Constitutional Law - Justia Case Law Summaries

Sochor v. State

2026-07-08T12:04:29-08:00

In 1981, Dennis Sochor murdered Patricia Gifford after she refused his sexual advances; her body was never recovered. Sochor, who had fled the state after seeing himself on television, was apprehended in Georgia five years later and confessed multiple times to the crime. At trial, the jury found him guilty of kidnapping and first-degree murder, recommending a death sentence by a 10-2 vote. The trial court imposed the death penalty, finding four aggravating factors and no mitigating circumstances. On direct appeal, the Supreme Court of Florida affirmed Sochor’s conviction and sentence but was later instructed by the United States Supreme Court to conduct a harmless error analysis regarding one aggravator. After doing so, the Florida court again affirmed. Sochor's conviction and sentence became final in 1993. Since then, he has pursued numerous postconviction challenges in both state and federal courts, all unsuccessful. After the Governor signed a death warrant in June 2026, Sochor filed a sixth successive postconviction motion in the Circuit Court for Broward County, raising two claims: a Brady/Giglio violation concerning a 2022 letter to his brother, and a facial challenge to Florida’s lethal injection protocol. The circuit court summarily denied both claims as untimely, procedurally barred, and without merit. The Supreme Court of Florida reviewed the summary denial de novo and affirmed the circuit court’s ruling. The court held that Sochor’s method-of-execution claim was untimely because the evidence on which it relied had been discoverable since at least 2017, and that the claim was meritless because similar challenges to Florida’s lethal injection protocol had repeatedly been rejected. The court also denied Sochor’s motion for a stay of execution and declined to hold oral argument or entertain a motion for rehearing. View "Sochor v. State" on Justia Law

Duckett v. State

2026-07-08T12:04:29-08:00

James Aren Duckett, a police officer, was convicted nearly forty years ago of the sexual battery and first-degree murder of eleven-year-old Teresa McAbee. On the night of May 11, 1987, Duckett was the only officer on patrol in Mascotte, Florida and was the last person seen with Teresa in his patrol car. Circumstantial evidence, including tire tracks and comingled fingerprints from the victim and Duckett on his patrol car, implicated him. Teresa’s body was found the next morning, and a medical examiner determined she had been sexually assaulted, strangled, and drowned. The jury found Duckett guilty and recommended a death sentence, which the trial court imposed after finding aggravating circumstances. Duckett’s conviction and sentence were affirmed by the Supreme Court of Florida in 1990. He subsequently sought postconviction relief several times in both state and federal courts, but all motions and petitions were denied. After a death warrant was signed in 2026, Duckett filed for postconviction DNA testing, which the circuit court granted. He then filed his fifth successive postconviction motion under Rule 3.851, raising claims of actual innocence and alleged constitutional violations. Before DNA testing results were available, the circuit court summarily denied his motion and declined to stay his execution. Duckett appealed and requested a stay, which the Supreme Court of Florida granted to allow completion of DNA testing. The Supreme Court of Florida reviewed the circuit court’s summary denial de novo. Duckett’s DNA testing results were found inconclusive, and his claims of actual innocence and constitutional violations lacked merit under Florida law. The Court affirmed the circuit court’s denial of Duckett’s fifth successive postconviction motion, denied his habeas petition, and lifted the stay of execution. No rehearing would be considered, and the mandate issued immediately. View "Duckett v. State" on Justia Law

US v. Carson

2026-07-08T10:30:41-08:00

Officers responding to reports of suspected drug activity at a public housing development in Asheville, North Carolina, began surveilling individuals frequenting the area. One individual, Jermaine Derrick Carson, Jr., was observed as a passenger in a vehicle whose driver had a suspended license. Weeks later, during a joint law enforcement operation targeting crime near downtown bars, officers recognized the same vehicle at a gas station and initiated a traffic stop before it returned to the housing complex. During the stop, officers detected the odor of marijuana and observed drug paraphernalia in the car. Carson was frisked and found to possess a loaded firearm. After Carson was indicted for possession of a firearm by a convicted felon in the United States District Court for the Western District of North Carolina, he moved to suppress the firearm, arguing that the traffic stop was unlawfully prolonged and that the frisk lacked reasonable suspicion. A magistrate judge held an evidentiary hearing, during which officers testified and body camera footage was reviewed. The magistrate judge recommended denial of the suppression motion, finding the officers had probable cause to search the vehicle after the detection of marijuana and that the frisk was lawful. The district court adopted the recommendation, denied the motion, and subsequently accepted Carson’s conditional guilty plea, sentencing him to 24 months imprisonment. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying de novo review for legal questions and clear error for factual findings. The court held that the officers had independent reasonable suspicion—specifically, the detection of marijuana odor—which justified the extension of the stop and the search. Additionally, the frisk was permissible due to reasonable suspicion of illegal drugs in the vehicle. The Fourth Circuit affirmed the district court’s denial of Carson’s suppression motion. View "US v. Carson" on Justia Law

