Constitutional Law - Justia Case Law Summaries

AB Realty, LLC v. Lane

2026-11-06T08:30:13-08:00

During the summer of 2018, housing advocates interacted with tenants at the Yale Park Apartment Complex in Omaha, documenting alleged building code violations and submitting complaints to the City. Based largely on this information, the City’s Chief Housing Inspector applied for and received an inspection warrant. Subsequent searches led to the closure of the complex, and tenants were forced to relocate. The City later provided AB Realty, LLC—the owner—and Kay and Janae Anderson with a list of violations and barred reopening until repairs were made. AB Realty attempted to challenge the closure through the Property Management Appeals Board and faced ongoing notices and prosecution for code violations. After completing repairs and reopening the complex in 2021, AB Realty and the Andersons initiated a lawsuit. The United States District Court for the District of Nebraska granted the defendants’ motion to dismiss in part and stayed proceedings pending the outcome of Kay Anderson’s criminal trial. After a state-court jury convicted Kay on a few counts but acquitted him of most, the district court dismissed the remaining claims against the City of Omaha and associated defendants. The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The court held that the search warrant, even excluding disputed information, was supported by probable cause based on the complaints and evidence of violations. It further determined that violations of Nebraska state law regarding warrants did not sustain a federal constitutional claim under 42 U.S.C. § 1983. The court also found AB Realty’s procedural due process allegations insufficiently specific to identify constitutionally protected interests or responsible parties. Finally, the court ruled that AB Realty failed to plead either a per se or regulatory taking under the Fifth Amendment, as the City did not physically appropriate the property and the closure for code violations did not constitute a regulatory taking. All claims against all defendants were dismissed. View "AB Realty, LLC v. Lane" on Justia Law

McClinton v. Warden

2026-11-06T08:00:43-08:00

A prison inmate was transferred from Phillips State Prison in Georgia, where he had stabbed a high-ranking member of the Bloods gang, to Baldwin State Prison after being placed in protective custody due to the imminent threat of retaliation. The transfer request cited his need for mental health services and mentioned the risk posed by his known enemy, but did not specify risks at Baldwin. Upon arriving at Baldwin, the inmate was placed in the general population, and after briefly requesting protective custody—which he later withdrew—he was stabbed to death by another inmate, allegedly a Bloods member. The parents and estate of the deceased sued five Georgia Department of Corrections officials, alleging that each was deliberately indifferent to the risk of harm under the Eighth Amendment. The United States District Court for the Middle District of Georgia initially dismissed certain wrongful death claims as time-barred, but allowed Eighth Amendment claims by the estate against all five defendants to proceed. The district court ultimately granted summary judgment in favor of the defendants, holding that each was entitled to qualified immunity because there was no violation of clearly established law and no evidence of subjective awareness by any defendant that their conduct caused a substantial risk of harm. The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s rulings de novo. The Eleventh Circuit affirmed the district court’s judgment, holding that none of the defendants possessed the requisite subjective knowledge that their actions or inactions placed the inmate at substantial risk of serious harm. Applying the deliberate indifference standard established in Wade v. McDade and Farmer v. Brennan, the court concluded that all defendants were protected by qualified immunity, as there was no constitutional violation. View "McClinton v. Warden" on Justia Law

Am. Future Fund, Inc. v. N.Y. Bd. of Elections

2026-11-06T08:00:03-08:00

A nonprofit organization planned to run several political advertisements critical of socialism and the Democratic Socialists of America ahead of the 2025 New York City Mayoral Election. New York’s independent expenditure disclosure law, which requires entities spending money on political elections to register and disclose information about their expenditures, was interpreted by state regulators to cover these advertisements, as the only citywide candidate affiliated with the DSA was running for mayor. The organization feared enforcement of the law against its ads and sought judicial relief. After filing its complaint in the United States District Court for the Southern District of New York, the organization moved for a preliminary injunction to prevent the State from enforcing the disclosure law against its advertisements before the upcoming election. The district court denied this emergency motion. The organization then appealed the denial to the United States Court of Appeals for the Second Circuit while the underlying challenge to the law was stayed in the district court at the organization’s request. The United States Court of Appeals for the Second Circuit dismissed the appeal as moot. The court explained that the motion for preliminary injunction sought relief only for an injury related to the 2025 mayoral election, which had already occurred, making it impossible for the appellate court to grant effectual relief. The court further held that the “capable of repetition, yet evading review” exception to mootness did not apply because the underlying action remained pending in the district court, and thus could still be litigated and reviewed in the future. The appeal was therefore dismissed for lack of a live controversy, with instructions that any future appeals concerning preliminary injunctions in this matter would be heard by the same panel. View "Am. Future Fund, Inc. v. N.Y. Bd. of Elections" on Justia Law

State v. Defoe

2026-11-06T07:38:20-08:00

In December 2024, Colton Kenneth Defoe was stopped by a McKenzie County Sheriff’s officer due to an outstanding warrant. The officer cleared Defoe’s vehicle of other passengers and used a K-9 unit to inspect the car, which resulted in an alert for narcotics. A search revealed a plastic baggie and a bindle, both containing methamphetamine residue, and a plastic tube with burn marks. Although Defoe and his passengers denied possession, lab tests confirmed methamphetamine in both the baggie and the bindle, while the tube yielded inconclusive results. No gabapentin was detected, contrary to initial suspicions. Defoe was charged in the District Court of McKenzie County, Northwest Judicial District, with possession of methamphetamine, possession of drug paraphernalia, and driving under suspension. Two additional charges were dismissed before trial. The jury found Defoe guilty on all counts, and the district court entered judgment. Defoe appealed, arguing improper jury instructions deprived him of due process and that there was insufficient evidence to support his convictions. He did not object to the jury instructions at trial but argued the issue in his Rule 29 motion for acquittal, which was denied. The Supreme Court of North Dakota reviewed the appeal. It held that Defoe had not preserved any challenge to the jury instructions for appellate review, as he failed to object distinctly and specifically as required under N.D.R.Crim.P. 30(c). The Court also found no plain error in the instructions, concluding they accurately stated the law and did not mislead the jury. Additionally, the Court determined that substantial evidence supported the jury’s verdicts. The criminal judgment was affirmed. View "State v. Defoe" on Justia Law

State v. Finley

2026-11-06T07:33:36-08:00

On the afternoon of July 31, 2022, a shooting occurred at a BP gas station in Overland Park, Kansas. Surveillance video captured Zarrell Semaj Finley retrieving an AK-47 from a backpack and shooting Shaquille Jackson multiple times following a brief physical struggle over the backpack. Finley then fled the scene with others, leaving Jackson, who later died from his wounds. During a subsequent police interview, Finley admitted to drinking heavily before the incident and claimed he acted in self-defense, believing Jackson was armed and posed a threat. Finley's sister testified that the firearm belonged to her, and Finley had been drinking on the day of the shooting. In Johnson District Court, Finley was charged with first-degree premeditated murder and criminal possession of a weapon by a convicted felon, to which he pleaded guilty to the weapons charge. The murder charge proceeded to trial, where the jury found Finley guilty, and the court imposed a life sentence. At trial, the court denied Finley’s requests for jury instructions on voluntary intoxication and heat of passion voluntary manslaughter. The court also declined to instruct on voluntary manslaughter based on defense of an occupied vehicle, but did instruct on imperfect self-defense voluntary manslaughter and other lesser included offenses. The Supreme Court of the State of Kansas reviewed Finley’s direct appeal. The court held that the district court properly refused Finley’s requested jury instructions because the evidence did not support a finding of impairment sufficient for voluntary intoxication, nor was there legally sufficient provocation for heat of passion manslaughter or factual basis for a defense of an occupied vehicle instruction. The court found that any prosecutorial errors during closing argument were harmless beyond a reasonable doubt. Finally, it concluded that sufficient evidence supported the jury’s finding of premeditation. The court affirmed Finley’s conviction. View "State v. Finley " on Justia Law

Archambault v. State

2026-11-06T07:12:55-08:00

The petitioner was convicted of continuous sexual abuse of a child, involving at least twenty acts against a minor between November 2019 and August 2020. Sentenced in March 2022, he appealed his conviction, which was affirmed by the North Dakota Supreme Court in November 2022. In March 2023, he filed his first postconviction relief petition, which was denied by the District Court of Ward County and affirmed on appeal in March 2024. On April 29, 2025, the petitioner filed a second postconviction relief petition, alleging constitutional violations based on alleged withholding of evidence and false testimony by the State, citing Glossip v. Oklahoma, 604 U.S. 226 (2025). After the State answered the petition—raising the statute of limitations, res judicata, and misuse of process as affirmative defenses—it moved for summary disposition on the basis of misuse of process but omitted the statute of limitations in its motion. The district court, however, ordered briefing on the statute of limitations and the impact of Glossip. Neither party scheduled a hearing, and the court ultimately granted summary disposition and dismissed the petition as untimely. The Supreme Court of North Dakota reviewed the appeal. It held that the State preserved the statute of limitations defense by raising it in its answer, and the district court could properly consider that defense even though it was not included in the State’s summary disposition motion. The Court determined that the petitioner forfeited his hearing request by failing to schedule it, and that the district court provided adequate notice and opportunity to respond regarding the statute of limitations issue. The Court found the petitioner failed to show that his claim fell within an exception to the statute of limitations for a new interpretation of law. The Supreme Court of North Dakota affirmed the district court’s dismissal of the petition. View "Archambault v. State" on Justia Law

Guzman v. State of Florida

2026-11-05T08:08:44-08:00

The case concerns James Guzman, who was convicted of the murder of David Colvin. Guzman has been tried three times for Colvin's murder, with the most recent conviction occurring in 2016. Following this conviction, Guzman has undergone four penalty-phase proceedings, each resulting in a death sentence. The current appeal focuses on the fourth penalty phase and the resulting death sentence, which followed a unanimous jury recommendation. During that penalty phase, Guzman moved to disqualify the judge based on her prior employment at the law firm (Rice and Rose) that represented him in his first appeal, though she did not work on his case or any criminal matters at the firm. Previously, the Circuit Court for the Seventh Judicial Circuit conducted the penalty phase, presided over jury selection, and ruled on Guzman's motion to disqualify the judge, finding it legally insufficient. The jury found four aggravating factors and recommended death, and the judge imposed the sentence after considering both aggravating and mitigating circumstances. Guzman appealed, raising issues regarding the judge’s disqualification, the jury instructions on victim impact testimony, and the constitutionality of the death penalty. The Supreme Court of Florida reviewed the case and affirmed the lower court’s decisions. The Court held that Guzman’s motion to disqualify the judge was legally insufficient, as the allegations did not establish an objectively reasonable fear of bias or prejudice. The Court also found Guzman’s challenge to the jury instructions regarding victim impact testimony was unpreserved and, even if preserved, meritless, since the instructions given were adequate. Finally, the Court rejected Guzman’s argument that the death penalty is inherently cruel and unusual, citing longstanding precedent. The disposition by the Supreme Court of Florida was to affirm Guzman’s sentence of death. View "Guzman v. State of Florida" on Justia Law

WRIGHT v. STATE OF ARKANSAS

2026-11-05T08:01:39-08:00

A masked individual entered Plato’s Closet in Jonesboro, Arkansas, threatened employees with what appeared to be a handgun, and stole $598 before fleeing in a gray Mercury sedan. Shortly after, law enforcement stopped Pierre Wright, who was driving a vehicle matching the description. Officers found clothing matching the suspect’s, an imitation firearm, and a Plato’s Closet bag containing $598 in the car. Additional evidence, including GPS and cell-phone data, further linked Wright to the crime. The State charged Wright with aggravated robbery and theft of property and sought to classify him as a habitual offender based on prior Tennessee convictions. At trial in the Craighead County Circuit Court, Wright moved for directed verdicts, arguing insufficient evidence of his identity as the robber. The circuit court denied these motions, and the jury found Wright guilty. During sentencing, the State introduced certified records of Wright’s prior Tennessee convictions—one for aggravated robbery and two for aggravated burglary—and argued that the Tennessee aggravated-burglary offenses were comparable to Arkansas’s aggravated residential burglary, making Wright eligible for a mandatory life sentence under Arkansas Code Annotated section 5-4-501(d). The circuit court agreed and imposed the life sentence. On appeal to the Supreme Court of Arkansas, Wright raised three arguments: the sufficiency of the evidence, the comparability of his Tennessee convictions to Arkansas offenses for sentencing enhancement, and the propriety of his mandatory life sentence. The Supreme Court of Arkansas held that the evidence was sufficient to support the convictions, that the circuit court did not abuse its discretion in finding the Tennessee aggravated-burglary convictions comparable to the Arkansas statute, and that the mandatory life sentence was proper. The Court affirmed the judgment and sentence. View "WRIGHT v. STATE OF ARKANSAS" on Justia Law

MCCOY v. STATE OF ARKANSAS

2026-11-05T08:01:38-08:00

On October 18, 2022, a fatal shooting occurred in the parking lot of The Ridge apartment complex in Little Rock, Arkansas. The evidence at trial established that Ferrad McCoy traveled with Mason Abraham from Memphis to Little Rock, where Abraham, as the passenger in a white Infiniti, shot and killed Broderick Blueford. Law enforcement later pursued the same vehicle on Interstate 40, resulting in a high-speed chase and crash. Both McCoy and Abraham fled on foot but were apprehended nearby. Physical evidence, including firearms, shell casings, a cell phone, and a hoodie matching McCoy’s attire, as well as video footage and cell phone records, linked both men to the crime and location. The Pulaski County Circuit Court presided over a jury trial in which McCoy was convicted of capital murder, first-degree unlawful discharge of a firearm from a vehicle, and firearm enhancements. He received life imprisonment plus additional years for the enhancements. McCoy challenged the sufficiency of the evidence and objected to the admission of several items, including photographs, firearms, video footage, and a “BOLO” flyer. He also raised issues regarding jury instructions and the Confrontation Clause. The Supreme Court of Arkansas reviewed the case, applying the substantial evidence standard and broad discretion for evidentiary rulings. The Court held that there was substantial evidence to support the convictions, properly admitted the contested evidence, and found no reversible error in the circuit court’s rulings. The Court also determined that McCoy’s jury instruction and Confrontation Clause arguments were either waived or without merit. The convictions and sentences imposed by the Pulaski County Circuit Court were affirmed. View "MCCOY v. STATE OF ARKANSAS" on Justia Law

State v. Notafraid

2026-11-04T15:36:52-08:00

The defendant was charged with deliberate homicide following an arrest in March 2021. Initially released on bond, he was later taken into custody after missing a required hearing. At a pretrial release revocation hearing, the State was represented by then-Deputy County Attorney Brett Linneweber. Over time, the defendant changed attorneys multiple times, displaying distrust toward counsel and initially refusing to accept any plea agreement. Ultimately, after negotiations, he agreed to plead guilty to mitigated deliberate homicide in exchange for a binding sentencing recommendation and dismissal of other charges. Before the plea hearing, Judge Linneweber, who had since been appointed to the bench, was assigned to the case. Although he had previously appeared for the State in a related proceeding, he determined his involvement was minimal and did not recuse himself, accepting the defendant’s guilty plea. After his plea, the defendant filed a motion for Judge Linneweber’s disqualification, which was referred to the Montana Supreme Court. Judge Linneweber then recused himself, and the motion was denied as moot. The defendant later sought to withdraw his guilty plea, citing involuntariness, ineffective assistance of counsel, newly discovered evidence, and pressure to accept the plea, but did not explicitly raise the disqualification issue as a basis for withdrawal. The Thirteenth Judicial District Court denied the motion, finding no evidence that the plea was not knowing or voluntary and that the new evidence could have been discovered earlier. The Supreme Court of the State of Montana reviewed whether the failure to recuse constituted good cause for plea withdrawal. The Court held that Judge Linneweber’s prior involvement as counsel required disqualification by statute and rule. The failure to recuse was a due process violation and constituted good cause to withdraw the guilty plea. The Court reversed the District Court’s order and remanded for further proceedings. View "State v. Notafraid" on Justia Law

State ex rel. Trustees of the West Virginia Conference of the United Methodist Church v. Wills

2026-11-04T12:15:02-08:00

A group of local United Methodist churches, through their trustees, sought to disaffiliate from the United Methodist Church while retaining ownership of their church property. This dispute arose amid a broader doctrinal disagreement within the denomination, particularly regarding the ordination of homosexual clergy and performance of same-sex weddings. The Conference, representing the denomination’s regional authority, asserted that church property was held in trust for the benefit of the entire denomination and could not be retained by a local church upon disaffiliation except as authorized by church law. The local churches alleged that the Conference engaged in fraudulent and collusive conduct, including misrepresentations about the procedures and timing for lawful disaffiliation, which caused them to miss the window for disaffiliation with property under denominational rules. The Circuit Court of Mercer County initially dismissed the complaint, holding that it lacked subject matter jurisdiction under the ecclesiastical abstention doctrine since the dispute required interpretation of church doctrine and governance—a matter reserved for the church’s highest tribunals. The court found that the allegations of fraud and collusion did not pertain to the procurement of a final ecclesiastical adjudication. However, following a Rule 59(e) motion by the local churches, a different judge vacated the prior dismissal, determining that the allegations of fraud and collusion raised factual questions for a jury and reopened the case. The Supreme Court of Appeals of West Virginia reviewed the matter on a petition for a writ of prohibition. The court held that constitutional limitations under the First Amendment and the West Virginia Constitution prevented civil courts from adjudicating disputes involving church doctrine, discipline, or governance. The court further clarified that the fraud or collusion exception only applies if such conduct procured a final ecclesiastical adjudication, which was not alleged here. The writ of prohibition was granted, barring enforcement of the order reopening the case, and reaffirming the circuit court’s lack of jurisdiction. View "State ex rel. Trustees of the West Virginia Conference of the United Methodist Church v. Wills" on Justia Law

State v. Crawford

2026-11-04T12:14:51-08:00

A man and a female companion were suspected of shoplifting at a Walmart in White Hall, West Virginia. After the store employee alerted law enforcement, officers stopped and searched the vehicle the pair had used. The man, sitting in the passenger seat, was arrested, and officers found a black fanny pack under his seat, which contained a loaded firearm, baggies of white powder suspected to be cocaine, and pills believed to be oxycontin. He was indicted on six counts, including possession with intent to deliver cocaine and fentanyl, use or presentation of a firearm during the commission of a felony, possession of a firearm by a prohibited person, and prohibited person carrying a concealed firearm. The Circuit Court of Marion County presided over a one-day jury trial, after which the jury found the man guilty of five counts and not guilty of conspiracy. He filed a post-trial motion for judgment of acquittal or, alternatively, a new trial, arguing that the evidence was insufficient for the firearm charge and that his Sixth Amendment right to confront the forensic analyst was violated when the analyst who performed drug testing was not called to testify. The circuit court denied the motion, ruling that the sufficiency of evidence was a question for the jury and that the testimony of a substitute expert satisfied the confrontation requirement. The Supreme Court of Appeals of West Virginia reviewed the case and applied a de novo standard to the sufficiency and confrontation issues. The court held that the evidence was insufficient to sustain a conviction for use or presentation of a firearm during a felony because there was no proof the defendant actively employed the firearm. The court further held that admitting the forensic laboratory report through a surrogate expert violated the Confrontation Clause. Accordingly, the court reversed the firearm conviction, vacated the drug convictions, and remanded for a new trial on the drug charges. View "State v. Crawford" on Justia Law

