Dade surveilled a house known for prior drug activity and a recent drive-by shooting. They observed Olson Joseph getting a haircut on the front lawn and later noticed he was carrying a concealed handgun in his sweatshirt pocket. The officers detained Joseph at gunpoint, removed the firearm, and conducted records checks, revealing Joseph was a felon without a concealed-carry permit. About twenty minutes after the stop, Joseph was transported to the station. He was subsequently charged in federal court with possession of a firearm and ammunition by a felon in violation of 18 U.S.C. § 922(g)(1). The United States District Court for the Southern District of Florida denied Joseph’s motion to dismiss the indictment, rejecting his argument that § 922(g)(1) violated the Second Amendment. The court also denied his motion to suppress the gun, finding the encounter was a Terry stop and that the officers had reasonable suspicion based on Joseph’s gun possession, his presence in a high-crime area, and proximity to a house associated with a recent homicide and drug activity. Joseph entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that, under circuit precedent, § 922(g)(1) does not violate the Second Amendment and affirmed denial of the motion to dismiss. However, the court found that the officers lacked reasonable suspicion for the stop, since Florida’s 2015 concealed-carry statute amendment made carrying a concealed weapon presumptively lawful, and Joseph’s conduct did not indicate criminal activity. The court vacated Joseph’s conviction, reversed the partial denial of the suppression motion, and remanded for further proceedings. View "USA v. Olson" on Justia Law

Eriakha v. University of MS

2026-09-09T09:30:07-08:00

Twin brothers, both Black international students, were enrolled as doctoral candidates at the University of Mississippi’s Department of Pharmacy Administration. One brother, Bennard, disagreed with changes to his faculty mentorship arrangement, objected to mandatory in-person meetings, and declined to complete a required program assessment called the Abilities Transcript. After being repeatedly warned and given extensions, he was placed on provisional status for failing to complete the requirement, which also caused the loss of his graduate assistantship. Bennard and his brother each filed lawsuits against the University and several faculty members, alleging constitutional, statutory, and contract violations related to academic sanctions and alleged discriminatory treatment. The United States District Court for the Northern District of Mississippi consolidated the brothers’ cases. It dismissed Bennard’s claims against the University on sovereign-immunity grounds, dismissed his remaining federal claims under Rule 12(b)(6) for failure to state a claim, and declined to exercise supplemental jurisdiction over his individual-capacity state contract claims. Bennard appealed, while his brother’s appeal was dismissed for failure to prosecute. The United States Court of Appeals for the Fifth Circuit reviewed Bennard’s remaining claims. The court held that sovereign immunity barred claims against the University, claims against one defendant in her official capacity, and official-capacity state-law contract claims; those dismissals must be without prejudice. The court further found that Bennard failed to plausibly allege First or Fourteenth Amendment violations, and that the faculty defendants were entitled to qualified immunity on individual-capacity claims. The court affirmed the district court’s refusal to exercise supplemental jurisdiction over the remaining contract claims and upheld consolidation of the cases and dismissal of moot preliminary injunction motions. The judgment was affirmed as modified to clarify the proper form of dismissal for sovereign-immunity-barred claims. View "Eriakha v. University of MS" on Justia Law

USA v. Brown

2026-09-09T08:30:45-08:00

Rodney Brown was charged with Hobbs Act robbery and brandishing a firearm during a crime of violence after he robbed a convenience store, threatening a cashier and her son, and stealing money and personal items. The robber left a soda bottle at the scene, which, along with a mask found nearby, was tested for DNA. Law enforcement obtained Brown’s DNA and had it analyzed by a private lab. At trial, a DNA analyst from the lab testified that Brown’s DNA matched the evidence, but the analyst had not personally performed the hands-on lab work generating the DNA profiles. In the United States District Court for the Southern District of Florida, a jury found Brown guilty on both counts. At sentencing, the court classified Brown as a career offender under the United States Sentencing Guidelines, using the 2023 version of the Guidelines, which treated Hobbs Act robbery as a crime of violence. This resulted in an increased sentencing range, and Brown was sentenced to 324 months in prison. On appeal to the United States Court of Appeals for the Eleventh Circuit, Brown argued for the first time that his Confrontation Clause rights were violated by the DNA analyst’s testimony, and that the Ex Post Facto Clause was violated when the district court used a later version of the Guidelines Manual. The Eleventh Circuit held that the district court did not plainly err in permitting the DNA analyst’s testimony, since the analyst independently reviewed and analyzed the DNA profiles and did not merely act as a surrogate for other lab personnel. However, the court found plain error in sentencing Brown under the 2023 Guidelines Manual, as the offense occurred before the relevant amendment. The court affirmed Brown’s convictions, vacated his sentence, and remanded for resentencing under the correct Guidelines version. View "USA v. Brown" on Justia Law

SC Public Interest Foundation v. Oconee County

2026-09-09T06:09:30-08:00

Several residents and a public interest foundation sought to block a county’s implementation of an ordinance that authorized the issuance of $25 million in general revenue bonds. The bonds were intended to fund the final phase of a sewer and wastewater treatment project serving only the southernmost part of the county. The ordinance provided for an annual ad valorem tax on all taxable property in the county to support repayment. The plaintiffs argued the ordinance violated the state constitution by levying a county-wide tax for a benefit limited to a specific geographic area. The Oconee County Circuit Court considered the county’s motion to dismiss, which argued that the plaintiffs lacked standing, that the action was untimely, and that the ordinance was constitutional. The circuit court rejected the county’s arguments on standing and timeliness but granted the motion to dismiss by concluding the ordinance was constitutional. The plaintiffs appealed, and the county cross-appealed, asserting the action should be barred as untimely. The Supreme Court of South Carolina reviewed the case. It held that the plaintiffs’ action was barred by the twenty-day statute of limitations in South Carolina Code section 11-15-30, which requires any action challenging the issuance of bonds to be filed within twenty days of filing the official record of bond proceedings. The Court determined the plaintiffs’ challenge was “on account of” the bond issuance, as the ordinance authorizing the bonds and their use were inseparable. Because the plaintiffs filed their action more than four months after the required record was filed with the clerk of court, the Supreme Court held the action was untimely. The judgment of the circuit court was affirmed as modified, with the Supreme Court declining to address other issues, including standing and constitutionality. View "SC Public Interest Foundation v. Oconee County" on Justia Law