Deal v. City of Monroe

2026-07-08T10:30:40-08:00

Kenneth Deal was appointed to the City of Monroe, North Carolina’s board of adjustment, a quasi-judicial municipal body responsible for handling certain appeals and permits. After completing one three-year term, he was reappointed to a second term. However, during this second term, the City Council voted to remove him from the board without cause or prior notice. Deal was not present at the meeting where the removal occurred, nor was he informed that his removal would be considered. Deal filed suit in the United States District Court for the Western District of North Carolina, alleging that the City violated his procedural due process rights when it deprived him of his board seat without notice or an opportunity to be heard. He sought relief under 42 U.S.C. § 1983 and requested a declaratory judgment to void his removal. Deal moved for partial summary judgment on liability, while the City sought summary judgment on all claims. The district court granted summary judgment in favor of the City, concluding that Deal did not have a constitutionally protected property interest in his board seat because the City Council retained discretion to remove board members at any time, with or without cause. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit affirmed the district court’s decision, holding that Deal lacked a constitutionally protected property interest in his seat. The court reasoned that because the City had broad discretion under its code and state law to appoint, remove, or even abolish the board, Deal’s interest in his seat did not amount to a legitimate claim of entitlement protected by the Fourteenth Amendment. The court rejected Deal’s reliance on state cases and found that local discretion was dispositive, affirming the district court’s judgment. View "Deal v. City of Monroe" on Justia Law

South Carolina State Conference of the NAACP v. Weaver

2026-07-08T10:30:40-08:00

A South Carolina budget provision, known as the “Proviso,” prohibits public schools from using state funds to teach certain concepts related to race and sex. Several Black students, the South Carolina State Conference of the NAACP (SC NAACP), and author Ibram Kendi challenged the Proviso, alleging it led to the removal of an Advanced Placement African American Studies (AP AAS) course and one of Kendi’s books from school libraries. The students and SC NAACP asserted that eliminating the AP AAS course infringed upon students’ First Amendment right to receive information, while Kendi claimed the book’s removal constituted viewpoint discrimination. Plaintiffs further alleged that the Proviso was void for vagueness and violated the Equal Protection Clause. The United States District Court for the District of South Carolina dismissed the complaint for lack of Article III standing. The court concluded that the individual students did not allege a concrete injury as they had not actually enrolled in AP AAS, and found that even a student who had enrolled failed to establish that her injury was traceable to the Proviso rather than an unrelated curriculum review. The district court also held that Kendi’s injury was not redressable because the school district cited an alternative, unchallenged rationale for removing his book. The United States Court of Appeals for the Fourth Circuit affirmed in part, reversed in part, vacated in part, and remanded. It affirmed dismissal with respect to a student who had graduated and another who had not taken concrete steps to enroll in AP AAS. However, it held that SC NAACP adequately alleged standing for at least one member with an ongoing injury, and Kendi sufficiently alleged standing for his viewpoint discrimination claim. The court vacated dismissal of other claims and remanded for the district court to address unresolved standing and merits questions. View "South Carolina State Conference of the NAACP v. Weaver" on Justia Law

Roberts v. Engelke

2026-07-08T10:30:38-08:00

An inmate at Red Onion State Prison in Virginia, who is a Sunni Muslim, requested accommodations to observe both the Ramadan fast and to maintain a diet prepared according to Jewish Kashrut law, as he sincerely believed both were religious requirements. The prison had an Orthodox Jewish Kosher Diet (OJKD) and a Common Fare menu, but in 2020 could not provide a version of the OJKD that also allowed for Ramadan fasting on short notice. The inmate was offered a choice between maintaining the OJKD without fasting or switching to the Common Fare menu to fast, but with restrictions on switching back. He tried to fast by saving OJKD meals for sunset, but this led to food poisoning. By 2021, the prison had created a Ramadan-compliant OJKD. The United States District Court for the Western District of Virginia granted summary judgment to the prison officials on all claims. The court held that the officials were protected by Eleventh Amendment immunity for damages in their official capacities and found that damages were not available under RLUIPA. The court also found the request for injunctive relief moot after the policy change. The remaining claims for damages under the Constitution were dismissed on qualified immunity grounds, as the court determined the rights were not clearly established or that there was no constitutional violation. On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the denial of a discovery motion and agreed that injunctive and declaratory relief were moot, and that summary judgment was proper on the Establishment Clause and Equal Protection claims. However, the Fourth Circuit held that the inmate’s right to a religious diet consistent with his sincerely held beliefs was clearly established and that the district court erred by failing to apply the proper standard to his Free Exercise claim. The court reversed in part, vacated in part, and remanded for the district court to consider whether the failure to accommodate in 2020 was reasonably related to legitimate penological interests under the Turner standard. View "Roberts v. Engelke" on Justia Law

US v. Williams

2026-07-08T10:30:38-08:00

Police officers responded to an anonymous 911 call reporting that individuals inside a white Mercedes sedan parked near the pool area of an apartment complex might be selling or possessing narcotics. The officers received this information through their department’s computer-aided dispatch system. Upon arrival, the officers stopped their marked police vehicles in the roadway, positioning themselves such that one car was partially in front of the Mercedes and another behind. They exited their vehicles, approached the Mercedes, and immediately smelled marijuana. Williams, the defendant, admitted to smoking marijuana, after which he and the other occupants were directed to exit the vehicle. In the ensuing search, officers found a handgun, and Williams admitted ownership. The United States District Court for the Western District of North Carolina denied Williams’ motion to suppress the evidence found during the search. The district court found that Williams was not seized when the officers stopped their cars, reasoning that there was physical room for him to leave and a reasonable person would have felt free to do so. The court further concluded that the officers had reasonable suspicion to seize Williams after smelling marijuana and that the search was supported by probable cause. Williams was subsequently convicted of being a felon in possession of a firearm after a bench trial. On appeal, the United States Court of Appeals for the Fourth Circuit held that Williams was seized for Fourth Amendment purposes when the officers blocked his vehicle with their marked patrol cars, as a reasonable person would not have felt free to leave under the circumstances. The court further held that the officers lacked reasonable suspicion to justify this seizure based solely on the anonymous tip and the fact the encounter occurred in a high-crime area. The court reversed the district court’s denial of the suppression motion, vacated Williams’ conviction, and remanded for further proceedings. View "US v. Williams" on Justia Law