Ortiz-Resto v. Rivera-Schatz

2026-11-03T14:30:03-08:00

Three former employees of the Senate of the Commonwealth of Puerto Rico alleged they were terminated from their positions—Protocol Officer and Liaison Technician—because of their political affiliations, in violation of their First Amendment rights. The suit was brought against Senate officials in their personal capacities under 42 U.S.C. § 1983, seeking damages for alleged unconstitutional patronage dismissals. The U.S. District Court for the District of Puerto Rico initially heard the case, which involved numerous plaintiffs and claims, including due process, equal protection, and Puerto Rico law claims. Many claims were dismissed at earlier procedural stages. The claims relevant to this appeal survived summary judgment and concerned only the First Amendment-based damages actions brought by the three former employees. The District Court denied the defendants’ motion for summary judgment, which was based on qualified immunity, finding there were genuine disputes of material fact regarding the plaintiffs’ job duties and whether defendants had considered the nature of those duties before termination. The United States Court of Appeals for the First Circuit reviewed the interlocutory appeal, which focused on the denial of qualified immunity. The First Circuit affirmed the District Court’s order. The appellate court held that the District Court erred in considering whether the officials had subjectively inquired into the plaintiffs’ job duties, as qualified immunity is an objective standard. However, the First Circuit found no error in the District Court’s other reasoning, ruling that unresolved factual disputes about the nature of the plaintiffs’ job responsibilities precluded summary judgment on qualified immunity. The court also determined that claims against the officials in their personal capacities were not discharged by the Commonwealth’s bankruptcy proceedings under PROMESA. Thus, the District Court’s denial of summary judgment was affirmed. View "Ortiz-Resto v. Rivera-Schatz" on Justia Law

People v. Savoy

2026-11-03T14:01:07-08:00

The defendant was convicted in 2011 of first degree murder, multiple sexual offenses, and related crimes stemming from incidents in July 2008. A jury found him guilty and determined that he personally and intentionally discharged a firearm causing great bodily injury or death. Additional findings included three prior prison terms. He was originally sentenced to 78 years to life in prison. Following a change in the law eliminating one-year sentence enhancements for prior prison terms, the defendant petitioned for resentencing. The trial court resentenced him to 77 years to life, removing the prior prison term enhancements but retaining all other aspects of the sentence, including the gun enhancement. After the resentencing, the defendant argued that the trial court should have dismissed the gun enhancement under Penal Code section 1385(c), specifically referencing the Racial Justice Act (RJA). He contended that applying the enhancement would result in a discriminatory racial impact. In the Alameda County Superior Court, the trial judge found that dismissing the enhancement would endanger public safety and that none of the mitigating factors, including those based on racial bias, were established. The defendant’s evidence of racial bias was based on a statistical report and a claim of bias by the original sentencing judge, but the trial court found these claims insufficient under the RJA. On appeal, the California Court of Appeal, First Appellate District, Division Three, held that the defendant failed to present evidence meeting the RJA’s requirements. Specifically, he did not show that he received a longer sentence than similarly situated individuals of other races in the same county, nor did he provide comparator cases or adequate statistical evidence. The appellate court affirmed that to trigger section 1385(c)(2)(A), a defendant must satisfy the RJA’s standard, which the defendant did not. Accordingly, the judgment was affirmed. View "People v. Savoy" on Justia Law

TRAMMELL v. THE STATE

2026-11-03T05:04:02-08:00

The defendant was indicted in Floyd County, Georgia, and convicted by a jury of possession of less than one ounce of marijuana and possession of a firearm by a convicted felon. His firearm conviction was based on three prior non-violent felonies. Before trial, he filed a general demurrer, arguing that the statute prohibiting felons from possessing firearms was unconstitutional as applied to him because it imposed a permanent ban on non-violent offenders. He was sentenced to twelve months for the marijuana conviction and ten years for the firearm conviction, with four years to be served in prison. After briefs and a hearing, the Superior Court of Floyd County denied his demurrer, citing precedent upholding the constitutionality of the statute and reasoning that felons are presumptively excluded from firearm possession. The trial court reaffirmed this position when denying his motion for new trial. On appeal to the Supreme Court of Georgia, the defendant again argued that the statute, as applied to non-violent felons, violated the Second Amendment. However, the Attorney General, participating as amicus, raised a procedural issue: the defendant had not served the Attorney General with notice of his constitutional challenge, as required by OCGA § 9-4-7(c). The Supreme Court of Georgia determined that the notice requirement applies not only to civil actions but also to criminal prosecutions challenging the constitutionality of a statute. Because the defendant failed to serve the Attorney General, the trial court lacked subject-matter jurisdiction to decide the constitutional issue. The Supreme Court of Georgia vacated the portion of the trial court’s order addressing the constitutional challenge and remanded the case for compliance with the statutory notice requirement, without reaching the merits of the Second Amendment claim. View "TRAMMELL v. THE STATE" on Justia Law

Metropolitan Government of Nashville and Davidson County v. Lee

2026-11-02T12:42:33-08:00

In 2023, the Tennessee General Assembly enacted a statute imposing a cap of twenty voting members on metropolitan councils, affecting the Metropolitan Government of Nashville and Davidson County, which had a forty-member council. Metro Nashville and several individual plaintiffs challenged the statute, arguing it violated the Local Legislation Clause and the Exemption Clause of the Tennessee Constitution. They sought declaratory and injunctive relief to prevent implementation of the law. The Chancery Court for Davidson County, sitting as a three-judge panel, held that the cap violated both constitutional provisions and issued a permanent injunction against enforcement. The panel found some claims moot due to expired compliance deadlines but concluded that the main cap provision remained justiciable. The Court of Appeals reversed, holding that the cap did not violate either clause and that the claims were not moot, except as to certain implementation provisions. After granting permission to appeal, the Supreme Court of Tennessee reviewed the case. During the proceedings, the General Assembly amended the statute, removing the implementation provisions and the language linking the cap to those provisions. The Supreme Court determined that these amendments rendered the Local Legislation Clause claim moot, as the alleged defect no longer existed. The Court vacated the Court of Appeals’ judgment on this issue and instructed the trial court to dismiss the claim. The Court further held that the Exemption Clause claim remained justiciable but, on the merits, concluded that the Exemption Clause only exempts consolidated governments from constitutional requirements regarding legislative bodies, not from statutory requirements imposed by the legislature. Therefore, the twenty-member cap does not violate the Exemption Clause. The Supreme Court of Tennessee affirmed the Court of Appeals’ judgment on this issue and remanded the case for further proceedings consistent with its opinion. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law

Metropolitan Government of Nashville and Davidson County v. Lee

2026-11-02T12:42:20-08:00

A 2023 Tennessee law amended the structure and appointment process for the board of commissioners of the Metropolitan Nashville Airport Authority, reducing its board size and transferring most appointment powers to state officials. The changes applied only to the Nashville authority and not to any other airport authority in the state. The Metropolitan Government of Nashville and Davidson County filed suit, alleging that the new law violated specific provisions of the Tennessee Constitution, including the Local Legislation Clause and Anti-Ripper Clause. The Chancery Court for Davidson County, sitting as a three-judge panel, found that the law violated all three constitutional provisions alleged and enjoined its enforcement. The state defendants appealed and the Tennessee Court of Appeals affirmed the trial court in part, holding that the law violated the Local Legislation Clause, but reversed on the Law of the Land Clause. The Anti-Ripper Clause claim was not addressed by the appellate court. The state sought further review in the Supreme Court of Tennessee. While the case was pending before the Supreme Court of Tennessee, the General Assembly repealed and replaced the challenged provisions with new legislation that applied more broadly to multiple airport authorities. The Supreme Court of Tennessee held that these legislative changes rendered the case moot because the specific statutory provisions challenged were no longer in effect and could not reasonably be expected to recur. It found no basis to apply the voluntary cessation exception to mootness, as there was no evidence the legislature would reenact the specific challenged provisions. The Supreme Court vacated the lower courts’ judgments and remanded the case to the trial court with instructions to dismiss it as moot. View "Metropolitan Government of Nashville and Davidson County v. Lee" on Justia Law

Mostafa v. Blanche

2026-11-02T09:30:57-08:00

A man serving a life sentence for terrorism-related convictions at a federal prison in Colorado, who is severely disabled with both arms amputated above the elbow and vision loss in one eye, filed suit against several federal officials. He alleged violations of his federal constitutional and statutory rights stemming from his conditions of confinement and medical care while incarcerated. His claims included inadequate dental and medical care, denial of a medical diet, lack of proper prosthetics, and insufficient accommodation for his disabilities. The United States District Court for the District of Colorado dismissed most claims on the defendants’ motions to dismiss and for summary judgment. Some claims were dismissed as moot or for failure to exhaust administrative remedies, while others, including his Eighth Amendment deliberate indifference claim, were dismissed for failure to state a claim under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. The district court also found his Administrative Procedure Act (APA) claim challenging his placement at the prison was time-barred. The plaintiff voluntarily dismissed his remaining claims with prejudice and then appealed. The United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment. The appellate court held that the plaintiff could not pursue his Eighth Amendment deliberate indifference claim under the APA because he failed to allege a final agency action and sued individual officers rather than the agency or officials in their official capacities. The court also held that his Bivens claim for deliberate indifference arose in a new context and was foreclosed due to the existence of the Bureau of Prisons’ administrative remedies. The appellate court further found no abuse of discretion in denying leave to amend the complaint and ruled that the plaintiff had waived his challenge to deposition transcript fees by failing to object before the magistrate judge. View "Mostafa v. Blanche" on Justia Law

JOHNSON V. ADGAR

2026-11-02T09:30:32-08:00

During a protest at San Jose City Hall, the plaintiff attended as a peaceful participant. At one point in the evening, after some protestors threw bottles and objects at the police, an officer equipped with a 40mm projectile impact weapon responded by firing into the crowd. The plaintiff, who did not throw anything or engage with the police, was struck behind the knee by a foam baton round and subsequently developed a pulmonary embolism as a result of his injury. After these events, the plaintiff filed suit in the United States District Court for the Northern District of California against the officer and the City of San Jose, alleging violations of his constitutional rights under 42 U.S.C. § 1983 and California’s Bane Act, as well as common law claims. The case proceeded to trial, where the plaintiff argued that the officer fired indiscriminately into the crowd rather than targeting a specific threat. The jury found in favor of the plaintiff on all claims against the officer, awarding damages, and specifically found that the officer fired indiscriminately. The district court denied the officer’s post-verdict motion for judgment as a matter of law on the Fourth Amendment and Bane Act claims. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court concluded that the officer’s actions constituted a seizure and that the use of force was excessive, thus violating the plaintiff’s Fourth Amendment rights. However, the court held that the law was not clearly established for purposes of qualified immunity because prior precedent, particularly Nelson v. City of Davis, was materially distinguishable from the circumstances present here. As a result, the Ninth Circuit reversed the district court’s denial of qualified immunity on the Fourth Amendment claim, vacated the award of attorneys’ fees, and remanded for recalculation pending resolution of the state law claim, which was certified to the California Supreme Court. View "JOHNSON V. ADGAR" on Justia Law

Anderson Federation of Teachers v. Rokita

2026-11-02T09:00:15-08:00

In this case, Indiana enacted legislation in 2021 that imposed new requirements on public school teachers who wished to have union dues automatically deducted from their paychecks. These requirements included submitting a written authorization containing a specific statement regarding their First Amendment rights, annual renewal of the authorization, confirmation via official work email, and annual notice of their right to resign from the union. These procedures applied only to teachers and not to other public employees in Indiana. Previously, the United States District Court for the Southern District of Indiana reviewed the case after teachers’ unions and individual members challenged the law, arguing it violated their First Amendment rights to free speech and association. The district court initially found that the mandated statement on the authorization form constituted compelled speech and issued a preliminary injunction. After Indiana amended the statute in response, the district court concluded that the revised law no longer violated the Free Speech Clause, but still found that the additional requirements on teachers constituted viewpoint discrimination against their freedom of association. The court permanently enjoined enforcement of the provisions and the State appealed. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s judgment. The Seventh Circuit held that the authorization form’s required statement was government speech, not compelled private speech, and did not violate the Free Speech Clause. However, the court agreed with the district court that the additional requirements imposed only on teachers and their unions amounted to unconstitutional viewpoint discrimination under the First Amendment’s Freedom of Association protections. The court applied strict scrutiny and found Indiana’s justifications insufficient. As a result, the Seventh Circuit affirmed the district court’s judgment permanently enjoining enforcement of the challenged provisions. View "Anderson Federation of Teachers v. Rokita" on Justia Law

State v. Neal

2026-11-01T10:52:53-08:00

A woman traveling through Raton, New Mexico, was approached twice by the defendant, who eventually led her into an abandoned motel. There, the defendant forcibly pulled her through a window, assaulted, strangled, and sexually assaulted her, causing physical and sexual injuries. The key facts are that the defendant's actions resulted in serious harm to the victim, including both physical and sexual violence, and these actions were largely undisputed at trial. The defendant was charged in district court with first-degree kidnapping, second-degree criminal sexual penetration (CSP II), and aggravated battery. The jury convicted him on all three counts, and he received an aggregate sentence of approximately thirty years. On appeal, the New Mexico Court of Appeals vacated both the CSP II and aggravated battery convictions on double jeopardy grounds, applying a novel analytical approach that compared the lesser offenses against each other, rather than against the most serious conviction, which was first-degree kidnapping. The State challenged this approach, arguing that the proper analysis should compare each lesser conviction with the most severe conviction that remained. The Supreme Court of the State of New Mexico held that double jeopardy barred the defendant’s conviction for CSP II because the State relied on that single sexual offense both to support the first-degree kidnapping charge and as an independent offense, without introducing another distinct sexual offense. Accordingly, the CSP II conviction was vacated. However, the Court found that aggravated battery and kidnapping were supported by sufficiently distinct factual bases, allowing both convictions to stand. The Court reversed the Court of Appeals’ decision vacating aggravated battery and affirmed its decision vacating CSP II, remanding for further proceedings. The Court also declined to change its established double jeopardy analysis. View "State v. Neal" on Justia Law

State v. Villalobos

2026-11-01T10:52:52-08:00

A fifteen-year-old defendant with an intellectual disability was arrested and charged with first-degree murder and tampering with evidence after the death of a younger child. Unable to post a high cash bond, the defendant remained incarcerated pretrial. At arraignment, defense counsel raised concerns about the defendant’s competency to stand trial. Over the next three years and three months, the case was repeatedly delayed due to defense counsel’s failure to schedule and facilitate a competency evaluation. The defendant was ultimately found competent to stand trial after several years in custody. Additional delays occurred, including a fourteen-month period during which the State pursued an interlocutory appeal. The first trial ended in a mistrial, while the second resulted in convictions for second-degree murder and tampering with evidence, leading to an adult prison sentence. After conviction, the defendant argued that his constitutional right to a speedy trial had been violated. The District Court for Santa Fe County rejected this claim, attributing much of the delay to defense counsel. The New Mexico Court of Appeals affirmed, holding that the delays caused by defense counsel’s neglect should be attributed to the defendant and that the State’s conduct did not warrant relief. The Supreme Court of the State of New Mexico reversed. Applying the Barker v. Wingo factors, the court held that the nearly six-year delay was extraordinary and presumptively prejudicial. It concluded that because the delays were caused by defense counsel’s neglect, and the defendant’s intellectual disability prevented him from meaningfully participating or acquiescing, the delays could not be weighed against the defendant. The State also failed to monitor and move the case forward. The court held that the defendant’s speedy trial rights were violated, vacated the convictions, and ordered dismissal of the indictment. View "State v. Villalobos" on Justia Law

Cozy Inn, Incorporated v. City of Salina, Kansas

2026-10-30T08:01:11-08:00

The owner of a long-standing hamburger restaurant in Salina, Kansas hired an artist to paint a large, UFO-themed display on the exterior wall of the business. The display included playful imagery related to the restaurant and a slogan. Shortly after painting began, city officials determined the display was a "sign" under Salina's sign code, not an unregulated mural, because it referenced the restaurant's products. They concluded the display was too large to qualify for a permit, informed the owner to pause work, and instructed him to submit a permit application. The city later placed the application on indefinite hold, citing a review of the sign regulations. The owner disputed consenting to this hold and subsequently filed suit challenging the sign code and the city's enforcement. The United States District Court for the District of Kansas granted summary judgment to the plaintiffs on their First Amendment claims. The court found Salina's sign code failed intermediate scrutiny because there was insufficient evidence connecting the city’s distinction between signs and murals to its stated interests of safety, aesthetics, and property values. Declaratory relief was granted, but a permanent injunction was denied. Salina appealed. Reviewing the case, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s judgment. The appellate court held that Salina did not produce evidence demonstrating that regulated signs—as defined by the city—posed greater risks to its interests than unregulated murals. Therefore, the sign code failed intermediate scrutiny. The court further held that placing the permit application on indefinite hold constituted an impermissible prior restraint on speech, as the city did not show the applicant consented to the hold or that it complied with required time limits. The district court’s judgment was affirmed. View "Cozy Inn, Incorporated v. City of Salina, Kansas" on Justia Law

United States v. Laykovich

2026-10-29T11:30:10-08:00

The defendant was stopped by police in Kentucky while driving erratically. He was found wearing body armor and carrying eight firearms, knives, ammunition, drugs, and a gasoline can. He claimed he was headed to Fort Knox to discuss a security clearance. Investigation revealed that he was prohibited from possessing firearms due to a prior Missouri court adjudication of mental illness, which had resulted from an incident in St. Louis where he exhibited erratic behavior and his girlfriend reported suicidal tendencies. The Missouri court had committed him for treatment and barred him from firearm possession, and he never petitioned to restore his rights. The United States District Court for the Eastern District of Kentucky reviewed the case after Laykovich was indicted for violating 18 U.S.C. § 922(g)(4) (prohibiting firearm possession by persons adjudicated as mentally defective). Laykovich moved to dismiss the charge on Second Amendment grounds, but the district court denied the motion, reasoning that the government could disarm individuals whose mental illness posed a risk of harm. Laykovich then entered a plea agreement, reserving his right to appeal both the constitutional issue and sentencing. At sentencing, the district court found, based on circumstantial evidence, that Laykovich had induced his girlfriend to act as a straw purchaser for some firearms, and applied a sentencing enhancement. The United States Court of Appeals for the Sixth Circuit reviewed the appeal de novo. It held that § 922(g)(4) is constitutional as applied to persons adjudicated as mentally defective and dangerous, because it is “relevantly similar” to longstanding laws allowing civil detention of dangerous mentally ill persons and serves the same public safety purpose. The court affirmed the district court’s application of the sentencing enhancement and its within-guidelines sentence, finding no procedural or substantive error. The judgment was affirmed. View "United States v. Laykovich" on Justia Law

State v. Pinkerman

2026-10-29T11:14:40-08:00

After the petitioner’s adult son was terminated from a local fire department, shots were fired at the fire station, leading to an investigation by the Cabell County Sheriff's Department. Officers suspected the son due to recent statements and visited the petitioner’s property, where the son exited holding a 9mm pistol. The officers handled and photographed the firearm for safety reasons. Later, a mistaken report led officers to believe the pistol was stolen, prompting a search warrant and an arrest warrant for the son. When officers returned to execute the warrants, a confrontation ensued, resulting in injuries to officers and the petitioner, and the son’s death. It was later determined the firearm was lawfully owned by the petitioner. The Cabell County grand jury indicted the petitioner on several charges, including attempted murder and obstructing an officer. During the grand jury proceedings, officers referred to the 9mm Beretta as “stolen,” but did not disclose its lawful ownership, which had been discovered weeks after the incident. The petitioner moved to suppress evidence relating to the firearm, to dismiss the indictment due to alleged misleading grand jury testimony, and to strike two jurors for cause. The Circuit Court of Cabell County denied these motions, finding that any mistakes regarding the firearm’s status were innocent, that no prima facie showing of willful fraud by officers was made, and that the challenged jurors affirmed their impartiality. The Supreme Court of Appeals of West Virginia reviewed the appeal and affirmed the circuit court’s order. The Court held that any error regarding the search and seizure of the firearm was harmless beyond a reasonable doubt, as the conviction for obstructing an officer was based on the petitioner’s own conduct. The Court also concluded there was no basis to go behind the indictment, as no willful fraud was shown, and found no prejudice in jury selection since the petitioner removed the challenged jurors using peremptory strikes. View "State v. Pinkerman" on Justia Law

