Constitutional Law - Justia Case Law Summaries

United States v. DeFelice

2026-09-02T06:30:09-08:00

Federal agents began investigating the defendant in early 2021 after receiving information that he was operating a firearms manufacturing and dealing business from his home without the required federal license. Undercover agents arranged the purchase of a semi-automatic firearm and a high-capacity magazine from him, during which he described the magazine as “highly illegal.” Following a year-long investigation, law enforcement executed a search warrant and recovered two unregistered short-barreled rifles and an unregistered suppressor from his residence. A grand jury indicted the defendant on two counts: dealing and manufacturing firearms without a license under federal law, and possession of unregistered National Firearms Act (NFA) firearms (the rifles and suppressor). He moved to dismiss both counts, alleging the NFA violated his Second Amendment rights. The United States District Court for the District of Connecticut denied his motion, holding that the Second Amendment did not cover possession of unregistered rifles and suppressors. The defendant then entered a conditional guilty plea to the NFA count, preserving his right to appeal the denial and his sentence. He was sentenced to twelve months and one day in prison. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the defendant lacked standing to challenge the NFA as amended after his offense because the amendment was not retroactive. The court applied the Bruen framework, assumed without deciding that short-barreled rifles and suppressors are “arms,” but concluded the NFA’s registration and taxation requirements did not meaningfully constrain the defendant’s Second Amendment rights. The court also found no procedural or substantive error in the district court’s sentencing determination. The Second Circuit affirmed the judgment of the district court. View "United States v. DeFelice" on Justia Law

Bryan v. Commissioner of Correction

2026-09-02T04:02:56-08:00

The petitioner was convicted of murder and conspiracy to commit murder in connection with the shooting death of a woman who was pregnant with his child. After unsuccessfully convincing the victim to have an abortion, he conspired with a close friend to kill her. The friend ultimately fired the fatal shot. Weeks later, the friend confessed to a mutual acquaintance, who later served as a key prosecution witness. That witness also participated in a subsequent robbery with the friend, using the same firearm as in the murder. Information from the robbery investigation helped implicate both the friend and the petitioner in the murder. At trial, the witness testified that he had not been promised any deals or consideration for his testimony, although he later alluded to unspecified “considerations.” His defense attorney also testified, indicating there would be some consideration for truthful testimony but denying any formal agreement. The habeas court, Superior Court in the judicial district of Tolland, denied the petitioner’s request for a writ of habeas corpus. The court found that the witness’s testimony about the scope of any agreement was truthful and that the jury had been made aware that something would be done in exchange for his testimony. It further concluded that any ambiguity was clarified by testimony from the witness’s defense attorney, who explained that consideration would be given but no specific deal existed. The Supreme Court of Connecticut reviewed the case and held that the prosecutor violated Napue v. Illinois by eliciting false or substantially misleading testimony regarding the existence and nature of an agreement with the witness, failing to correct those misimpressions, and relying on the misleading testimony in closing argument. The court found these violations were material, as there was a reasonable likelihood they affected the jury’s verdict. The judgment of the habeas court was reversed, and the case remanded with instructions to grant the habeas petition, vacate the conviction, and order a new trial. View "Bryan v. Commissioner of Correction" on Justia Law

de la Fuente Diaz v. Gonzalez Colon

2026-09-01T14:00:03-08:00

Six nonbinary individuals born in Puerto Rico sought to amend their birth certificates to reflect a nonbinary gender marker ("X"), arguing that the existing Application for Gender Change, which only allowed selection of "male" or "female," discriminated against them. Their request followed an earlier federal court decision (Arroyo González v. Rossello Nevares) that required Puerto Rico to allow transgender binary individuals to amend their birth certificates, but did not address nonbinary persons. After their request was denied by the Director of the Demographic Registry, the plaintiffs filed suit, alleging violations of their constitutional rights under the Equal Protection and Due Process Clauses of the Fourteenth Amendment and the First Amendment. The United States District Court for the District of Puerto Rico reviewed cross-motions for summary judgment. The district court granted summary judgment to the plaintiffs on their Equal Protection claim, finding that Puerto Rico’s Birth Certificate Policy created a facial classification between binary and nonbinary individuals. The court applied rational basis review and concluded that Puerto Rico’s stated interests—including separation of powers and maintaining the integrity of public records—did not justify the exclusion of a nonbinary option. It found no rational basis for the policy and inferred animosity towards nonbinary persons, ordering Puerto Rico to amend its Application for Gender Change to include an "X" gender marker. The United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment order de novo. The appellate court concluded that Puerto Rico's Birth Certificate Policy is supported by a rational basis, specifically Puerto Rico’s legitimate interest in protecting privacy rights. Because the plaintiffs did not demonstrate that the policy infringes on their privacy rights or that privacy rights are not furthered by the policy, the court found a rational relationship between the challenged classification and the government’s legitimate goals. The First Circuit vacated the district court’s order and remanded for further proceedings. View "de la Fuente Diaz v. Gonzalez Colon" on Justia Law

State v. Laroque

2026-09-01T13:07:28-08:00

A pickup truck driven by Lilly Laroque collided head-on with another vehicle on a Montana highway, resulting in serious injuries to Laroque and the death of the other driver, Delaney Doherty. At the crash scene, law enforcement found marijuana-related items in Laroque’s vehicle, and evidence suggested Laroque had been texting and using marijuana while driving shortly before the crash. While hospitalized after the accident, Sergeant Stoner of the Montana Highway Patrol requested a blood sample from Laroque to test for intoxicants, reading her the Montana Implied Consent Advisory. Laroque did not respond verbally to repeated requests for consent, and the officer directed medical staff to draw her blood, which later tested above the legal limit for THC. The Eighteenth Judicial District Court of Montana reviewed Laroque's motion to suppress the blood sample and toxicology report, considering arguments that the warrantless blood draw violated her constitutional protections against unreasonable searches and seizures. The State argued that Montana’s Implied Consent statute authorized the blood draw, relying on precedent from City of Great Falls v. Allderdice. The District Court found Laroque did not exhibit understanding or consent required by the Implied Consent Advisory, distinguishing her case from Allderdice. The court suppressed the evidence, finding no exception to the warrant requirement applied and declined to apply the good faith exception. The State appealed this suppression order. The Supreme Court of the State of Montana reviewed whether the District Court’s finding that Laroque did not consent was clearly erroneous. Applying the clear error standard, the Supreme Court found substantial evidence supported the District Court’s conclusion that Laroque did not consent to the warrantless blood draw. The Supreme Court affirmed the suppression of the blood sample and toxicology report, holding the District Court’s factual findings were not clearly erroneous and declining to address the State’s good faith doctrine argument, as it was not raised below. View "State v. Laroque" on Justia Law

Zafirov v. Florida Medical Associates, LLC

2026-09-01T12:00:58-08:00

A physician brought a lawsuit on behalf of the United States under the False Claims Act (FCA), alleging that her employer and associated healthcare entities knowingly submitted false diagnosis codes to Medicare in order to obtain inflated payments. The case proceeded for several years. In February 2024, the defendants sought judgment on the pleadings or dismissal, arguing that the FCA’s qui tam provisions—which allow private individuals (relators) to sue on behalf of the government—violated the Constitution’s Appointments Clause, Take Care Clause, and Vesting Clause. The United States District Court for the Middle District of Florida granted the defendants’ motion, concluding that the qui tam provisions violated the Appointments Clause. The district court reasoned that relators are “officers of the United States” because they exercise significant federal authority and occupy a continuing position established by law, but are not appointed by the President as required by Article II. The court dismissed the case, finding the relator lacked authority to proceed on behalf of the United States, and did not address the other constitutional arguments. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s constitutional analysis de novo. The Eleventh Circuit disagreed with the lower court’s conclusion, holding that relators under the FCA are not officers of the United States because they do not occupy a continuing position established by law. The court explained that relators’ roles are temporary, personal, and lack a continuing emolument or transferable duties. Therefore, the FCA’s qui tam provisions do not violate the Appointments Clause. The Eleventh Circuit vacated the district court’s dismissal and remanded the case for consideration of the remaining constitutional arguments. View "Zafirov v. Florida Medical Associates, LLC" on Justia Law

People v. Campbell

2026-09-01T09:31:46-08:00

Sidney Campbell was convicted by a jury of second degree murder in 2003 after he and his brother shot and killed a 15-year-old boy following a confrontation related to a damaged bicycle rim. Witnesses testified that Campbell was one of the shooters, and the jury found he personally used and discharged a firearm during the offense. The jury was not instructed on felony murder or the natural and probable consequences doctrine, but was instructed on implied malice. Following his conviction, Campbell was sentenced to 35 years to life. The California Court of Appeal previously affirmed his conviction. In 2022, Campbell filed a petition for resentencing under Penal Code section 1172.6, arguing that recent statutory amendments and relevant case law might render him eligible for relief because his conviction could have rested on an imputed malice theory, particularly given ambiguities in the aiding and abetting instructions. The Los Angeles County Superior Court summarily denied the petition at the prima facie stage, finding Campbell ineligible for resentencing as a matter of law. The California Court of Appeal, Second Appellate District, Division Six, reviewed the trial court’s denial after the California Supreme Court directed reconsideration in light of People v. Lopez (2026) 19 Cal.5th 639, which clarified that the ability to raise instructional error on direct appeal does not categorically bar relief under section 1172.6. The appellate court independently reviewed the record and concluded that the jury instructions did not allow for conviction based on imputed malice and that it was not reasonably likely the jury relied on such a theory. Therefore, Campbell was found ineligible for resentencing as a matter of law. The order denying Campbell’s section 1172.6 petition was affirmed. View "People v. Campbell" on Justia Law

USA v. Berger

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

Federal agents intercepted a package containing three silencers shipped from China to Joseph Berger’s residence in Bethlehem, Pennsylvania. Upon searching the home with a warrant, agents discovered more than sixty firearms, including thirteen fully automatic guns (mostly AK-47 variants), a dozen silencers, and parts for converting semi-automatic weapons into machine guns. Berger was indicted for possession of machine guns and unregistered silencers, violations of federal law. He is a Navy veteran who lived with his father, and evidence suggested both were involved in acquiring conversion parts. In the U.S. District Court for the Eastern District of Pennsylvania, Berger raised an as-applied Second Amendment challenge. The court denied his challenge, finding that machine guns were “dangerous and unusual weapons” not commonly used for self-defense, and that silencers were not “bearable arms” under the Second Amendment. Berger then pleaded guilty to possessing a machine gun and an unregistered silencer, reserving his right to appeal the Second Amendment issue. The government dismissed the charge of possessing an unregistered machine gun as part of the plea agreement. The United States Court of Appeals for the Third Circuit reviewed Berger’s appeal de novo, focusing on pure issues of law. The court held that the Second Amendment does not protect possession of machine guns because they are not commonly used for lawful purposes and are classified as “dangerous and unusual.” Furthermore, the registration requirement for silencers under the National Firearms Act imposes only a minimal, objective burden and does not infringe upon Second Amendment rights. The court affirmed Berger’s conviction and sentence, holding that both the machine-gun ban and the silencer registration requirement are constitutional as applied to Berger. View "USA v. Berger" on Justia Law

USA v. Aleman-Lozano

2026-09-01T09:00:05-08:00

The case concerns a noncitizen from El Salvador who lawfully entered the United States on a nonimmigrant temporary visa with work authorization. While residing in the United States, he was stopped by a Pennsylvania state trooper for a traffic violation. During the stop, the officer observed a rifle cartridge in the vehicle, leading to a search warrant and the discovery of a loaded pistol without a serial number. The individual admitted to purchasing the pistol in Maryland. He was indicted by a grand jury for violating 18 U.S.C. § 922(g)(5)(B), a statute prohibiting nonimmigrant visa holders from possessing firearms. He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The United States District Court for the Middle District of Pennsylvania denied his motion, holding the statute constitutional. After entering a conditional guilty plea, reserving his right to appeal the constitutional issue, he was sentenced to twenty-four months’ imprisonment and one year of supervised release. On appeal, the United States Court of Appeals for the Third Circuit addressed whether 18 U.S.C. § 922(g)(5)(B) is facially unconstitutional under the Second Amendment. The Court, following the framework from New York State Rifle & Pistol Ass’n v. Bruen, assumed without deciding that some noncitizens may be included among “the people” protected by the Second Amendment. The Court then considered whether the statute is consistent with the nation’s historical tradition of firearm regulation. It found that there is a longstanding historical practice of disarming individuals considered disloyal to the sovereign, including noncitizens with allegiance to another country. Concluding that § 922(g)(5)(B) is relevantly similar to these historical analogues, the Court held that the statute does not violate the Second Amendment and affirmed the conviction. View "USA v. Aleman-Lozano" on Justia Law

Bickford v. Bradeen

2026-09-01T07:36:14-08:00

The case involves two parents, Emily A. Bickford and Matthew A. Bradeen, who share parental rights and responsibilities for their child. They initially agreed to a shared parenting arrangement in 2013, requiring joint decisions on matters such as the child’s religious upbringing and medical care. In 2021, disputes arose when Bradeen alleged that Bickford involved the child in religious activities without his knowledge, while Bickford claimed Bradeen tried to prevent the child’s religious training. Both parents sought sole authority over the child’s religious upbringing. After mediation resolved most issues except religion and healthcare, the District Court held hearings and found that Bickford's unilateral decisions regarding religion and medical care caused the child anxiety and endangered her relationship with Bradeen. The court also found that Bradeen was more capable of making decisions in the child’s best interest. The District Court (Portland) modified the prior order, allocating to Bradeen final decision-making authority regarding the child’s religious upbringing (especially relating to Calvary Chapel Greater Portland) and medical care. The court used a best-interest standard for medical decisions and, believing strict scrutiny was required for religious matters, found a compelling interest in protecting the child from psychological harm. Bickford’s motions for post-judgment relief were denied, and she appealed, arguing constitutional violations. The Maine Supreme Judicial Court reviewed the case and clarified that strict scrutiny does not apply to allocations of parental rights between parents, even in religious matters. The Court held that the best-interest standard governs such decisions, provided there is no religious bias. It found no evidence of religious hostility or abuse of discretion by the District Court and affirmed the judgment, upholding Bradeen’s final authority in the disputed areas. View "Bickford v. Bradeen" on Justia Law

State of Idaho v. Orr

2026-09-01T07:03:52-08:00

After being arrested for domestic battery against S.O., Nicholas James Orr was subject to a criminal no contact order prohibiting communication with S.O. Despite this order, Orr repeatedly called S.O. from jail and made statements that included urging her to alter her testimony, suggesting she say the incident “didn’t happen,” and implying that her actions could “fix” his legal troubles. The State charged Orr with intimidating a witness under Idaho Code section 18-2604(3), as well as multiple violations of the no contact order. The District Court of the Sixth Judicial District denied Orr’s motion to dismiss the witness intimidation charge. Orr had argued that the statute was facially overbroad under the First Amendment and unconstitutional as applied to his conduct, asserting that the “by any manner” language of the statute criminalized protected speech, including his attempts to persuade S.O. to provide more information or clarify her statements. The district court concluded that the statute did not infringe on protected speech, as it targeted attempts to influence or prevent truthful testimony, and that Orr’s conduct could be interpreted as seeking perjury. Orr entered a conditional guilty plea to the intimidation charge, reserving the right to appeal the denial of his motion to dismiss. The Supreme Court of the State of Idaho reviewed the case de novo and affirmed the district court’s decision. The Idaho Supreme Court held that Idaho Code section 18-2604(3) is not unconstitutionally overbroad because it prohibits speech integral to criminal conduct, such as suborning perjury, which is not protected by the First Amendment. The court also held that, as applied to Orr, the statute was constitutional because his statements could reasonably be interpreted as attempts to convince S.O. to testify untruthfully. The court affirmed the denial of the motion to dismiss. View "State of Idaho v. Orr" on Justia Law

National Park Service v. National Trust for Historic Preservation in the United States

2026-08-31T12:45:06-08:00

The federal government initiated a project to replace the East Wing of the White House, completing demolition in December 2025 and beginning construction of a new wing, which included both a below-ground military installation and an above-ground ballroom. The National Trust for Historic Preservation challenged aspects of the ongoing construction and sought a preliminary injunction to halt the above-ground work due to concerns about its impact on aesthetic, cultural, and historical interests. The United States District Court for the District of Columbia granted the Trust’s motion for a preliminary injunction, allowing only construction strictly necessary for security purposes above ground but permitting below-ground work to continue. The government appealed, and the United States Court of Appeals for the District of Columbia Circuit initially stayed the injunction, then ultimately affirmed the district court’s order. With the injunction set to take effect, the government sought relief from the Supreme Court of the United States. The Supreme Court granted the requested stay of the district court's injunction pending the government’s petition for certiorari. The Court held that the government is likely to succeed in showing the Trust lacks Article III standing, as the Trust’s asserted injury—distress at viewing the new ballroom’s design—does not constitute a concrete and particularized injury. The Court also found that the government would likely suffer irreparable harm from halting construction, given national security concerns and operational needs, while the Trust’s claimed harm was outweighed by these factors. The stay will remain in effect until certiorari is denied or, if granted, until the judgment is issued. View "National Park Service v. National Trust for Historic Preservation in the United States" on Justia Law

Pomeroy v. Utah State Bar

2026-08-31T12:00:55-08:00

An attorney licensed in Utah challenged the state’s requirement that lawyers join the Utah State Bar and pay annual dues as a condition of practicing law. She argued that the Bar engaged in activities—such as lobbying, publishing a journal, and posting on social media—that were not sufficiently related to regulating the legal profession or improving legal services. She also objected to the procedures used by the Bar for handling members’ mandatory dues, claiming they were inadequate to protect her First and Fourteenth Amendment rights. The United States District Court for the District of Utah first dismissed the plaintiff’s claim that mandatory dues violated her rights, relying on precedent from the Tenth Circuit’s decision in Schell v. Chief Justice & Justices of Oklahoma Supreme Court. The district court then reviewed cross-motions for summary judgment on the remaining claims. It ruled for the defendants, finding that most challenged Bar activities were germane under the standard set in Keller v. State Bar of California, and that the Bar’s procedures for handling objections to expenditures and providing refunds were constitutionally sufficient. The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s decisions. The appellate court held that, under existing Supreme Court and Tenth Circuit precedent, mandatory bar dues are constitutional when used for activities germane to regulating the legal profession or improving legal services. The court also held that the correct legal standard for evaluating the Bar’s activities is the “germaneness” test from Keller, not a heightened “exacting scrutiny” standard. Because the plaintiff did not adequately challenge the district court’s germaneness findings or show that the Bar’s procedures were constitutionally deficient, the Tenth Circuit affirmed the lower court’s dismissal and summary judgment rulings. View "Pomeroy v. Utah State Bar" on Justia Law

Parsons v. City of Indian Wells

2026-08-31T10:01:32-08:00

The case involves a dispute between homeowners who own property within a common interest development (CID) in the City of Indian Wells and the City itself. The City, responding to complaints about the negative effects of short-term rentals (STRs), enacted ordinances that effectively banned STRs by imposing a 29-night minimum stay requirement. To accommodate homeowners in CIDs who wanted to operate STRs, the City adopted an ordinance (No. 732) allowing CIDs to opt out of the minimum stay requirement through a vote of their members. The plaintiffs, owners of property in a CID with governing documents allowing rentals of any duration, sought an STR permit after their CID certified an opt-out vote. The City denied the permit, leading the plaintiffs to file suit, arguing that the City’s opt-out provision conflicted with state law and unconstitutionally delegated legislative authority to private parties. The Superior Court of Riverside County ruled in favor of the plaintiffs, finding that the City’s opt-out ordinance conflicted with provisions of the Davis-Stirling Common Interest Development Act, particularly Civil Code section 4740, and with the Act’s voting requirements for amending CID governing documents. The court also found that the opt-out provision was an unconstitutional delegation of legislative authority. As a result, the court ordered the City to issue an unrestricted STR permit and awarded attorney fees to the plaintiffs. The California Court of Appeal, Fourth Appellate District, Division Two, reversed the trial court’s judgment. It held that the City’s opt-out provision is not preempted by Civil Code section 4740 because a CID’s vote to opt out does not amend its governing documents or conflict with the Act. The Court further held that the City did not unconstitutionally delegate legislative authority because it established a general policy and permissibly allowed CIDs to waive the restriction. The City’s enactment of the ordinance was not arbitrary or capricious. The judgment and attorney fee order were reversed. View "Parsons v. City of Indian Wells" on Justia Law