State v. Schuster

2026-07-08T08:40:37-08:00

The defendant in this case was arrested following a traffic stop and charged with several offenses, including receiving or transferring a stolen motor vehicle and possession of a controlled substance. He was released on his own recognizance the same day and remained at liberty under court-imposed conditions. More than three years elapsed between his arrest and the district court’s decision on his motion to dismiss for violation of his right to a speedy trial. During this period, delays were attributed to procedural extensions, COVID-19-related jury trial suspensions, and significant systemic backlog in the local court system, which the district court found was exacerbated by prosecutorial policy. The district court, applying the four-factor test from Barker v. Wingo and New Mexico precedent, found that the length of delay was presumptively prejudicial, most of the delay was attributable to the State, and the defendant had adequately asserted his right to a speedy trial. The court also found that the defendant suffered particularized prejudice and alternatively presumed prejudice due to governmental indifference. As a result, the district court dismissed the charges with prejudice. The State appealed. The New Mexico Court of Appeals reversed, finding that the defendant did not show particularized prejudice and that the other Barker factors did not all weigh heavily enough against the State to excuse the absence of such a showing. The Court of Appeals weighed the State’s culpability as only “moderately to heavily” against it and reduced the impact of the defendant’s assertions of his right, viewing them as largely pro forma. The Supreme Court of the State of New Mexico reversed the Court of Appeals, holding that the first three Barker factors—length of delay, reasons for delay, and assertion of the right—each weighed heavily against the State. The Court concluded that, under New Mexico law, when these three factors weigh heavily against the State, a showing of particularized prejudice is not required, and the defendant’s right to a speedy trial was violated. The Court remanded for dismissal with prejudice. View "State v. Schuster" on Justia Law

State v. Causey

2026-07-08T08:40:36-08:00

Two days after a double homicide occurred in Bernalillo County, New Mexico, a vehicle registered in New Mexico was stopped in Wheeler County, Texas, for an equipment violation. The defendant was a passenger in the vehicle. During the stop, the Texas deputy sheriff questioned the driver, who eventually admitted there was marijuana in the car. The deputy conducted a probable cause search, detained the defendant, and discovered a handgun, later linked to the New Mexico homicides. The defendant was indicted in New Mexico on charges related to the homicides and other crimes. He moved to suppress the physical evidence and statements obtained during the Texas stop, arguing the search violated both the U.S. Constitution and Article II, Section 10 of the New Mexico Constitution. The State argued Texas law should govern the admissibility of the evidence, as the search occurred in Texas and was lawful there. The District Court of Bernalillo County disagreed, applying New Mexico’s exclusionary rule and suppressing the evidence, relying on New Mexico cases concerning evidence gathered by federal agents within New Mexico. The Supreme Court of the State of New Mexico reviewed whether the district court correctly applied New Mexico’s constitutional exclusionary rule to evidence obtained in another state, where the search complied with that state’s law but would violate New Mexico’s constitution. The court held that Article II, Section 10 of the New Mexico Constitution governs the admissibility of evidence in New Mexico courts, regardless of whether the evidence was obtained by out-of-state law enforcement in compliance with their own laws. Evidence gathered in violation of Article II, Section 10 is inadmissible in New Mexico courts. The court affirmed the district court’s order suppressing the evidence. View "State v. Causey" on Justia Law

Spengler v Cooperative Educational Service Agency 7

2026-07-08T08:30:47-08:00

A special education administrator was employed by a Wisconsin state agency that facilitated educational services across multiple school districts. After a couple years, her supervisors, following directives from the Wisconsin Department of Public Instruction, pushed staff to adopt an “equity mindset,” which involved examining personal biases and working to disrupt systems influenced by white supremacy. The administrator disagreed with the perceived ideological requirements and refused to fully embrace the equity mindset, leading to concerns from the Department of Public Instruction, pressure on the agency, and her eventual demotion to a lower-paying job. The administrator filed suit in the United States District Court for the Eastern District of Wisconsin, alleging violations of Title VII and the Equal Protection Clause, claiming discrimination and retaliation based on her race. She also asserted a First Amendment claim, alleging retaliation based on her speech and beliefs. The district court granted summary judgment to the defendants on the Title VII and Equal Protection claims, finding no evidence that race was a motivating factor in her demotion, as the ideological requirements were applied to employees of all races. The court rejected her First Amendment claims regarding her speech and insufficiently pleaded her beliefs-based claim. The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the district court’s summary judgment on the Title VII and Equal Protection claims, holding that no reasonable jury could find her race was the cause of her demotion and that she did not engage in an objectively reasonable protected activity for retaliation purposes. However, the Seventh Circuit determined she adequately pleaded a First Amendment claim based on retaliation for her beliefs and remanded that claim for further proceedings. View "Spengler v Cooperative Educational Service Agency 7" on Justia Law