CALIFORNIA CHAMBER OF COMMERCE V. BONTA

2026-10-29T08:30:53-08:00

California enacted a law (Senate Bill 399) that prohibits employers from subjecting, or threatening to subject, employees to adverse employment actions if those employees decline to attend employer-sponsored meetings or communications meant to express the employer’s opinion on political or religious matters. Three industry groups representing California employers sued the state officials responsible for enforcing the law, arguing that it violates their First Amendment rights and is preempted by federal labor law. The Western Growers Association, one of the groups, asserted that its members regularly hold “all-hands” meetings to discuss political issues, and that SB 399 would chill this practice due to the threat of enforcement. The United States District Court for the Eastern District of California found that the industry groups had standing and granted a preliminary injunction, preventing California from enforcing SB 399. The district court concluded that the groups were likely to succeed both on their First Amendment claim and the preemption argument. California appealed, contending that the groups lacked standing for a pre-enforcement challenge and were unlikely to prevail on the merits. The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the Western Growers Association had associational standing because its members intended to engage in conduct arguably proscribed by SB 399, and faced a credible threat of enforcement. The court determined that SB 399 is subject to First Amendment scrutiny because it targets expressive conduct based on content and speaker. Applying strict scrutiny, the court concluded that California had not identified a compelling interest sufficient to justify the law’s content-based restrictions. The Ninth Circuit therefore affirmed the district court’s preliminary injunction, holding that the industry groups are likely to succeed on their First Amendment claim. The court did not address the preemption claim. View "CALIFORNIA CHAMBER OF COMMERCE V. BONTA" on Justia Law

UBER TECHNOLOGIES, INC. V. CITY OF SEATTLE

2026-10-29T08:30:52-08:00

Two companies that operate platforms connecting app-based workers with customers, primarily for delivery services, challenged a Seattle city ordinance that restricts “unwarranted deactivations” of worker accounts. The ordinance requires network companies to provide written notice to workers about their deactivation policies and mandates that these policies be “reasonably related” to safe and efficient operations. The companies argued that these requirements violate their First Amendment rights by compelling speech and that the ordinance is unconstitutionally vague. After the ordinance was enacted, the companies sought a temporary restraining order and preliminary injunction in the United States District Court for the Western District of Washington. The district court concluded that the ordinance primarily regulated conduct and any impact on speech was incidental. It also held that the term “reasonable” was not unconstitutionally vague and that the companies had not demonstrated a likelihood of success on the merits, irreparable harm, or a balance of equities in their favor. Accordingly, the district court denied the request for injunctive relief. The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of a preliminary injunction. Assuming, without deciding, that the ordinance regulates speech, the court determined that any regulated speech was commercial in nature. Applying the standard from Zauderer v. Office of Disciplinary Counsel of the Supreme Court of Ohio, the court found the ordinance’s disclosure and policy requirements to be reasonably related to substantial governmental interests and not unduly burdensome or controversial. The court also rejected the companies’ vagueness challenge, holding the ordinance provided adequate notice of what conduct was required. Because the plaintiffs were unlikely to succeed on the merits, the court affirmed the district court’s denial of a preliminary injunction. View "UBER TECHNOLOGIES, INC. V. CITY OF SEATTLE" on Justia Law

HAGEN VS. HARRISON

2026-10-29T07:18:33-08:00

An architect licensed in California, through his firm, provided architectural services and held himself out as an architect in Nevada without obtaining a Nevada license. The Nevada State Board of Architecture, Interior Design and Residential Design regulates such activities in Nevada. The Board issued charges against the architect for violating statutes prohibiting unlicensed practice and advertising as an architect without a Nevada license. Following an administrative hearing, the Board found violations and imposed a $20,000 civil penalty. After the Board’s decision, the architect petitioned for judicial review in the Eighth Judicial District Court. The district court remanded the matter to the Board to determine whether the violations implicated any common law issue entitling him to a jury trial. The Board held a second hearing and determined no such right existed. Upon renewed petition for judicial review, the district court denied the architect's petition, prompting an appeal. The Supreme Court of the State of Nevada considered whether Article 1, Section 3 of the Nevada Constitution guarantees a right to a jury trial in administrative agency proceedings involving civil penalties where the statutory violations lack a common law analog. The Court held that the constitutional right to a jury trial does not apply to administrative proceedings imposing civil penalties for statutory violations that are not sufficiently analogous to common law actions for which a jury trial was historically available. The Court concluded that none of the statutes violated—regarding unlicensed practice, misrepresentation, or civil penalties—was sufficiently analogous to common law causes of action such as fraudulent misrepresentation, professional negligence, or action in debt. Accordingly, the Supreme Court of Nevada affirmed the district court’s order denying the petition for judicial review. View "HAGEN VS. HARRISON" on Justia Law

Guardado v. State of Florida

2026-10-29T07:02:27-08:00

The appellant was convicted of the murder of a seventy-five-year-old woman, whom he knew personally and had previously lived with. In 2004, after an unsuccessful attempt to rob a grocery store, he decided to rob the victim at her secluded home. Armed with a metal bar and a knife, he entered her residence, violently assaulted her, and stole various items. He pleaded guilty to first-degree murder and robbery with a weapon. At sentencing, the court found multiple aggravating factors and, despite acknowledging nonstatutory mitigating circumstances, imposed a death sentence. Following the conviction and sentencing in the Eighth Judicial Circuit Court, the appellant pursued multiple avenues of relief. The Supreme Court of Florida affirmed the conviction and sentence on direct appeal. Subsequent postconviction motions, including claims of ineffective assistance of counsel and challenges under Hurst v. Florida, were denied by the circuit court and affirmed by the Supreme Court of Florida. Federal habeas petitions were also unsuccessful. After the Governor signed a death warrant, the appellant filed another successive postconviction motion, raising claims about the constitutionality of Florida’s clemency and warrant process, and the reliability of his death sentence due to counsel’s performance. The Supreme Court of Florida reviewed the circuit court’s summary denial of the successive postconviction motion de novo. The court held that the appellant was not entitled to relief. It held that Florida’s clemency process does not violate due process, as the appellant received clemency review and there is no requirement for specific procedures. Claims regarding ineffective assistance of counsel and the reliability of the death sentence were found untimely and procedurally barred. Challenges to the expedited warrant process were also rejected based on settled precedent. The Supreme Court of Florida affirmed the circuit court’s denial and denied the appellant’s request for a stay of execution. View "Guardado v. State of Florida" on Justia Law

WESLEY v. STATE OF ARKANSAS

2026-10-29T07:01:32-08:00

Wesley Cooper fatally shot his neighbor, Donald Lewis, and his uncle, Terry Brasuell in Crawford County in 2023. Cooper, under the influence of drugs, mistakenly believed that Lewis and Brasuell had killed his family after he was unable to contact them, not realizing they were merely camping in a location without cell service. He purchased black clothing for his intended actions, stole two handguns from his father's safe, and proceeded to carry out both killings. After the second shooting, a neighbor, Melinda Ball, witnessed the event and relayed her account to police officers, which was subsequently documented by another neighbor, Helene Plonski, at the direction of law enforcement. Cooper was arrested and confessed to both murders. The Crawford County Circuit Court presided over Cooper's trial. Prior to trial, Melinda Ball passed away. Cooper moved to exclude Ball’s written statement on hearsay and confrontation grounds, arguing he had no opportunity to cross-examine her. The circuit court denied his motion, finding the statement admissible as a present sense impression and excited utterance, but did not rule specifically on the confrontation issue. The statement was introduced at trial, and Cooper renewed his objections, which were denied without explicit consideration of the confrontation argument. The jury convicted Cooper on both counts of capital murder, imposing two life sentences without parole. The Supreme Court of Arkansas reviewed the case, focusing solely on Cooper’s appeal regarding the conviction for Brasuell’s murder. The court held that the admission of Ball’s statement did violate Cooper’s right to confront witnesses against him, as the statement was testimonial and Cooper had no prior opportunity for cross-examination. However, the court found the error harmless beyond a reasonable doubt, given Cooper’s confession and corroborating eyewitness evidence. The conviction and sentence were affirmed. View "WESLEY v. STATE OF ARKANSAS" on Justia Law

TAYLOR v. STATE OF TEXAS

2026-10-29T04:26:24-08:00

A man was arrested outside his ex-girlfriend’s house, where he was found illegally parked. He had two outstanding warrants for stalking and making a terroristic threat, both related to his prior conduct toward the same woman. After arresting him, police officers decided to have his vehicle towed and conducted an inventory search prior to impoundment. During this search, the officers found a handgun in the center console. The inventory search was not conducted in perfect conformity with the police department’s written policy; for example, the officers did not obtain the arrestee’s signature on the inventory report and did not itemize every object in the vehicle. The trial court in Hays County denied the defendant’s motion to suppress the handgun, finding that the search was reasonable under the circumstances. The case proceeded to a jury trial, which resulted in a conviction for unlawful possession of a firearm by a felon. On appeal, the Seventh Court of Appeals determined that the inventory search deviated from departmental policy and that the trial court erred in denying the motion to suppress. Relying on its interpretation of earlier Texas precedent, the appellate court reversed the conviction and remanded the case for further proceedings. The Court of Criminal Appeals of Texas reviewed the case on discretionary review. It held that minor deviations from departmental policy during an inventory search do not render the search unreasonable under the Fourth Amendment, as long as the deviations are not used as a pretext for criminal investigation and do not undermine the purposes of an inventory search. The Court found that the inventory search here was reasonable under the totality of the circumstances. Accordingly, it reversed the judgment of the court of appeals and affirmed the trial court’s decision to deny suppression. View "TAYLOR v. STATE OF TEXAS" on Justia Law

Tucker v. State of Idaho

2026-10-28T08:33:07-08:00

Several indigent criminal defendants in Idaho brought a lawsuit against the State, alleging that the longstanding county-based public defense system failed to provide constitutionally adequate legal representation. The plaintiffs asserted that the State’s system resulted in excessive caseloads, insufficient support staff, inadequate funding, lack of independence for defense attorneys, and other systemic deficiencies that jeopardized defendants’ rights under both the Sixth Amendment and the Idaho Constitution. Initially, the District Court of the Fourth Judicial District dismissed the plaintiffs’ claims based on justiciability grounds. After an appeal, the Supreme Court of Idaho allowed certain claims to proceed against the State, setting a standard that plaintiffs must prove widespread, persistent structural deficiencies likely to result in actual or constructive denial of counsel at critical stages. Subsequent legislative reforms shifted funding responsibility for indigent defense from counties to the state and created a centralized Office of the State Public Defender. Following these changes, the district court partially granted plaintiffs’ summary judgment motion, enjoining the State from returning to the prior county-based system, but dismissed the rest of the case, declining to impose a remedial plan on the new system. On appeal to the Supreme Court of Idaho, plaintiffs argued that the district court erred in determining the new system was unlikely to perpetuate constitutional violations and in refusing to devise and enforce its own remedial plan. The Supreme Court of Idaho held that a district court may properly exercise remedial discretion by declining to issue injunctive relief when doing so would conflict with ongoing legislative reforms and efforts of a coordinate branch of government. The Court found no abuse of discretion and affirmed the district court’s order. The plaintiffs were not awarded attorney fees, as they were not prevailing parties under relevant legal standards. View "Tucker v. State of Idaho" on Justia Law

Bear v. Bear

2026-10-28T06:02:04-08:00

Former spouses entered into a marital settlement agreement during their divorce proceedings in Montana, which included provisions for the ownership and future sale of a residential property located in Eagle, Idaho. The agreement specified that the Eagle property would be held as tenants in common and sold upon the mutual agreement of both parties. The settlement agreement was incorporated into the Montana divorce decree, which reserved exclusive jurisdiction to the Montana court over the enforcement, modification, or interpretation of the agreement. After the divorce, one spouse relocated to Idaho and, believing she was entitled to force a sale, filed a partition action in Ada County, Idaho, seeking to compel the sale of the Eagle property and to receive credit for fair market rent. The District Court of the Fourth Judicial District of Idaho considered the partition action. The court denied the plaintiff’s motion for summary judgment and dismissed the action, reasoning that the Montana court’s decree, which incorporated the settlement agreement and reserved exclusive jurisdiction to the Montana court, deprived the Idaho court of subject matter jurisdiction over the partition claim. The court also denied a motion for reconsideration. On appeal, the Supreme Court of the State of Idaho reviewed the district court’s decision. The Supreme Court held that the Idaho district court did possess subject matter jurisdiction over partition actions generally, but that the Full Faith and Credit Clause of the United States Constitution required Idaho courts to honor the Montana divorce decree’s reservation of exclusive jurisdiction. The Idaho Supreme Court concluded that resolving the partition action would necessarily require interpreting or enforcing the Montana agreement, which only the Montana court could do. Accordingly, the Supreme Court affirmed the district court’s dismissal of the partition action, but on the alternative ground that full faith and credit precluded the relief sought, rather than a lack of subject matter jurisdiction. The court also declined to award attorney fees on appeal. View "Bear v. Bear" on Justia Law

State v. Erickson

2026-10-27T14:04:54-08:00

The defendant was charged with Criminal Mischief and Threats and Other Improper Influence in Official and Political Matters after damaging property and threatening officers during and after a court proceeding in Lake County, Montana. Following these events, he was arrested and charged. Attempting to resolve the charges, the defendant and the State negotiated plea agreements, but the District Court rejected them due to insufficient factual basis and misrepresentation of the defendant’s status as a repeat Persistent Felony Offender. After further attempts, the defendant ultimately entered an open guilty plea, meaning there was no plea agreement and no promises regarding sentencing. The Twentieth Judicial District Court sentenced the defendant to two consecutive thirty-year terms at the Montana State Prison, with parole restrictions. However, after the defendant filed a notice of appeal, it was discovered that audio recordings from several hearings—including the sentencing hearing—were missing or indiscernible. The partial and unofficial transcript attached to the presentence investigation report was not recognized as an official record. The defendant argued on appeal that he was entitled to enforcement of an amended plea agreement and that the lack of a sentencing transcript deprived him of due process. The Supreme Court of the State of Montana reviewed the case. It held that the defendant waived his right to appeal adverse pre-plea rulings by entering an open guilty plea without reserving any such rights. However, the Court determined that the absence of a certified transcript or suitable alternative from the sentencing hearing constituted a substantial and significant omission, denying the defendant due process and preventing effective appellate review. The Court affirmed the acceptance of the guilty plea but remanded the case for resentencing before a new District Court judge. View "State v. Erickson" on Justia Law

United States v. Johnson

2026-10-27T11:30:08-08:00

The defendant was stopped by Columbus police for driving with a broken headlight and found to be driving on a suspended license related to a prior OVI offense. After arresting him, police conducted an inventory search of his car, which revealed heroin, cocaine, and ammunition. Subsequent searches of his residence and his grandmother’s home, both conducted pursuant to warrants, uncovered additional drugs, cash, and firearms. The defendant was implicated in a long-running drug-trafficking organization operated by his uncle and another individual, and was charged in a federal indictment with conspiracy and various drug and firearm offenses. Before trial, the defendant moved to suppress evidence from all three searches, arguing, among other things, that the impoundment and search of his car were improper and that the warrants for the residences lacked probable cause. The United States District Court for the Southern District of Ohio denied all suppression motions. During trial, the government discovered that most of the cocaine from the car was powder, not crack, and successfully moved to amend Count Two of the indictment to reflect this. The jury convicted the defendant of conspiracy and several drug offenses, acquitting him on firearm counts. The district court denied post-verdict motions and sentenced him to concurrent terms of imprisonment. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. It affirmed the denial of all suppression motions, finding the searches lawful and either properly supported by probable cause or covered by the good-faith exception. The appellate court also affirmed the admission of alleged hearsay, ruling it fell within the co-conspirator exception. The court upheld the conviction for conspiracy, determining that sufficient evidence supported the jury’s verdict. However, the court held that the mid-trial amendment to Count Two of the indictment constituted an actual amendment in violation of the Fifth Amendment's Presentment Clause and vacated the conviction on that count, remanding for further proceedings. View "United States v. Johnson" on Justia Law

Jackson v. Thomson Reuters America Corp.

2026-10-27T10:30:11-08:00

A retired law enforcement officer in West Virginia initiated five separate lawsuits against several data broker companies, alleging they published his home address and unpublished telephone number online without his consent. He claimed these disclosures, made via “people search” services, also affected thousands of other similarly situated officials protected under West Virginia’s Daniel’s Law. The statute prohibits the dissemination of home addresses or unpublished phone numbers of certain judicial and law enforcement officials if a reasonable person would believe such disclosure would expose them to harassment or harm. The United States District Court for the Northern District of West Virginia reviewed consolidated motions to dismiss by the defendants. The district court found that the challenged provision of Daniel’s Law was a content-based restriction on speech, necessitating strict scrutiny under the First and Fourteenth Amendments. The court recognized the compelling state interest in protecting officials’ safety but concluded the statute was not narrowly tailored, as it imposed liability without requiring notice or knowledge of the protected status of individuals whose information was disclosed. The district court thus dismissed the actions, determining the law was facially unconstitutional. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The appellate court held that the statute regulated speech protected by the First Amendment, was content-based, and therefore subject to strict scrutiny. The court agreed that the law was not the least restrictive means to serve the state’s compelling interest because it lacked a notice requirement and imposed automatic liability. As a result, the Fourth Circuit held that the provision of West Virginia’s Daniel’s Law at issue violated the First and Fourteenth Amendments and affirmed the dismissal of the lawsuits. View "Jackson v. Thomson Reuters America Corp." on Justia Law

MARDELL v. THE STATE

2026-10-27T04:31:51-08:00

The case involves Alexzandria Mardell, who killed her husband, John Mardell, on December 23, 2019, after a violent altercation at their shared home. Earlier that day, John had obtained a temporary protective order (TPO) against Alexzandria and requested law enforcement to serve her with the TPO and a divorce petition. After the attempted service, Alexzandria attacked John with a broken golf club, a glass jar, and stabbed him 20 times, resulting in his death. The incident was followed by Alexzandria calling 911 and interactions with responding officers, which were documented and presented at trial. Alexzandria claimed self-defense, testifying about alleged abuse and control exerted by John during their marriage. A Fayette County grand jury indicted Alexzandria for malice murder, felony murder, and aggravated assault. After a jury trial in the Superior Court of Fayette County, she was found guilty on all counts. The court sentenced her to life in prison without parole for malice murder, vacated the felony murder conviction, and merged the aggravated assault charge. Her motion for a new trial was denied following a hearing. The Supreme Court of Georgia reviewed Alexzandria’s appeal, in which she argued that admitting John’s written statements from his ex-parte TPO petition violated her confrontation rights and that her counsel was ineffective. The Court held that the admission of John’s statements did not violate the Confrontation Clause because they were not hearsay—the statements were not admitted for the truth of the matter asserted but for other purposes. The Court also rejected her ineffective assistance claims, finding no deficient performance or prejudice resulting from counsel’s actions. Additionally, the Court concluded that no cumulative prejudice resulted from the alleged errors. The judgment of conviction was affirmed. View "MARDELL v. THE STATE" on Justia Law