Utah Vapor Business Association v. State of Utah

2026-08-31T09:00:57-08:00

Businesses selling flavored e-cigarettes in Utah challenged a state law passed in March 2024 that banned the sale of any e-cigarette flavors other than tobacco or menthol. The plaintiffs, representing Retail Tobacco Specialty Businesses (RTSBs), argued that this “Flavor Ban” would severely affect their operations, as the majority of their sales involved flavored products. They asserted that the ban was preempted by the Federal Family Smoking Prevention and Tobacco Control Act and also contended that the law’s enforcement mechanism, which authorized warrantless searches by local health departments, violated the Fourth Amendment. The plaintiffs filed suit in the United States District Court for the District of Utah, seeking preliminary injunctions against both the Flavor Ban and the enforcement mechanism. The district court denied the preliminary injunction regarding the Flavor Ban, concluding that federal law did not preempt the state’s action, but granted an injunction against the enforcement provision, finding the warrantless search mechanism unconstitutional. The court determined that the enforcement provision was severable from the rest of the Act, so it left the remainder of the law, including the Flavor Ban, intact. Both sides appealed the rulings adverse to them. After the Utah legislature amended the enforcement provision, both parties agreed that the Fourth Amendment issue was moot. The only remaining issue on appeal was whether the federal law preempted the state’s Flavor Ban. However, the plaintiffs failed to properly identify the relevant district court order denying the preliminary injunction against the Flavor Ban in their notice of appeal. The United States Court of Appeals for the Tenth Circuit held that because the plaintiffs’ notice of appeal did not specify the order they sought to challenge, the court lacked jurisdiction to consider the preemption issue. Accordingly, the court dismissed the appeal. View "Utah Vapor Business Association v. State of Utah" on Justia Law

MacDonald v. President NJ State Board of Medical Examiners

2026-08-31T09:00:04-08:00

Several plaintiffs challenged a New Jersey law requiring any doctor who wishes to provide telemedicine services to a patient located in New Jersey to first obtain a license from the state’s Board of Medical Examiners. The plaintiffs included two physicians licensed outside New Jersey and three New Jersey residents who wanted to receive virtual medical consultations from those doctors. The doctors argued that New Jersey’s licensing requirement placed an undue burden on their ability to provide telemedicine services, especially since they were already licensed in their home states. The patients and a parent also raised claims based on their rights to receive medical advice and direct their child’s care. The United States District Court for the District of New Jersey dismissed all the plaintiffs’ claims for failure to state a claim. The court held that the licensing requirement did not violate the First Amendment, the dormant Commerce Clause, the Privileges and Immunities Clause, or substantive due process. The plaintiffs appealed, maintaining that the law, as applied, unconstitutionally restricted their right to free speech and imposed excessive burdens on interstate medical practice. The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal of all claims, with one modification. The Third Circuit held that requiring a medical license to provide telemedicine services is a content-based restriction on speech, but such regulations have a long tradition and thus do not warrant strict scrutiny. Instead, the law survives intermediate scrutiny because the burdens imposed are not substantial compared to New Jersey’s interest in ensuring competent medical care. The court further held that the law does not violate the dormant Commerce Clause or the Privileges and Immunities Clause, as it applies equally to all doctors regardless of their state of residence. The court also found that the plaintiff asserting a substantive due process right lacked standing, and that claim was ordered dismissed without prejudice for lack of jurisdiction. View "MacDonald v. President NJ State Board of Medical Examiners" on Justia Law

Americans for Prosperity Foundation v. Albence

2026-08-31T09:00:04-08:00

Two nonprofit organizations that engage in nationwide issue advocacy challenged Delaware’s Elections Disclosure Act, which requires groups spending over $500 on electioneering communications near an election to publicly disclose donors giving more than $100 during the relevant cycle. The law’s disclosure obligations are broad: they are not limited to donors earmarking funds for political ads, nor can donors avoid disclosure by restricting the use of their contributions. The law also looks back several years for purposes of disclosure. The organizations, which have not previously run such communications in Delaware but claim they intend to do so in the upcoming election, argue that the law violates the First Amendment. After the organizations filed suit in the U.S. District Court for the District of Delaware, they sought a preliminary injunction to halt enforcement of the Act. The District Court denied the request, finding no likelihood of success on the facial challenge because prior Third Circuit precedent, Delaware Strong Families v. Attorney General of Delaware, had upheld the Act and the Supreme Court’s subsequent decision in Americans for Prosperity Foundation v. Bonta did not clearly abrogate that ruling. The court also doubted the as-applied challenge, citing the plaintiffs’ failure to offer specific evidence of harm to donors. The District Court emphasized the law’s decade-long enforcement and the lack of urgent need to change the status quo. The United States Court of Appeals for the Third Circuit reviewed the denial. Applying a deferential standard, the court found that the plaintiffs had not made a clear showing of entitlement to a preliminary injunction. It held that even with some likelihood of success and possible irreparable injury, the balance of equities and the public interest favored preserving the longstanding status quo. The court affirmed the District Court’s order denying the preliminary injunction. View "Americans for Prosperity Foundation v. Albence" on Justia Law

Fitil v. Riley

2026-08-31T07:30:15-08:00

During the aftermath of George Floyd’s death, Tosun Fitil participated in a protest in Omaha, Nebraska, holding a sign to honor Floyd and Zachary Bear Heels. The Omaha Police Department deployed numerous officers, including SWAT member Justyn Riley. When unrest escalated, officers responded to thrown water bottles with pepper balls, which further intensified the confrontation. Amidst this, Fitil stepped forward to confront the officers. As rocks were thrown toward Officer Riley, he threw a flashbang device that detonated near Fitil’s head, causing serious injuries including burns, ruptured eardrums, concussion, and lasting hearing and balance problems. Fitil filed suit in the United States District Court for the District of Nebraska, asserting claims under 42 U.S.C. § 1983 for violations of his First Amendment rights (free speech and assembly) and the Fourth Amendment (excessive force). At summary judgment, the district court denied qualified immunity for both claims, finding that factual disputes remained and a reasonable jury could conclude Riley had effectuated a seizure by deploying the flashbang. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court determined that it had jurisdiction only to address the denial of qualified immunity on the Fourth Amendment claim, not the First Amendment claim, because the district court had not explicitly ruled on qualified immunity for the latter. The Eighth Circuit held that the law was not clearly established regarding whether the use of a flashbang in an open area to disperse protestors amounted to a seizure under the Fourth Amendment. Therefore, it reversed the district court’s denial of qualified immunity on the excessive force claim, dismissed the remainder of the appeal for lack of jurisdiction, and remanded for further proceedings. View "Fitil v. Riley" on Justia Law

Dolce v. Connetquot Cent. Sch. Dist.

2026-08-31T06:30:03-08:00

Three teachers at a public high school, who openly identify as members of the LGBTQ+ community, were directed by school district officials to remove pride flags and stickers from their classrooms. The officials cited a district policy that restricted displays to only the American and New York State flags, characterizing other flags and certain stickers as “political.” While the teachers complied, they alleged that other non-sanctioned displays, such as sports flags and stickers for student organizations, were allowed to remain. The teachers also recounted differing treatment regarding permission slips for an LGBTQ+ club field trip. They filed suit, claiming violations of their First and Fourteenth Amendment rights, as well as employment discrimination under federal, state, and local law. The United States District Court for the Eastern District of New York dismissed the complaint. The court found the individual officials entitled to qualified immunity on the First Amendment claims, ruled that there was no plausible showing of discriminatory intent for the equal protection claims, determined no adverse employment actions occurred for Title VII purposes, and declined to exercise supplemental jurisdiction over the state and local law claims. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment, though it relied on different reasoning for the First Amendment claim. The Second Circuit held that classroom wall and door decorations by teachers constitute speech pursuant to their official duties under Garcetti v. Ceballos, and therefore, the school district could regulate or restrict such speech without violating the teachers’ First Amendment rights. The court further held that the teachers failed to plausibly allege selective enforcement based on impermissible motives or any adverse employment actions, and found no abuse of discretion in the district court’s decisions regarding the state claims and leave to amend. View "Dolce v. Connetquot Cent. Sch. Dist." on Justia Law

McDonald v. US

2026-08-28T11:30:03-08:00

The appellant was convicted in the 1990s for bank and armored car robberies committed with a group that included Anthony Shea. These crimes involved frequent use of firearms, and in one particularly violent incident, two armored car guards were killed execution-style. The convictions included armed bank robbery, carjacking, Hobbs Act robbery and conspiracy, gun possession by a felon or drug user, and aiding and abetting the use of a firearm during a crime of violence under 18 U.S.C. § 924(c). The trial judge instructed the jury that several offenses were “crimes of violence” for the gun-use charge, but the verdict form did not specify which predicate offense the jury relied upon. Following his conviction, the United States District Court for the District of New Hampshire sentenced him to life imprisonment, applying enhancements under the Armed Career Criminal Act (ACCA) based on prior convictions. After the Supreme Court in Johnson v. United States struck down ACCA’s residual clause, a panel of the United States Court of Appeals for the First Circuit allowed the appellant to file a successive habeas petition. The district court subsequently vacated the ACCA-enhanced sentence and imposed a lower term, but declined to grant a full resentencing or to vacate the § 924(c) conviction, reasoning that the jury instruction error was harmless because valid predicate offenses remained. Upon appeal, the United States Court of Appeals for the First Circuit reviewed the denial of § 2255 relief de novo and for harmless error. It held that the district court's reliance on the harmless-error standard was correct and that the error in instructing on an invalid predicate offense did not have a substantial and injurious effect on the jury’s verdict, given the interrelated and coextensive nature of the valid and invalid predicates. The court further held that the appellant was not entitled to a certificate of appealability or to a full resentencing, as no substantial constitutional claim was raised regarding the district court’s choice of remedy. The judgment was affirmed and the request for a certificate of appealability denied. View "McDonald v. US" on Justia Law

United States v. Hoffpowier

2026-08-28T11:00:07-08:00

The case concerns Michael C. Hoffpowier, who was investigated after his estranged wife, B.H., reported to law enforcement that he had scheduled an appointment at her workplace under a false name and had a history of harassing her across multiple states. Officers responding to the scene located Hoffpowier’s vehicle in a nearby parking lot. Upon approaching, they observed behavior they interpreted as a potential flight risk, including the vehicle being put in reverse. Hoffpowier was handcuffed after failing to comply with commands to approach an officer. While detained, officers reviewed text messages between Hoffpowier and B.H. and, with his consent, observed binoculars and a gun magazine in his vehicle. A search of the vehicle revealed firearms and a silencer. The United States District Court for the Eastern District of Tennessee denied Hoffpowier’s motion to suppress the evidence obtained from the search, concluding that the handcuffing did not constitute an arrest and that there was a reasonable basis to believe the vehicle contained evidence related to stalking. The magistrate judge’s report and recommendation to deny suppression was adopted after Hoffpowier’s objections were overruled, in part because he did not update his arguments in light of the report’s analysis. Hoffpowier subsequently pleaded guilty to possession of an unregistered silencer. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that the officers’ use of handcuffs during the investigatory stop was reasonable given the circumstances and did not convert the stop into an arrest. It further held that the presence of binoculars visible in the vehicle provided a reasonable basis to believe that the vehicle contained evidence pertinent to the stalking offense, justifying the warrantless search under the search-incident-to-arrest exception. View "United States v. Hoffpowier" on Justia Law

NetChoice, LLC v. Skrmetti

2026-08-28T11:00:07-08:00

A trade association representing internet companies challenged the enforcement of a new Tennessee statute designed to protect minors from social media risks. The law requires social media companies to verify the ages of all prospective account holders and secure parental consent before allowing minors to create accounts. It also mandates that parents be given tools to supervise their children’s accounts. The association argued that its members would suffer unrecoverable compliance costs and that the law would restrict their and their users’ First Amendment rights. The United States District Court for the Middle District of Tennessee denied the association’s motion for a preliminary injunction. The district court concluded that the association had not established irreparable harm, finding that the alleged loss of First Amendment freedoms was not sufficiently certain or imminent, and that unrecoverable compliance costs did not qualify as irreparable harm. Because the court found no irreparable harm, it did not consider the other preliminary injunction factors. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial. The appellate court disagreed with the lower court’s analysis of irreparable harm, holding that both unrecoverable compliance costs and the loss of First Amendment freedoms can satisfy the threshold requirement for irreparable harm. The court explained that compliance costs need not be extraordinary to be considered irreparable and that the chilling effect on speech, even before enforcement, can constitute irreparable harm if enforcement is likely and imminent. The Sixth Circuit vacated the district court’s order and remanded the case for further consideration of all preliminary injunction factors, directing the lower court to weigh the harm asserted and address the remaining legal standards as appropriate. View "NetChoice, LLC v. Skrmetti" on Justia Law

Gomez-Echeverria v. Purpose Point Harvesting, LLC

2026-08-28T11:00:06-08:00

A group of Guatemalan nationals were recruited under the H-2A visa program by a Michigan agricultural company and its owners to work seasonal jobs between 2017 and 2019. The plaintiffs alleged that the defendants illegally charged recruitment fees, underpaid wages, forced them to live in poor conditions, confiscated personal documents, limited their freedom, and threatened them with deportation if they complained. The plaintiffs claimed these actions violated federal anti-trafficking laws, the Fair Labor Standards Act, Michigan labor and trafficking statutes, and state contract law. In the United States District Court for the Western District of Michigan, the case proceeded to a jury trial. The jury found in favor of the plaintiffs on most claims, awarding both compensatory and punitive damages, while denying certain claims against one defendant and rejecting the defendants’ counterclaims. The district court denied the defendants’ motions for mistrial, to dismiss for forum non conveniens, for a new trial, and for remittitur of punitive damages. The court entered judgment for the plaintiffs, including damages, attorney fees, and costs. The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the punitive damages awarded were not grossly excessive or arbitrary and thus did not violate due process, applying the guideposts from BMW of North America, Inc. v. Gore and State Farm Mutual Automobile Insurance Co. v. Campbell. The court also found no abuse of discretion in the district court’s evidentiary rulings, denial of a mistrial, or in allowing the case to proceed in Michigan rather than Guatemala. The court further concluded that alleged statute of limitations defenses were either inapplicable or waived. The Sixth Circuit affirmed the district court’s judgment in all respects. View "Gomez-Echeverria v. Purpose Point Harvesting, LLC" on Justia Law

USA v. Smith

2026-08-28T10:00:54-08:00

Reginald Smith, previously convicted of multiple cocaine-related felonies in Florida state court, was arrested in December 2019 after officers investigating illegal hunting found him holding a loaded shotgun. During a search, officers discovered additional ammunition, a hunting knife, and MDMA pills. An agent determined that Smith’s shotgun had traveled in interstate commerce, having been manufactured outside Florida. Smith, as a result, was indicted for possession of a firearm as a felon under 18 U.S.C. § 922(g)(1) and possession of MDMA under 21 U.S.C. § 844(a). He pleaded guilty to both counts. The United States District Court for the Middle District of Florida reviewed Smith’s prior convictions to determine whether they triggered the mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e). The court considered evolving precedent—including United States v. Conage and United States v. Jackson—regarding whether certain Florida drug crimes qualified as “serious drug offenses” under ACCA. After law developments clarified that Smith’s two 1993 convictions for selling cocaine and his 2001 conviction for trafficking cocaine were ACCA predicates under Eleventh Circuit precedent, the court applied the ACCA enhancement. Smith was sentenced to 180 months’ imprisonment for the firearm count and 12 months for MDMA possession, to run concurrently. Smith objected to the ACCA enhancement but acknowledged its applicability under current circuit law. The United States Court of Appeals for the Eleventh Circuit affirmed Smith’s conviction and sentence. The court held that § 922(g)(1) did not violate the Second Amendment or Commerce Clause, Smith invited any error regarding ACCA classification of his convictions, the district court’s error under Erlinger v. United States did not affect Smith’s substantial rights, and any error in calculating his base offense level under the Sentencing Guidelines was harmless. View "USA v. Smith" on Justia Law

Morocho v. Warden Philadelphia FDC

2026-08-28T09:00:04-08:00

Two individuals, citizens of Ecuador and Brazil, respectively, entered the United States without inspection in 2001 and 2014. In late 2025 and early 2026, each was arrested by U.S. Immigration and Customs Enforcement and detained, without the possibility of bond, under 8 U.S.C. § 1225(b)(2)(A). This marked a change in government practice, as similar noncitizens had previously been detained or released under 8 U.S.C. § 1226(a), which allows for discretionary bond if the person is not a danger or flight risk. In 2025, the government began applying § 1225(b)(2)(A) to noncitizens already present in the United States who entered without inspection, resulting in mandatory detention without bond. Both individuals filed habeas petitions in the United States District Court for the Eastern District of Pennsylvania, arguing their detentions violated the Immigration and Nationality Act (INA). The district courts granted their petitions, finding that § 1225(b)(2)(A) did not apply to them and that their continued detention without bond violated the INA. One district court also held that such detention violated the Fifth Amendment’s Due Process Clause. Both petitioners were subsequently released, and the government appealed these decisions. The United States Court of Appeals for the Third Circuit reviewed the statutory language and structure of the INA and considered relevant precedent. The court held that § 1225(b)(2)(A) applies only to noncitizens who are both “applicants for admission” and “seeking admission,” meaning those engaged in a present or ongoing attempt to gain lawful entry into the United States. The court concluded that noncitizens already present in the United States who are not actively seeking admission are not subject to mandatory detention under this provision and should be considered under § 1226(a), which allows for bond. The Third Circuit also held that detaining such individuals without a bond hearing violates the Due Process Clause. The court affirmed the district courts’ orders directing the release of the petitioners. View "Morocho v. Warden Philadelphia FDC" on Justia Law

JACQUES V. BLANCHE

2026-08-28T08:30:31-08:00

A Jamaican citizen, Jacques, entered the United States as a teenager and overstayed his visa. In 2021, he was arrested in Utah during a traffic stop and pleaded guilty to misdemeanor possession of marijuana with intent to distribute. After serving a suspended sentence and probation, he was detained by Immigration and Customs Enforcement. Jacques applied for withholding of removal, arguing his return to Jamaica would place him in danger due to his mother’s political activities and murder. An Immigration Judge twice granted Jacques’s application for withholding of removal, finding his conviction was not a particularly serious crime barring relief. The Department of Homeland Security (DHS) appealed both grants to the Board of Immigration Appeals (BIA). In both instances, the BIA or DHS failed to send notices of appeal and briefing schedules to the correct detention address, despite having updated information on Jacques’s location. As a result, Jacques was excluded from participating in both appellate proceedings, and did not respond to the appeals or submit briefs. The BIA reversed the Immigration Judge’s decisions each time, determining that Jacques’s conviction constituted a particularly serious crime and denying him withholding of removal. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that Jacques’s due process rights were violated because the government failed to serve him with reasonably calculated notice of DHS’s appeals, excluding him from participating in the proceedings. The court further held that Jacques was prejudiced by this deprivation, as the outcome of the appeals may have been affected had he been given notice and an opportunity to respond. The Ninth Circuit granted Jacques’s petition, vacated the BIA’s orders, and remanded with instructions to re-notice the appeal and reissue a briefing schedule to the correct address. View "JACQUES V. BLANCHE" on Justia Law