US v. Johnson

2026-07-07T13:30:02-08:00

The defendant was investigated after law enforcement used a specialized tool called Freenet Roundup, which is a modified version of a peer-to-peer software called Freenet. Freenet allows users to share files anonymously, but its Opennet mode warns users that their identity could be discovered and their IP address is visible to strangers. Freenet Roundup, available only to law enforcement, logs requests for known child sexual abuse material (CSAM) and uses a formula to help identify whether a request came from an original source or was simply relayed. After Freenet Roundup flagged requests associated with the defendant’s IP address for CSAM, the FBI obtained a search warrant for his residence, finding devices containing child pornography. The defendant was charged in the United States District Court for the District of Massachusetts with possession of child pornography. Before trial, he moved to suppress the evidence, arguing that law enforcement’s use of Freenet Roundup constituted an unlawful Fourth Amendment search, as he claimed a reasonable expectation of privacy in his Freenet transmissions. The district court denied the motion, reasoning that because the defendant voluntarily used Freenet’s Opennet mode, which warns of identity risks and connections with strangers, he lacked a reasonable expectation of privacy in the relevant activity. The court distinguished this case from Carpenter v. United States, finding that law enforcement’s actions did not amount to wholesale surveillance or use of technology not in general public use. The defendant then entered a conditional guilty plea, preserving his right to appeal the suppression ruling. On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s findings for clear error and its legal conclusions de novo. The First Circuit held that a defendant lacks a reasonable expectation of privacy in activity voluntarily shared on publicly-available peer-to-peer networks like Freenet’s Opennet mode. The court affirmed the district court’s denial of the suppression motion. View "US v. Johnson" on Justia Law

City of Clearlake v. Highlands Mutual Water Co.

2026-07-07T13:13:56-08:00

A city owned shares in a mutual water company that were appurtenant to land it held. After a dispute regarding the city’s right to inspect corporate records, the water company cancelled the city’s shares, citing Corporations Code section 14300, which requires mutual water companies to cancel appurtenant shares held by public entities. The city argued that this statute violated its rights under article XVI, section 17 of the California Constitution, which allows public entities to acquire and hold shares in mutual water companies for furnishing water for public, municipal, or governmental purposes. The Superior Court of Lake County initially issued a temporary restraining order invalidating a board election and later granted the city’s request for a preliminary injunction. The injunction required the water company to re-issue the cancelled shares to the city, concluding that Corporations Code section 14300 was unconstitutional because it conflicted with section 17 of the state constitution. The trial court found that the city’s operation of a public facility, such as a splash pad, constituted a valid public purpose under section 17 and determined that the city was likely to suffer harm without the injunction. On appeal, the Court of Appeal of the State of California, First Appellate District, Division One, reviewed the constitutionality of Corporations Code section 14300 de novo, applying a presumption in favor of the statute’s validity. The appellate court interpreted section 17 as permitting public entities to hold shares only when acting as a water purveyor for their territory, not merely as a landowner receiving water for its own parcels. The court held that section 14300 does not violate section 17, as the statute can reasonably be construed to exclude appurtenant shares from the constitutional exception. Accordingly, the Court of Appeal reversed the trial court’s order granting the preliminary injunction and remanded the case for further proceedings. View "City of Clearlake v. Highlands Mutual Water Co." on Justia Law

USA v. Martinez

2026-07-07T08:30:47-08:00

A semi-truck driver was stopped in Illinois after state police received a tip from another law enforcement agency that the truck was carrying a large amount of narcotics. Two K9 troopers, not on routine patrol, waited on the side of the highway in the early morning hours to intercept the vehicle. The stated purpose for the stop was to conduct an administrative Level 3 inspection under Illinois’s commercial trucking regulatory scheme, involving checks of driver and vehicle documents. During the stop, the trooper noticed several signs he considered suspicious, including an odor of air freshener and irregularities with the driver’s route and cargo. A dog sniff of the truck led to the discovery of narcotics, and the driver was arrested. The United States District Court for the Central District of Illinois heard the defendant’s suppression motion, in which he argued the stop was a pretextual administrative inspection aimed solely at investigating criminal activity, thus violating the Fourth Amendment. The district court denied the motion, reasoning that the officer’s subjective intent was irrelevant so long as the stop was authorized under Illinois’s regulatory scheme. On appeal, the United States Court of Appeals for the Seventh Circuit held that, in the context of administrative inspections, an officer’s actual motivation for conducting the stop is relevant. The court found that the evidence showed the stop was undertaken solely to further a criminal investigation, not to enforce administrative regulations. It further held that the government had failed to demonstrate the stop was justified in its inception under the administrative inspection exception to the warrant requirement. The court concluded that the evidence obtained as a result of the stop must be suppressed and that the good faith exception to the exclusionary rule did not apply. The Seventh Circuit reversed the district court’s denial of the suppression motion and remanded for further proceedings. View "USA v. Martinez" on Justia Law