Cormier v. Florida Department of Corrections

2026-10-26T12:00:43-08:00

The petitioner was convicted in Florida state court in 2013 of two counts of first-degree grand theft and one count of second-degree grand theft for taking investments from three individuals and using the funds for personal expenses. He was sentenced to fifteen years in prison and ordered to pay $835,000 in restitution. His conviction and sentence were affirmed by the Florida Fourth District Court of Appeal, and his motion for rehearing was denied in January 2016, making his conviction final ninety days later. Shortly before his conviction became final, he filed a motion to reduce his imprisonment, which was denied in April 2016. He later mailed a separate motion, challenging only the restitution part of his sentence, but this motion was never docketed by the state court. In December 2017, he filed a state post-conviction motion, which was eventually denied and became final in December 2022. The United States District Court for the Southern District of Florida dismissed his federal habeas petition as untimely under the Antiterrorism and Effective Death Penalty Act (AEDPA), holding that the one-year limitations period was not tolled by his undocketed motion challenging restitution, because it did not challenge the custody-imposing portion of his sentence. The district court also found no basis for equitable tolling and held, in the alternative, that his ineffective-assistance-of-counsel and due process claims were not colorable. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The Eleventh Circuit held that a motion challenging only restitution does not toll AEDPA’s statute of limitations, because restitution does not relate to the custody underlying habeas relief. Therefore, his federal habeas petition was untimely, and the court did not reach the merits of his constitutional claims. The district court’s order was affirmed. View "Cormier v. Florida Department of Corrections" on Justia Law

Safe Affordable Georgia, Inc. v. Chairman of the State Ethics Commission

2026-10-26T10:30:44-08:00

Several individuals sought the Republican nomination for Governor in Georgia’s 2026 primary election. Under state law, only certain officials—including the Lieutenant Governor—could create a special “leadership committee” that was permitted to raise and spend unlimited funds in direct coordination with their campaigns. Burt Jones, the Lieutenant Governor, formed such a committee to support his own campaign. Brad Raffensperger, Georgia’s Secretary of State, also ran in the primary, but his supporters—including Safe Affordable Georgia, a hybrid political action committee (PAC) chaired by Raffensperger—were subject to contribution and coordination restrictions and could not operate a leadership committee. Safe Affordable Georgia filed suit in the United States District Court for the Northern District of Georgia, challenging these campaign finance restrictions as violating the First Amendment. The group sought a preliminary injunction to prevent enforcement of the contribution and coordination limits against it, specifically so it could support Raffensperger’s campaign during the ongoing primary. The district court denied the motion for preliminary injunction. Safe Affordable Georgia appealed to the United States Court of Appeals for the Eleventh Circuit, seeking expedited review. By the time the Eleventh Circuit heard the appeal, the 2026 primary election was over and Raffensperger’s campaign had ended. The Eleventh Circuit concluded that the case was moot because the court could no longer provide meaningful relief relating to the completed election. The court also found that the “capable of repetition yet evading review” exception to mootness did not apply, as there was no reasonable expectation that the same dispute would recur involving the same parties. Consequently, the Eleventh Circuit dismissed the appeal and remanded the case with instructions to dismiss it as moot. View "Safe Affordable Georgia, Inc. v. Chairman of the State Ethics Commission" on Justia Law

USA v. Waeckerle

2026-10-26T09:30:10-08:00

Several candidates, including Georgia’s Lieutenant Governor and Secretary of State, sought the Republican nomination for Governor in Georgia’s 2026 primary. Under Georgia law, only certain officeholders, such as the incumbent Lieutenant Governor, could establish “leadership committees,” which allowed them to raise and spend unlimited funds and coordinate directly with their campaigns. Safe Affordable Georgia, a hybrid PAC chaired by Secretary Raffensperger, could not coordinate with his campaign or raise unlimited funds to support him. Safe Affordable Georgia filed suit in the United States District Court for the Northern District of Georgia against state officials, arguing that Georgia’s campaign finance scheme violated the First Amendment by treating it differently from leadership committees. The PAC sought a preliminary injunction to bar enforcement of contribution and coordination limits against it, aiming to support Raffensperger in the ongoing primary. The district court denied the request for emergency injunctive relief, and the PAC appealed to the United States Court of Appeals for the Eleventh Circuit. While the appeal was pending, the primary election concluded and Raffensperger’s campaign ended. The United States Court of Appeals for the Eleventh Circuit determined that, because the election was over and the PAC’s requested relief focused specifically on the 2026 primary, federal courts could no longer offer meaningful relief. The court held that the case was moot and did not qualify for the “capable of repetition, yet evading review” exception because there was no reasonable expectation the same situation would recur for the same party. The Eleventh Circuit dismissed the appeal and remanded the case to the district court with instructions to dismiss it as moot. View "USA v. Waeckerle" on Justia Law

ROBBINS v STATE OF ARIZONA

2026-10-26T09:01:09-08:00

Two defendants were jointly indicted for money laundering, illegal control of an enterprise, and attempts to commit trafficking in stolen property. During their trial, the State introduced evidence referencing financial records that had previously been excluded as untimely. One defendant’s counsel objected and moved for a mistrial, additionally requesting dismissal with prejudice, arguing the jury had been irreparably exposed to precluded evidence. The co-defendant’s counsel joined in these motions. The trial court excused the jury, heard arguments, and granted a mistrial, but denied dismissal with prejudice, finding the State’s conduct was not intentional nor in bad faith. After the mistrial was granted, both defendants attempted to withdraw their mistrial requests, expressing preference to continue the trial if dismissal with prejudice was unavailable, but the court declined to revisit its decision. The defendants sought special action review from the Arizona Court of Appeals, arguing that a retrial would violate the Double Jeopardy Clause. The court of appeals accepted jurisdiction, granted relief, and vacated the trial court’s order of mistrial, concluding that retrial would violate double jeopardy because the defendants had not consented to a mistrial without prejudice. The appellate court found the trial court abused its discretion in declaring a mistrial without manifest necessity and instructed that the charges be dismissed with prejudice, reasoning the defendants’ requests were ambiguous and their later attempts to clarify indicated they sought only a mistrial with prejudice. The Supreme Court of Arizona reviewed the case to address whether a defendant can withdraw or clarify a mistrial motion after the court’s ruling and what framework governs appellate review of a manifest necessity finding. The Court held that defendants cannot withdraw or condition a mistrial motion after the trial court has ruled; consent to a mistrial must be withdrawn or clarified before the ruling. The Court also held that either consent or manifest necessity is independently sufficient to permit retrial under double jeopardy principles, and affirmed the trial court’s finding of manifest necessity. The relief granted by the court of appeals was vacated, and the case was remanded. View "ROBBINS v STATE OF ARIZONA" on Justia Law

US v. Barros Brandao

2026-10-23T14:30:04-08:00

The defendant, an American citizen, applied for a temporary emergency passport at the U.S. Embassy in Senegal after fleeing Cape Verde, where he faced two pending homicide charges and other criminal accusations. The Cape Verdean authorities had confiscated his passports and identification, but shortly after his release from pretrial detention (with instructions not to leave the country), he traveled to Senegal and claimed to have lost his American passport. Based on these events, he was charged in the United States with knowingly making false statements on a passport application, specifically that he had lost his passport in Dakar. Proceedings in the United States District Court for the District of Massachusetts included the denial of the defendant’s motion to exclude evidence regarding the Cape Verdean homicide charges, on the grounds that such evidence was relevant to motive. The district court also declined to give a missing witness instruction regarding the absence of a Cape Verdean official and did not ask a proposed voir dire question about potential juror bias related to the homicide charges. The jury convicted the defendant, who then appealed to the United States Court of Appeals for the First Circuit. The United States Court of Appeals for the First Circuit found that the district court did not abuse its discretion by declining to give a missing witness instruction or by prohibiting argument about the absent Cape Verdean official. However, the appellate court concluded that the district court erred in not questioning potential jurors about bias from the homicide charges and in admitting evidence specifically referencing those charges, which was unduly prejudicial. Nonetheless, because the evidence of guilt was overwhelming, the court held these errors to be harmless and affirmed the conviction. View "US v. Barros Brandao" on Justia Law

Alvarado v. Vergara

2026-10-23T09:30:06-08:00

Three individuals, all foreign nationals who had resided in the United States for many years without lawful admission, were detained by immigration authorities under 8 U.S.C. § 1225(b)(2)(A) following traffic stops. Each sought habeas corpus relief, arguing that their continued detention without a bond hearing to assess their dangerousness or flight risk violated their Fifth Amendment due process rights. The United States District Court for the Western District of Texas granted habeas relief in each case, ordering the release of the individuals and enjoining federal authorities from further detaining them absent individualized bond hearings. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit affirmed the district courts’ rulings, holding that the Fifth Amendment required a bond hearing within 90 days of detention. The panel also consolidated the cases due to their similar legal questions regarding detention under § 1225(b)(2)(A). The United States Court of Appeals for the Fifth Circuit, sitting en banc, subsequently reconsidered the panel’s decision. The en banc court held that unadmitted aliens detained under § 1225(b)(2)(A) are not constitutionally entitled to individualized hearings on dangerousness or flight risk before detention, and that the duration of their detention did not present constitutional concerns warranting habeas relief. The court reasoned that such procedural protections are not required by the statute, nor by the Fifth Amendment, given Congress’s plenary power over immigration and the specific statutory framework for applicants for admission. Accordingly, the Fifth Circuit reversed the district courts’ judgments and vacated their orders granting habeas relief to the petitioners. View "Alvarado v. Vergara" on Justia Law

Johnson v. Reed

2026-10-23T05:30:47-08:00

A group of plaintiffs filed suit in the Montgomery Circuit Court against the Secretary of the Alabama Department of Workforce, alleging that their applications for unemployment benefits during the COVID-19 pandemic were unreasonably delayed. They also claimed that the Department’s notices regarding the unemployment process were too difficult to understand, violating the due process requirements of the Fourteenth Amendment and the Social Security Act. Their complaint sought various forms of injunctive relief, primarily to require prompt processing of applications and to mandate that notices be written at a level comprehensible to people with an eighth-grade education. The Montgomery Circuit Court dismissed the complaint, holding that it lacked subject-matter jurisdiction because the plaintiffs had not exhausted the required state administrative remedies under Alabama law. The Supreme Court of Alabama affirmed, rejecting the plaintiffs’ argument that federal law under Patsy v. Board of Regents of the State of Florida precluded the exhaustion requirement for claims brought under 42 U.S.C. § 1983. The United States Supreme Court subsequently reversed this decision, but only on the narrow ground that, when a state’s exhaustion requirement effectively immunizes state officials from § 1983 claims of administrative delay, such claims cannot be denied for failure to exhaust. The case was remanded for further proceedings. On remand, the Supreme Court of Alabama directed the circuit court to determine if the case was moot, given that the Secretary asserted all plaintiffs had either been paid or received final denials. The circuit court found the case moot. Reviewing this determination, the Supreme Court of Alabama held that the plaintiffs had not shown any remaining justiciable controversy, as their delay claims were moot and their arguments for relief on the notice claims were inadequately supported. The court dismissed the appeal as moot. View "Johnson v. Reed" on Justia Law

State v. Elias

2026-10-23T05:05:52-08:00

The case involved a defendant convicted of second degree murder, unlawful discharge of a firearm, and two counts of use of a weapon to commit a felony related to a drive-by shooting. Key evidence included cell phone location data obtained through a "tower dump" order under Nebraska and federal statutes, which provided law enforcement with phone numbers of all cell phones accessing certain towers during a specified period. This order was sought soon after the crime because carriers retained such data only briefly. After the defendant was identified as a suspect, his number was found among the collected data, and this evidence linked him to the crime scene. On direct appeal, the Nebraska Supreme Court affirmed the convictions, holding that the trial court correctly admitted the tower dump data. The court found the data collection did not constitute a "search" under the Fourth Amendment, distinguishing it from broader location tracking at issue in Carpenter v. United States. The court also held that, even if the search were subject to the Fourth Amendment, the good faith exception to the exclusionary rule applied because law enforcement reasonably relied on the court's order. The same attorneys represented the defendant at trial and on direct appeal. Subsequently, with new counsel, the defendant filed a motion for postconviction relief in the District Court for Lancaster County. He argued that his previous counsel was ineffective for failing to raise First Amendment and statutory arguments regarding the cell tower data, and that the state's failure to notify affected subscribers violated statutory and constitutional rights. The district court denied these claims without an evidentiary hearing, concluding the arguments were either procedurally barred, lacked merit, or were precluded by prior appellate rulings. The Nebraska Supreme Court affirmed, holding that the claims were procedurally barred or precluded by its prior decision, and that counsel was not ineffective for failing to raise meritless or novel legal theories. The court also found recent Supreme Court precedent did not alter this outcome. View "State v. Elias" on Justia Law

Jackson Federation of Teachers v. Fitch

2026-10-22T15:30:07-08:00

In this case, a group of teachers, professors, students, parents, and advocacy organizations challenged the constitutionality of a recently enacted Mississippi law, House Bill 1193, which restricts the use of state education funds for diversity, equity, and inclusion (DEI) initiatives in public schools and colleges. The law prohibits the mandatory implementation of DEI programs, penalizing students for disagreeing with DEI concepts, promoting DEI through official course materials, and engaging in DEI activities in official capacities, while carving out exceptions for scholarly research, creative works, and student group activities. After the plaintiffs filed a pre-enforcement facial challenge on First Amendment and Fourteenth Amendment grounds, the United States District Court for the Southern District of Mississippi issued a temporary restraining order (TRO) and later a preliminary injunction blocking the law’s enforcement. The district court’s proceedings, however, were marred by multiple errors: the TRO included fabricated facts, non-existent parties, and a citation to a fictitious case, some of which stemmed from the judge’s or his clerk’s reliance on artificial intelligence in drafting. When these issues came to light, the judge revised the TRO without adequate explanation and incorporated the flawed order by reference into the preliminary injunction. The district court’s legal analysis was also found deficient, failing to properly apply binding Supreme Court precedent and misinterpreting the requirements for facial constitutional challenges. The United States Court of Appeals for the Fifth Circuit reviewed the case and found grave procedural and substantive errors in the district court’s handling, including the use of fabricated evidence, failure to follow controlling legal standards, and an overbroad injunction. The Fifth Circuit vacated the preliminary injunction, holding that the errors justified reassignment of the case to a different district judge on remand. The court provided detailed instructions for the new judge, emphasizing the need to follow the Supreme Court’s framework for facial First Amendment challenges and to properly analyze the law’s scope and constitutionality. The disposition was to vacate the injunction and remand the case for further proceedings before a new judge. View "Jackson Federation of Teachers v. Fitch" on Justia Law

People v. Thomas

2026-10-22T14:00:56-08:00

Police officers observed Anthony Thomas commit two minor traffic violations but did not issue him a ticket. After Thomas parked his car legally in a parking lot and began to walk away, officers approached him, expressing suspicion about his actions and the vehicle. Due to an error in running the license plate, officers received a “no information” result, which increased their suspicion that the vehicle might be stolen. Although Thomas explained the car was his mother’s rental and this proved true, officers decided to impound the vehicle under a provision of the Vehicle Code that was inapplicable, as the car was legally parked with valid plates. Without verifying the vehicle’s status or giving Thomas an opportunity to arrange for someone to move it, officers arrested him on an outstanding misdemeanor warrant and conducted a search that uncovered a gun, leading to firearms charges. In the Superior Court of Los Angeles County, Thomas moved to suppress the gun evidence, arguing that the search was not a valid inventory search and lacked a true community caretaking purpose. The court denied the motion without making findings about the officers’ motivation for impoundment. Thomas then pleaded guilty, preserving his right to appeal the suppression issue. Upon review, the Court of Appeal of the State of California, Second Appellate District, Division Eight, found that the search did not qualify as a valid inventory search because the prosecution failed to show a legitimate community caretaking rationale. Instead, the officers’ actions indicated an investigatory purpose. The court held that the prosecution did not meet its burden to justify the warrantless search, and the inventory search exception could not be used as a pretext for investigating criminal activity. The order denying the suppression motion was reversed, and the case was remanded with instructions to grant the suppression motion. View "People v. Thomas" on Justia Law

State v. Gaeta

2026-10-22T11:31:37-08:00

A woman reported being sexually assaulted by a man with whom she had socialized during an evening out. She alleged that the man engaged in acts that constituted sexual assault and attempted sexual assault in the second degree, including penetration, and later reported significant emotional distress and physical harm. The man was indicted on several felony charges, but through plea negotiations, he agreed to plead no contest to a misdemeanor charge of sexual assault in the fourth degree, specifically for exposing his genitals in a manner likely to alarm or cause fear, in exchange for dismissal of the more serious charges. The Circuit Court of the Third Circuit accepted the no contest plea but denied the defendant’s motion to defer acceptance of the plea (DANC), which would have allowed him to avoid a criminal conviction if he complied with certain conditions. The court sentenced him to probation, emphasizing the impact on the victim rather than considering allegations of penetration or lack of remorse. The defendant appealed, arguing that the court improperly considered dismissed charges and his alleged lack of remorse. The Intermediate Court of Appeals affirmed, finding the trial court acted within its discretion and did not improperly rely on the dismissed charges or lack of remorse. The Supreme Court of the State of Hawai‘i affirmed both the circuit court’s judgment and the Intermediate Court of Appeals’ judgment. The court held that trial courts may not consider dismissed charges at sentencing, even if a plea agreement purports to allow it, as this violates constitutional rights. The court also prospectively held that lack of remorse cannot be used against defendants who plead no contest, due to their limited right against self-incrimination, establishing a new rule applicable to future cases. View "State v. Gaeta" on Justia Law

Rhodes v. State of Florida

2026-10-22T07:02:57-08:00

A Florida Highway Patrol officer stopped Richard Rhodes in March 1984 while he was driving a car registered to Karen Nieradka. Rhodes was arrested for driving without a valid license and held in the Citrus County Jail. Weeks later, Nieradka’s decomposed body was discovered in construction debris in St. Petersburg, with the medical examiner determining manual strangulation as the cause of death. Detectives interviewed Rhodes, who gave inconsistent statements but always denied killing Nieradka. After further investigation, Rhodes was arrested for her murder. At trial, several jailhouse informants testified that Rhodes confessed to the killing; Rhodes was convicted of first-degree murder and sentenced to death. On direct appeal, the Supreme Court of Florida affirmed the conviction but remanded for resentencing, which again resulted in a death sentence and was affirmed. Rhodes later filed multiple postconviction motions. In the most recent proceeding, he filed a successive motion under Florida Rule of Criminal Procedure 3.851, submitting affidavits from jailhouse witnesses who recanted or claimed their trial testimony had been elicited or coached by the State in exchange for leniency or other benefits. At an evidentiary hearing, these witnesses testified, but their accounts were contradicted by State witnesses and records. The postconviction court found Rhodes’s witnesses not credible and denied all relief. The Supreme Court of Florida reviewed the denial of postconviction relief, applying deference to the lower court’s credibility findings and reviewing legal conclusions de novo. The court held that the postconviction court’s findings regarding witness credibility were supported by competent, substantial evidence. Rhodes failed to establish a violation under Brady v. Maryland, Giglio v. United States, or Massiah v. United States, and the affidavits did not constitute newly discovered evidence warranting a new trial. The Supreme Court of Florida affirmed the denial of Rhodes’s successive motion for postconviction relief. View "Rhodes v. State of Florida" on Justia Law

BARRON v. US

2026-10-22T05:30:37-08:00

Landowners in Florida who own property adjacent to a former rail corridor challenged the federal government’s issuance of a Notice of Interim Trail Use (“NITU”) under the National Trails System Act Amendments of 1983. This NITU allowed the rail corridor to be converted to a recreational trail rather than being abandoned completely. The landowners asserted that when the NITU was issued, it blocked their reversionary interests from taking effect, amounting to an uncompensated taking under the Fifth Amendment. The crux of the dispute centered on whether the railroad’s original property interests, acquired through various deeds and a condemnation judgment, were fee simple estates or merely easements. The United States Court of Federal Claims reviewed the evidence, including the deeds and the condemnation judgment, and determined that the language of each deed unambiguously conveyed a fee simple interest to the railroad. For the condemnation judgment, the court found the language ambiguous but, after consulting extrinsic evidence from the condemnation proceeding, also concluded it conveyed fee simple title. On this basis, the Claims Court held that no reversionary interest remained with the landowners, and thus no taking had occurred. The court granted summary judgment for the government. On appeal, the United States Court of Appeals for the Federal Circuit reviewed the Claims Court’s summary judgment de novo. It agreed with the lower court’s interpretation of Florida law, finding that the relevant deeds and condemnation judgment conveyed fee simple title to the railroad. The court explained that, where the language of a deed is unambiguous, it must be enforced as written, and extrinsic evidence is only considered if ambiguity exists. The Federal Circuit affirmed the Claims Court’s judgment, holding that the landowners did not retain a reversionary interest and that the issuance of the NITU did not constitute a compensable taking. View "BARRON v. US " on Justia Law