Public Interest Legal Foundation, Inc. v. Simon

2026-08-28T08:00:11-08:00

An organization based in Virginia requested access to Minnesota’s Registered Voter List under a federal statute, asserting it was entitled to the records despite Minnesota’s exemption from the law. Minnesota denied the request, citing its exemption as a state with continuous election-day registration since August 1, 1994. The organization also sought the information under a Minnesota statute, but was again denied because no Minnesota-registered voter joined the request. The organization acknowledged it could obtain the information by recruiting a Minnesota voter but did not do so. It then filed suit, claiming Minnesota’s exemption from the federal disclosure requirement was unconstitutional, alleging informational injury and other adverse consequences. The United States District Court for the District of Minnesota reviewed the case. Minnesota moved to dismiss, and the United States intervened to defend the statute’s constitutionality. The district court dismissed the organization’s claim on the merits, concluding that the “equal sovereignty” principle does not apply to Congress’s authority under the Elections Clause. On appeal, the United States Court of Appeals for the Eighth Circuit considered whether the organization had Article III standing. The court reviewed standing de novo and focused on whether the plaintiff had suffered a concrete injury in fact. The court held that a purely informational injury does not satisfy Article III’s requirements and found the plaintiff’s alleged downstream consequences insufficient, as they lacked a nexus to the interests Congress sought to protect. The court concluded the plaintiff failed to allege a concrete injury and therefore lacked standing. The Eighth Circuit vacated the district court’s judgment and remanded with instructions to dismiss the complaint for lack of jurisdiction. View "Public Interest Legal Foundation, Inc. v. Simon" on Justia Law

USA v. Almonte

2026-08-28T07:01:05-08:00

The case concerns Cesar Gomez Almonte, who was convicted for his role in an international drug-smuggling conspiracy. Beginning in 2016, conspirators based in the Dominican Republic transported large quantities of cocaine into the United States using boats with secret compartments. Almonte was responsible for procuring and outfitting these vessels. After U.S. officials became aware of the operation, Almonte was indicted under seal in Washington, D.C., and later arrested during a layover at Miami International Airport. The United States District Court for the District of Columbia oversaw Almonte’s trial, during which a jury found him guilty of conspiracy to import cocaine and sentenced him to 184 months in prison. Almonte raised several constitutional claims on appeal: he argued that the 18-month delay between his indictment and arrest violated his Sixth Amendment right to a speedy trial, that venue in D.C. was improper under Article III and 18 U.S.C. § 3238, and that the district court’s refusal to grant a new trial after certain jurors expressed concerns about his counsel denied him an impartial jury. The United States Court of Appeals for the District of Columbia Circuit reviewed these claims. The court held that the delay between indictment and arrest did not violate Almonte’s right to a speedy trial, given the government’s good-faith investigative reasons and his failure to show specific prejudice. On venue, the court found that Almonte waived his only meritorious venue argument regarding the Eastern District of Virginia by not raising it when invited, and his other arguments about venue in Florida were either without merit or forfeited. Regarding juror impartiality, the court concluded that the district court handled the matter appropriately through voir dire and did not abuse its discretion in denying a mistrial or new trial. The judgment of the district court was affirmed. View "USA v. Almonte" on Justia Law

ROCKY PATEL PREMIUM CIGARS, INC. V. BONTA

2026-08-27T12:30:35-08:00

A group of premium cigar manufacturers and trade associations challenged California’s Unflavored Tobacco List statute, which requires tobacco products to be approved and listed by the California Attorney General before they may be sold to consumers, retailers, or wholesalers in the state. To be listed, manufacturers must submit detailed applications and pay fees, certifying their products lack any characterizing flavor. The plaintiffs argued that the law would impose considerable compliance costs, particularly burdensome for the premium cigar industry where products are hand-made in smaller batches and change blends frequently. They asserted that their premium cigars, by federal definition, do not contain flavoring additives, and that the application and fee requirements would force them to reduce their product offerings in California. The plaintiffs sought a preliminary injunction against enforcement of the statute in the United States District Court for the Central District of California. They contended that the federal Family Smoking Prevention and Tobacco Control Act (TCA) expressly preempts California’s law as applied to premium cigars and that the statute’s presumption against flavoring based on manufacturers’ speech violates the First Amendment. The district court denied the motion, concluding the plaintiffs were unlikely to succeed on the merits of their claims. Upon review, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of a preliminary injunction. The appellate court held that the TCA’s Savings Clause exempts state requirements related to the sale of tobacco products from preemption, and the challenged statute falls within this exemption as it is directly tied to retail sales. The court also found that, based on the Attorney General’s representations, the statute imposes only a minimal burden on commercial speech and does not restrict speech more than necessary. Thus, the Ninth Circuit affirmed the denial of injunctive relief. View "ROCKY PATEL PREMIUM CIGARS, INC. V. BONTA" on Justia Law

RICHARDS V. NEWSOM

2026-08-27T12:30:35-08:00

Several federally licensed firearms dealers (FFLs), including both brick-and-mortar and home-based businesses, gun rights organizations, and private citizens challenged a California statute, Section 26806, which requires all FFLs to maintain a digital video and audio recording system on their business premises. The statute mandates 24/7 surveillance of specific areas, such as points of sale and firearm display areas, and limits when and how recordings may be released or accessed, including requirements for posting notification signs and annual certification of system functionality. Plaintiffs argued that this law infringed their rights under the First, Fourth, and Fifth Amendments by imposing surveillance burdens, chilling speech, violating privacy, and effecting a taking of property. The United States District Court for the Central District of California dismissed the complaint for failure to state a claim. The district court found that Plaintiffs had not sufficiently alleged a likelihood of success on the merits of any claims, denied injunctive relief, and granted leave to amend. Plaintiffs eventually chose not to further amend and requested final judgment, which the district court entered, leading to this appeal. The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The court held that Plaintiffs failed to allege a cognizable Fourth Amendment claim because there was no physical government intrusion or access to recordings, nor did mere compliance with the statute transform FFLs into state actors. The court also found no Fifth Amendment violation, as the statute did not result in a physical or regulatory taking; FFLs retained ownership and control over their recording systems, and the economic impact did not rise to a taking. Finally, the court ruled that the First Amendment theories advanced by Plaintiffs—overbreadth, violations of the right to anonymity and association, and chilling of speech—were unsupported because the statute did not regulate or compel speech or disclosure, nor did it plausibly chill protected expression. The Ninth Circuit therefore affirmed the district court’s judgment. View "RICHARDS V. NEWSOM" on Justia Law

Zimmermann v. Labish

2026-08-27T11:30:22-08:00

A fourteen-year-old student, JPZ, was suspended from school following an altercation. The school principal, Melissa Arendts, notified JPZ's mother and requested JPZ be picked up. Upon arrival, JPZ's grandmother found him isolated and awaiting questioning by Scott Labish, a sheriff’s deputy serving as a school resource officer. Labish, in uniform, questioned JPZ, allegedly in a threatening manner, and told him about a “Three Strike” policy that would result in criminal prosecution and expulsion after another infraction. JPZ became distressed, left school, and subsequently died by suicide at home several hours later. JPZ's father, Brian Zimmermann, as administrator of JPZ’s estate, sued Arendts, Labish, the school district, and Macomb County, alleging federal due process violations and state law claims. The United States District Court for the Eastern District of Michigan dismissed the wrongful death claim but allowed four other claims to proceed: deprivation of substantive due process, conspiracy, intentional infliction of emotional distress, and Monell liability. Defendants moved to dismiss the remaining claims based on qualified and state governmental immunity and deficiencies in the Monell claim. The district court denied these motions in part, leading to an interlocutory appeal by the defendants. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial de novo. The Sixth Circuit held that the facts did not support a substantive due process claim under the state-created danger doctrine, as the defendants neither increased JPZ’s risk of harm from a third party nor acted with deliberate indifference. The conspiracy and Monell claims failed because no underlying constitutional violation was adequately alleged. The court also found the defendants entitled to state governmental immunity for the intentional infliction of emotional distress claim, as the conduct alleged did not indicate malice. The Sixth Circuit reversed the district court’s denial of the motions to dismiss and remanded the case. View "Zimmermann v. Labish" on Justia Law

P. v. Hazlett

2026-08-27T09:02:52-08:00

In October 1978, a woman named Tana Woolley was found dead in her apartment in Rosamond, California. She had been strangled with a sock, and her body was partially undressed. Initial investigation yielded no arrests, although DNA and other forensic evidence were collected. Decades later, with advances in DNA technology, semen stains found on Woolley’s bedspread were tested and matched the defendant, who lived in the same apartment complex at the time. The defendant denied knowing Woolley or ever being in her apartment. Further investigation revealed he had previously committed multiple sexual assaults, and evidence of these prior offenses was admitted at trial. The case was first tried in the Kern County Superior Court. The jury convicted the defendant of first degree murder and found true two special circumstances: that the murder was committed during the commission or attempted commission of rape and burglary, both requiring a finding of willful, deliberate, and premeditated murder under the then-applicable 1977 death penalty law. At the penalty phase, the jury returned a verdict of death, and the trial court entered judgment accordingly. The defense raised several issues, including challenges to jury selection, the admission of prior sexual offenses, and various constitutional and evidentiary claims. The Supreme Court of California reviewed the case on automatic appeal. It addressed whether the defendant established a prima facie case of racial discrimination in jury selection, the admissibility and instructions regarding other sexual offenses, the sufficiency of the evidence for the murder and special circumstance findings, and challenges under the California Racial Justice Act. The court held that the defendant failed to establish a prima facie case of discrimination in jury selection, that the evidence and instructions regarding prior sexual offenses were properly admitted, and that sufficient evidence supported the convictions and special circumstance findings. It further determined that no prejudicial error occurred under the Racial Justice Act. The court affirmed the judgment of death. View "P. v. Hazlett" on Justia Law

United States v. Valdez

2026-08-27T08:31:28-08:00

The case involves a defendant who was observed in a high-crime area of Albuquerque, New Mexico, acting suspiciously by loitering near a house, retrieving a duffel bag he had left overnight, and peering into the window of a car for sale. After the homeowner reported his behavior to the police, deputies responding to the call found the defendant matching the caller’s description. During their interaction, the defendant acted nervously, repeatedly reached into his duffel bag, and did not comply with officers’ commands. The deputies conducted a pat-down, discovering a pistol, a magazine, and cash on his person. After running his information, they learned of outstanding felony warrants, arrested him, and searched the duffel bag, uncovering methamphetamine and drug paraphernalia. In the United States District Court for the District of New Mexico, the defendant moved to suppress the evidence from his person and the duffel bag, arguing the stop, frisk, and search were unlawful. Initially, the district court indicated the stop and frisk were lawful but suppressed the contents of the duffel bag, finding no valid inventory search or basis for inevitable discovery. After the government submitted additional evidence regarding inventory procedures, the district court reconsidered and denied the motion to suppress, holding that the items would have been inevitably discovered during a lawful inventory search prior to booking. The United States Court of Appeals for the Tenth Circuit reviewed the appeal. The court concluded that the stop was supported by reasonable suspicion given the defendant's suspicious behavior in a high-crime area. The court further held that, even if the frisk or bag search had been unlawful, the items would have been inevitably discovered either during a search incident to arrest or a proper inventory search. The Tenth Circuit affirmed the district court’s denial of the motion to suppress, upholding the convictions. View "United States v. Valdez" on Justia Law

Romantix-Fargo, Inc. v. City of Fargo

2026-08-27T07:30:18-08:00

A business specializing in adult products sought to open a store in downtown Fargo, North Dakota, in a zone designated for mixed-use development. The proposed store intended to sell items such as lingerie and sexual wellness products, but not sexually explicit media like books or DVDs. To proceed, the business’s landlord applied for a change-of-use permit to allow retail sales and service at the location. The City of Fargo, through its Director of Planning and Development, denied the application, concluding that the business constituted an "Adult Bookstore" as defined by the city’s municipal code, which prohibited such establishments in the downtown zone. The city’s decision was upheld by both the Fargo Board of Adjustment and the Board of City Commissioners. Following these administrative decisions, the business filed suit in the United States District Court for the District of North Dakota, raising constitutional claims including violations of the First Amendment, the imposition of a prior restraint, denial of procedural due process, and unconstitutional vagueness in the city’s code. The business also challenged the Commissioners’ decision under state law, arguing it was arbitrary and capricious. While the lawsuit was pending, Fargo amended its code to explicitly prohibit “Sexual Device Shops” in the relevant zone. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the dismissal of all federal claims, holding that the business’s planned activities were not protected expressive conduct under the First Amendment, the permit process was not a prior restraint, and the business received adequate procedural process. The court also found the city’s ordinance was not unconstitutionally vague. However, the court determined that denying the permit as an “Adult Bookstore” was arbitrary and capricious under state law, reversed the dismissal of the state-law claim, and remanded for further proceedings regarding possible relief. View "Romantix-Fargo, Inc. v. City of Fargo" on Justia Law

Rokhvand & Barmada v. Herzfeld

2026-08-27T06:31:38-08:00

Two activists participated in demonstrations outside the Israeli embassy in Washington, D.C., protesting Israel's military actions in Gaza. Over several months, three incidents occurred involving Rabbi Herzfeld, a local rabbi and community leader, and the activists. During these incidents, the activists alleged that Rabbi Herzfeld and his companions made provocative and upsetting remarks, engaged in intimidating behavior, and, in one instance, initiated a federal lawsuit and media coverage that the activists felt endangered them. The activists felt harassed and took steps to increase their personal security after these events. Following the third incident, the activists filed petitions for anti-stalking orders in the Superior Court of the District of Columbia, alleging that Rabbi Herzfeld’s conduct constituted stalking under D.C. law. Rabbi Herzfeld moved to dismiss the petitions, arguing that his actions were protected by the First Amendment and did not meet the statutory definition of stalking, citing precedent from Mashaud v. Boone. The trial court held a summary trial and ultimately denied the petitions, finding that the conduct did not amount to threats or surveillance within the meaning of the statute and was constitutionally protected speech. Rabbi Herzfeld later sought attorney’s fees under the D.C. Anti-SLAPP Act and, alternatively, for alleged bad faith. The District of Columbia Court of Appeals reviewed the case. It affirmed the denial of the anti-stalking petitions, holding that Rabbi Herzfeld’s conduct did not constitute “true threats” and was protected political speech, not actionable as stalking. The court vacated the award of attorney’s fees, finding the trial court had applied the wrong legal standard under the Anti-SLAPP Act and had not given proper notice for a bad-faith fee award. The matter was remanded for further proceedings regarding attorney’s fees. View "Rokhvand & Barmada v. Herzfeld" on Justia Law

Quarles v. United States

2026-08-27T06:31:38-08:00

Police officers observed an African-American man walking past their parked cruiser and believed they saw the imprint of a handgun magazine under his clothing at his waistband. The officer, with extensive firearms experience, was not certain whether the object could have been a wallet or a bag. The officers followed the man after he left a restaurant, calling out to him. When he did not respond and instead ran, the officers chased and tackled him, recovering a handgun from his hip. The officers were not responding to any report of crime and had no prior information about the man. They did not know whether he was lawfully carrying the firearm. After a hearing, the Superior Court of the District of Columbia denied the defendant’s motion to suppress the firearm, finding that the officers had reasonable, articulable suspicion of criminal conduct based on the officer’s testimony and the defendant’s flight, which was interpreted as consciousness of guilt. The defendant was subsequently convicted of several weapon offenses. On appeal, the District of Columbia Court of Appeals reviewed the trial court’s factual findings for clear error and considered de novo whether reasonable, articulable suspicion existed. The appellate court held that, in light of recent constitutional and statutory developments, mere possession of a handgun, without more, does not provide reasonable, articulable suspicion for a stop in the District of Columbia. The court also found that the circumstances of the defendant’s flight did not significantly increase suspicion, given the context of the police approach. Considering the totality of the circumstances, the appellate court concluded that the officers lacked reasonable, articulable suspicion and that the stop violated the Fourth Amendment. The court vacated the convictions and remanded the case for further proceedings. View "Quarles v. United States" on Justia Law

Allied Health & Chiropractic, L.L.C. v. State

2026-08-27T05:00:39-08:00

Two Ohio statutes were originally enacted as part of the state’s 2020-2021 budget bill. One statute restricted healthcare providers from soliciting crime or motor-vehicle-accident victims for 30 days after such incidents, and the other created a public records exception for victims’ telephone numbers in police reports. Before these statutes took effect, several healthcare providers challenged their constitutionality in Cuyahoga County Common Pleas Court, arguing that the statutes violated Ohio’s constitutional one-subject rule by exceeding the proper scope of a budget bill. While litigation was ongoing, the General Assembly enacted separate bills that amended both statutes: one changed the solicitation restriction, and two others amended the public records exception. The trial court denied the defendants’ motions to dismiss and subsequently granted summary judgment for the plaintiffs, holding that the two statutes were unenforceable because they originated in a budget bill that violated the one-subject rule. The Eighth District Court of Appeals affirmed this decision, concluding that the subsequent amendments were void since they amended provisions not validly enacted in the first place. The appellate court did not rule on other constitutional claims, finding it unnecessary after resolving the one-subject rule issue. The Supreme Court of Ohio reviewed the case and reversed the Eighth District’s judgment. The court held that when the General Assembly amends a statute through a new bill, the amendment repeals the prior version and enacts the statute anew. Therefore, the constitutionality of the original versions does not render the amended statutes void. The operative law is now the amended language, and any alleged constitutional defects in the earlier versions are irrelevant to the validity of the later-enacted statutes. The case was remanded to the Eighth District for further proceedings on other issues. View "Allied Health & Chiropractic, L.L.C. v. State" on Justia Law

USA v. Palencia-Berrum

2026-08-26T15:30:08-08:00

The defendant pled guilty to a single count of illegal reentry after removal from the United States. His presentence report detailed a criminal history that included prior convictions for driving under the influence, obstruction of justice, unlawful possession or consumption of alcohol by a minor, domestic battery, drug trafficking, and a previous illegal reentry. After being deported for his earlier illegal reentry, the defendant returned to the United States, purportedly to assist his wife, who was recovering from a significant injury and mental health issues. About ten months after his return, he was arrested for assaulting his wife, but the charges were later dismissed. The presentence report indicated the incident involved the defendant throwing water bottles at his wife, causing minor injuries, but made no mention of direct physical contact or biting. The United States District Court for the Western District of Texas conducted a brief sentencing hearing, during which it adopted the presentence report but made several factual errors. The court incorrectly referenced a 2020 illegal reentry conviction that did not exist and mistakenly asserted that the defendant had bitten his wife during the alleged assault. The district court treated these purported facts as aggravating factors and sentenced the defendant to 46 months, at the top of the Guidelines range, without stating whether the same sentence would have been imposed absent these errors. No contemporaneous objections were raised by the parties. The United States Court of Appeals for the Fifth Circuit reviewed the case under the plain error standard. The court found that the district court relied on clearly erroneous facts, that the errors were clear under established law, and that they affected the defendant’s substantial rights by likely increasing his sentence. The Fifth Circuit vacated the sentence and remanded for resentencing, holding that sentencing based on unfounded facts violates due process and undermines the fairness and integrity of judicial proceedings. View "USA v. Palencia-Berrum" on Justia Law