Angelo v. DC

2026-07-07T07:32:03-08:00

Several individuals who hold concealed-carry pistol licenses issued by the District of Columbia challenged a local law prohibiting licensed carriers from possessing firearms on public transportation, including the Metro system. Fearing prosecution if they carried their pistols on the Metro, these plaintiffs avoided using public transit and instead paid for more expensive private transportation. They alleged that this criminal statute violated their Second and Fifth Amendment rights and sought declaratory, injunctive, and monetary relief against the District and several officials in both their official and personal capacities. The United States District Court for the District of Columbia initially denied the plaintiffs’ motion for injunctive relief, citing circuit precedent that required them to demonstrate a special law enforcement priority or heightened risk of prosecution. When the plaintiffs amended their complaint to include allegations of increased transportation costs and added defendants, the District Court dismissed the case for lack of standing. Specifically, it found the plaintiffs had not alleged facts indicating a credible and imminent threat of prosecution, and it rejected their economic injury as insufficient for standing. The court also dismissed damages claims against individual defendants, which plaintiffs abandoned. The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. It held that the plaintiffs had standing for their claims for declaratory and injunctive relief against all defendants (except one official capacity claim not appealed), as well as for damages against the District, because their ongoing economic injury—incurred by complying with the Metro Ban—constituted a concrete, imminent, and traceable harm. The Court affirmed the dismissal of damages claims against individual defendants, reversed the dismissal of the remaining claims, and remanded for further proceedings. View "Angelo v. DC" on Justia Law

Pernell v. Commissioner of the FL State Board of Education

2026-07-07T06:31:44-08:00

Florida enacted a law prohibiting public university professors from endorsing or promoting certain ideas related to race, color, sex, and national origin in classroom instruction. The law, known as the Individual Freedom Act, identifies eight specific concepts that professors are barred from espousing, such as claims of moral superiority based on race or sex, inherent racism or oppression, and the idea that virtues like merit or colorblindness are themselves racist or sexist. The law allows professors to discuss these concepts in a neutral way, but not to advocate for them, and imposes severe penalties on both individual professors and universities for violations, including the loss of significant funding and potential termination of employment. Groups of professors and students from several Florida public universities filed lawsuits in the United States District Court for the Northern District of Florida, arguing that the Act violated their First Amendment rights by restricting viewpoint-based expression and was unconstitutionally vague. The district court granted preliminary injunctions in both cases, enjoining enforcement of the Act’s classroom restrictions against the plaintiffs, finding that at least one plaintiff had standing to challenge each prohibited concept. The court concluded the Act was likely unconstitutional as applied to public university professors. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s grant of a preliminary injunction. The Eleventh Circuit affirmed, holding that the Act’s restrictions amount to unconstitutional viewpoint discrimination in violation of the First Amendment. The court distinguished between permissible curricular control by universities and the broad, legislative ban imposed by the state’s political branches. It concluded that neither public-employee speech doctrine nor government speech doctrine justified the law’s suppression of disfavored ideas in the university classroom, and that the Act impermissibly infringed on academic freedom and open inquiry. The preliminary injunction was affirmed. View "Pernell v. Commissioner of the FL State Board of Education" on Justia Law

People Of Michigan v. Klungle

2026-07-07T05:00:03-08:00

The case arose from a dispute over property ownership following the death of a homeowner who did not leave a will. The defendant, who had lived in the home with his children and grandmother, refused to leave after her death despite an eviction order. When sheriff’s deputies arrived to enforce the eviction, the defendant resisted leaving and was arrested. As a result, he was charged with trespassing and two counts of resisting or obstructing a police officer. The defendant maintained throughout that he believed he had a right to remain in the home and thus was not trespassing. After a jury trial in Emmet Circuit Court, the defendant was convicted on all counts. He moved for a new trial, arguing that his Sixth Amendment rights were violated when his counsel conceded guilt on the trespassing charge during closing argument without consulting him or securing his consent. At the evidentiary hearing, trial counsel testified that the defendant had consistently maintained his innocence before trial and was not informed of the plan to concede guilt. The trial court denied the motion, reasoning that the defendant failed to cooperate with counsel and did not object to the concession. The Court of Appeals affirmed, finding that counsel acted within his discretion given the lack of communication. The Michigan Supreme Court reviewed the case and held that under McCoy v. Louisiana, a criminal defendant has the right to decide the objective of the defense, including maintaining innocence. The Court found that defense counsel’s unilateral concession of guilt, despite the defendant’s insistence on innocence and without consultation, violated this right. The Court clarified that a defendant is not required to contemporaneously object to preserve this claim. The structural error required automatic reversal. The judgment of the Court of Appeals was reversed, the convictions vacated, and the case remanded for a new trial on all charges. View "People Of Michigan v. Klungle" on Justia Law

AbbVie v. Murrill

2026-07-06T15:30:30-08:00

Several pharmaceutical manufacturers and a trade association challenged a Louisiana statute enacted in 2023, which prohibits drug manufacturers and distributors from interfering with the acquisition or delivery of discounted drugs—purchased under the federal Section 340B Drug Pricing Program—to pharmacies contracted by certain healthcare providers. The 340B Program requires drug manufacturers participating in Medicaid and Medicare to provide discounted outpatient drugs to designated healthcare providers serving low-income and rural populations. Many of these providers lack in-house pharmacies and use external contract pharmacies. In response to manufacturer-imposed limits on contract pharmacy use, Louisiana enacted Act 358 to preserve covered entities’ ability to use such pharmacies. The plaintiffs, including AbbVie, AstraZeneca, and the Pharmaceutical Research and Manufacturers of America, filed separate lawsuits in the United States District Court for the Western District of Louisiana against the Louisiana Attorney General, arguing that Act 358 is preempted by federal law, constitutes an unconstitutional taking, impairs contracts in violation of the Contracts Clause, and is unconstitutionally vague. The district court consolidated the cases, granted summary judgment for Louisiana and the Louisiana Primary Care Association (an intervenor), and rejected all of the manufacturers’ claims. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that Act 358 is not preempted by federal law, as the federal 340B Program does not regulate drug distribution logistics or the use of contract pharmacies, and thus leaves room for state regulation. The court further concluded that Act 358 does not effect a taking under the Fifth Amendment, does not substantially impair contractual obligations under the Contracts Clause, and is not unconstitutionally vague under the Due Process Clause. The Fifth Circuit thus upheld summary judgment for Louisiana on all claims. View "AbbVie v. Murrill" on Justia Law