State v. Hefferon

2026-10-22T05:05:50-08:00

Police in Seabrook, New Hampshire, were investigating reports of drug sales at a particular apartment complex. They received multiple tips, including one specifically naming a red Chevrolet Cruze and a silver Honda Civic, with license plate numbers, as being involved in these activities. The Cruze was registered to a woman living in the investigated complex, and she had previously been identified in reports as a suspected drug dealer. On June 2, 2023, an officer observed the Cruze with two occupants—a woman presumed to be the registered owner and a male passenger. The officer followed the vehicle from Seabrook to an apartment complex in Methuen, Massachusetts, known to be connected to drug activity. After about ten minutes at that location, the Cruze left, made a brief stop at a store parking lot, and then returned to Seabrook. The officer observed no traffic violations but did note "excessive blinker usage" and requested another officer to conduct a stop based on reasonable suspicion of drug possession. The defendant, identified as the male driver after a seat change, was found to be a certified habitual offender and admitted to having purchased fentanyl, which was located on the female passenger. He was charged with operating after certification as a habitual offender. He moved to suppress evidence from the stop, arguing lack of reasonable suspicion. The Rockingham County Superior Court concluded the officer’s observations and prior tips did not establish reasonable suspicion and granted the motion to suppress. The Supreme Court of New Hampshire reviewed the case de novo. It held that, viewing the totality of the circumstances—including prior reliable tips, the known drug-related activity at both apartment complexes, and the officer’s observations—the officer had reasonable suspicion to justify the investigatory stop. The court reversed the suppression order and remanded the case for further proceedings. View "State v. Hefferon" on Justia Law

Knife Rights v. Blanche

2026-10-21T17:28:50-08:00

A group of individuals, businesses, and an advocacy organization challenged the constitutionality of two provisions of the Federal Switchblade Act (FSA), which restricts the introduction, manufacture, transportation, distribution, sale, and possession of switchblade knives. The plaintiffs argued that these restrictions violate their rights under the Second Amendment. Some plaintiffs are individuals who wish to purchase, carry, or sell switchblade knives, while others are businesses that would sell such knives but refrain from doing so due to the FSA’s provisions. The United States District Court for the Northern District of Texas dismissed the plaintiffs’ challenge to the provision regulating possession, sale, and manufacture of switchblades in certain federal jurisdictions (15 U.S.C. § 1243) for lack of standing, finding no substantial threat of enforcement. It allowed standing for the challenge to the provision targeting interstate commerce in switchblades (15 U.S.C. § 1242) but ruled that this section did not violate the Second Amendment, reasoning that it was not a de facto ban on possession since switchblades remained available through intrastate commerce. The plaintiffs appealed the dismissal of their claims. The United States Court of Appeals for the Fifth Circuit held that plaintiffs had standing to challenge both provisions. Applying the framework from New York State Rifle & Pistol Association, Inc. v. Bruen, the Fifth Circuit determined that switchblades are “arms” under the Second Amendment and that § 1242 burdens constitutionally protected conduct. The court found the government failed to show that the regulation was consistent with the historical tradition of arms regulation, particularly regarding the manner in which it restricted switchblade knives. Therefore, the Fifth Circuit reversed the district court’s dismissal of the § 1242 claim. However, it affirmed dismissal of the § 1243 claim, concluding that the plaintiffs had not met the demanding standard required for a facial challenge to that provision. The case was remanded for further proceedings. View "Knife Rights v. Blanche" on Justia Law

Abedi v. Carter

2026-10-21T10:00:38-08:00

A noncitizen from Iran, who was granted asylum in the United States as a child, faced removal proceedings after a drug conviction. In 2002, an immigration judge deferred his removal under the Convention Against Torture, and he was released on supervision, consistently complying with all terms for over 20 years. After relocating from California to Kansas with approval from immigration authorities, he was unexpectedly detained by ICE officers in June 2025, despite no alleged violations of his release terms. He was subsequently notified that his release was revoked due to a supposed new possibility of removal to a third country, yet was not given the required informal interview to contest this revocation. The United States District Court for the District of Kansas denied his initial habeas petition challenging the legality of his detention, as well as his request for a preliminary injunction to stop his transfer out of Kansas. The court suggested he could file a new habeas petition if detained for more than six months. After over eight months in detention, the petitioner filed a second habeas petition, which the district court granted, leading to his release. The government then moved to dismiss his appeal as moot. The United States Court of Appeals for the Tenth Circuit determined the appeal was not moot, applying the exception for wrongs capable of repetition yet evading review. On the merits, the court held that the district court misapplied the applicable legal standards. It concluded that the government violated its own regulations by failing to promptly provide the petitioner with an informal interview upon revocation of his release, a due process violation that was per se prejudicial. The court also found error in the district court's application of the six-month presumptive reasonableness standard for detention under Zadvydas v. Davis, ruling it did not reset with each re-detention. The Tenth Circuit reversed and remanded for further proceedings. View "Abedi v. Carter" on Justia Law

Commonwealth v. Thomson

2026-10-21T04:19:53-08:00

A police officer stopped a car after it ran a red light and found three occupants, all under the age of twenty-one. There was marijuana in the car, and none of the occupants was wearing a seat belt. When asked if anyone had a weapon, the defendant, seated in the front passenger seat, did not respond. The officer asked him to exit the car, at which point the defendant pushed the officer and fled, discarding a loaded handgun during the pursuit. The defendant was charged with assault and battery on a police officer and unlawful possession of a firearm without a license. The charges were brought in the Dorchester Division of the Boston Municipal Court Department. A jury found the defendant guilty on both counts. The defendant appealed his convictions, raising no challenge to the assault and battery conviction. The Supreme Judicial Court of Massachusetts transferred the appeal from the Appeals Court on its own initiative to address the defendant's challenge to his conviction for unlawful possession of a firearm without a license. Specifically, the defendant argued that the statutory minimum age requirement of twenty-one for obtaining a license to carry a firearm violated his Second Amendment rights, both facially and as applied to him, even though he had never applied for a license and was only twenty years old at the time of the offense. The Supreme Judicial Court of Massachusetts held that while the defendant lacked standing to bring an as-applied challenge because he had not applied for a license, he did have standing to bring a facial challenge. The court found that the Commonwealth’s licensing age restriction—requiring individuals to be at least twenty-one years old to obtain a license to carry a firearm—was consistent with the nation’s historical tradition of firearm regulation and did not violate the Second Amendment. The court affirmed the defendant’s convictions. View "Commonwealth v. Thomson" on Justia Law

People v. Andrade

2026-10-20T12:01:33-08:00

Two victims were robbed at gunpoint and had their personal items and vehicle stolen by two suspects, one of whom drove away in the victims’ car while the other fled in a different vehicle. Police responded shortly after, locating the victim’s vehicle and monitoring the suspect’s vehicle at an address associated with one of the suspects, Marcos Andres Andrade. During the investigation, officers obtained cell site location information (CSLI) from Andrade’s phone carrier without a warrant by submitting an emergency disclosure request. This data assisted in acquiring search and arrest warrants, leading to Andrade’s arrest and recovery of some stolen items. The Santa Clara County Superior Court reviewed Andrade’s motion to suppress evidence derived from the warrantless CSLI request. The trial court denied the motion, finding exigent circumstances justified the search because the suspects were outstanding, armed, and there was potential for destruction of evidence or public danger. Andrade subsequently entered a no contest plea to second degree robbery and admitted a prior strike, receiving a four-year sentence. He appealed, arguing the exigent circumstances exception did not apply. The California Court of Appeal, Sixth Appellate District, considered whether the warrantless acquisition of both historical and real-time CSLI was a Fourth Amendment search, and if exigent circumstances justified the search. The court held that law enforcement’s request for historical and real-time CSLI constituted a Fourth Amendment search, requiring a warrant unless a valid exception applied. The court found that no exigent circumstances justified the warrantless search in this case and directed suppression of the CSLI data. The judgment was reversed and remanded for further proceedings, with instructions for the trial court to permit Andrade to withdraw his plea and to determine whether other evidence should be suppressed as fruits of the illegally obtained CSLI. View "People v. Andrade" on Justia Law

ALEXANDER v. DUONG

2026-10-20T07:30:37-08:00

A man was killed in a motor vehicle accident while working for Rent-A-Center. His widow and the mother of his minor child sued the driver responsible for the accident and other related parties in the District Court of Bryan County, Oklahoma. The employer and its insurance carrier, having paid statutory workers' compensation death benefits to the widow and child, were allowed to intervene, seeking reimbursement for the death benefits from any recovery against the tortfeasor, as authorized by 85A O.S.2014, § 43. Plaintiffs moved for summary judgment, arguing that Section 43 was unconstitutional under Article 23, section 7 of the Oklahoma Constitution. The District Court granted summary judgment in favor of the plaintiffs, finding the statute unconstitutional as applied to death benefits. The employer and insurer appealed, and the Court of Civil Appeals, Division I, reversed the trial court’s order, holding Section 43 constitutional based on precedent and persuasive authority from other jurisdictions. Plaintiffs then petitioned for certiorari review by the Oklahoma Supreme Court, which was granted. The Supreme Court of the State of Oklahoma conducted a de novo review and held that 85A O.S.2014, § 43 is constitutional and does not violate Article 23, section 7 of the Oklahoma Constitution. The court clarified that Section 43 does not abrogate the right of action for wrongful death but rather apportions recovery between dependents and the employer or insurer who paid benefits. The opinion of the Court of Civil Appeals and the trial court’s order were both vacated, and the case was remanded for further proceedings consistent with the Supreme Court’s decision. View "ALEXANDER v. DUONG" on Justia Law

Seabrook v. City of New York

2026-10-20T07:00:03-08:00

James Seabrook was arrested in May 2016 and spent more than seven and a half years in pre-trial detention. In April 2019, he was convicted of criminal possession of a weapon, but juries hung on more serious charges during subsequent retrials, and Seabrook was ultimately acquitted of those charges in December 2023. On January 31, 2024, Seabrook was sentenced to an indeterminate term of three and a half to seven years for the 2019 conviction. All parties recognized at sentencing that he had already served more time than the maximum sentence, yet he was remanded to Rikers Island, where he remained for seventeen days pending transfer from the New York City Department of Correction to the New York State Department of Corrections and Community Supervision, before his release. Seabrook filed suit in the United States District Court for the Southern District of New York, alleging violations of the Eighth and Fourteenth Amendments under 42 U.S.C. § 1983, naming the City of New York and various DOC officials. The district court dismissed his claims, holding that the complaint did not adequately allege deliberate indifference by any individual defendant, nor the existence of a City policy or practice causing his over-detention. The court also found no deprivation of a cognizable liberty interest or lack of procedural protections sufficient to sustain the due process claim. The United States Court of Appeals for the Second Circuit reviewed the case and held that Seabrook had plausibly alleged both an unconstitutional City policy or practice causing his excessive detention and deliberate indifference by DOC Captain Monastero. The Court further determined that Seabrook's procedural due process claim was sufficiently pleaded, given the absence of adequate processes to prevent over-detention. The Second Circuit vacated the district court's dismissal and remanded for further proceedings. View "Seabrook v. City of New York" on Justia Law

Mennonite Church USA v. DHS

2026-10-20T06:31:14-08:00

A coalition of twenty-seven Judeo-Christian organizations challenged a change in federal immigration enforcement policy that removed longstanding protections for houses of worship. For over thirty years, the government had a "Sensitive Locations Policy" that limited immigration enforcement at places like churches, synagogues, and mosques, except in exigent circumstances or with high-level approval. In January 2025, the Department of Homeland Security rescinded this policy, instructing immigration officers to use their discretion when conducting enforcement at these locations. Subsequent agency memoranda implemented this change, allowing supervisory agents to approve enforcement operations at or near houses of worship on a case-by-case basis, with no bright-line rules. Plaintiffs, representing congregations that serve undocumented immigrants, alleged that the new policy created a credible threat of enforcement, causing declines in attendance, financial burdens, and moral dilemmas. The United States District Court for the District of Columbia denied the plaintiffs’ motion for a preliminary injunction. The court concluded that the plaintiffs were unlikely to have Article III standing, finding their asserted injuries were not sufficiently imminent, not traceable to the policy change, or not redressable by reverting to the prior policy. Specifically, the district court relied on a legal standard requiring plaintiffs to show they were uniquely targeted for enforcement, which it found was not satisfied. The United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s denial of the preliminary injunction. The appellate court held that the plaintiffs likely have associational standing based on the imminent threat of enforcement actions at houses of worship, which burdens expressive and religious rights. The court determined that the harm was imminent, traceable to the government’s policy change, and redressable by the requested relief. The main holding was that plaintiffs likely have standing, and the district court’s denial of the preliminary injunction was reversed and remanded for further proceedings. View "Mennonite Church USA v. DHS" on Justia Law

State v. Pendleton

2026-10-19T11:32:29-08:00

A woman was stopped by police in Idaho for driving with an expired vehicle registration. During the traffic stop, a drug detection dog named Edo was deployed to conduct a “free-air sniff” around her vehicle. While sniffing, Edo briefly touched the vehicle’s door handle with the tip of his nose and alerted to the presence of drugs. Based on this alert, officers searched the vehicle and discovered methamphetamine, marijuana, alprazolam, and drug paraphernalia, leading to her arrest and subsequent charges for possession. After an earlier appeal concerning discovery issues related to Edo’s performance records, the defendant moved to suppress the evidence from the stop, arguing that the dog’s contact with her vehicle transformed the sniff into a trespassory search in violation of the Fourth Amendment. The District Court of the Fourth Judicial District in Ada County heard testimony and reviewed video evidence, ultimately granting the motion to suppress. The court concluded that the brief nose contact constituted trespassing and an unlawful search under Idaho precedent, specifically State v. Dorff, 171 Idaho 818, 526 P.3d 988 (2023). The State appealed, and the Idaho Court of Appeals reversed the district court’s suppression order, finding that the contact was not trespassory and that Edo’s alert provided probable cause for the search. The defendant then petitioned for review, which was granted by the Supreme Court of the State of Idaho. The Supreme Court held that the drug dog’s fleeting, momentary nose contact did not amount to “intermeddling” or trespassory conduct under the property-based Fourth Amendment analysis established in Dorff. Therefore, the contact did not transform the free-air sniff into a search, and the district court erred in granting the motion to suppress. The suppression order was reversed and the case remanded for further proceedings. View "State v. Pendleton " on Justia Law

Pen American Center, Inc. v. Adams

2026-10-19T11:01:21-08:00

A group of parents, authors, a free speech organization, and a book publisher brought a lawsuit against a county school board, challenging the removal of certain library books from public school libraries. The school board had adopted policies, as required by Florida law, mandating the removal of materials deemed pornographic or describing sexual conduct, and established procedures for reviewing objections to specific books. After objections were raised to various titles, review committees and the superintendent made recommendations, and the school board ultimately voted to remove several groups of books based on its existing policies and a directive aligned with state guidelines. Prior to this appeal, the United States District Court for the Northern District of Florida considered whether members of the school board could claim legislative privilege to avoid being deposed about their reasons for voting to remove the books. The district court ruled that legislative privilege did not apply in this context, finding that the board members’ votes to remove specific books constituted administrative acts—applying established policy to particular facts—rather than legislative acts involving the creation or amendment of policy. The district court denied the board members’ motion for a protective order and subsequent motions to quash deposition subpoenas. The United States Court of Appeals for the Eleventh Circuit reviewed whether legislative privilege shielded the school board members from testifying about their decisions to remove the books. The Eleventh Circuit affirmed the district court, holding that the board members’ votes to remove specific books, as applications of existing policy to individual cases, were administrative rather than legislative acts. Therefore, legislative privilege did not bar their depositions regarding those specific removal decisions. The court emphasized its holding was limited to the particular facts of this case and did not address whether other privileges or rules might limit such discovery. View "Pen American Center, Inc. v. Adams" on Justia Law

Holy Trinity Ukrainian Catholic Church v. Township of Collier

2026-10-19T09:00:04-08:00

A Ukrainian Catholic parish near Pittsburgh owns two plots of land, one containing its church and the other, a cemetery and mausoleum. The parish sought to build a large shrine dedicated to Mary and the sanctity of life on its second plot in Collier Township, but the township’s zoning code did not allow such a use. The parish applied to amend the code and rezone its land to facilitate the project, submitting plans and a traffic study. After a public hearing, the township’s Board of Commissioners denied the application, citing traffic concerns, fundraising issues, and objections to the shrine’s pro-life message. The parish then proposed a smaller chapel, which was approved but with restrictive conditions. Initially, the parish appealed in state court, but it abandoned that appeal to file a federal lawsuit, alleging violations of the First Amendment and RLUIPA. The U.S. District Court for the Western District of Pennsylvania reviewed the parish’s motion for a preliminary injunction. The court denied the motion, reasoning that the parish was not substantially likely to succeed on the merits, the requested relief was unclear, and granting an injunction would disrupt the status quo rather than preserve it. The court also found that no injunction was necessary to keep the case viable. The United States Court of Appeals for the Third Circuit reviewed the District Court’s denial of the preliminary injunction. Applying a deferential standard, the Third Circuit affirmed the denial, holding that although the parish had a strong likelihood of success on its RLUIPA substantial-burden claim, it failed to demonstrate irreparable harm or the necessity of preliminary relief. The court emphasized that preliminary injunctions are meant to preserve the status quo pending trial, not to grant final relief. The denial was affirmed. View "Holy Trinity Ukrainian Catholic Church v. Township of Collier" on Justia Law

Holtz v. Moreles

2026-10-16T11:32:03-08:00

Santa Clara County’s Board of Supervisors responded to significant anticipated federal funding cuts, stemming from Congress’s enactment of H.R. 1, by declaring an emergency and calling for a special election to seek voter approval for Measure A—a five-year general sales tax increase. The Board determined that these federal cuts would have an immediate and severe impact on healthcare and social safety net services for county residents, and that waiting until the next general election would result in deep service reductions. The Board’s resolution outlined detailed findings about the emergency’s nature and magnitude, and the measure was placed before voters in a special election. Prior to the election, individual county residents challenged the legal sufficiency of the emergency declaration in the Superior Court of Santa Clara County. They argued that the “cases of emergency” exception in article XIII C, section 2 of the California Constitution was improperly applied, and that the measure’s ballot question and impartial analysis were not impartial or accurate as required by the Elections Code. After expedited proceedings, the trial court denied their petition regarding the emergency declaration but ordered agreed-upon modifications to some ballot language. On appeal, the California Court of Appeal, Sixth Appellate District, held that the “cases of emergency” clause should be interpreted according to its ordinary meaning—referring to unforeseen circumstances requiring immediate action—and does not require a narrow or specially defined scope. The court found that the Board’s resolution and findings provided sufficient factual basis for the emergency declaration and that the trial court’s handling of judicial notice, even if imperfect, was not prejudicial. The court declined to address arguments about the specific ballot language or impartial analysis, finding those issues moot. The judgment denying the writ was affirmed. View "Holtz v. Moreles" on Justia Law