Natl Infusion Center v. Kennedy

2026-08-26T15:30:07-08:00

A group of associations representing infusion centers, cancer patients, and pharmaceutical manufacturers challenged the constitutionality of a program created by the Inflation Reduction Act of 2022, which directs the Secretary of Health and Human Services (HHS), through the Centers for Medicare and Medicaid Services (CMS), to negotiate prices for high-expenditure prescription drugs under Medicare Parts B and D. The program allows HHS to select drugs based on certain criteria, negotiate a “maximum fair price” with manufacturers, and impose an excise tax on manufacturers who refuse to negotiate. The tax is calculated as a high percentage of sales reimbursed by Medicare. Manufacturers may avoid the program by withdrawing from Medicare and Medicaid participation. The statutory scheme also limits administrative and judicial review of key program decisions and allows HHS to implement early cycles of the program through guidance rather than notice-and-comment rulemaking. The United States District Court for the Western District of Texas initially dismissed the case for lack of subject-matter jurisdiction and improper venue. On appeal, the United States Court of Appeals for the Fifth Circuit reversed and remanded, finding that at least one plaintiff had standing and venue was proper. On remand, the district court granted summary judgment for the government, holding that the program did not violate the nondelegation doctrine, that the Anti-Injunction Act barred the plaintiffs’ Eighth Amendment claim, and that the plaintiffs lacked a protected property interest to support their due process claim. Upon further appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The court held that the statute provided an “intelligible principle” sufficient to withstand a nondelegation challenge, that the Anti-Injunction Act did not bar the Eighth Amendment claim but the excise tax did not constitute a punitive fine, and that neither manufacturers, providers, nor patients possessed a protected property or liberty interest implicated by the program. The government’s summary judgment was affirmed in full. View "Natl Infusion Center v. Kennedy" on Justia Law

Fellers v. Kelley

2026-08-26T13:30:02-08:00

Several parents and a grandparent of two female high school athletes challenged actions taken by officials of a New Hampshire public school district. The dispute arose after the parents wore pink "XX" wristbands during a girls' soccer game as a passive protest against the participation of a transgender athlete, in light of recent litigation about transgender students’ eligibility for girls’ sports. School administrators, concerned about possible harassment and disruption, instructed the protestors to remove the wristbands and later issued sanctions, including no-trespass orders preventing them from attending future school events. The United States District Court for the District of New Hampshire reviewed the plaintiffs’ request for a preliminary injunction. It analyzed the school’s actions under First Amendment principles applicable to limited public fora and determined that the administrators’ interpretation and enforcement of school policy did not constitute impermissible viewpoint discrimination. The district court denied the request for injunctive relief, concluding that the school’s interests justified its response to the protest. The United States Court of Appeals for the First Circuit examined whether the school district’s actions amounted to viewpoint discrimination against the plaintiffs’ passive speech. The court found that the protest did not materially disrupt the event or amount to harassment, and that the sanctions appeared motivated by disagreement with the protest’s message. The First Circuit held that the plaintiffs demonstrated a likelihood of success on their viewpoint discrimination claim, specifically regarding the sanctions imposed at the soccer game’s sidelines and adjacent parking lot. The court remanded the case to the district court for further proceedings to determine whether any interim relief, such as a declaratory judgment, is warranted. No costs were awarded. View "Fellers v. Kelley" on Justia Law

O'Connor v. Eubanks

2026-08-26T11:30:07-08:00

Dennis O’Connor had two non-interest-bearing financial accounts with private companies. After O’Connor lost contact with these companies, they transferred his accounts to the State of Michigan under the state’s Uniform Unclaimed Property Act, which governs the handling of unclaimed property. Michigan took custody of O’Connor’s accounts and deposited the funds into its general fund, where the money could generate interest for the state. When O’Connor learned of this, he contended that the state’s failure to pay him the interest earned while holding his money violated his constitutional rights. Previously, the United States District Court for the Eastern District of Michigan dismissed all of O’Connor’s claims, finding that the state took ownership of his accounts and thus owed him no interest. On an earlier appeal, the United States Court of Appeals for the Sixth Circuit affirmed the dismissal of his takings claims but vacated the dismissal of his due process claims and remanded for further proceedings. On remand, the district court again dismissed O’Connor’s due process claims, reasoning that Michigan’s ownership of the accounts meant O’Connor had no right to the interest and that the procedures provided were constitutionally sufficient. The United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that under Michigan law, the state only assumes custody—not ownership—of unclaimed property, and the original owner retains title to both the principal and any interest generated. The court found that the district court erred by following contrary state appellate precedent and by concluding that O’Connor had no property interest in the funds or the interest. The court vacated the district court’s judgment dismissing the due process claims and remanded for further proceedings, directing the lower court to analyze the due process claim based on the correct understanding that O’Connor retained ownership rights. View "O'Connor v. Eubanks" on Justia Law

State v. Toste

2026-08-26T10:33:00-08:00

The defendant was convicted of murder following a retrial in 1981 and sentenced to an indeterminate term of 25 years to life, with a mandatory minimum of 25 years. The underlying facts involved the killing of a friend’s mother during a burglary and a subsequent fatal car crash. The defendant’s conviction was affirmed on direct appeal and collateral review. While incarcerated, the defendant applied for parole in 2013 and 2019, and for a commutation of his sentence in 2021; all applications were denied. He then filed a motion for sentence modification, citing his intellectual disability, youth at the time of the offense, remorse, age, physical incapacity, and low risk of recidivism as grounds for good cause. The trial court denied the motion, finding the defendant had not established good cause. On appeal, the Connecticut Appellate Court affirmed the trial court’s decision, holding that it was proper to consider the Board of Pardons and Paroles’ prior denials of parole and commutation as part of the sentence modification inquiry. The Appellate Court also noted that the trial court had considered other relevant factors, such as the seriousness of the offense, the impact on the victims, and the defendant’s disciplinary record while incarcerated. The Supreme Court of Connecticut reviewed the case on certification. It held that a trial court may consider prior decisions of the Board of Pardons and Paroles in ruling on a motion for sentence modification, as such information falls within the broad scope of relevant sentencing information. The Court found no abuse of discretion or due process violation, as the trial court’s reliance on the board’s denials was not impermissibly speculative and was only one factor among several considered. The judgment of the Appellate Court was affirmed. View "State v. Toste" on Justia Law

Acevedo v. de la Portilla

2026-08-26T09:31:03-08:00

A city’s Chief of Police was recruited for his reformist reputation and soon after his arrival, he observed and reported that several City Commissioners were improperly interfering in police investigations and using police resources to pursue personal vendettas. The Chief communicated his concerns to the Mayor and City Manager, and, believing himself unable to investigate the Commissioners due to a prior City resolution, he sent a whistleblowing memorandum detailing abuses of power to the Mayor, City Manager, the State Attorney’s Office, and the FBI. The memo was subsequently leaked to the media. Following this, the Chief faced public criticism from the Commissioners, had his job responsibilities undermined, was suspended with pay by the City Manager pending a termination hearing, and was ultimately terminated by the City Commission. The Chief filed suit in the United States District Court for the Southern District of Florida against three Commissioners and the City Manager, alleging retaliation for protected First Amendment activity under 42 U.S.C. § 1983. The individual defendants moved to dismiss, asserting legislative and qualified immunity. The district court denied their motions, finding that neither defense shielded the Commissioners or the City Manager at that stage. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of immunity de novo. The Eleventh Circuit held that the Commissioners were not entitled to legislative immunity because terminating an employee is administrative, not legislative, action. The court further held that the Commissioners were not entitled to qualified immunity at the pleading stage because, accepting the complaint’s allegations as true, the Chief’s whistleblower memo was constitutionally protected speech, and binding precedent clearly established that retaliating against such speech is unlawful. However, the court held that the City Manager was entitled to qualified immunity, as it was not clearly established that suspending the Chief with pay, pending further proceedings, constituted an adverse employment action. The panel affirmed the denial of immunity for the Commissioners, reversed as to the City Manager, and remanded for further proceedings. View "Acevedo v. de la Portilla" on Justia Law

USA v. Mitchell

2026-08-26T09:30:09-08:00

Officers responding to a reported burglary encountered Maurice Mitchell near a storage facility, leading to his flight, capture, and discovery of a loaded revolver in a bag on his bicycle. Mitchell has a history of felony convictions, including drug possession and attempting to disarm a peace officer, the latter involving an attempt to grab pepper spray from an officer during an arrest. Based on the January 2023 incident, Mitchell was indicted for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The United States District Court for the Western District of Louisiana denied Mitchell’s pretrial motions to dismiss the indictment, which asserted Second Amendment protections against prosecution. The court focused on Mitchell’s drug convictions as predicates, not addressing the attempted disarmament conviction. At trial, the court issued a flight instruction over Mitchell’s objection, directing the jury to consider his flight as evidence of consciousness of guilt. The jury ultimately returned a guilty verdict, and Mitchell was sentenced to prison and supervised release. He timely appealed. The United States Court of Appeals for the Fifth Circuit reviewed Mitchell’s Second Amendment challenge de novo. The court held that Mitchell’s conviction for attempting to disarm a police officer is analogous to robbery, historically a crime for which individuals could be disarmed under firearm regulations. Thus, the application of § 922(g)(1) to Mitchell was constitutional. The court also found that the district court did not abuse its discretion in issuing the flight instruction, and the evidence was sufficient to support Mitchell’s conviction under the stringent “manifest miscarriage of justice” standard. Consequently, the Fifth Circuit affirmed the judgment of the district court. View "USA v. Mitchell" on Justia Law

GRENNING V. KEY

2026-08-26T09:00:34-08:00

An inmate at Airway Heights Corrections Center participated in a prison writing program sponsored by Eastern Washington University, which encouraged submissions to a university literary journal. The inmate wrote a short story containing a brief reference to sexual intimacy and submitted it for consideration. The prison’s Community Partnership Program Coordinator intercepted the submission, deeming it “inappropriate for publication” due to its “sexual content,” and returned it to the inmate. The inmate then mailed the story directly to the university and complained to the prison superintendent, who endorsed the decision to block the submission and warned that further unauthorized correspondence would result in removal from the program. The United States District Court for the Eastern District of Washington granted summary judgment for the prison officials, concluding that they had not violated the inmate’s First Amendment rights and, even if they had, their actions were protected by qualified immunity. The court applied the deferential standard from Turner v. Safley, which governs regulations of prisoner conduct, and found no retaliation. The court also denied the inmate’s motions for additional discovery and to vacate the judgment. Reviewing the case, the United States Court of Appeals for the Ninth Circuit reversed the district court’s summary judgment, including its qualified immunity determination, and remanded for further proceedings. The Ninth Circuit held that the district court erred by applying the Turner standard instead of the standard from Procunier v. Martinez, which governs outgoing inmate correspondence. The panel determined that genuine disputes of fact existed and, if proven, could show that the prison officials’ refusal to transmit the inmate’s story constituted prohibited censorship under the First Amendment. The court also held that the district court erred in its analysis of the retaliation claim and instructed that it should be evaluated under Rhodes v. Robinson, which sets forth the elements for a First Amendment retaliation claim in the prison context. View "GRENNING V. KEY" on Justia Law

USA v. McIver

2026-08-26T09:00:04-08:00

A member of Congress from New Jersey was charged with three counts of violating federal law after allegedly physically interfering with federal officials during an oversight visit to a federal immigration detention facility in Newark. During the visit, the Congresswoman and other Representatives encountered Newark’s Mayor, who was ordered to leave the premises by federal agents. When federal agents attempted to arrest the Mayor, the Congresswoman allegedly placed herself between the Mayor and an agent, forcibly made contact with the agent, and later pushed past another federal officer to reenter the facility. The charges stem from these physical altercations and the Congresswoman’s efforts to impede the Mayor’s arrest. The United States District Court for the District of New Jersey denied the Congresswoman’s motions to dismiss the indictment. The court found that her conduct was not protected by legislative immunity under the Speech or Debate Clause, concluding it was non-legislative in nature. The court also rejected her arguments based on the separation of powers doctrine, distinguishing between Presidential and legislative immunities. Additionally, the court ruled against her selective and vindictive prosecution claims, finding she failed to demonstrate discriminatory effect or personal animus by the prosecution. The United States Court of Appeals for the Third Circuit reviewed the District Court’s decisions. The Third Circuit affirmed the denial of legislative immunity for Counts One and Two, holding that prosecution of those charges would not require the Congresswoman to answer for any legislative acts. The court vacated and remanded with respect to Count Three for further consideration as to whether legislative immunity might apply. The court dismissed the remainder of her appeal, including claims of selective and vindictive prosecution, for lack of jurisdiction. View "USA v. McIver" on Justia Law

USA v. Luna

2026-08-25T15:30:05-08:00

Raymond Luna was indicted under 18 U.S.C. § 922(g)(1) for being a felon in possession of a firearm. The only felony conviction supporting this indictment was Luna’s prior conviction for possession of a controlled substance. The district court found that applying § 922(g)(1) to Luna violated the Second Amendment as applied to him and dismissed the indictment. After the dismissal, the Government moved for reconsideration, providing new evidence from Luna’s prior conviction that suggested he was involved in drug trafficking, rather than mere possession. The district court denied the motion for reconsideration, reasoning that the Government could have, but did not, present this evidence earlier. On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of the motion for reconsideration for abuse of discretion, as the district court declined to consider the new evidence presented by the Government after the original dismissal. The Fifth Circuit observed that the Government did not argue in its opening appellate brief that the district court abused its discretion in refusing to consider the late-submitted evidence, thereby forfeiting that argument. The appellate court further declined to revisit the district court’s ruling based on the late-submitted evidence. The Fifth Circuit held that, with only the fact of Luna’s conviction for simple possession before it, binding precedent established that such a conviction cannot support a § 922(g)(1) prosecution post-Hembree. The court also rejected the Government’s alternative arguments, including the assertion that historical regulations on illicit marketplaces justified disarmament, and found that Luna’s indictment status for a separate firearm offense was irrelevant under circuit precedent. As a result, the Fifth Circuit affirmed the district court’s dismissal of the indictment. View "USA v. Luna" on Justia Law

State v. Garding

2026-08-25T15:11:29-08:00

The appellant was convicted by a jury in 2011 of vehicular homicide while under the influence, failure to stop immediately at an accident scene involving an injured person, and driving without a valid driver’s license, and received a forty-year prison sentence. Over the years, she challenged her conviction through direct appeal and postconviction relief in the Montana Supreme Court, raising issues such as the limitation of cross-examination, undisclosed witnesses, ineffective assistance of counsel, and alleged Brady violations. Each of her challenges was rejected by the Montana Supreme Court, which found no reversible error or constitutional violation. After exhausting state remedies, the appellant petitioned for federal habeas corpus relief in the United States District Court for the District of Montana, which partially granted relief based on ineffective assistance of counsel. The federal district court ordered the State to either retry the appellant or release her. In response, the State reinstated criminal proceedings in the state District Court, and the appellant filed a motion to substitute the presiding judge. However, while those state proceedings were pending, the United States Court of Appeals for the Ninth Circuit reversed the federal district court’s grant of habeas relief, upholding the Montana Supreme Court’s findings and nullifying the order that had set aside the conviction. Following the Ninth Circuit’s reversal, the Fourth Judicial District Court, Missoula County, reinstated the appellant’s convictions and custody. On appeal, the Supreme Court of the State of Montana held that the appellant was not entitled to judicial substitution because no new criminal action or proceeding had commenced following the federal habeas reversal. The Court affirmed the District Court’s reinstatement of the convictions, concluding that the statutory requirements for judicial substitution had not been triggered. View "State v. Garding" on Justia Law

United States v. Phillips

2026-08-25T13:00:54-08:00

The case concerns a fatal shooting that occurred after an altercation in a bar, where the defendant, after being physically attacked and ejected by several patrons, retrieved a firearm from his vehicle and fired into the bar, killing a patron. There was evidence presented that the defendant suffered from post-traumatic stress disorder and possibly a traumatic brain injury as a result of the fight, which could have affected his mental state and perception of danger at the time of the shooting. The United States District Court for the Eastern District of Oklahoma presided over the original trial, where the defendant was convicted of first-degree murder in Indian Country and using a firearm during and in relation to a crime of violence. The district court instructed the jury on imperfect self-defense but did not inform them that the government bore the burden to disprove this defense beyond a reasonable doubt. The court also instructed on diminished capacity, stating it was not a defense to second-degree murder or manslaughter. The defendant raised several challenges on appeal, including errors in jury instructions and prosecutorial misconduct during closing arguments. The district court also addressed multiplicitous charges under 18 U.S.C. §§ 924(c) and 924(j), dismissing the greater-included offense. On appeal, the United States Court of Appeals for the Tenth Circuit found that the district court committed plain error by failing to instruct the jury that the government must disprove imperfect self-defense beyond a reasonable doubt as to first-degree murder. This error affected the defendant's substantial rights and seriously impacted the fairness of the proceedings, necessitating reversal of the first-degree murder conviction. The Tenth Circuit rejected the defendant’s other challenges, including those related to diminished capacity instructions and prosecutorial statements. The court affirmed the district court’s choice to dismiss the greater-included firearm offense and remanded for further proceedings consistent with its opinion. View "United States v. Phillips" on Justia Law

USA v Anderegg

2026-08-25T12:00:11-08:00

The defendant was charged with producing, distributing, and possessing AI-generated images that depicted minors engaged in sexually explicit conduct, as well as transferring such material to a minor. The images were alleged to be created using Stable Diffusion, a text-to-image generative AI program, and did not involve real children. Law enforcement linked the defendant to these images after a report by Meta Platforms, which found the material sent to a minor on Instagram. A search of the defendant’s devices revealed hundreds of similar AI-generated images. In the United States District Court for the Western District of Wisconsin, the defendant moved to dismiss the count charging him with knowing possession of obscene virtual child sexual abuse material (CSAM) in violation of 18 U.S.C. § 1466A(b)(1). The district court granted the motion as to the possession charge, concluding that the statute was unconstitutional as applied in this context. The court reasoned that, under Stanley v. Georgia, individuals have a First Amendment right to possess obscenity in their homes, and that this right extends to virtual CSAM, especially in light of the Supreme Court’s decision in Ashcroft v. Free Speech Coalition, which distinguished virtual CSAM from material involving actual children. The court left the production and distribution charges intact. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. The Seventh Circuit held that Supreme Court precedent—specifically Stanley v. Georgia and Ashcroft v. Free Speech Coalition—controls the as-applied challenge. The court found that, because the images did not depict real children, the government’s justifications for banning their possession in the home had been expressly rejected by the Supreme Court. Accordingly, the Seventh Circuit affirmed the district court’s judgment, holding that 18 U.S.C. § 1466A(b)(1) is unconstitutional as applied to the defendant’s in-home possession of obscene virtual CSAM. View "USA v Anderegg" on Justia Law

United States v. Barker

2026-08-25T10:31:45-08:00

In this case, the defendant was indicted for murder and related firearm offenses arising from the death of an individual in Indian Country. A key witness, William Lozer, had previously testified at a state preliminary hearing that the defendant confessed to and described details of the crime. Prior to the defendant's federal trial, the government was unable to locate Lozer, who was known to be transient and had not been seen or contacted by his family or attorney for months. The government sought to introduce Lozer's prior testimony, which had been given under oath and subject to cross-examination by defense counsel. The United States District Court for the Eastern District of Oklahoma considered whether the government had made sufficient efforts to locate Lozer and ultimately found that, despite reasonable and good-faith efforts, Lozer was unavailable as a witness. As a result, the court permitted the prior testimony to be read to the jury. At trial, additional evidence against the defendant was introduced, including incriminating statements to other individuals and physical evidence. The defendant was convicted on all counts, and the district court sentenced him to life in prison. On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the defendant’s argument that his Sixth Amendment right to confront witnesses was violated by the admission of Lozer’s prior testimony. Applying a de novo standard of review, the Tenth Circuit held that the government’s efforts to locate Lozer were reasonable and made in good faith under the circumstances. Thus, Lozer was properly deemed unavailable, and the admission of his prior, cross-examined testimony did not violate the defendant’s confrontation rights. The Tenth Circuit affirmed the defendant’s convictions. View "United States v. Barker" on Justia Law