Adelanto Elementary Sch. Dist. v. Krause

2026-07-06T11:03:28-08:00

A former superintendent of a California school district, who later became an elected member of the district’s Board of Trustees, was subject to a workplace violence restraining order (WVRO) requested by the district on behalf of three employees. These employees, who worked closely with the superintendent, reported that he engaged in a persistent course of conduct that included angry outbursts, threats of termination, intrusive and inappropriate text messages, stalking behaviors, and unsolicited photographs. The conduct caused substantial emotional distress and fear among the employees, leading them to seek mental health treatment and report his actions to the police. After his termination, the superintendent continued to interact with the employees in ways they perceived as intimidating, including the placement of campaign signs near their homes and the publication of internal documents on social media. The Superior Court of San Bernardino County granted a temporary restraining order and, after a multi-day hearing, issued a WVRO prohibiting the superintendent from harassing, disturbing the peace of, or contacting the three employees. The WVRO imposed restrictions on his proximity to the employees and their workplace, allowed his attendance at board meetings only under specific conditions, and included a provision barring him from commenting on the WVRO at board meetings. The order was set to last four years, subject to early termination if he was no longer associated with the district. The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that an employer’s right to seek a WVRO on behalf of employees is unwaivable under Civil Code section 3513, rejected arguments concerning insufficient evidence and violation of parental rights, and found sufficient evidence of a future threat of harassment. However, it determined that the WVRO’s prohibition on comments at board meetings was overbroad and violated First Amendment rights, and that the order’s four-year duration exceeded the statutory maximum. The court modified the order to remove the speech restriction and limit its duration to three years, then affirmed the WVRO as modified. View "Adelanto Elementary Sch. Dist. v. Krause" on Justia Law

State of Florida v. Secretary, US Department of Education

2026-07-06T09:32:09-08:00

The dispute centers on whether the U.S. Department of Education may constitutionally rely on private educational accreditors in disbursing federal education funds. Under the Higher Education Act, colleges and universities must be accredited by a recognized accreditor for their students to be eligible for federal financial aid. Accreditors are private, voluntary organizations funded by the schools they accredit. Florida challenged this arrangement, alleging that it unconstitutionally delegates government power to private accreditors and violates both the Appointments Clause and the Spending Clause, claiming the accreditation requirement is an unascertainable condition for federal funds. The United States District Court for the Southern District of Florida reviewed the suit after Florida brought four claims: a private nondelegation doctrine challenge, an Appointments Clause challenge, a Spending Clause challenge, and a now-abandoned Administrative Procedure Act challenge. The federal government moved to dismiss, and the district court granted the motion. The district court found no unlawful delegation of government power, noted that Title IV funds are directed to students and not institutions, determined the accreditation requirement is unambiguous, and dismissed the Appointments Clause claim because accreditors do not determine eligibility for federal funds. On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s dismissal de novo. The Court held that private accreditors do not exercise government authority that could violate the Vesting Clauses or the Appointments Clause. The Court also determined that the accreditation requirement is an ascertainable condition for federal funds, as it is a well-understood, longstanding practice and does not amount to an ambiguous or novel restriction. The Eleventh Circuit affirmed the district court’s dismissal of Florida’s suit. View "State of Florida v. Secretary, US Department of Education" on Justia Law

Henry v. Sheriff of Tuscaloosa County, Alabama

2026-07-06T07:32:30-08:00

A man who was convicted of possessing child pornography in 2013 served his sentence and later married and had a son. Despite completing sex offender treatment and complying with supervised release conditions, he remained subject to Alabama’s Sex Offender Registration and Community Notification Act (“the Act”). This law prohibits him, for life, from residing with or conducting overnight visits with any minor—including his own child—because his conviction involved a child-related offense. The Act contains no mechanism for relief or individualized assessment, even for parents who have shown rehabilitation. After the birth of his son, the man sued the Sheriff and District Attorney of Tuscaloosa County and the Alabama Attorney General under 42 U.S.C. § 1983, seeking to enjoin enforcement of the Act’s prohibition against living with his child. The United States District Court for the Middle District of Alabama granted summary judgment in his favor, declaring the Act’s prohibition facially unconstitutional and issuing a universal injunction. On appeal, a panel of the United States Court of Appeals for the Eleventh Circuit affirmed in part, reversed in part, and vacated and remanded in part, finding the Act unconstitutional as applied to the plaintiff but vacating the universal injunction. The panel’s opinion was then vacated, and the case was reheard en banc. The United States Court of Appeals for the Eleventh Circuit held that all parents—including those with past convictions or “misconduct”—enjoy a fundamental right to live with their children under the Fourteenth Amendment. The court rejected Alabama’s argument that certain classes of parents lack this right due to prior offenses. The court remanded the case to the panel for further proceedings under strict scrutiny, requiring Alabama to show its law is narrowly tailored to serve a compelling state interest. The court affirmed in part and remanded in part. View "Henry v. Sheriff of Tuscaloosa County, Alabama" on Justia Law