Doe v. Catholic Relief Services

2026-10-16T10:30:13-08:00

An IT analyst who is openly gay was hired by a large, Catholic-affiliated nonprofit based in Maryland. At the time of hiring, he was told his husband would be covered under the organization’s dependent health benefits. However, several months after his employment began, the organization informed him that providing benefits to his same-sex spouse was contrary to its religious beliefs and terminated those benefits. The employee declined alternative compensation and ultimately resigned from the organization after several years. The employee sued in the United States District Court for the District of Maryland, bringing claims under federal and state employment discrimination laws, including Title VII, the Equal Pay Act, and the Maryland Fair Employment Practices Act (MFEPA). The district court granted summary judgment for the employee on the Title VII and Equal Pay Act claims and, after certifying questions to the Maryland Supreme Court regarding the scope of the MFEPA’s religious exemption, held a bench trial and entered judgment for the employee on the remaining MFEPA claim. The parties stipulated to damages, but the employer reserved the right to appeal on liability. The United States Court of Appeals for the Fourth Circuit reviewed the employer’s statutory and constitutional defenses. The court held that Title VII’s religious employer exemption does not shield religious organizations from liability for discrimination based on sex, even if the employment decision is rooted in religious belief. Similarly, under MFEPA, the court found the exemption applies only to employees whose duties directly further the core mission of the organization; the employee’s roles did not meet this test. The court also held that the Religious Freedom Restoration Act does not apply to suits between private parties. Constitutional arguments based on the First Amendment’s Religion Clauses and church autonomy doctrine were rejected as grounds for immunity. The Fourth Circuit affirmed the district court’s judgment on Title VII and MFEPA claims and dismissed the Equal Pay Act appeal as moot. View "Doe v. Catholic Relief Services" on Justia Law

GH America v. Fohn

2026-10-16T09:30:07-08:00

A Texas-based energy company, structured as a subsidiary of a Chinese corporation, sought to develop renewable energy projects in Texas, including the Blue Star Solar Project, and to interconnect these projects to the Texas electric grid managed by the Electric Reliability Council of Texas (ERCOT). The Texas Lone Star Infrastructure Protection Act (LSIPA), enacted in 2021, prohibits entities majority-owned or controlled by Chinese citizens or corporations from owning or controlling critical infrastructure, including the state’s electric grid. In 2022, ERCOT, applying LSIPA, denied the company’s request to interconnect the Blue Star project and rejected subsequent efforts to repurpose the project. The company sued in the United States District Court for the Western District of Texas, arguing that LSIPA was preempted by federal law—specifically, the Committee on Foreign Investment in the United States (CFIUS) regime under the Defense Production Act and its amendments. The company also asserted constitutional claims, but ultimately narrowed its appeal to the preemption issue. The district court dismissed the claims, holding that LSIPA was not preempted by the federal CFIUS regime, finding no conflict or field preemption. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed. The Fifth Circuit held that the federal CFIUS regime does not impliedly preempt LSIPA. The court found that LSIPA and CFIUS operate in purposive harmony, with LSIPA providing additional state-level protections without conflicting with federal objectives. The court also held that CFIUS is not a pervasive federal regulatory scheme that would field-preempt state law in this area. Accordingly, the Fifth Circuit affirmed the district court’s dismissal of the preemption claims. View "GH America v. Fohn" on Justia Law

United States v. Cook

2026-10-16T09:00:07-08:00

Antoine Cook was arrested after his then-girlfriend, E.C., contacted his parole officer and reported both his arrest for domestic violence and their recent drug use. When parole officers arrived at the hotel, E.C. had Cook’s cell phone and stated it was her only means of communication. She provided the officers with the phone’s passcode and consented to their request to search the device. On the phone, officers found incriminating images and videos depicting drugs and firearms. Based on this evidence and a subsequent consent search of the hotel room, officers discovered ammunition and controlled substances. The United States District Court for the Northern District of Ohio denied Cook’s motion to suppress evidence obtained from the cell phone, holding that Cook’s parole conditions permitted warrantless searches. The district court also rejected Cook’s challenges regarding the authority to consent to the phone search and permitted the evidence from the hotel room. Cook was later convicted by a jury on counts of possessing methamphetamine and cocaine with intent to distribute, and being a felon in possession of ammunition. He appealed, arguing improper denial of the suppression motion, ineffective assistance of counsel, and judicial bias. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that E.C. had common authority over the cell phone and could consent to its search, obviating the need to consider parole-based search arguments. The court also found no plain error in the seizure of the phone, as officers had probable cause and Cook’s possessory interest was not meaningfully interfered with while he was in custody. The court declined to address the ineffective assistance of counsel claim due to an insufficient record and found no evidence of judicial bias by the district judge. View "United States v. Cook" on Justia Law

In re: State of Alabama v. Marquette

2026-10-16T05:30:57-08:00

A police officer in Decatur, Alabama, was involved in a fatal shooting that occurred while a tow-truck driver attempted to repossess a vehicle from a homeowner’s property. The tow-truck driver had experienced a prior confrontation with the homeowner, who allegedly pointed a gun at him and ordered him to leave. When the tow-truck driver returned with several police officers prepositioned for safety, the homeowner again emerged armed and pointed his gun, first at the tow-truck driver and then in the direction of one of the officers. The officer fired, resulting in the homeowner’s death. After being indicted for murder, the officer moved for pretrial dismissal, claiming statutory immunity under Alabama’s defense-of-persons statute, which justifies the use of force under certain conditions and provides for immunity from prosecution if the statute’s requirements are met. The Morgan Circuit Court held a pretrial hearing but denied the motion, reasoning that the peace-officer-specific use-of-force statute was the applicable law rather than the more general defense-of-persons statute. The court focused on whether the officer acted as a “reasonable police officer” and whether he was acting within the scope of his police authority, ultimately setting the case for trial but staying proceedings pending appellate review. The Alabama Court of Criminal Appeals affirmed this approach, also applying the peace-officer statute. The Supreme Court of Alabama reviewed the case and determined that the lower courts had applied the incorrect legal standard by relying on the peace-officer statute instead of the defense-of-persons statute. The Supreme Court held that the officer had a clear legal right to have his immunity claim evaluated under the defense-of-persons statute, which applies to all persons, not just police officers, and provides for pretrial immunity. The Court issued a writ of mandamus, directing the circuit court to vacate its previous order and reevaluate the officer’s claim under the correct statute. View "In re: State of Alabama v. Marquette" on Justia Law

Holmes v Neal

2026-10-15T13:00:07-08:00

Eric Holmes was convicted by an Indiana jury in 1992 of two counts of murder, attempted murder, robbery, and conspiracy to commit robbery, stemming from an incident at a restaurant. During sentencing, the jury could not unanimously recommend the death penalty, so the trial judge, as allowed by Indiana law at the time, found aggravating circumstances and imposed a death sentence. Holmes exhausted his direct appeals and post-conviction relief in state court, then filed a federal habeas corpus petition. While that federal petition was pending, Indiana amended its death penalty statute in 2002 to require jury findings on aggravating circumstances, in response to Apprendi v. New Jersey and Ring v. Arizona. In Saylor v. Indiana, the Indiana Supreme Court vacated a death sentence for a defendant whose jury had unanimously recommended against death, holding it inappropriate to execute someone sentenced under the old procedure. Holmes sought similar relief in state court, but the Indiana Supreme Court denied his request, distinguishing his case because his jury had not reached a recommendation at all, as opposed to Saylor’s unanimous recommendation against death. Holmes then filed a second federal habeas petition in the United States District Court for the Southern District of Indiana, claiming the Indiana Supreme Court’s decision violated his Fourteenth Amendment rights to equal protection. The district court dismissed the petition as “second or successive,” lacking jurisdiction. On appeal, the United States Court of Appeals for the Seventh Circuit disagreed with the district court’s procedural ruling, finding Holmes’s equal protection claim was not “second or successive” because it was not ripe during his first petition. However, the court affirmed the dismissal on the merits, holding the Indiana Supreme Court had a rational basis for treating Holmes differently, since his jury had not reached a unanimous recommendation, and thus there was no Equal Protection violation. View "Holmes v Neal" on Justia Law

USA V. LE

2026-10-15T08:00:19-08:00

Three individuals departed from Dana Point Harbor in Southern California at night, ostensibly for a lobster-fishing trip. When the boat returned, one person was missing, and his body was later found floating in the ocean with evidence of drowning, gunshot wounds, and blunt force trauma. Location data placed the incident within three nautical miles of the California coast. The surviving participants did not report the death. Following an investigation, federal authorities charged one of the surviving individuals with first-degree murder, conspiracy to commit murder, and possession of a firearm in furtherance of murder. The United States District Court for the Central District of California heard the case. The defense argued that the federal government lacked jurisdiction because the death occurred within the three-nautical-mile territorial sea, which they claimed was under California's exclusive criminal jurisdiction. The district court rejected this argument, finding that federal jurisdiction extended twelve nautical miles from shore under the Antiterrorism and Effective Death Penalty Act of 1996. At trial, the jury was instructed accordingly and convicted the defendant on all counts. During jury deliberations, a juror experiencing distress and mental health concerns, which were linked to pressure from other jurors regarding the verdict, was excused and replaced by an alternate, with the agreement of both parties. The reconstituted jury returned guilty verdicts. On appeal, the United States Court of Appeals for the Ninth Circuit held that the federal government’s jurisdiction under Title 18 did extend to the first three nautical miles from shore. However, the appellate court found that the removal of the juror violated the defendant’s Sixth Amendment right to a unanimous jury verdict because her dismissal stemmed from her views on the merits of the case. The Ninth Circuit vacated the convictions and remanded the case for further proceedings. View "USA V. LE" on Justia Law

Munoz v. The State of Wyoming

2026-10-15T07:19:48-08:00

A 17-year-old individual was charged as an adult for the shooting death of a 15-year-old girl during a drive-by incident at a public park in Cheyenne, Wyoming. The evidence showed that the defendant was the front passenger in an SUV from which shots were fired into a group of teenagers. Investigators recovered shell casings and the fatal bullet, and testimony indicated the victim was killed by a bullet likely fired from the defendant’s position. While the defendant denied involvement and claimed no one in the SUV had a gun, multiple witnesses and forensic analysis pointed to his participation. The District Court of Laramie County denied the defendant’s motion to transfer the case to juvenile court, citing the seriousness of the offense, lack of adequate juvenile facilities, and insufficient evidence for rehabilitation within the juvenile system. At trial, the jury was instructed on both the charged offenses and lesser included offenses. The jury acquitted the defendant of first-degree murder and conspiracy but convicted him of second-degree murder. The defendant was sentenced to 25–35 years imprisonment. He subsequently filed two post-conviction motions under Wyoming Rule of Appellate Procedure 21, alleging ineffective assistance of counsel for failures at the juvenile transfer hearing, trial, and sentencing. The district court denied these motions. On consolidated appeal to the Supreme Court of Wyoming, the defendant argued sufficiency of evidence, error in jury instructions regarding transferred intent, and that Article 1, Section 10 of the Wyoming Constitution required a stricter standard for ineffective assistance claims than the federal Sixth Amendment. The Supreme Court of Wyoming affirmed the conviction and denial of post-conviction relief. The court held that the evidence was sufficient for second-degree murder, the jury instruction on transferred intent was not plainly erroneous, Article 1, Section 10 does not require a more protective prejudice standard than Strickland, and the defendant was not denied effective assistance of counsel. View "Munoz v. The State of Wyoming" on Justia Law

State v. Jeffries-Porter

2026-10-15T07:19:35-08:00

The case concerns an individual who pleaded guilty to first degree child molestation and was sentenced to prison and a term of community custody. As a part of his community custody conditions, the trial court prohibited him from possessing or accessing “sexually exploitive materials (as defined by Defendant’s treating therapist or [Community Corrections Officer]).” The condition did not define “sexually exploitive materials,” nor did it reference any statute or provide illustrative examples. The defendant argued that this condition was unconstitutionally vague. The Washington Court of Appeals, in a split decision, upheld the condition. The majority reasoned that two statutes—though not referenced in the condition or the defendant’s proceedings—could provide sufficient clarity as to what “sexually exploitive materials” meant. The dissent, however, found that the phrase was undefined, not clarified by the referenced statutes (which described different crimes or phrases), and thus failed to give ordinary people notice of what conduct was prohibited. The Supreme Court of the State of Washington reviewed the case. The court concluded that the community custody condition was unconstitutionally vague because it did not define “sexually exploitive materials,” provide statutory or case law definitions, or include clarifying examples. The court emphasized that due process requires conditions to be clear enough for an ordinary person to understand what is prohibited and to protect against arbitrary enforcement. Furthermore, because the condition implicated First Amendment rights, it also had to be narrowly tailored and directly related to the state’s goals of public safety and rehabilitation. The court found that the condition failed these requirements and reversed the Court of Appeals, remanding the case for further proceedings. The court held specifically that the condition as written does not provide constitutional notice, does not protect against arbitrary enforcement, and is not narrowly tailored. View "State v. Jeffries-Porter" on Justia Law

Jones v. State of Florida

2026-10-15T07:08:16-08:00

In this case, the defendant was convicted and sentenced to death for a 2003 murder. The victim, a young man, was found strangled and stabbed in a motel room. The defendant had worked with the victim and became a suspect when his vehicle matched that associated with another double homicide. Physical evidence included a hair and shoe impressions linking the defendant to the scene. The prosecution also presented evidence of the defendant’s involvement in other similar murders. At trial, the State argued that the murder involved sadistic sexual assault, relying in part on DNA evidence found on the victim, which was attributed to another individual living at the motel. Following the conviction, the defendant sought postconviction relief in the Circuit Court, arguing, among other things, that the State had withheld evidence in violation of Brady v. Maryland. The evidence in question consisted of Florida Department of Law Enforcement (FDLE) call logs indicating that analysts believed the DNA found was unlikely to be the result of secondary transfer, contrary to the State’s theory at trial. The postconviction court found that this evidence was withheld and was favorable to the defense, but concluded it was not exculpatory and denied relief. The Supreme Court of Florida reviewed the appeal. The Court held that the State violated its obligations under Brady by suppressing material impeachment evidence regarding the likelihood of secondary DNA transfer. The undisclosed evidence could have impeached key State witnesses and undermined the prosecution’s theory. The Court found that the suppressed evidence was material and that its absence prejudiced the defendant, creating a reasonable probability of a different verdict. Accordingly, the Supreme Court of Florida reversed the postconviction court’s denial of relief, set aside the conviction, and remanded for a new trial. View "Jones v. State of Florida" on Justia Law

GULLEY v. JEFFREY

2026-10-15T07:01:16-08:00

Kristina Gulley, who previously served as justice of the peace for District 10 in Pulaski County, Arkansas, sought reelection after having been disqualified in earlier proceedings due to two prior misdemeanor hot-check convictions from 1997 and 2003. Multiple prior legal actions had resulted in findings that these convictions constituted “infamous crimes” under article 5, section 9 of the Arkansas Constitution, rendering her ineligible to run for or hold public office. Despite these rulings, Gulley again filed as a candidate in the 2026 primary election. Registered voters in the district challenged her eligibility, seeking a declaratory judgment and writ of mandamus to prevent her name from appearing on the ballot and to prohibit counting any votes cast for her. The Pulaski County Circuit Court held an expedited hearing, denied Gulley’s requests for a continuance and for relief from judgment, and reaffirmed her ineligibility based on the prior convictions. The court found that neither the sealing of her record nor a gubernatorial pardon restored her eligibility to run for office, and it ordered the Board of Election Commissioners not to certify her as a candidate or count votes for her. Gulley appealed, challenging the circuit court’s findings on factual and constitutional grounds. However, she did not obtain a stay of the court’s order or the certification of the election results. Upon review, the Supreme Court of Arkansas determined that the appeal was moot because the March 2026 primary election had already occurred, and the election results had been certified. The court held that no effective relief could be granted as to the election in question, and none of the recognized exceptions to the mootness doctrine applied. Accordingly, the Supreme Court of Arkansas granted the motion to dismiss the appeal as moot and dismissed the case. View "GULLEY v. JEFFREY" on Justia Law

NetChoice v. Attorney General, State of Georgia

2026-10-15T04:30:22-08:00

A recently enacted Georgia law restricts minors’ ability to create accounts on social media platforms. The statute requires covered platforms to verify users’ ages, prohibits minors under sixteen from creating accounts without parental consent, and limits how personal data may be used for advertising to minors. The law defines “social media platform” broadly, but includes numerous exceptions for platforms with different primary functions. An internet trade association, representing major social media companies, challenged the law before its effective date, arguing that it violates the First Amendment, is unconstitutionally vague, and is preempted by Section 230 of the Communications Decency Act. The United States District Court for the Northern District of Georgia granted a preliminary injunction, preventing enforcement of the law. The court found that the association had associational and third-party standing, that the law was likely a content-based speech restriction failing strict scrutiny, was unconstitutionally vague, and was preempted by federal law. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the association had standing and whether it demonstrated a likelihood of success on the merits. The circuit court held that the association had associational standing to challenge the law on behalf of its members. However, the court concluded that the association failed to meet the burden required for a facial First Amendment challenge under the standard set forth in Moody v. NetChoice, LLC, because it did not adequately address the full range of the law’s applications and did not demonstrate that unconstitutional applications substantially outweighed constitutional ones. The court also found that the vagueness and Section 230 preemption claims were unlikely to succeed. The Eleventh Circuit affirmed the standing determination, vacated the preliminary injunction, and remanded the case for further proceedings. View "NetChoice v. Attorney General, State of Georgia" on Justia Law

Computer & Communications Industry Association v. Attorney General, State of Florida

2026-10-14T10:00:27-08:00

Florida enacted a statute (HB3) restricting minors’ access to social media platforms that employ certain “addictive features,” such as infinite scrolling, push notifications, and auto-play. Platforms meeting defined criteria—including algorithmic content selection and significant minor usage—must prohibit account creation by those under 14 and require parental consent for those aged 14–15. The Computer & Communications Industry Association and NetChoice, representing affected platforms, challenged the law on First Amendment grounds, asserting both facial and as-applied claims. The United States District Court for the Northern District of Florida initially denied a preliminary injunction for lack of associational standing, but after the plaintiffs amended their complaint and renewed their motion, the court granted a preliminary injunction. The district court found that the trade groups had standing, abstention under Younger v. Harris was unwarranted, and that although HB3 was a content-neutral regulation, it was insufficiently tailored to survive intermediate scrutiny, thus likely unconstitutional. On appeal, the United States Court of Appeals for the Eleventh Circuit first held that the plaintiffs had associational standing to challenge HB3 on behalf of their members. The court also determined that the district court properly declined to abstain under Younger because substantial proceedings had already occurred in federal court before the state enforcement action was initiated. Addressing the merits, the Eleventh Circuit concluded that HB3 is a content-neutral regulation implicating the First Amendment, but it likely survives intermediate scrutiny due to its age-based tailoring and focus on addictive features. The court rejected the facial challenge, holding that the plaintiffs had not demonstrated, as required by Moody v. NetChoice, LLC, that HB3’s unconstitutional applications substantially outweighed its constitutional ones. The disposition affirmed in part, reversed in part, vacated in part, and remanded for further proceedings. View "Computer & Communications Industry Association v. Attorney General, State of Florida" on Justia Law

VoteAmerica v. Schwab

2026-10-14T10:00:25-08:00

Two nonprofit organizations dedicated to increasing voter participation, especially among underrepresented groups, sent mail ballot applications to Kansas voters during the 2020 election. These mailings included applications that had been partially prefilled with voter information obtained from public and commercial sources. Due to outdated or inaccurate data, many applications contained errors, leading to voter confusion and administrative burdens for local election officials who had to process erroneous or duplicate applications and respond to concerned voters. Following this experience, the Kansas legislature enacted a law prohibiting private entities from mailing partially prefilled advance ballot applications to registered voters. The nonprofits challenged the law in the United States District Court for the District of Kansas, arguing that it infringed on their First Amendment rights. The district court initially enjoined enforcement of the law, but the United States Court of Appeals for the Tenth Circuit reversed and remanded, instructing the district court to apply intermediate scrutiny unless it found the law was enacted with an improper purpose. On remand, the district court found that the Kansas legislature had acted with an improper purpose, concluded that strict scrutiny should apply, and again enjoined the law. On the second appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s findings de novo. The appellate court held that the district court erred in finding improper legislative intent, as there was no sufficient evidence in the law’s text, justifications, or legislative history to support that conclusion. Applying intermediate scrutiny, the Tenth Circuit found that the law served significant governmental interests—minimizing voter confusion, facilitating efficient election administration, and fostering confidence in elections—and was narrowly tailored to those interests without substantially burdening protected speech. Consequently, the Tenth Circuit reversed the district court’s judgment. View "VoteAmerica v. Schwab" on Justia Law