US v. Smith

2026-08-25T10:30:48-08:00

After police responded to a theft report at a convenience store in Chesterfield County, Virginia, Markel Trevon Smith and another individual were detained. A search of their vehicle revealed four firearms, including a Glock pistol equipped with a device converting it into a machinegun. This Glock bore three serial numbers: two had been scratched, leaving only partial digits visible, while one serial number remained fully legible. The firearm was traced using the unaltered serial number. Smith was indicted in the United States District Court for the Eastern District of Virginia for possession of a machinegun in violation of 18 U.S.C. § 922(o). He moved to dismiss, arguing that § 922(o) violated the Second Amendment, but the district court denied the motion. Smith then pled guilty. At sentencing, the court adopted the Presentence Report’s recommendation to apply a four-level enhancement under U.S. Sentencing Guidelines § 2K2.1(b)(4)(B)(i), which increases the offense level if any firearm has a serial number modified so that the original information is illegible or unrecognizable to the unaided eye. The district court reasoned that altering any serial number on the firearm warranted the enhancement, and sentenced Smith to 57 months’ imprisonment. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed Smith’s conviction, holding that § 922(o) does not violate the Second Amendment, either facially or as applied to Smith, because machineguns are not in common use for lawful purposes. However, the Fourth Circuit found that the district court erred in applying the serial number enhancement. The court held that the enhancement only applies where modifications render the firearm as a whole untraceable, which was not the case since one serial number remained fully legible. The appellate court therefore reversed the application of the enhancement, vacated Smith’s sentence, and remanded for resentencing without the enhancement. View "US v. Smith" on Justia Law

COUNTY OF KING V. TURNER

2026-08-25T08:30:27-08:00

Several cities, counties, and local agencies across the United States challenged new conditions imposed by the Department of Housing and Urban Development (HUD) and the Department of Transportation (DOT) on federal grants they had already been awarded. These new conditions, added after the grants were awarded, required recipients to certify compliance with federal antidiscrimination laws for all their programs (not just those funded by the grants), acknowledge that such certifications are material for purposes of the False Claims Act, refrain from using grant funds to promote “gender ideology,” “elective abortions,” or “illegal immigration,” and verify the immigration status of individual grant recipients. The United States District Court for the Western District of Washington considered the plaintiffs’ motion for a preliminary injunction. The district court found that the new conditions went beyond merely enforcing existing legal requirements and exceeded the agencies' statutory authority. It enjoined the agencies from enforcing all of the challenged conditions, from withholding grant funds based on those conditions, from requiring certifications of compliance, and from refusing to process grant agreements because of the litigation. On appeal, the United States Court of Appeals for the Ninth Circuit reviewed whether the agencies’ imposition of these grant conditions was lawful under the relevant statutes. The Ninth Circuit affirmed the district court’s preliminary injunction in large part. The court held that: (1) the conditions requiring compliance with antidiscrimination laws are unlawful to the extent they apply to programs or activities not receiving federal funds, but are permissible as to federally funded programs; (2) the conditions making compliance certifications “material” for False Claims Act purposes are not authorized by statute; (3) the restrictions on the use of grant funds for promoting certain ideas or activities exceed statutory authority; and (4) the requirement to use a specific immigration verification system is unauthorized. The appellate court remanded with instructions to narrow the injunction to allow antidiscrimination conditions for federally funded programs, but otherwise affirmed the district court’s injunction. View "COUNTY OF KING V. TURNER" on Justia Law

Prunty v. Obregon

2026-08-25T07:30:12-08:00

A police officer in Jonesboro, Arkansas, encountered Jayden Prunty standing in the street holding a plastic bag late at night in an area known for high crime. The officer, identifying himself and stating he was conducting drug interdiction, approached Prunty, claimed to smell marijuana, and repeatedly told him to “come here.” Prunty denied the accusation, became visibly nervous, and walked away. When Prunty began to run, the officer caught him and pushed him to the ground. During the ensuing struggle, a firearm discharged, and the officer was shot in the leg. The officer then drew his own weapon and fatally shot Prunty. Prunty was later pronounced dead at the hospital. The administrators of Prunty’s estate brought a civil rights action in the United States District Court for the Eastern District of Arkansas under 42 U.S.C. § 1983, alleging violations of the Fourth and Fourteenth Amendments. The district court granted summary judgment in favor of the officer, finding that the officer’s actions did not violate clearly established rights and that he was entitled to qualified immunity. The court determined that the officer had reasonable suspicion to detain Prunty based on the odor of marijuana, Prunty’s nervous behavior, and attempted flight, and that his use of force was objectively reasonable under the circumstances. Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the officer did not seize Prunty until applying physical force, at which point reasonable suspicion existed. The court also found the officer’s use of force, including the takedown and subsequent use of deadly force after being shot, was objectively reasonable. Accordingly, the officer was entitled to qualified immunity, and the grant of summary judgment was affirmed. View "Prunty v. Obregon" on Justia Law

United States v. Burton

2026-08-25T07:30:12-08:00

Law enforcement officers responded to a report of a possible drug overdose at a residence in Onamia, Minnesota. Upon arrival, they found Jeremy Burton unconscious with drug paraphernalia present. After being revived with Narcan, officers noticed a handgun magazine protruding from Burton’s shorts. During the encounter, another individual tried to prevent officers from retrieving the firearm, but it was ultimately secured. Burton was transported to a hospital and found to have multiple controlled substances in his system. He was charged as a felon in possession of a firearm, with a sentencing enhancement under the Armed Career Criminal Act due to prior convictions. The United States District Court for the District of Minnesota presided over Burton’s trial. The court granted the government’s motion in limine to exclude expert testimony from a pharmacologist regarding the effects of drugs on Burton’s mental state, finding voluntary intoxication was not a defense to the charge. At trial, Burton testified that someone had planted the gun on him while he was unconscious, but the jury found him guilty. The district court sentenced him to 240 months of imprisonment, which was a downward variance from the applicable guidelines range. Burton appealed, arguing error in excluding the expert testimony and that his sentence was substantively unreasonable. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary ruling for abuse of discretion and, where constitutional issues were implicated, de novo. The appellate court held that voluntary intoxication is not a defense to being a felon in possession of a firearm, and thus the exclusion of the expert testimony was proper. The court also found that the sentence was substantively reasonable, given the district court’s consideration of both aggravating and mitigating factors. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Burton" on Justia Law

SGCI Holdings III LLC v. FCC

2026-08-25T07:01:19-08:00

In 2022, Soohyung Kim and his company, through an affiliate, secured a winning bid to purchase TEGNA, a large broadcast television company. The transaction required regulatory approval from the Federal Communications Commission (FCC) within 450 days, as specified in the merger agreement. The proposal drew objections from several organizations and individuals, including labor unions, public interest groups, and a rival bidder. Amid ongoing objections and extended public comment periods, the FCC’s Media Bureau ultimately failed to approve the license transfer within the required timeframe, resulting in the expiration of the merger agreement and obligating Kim’s group to pay significant break-up fees. After the collapse of the merger, the appellants filed suit in the United States District Court for the District of Columbia against both the FCC and various private parties. They alleged constitutional and statutory violations, including Equal Protection claims, Communications Act violations, federal civil rights and conspiracy claims, and D.C.-law tort claims, asserting that the FCC and private parties conspired to prevent the merger based on race. The District Court dismissed all claims. Regarding the FCC, the court found the appellants lacked standing for prospective relief, as they failed to allege a substantial risk of future injury. The court also dismissed the Communications Act claims for lack of jurisdiction. As to the claims against private parties, the court applied Noerr-Pennington immunity and found no plausible basis for the civil rights or tort claims. On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the District Court’s dismissal. The court held that the appellants lacked standing against the FCC due to insufficient allegations of likely future injury. The court further held that the claims against private appellees failed because the complaint did not plausibly allege intentional race discrimination or actionable tortious interference, and thus did not state a claim upon which relief could be granted. View "SGCI Holdings III LLC v. FCC" on Justia Law

Trump v. California

2026-08-25T05:15:05-08:00

The President issued an Executive Order that directed certain federal agencies to take actions related to election integrity, including creating and distributing lists of eligible voters, prioritizing prosecution of officials issuing ballots to ineligible voters, and initiating a rulemaking related to ballot tracking. The Order did not impose any requirements on states or parties outside the Executive Branch, and all actions were subject to feasibility and compliance with existing law. Shortly after the Order was issued, several states and the District of Columbia sued, arguing that the Order unconstitutionally infringed on their authority to administer elections. The United States District Court for the District of Massachusetts agreed with the states and entered a final judgment enjoining the federal government from implementing the challenged provisions of the Order as to the plaintiff states for the upcoming midterm elections. The government sought a stay of this injunction from the United States Court of Appeals for the First Circuit, which was denied, prompting an emergency application to the Supreme Court. The Supreme Court of the United States granted the stay, holding that the government is likely to succeed on its argument that the District Court lacked jurisdiction because the states lacked standing and their claims were not ripe for adjudication. The Court reasoned that the Order was an internal directive that did not cause concrete or imminent harm to the states, and any alleged injury was speculative and dependent on uncertain future events. The Court also found that the government would likely suffer irreparable harm from the injunction, which interfered with the internal workings of the Executive Branch. As a result, the Supreme Court stayed the District Court’s injunction pending further appellate review. View "Trump v. California" on Justia Law

State v. Garces

2026-08-24T13:11:35-08:00

The case concerns a defendant who was convicted of murdering his girlfriend after a violent altercation in their home. The defendant called 911, expressing both an apparent confession and suicidal intent. He was apprehended after returning home the next day. At the police station, he was advised of his rights using the Maui Police Department’s Miranda waiver form, which, at the time, did not include an explicit warning that he could stop answering questions or request an attorney at any time during interrogation. The defendant subsequently confessed during a custodial interview and did not attempt to invoke his right to silence or counsel. Proceedings in the Circuit Court of the Second Circuit were delayed to evaluate the defendant’s mental fitness. After finding him fit, the court denied his motion to suppress statements, concluding he had voluntarily, knowingly, and intelligently waived his Miranda rights, despite his claims of mental distress and the absence of the so-called “fifth Miranda warning.” At trial, the jury found him guilty of second-degree murder, and he was sentenced to life imprisonment with the possibility of parole. On appeal, the Intermediate Court of Appeals affirmed the conviction, holding that the Miranda warnings given were constitutionally sufficient and the waiver voluntary. The Supreme Court of the State of Hawai‘i reviewed the case. It held that, under the Hawai‘i Constitution, law enforcement must henceforth provide not only the traditional four Miranda warnings but also explicitly inform custodial suspects of their right to cease answering questions and request an attorney at any time. However, because this is a new constitutional rule, the court applied it prospectively only, not to the defendant’s case. The court affirmed both the conviction and sentence, holding that the defendant’s waiver was valid under the previous standard. View "State v. Garces" on Justia Law

Woodcock v. Univ. of Kentucky

2026-08-24T11:30:06-08:00

A tenured law professor at a state university posted an online petition calling for military action against Israel. The university responded by placing the professor on administrative leave and restricting his campus access while it investigated whether his actions violated university policy or law. The investigation included notices to the professor, requests for evidence, and allegations from students, but had not progressed beyond the preliminary fact-finding stage. No formal hearing or charges had been initiated by the university at the time of the lawsuit. The professor filed suit in the United States District Court for the Eastern District of Kentucky, seeking a preliminary injunction to stop the university’s actions. The university moved for abstention under the doctrine established in *Younger v. Harris*, arguing that the ongoing university investigation constituted a state proceeding warranting federal court abstention. The district court agreed with the university and abstained from hearing the case, prompting the professor to appeal. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s abstention decision de novo. The Sixth Circuit held that the university’s investigation was still in a preliminary, investigatory stage and did not constitute an ongoing formal proceeding as required under the *Younger* abstention framework. The court distinguished the circumstances from prior cases involving formal disciplinary hearings, noting that no formal charges or hearings had yet been initiated. As a result, the Sixth Circuit reversed the district court’s decision to abstain and remanded the case for consideration of the professor’s motion for a preliminary injunction. View "Woodcock v. Univ. of Kentucky" on Justia Law

USA V. AGUILERA

2026-08-24T08:30:31-08:00

A man was detained in San Francisco after police responded to reports of gunfire near a bar in the Mission District. Officers received gunshot detection alerts and eyewitness reports describing the shooter as a Hispanic male in a blue jacket. Police pursued a suspect matching this description, who fled when ordered to stop and was later found hiding behind a fence near the reported location. Upon his detention, officers discovered a gun, ammunition, and a magazine in his possession. The man was charged with being a felon in possession of ammunition. In the United States District Court for the Northern District of California, the defendant moved to suppress the evidence, arguing that officers lacked reasonable suspicion to detain him, and also moved to dismiss the indictment on constitutional grounds. The district court denied both motions. The defendant then proceeded to a stipulated bench trial, did not contest the evidence or cross-examine witnesses, and was found guilty. At sentencing, the court declined to grant a reduction for acceptance of responsibility, reasoning that the defendant’s efforts to preserve his right to appeal, including a motion to suppress and going to trial, precluded such a reduction. The defendant was sentenced to 45 months in prison. The United States Court of Appeals for the Ninth Circuit reviewed the case. It affirmed the conviction, holding that the district court correctly found reasonable suspicion existed for the seizure based on the officers’ collective knowledge and the totality of the circumstances, including eyewitness identification and the defendant’s proximity and conduct. However, the Ninth Circuit vacated the sentence and remanded for resentencing, holding that the district court applied the wrong legal standard by considering the defendant’s constitutionally protected conduct against him when denying a sentencing reduction for acceptance of responsibility. The error was not harmless because it could have affected the sentence imposed. View "USA V. AGUILERA" on Justia Law

1 Community Compact v. City of Fresno

2026-08-21T15:02:36-08:00

A city council adopted a resolution to rename three historically significant streets—East Kings Canyon Road, East Ventura Avenue, and West California Avenue—in honor of Cesar Chavez, a prominent labor leader and civil rights activist. The plaintiff, an association of residents and business owners on or near these streets, opposed the renaming, arguing that it disrupted their personal and community identities, imposed financial and administrative burdens, and forced them to be associated with a political figure they found objectionable. The association also alleged that the renaming process was procedurally unfair and failed to provide adequate notice or opportunity for input from those affected. After the city proceeded with the renaming, the plaintiff filed suit in the Superior Court of Fresno County, raising claims that the city’s action constituted an invalid exercise of police power, violated due process, infringed on free speech and association rights, amounted to waste of public funds, and denied equal protection. The Superior Court sustained the city’s demurrer to the due process, free speech, and equal protection claims, and granted summary judgment to the city on the police power and waste claims, finding the city’s actions valid and within its discretion. On appeal, the California Court of Appeal, Fifth Appellate District, considered the case even though the city had reverted the street names after new information about Cesar Chavez emerged. Applying the public interest exception to mootness, the court affirmed the Superior Court’s judgment. The appellate court held that the renaming constituted government speech, which is generally not subject to free speech protections, and did not compel residents or business owners to espouse a particular message. The court further held that the city’s action was a valid exercise of its police power, reasonably related to a legitimate governmental objective, and that the use of public funds for the renaming was discretionary and not subject to challenge as waste. The court’s decision affirmed the judgment in favor of the city. View "1 Community Compact v. City of Fresno" on Justia Law

State of Minnesota vs. Engel

2026-08-21T14:12:57-08:00

A police officer attempted to stop a driver on a rural Minnesota highway shortly after midnight because he believed the van lacked a visible rear license plate or temporary registration. The driver, instead of stopping, turned on his hazard lights and continued driving for several miles with the officer in pursuit, ignoring repeated commands to stop. The pursuit ended only after additional officers joined and the driver stopped at a protest encampment. After his arrest, officers determined the van did have valid temporary registration, but the driver was charged with felony fleeing a peace officer in a motor vehicle. At trial in the District Court, the driver moved to suppress evidence of his flight, arguing that the initial traffic stop was unconstitutional and that the subsequent evidence of fleeing was “fruit of the poisonous tree.” The District Court denied the motion, finding the officer had an objective reason for the stop. A jury convicted the driver. On appeal, the Minnesota Court of Appeals held the traffic stop was unconstitutional but affirmed the conviction, concluding that the evidence of flight was admissible under existing law. The Minnesota Supreme Court reviewed whether, under the Minnesota Constitution, evidence of a defendant’s new crime—here, vehicular flight—committed in response to an unconstitutional seizure must be suppressed. The court held that courts should apply the four-factor attenuation test from State v. Warndahl to determine if such evidence is the fruit of the poisonous tree. Applying this test, the court found that the driver’s flight was an intervening act of free will that attenuated the connection to the unconstitutional stop, and thus, the exclusionary rule did not require suppression. The Supreme Court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

US v. Bourget

2026-08-21T13:30:02-08:00

A correctional officer participated in a "forced cell move" at a federal medical facility, where a mentally ill and physically frail inmate, KT, was handcuffed behind his back. During the incident, the officer, equipped with a shield, entered the cell at high speed and struck KT in the chin and face, causing him to fall backward and suffer serious head and facial injuries. The event was captured on video. Prior to this, KT had spat on staff, including the officer, but was not threatening or aggressive at the time the force was used. The officer was indicted in the United States District Court for the District of Massachusetts on two counts of deprivation of rights under color of law. At the first jury trial, he was acquitted on one count, while the jury hung on the count concerning the shield strike, leading to a retrial. In the second trial, the district court excluded a training video the defense sought to introduce, finding it irrelevant and more prejudicial than probative, particularly since the circumstances in the video were materially different from those at issue. The jury convicted the officer on the remaining count. The district court denied post-trial motions and imposed a sentence of imprisonment and supervised release. On appeal to the United States Court of Appeals for the First Circuit, the officer challenged the sufficiency of the evidence, jury instructions, exclusion of the training video, and certain testimonial evidence, also alleging cumulative error. The First Circuit held that sufficient evidence supported the jury's finding that the officer acted maliciously and sadistically, violating the inmate's Eighth Amendment rights and meeting the willfulness standard under 18 U.S.C. § 242. The court found no error in the exclusion of the video, the jury instructions, or the evidentiary rulings, and determined that no cumulative error occurred. The conviction was affirmed. View "US v. Bourget" on Justia Law

Till v. King

2026-08-21T11:31:21-08:00

A 15-year-old, ELG, participated in a vocational program for teenagers that included a visit to a Michigan district court. During a lecture given by Judge Kenneth J. King about his career, ELG fell asleep, which offended Judge King. In response, Judge King orchestrated a plan to “scare her straight” by having ELG handcuffed, placed in a detention cell, required to wear a prison jumpsuit, and later subjected her to a mock trial in front of her peers, which was streamed online. There was no official court proceeding, case number, or record associated with these actions, and Judge King later admitted his actions were intended to teach ELG a lesson for perceived disrespect. Following these events, Latoreya Till, ELG’s mother, filed a lawsuit in the United States District Court for the Eastern District of Michigan. The complaint alleged violations of ELG’s Fourth Amendment rights and state law torts. Judge King moved to dismiss the case, arguing judicial immunity protected him from suit. The district court denied his motion, finding that the conduct alleged was not within the scope of judicial functions. Judge King appealed, and Till cross-appealed on an alternative theory. The United States Court of Appeals for the Sixth Circuit reviewed the lower court’s denial of the motion to dismiss de novo. It held that Judge King’s alleged actions were not judicial acts because they did not constitute functions normally performed by a judge nor did they occur in his judicial capacity. The court further found that Till’s alternative argument, based on a “complete absence of all jurisdiction,” was inapplicable. The Sixth Circuit affirmed the district court’s decision, holding that Judge King was not entitled to judicial immunity at this stage of the proceedings. View "Till v. King" on Justia Law

Gordon v. City of Hamtramck, Mich.