Sosnava Rodriguez v. Ortega

2026-07-02T15:30:29-08:00

Three individuals, each having entered the United States unlawfully more than a decade ago, were detained by federal immigration authorities after routine traffic stops in Texas. None had criminal histories, and each was a long-term resident and father of U.S. citizen children. They petitioned for cancellation of removal under 8 U.S.C. § 1229b(b)(1), claiming exceptional hardship to their U.S. citizen children if removed. After being detained without bond under 8 U.S.C. § 1225(b)(2)(A), they filed habeas corpus petitions, asserting their detention violated the Fifth Amendment’s Due Process Clause. The United States District Court for the Western District of Texas reviewed each petition, applying the procedural due process framework from Mathews v. Eldridge. The district courts found the mandatory detention regime unconstitutional as applied to these petitioners, ordered their immediate release, and required that any future detention must be preceded by a hearing to determine dangerousness or risk of flight. The government appealed these rulings, and the United States Court of Appeals for the Fifth Circuit consolidated the cases. The Fifth Circuit examined precedent, including Zadvydas v. Davis, Demore v. Kim, and Department of Homeland Security v. Thuraissigiam, and concluded that physical presence and long-term residence within the United States entitles aliens to due process protections. The court held that mandatory, indefinite detention of noncriminal, long-term resident aliens under § 1225(b)(2)(A) without a bond hearing violates the Fifth Amendment. The government must provide a bond hearing within ninety days of detention to determine if continued detention is justified by individualized findings of dangerousness or flight risk. The court affirmed the district courts’ grants of habeas corpus and clarified the scope of its decision to similar aliens detained under § 1225(b)(2)(A). View "Sosnava Rodriguez v. Ortega" on Justia Law

St. Dominic Academy v. Makin

2026-07-02T13:30:04-08:00

A Maine Catholic school, the Roman Catholic Diocese that operates it, and parents seeking to send their children there challenged several antidiscrimination provisions in Maine’s Human Rights Act (MHRA). The MHRA applies to schools receiving public tuition assistance and prohibits discrimination based on religion, sexual orientation, and gender identity. St. Dominic Academy, not currently receiving tuition assistance but eligible to do so, argued that these rules would require them to change admissions and employment policies central to their religious mission, including prioritizing Catholic students and requiring conformity with Catholic teachings. The school also objected to policies on gender identity that would compel the school to use students’ preferred pronouns and permit dress consistent with gender identity, potentially over parental objections. The United States District Court for the District of Maine denied St. Dominic’s request for a preliminary injunction, finding the school’s employment practices protected by MHRA carveouts and determining St. Dominic had not shown a likelihood of success on its other claims. The court also denied similar relief in a companion case brought by another religious school, and entered final judgment for the state officials. Reviewing the appeal, the United States Court of Appeals for the First Circuit affirmed in part and reversed in part. The court affirmed that St. Dominic lacked standing to challenge the employment rule, and that the challenges to the religious nondiscrimination and sexual orientation/gender identity rules were unlikely to succeed: these rules are neutral, generally applicable, and rationally related to legitimate state interests. However, the court reversed as to the “Religious Expression Rule,” finding it facially nonneutral and likely unconstitutional under the Free Exercise Clause. The First Circuit ordered entry of a preliminary injunction against enforcement of this rule as applied to St. Dominic. The parental-rights claim was deemed moot and remanded for dismissal. View "St. Dominic Academy v. Makin" on Justia Law

Crosspoint Church v. Makin

2026-07-02T13:30:03-08:00

A Christian church in Maine operates a private K–12 school that adheres closely to its religious beliefs, including requiring students and staff to conform to a statement of faith and specific codes of conduct and dress. The school is willing to admit students of any background if their families support its religious philosophy, but it maintains policies that exclude students who are openly gay or transgender and requires employees to be co-religionists. The school sought to participate in Maine’s tuition-assistance program, which allows public funds for private education in certain circumstances, but did not apply because of state nondiscrimination laws it believed would conflict with its religious practices. The United States District Court for the District of Maine denied the school’s motion for a permanent injunction against several provisions of the Maine Human Rights Act (MHRA), finding either no case or controversy or no constitutional violation. The case reached the United States Court of Appeals for the First Circuit after the parties stipulated to final judgment based on the preliminary injunction record, reserving all appellate rights. The United States Court of Appeals for the First Circuit reviewed whether the MHRA’s rules on employment, religious expression, religious nondiscrimination, and sexual orientation/gender identity nondiscrimination violate the First Amendment as applied to the school. The court held there was no case or controversy regarding the employment rule due to existing carveouts. It affirmed the district court’s rejection of the school’s challenges to the religious nondiscrimination and sexual orientation/gender identity rules, finding no constitutional violation. However, the court determined that the religious expression rule violates the school’s free-exercise rights and must be enjoined as applied to the school. The judgment was affirmed in part and reversed in part, and the case was remanded for entry of a permanent injunction against enforcement of the religious expression rule. View "Crosspoint Church v. Makin" on Justia Law