State v. Pendleton

2026-10-14T09:32:36-08:00

The case involved a traffic stop of Shawna Rae Pendleton in October 2021 due to expired vehicle registration. Officer Miller and his drug dog, Edo, were called to conduct a free-air sniff around Pendleton’s vehicle. During the sniff, Edo closely investigated the vehicle doors and briefly touched the exterior handle of at least one door with the tip of his nose before alerting to the presence of illegal drugs. A subsequent search of the vehicle revealed methamphetamine, marijuana, alprazolam, and drug paraphernalia, resulting in Pendleton’s arrest and charges for possession offenses. Pendleton moved to suppress the evidence, arguing that Edo’s brief contact with her vehicle constituted a trespass, transforming the sniff into an unlawful search under the Fourth Amendment. The District Court of the Fourth Judicial District in Ada County agreed with Pendleton, relying on State v. Dorff and finding that Edo’s contact amounted to intermeddling and a trespass for the purpose of obtaining information. The court granted the motion to suppress. The State appealed, and the Idaho Court of Appeals reversed, determining the contact was not trespassory and that Edo’s alert prior to contact provided probable cause for the search. Pendleton petitioned for review, which the Idaho Supreme Court granted. The Supreme Court of the State of Idaho held that Edo’s momentary and minimal contact with the vehicle did not rise to the level of intermeddling and therefore was not trespassory. The Court concluded that such brief contact did not meaningfully interfere with Pendleton’s possessory interest in the vehicle. Absent a trespass, the sniff did not constitute a search within the meaning of the Fourth Amendment. The district court’s order suppressing the evidence was reversed and the case remanded for further proceedings. View "State v. Pendleton " on Justia Law

Estate of Stinson v. Streicher

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

A Milwaukee County Sheriff’s deputy, while on duty and driving his unmarked vehicle, caused a fatal collision after running a red light at a controlled intersection. The deputy failed to notice the light change because he was distracted—looking at either his cellphone or his dashboard computer—for over 15 seconds as he approached the intersection. He was traveling at or just below the speed limit at the time. The victim, Ceaser Stinson, was lawfully passing through the intersection when his vehicle was struck and he was killed. Investigations confirmed the deputy’s inattention as the cause of the accident. Following the crash, Stinson’s estate filed a lawsuit in state court against the deputy, Milwaukee County, and the county’s insurer, alleging, among other claims, a violation of Stinson’s substantive due process rights under 42 U.S.C. § 1983. After removal to the United States District Court for the Eastern District of Wisconsin, the court dismissed some claims but permitted the estate’s § 1983 claim against the deputy to proceed. The defendants moved for summary judgment, arguing that the deputy’s conduct did not meet the threshold for a constitutional violation and that he was entitled to qualified immunity. The district judge denied the motion, concluding that a jury should decide whether the conduct was egregious enough to violate due process and deferred ruling on qualified immunity until after a jury verdict. The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the estate failed to show the deputy acted with deliberate indifference to a known and imminent harm, as required for a substantive due process violation. The court further held that it was not clearly established that distracted driving by a law enforcement officer violates due process. Accordingly, the court reversed the district court’s judgment and ordered entry of judgment in favor of the deputy, finding him entitled to qualified immunity. View "Estate of Stinson v. Streicher" on Justia Law

USA V. STATE OF CALIFORNIA

2026-10-14T08:00:16-08:00

California enacted the No Vigilantes Act, which, among other things, requires any non-uniformed federal law enforcement officer operating in the state to visibly display identification showing their agency and either a name or badge number while performing enforcement duties. This requirement, codified at California Penal Code § 13654, applies broadly to federal officers, subject to narrow exceptions, and provides for criminal penalties for willful violations. The Act also allows agencies to avoid these requirements by publicly posting a written identification policy that complies with the statute. After the Act was passed, the United States filed a lawsuit in the United States District Court for the Central District of California, challenging the constitutionality of the identification requirement before it had been enforced. The United States argued that the law violated the Supremacy Clause by directly regulating federal law enforcement operations. The district court denied the United States’ request for a preliminary injunction against enforcement of the identification requirement, finding the government had not shown that California’s law interfered with or controlled federal operations to a degree that would render it unconstitutional. The district court did, however, grant partial relief under a different statute, and ruled that the United States lacked standing to challenge other provisions. On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s denial of a preliminary injunction. The Ninth Circuit concluded that the United States was certain to succeed on its Supremacy Clause claim because the Act directly regulated federal operations without congressional authorization, in violation of intergovernmental immunity. The court held that no set of circumstances existed under which the challenged requirement would be valid, and that the other factors for preliminary injunctive relief also favored the United States. The Ninth Circuit ordered the district court to enter a preliminary injunction barring enforcement of the identification requirement against the United States, its agencies, and officers. View "USA V. STATE OF CALIFORNIA" on Justia Law

DANIELS v. THE STATE

2026-10-14T04:04:12-08:00

The case concerns a fatal shooting that took place on a MARTA train in April 2017. The defendant and the victim had previously lived together with the defendant’s girlfriend, after which the defendant accused the victim of stealing their money, personal items, and drugs. Several months later, after an earlier confrontation at a mall, the defendant encountered the victim and others on a train. Surveillance video and eyewitnesses established that the defendant boarded after the victim, lay in wait, then ambushed and fatally shot the victim, also wounding several passengers. The defendant was apprehended at the station and identified by eyewitnesses, and ballistic evidence connected the firearm he possessed to the shooting. Following indictment in the Superior Court of Fulton County, the defendant was tried by jury and found guilty of malice murder, armed robbery, aggravated assault, and firearms offenses. He received a life sentence without parole plus additional years. After trial, the defendant filed a motion for new trial, which was denied. He then appealed to the Supreme Court of Georgia. On appeal, the Supreme Court of Georgia reviewed the defendant’s claims that the trial court erred by refusing to instruct the jury on voluntary manslaughter and that trial counsel was constitutionally ineffective. The Supreme Court held that any error in failing to give the voluntary manslaughter instruction did not affect the outcome due to the strength of the evidence supporting malice murder and the lack of sufficient evidence of provocation. The Court also found that trial counsel’s performance was not deficient for not objecting to the omitted instruction, given the strategic decision to pursue a misidentification defense. The ineffective assistance claim regarding stipulation to felony status was deemed waived because it was not timely raised. The Supreme Court of Georgia affirmed the judgment. View "DANIELS v. THE STATE" on Justia Law

GARDEI v. TAYLOR

2026-10-14T04:04:09-08:00

An individual who was convicted in Arizona for several sexual offenses moved to Georgia after completing his sentence and registration period in New Mexico. Upon arrival in Georgia, he was advised by law enforcement that he would need to register as a sex offender under Georgia law. After several years, he sought removal from the registry, arguing that he had fulfilled his obligations elsewhere, that the crimes for which he was convicted did not require registration in Georgia, and that continued enforcement of the registry against him violated his constitutional rights. The Superior Court of DeKalb County initially dismissed his petition for declaratory relief, finding it time-barred under the two-year statute of limitations for personal injury actions. The Court of Appeals affirmed this dismissal. The Supreme Court of Georgia later reversed, holding that his claims for prospective relief had not accrued and thus were not time-barred, and remanded the case. On remand, after further amendments and substitution of parties, the trial court dismissed the petition again, this time as moot, citing recent revisions to Georgia’s Registry Act which provided a statutory mechanism for requesting removal from registration requirements. The Court of Appeals affirmed the dismissal, but on the alternative ground that any decision would be an impermissible advisory opinion since only prospective relief was sought. The Supreme Court of Georgia reviewed the case and held that seeking prospective relief in a declaratory judgment action is not grounds for dismissal as an impermissible advisory opinion. The Court vacated the Court of Appeals' judgment and remanded the case for further proceedings consistent with its opinion, directing the Court of Appeals to address whether the trial court’s dismissal on mootness grounds was proper and, if not, to instruct the trial court to adjudicate the merits of the declaratory judgment claim. View "GARDEI v. TAYLOR" on Justia Law

In re: T.J.

2026-10-13T15:01:55-08:00

After reports and investigations of sexual abuse allegations against a father, the State’s Department of Human Services (DHS) petitioned for foster custody of his children. The family court consolidated the cases, and in September 2024, it issued orders granting DHS foster custody and incorporating a Service Plan that required the father to participate in sex abuse treatment. Importantly, the plan mandated that he “acknowledge and take responsibility for the sexual abuse to his victims” as a condition of successful completion. The father appealed these orders to the Intermediate Court of Appeals of Hawai‘i (ICA), which affirmed the family court's decision. Due to complications with his legal representation, the father’s application for writ of certiorari to the Supreme Court of Hawai‘i was filed late, but the Supreme Court agreed to consider the merits, recognizing his constitutional right to counsel in parental rights termination proceedings. The Supreme Court of Hawai‘i reviewed whether the State can require a parent, as part of mandated rehabilitation therapy in child custody proceedings, to make incriminating disclosures. The court held that under Article I, Section 10 of the Hawai‘i Constitution, the State may not require a parent to admit to criminal misconduct as a condition of completing court-ordered therapy, as this violates the privilege against self-incrimination. However, the court clarified that if a parent’s silence or refusal to admit abuse hinders effective therapy, the court may consider that as a factor in custody determinations without violating the constitutional privilege. The court vacated the lower courts’ orders to the extent they required the father to admit to sexual abuse, and remanded for further proceedings consistent with its opinion. The lower courts’ orders were otherwise affirmed. View "In re: T.J." on Justia Law

Gateway Conservation Alliance v. State

2026-10-13T14:05:50-08:00

Gateway Conservation Alliance challenged the Montana Department of Environmental Quality’s (DEQ) issuance of an opencut mining permit to TMC, Inc. for a site in Gallatin County. After DEQ approved the permit, Gateway filed an administrative appeal with the Board of Environmental Review, alleging violations of environmental statutes related specifically to the permit and site. While that administrative appeal was pending, Gateway also filed a complaint in the Gallatin County District Court, arguing that recent legislative amendments (HB 599) to the governing mining statute violated Montana’s constitutional right to a clean and healthful environment. Gateway sought a declaration of unconstitutionality, an injunction against enforcement, and vacatur of the permit. The District Court for the Eighteenth Judicial District dismissed Gateway’s complaint, holding that Gateway had failed to exhaust its administrative remedies before seeking judicial review, as required under the Montana Administrative Procedure Act (MAPA). The District Court reasoned that Gateway’s constitutional challenge was not a pure facial attack on the administrative scheme itself, but was instead tied to the specific permit at issue, and thus did not fall within any exception to the exhaustion requirement. On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal. The Supreme Court held that a party challenging an agency decision governed by MAPA must first complete the administrative process and obtain a final agency decision before seeking judicial review, even if the challenge includes constitutional claims. The only exception recognized is for pure facial constitutional challenges to the administrative process itself, which was not present here. The Court concluded that Gateway’s claims could be raised on judicial review after exhausting administrative remedies, but not before. The order of dismissal was affirmed. View "Gateway Conservation Alliance v. State" on Justia Law

Alawieh v. Mullin

2026-10-13T12:30:03-08:00

A Lebanese citizen who worked as a physician and educator in the United States traveled to Lebanon to visit family and, upon her return to Boston Logan International Airport, was detained by Customs and Border Protection (CBP) officers. During inspection, officers reviewed her phone and found photos and videos related to Hezbollah, which is designated as a foreign terrorist organization by the United States. She acknowledged deleting some of the photos before her arrival, explained her religious motivations and familial connections, and denied supporting Hezbollah’s political or military activities. After an interview, CBP officers determined she was inadmissible as an immigrant without valid documents because her intentions could not be verified due to derogatory information found during inspection. She was issued an expedited removal order, her H-1B visa was revoked, and she was returned to Lebanon, subject to a five-year bar on reentry. The United States District Court for the District of Massachusetts dismissed her amended habeas corpus petition for lack of jurisdiction, finding that the Immigration and Nationality Act (INA) strips federal courts of jurisdiction to review expedited removal orders except in narrow circumstances not present in her case. The district court also concluded that the Suspension Clause did not preserve jurisdiction for her claims and that her remaining arguments fell outside the scope of habeas review permitted under the INA. The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that it lacked jurisdiction to review the petitioner’s challenge to the expedited removal order and the revocation of her visa because her claims did not fall within the exceptions enumerated in 8 U.S.C. § 1252(e)(2). The court further concluded that the Suspension Clause did not require broader habeas review in these circumstances and rejected arguments that her case was distinguishable from binding Supreme Court precedent. View "Alawieh v. Mullin" on Justia Law

Williams v. Attorney General

2026-10-13T11:00:04-08:00

Edward Williams was convicted in Pennsylvania for driving under the influence of alcohol at the “highest rate,” a crime punishable by up to five years in prison due to a prior DUI offense. He was sentenced to home confinement for ninety days to two years, but his conviction triggered 18 U.S.C. § 922(g)(1), which prohibits firearm possession by anyone convicted of a crime punishable by more than one year of imprisonment. Williams continued to possess firearms until learning of the prohibition, after which he divested himself of firearms and refrained from further possession. The United States District Court for the Eastern District of Pennsylvania reviewed Williams’s claim that § 922(g)(1), as applied to him, violated the Second Amendment. Both parties moved for summary judgment. The District Court granted summary judgment in favor of Williams, holding that the statute’s application to his nonviolent DUI conviction was unconstitutional under the Second Amendment. The United States appealed this decision. The United States Court of Appeals for the Third Circuit, sitting en banc, affirmed the District Court’s judgment. The Court held that the permanent firearm prohibition imposed by § 922(g)(1) was not consistent with the Nation’s historical tradition of firearm regulation when applied to individuals convicted of nonviolent offenses, such as Williams’s DUI. The Court emphasized that longstanding restrictions targeted individuals who posed a risk of violence or misuse of arms, not felons in general or those convicted of nonviolent conduct. The government failed to show that Williams’s offense or current status justified permanent disarmament under historical analogues. The Court concluded that Williams, as a peaceable citizen who poses no present risk, is constitutionally protected in his right to possess firearms. The District Court’s decision was affirmed. View "Williams v. Attorney General" on Justia Law

TURNER v. OKLAHOMA GRAND RIVER DAM AUTHORITY

2026-10-13T10:11:58-08:00

An employee with a long tenure at a state agency suffered a heart attack and was subject to permanent medical restrictions preventing him from performing his original job duties at a coal-fired power plant. The agency accommodated him for two years with a temporary assignment and ultimately offered him a permanent position that met his medical restrictions, but at a lower hourly wage. The employee did not respond to the offer and was subsequently terminated. The employee sought review of his termination before the Civil Service Division of the Office of Management and Enterprise Services (OMES). An administrative law judge found he failed to meet his burden to prove that the agency had no reasonable basis for his termination, and OMES adopted that decision. The employee then sought judicial review in the District Court of Mayes County, which reversed OMES’s order. The district court found that the employee had a substantial interest in his employment and that the statutory and regulatory procedures for termination under 62 O.S. § 34.301 violated due process. The district court also concluded that the agency lacked a reasonable basis to terminate the employee and ordered further proceedings. The Supreme Court of the State of Oklahoma reviewed the case. It held that the Civil Service Modernization Act does not create a constitutionally protected property interest in continued public employment for state employees, so due process protections are not triggered by terminations under this statute. The Court further held that the district court erred in reweighing the evidence and misapplied the statutory burden of proof: the employee did not prove there was no reasonable basis for his termination. The Supreme Court reversed the district court’s judgment and affirmed OMES’s final agency order upholding the termination. View "TURNER v. OKLAHOMA GRAND RIVER DAM AUTHORITY" on Justia Law

USA v. Bost

2026-10-13T09:00:04-08:00

James Bost previously pleaded guilty to several crimes in Pennsylvania, including terroristic threats, which involved threatening to commit a violent crime with intent to terrorize another. Years after his conviction, Bost was found by police with a stolen pistol while on bail for an unrelated charge. This led to federal charges for possessing a firearm as a felon under 18 U.S.C. § 922(g)(1), and for possessing a stolen firearm under § 922(j). Bost moved to dismiss the indictment, contending that the felon-in-possession law was unconstitutional both on its face and as applied to him, citing his Second Amendment rights. The U.S. District Court for the Western District of Pennsylvania denied Bost’s motion to dismiss. It reasoned that his conviction for terroristic threats sufficed to show he could not be trusted with a firearm and rejected his facial challenge to the statute, finding he could not demonstrate that the law was unconstitutional in every application. Bost then entered a conditional guilty plea, preserving his right to appeal the Second Amendment claims. The United States Court of Appeals for the Third Circuit, sitting en banc, reviewed the District Court’s denial de novo. The Third Circuit held that certain predicate crimes, such as Bost’s conviction for terroristic threats, establish a prima facie risk of physical violence from misuse of firearms and thus justify disarmament under § 922(g)(1). The court concluded that because Bost’s predicate crime involved a threat of physical violence, his disarmament was consistent with the historical tradition of firearm regulation. The court rejected his facial, vagueness, and Commerce Clause challenges, as well as his challenge to the stolen firearm statute. The Third Circuit affirmed the judgment of the District Court. View "USA v. Bost" on Justia Law

USA V. YOUNGBLOOD

2026-10-13T08:00:14-08:00

Dylan Youngblood was arrested in Kalispell, Montana, in September 2023 on an outstanding felony warrant. During the arrest, officers found fentanyl pills on his person and located two pistols, drug paraphernalia, and suspected methamphetamine in his car. Youngblood admitted ownership of one pistol and to having used fentanyl earlier that day. He was indicted for possessing a firearm while being an unlawful user of, and addicted to, a controlled substance, in violation of 18 U.S.C. § 922(g)(3). In the United States District Court for the District of Montana, Youngblood moved to dismiss the indictment, arguing that § 922(g)(3) was unconstitutional both on its face and as applied to him. The district court denied the motion, applying the Second Amendment framework from New York State Rifle & Pistol Ass’n v. Bruen, and found that while Youngblood’s conduct fell within the Second Amendment’s text, the statute’s application to frequent users of methamphetamine and fentanyl was consistent with a historical tradition of temporarily disarming intoxicated individuals. The district court concluded that the statute was both facially and as-applied constitutional. Youngblood then entered a conditional guilty plea, preserving his right to appeal the denial of his motion. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that its prior decision in United States v. Stennerson, which upheld the facial constitutionality of § 922(g)(3), remained binding even after the Supreme Court’s decision in United States v. Hemani, which addressed only an as-applied challenge. The Ninth Circuit also found that Youngblood waived his as-applied challenge by failing to argue it specifically and distinctly in his opening brief. The court affirmed Youngblood’s conviction. View "USA V. YOUNGBLOOD" on Justia Law

Rockett v. Eighmy

2026-10-13T07:30:11-08:00

Two children, whose parents divorced in Missouri, were involved in a custody dispute. After the parents agreed to a custody arrangement, the children refused to leave the courthouse with their mother. Judge Eric Eighmy intervened, escorting the children to a conference room and later to the juvenile division, where repeated threats of foster care failed to persuade them. Ultimately, Judge Eighmy ordered a juvenile officer to lock the children in holding cells for twenty to forty minutes, after which they agreed to leave with their mother. The children’s father brought suit in the United States District Court for the Western District of Missouri, alleging violations of their Fourth Amendment rights under 42 U.S.C. § 1983. Judge Eighmy’s claim for judicial immunity was denied both at the motion-to-dismiss and summary-judgment stages, and the Eighth Circuit previously affirmed that denial in Rockett ex rel. K.R. v. Eighmy, 71 F.4th 665 (8th Cir. 2023). After a trial, the jury found for the children, awarding $5,000 each in damages. The district court resubmitted the damages issue for clarification and ultimately upheld the jury’s award, also granting $326,637.22 in attorney fees. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo and affirmed the district court’s judgment. The court held that Judge Eighmy’s actions constituted an unreasonable seizure in violation of clearly established Fourth Amendment rights. The court also dismissed the appeal regarding judicial immunity, finding it unreviewable due to procedural forfeiture. The Eighth Circuit affirmed the damages and attorney fees awards, finding no abuse of discretion by the district court. The disposition was to dismiss the appeal in part and affirm the district court’s judgments. View "Rockett v. Eighmy" on Justia Law