2026-08-21T11:31:21-08:00

In this case, two individuals served as members of the Human Relations Commission (HRC) in Hamtramck, Michigan, which oversaw city-owned flagpoles along a main avenue. For a decade, the HRC operated under an unwritten policy that allowed residents to request flags to be flown, including flags of different nations and various groups, such as the Pride flag. After a change in city administration in 2021, tension arose when the HRC flew the Pride flag in 2022. Responding to controversy, the newly elected City Council enacted a resolution in 2023 restricting the flagpoles to only certain flags—specifically, the American, Michigan, Hamtramck, and Prisoner of War flags, as well as those of nations representing the city’s international character. When the plaintiffs raised the Pride flag in defiance, the City Council removed them from the HRC and stripped the HRC’s authority over the flagpoles. The plaintiffs then brought suit in the United States District Court for the Eastern District of Michigan, alleging violations of the Free Speech, Establishment, and Equal Protection Clauses. The district court granted summary judgment in favor of the City and its officials, finding that after the 2023 resolution, the flagpoles served as a forum for government speech, not private speech, and that the resolution was facially neutral regarding religion and not motivated by religious purpose. The court also determined that the plaintiffs had not adequately developed an equal protection claim. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the City permissibly closed the flagpoles to private speech, making them a vehicle solely for government speech, and thus the plaintiffs’ Free Speech Clause claim failed. The court also held that the plaintiffs’ Establishment Clause claim was unavailing, as there was no evidence the resolution’s primary purpose was to advance religion. Finally, the court concluded the plaintiffs had forfeited their equal protection claim by not developing it. View "Gordon v. City of Hamtramck, Mich." on Justia Law

USA v. Birry

2026-08-21T09:00:13-08:00

Police officers in Blakely, Pennsylvania, stopped a car with a cracked windshield and expired registration. The car had two occupants: the driver, who lacked a valid insurance card and was unsure about his recent whereabouts, and Christopher Essameddin Birry, the passenger. When the officers discovered that the driver had an outstanding arrest warrant, they detained him and announced that the car would be towed. While processing the scene, the officers asked Birry for identification and questioned him about his relationship with the driver. After several requests for Birry to keep his hands visible, one officer asked for consent to search Birry, which Birry granted. During the pat-down, officers found drugs, a loaded firearm, and other contraband in Birry’s pantleg. Birry was indicted on several counts, including possession with intent to distribute controlled substances and firearm offenses. The United States District Court for the Middle District of Pennsylvania held an evidentiary hearing on Birry’s motion to suppress the evidence found during the stop. Birry argued that the officers unlawfully prolonged the stop and exceeded the scope of his consent during the search. The District Court denied the motion, finding both the duration of the stop and the scope of the search constitutionally permissible. Birry entered a conditional guilty plea, reserving his right to appeal the suppression ruling. The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and its legal conclusions de novo. The appellate court concluded that the officers’ questioning and actions were within the permissible bounds of a traffic stop and that the search did not exceed the scope of Birry’s consent. Accordingly, the Third Circuit affirmed the District Court’s denial of Birry’s motion to suppress, holding that both the stop and search were constitutional. View "USA v. Birry" on Justia Law

Democracy Partners, LLC v. O'Keefe

2026-08-21T08:32:48-08:00

Two investigative journalists, on assignment for a nonprofit media organization known for undercover reporting, infiltrated Democratic political consulting operations in 2016 using false identities. One reporter, posing as a philanthropist, met with a political consultant who then arranged for his colleague to hire the second reporter, also undercover, as an unpaid intern at the consultant's firm. The intern secretly recorded conversations and internal meetings over eight days, gaining access to nonpublic information. The media organization later published a video series alleging a conspiracy to incite violence at political events, using footage from both public interactions and the intern’s covert recordings. After the video’s release, major clients of the consulting firm terminated their contracts, citing concerns about scandal and the security breach. The consulting firm and its principals sued the journalists and their organizations in the United States District Court for the District of Columbia, alleging fraudulent misrepresentation, conspiracy, and violations of federal and D.C. wiretapping laws. The district court granted summary judgment for the defendants on some claims but allowed others to proceed to trial. A jury found for the plaintiffs on the remaining claims and awarded damages for lost contracts and statutory damages for wiretapping. The United States Court of Appeals for the District of Columbia Circuit reviewed the verdict. It held that the First Amendment barred damages based on losses caused by the publication’s protected speech, as the plaintiffs failed to prove that the unprotected conduct (the infiltration and covert recording) was the predominant cause of their damages. The court also held that the intern did not owe a fiduciary duty to the consulting firm under D.C. law, and therefore the wiretapping claims could not stand. The court reversed the district court’s denial of judgment as a matter of law and vacated the damages awards. View "Democracy Partners, LLC v. O'Keefe" on Justia Law

USA v. Richardson

2026-08-21T08:32:46-08:00

A man with two prior felony convictions for carrying a pistol without a license in the District of Columbia was sentenced in 2022 to a period of supervised probation in lieu of imprisonment for his second offense. While still under this court-ordered supervision, he knowingly possessed a firearm, which was reportedly stolen and modified for automatic firing, and was alleged to have brandished it during a shootout. He was indicted by a federal grand jury under 18 U.S.C. § 922(g)(1), the federal felon-in-possession statute. In the United States District Court for the District of Columbia, the defendant moved to dismiss the indictment, arguing that § 922(g)(1) violated the Second Amendment both facially and as applied to him, particularly in light of the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, which emphasized historical tradition over means-end scrutiny in Second Amendment cases. The district court rejected his arguments, holding that earlier circuit precedent (Medina v. Whitaker) upholding § 922(g)(1) remained good law, and denied the motion to dismiss. The defendant then pleaded guilty while preserving his right to appeal the constitutional issue. The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court held that, even assuming prior precedent did not control and that § 922(g)(1) implicated conduct covered by the Second Amendment, there exists a widespread historical tradition of temporarily disarming felons while they are serving their criminal sentences, including during periods of noncustodial supervision such as probation or supervised release. Therefore, § 922(g)(1) is constitutional as applied to individuals still serving their sentences, and is not facially unconstitutional. The court affirmed the judgment of the district court. View "USA v. Richardson" on Justia Law

State v. Willard

2026-08-21T06:38:14-08:00

Three firefighters and a police officer responded to a call about a woman found unconscious under a bridge. The firefighters woke her, and although she refused medical treatment, she did provide her name. When the police officer arrived, he ran a warrant check using the name she gave and discovered an outstanding warrant. The officer then arrested her, and during a search at the jail, methamphetamine was found in her possession. She was charged with possession of methamphetamine and possession of drug paraphernalia. The case proceeded in Reno District Court, where the defendant moved to suppress the evidence obtained from the search, arguing that she was unlawfully seized during what began as a public welfare check. The district court conducted a hearing, found that she had not been seized for purposes of the Fourth Amendment, denied the suppression motion, and later convicted her on stipulated facts. She received a suspended sentence and probation. On appeal, the Kansas Court of Appeals reversed the district court, holding that she had been unlawfully seized, and ordered suppression of the evidence, thus vacating her convictions and sentence. One judge dissented. Upon review, the Supreme Court of the State of Kansas held that the Fourth Amendment does not restrict its application only to law enforcement officers but to all government actors. The court considered the actions of both the firefighters and the police officer in assessing whether a reasonable person in the defendant's position would have felt free to end the encounter. The court concluded that the officials’ conduct did not amount to a seizure because their words and actions conveyed that she was free to leave. Therefore, the court reversed the judgment of the Court of Appeals and affirmed the district court’s decision to deny the motion to suppress. View "State v. Willard " on Justia Law

Brown v. Commissioner, Alabama Department of Corrections

2026-08-21T06:02:10-08:00

The case concerns a man who was convicted by an Alabama jury of murdering his girlfriend and her mother. The key facts established at trial showed that after the murders occurred in the victims’ home, the defendant left the state with the children, the victims’ car, and their checks, traveling to Cleveland, Ohio. Witness testimony placed him at the scene around the time of the murders, and his fingerprints were found on duct tape used to bind one of the victims. Additional evidence included his efforts to obtain cash using the victims’ checks, his lies about needing money for a child’s medical care, and his subsequent standoff with police in Cleveland. Family members of the defendant, including his aunt and uncle, were involved in alerting police to possible trouble at the victims’ home before the bodies were discovered. The Alabama Court of Criminal Appeals, reviewing the conviction and death sentence, agreed that the trial court erred in admitting testimony from a police investigator about a statement the defendant allegedly made to his aunt (“I hurt them girls”) without proper impeachment procedure. However, the appellate court held that this error was harmless beyond a reasonable doubt, given the overwhelming evidence of guilt. After unsuccessful state postconviction proceedings, the defendant sought federal habeas relief in the United States District Court for the Northern District of Alabama, arguing that admission of his alleged statement violated his federal due process rights. The district court denied relief, ruling that any error was not prejudicial in light of the full record. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed, holding that admission of the statement did not violate due process because it was not a crucial or highly significant factor in the conviction, and any error was harmless under both state and federal standards. View "Brown v. Commissioner, Alabama Department of Corrections" on Justia Law

Fitzmaurice v. City of Quincy

2026-08-21T04:07:24-08:00

The mayor of a city in Massachusetts decided to commission and install two ten-foot-tall bronze statues of Saint Michael and Saint Florian on the façade of a new public safety building, using public funds. Both figures are Catholic saints, recognized for their religious significance and as patron symbols of police and firefighters. The statues were to be the only adornments on the building, which serves various public functions and is located on a prominent city street. The city had already spent over $760,000 on the statues, with additional costs anticipated for their installation. News of the statues’ religious symbolism led to significant public opposition, including protests, petitions, and statements from local faith leaders expressing concern about the exclusionary message conveyed by featuring only Catholic figures on a municipal building. Fifteen city residents and taxpayers filed suit in Norfolk County Superior Court against the city and the mayor in his official capacity. They sought to enjoin further expenditure of public funds and prohibit installation of the statues, arguing that the actions violated Article 3 of the Massachusetts Declaration of Rights, as amended, which bars the establishment or subordination of any religious sect. The Superior Court judge granted a preliminary injunction stopping further installation and denied the city’s motion to dismiss, finding the plaintiffs had standing as taxpayers and had shown a likelihood of success under the standard set in *Colo v. Treasurer & Receiver General*. On direct appellate review, the Supreme Judicial Court of Massachusetts affirmed the Superior Court’s orders. The Court held that the plaintiffs had standing under the ten-taxpayer statute and that the constitutionality of the statues must be analyzed under the framework set out in *Colo*, which emphasizes constitutional text, history, purpose, and factors such as secular purpose, primary effect, and potential for divisiveness. The Court concluded that the statues likely violated Article 3 by conveying government endorsement of a particular religion, and that the public interest favored an injunction. The orders granting the preliminary injunction and denying the motion to dismiss were affirmed. View "Fitzmaurice v. City of Quincy" on Justia Law

Carroll Brothers, LLC v. Graham

2026-08-21T01:22:25-08:00

Three related business entities and an individual were audited by the Mississippi Department of Revenue (MDOR) for sales and income taxes covering various periods between 2019 and 2021. After a meeting to discuss the audit results, the taxpayers updated their mailing address with MDOR. MDOR subsequently determined that the entities and individual owed tax assessments and mailed these assessments to the updated address. The taxpayers later claimed they did not receive the assessments and missed the statutory deadline to appeal. The taxpayers attempted to appeal the assessments to the MDOR Board of Review, but their appeal was denied as untimely. They then appealed to the Board of Tax Appeals, which also affirmed the denial. The taxpayers next appealed to the Hinds County Chancery Court, arguing that MDOR had not sufficiently proven the assessments were actually mailed and that the statutory notice provisions violated due-process rights. Both parties moved for summary judgment. The chancery court granted summary judgment in favor of MDOR, finding the statutory notice provisions had previously been upheld as constitutional. The Supreme Court of Mississippi reviewed the case de novo, considering both the grant of summary judgment and the legal questions presented. The Court held that MDOR had provided sufficient evidence, through affidavits and mailing records, to establish that the assessments were mailed according to statutory requirements. The Court also held that the notice provisions in Mississippi Code Sections 27-65-37(2) and 27-77-5(1) are constitutional, as they are reasonably calculated to provide notice and an opportunity to contest the assessments, satisfying due-process requirements. The judgment of the Hinds County Chancery Court was affirmed. View "Carroll Brothers, LLC v. Graham" on Justia Law

USA v. Braun

2026-08-20T11:01:16-08:00

In September 2020, Microsoft and Google each reported to the National Center for Missing and Exploited Children (NCMEC) that images suspected to be child sexual abuse material (CSAM) were uploaded from the same IP address to their platforms. The images were not viewed by the companies or by NCMEC; instead, they were flagged by automated systems after matching hash values of known CSAM. NCMEC forwarded these reports to the Wisconsin Department of Justice, which traced the IP address to Peter Braun's residence. Special Agent Aaron Koehler viewed the images without a warrant, conducted surveillance, and obtained a prior report from 2015 indicating Braun had been observed chatting online with very young girls. Based on this information, Koehler applied for and obtained a state search warrant for Braun’s home, leading to charges of producing CSAM. The United States District Court for the Eastern District of Wisconsin, after referral to a magistrate judge, granted Braun’s motion to suppress the evidence from the search. The district court found that Agent Koehler’s warrantless viewing of the images was unlawful, and that, excluding his descriptions of the images, the warrant affidavit did not establish probable cause. The court also determined that the good-faith exception to the exclusionary rule did not apply. The government appealed this decision. The United States Court of Appeals for the Seventh Circuit reviewed the case, applying de novo review to legal conclusions and clear error review to factual findings. The Seventh Circuit held that, even without the descriptions of the images obtained from the unlawful search, Agent Koehler’s affidavit contained sufficient information—such as the reliability of the reporting sources, the incriminating file name, and corroborating evidence regarding Braun’s prior behavior—to establish probable cause for the search. The court concluded that the decision to seek the warrant was not prompted by the unlawfully obtained information. Accordingly, the Seventh Circuit reversed the district court’s order suppressing the evidence. View "USA v. Braun" on Justia Law

Hayat v. Diaz

2026-08-20T10:30:36-08:00

Police in Montgomery County, Maryland, responded to a high-priority call reporting that a Black male had placed three children into the trunk of a black Tesla, possibly indicating a kidnapping. Officers quickly traced the vehicle and address to Fareed Hayat. Upon arriving at his home, they found Hayat and his wife on the porch and initiated questioning. Hayat acted evasively, did not answer whether he had been at the location in question, cut off his wife’s conversation with officers, and attempted to retreat into his house, insisting the police could not enter. The officers prevented him from closing the door, entered the front hall, handcuffed Hayat, and checked on the children’s welfare. After confirming no kidnapping had occurred, the officers released Hayat. Hayat subsequently filed a lawsuit in the United States District Court for the District of Maryland against the officers, the Chief of Police, and Montgomery County. He alleged violations of his Fourth and Fourteenth Amendment rights, as well as various federal and state law claims. The district court dismissed most claims and granted summary judgment to the defendants on the remaining claims, finding that the officers had a reasonable suspicion justifying a Terry stop prior to Hayat’s retreat into his home. The court also held that the officers were justified in entering the home to complete the stop and to confirm the children’s welfare, given the exigency created by Hayat’s conduct. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officers had reasonable articulable suspicion to justify a Terry stop based on corroborated eyewitness accounts and Hayat’s suspicious behavior. The court further held that entry into the home was justified to complete the Terry stop and to ensure the safety of the children, under both the exigent circumstances and “hot pursuit” exceptions to the warrant requirement. The court concluded that Hayat’s Fourth Amendment rights were not violated. View "Hayat v. Diaz" on Justia Law

The Legislature of the State of Nevada v. Elko County

2026-08-20T07:42:37-08:00

The Nevada Legislature enacted Assembly Bill 519 in 2023 to promote school district capital projects. This law included specific provisions requiring counties with populations between 52,500 and 57,500 to levy a property tax to fund these projects, with a default tax imposed if such a levy was not enacted by a certain date. At the time of the latest census, only Elko County fell within this population range, making it the sole county affected by these mandatory provisions. Elko County challenged the constitutionality of these sections, arguing that they constituted a local or special law targeting a single county rather than applying statewide. The First Judicial District Court, Carson City, reviewed Elko County’s complaint and granted summary judgment in its favor. The court found that the challenged sections were unconstitutional local or special laws because they singled out Elko County. The court also concluded that these provisions violated the Nevada Constitution’s requirement for a uniform system of county government and severed the offending sections from the rest of the legislation, allowing the remainder of the law to stand. Only the Nevada Legislature appealed this ruling to the next level. The Supreme Court of the State of Nevada affirmed the district court’s decision. The Supreme Court concluded that the population-based provisions of Assembly Bill 519 were not rationally related to the law’s purpose and created an improper, narrowly tailored distinction that targeted Elko County. The Court held that these sections were local or special laws and violated Article 4, Section 20 of the Nevada Constitution by impermissibly regulating county business. As a result, the Supreme Court affirmed the order granting summary judgment and held that the challenged sections of the law were unconstitutional. View "The Legislature of the State of Nevada v. Elko County" on Justia Law

Minnesota Voters Alliance v. Ellison

2026-08-20T07:31:14-08:00

Several individuals and a nonprofit organization in Minnesota, focused on election integrity, wished to publicly advocate their interpretation that certain felons—specifically those still on supervised release—are constitutionally ineligible to vote in Minnesota. State law, however, allows felons to vote once released from incarceration, regardless of whether they are on parole or probation. Concerned about possible prosecution under a Minnesota statute that criminalizes knowingly false statements about voter eligibility made within 60 days of an election, the plaintiffs sought to continue their advocacy without facing criminal or civil penalties. After the Minnesota Supreme Court held that the group lacked standing to challenge the felon voting law in state court, the plaintiffs filed suit in the United States District Court for the District of Minnesota. They sought declaratory and injunctive relief against the enforcement of the election disinformation statute, arguing it violated the First Amendment. In response, the Anoka County Attorney filed a counterclaim, seeking to restrain the plaintiffs from violating the law and to obtain damages. The district court dismissed the plaintiffs’ complaint and denied a preliminary injunction, concluding that the law could constitutionally restrict their speech. The plaintiffs appealed the denial of a preliminary injunction while the counterclaim remained pending. The United States Court of Appeals for the Eighth Circuit reviewed the denial of preliminary injunctive relief and found that the plaintiffs had standing due to both actual and imminent injuries. The court held that the statute at issue regulated protected political speech based on its content and was therefore subject to strict scrutiny. The court determined that Minnesota’s law was not narrowly tailored to serve a compelling state interest, as it both overreached and underreached in its restriction of speech, and also authorized unconstitutional prior restraints. The Eighth Circuit reversed the denial of a preliminary injunction in part, affirmed in part, and remanded for entry of a preliminary injunction in favor of the plaintiffs. View "Minnesota Voters Alliance v. Ellison" on Justia Law