USA v. Louis

2026-10-13T07:00:22-08:00

The defendant, after serving a prison sentence for a Florida felony drug offense, was released into the state's conditional release program. Three days post-release, he signed a certificate agreeing to various conditions, including submission to searches by his release supervisor. Shortly before his conditional release was scheduled to end, he tested positive for cocaine. The supervisor recommended a warrant for his arrest, which was issued by the Florida Commission on Offender Review. When officers executed the warrant at his residence, the supervisor conducted a warrantless search, finding drugs and a firearm. This led to federal charges including possession of a firearm by a convicted felon and possession with intent to distribute a controlled substance. The United States District Court for the Southern District of Florida denied the defendant’s motion to suppress evidence from the warrantless search, concluding he was still on conditional release at the time and that reasonable suspicion justified the search. The defendant then pleaded guilty to the firearm possession charge. During sentencing, the presentence investigation report recommended a mandatory minimum sentence under the Armed Career Criminal Act (ACCA), listing several prior Florida convictions as possible predicate offenses. The defendant objected, arguing both legally and factually that the convictions did not qualify and that the government had not proven their existence by a preponderance of the evidence. The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s denial of the motion to suppress, holding that the defendant was still subject to conditional release and that the search was supported by reasonable suspicion. However, the appellate court vacated the sentence, finding the district court erred by imposing the ACCA enhancement without requiring the government to prove the necessary predicate convictions. The case was remanded for resentencing without the ACCA enhancement. View "USA v. Louis" on Justia Law

Perrin v. Windham Southeast Supervisory Union

2026-10-13T06:48:51-08:00

A high school principal was terminated by his school district’s board after an internal investigation into allegations that he mistreated a female student over several years and attempted to dissuade staff from making a mandatory report of child abuse. The investigation included interviews with the student, a school counselor, the principal, and other witnesses. The board provided the principal with written notice of the allegations and an opportunity to respond, after which it held a multi-day hearing where both sides presented evidence and witnesses. The board found, by a preponderance of the evidence, that the principal had engaged in inappropriate conduct toward the student and interfered with mandatory reporting obligations, and concluded that there was just and sufficient cause for termination. The principal appealed the dismissal to the Windham Southeast School District Board and, following the board’s decision, filed suit in the Vermont Superior Court, Bennington Unit, Civil Division. He challenged the sufficiency of the evidence, argued that the pre-termination and post-termination processes violated his constitutional rights, and asserted claims of breach of contract, wrongful termination, denial of due process, intentional infliction of emotional distress, and defamation. The civil division dismissed some claims, granted summary judgment to the defendants on the remaining claims, and found that the board’s decision was supported by the record, that the principal was afforded adequate due process, and that no evidence supported claims of bias or other wrongdoing. The Vermont Supreme Court reviewed the case and affirmed the civil division’s decision. The Court held that the principal received constitutionally adequate pre- and post-termination process, that the trial court did not abuse its discretion in denying discovery related to alleged bias, and that sufficient evidence supported the board’s findings and conclusion that just cause existed for dismissal. The Court also found that structural or actual bias claims were either unpreserved or unsupported. View "Perrin v. Windham Southeast Supervisory Union" on Justia Law

State v. Thoen

2026-10-13T05:00:05-08:00

A man was accused of raping his four-year-old granddaughter. After being interviewed by detectives, he confessed to the offense. Initially, he was charged by complaint in municipal court, and the matter was transferred to the Knox County Common Pleas Court. There, he waived his right to an indictment and pleaded guilty to a bill of information charging him with rape of a child under the age of ten, though the plea agreement and colloquy misstated the mandatory penalty for the offense. Under Ohio law, such a charge must be prosecuted by indictment, and the right to indictment cannot be waived. After the trial court accepted his guilty plea but before sentencing, the prosecution realized the error in the charging instrument and moved to dismiss the bill of information. The court granted the motion. The case was then presented to a grand jury, which returned an indictment for the same offense. The defendant pleaded not guilty and moved to dismiss the indictment, arguing that double jeopardy barred further prosecution. The trial court denied this motion, finding that jeopardy had not attached to the guilty plea to the unlawful bill of information. The defendant was found guilty in a bench trial, sentenced to 15 years to life, and his conviction was affirmed by the Fifth District Court of Appeals, which rejected his double-jeopardy argument. The Supreme Court of Ohio reviewed the case and held that jeopardy does not automatically attach when a trial court unconditionally accepts a guilty plea. Instead, whether the Double Jeopardy Clauses bar further proceedings depends on whether the defendant had a legitimate expectation of finality in the plea proceeding and whether concerns of prosecutorial overreach existed. Because the original charging instrument was not authorized by law, the defendant never acquired a legitimate expectation of finality, and double jeopardy protections did not apply. The court affirmed the judgment of the Fifth District Court of Appeals. View "State v. Thoen" on Justia Law

R.H. v. Hayashi

2026-10-09T13:02:21-08:00

A student with severe cognitive disabilities attended a public high school in Hawai‘i and was repeatedly sexually abused by male students, resulting in significant psychological harm, including a psychotic breakdown and persistent post-traumatic stress disorder. The student’s mother, acting for herself and her daughter, sued the State of Hawai‘i, the Department of Education, and school employees for negligence, alleging failure to protect her daughter despite the school’s awareness of her vulnerabilities and repeated warning signs. The evidence at trial showed that school staff recognized the student’s extraordinary vulnerability and received multiple reports of abuse but failed to take reasonable steps to prevent or address it. The Circuit Court of the First Circuit conducted a lengthy bench trial and found the State liable for negligently failing to protect the student, awarding over $14 million in damages to the plaintiffs. However, without a request from the State, the court sua sponte reduced the damages by 30%, attributing that portion of fault to the male students who committed the abuse, citing Hawai‘i Revised Statutes § 663-10.5. The State had not argued at trial that the male students should be apportioned fault; instead, its arguments for apportionment focused on the mother’s alleged negligence, which the court rejected. Plaintiffs moved to amend the judgment to reverse the apportionment, but the court denied the motion. On appeal, the Supreme Court of the State of Hawai‘i held that the circuit court’s sua sponte allocation of fault to the male students violated the plaintiffs’ constitutional due process rights because they lacked notice and an opportunity to be heard on the issue. The court further found insufficient evidence that the male students were “other tortfeasors” under the statute and held that apportionment under HRS § 663-10.5 is an affirmative defense, for which the State bears the burden of pleading and proof. The Supreme Court vacated the apportionment, affirmed the remainder of the circuit court’s judgment, and remanded for entry of an amended judgment awarding plaintiffs the full damages. The State’s cross-appeal regarding discovery and damages was rejected. View "R.H. v. Hayashi" on Justia Law

Miles-El v. Michigan

2026-10-09T09:30:11-08:00

A former Michigan Department of Corrections prisoner with asthma and an alleged allergy to dogs experienced allergic reactions while incarcerated at multiple facilities that housed dogs for training purposes. He reported symptoms such as asthma attacks and respiratory infections to prison officials, who provided prescribed treatments but did not confirm a specific dog allergy. After pursuing the prison’s grievance process, he was moved within the facility but still encountered dogs during required programming. Subsequently, he requested an ADA accommodation to be housed away from dogs, but this was denied due to lack of medical documentation. He later filed suit, alleging violations of the Eighth Amendment, the ADA, the Rehabilitation Act, and state laws. The United States District Court for the Western District of Michigan granted summary judgment in favor of the defendants. The court found that prison officials were not deliberately indifferent to his medical needs under the Eighth Amendment, as they consulted medical staff who did not recommend a transfer based on his condition. For the ADA and Rehabilitation Act claims, the court determined that inadequate medical treatment was not actionable under those statutes and that the plaintiff had not demonstrated denial of prison services or programs due to his disability. The court also declined to exercise supplemental jurisdiction over the state-law claims. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the grant of summary judgment, holding that the prison counselor was entitled to qualified immunity because no clearly established law required the transfer of prisoners with asthma to facilities without dog programs. The court also found that the plaintiff failed to provide sufficient medical documentation to support the necessity of the requested accommodation under the ADA and Rehabilitation Act and did not establish discriminatory animus. The district court’s refusal to exercise supplemental jurisdiction over state-law claims was also affirmed. View "Miles-El v. Michigan" on Justia Law

BLUNT v TOWN OF GILBERT

2026-10-09T09:01:06-08:00

Brian Blunt, a long-term employee of the Town of Gilbert, was promoted to Commander in 2021 and signed an at-will employment agreement as a condition of his promotion and pay raise. This agreement allowed either party to terminate the relationship at any time, with or without cause, and was consistent with the then-existing Peace Officers’ Bill of Rights (POBR), which permitted such contractual deviations. In 2023, following employee complaints and an external investigation, Blunt was terminated without a pre-termination hearing or appeal process. He requested these procedural protections but was denied. After his termination, Blunt brought an action in Arizona Superior Court seeking a writ of mandamus compelling the Town to provide him procedural protections under POBR and due process. The Town removed the case to the United States District Court for the District of Arizona and moved to dismiss. The District Court granted the motion, holding that Blunt had no constitutionally protected employment interest because his contract was at-will and the 2022 amendment to POBR did not apply retroactively to his agreement. Blunt appealed to the United States Court of Appeals for the Ninth Circuit, which certified three questions to the Supreme Court of Arizona regarding the retroactive application of the 2022 POBR amendment. The Supreme Court of Arizona held that the presumption against retroactivity, codified in Arizona law, prohibits applying the 2022 amendment to at-will employment agreements executed before its effective date. The court found that the at-will employment term constituted a vested substantive right at the time of contract formation, and absent express legislative intent for retroactivity, the amendment cannot alter those pre-existing rights. The court answered only the first certified question, as its resolution was dispositive, and returned the matter to the Ninth Circuit. View "BLUNT v TOWN OF GILBERT" on Justia Law

Dash D. v. State

2026-10-09T09:00:55-08:00

The appellant, a father of six Indian children, challenged the termination of his parental rights under the Indian Child Welfare Act (ICWA). The Office of Children’s Services (OCS) took emergency custody of the children after receiving reports of neglect, including unsanitary living conditions and food insecurity. The father tested positive for multiple substances, and an initial out-of-home safety plan with a relative failed. OCS placed the children with their aunt, a preferred ICWA placement, and initiated proceedings for temporary custody, adjudication, disposition, and ultimately, termination of parental rights. Throughout the case, the father was represented by counsel at various stages, sometimes proceeding pro se, and repeatedly claimed he did not receive discovery materials. The Superior Court of the State of Alaska, Third Judicial District, Palmer, held hearings at each stage. Temporary custody was granted after expedited hearings, with findings that removal was necessary to prevent imminent harm. The father stipulated to probable cause for the children being in need of aid, reserving the right to contest at adjudication. Subsequent hearings resulted in approval of OCS’s permanency plan. The father failed to comply with his case plan, and OCS filed for termination. Multiple motions by the father, alleging ICWA and constitutional violations, were rejected by the superior court, which found OCS had complied with ICWA at all stages. On appeal, the Supreme Court of the State of Alaska reviewed three procedural arguments: denial of discovery, improper emergency removal, and alleged ICWA violations in earlier foster care proceedings. The court held that the superior court did not abuse its discretion regarding discovery, that OCS’s emergency removal complied with ICWA and Alaska law, and that alleged errors in earlier foster care actions did not invalidate the later, separate termination action. The court affirmed the termination order, finding no reversible error. View "Dash D. v. State" on Justia Law

Hernandez v. Florida Board of Bar Examiners

2026-10-09T08:30:35-08:00

Two attorneys, licensed in New Jersey and Michigan, sought admission to the Florida Bar and challenged a Florida rule requiring applicants admitted to another bar for more than twelve months to pay a higher application fee. They argued that this "experienced-applicant" rule violated the dormant Commerce Clause by burdening out-of-state applicants both on its face and in practical effect. One attorney paid the fee and then sued, seeking a refund and an injunction; the other attorney did not pay and joined the suit to seek prospective relief. The United States District Court for the Northern District of Florida initially dismissed most claims for lack of standing or based on Eleventh Amendment immunity, but allowed a limited practical-effect claim against the executive director of the Florida Board of Bar Examiners. After further amendments and discovery, the district court denied summary judgment to the plaintiffs and granted summary judgment to the executive director, finding that the rule did not discriminate against out-of-state applicants in practice. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the Board of Bar Examiners is an arm of the state and therefore immune from suit under the Eleventh Amendment. As to the claim against the executive director, the court found that the experienced-applicant rule did not facially discriminate against out-of-state applicants, as it was based solely on years of admission, not geographic origin. The court further concluded that undisputed evidence showed the rule imposed similar burdens on both in-state and out-of-state applicants and was adopted for legitimate, non-protectionist reasons. The Eleventh Circuit affirmed the district court’s dismissal and summary judgment, holding that neither facial nor practical-effect dormant Commerce Clause claims could succeed. View "Hernandez v. Florida Board of Bar Examiners" on Justia Law

Cannon v. State

2026-10-09T07:01:38-08:00

Alton Cannon, previously adjudicated as a Tier III sex offender, was convicted in 1998 for unlawful sexual contact in the first degree and required to register as a Tier III sex offender for life. After completing his original probation, Cannon was later found guilty in the Superior Court of Delaware in 2025 for two counts of failure to report as a registered sex offender. As part of his sentence for those offenses, he was placed on Level II probation and required by the Department of Correction to wear a GPS-enabled ankle bracelet. Cannon moved for a modification of his sentence, specifically requesting the removal of the GPS monitoring condition. The Superior Court denied his motion, finding that under 11 Del. C. § 4121(u), the Department of Correction was mandated to impose GPS monitoring on any Tier III sex offender under supervision, regardless of whether the probation was for the original sex offense or a subsequent crime. Cannon appealed this ruling, arguing that the statutory GPS monitoring requirement should only apply to probation for the offense that triggered the registry requirement, not to later, unrelated offenses. He also raised a constitutional challenge, asserting that the application of GPS monitoring in his case constituted an unreasonable search under the Fourth Amendment. The Supreme Court of the State of Delaware reviewed the statutory language and found it unambiguous, determining that the requirement applies to any Tier III sex offender on probation, regardless of the underlying offense. The court also concluded that, as applied to Cannon, the statute did not violate the Fourth Amendment. The court affirmed the judgment of the Superior Court, upholding both the statutory interpretation and the constitutionality of the GPS monitoring requirement. View "Cannon v. State" on Justia Law

In Re Detention Of Harlow

2026-10-09T06:04:42-08:00

A man with a history of sexual offenses, including a 2017 conviction for sexual abuse in the third degree, was later incarcerated for violating the terms of a special sentence imposed due to that conviction. While serving time for this parole revocation, the State petitioned to civilly commit him as a sexually violent predator (SVP) under Iowa Code chapter 229A. The petition was filed shortly before his anticipated discharge from prison. The man had a long criminal record and numerous behavioral violations in prison, several involving sexual misconduct. The Iowa District Court for Polk County conducted a trial, during which the respondent moved to dismiss the petition. He argued that because he was only confined for a nonsexual violation of his special sentence at the time of the petition, he was not “presently confined” as required by statute, and that due process required the State to prove a recent overt act indicating a risk of future violence. The district court denied the motion, found that the State had proven the statutory elements beyond a reasonable doubt—including that the respondent was an SVP and was presently confined as defined in the statute—and ordered his commitment. The respondent appealed, reasserting his statutory and constitutional arguments. The Supreme Court of Iowa reviewed the appeal. The court held that the statutory definition of “presently confined” includes incarceration resulting from a special sentence for a sexually violent offense, and that the State was not required to prove a recent overt act under these circumstances. The court further concluded that this statutory scheme did not violate federal or state due process, as long as the respondent was presently confined due to a sexually violent offense and found to be an SVP under the statute. The judgment of the district court was affirmed. View "In Re Detention Of Harlow" on Justia Law

ARMSTRONG VS. STATE

2026-10-08T12:07:26-08:00

A man entered a gun shop in Las Vegas seeking to sell two firearms, including a Glock 30 handgun equipped with an auto-sear device, which converts the weapon into a fully automatic machine gun. The store employee recognized the illegal modification and alerted the store owner, who then reported the incident to law enforcement and provided video surveillance. As a result, the man was charged with several offenses, including carrying a concealed firearm, possession of a machine gun, and violating regulations regarding modified semiautomatic firearms. A jury convicted him on these counts, and he later pleaded guilty to being a prohibited person in possession of a firearm. The Eighth Judicial District Court in Clark County entered convictions on all counts and imposed a prison sentence for possession of a machine gun, with lesser concurrent terms for the other offenses. The defendant appealed, raising constitutional and procedural challenges, including arguments that Nevada’s firearm statutes were unconstitutional and that his convictions for both possession of a machine gun and a modified semiautomatic firearm violated the Double Jeopardy Clauses of the United States and Nevada Constitutions. The Supreme Court of Nevada reviewed the case. It held that Nevada’s prohibitions on machine guns and modified semiautomatic firearms do not violate either the federal or state constitutions, as these weapons are considered dangerous and unusual and thus unprotected by the Second Amendment or the analogous Nevada provision. However, the court found that convicting the defendant for both possession of a machine gun and possession of a modified semiautomatic firearm based on the same conduct constituted double jeopardy, as the elements of the latter are entirely subsumed within the former. The court reversed the conviction for violating regulations regarding modified semiautomatic firearms, affirmed the remaining convictions, and remanded the case for entry of an amended judgment. View "ARMSTRONG VS. STATE" on Justia Law

United States v. Mixon

2026-10-08T11:30:07-08:00

Late at night, as Allison Beaver left work at a Taco Bell in Bristol, Tennessee, Charles Mixon confronted her in the parking lot with a handgun, forced her into her car, and ordered her to undress. When Mixon became distracted while driving, Beaver escaped and called the police. Mixon fled across the state line into Virginia, where he confessed to his stepfather, admitting he had stolen his stepfather’s gun for the carjacking. Upon refusing to return the firearm, Mixon was apprehended by police as he crossed back into Tennessee, in possession of the stolen gun. The United States District Court for the Eastern District of Tennessee heard the case against Mixon, who was indicted for carjacking, using and brandishing a firearm in furtherance of a crime, being a felon in possession of a firearm with at least three qualifying convictions under the Armed Career Criminal Act (ACCA), and possessing a stolen firearm. Mixon moved to dismiss the indictment, arguing the statutes exceeded Congress’s Commerce Clause power and that his Texas burglary convictions did not qualify as “violent felonies” under ACCA. The district court denied these motions and allowed evidence regarding his prior offenses, despite Mixon’s offer to stipulate to certain facts. On appeal, the United States Court of Appeals for the Sixth Circuit addressed Mixon’s Commerce Clause challenge, his argument that his Texas burglaries were not ACCA predicates, and his objection to the admission of prior crime evidence. The Sixth Circuit held that the statutes at issue were valid exercises of congressional power under prevailing precedent, that Texas burglary under Penal Code § 30.02(a) qualifies as generic burglary for ACCA purposes, and that the district court did not abuse its discretion in admitting evidence of Mixon’s prior robbery. Accordingly, the court affirmed Mixon’s convictions and sentence. View "United States v. Mixon" on Justia Law