United States v. Ellingburg

2026-08-20T07:31:12-08:00

In December 1995, Holsey Ellingburg, Jr. robbed a bank. He was convicted by a jury in August 1996 and sentenced in November 1996 by the United States District Court for the Western District of Missouri, which ordered him to pay $7,567.25 in restitution. At the time of his offense, the Victim and Witness Protection Act of 1982 (VWPA) governed restitution, limiting liability to twenty years after judgment. However, the Mandatory Victim Restitution Act (MVRA), enacted after his offense but before his conviction, extended the government’s ability to collect restitution to the later of twenty years after judgment or twenty years after release from imprisonment, and made interest awards mandatory unless the defendant was unable to pay. After his release in 2022, Ellingburg challenged the continued enforcement of his restitution order, arguing that retroactive application of the MVRA violated the Ex Post Facto Clause. The district court held that the MVRA’s extended liability period did not increase Ellingburg’s punishment and rejected his petition. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed, reasoning that MVRA restitution was not criminal punishment and therefore did not implicate the Ex Post Facto Clause. Ellingburg sought review in the Supreme Court, which reversed, holding that MVRA restitution is criminal punishment under the Ex Post Facto Clause, and remanded for further proceedings on whether the MVRA’s extended liability period increased his punishment. On remand, the United States Court of Appeals for the Eighth Circuit determined that the MVRA applied to Ellingburg because he was convicted after its enactment. The court held that retroactive application of the MVRA’s extended liability period increased Ellingburg’s punishment by prolonging his restitution liability well beyond what the law permitted at the time of his offense. The court therefore concluded that applying the MVRA to Ellingburg violated the Ex Post Facto Clause, vacated the district court’s judgment, and remanded for further proceedings. View "United States v. Ellingburg" on Justia Law

COMMONWEALTH OF KENTUCKY V. SHEPHERD

2026-08-20T06:10:05-08:00

A group of inmates under death sentences brought a lawsuit in Franklin Circuit Court in 2006 seeking declaratory and injunctive relief regarding Kentucky’s execution procedures. They challenged the Kentucky Department of Corrections’ execution protocols, arguing that the protocols had not been properly promulgated as administrative regulations under Kentucky’s Administrative Procedures Act. After the Kentucky Supreme Court ruled in 2009 that formal rulemaking was required, the Department issued new regulations, leading to ongoing litigation as the inmates continued to challenge subsequent amendments to the execution regulations on constitutional and statutory grounds, including issues regarding intellectual disability, insanity determinations, attorney access, and execution procedures. After further amendments to the execution regulations in 2023 and 2024, the inmates updated their claims, and the Commonwealth moved to dismiss, arguing the inmates had not exhausted administrative remedies as required by KRS 454.415. The Franklin Circuit Court denied the motion, finding that the grievances concerned the validity and constitutionality of regulations—matters not suited for administrative resolution—and that exhaustion was not required. The Commonwealth then petitioned the Supreme Court of Kentucky for a writ of prohibition, asserting that the circuit court lacked jurisdiction to proceed without exhaustion. The Supreme Court of Kentucky held that the Franklin Circuit Court had subject matter jurisdiction over declaratory and constitutional challenges to administrative regulations, regardless of whether exhaustion of administrative remedies was required or fulfilled for particular claims. The Court concluded that exhaustion is a non-jurisdictional procedural requirement, and any errors relating to exhaustion can be addressed on appeal after final judgment. Consequently, the Supreme Court of Kentucky denied the petition for a writ of prohibition. View "COMMONWEALTH OF KENTUCKY V. SHEPHERD" on Justia Law

EX PARTE GONZALEZ

2026-08-20T05:35:01-08:00

The applicant was convicted of capital murder for intentionally killing a peace officer in Bexar County, Texas. The prosecution’s case included evidence that the applicant, after drinking with a friend, approached a deputy at a red light and fired at least forty-six shots, killing the officer. The applicant’s identity as the shooter was not disputed at trial. The defense conceded the shooting but argued the applicant was in an automatistic state due to a combination of alcohol, drugs, head injury, brain dysfunction, and hypoglycemia. The state countered with expert testimony disputing this defense. At sentencing, the state highlighted the brutality of the crime and the applicant’s lack of remorse, while the defense presented limited mitigation evidence, primarily focusing on positive aspects of the applicant’s character and hardships he faced. The case was initially tried in the 175th District Court of Bexar County, which sentenced the applicant to death after the jury answered special punishment issues in a manner requiring such a sentence. The Texas Court of Criminal Appeals affirmed the conviction and sentence on direct appeal. The applicant then filed an initial habeas corpus application, raising claims of jury misconduct, ineffective assistance of counsel in various trial phases (including jury selection, guilt, punishment, and competency), and a Brady claim alleging withheld impeachment evidence. The Texas Court of Criminal Appeals reviewed the writ application. It held that the jury misconduct claim was procedurally barred. The court found claims of ineffective assistance regarding the guilt phase investigation, jury selection, competency trial, and the Brady claim were without merit. On the claim that counsel failed to investigate and present adequate mitigating evidence at sentencing, the court assumed without deciding that counsel may have performed deficiently but concluded there was no reasonable probability the outcome would have been different, given the facts of the offense and the jury’s deliberations. Relief was denied on all claims. View "EX PARTE GONZALEZ" on Justia Law

State v. Brinkman

2026-08-20T05:01:15-08:00

In June 2017, a man killed his friend and her two adult daughters in their home. After purchasing weapons and related items, he arranged to visit the home when the daughters were away, but they returned during his visit. He assaulted the mother, then restrained all three women using threats and physical restraints. He proceeded to stab the mother, smother one daughter, and strangle the other, causing all of their deaths. The next day, their bodies were discovered after concerned friends and family entered the home. The suspect was located several days later after a police standoff, subsequently confessed, and was arrested. The case was first heard in the Cuyahoga County Court of Common Pleas, where a three-judge panel accepted the defendant’s guilty plea to multiple counts of aggravated murder, aggravated burglary, kidnapping, and gross abuse of a corpse. After a mitigation hearing, the panel sentenced him to death for each victim. On appeal, the Supreme Court of Ohio vacated the convictions and sentences, finding that the defendant had not been properly advised of certain constitutional rights during his plea. The case was remanded for new proceedings. Upon remand, the defendant again pleaded guilty before a new three-judge panel, which found him guilty and again imposed three death sentences after a mitigation hearing. The Supreme Court of Ohio reviewed the case as a matter of right. The defendant raised numerous legal issues, including claims regarding the weighing of aggravating and mitigating factors, the sufficiency of the indictment, the plea and jury waiver processes, the admission of evidence, and the constitutionality of Ohio’s death penalty scheme. The court overruled all claims. It held that the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt for each murder and that the death sentences were appropriate and proportionate to similar cases. The convictions and death sentences were affirmed. View "State v. Brinkman" on Justia Law

Emerald Necklace Conservancy, Inc. v. City of Boston

2026-08-20T04:14:03-08:00

A nonprofit organization and several individuals, most residing near Franklin Park in Boston, challenged the city’s decision to enter into agreements allowing a private company to demolish and reconstruct White Stadium and to lease a portion of the new stadium for use as a professional women’s soccer venue. The plaintiffs argued that the land in question, originally acquired as parkland, remained subject to Article 97 of the Amendments to the Massachusetts Constitution, which requires a two-thirds legislative vote to dispose of or change the use of protected parkland. They also claimed that the agreements breached the terms of a public charitable trust, the George Robert White Fund, from which the stadium parcel was transferred, and that the city failed to meet other statutory requirements. The Superior Court dismissed the plaintiffs’ trust-based claims for lack of standing, finding that only the Attorney General or trustees can enforce a public charitable trust unless an individual plaintiff can show a distinct personal interest. After a bench trial, the court ruled in favor of the defendants on the remaining claims, concluding that the stadium parcel was no longer protected parkland at the time of the agreements and that the plaintiffs had not demonstrated violations regarding areas outside the stadium parcel. On appeal, the Supreme Judicial Court of Massachusetts affirmed. The court held that the plaintiffs lacked standing to enforce the White Fund’s trust terms. It further determined that, due to legislative actions in 1947 and 1950, the stadium parcel was removed from its park designation and dedicated as a school facility, so Article 97’s protections did not apply. The court also found that the agreements did not grant an easement over other areas of Franklin Park and that planned improvements outside the stadium parcel did not alter their park use. The judgment for the defendants was affirmed. View "Emerald Necklace Conservancy, Inc. v. City of Boston" on Justia Law

State of Minnesota vs. Engel

2026-08-20T01:29:05-08:00

A police officer in Thief River Falls, Minnesota, attempted to stop Nicholas Engel’s van late at night because he did not see a rear license plate or visible temporary registration. Rather than pull over, Engel turned on his hazard lights and continued driving for several miles, despite the officer’s emergency lights, siren, and repeated verbal commands to stop. Engel eventually stopped only after additional officers arrived and boxed in his vehicle near a protest camp. He was arrested and charged with felony fleeing a peace officer in a motor vehicle. The Thief River Falls District Court denied Engel’s motion to suppress evidence of his vehicular flight, concluding the officer had an objective reason to initiate the stop. After a jury convicted Engel, the Minnesota Court of Appeals affirmed, though all panel members agreed the traffic stop was unconstitutional because the officer lacked reasonable, articulable suspicion for the stop. The majority held that suppression of evidence of Engel’s flight was not warranted, while the dissent argued that the flight was fruit of the unconstitutional seizure and should be suppressed. The Supreme Court of Minnesota reviewed the case to determine whether evidence of Engel’s vehicular flight, which constituted a new crime in response to an unconstitutional stop, must be suppressed under the exclusionary rule of the Minnesota Constitution. The court held that when a suspect commits a new crime after law enforcement commits a constitutional violation, courts must apply the four-factor attenuation test from State v. Warndahl to determine whether the evidence of the new crime is fruit of the poisonous tree. Applying this test, the court found Engel’s flight to be an intervening act not sufficiently connected to the unconstitutional stop to warrant suppression. The court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

Toy v. City & County of S.F.

2026-08-19T13:02:43-08:00

Three individuals filed a class action lawsuit against San Francisco, challenging new water rates adopted by the city’s Public Utility Commission in May 2023. The plaintiffs alleged that the new rates violated Proposition 218 of the California Constitution by including costs unrelated to the actual provision of water service, resulting in charges that exceeded the cost of service. Before adopting the new rates, the city provided required notice to ratepayers, including information about a 120-day period for legal challenges under the applicable validation statutes. The plaintiffs sought a refund, declaratory and equitable relief, and a writ of mandate. After the class action was filed, the City litigated the case for over a year. It participated in discovery, case management, and even moved for summary judgment, without initially arguing that the suit was procedurally improper. Eventually, the City moved for judgment on the pleadings, arguing that plaintiffs’ action was subject to the validation statutes, specifically Government Code section 53759 and Code of Civil Procedure sections 860 et seq., which require reverse validation actions attacking agency matters like water rates to be brought within 120 days and with specific notice by publication to all interested parties. The trial court (San Francisco County Superior Court) agreed with the City, finding the statutes mandatory and jurisdictional, and dismissed the case for failure to comply with the procedural requirements, including timely filing and appropriate notice. On appeal, the California Court of Appeal, First Appellate District, Division Two, reviewed the judgment de novo. The court held that compliance with the validation statutes was mandatory and jurisdictional. Plaintiffs’ failure to file a proper reverse validation action and to provide notice by publication deprived the court of jurisdiction. The court rejected arguments that the City had waived these requirements or that good cause existed for noncompliance. The judgment in favor of the City was affirmed. View "Toy v. City & County of S.F." on Justia Law

Smith v. Price

2026-08-19T12:00:55-08:00

An inmate incarcerated at an Indiana prison was twice transported by correctional officers between the facility and a hospital in June 2019. During the first transport, after a medical appointment, the inmate was placed in a van in restraining gear that prevented him from buckling his seatbelt, and the officers refused to buckle it for him. One of the officers then drove the van in a manner the inmate described as reckless, resulting in a sudden stop that threw the inmate to the floor and caused a broken collarbone. The inmate alleged the officers made threatening remarks referencing his prior grievances against staff and later colluded to create consistent incident reports. On the second transport, after surgery, the inmate was buckled in but not placed in the more secure area he requested. Officers drove in a way that jostled his recent injuries, deliberately drove over rough terrain and railroad tracks, and laughed in response to his pain. The United States District Court for the Southern District of Indiana allowed the inmate’s Eighth Amendment claims against three officers to proceed, along with First Amendment retaliation claims. At summary judgment, the district court granted qualified immunity to all three officers on the Eighth Amendment claims, finding that the law was not clearly established for the conduct alleged, and entered judgment for the officers. The court analyzed the claims under both deliberate indifference and excessive force standards, depending on the officer’s role and the facts alleged. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed in part and vacated in part. The court held that the officer who failed to buckle the inmate’s seatbelt and did not intervene during reckless driving on the first transport was not entitled to qualified immunity, as it was clearly established that subjecting a restrained inmate to reckless driving without a seatbelt posed a substantial risk of serious harm. However, the court affirmed summary judgment for the officers involved in the second transport, finding the law was not clearly established that their conduct—though troubling—violated the Eighth Amendment under the specific facts presented. The case against the first officer was remanded for further proceedings. View "Smith v. Price" on Justia Law

Public Interest Legal Foundation, Inc. v. Wolfe

2026-08-19T11:00:56-08:00

A nonprofit organization dedicated to election integrity requested a copy of Wisconsin’s voter registration list, seeking access under the National Voter Registration Act (NVRA). Wisconsin, however, is exempt from the NVRA because it has permitted same-day polling-place registration since before August 1, 1994. The state processed the request under its public-records law, which required redaction of birth dates and imposed a fee of $12,500 due to the size of the list. The organization objected to both the fee and the redactions, arguing that Wisconsin’s exemption from the NVRA was unconstitutional. The United States District Court for the Western District of Wisconsin dismissed the case. The district judge held that the plaintiff’s claims—asserting violations of the “equal state sovereignty” principle from Shelby County v. Holder and the “congruence and proportionality” requirement from City of Boerne v. Flores—were not supported by law. While the judge found that the plaintiff had Article III standing due to the alleged financial injury, he expressed doubt about prudential standing but decided the case on the merits, concluding that neither cited Supreme Court decision undermined the validity of Wisconsin’s exemption. The United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The court agreed that the plaintiff had Article III standing but questioned prudential standing, as the legal theories invoked state, rather than individual, rights. Nonetheless, the court bypassed this issue, holding that the NVRA’s exemption for states like Wisconsin does not violate equal state sovereignty or the congruence and proportionality standard. The court emphasized that the exemption relieves, rather than imposes, federal regulatory burdens and that Congress acted under its Elections Clause authority, making City of Boerne inapplicable. The Seventh Circuit affirmed the district court’s dismissal. View "Public Interest Legal Foundation, Inc. v. Wolfe" on Justia Law

Peden v. Stephens

2026-08-19T08:32:43-08:00

A deputy sheriff in Gwinnett County, Georgia, was terminated from his position following allegations that he engaged in extramarital affairs during work hours and while using county resources. An anonymous letter triggered an internal investigation, which included a polygraph examination. After being confronted with the charges, the deputy was issued a pre-termination notice and ultimately fired. He appealed his termination but later entered into a settlement in which the Sheriff's Office agreed to treat his departure as a resignation. Subsequently, a local news outlet obtained and reported on his personnel file, and the deputy learned the identity of the person behind the anonymous letter. The former deputy and his wife filed a lawsuit in the United States District Court for the Northern District of Georgia, asserting claims for procedural due process and equal protection violations under the Fourteenth Amendment, as well as state law defamation. The district court granted summary judgment to the Gwinnett County officials on all claims, finding insufficient evidence to proceed. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s grant of summary judgment on the procedural due process and defamation claims. The court held that the plaintiff could not maintain a procedural due process claim because he failed to exhaust available state remedies before pursuing federal relief. The defamation claim failed due to a lack of evidence connecting the defendants to the alleged leak. However, the court vacated the summary judgment on the equal protection claim and remanded with instructions to dismiss that claim for lack of standing, because private citizens generally have no judicially cognizable interest in whether another individual is prosecuted. The officials’ cross-appeal was dismissed as moot. View "Peden v. Stephens" on Justia Law

Moore v. Commissioner of Correction

2026-08-19T04:02:55-08:00

The petitioner was convicted of murder after a jury trial in which a key witness, who had been involved in the crime and was separately charged, testified for the state. Before trial, the petitioner’s counsel inquired whether any deal or understanding of leniency existed between the state and the witness, but the prosecutor denied there were any assurances. During cross-examination, the witness denied having been promised any benefit in exchange for his testimony but indicated he was hoping his cooperation would help him at sentencing. Shortly after the petitioner’s conviction, the witness received a notably lenient sentence in his own criminal case, pursuant to a plea agreement. The petitioner subsequently filed for habeas corpus, alleging that the state had failed to disclose an informal cooperation agreement with the witness and had allowed the witness to deny such an agreement under oath, thus violating his due process rights under Napue v. Illinois. At the habeas trial in the Connecticut Superior Court, the witness, his defense counsel, and three prosecutors all testified that there was no cooperation agreement. The habeas court found no such agreement existed and denied the petition. The Connecticut Appellate Court affirmed this judgment. On appeal, the Supreme Court of Connecticut clarified that prosecutors have a duty to correct false or substantially misleading testimony about both formal and informal cooperation agreements, including those that are implied, unwritten, or tacit. The court held that, while lenient treatment alone does not prove an agreement, courts must consider whether prosecutors’ conduct created an expectation of leniency and whether the witness acted on that expectation. Because the record was insufficient to determine whether all parties understood what constitutes an informal agreement in this context, the Supreme Court remanded the case to the habeas court for further factual findings, while retaining jurisdiction for a final decision on the appeal. View "Moore v. Commissioner of Correction" on Justia Law

USA v. Enclade

2026-08-18T15:30:32-08:00

Law enforcement conducted a two-month investigation in New Orleans into two relatives, Terence Wilson and Travis Enclade, suspected of trafficking methamphetamine, fentanyl, and heroin. Surveillance techniques included pole cameras, physical observation, GPS tracking, and phone analysis at several residences linked to the defendants. Footage and investigative findings suggested hand-to-hand drug transactions, shared access to a stash house, and the presence of firearms. During a jailhouse call following Wilson’s arrest, coded language was used to direct Enclade to narcotics later found in a kitchen cabinet. Subsequent searches of three residences uncovered large quantities of drugs, distribution materials, and multiple firearms. The United States District Court for the Eastern District of Louisiana presided over the trial, where both defendants were convicted by a jury of conspiracy to distribute controlled substances. Wilson was also convicted of possession with intent to distribute and being a felon in possession of firearms, while Enclade was convicted of being a felon in possession of firearms. Both were acquitted on one count related to possessing firearms in furtherance of drug trafficking. The district court sentenced Enclade to 288 months and Wilson to 240 months, both below the Guidelines range. Defendants challenged the sufficiency of the evidence, evidentiary rulings, jury instructions, the conduct of the prosecutor, denial of a continuance, their sentences, and the constitutionality of 18 U.S.C. § 922(g)(1). The United States Court of Appeals for the Fifth Circuit reviewed the convictions and sentences. The court held that the evidence was sufficient for all convictions, that any evidentiary errors or improper prosecutorial remarks did not prejudice the defendants, and that the district court did not abuse its discretion in its rulings. The court further held that § 922(g)(1) was constitutional and that Enclade’s sentence was reasonable. The Fifth Circuit affirmed the district court’s judgment. View "USA v. Enclade" on Justia Law

Grant v. Belangia

2026-08-18T10:30:31-08:00

A group of registered voters in South Carolina, all under the age of sixty-five, challenged a provision of state law that restricts “no excuse” absentee-by-mail voting to voters sixty-five years of age or older. These plaintiffs argued that the statute unconstitutionally discriminates against them on account of age, in violation of the Twenty-Sixth Amendment, and also violates the Equal Protection Clause of the Fourteenth Amendment. The law at issue allows voters sixty-five and older to vote absentee by mail for any reason, while voters under sixty-five can only do so if they meet specific, narrow criteria such as disability, military service, or certain employment conflicts. The case was initially heard in the United States District Court for the District of South Carolina, where the court granted summary judgment in favor of the defendants—the South Carolina State Election Commission and related officials—on both constitutional claims. The district court found that the plaintiffs did not demonstrate a violation of either the Twenty-Sixth Amendment or the Equal Protection Clause. The plaintiffs appealed this decision. The United States Court of Appeals for the Fourth Circuit reviewed the appeal. This court held that the plaintiffs have standing and that South Carolina’s age-based absentee-by-mail voting scheme violates the Twenty-Sixth Amendment because it abridges the right to vote on account of age by providing greater ballot access to older voters. However, the court affirmed the district court’s decision to dismiss the Equal Protection claim, as age is not a suspect classification under the Equal Protection Clause and the plaintiffs did not challenge the law under rational basis or Anderson-Burdick scrutiny. The Fourth Circuit reversed the district court’s judgment on the Twenty-Sixth Amendment claim, affirmed the Equal Protection ruling, and remanded the case for appropriate remedy. View "Grant v. Belangia" on Justia Law

Bonds v. Woodall

2026-08-18T09:30:39-08:00

A kindergarten teacher in Mississippi was frustrated after being unable to use a remote entry service to unlock her car and, during a customer service call, told an agent that she was aggravated and might “kill some little kindergarteners.” She reiterated this after her issue was resolved, saying the agent had “saved 20 children from being killed.” The agent reported the statements to the police. The responding officers met with the teacher, who admitted to the remarks but said they were taken out of context. After consulting with an Assistant District Attorney, the teacher was charged with making terroristic threats, processed, and jailed. A grand jury declined to indict her. The teacher filed suit in the United States District Court for the Southern District of Mississippi against the city, the chief of police, and an officer, alleging false arrest, false imprisonment, malicious prosecution under state and federal law, and a Fourteenth Amendment violation. The defendants moved for summary judgment, asserting qualified immunity. The district court denied their motion, and the defendants appealed. The United States Court of Appeals for the Fifth Circuit held that the officers were entitled to qualified immunity, finding that the facts known to the officers at the time provided probable cause for arrest, defeating the constitutional claims. The court also found that, even if the officers erred, the right to be free from arrest under these circumstances was not clearly established. The appellate court reversed the district court’s denial of qualified immunity and declined to exercise pendent jurisdiction over the state law and municipal liability claims, remanding those for further proceedings. View "Bonds v. Woodall" on Justia Law

Planned Parenthood Great Northwest, Hawai'i v Commissioner of the Indiana State Department

2026-08-18T09:01:24-08:00

In 2017, Indiana enacted a statute known as the “aid-or-assist” law, which prohibits any person from knowingly or intentionally assisting an unemancipated pregnant minor in obtaining an abortion without fulfilling the state’s parental consent and notice requirements. Planned Parenthood, a nonprofit operating health centers in Indiana, regularly provides minors with factually accurate information and referrals about lawful abortion services in neighboring states, particularly after Indiana enacted more restrictive abortion laws following Dobbs v. Jackson Women’s Health Organization. Both parties agreed that, without adherence to Indiana’s parental consent law, providing such information would violate the aid-or-assist statute, exposing Planned Parenthood and its physicians to civil liability and professional discipline. After the law’s passage, Planned Parenthood filed suit in the United States District Court for the Southern District of Indiana, challenging the statute under the First Amendment as applied to its provision of information and referrals to minors about lawful out-of-state abortion services. The district court initially granted a preliminary injunction, and after changes in federal and state abortion law, ultimately issued a permanent injunction preventing enforcement of the aid-or-assist law as applied to Planned Parenthood’s speech and referrals about legal abortion practices in other states. The district court reasoned that the statute was a content-based restriction on protected speech and failed strict scrutiny. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the permanent injunction, with one modification: it removed the Commissioner of Health as a defendant because the Commissioner no longer had authority to provide relief. The Seventh Circuit held that Planned Parenthood’s provision of information and referrals about legal out-of-state abortion services was protected speech under the First Amendment. The court found that Indiana’s law, as applied, was a content- and viewpoint-based restriction that failed strict scrutiny, as it was not narrowly tailored to serve compelling state interests. The injunction was affirmed as modified. View "Planned Parenthood Great Northwest, Hawai'i v Commissioner of the Indiana State Department" on Justia Law

Teva Pharmaceuticals USA, Inc. v. Kennedy

2026-08-18T08:03:32-08:00

A pharmaceutical company that manufactures both branded and generic drugs challenged the federal agency rules implementing the Medicare Drug Price Negotiation Program created under the Inflation Reduction Act of 2022. Specifically, the company objected to two rules: first, the agency’s grouping of two drugs with the same active ingredient and manufacturer, but approved under separate applications, as one “qualifying single source drug” for price negotiation; and second, the agency’s requirement that a generic drug must be engaged in “bona fide marketing” to be considered as marketed, which affects when a branded drug exits the negotiation program. The company argued that these rules exceeded the agency’s statutory authority and that the program deprived it of protected property interests without due process. The United States District Court for the District of Columbia reviewed the case. It found that the statutory bar on judicial review did not prevent the company’s challenges to generally applicable agency guidance. On the merits, the district court upheld the agency’s definition of a qualifying single source drug, ruled that the challenge to the “bona fide marketing” standard was not yet ripe, and rejected the due process claim due to lack of a protected property interest. The company appealed. The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The appellate court held that the statutory review bar precludes review only of drug-specific determinations, not generally applicable legal standards. On the merits, it concluded that the statute permits the agency to treat drugs with the same active ingredient and manufacturer as one statutory drug. The court found that the due process challenge failed because the company lacked a protected property interest. However, it determined that the challenge to the “bona fide marketing” requirement was ripe and remanded that issue to the district court for further proceedings. The court thus affirmed in part, reversed in part, and remanded. View "Teva Pharmaceuticals USA, Inc. v. Kennedy" on Justia Law

Hesai Technology Co., Ltd v. DOD

2026-08-18T08:03:29-08:00

A technology company, along with its U.S. subsidiary, was designated by the Secretary of Defense as a “Chinese military company” under Section 1260H of the National Defense Authorization Act. This listing, published annually in the Federal Register, leads to significant legal consequences, including prohibitions on entering into certain federal contracts and receiving federal funds or support. The designation also carries reputational harm, as it publicly identifies the company as having ties to the Chinese military. The company develops and sells LiDAR products primarily used in advanced driver-assistance and autonomous vehicle systems. After being listed in January 2024, the company sued the Department of Defense in the United States District Court for the District of Columbia, challenging both the original and an October 2024 redesignation under the Administrative Procedure Act and the Fifth Amendment’s Due Process Clause. The company argued that it was not provided notice of the unclassified evidence relied upon or a meaningful chance to respond before the designation was finalized. The district court granted summary judgment to the government, upholding the designation and concluding that any due process violation was harmless because the company did not show prejudice. On appeal, the United States Court of Appeals for the District of Columbia Circuit held that the company had a protected liberty interest under the “stigma-plus” doctrine, as the designation combined reputational harm with formal exclusion from government contracting opportunities. The Court ruled that the Constitution required the Secretary to provide notice of the unclassified evidence and a meaningful pre-deprivation opportunity to respond. The Secretary’s failure to do so was not harmless error. The appellate court reversed the district court’s judgment and remanded with instructions to remand to the Secretary for further proceedings, but did not vacate the designation pending remedial process. View "Hesai Technology Co., Ltd v. DOD" on Justia Law

Brown v. People

2026-08-18T06:35:37-08:00

In June 2017, the defendant drove his truck into an alley and ran over two individuals sleeping under a blanket, resulting in one fatality and one serious injury. After being told by a witness that he had run over people, he denied it and drove away from the scene. Law enforcement, acting on witness information, located the defendant at his home, where he exhibited signs of alcohol use. Subsequently, the defendant was charged with leaving the scene of an accident resulting in death and with leaving the scene of an accident resulting in serious bodily injury. The prosecution later added habitual criminal counts based on prior felony convictions. At trial in the district court, the jury was instructed on the elements of the leaving-the-scene offenses without any requirement that the defendant acted with a culpable mental state, such as “knowingly.” The jury convicted the defendant on both charges. The judge, not a jury, adjudicated the defendant as a habitual offender and imposed a sixty-year sentence. The defendant appealed, arguing the trial court erred by not requiring proof of a mental state for the leaving-the-scene offenses and challenging the constitutionality of the habitual offender statute for permitting a judge, rather than a jury, to make factual findings that increased his sentence. The Colorado Court of Appeals affirmed both the convictions and the habitual offender adjudication, finding itself bound by existing precedent and concluding any error was harmless beyond a reasonable doubt. On review, the Supreme Court of Colorado held that its prior decision in People v. Manzo remains controlling, so the trial court did not err in omitting a culpable mental state from the jury instructions for the leaving-the-scene convictions. The court further held that the habitual offender statute was not unconstitutional and that any error in the judge’s factual findings, rather than a jury’s, was harmless beyond a reasonable doubt. The court affirmed the lower court’s judgment. View "Brown v. People" on Justia Law

Belya v. Kapral

2026-08-18T06:00:04-08:00

A priest formerly affiliated with the Russian Orthodox Church Outside of Russia (ROCOR) brought suit against various church leaders and entities, alleging defamation. He claimed that leaders within ROCOR falsely accused him of forging letters from church officials that purportedly announced his election as a bishop. The priest maintained that he had been chosen for elevation, and that the accusations of forgery, which circulated within the church and were subsequently posted online, damaged his reputation and led to his suspension and eventual removal from clerical office. The United States District Court for the Southern District of New York, upon reassignment to a new judge, granted summary judgment to the defendants. The court found that the plaintiff failed to present sufficient evidence under New York defamation law linking the defendants to the public dissemination of the allegedly defamatory statements. Additionally, the court held in the alternative that the lawsuit was barred by the First Amendment’s church autonomy doctrine, as adjudicating the claims would require the court to intrude upon religious questions regarding ROCOR’s selection, supervision, and discipline of clergy, as well as its internal governance protocols. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s decision, focusing on the constitutional ground. The Second Circuit held that the First Amendment’s church autonomy doctrine prevents civil courts from adjudicating claims that would interfere with a religious organization’s management of its ministers or require secular courts to resolve disputes over church protocols and internal governance. The court concluded that the plaintiff’s claims, whether based on internal or public statements, were barred because their resolution would necessitate unconstitutional entanglement in matters of church governance and doctrine. View "Belya v. Kapral" on Justia Law

TWUM-BAAH v. THE STATE

2026-08-18T04:06:02-08:00

The appellant was arrested in Mississippi, extradited to Georgia, and released on bond. He was charged with theft by conversion stemming from a dispute involving the sale of a tractor-trailer. While on bond, he filed a pretrial habeas corpus petition, arguing that he continued to be unconstitutionally restrained due to ongoing bond conditions and pending prosecution. He requested the court to order the State to justify the restraint and sought a prompt hearing on probable cause. He also objected to the assignment of his habeas case to the same judge presiding over his criminal case, repeatedly seeking that judge’s recusal. The Superior Court of Gwinnett County assigned his habeas petition to Judge Tracey Mason, who denied multiple motions for her own recusal, explaining that adverse rulings are not grounds for disqualification. When the habeas petition came for hearing, a different judge, Judge Kylene Armond, presided by designation. The appellant refused to participate in the hearing, insisting that a new judge should be assigned before he would proceed. Judge Armond noted the appellant offered no evidence and warned that the petition could be dismissed for failure to prosecute. The appellant maintained his refusal, and Judge Armond dismissed the petition due to his failure to present evidence or pursue the claim. On appeal, the Supreme Court of Georgia considered only the dismissal order. The Court held that because the appellant failed to challenge the dismissal on the ground that he presented no evidence, that ground was presumed correct and binding. The Court further found that the recusal issue was irrelevant, since the judge whose recusal was sought did not dismiss the petition. The judgment of dismissal was affirmed. View "TWUM-BAAH v. THE STATE" on Justia Law

GREENE v. THE STATE

2026-08-18T04:05:59-08:00

Rodney Greene was convicted for the felony murder of Tyjerus White following a shooting incident. On the night of the incident, White drove with three companions to visit a friend. While they were parked outside, Greene approached the car, acted aggressively, and initiated a confrontation with White and his companions. Witnesses testified that Greene appeared intoxicated and escalated the situation by threatening White with a lighter and later brandishing a handgun. After a heated argument, White attempted to leave but was confronted again by Greene, resulting in gunfire. White was fatally wounded and later found in his crashed vehicle. A .22 caliber bullet was recovered from White’s body, and shell casings at the scene matched a .22 caliber firearm, which was never found. Greene was arrested weeks later and admitted to the shooting. The Superior Court of Sumter County conducted a jury trial, which found Greene guilty of felony murder and aggravated assault. Greene was sentenced to life imprisonment with the possibility of parole. He filed a motion for a new trial, which the trial court denied after a hearing. Greene then appealed to the Supreme Court of Georgia, arguing that the evidence was insufficient to disprove his claim of self-defense and raising two claims of ineffective assistance of counsel. The Supreme Court of Georgia reviewed the case and held that the evidence was constitutionally sufficient for a rational jury to find Greene guilty beyond a reasonable doubt and to reject his justification defense. The Court also concluded that Greene’s trial counsel was not constitutionally ineffective either for failing to seek a mistrial due to alleged juror misconduct or for not calling a GBI agent whose testimony would have been inadmissible hearsay. The Supreme Court of Georgia affirmed Greene’s conviction. View "GREENE v. THE STATE" on Justia Law

RICHARDSON v. THE STATE

2026-08-18T04:05:59-08:00

The case concerns Andre Richardson, who was convicted of malice murder and possession of a firearm during a felony after the fatal shooting of Xavier Cato. The incident arose after Richardson, having separated from his wife, Shicana Brown, encountered her and Cato together in a parking lot. Richardson confronted them, displayed a firearm, and, after an exchange, shot Cato twice. Cato died from his injuries. Surveillance footage and Richardson’s own statements were presented at trial, with Richardson claiming he acted reflexively out of fear, and his defense centered on the argument that the killing constituted voluntary manslaughter rather than murder. The Superior Court of Fulton County presided over Richardson’s trial. The jury found him guilty of malice murder, aggravated assault with a deadly weapon, and possession of a firearm during the commission of a felony, while acquitting him of computer invasion of privacy. The felony murder conviction was vacated by operation of law, and the aggravated assault conviction merged with the malice murder conviction. Richardson was sentenced to life in prison plus five years. After trial, Richardson, with new counsel, filed a motion for a new trial, alleging ineffective assistance of counsel. The trial court denied this motion, finding that Richardson’s trial attorney was not deficient. The Supreme Court of Georgia reviewed Richardson’s claim that his trial counsel had been constitutionally ineffective for eliciting an investigator’s opinion about the decision to charge murder rather than voluntary manslaughter. The Court held that Richardson failed to show his counsel’s performance was objectively unreasonable, noting that the line of questioning was a legitimate trial strategy aimed at supporting the voluntary manslaughter theory. The Court affirmed the denial of the motion for a new trial and Richardson’s convictions. View "RICHARDSON v. THE STATE" on Justia Law

Warner v. Hillsborough County Clerk of Courts

2026-08-17T11:32:09-08:00

After being involved in an eviction proceeding in Hillsborough County, Florida, an individual deposited funds into the court registry, as required by state law. Over time, he changed addresses and updated his contact information in the state’s e-filing system, but did not always update his address with the county court. The county clerk attempted to notify him of unclaimed funds by mailing letters to an outdated address (despite repeated returned mailings) and by publishing notice in a local Spanish-language newspaper with very limited circulation in the county. The funds were eventually declared abandoned and forfeited to the county under a Florida statute. The United States District Court for the Middle District of Florida granted summary judgment in favor of the county clerk. The district court found that publication in the local newspaper constituted constitutionally sufficient notice and that the forfeiture did not amount to an unconstitutional taking because statutory schemes for escheatment of abandoned property are generally permissible. The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court held that the statute’s notice procedure is not facially unconstitutional because there are situations where publication alone may suffice—for instance, when the property owner is unknown. However, the court found the clerk’s application of the statute to this individual was unconstitutional. The clerk had access to alternative means of contact (including email and a valid mailing address in the state’s e-file system) but failed to use them, relying instead on methods not reasonably calculated to provide notice. The court also determined that the individual had not abandoned the funds, since he never received constitutionally adequate notice, and thus the county’s appropriation of the funds constituted an unconstitutional taking. The Eleventh Circuit affirmed in part, reversed in part, and remanded for further proceedings. View "Warner v. Hillsborough County Clerk of Courts" on Justia Law

P. v. Lightsey

2026-08-17T09:03:24-08:00

The defendant was charged with capital murder and other offenses in 1993. Throughout the proceedings, concerns arose regarding his mental competency and his ability to represent himself. On two occasions, the trial court declared a doubt as to the defendant’s competency and held hearings, concluding both times that he was competent. During the second such hearing in July 1994, the defendant represented himself, which meant no counsel was appointed despite statutory requirements. The medical experts at the hearing offered differing views: one expert found the defendant competent to stand trial but not to represent himself, while the other found him unable to cooperate rationally with counsel. The defendant was ultimately convicted and sentenced to death. After direct appeal, the Supreme Court of California found reversible error in the trial court’s failure to appoint counsel during the 1994 competency proceedings and remanded the case, instructing the trial court to determine if a retrospective competency hearing was feasible. If feasible, a hearing would be held; if not, the reversal would stand. On remand, the Kern County Superior Court found that a retrospective hearing was feasible, conducted the hearing, and a jury found the defendant competent at the relevant time, leading to reinstatement of the judgment. The defendant appealed again, arguing that feasibility was not established. The Supreme Court of California held that the trial court erred in finding a retrospective competency hearing feasible. The court emphasized that such hearings are generally disfavored and that the prosecution had not met its burden to show sufficient and reliable evidence existed to determine the defendant’s competence nearly two decades later, especially given the unavailability of key witnesses and the compromised development of evidence due to the lack of appointed counsel in 1994. As a result, the Supreme Court reversed the reinstated judgment, subject to retrial if the defendant is then found competent. View "P. v. Lightsey" on Justia Law

Fields v. USA

2026-08-17T08:30:55-08:00

Derek Fields was involved in a violent kidnapping in September 2015, during which he and his co-defendants abducted Adrian Harris, inflicted physical harm, and demanded ransom. Fields was arrested within days alongside his co-defendants and indicted on several charges, including kidnapping, making a ransom demand, and firearm offenses. The government extended multiple plea offers, each carrying substantial prison time, but Fields consistently rejected them, viewing sentences over twenty years as tantamount to a life sentence. After his motion to suppress evidence was denied, Fields proceeded to trial, was convicted on all counts, and originally sentenced to 53 years. On appeal, his conviction under one firearm statute was vacated pursuant to United States v. Davis, 588 U.S. 445 (2019), and he was resentenced to 43 years. After his conviction became final, Fields filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Northern District of Indiana, arguing that his last counsel was constitutionally ineffective for failing to adequately advise him about an alleged 37-year plea offer presented during jury selection. The district court denied the motion without an evidentiary hearing, focusing primarily on a different plea agreement attached to Fields’s reply brief, and concluded that Fields failed to show prejudice because he did not establish a reasonable probability he would have accepted the offer and received a lower sentence. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo for legal questions and for abuse of discretion regarding the lack of an evidentiary hearing. The Seventh Circuit assumed, for argument’s sake, that the alleged 37-year plea offer existed and that counsel’s advice was inadequate, but found that Fields did not demonstrate a reasonable probability he would have accepted the plea or received a lower sentence. The court therefore affirmed the district court’s denial of Fields’s § 2255 motion without an evidentiary hearing. View "Fields v. USA" on Justia Law