State v. Nahulu

2026-07-02T12:33:35-08:00

After a late-night police pursuit in Makaha, a white Honda being followed by several Honolulu Police Department officers crashed, causing severe injuries to its young occupants. Officer Joshua Nahulu was alleged to have driven the lead pursuit vehicle, with officers Erik Smith, Jake Ryan Bartolome, and Robert Gus Lewis III following. Witness accounts conflicted on whether police vehicles made physical contact with the Honda. However, an expert found no evidence of such contact. None of the officers stopped to render aid after the crash, and they only returned after other emergency responders had arrived. Nahulu was charged under Hawaiʻi’s “fled scene” statute, which requires a driver “involved in a collision” resulting in serious injury or death to stop and render aid. His co-defendants were charged with hindering prosecution and conspiracy. The Circuit Court of the First Circuit denied the defendants’ motions to dismiss, finding the statute’s language—specifically, “involved in a collision”—was not unconstitutionally vague and that the defendants had sufficient notice of the charges. The court ordered the State to clarify, through a bill of particulars, whether it alleged physical contact between Nahulu’s vehicle and the Honda; the State responded that it did not rely on such a theory. On appeal, the Supreme Court of the State of Hawaiʻi held that Nahulu could only challenge the statute as vague as applied to his conduct, not on its face, since the law does not implicate constitutional rights such as free speech. The court further held that “involved in a collision” is not unconstitutionally vague as applied to Nahulu and that the combination of the charging instrument and the bill of particulars provided sufficient notice of the nature and cause of the accusation. The Supreme Court affirmed the circuit court’s denial of the motions to dismiss. View "State v. Nahulu" on Justia Law

In re Melson

2026-07-02T11:03:27-08:00

The case centers on a defendant charged with multiple crimes stemming from a fatal gang-related shooting in Watts, Los Angeles. Two eyewitnesses, one from inside the victim’s car and another from a nearby house, identified the defendant as the shooter or as fleeing the scene. Their identification was primarily based on a photo lineup and their testimony at trial. The first trial ended in a hung jury, but during the retrial, both witnesses added new details, claiming to have told police about key identifying features or sightings soon after the shooting. These statements were contradicted by police interview transcripts, which were not presented at trial. Following the retrial, the defendant was convicted of murder, attempted murder, shooting at an occupied vehicle, and possession of a firearm by a felon. On direct appeal, one attempted murder conviction was reversed, but the rest of the judgment was affirmed by the California Court of Appeal. The defendant filed a habeas corpus petition, alleging that the prosecution allowed false testimony and that his trial counsel was ineffective for failing to impeach the witnesses. The Los Angeles County Superior Court denied the petition after an evidentiary hearing, finding the witnesses’ statements to be merely inconsistent, not false. The California Supreme Court then ordered the Court of Appeal to reconsider the habeas petition. The California Court of Appeal, Second Appellate District, reviewed the petition and found that the prosecution failed its constitutional duty to correct false testimony from its witnesses, and defense counsel’s lack of preparation contributed to the use of false evidence. Applying the materiality standard from Napue v. Illinois and Glossip v. Oklahoma, the court held that the People did not prove beyond a reasonable doubt that the false testimony did not contribute to the conviction. The court granted the writ of habeas corpus, vacated the conviction, and remanded the case for further proceedings. View "In re Melson" on Justia Law

Langford v. Stonebreaker

2026-07-02T10:30:50-08:00

After a robbery at a Chinese restaurant owner’s home in South Carolina, three masked men assaulted the family and stole their earnings. The victims could not identify the attackers, and no forensic evidence was left behind. Weeks later, a tip led investigators to three suspects, including K.C. Langford, who was arrested and indicted along with two co-defendants. Langford’s trial was delayed for nearly two years, partly due to difficulties in securing an interpreter for the victims and because one co-defendant, Alvin, initially refused to testify after being pressured by Langford and another defendant. The trial eventually proceeded, with Alvin testifying against Langford. Langford was convicted of criminal conspiracy, armed robbery, first-degree burglary, and kidnapping. After conviction, Langford appealed to the South Carolina Supreme Court, which affirmed his convictions. The court found that although the prosecutor’s control over the trial docket violated the state constitution, Langford suffered no prejudice from it. Applying the Barker v. Wingo framework, the court determined the nearly two-year delay did not violate Langford’s Sixth Amendment right to a speedy trial, considering the reasons for the delay and lack of prejudice to Langford’s defense. Langford’s postconviction relief application in the Court of Common Pleas was denied, as the court found no ineffective assistance of counsel regarding a hearsay issue in the trial. The South Carolina Court of Appeals denied certiorari. Langford’s co-defendant, Bryan, received postconviction relief in a separate proceeding. Langford then sought federal habeas corpus relief in the United States District Court for the District of South Carolina, which granted the writ on claims of speedy trial violation and ineffective assistance of counsel. The United States Court of Appeals for the Fourth Circuit reversed, holding that the South Carolina courts’ decisions were not unreasonable applications of clearly established federal law nor based on unreasonable factual determinations. The Fourth Circuit ordered reversal of the district court’s grant of habeas corpus. View "Langford v. Stonebreaker" on Justia Law

USA v Rose

2026-07-02T09:01:19-08:00

In 2009, Jonathan Rose was involuntarily committed to a mental institution in Indiana due to a psychiatric disorder, though the specific diagnosis and its severity were not detailed in the record. He was released in early 2010 and has not been recommitted since. In 2022, Rose successfully purchased multiple firearms, though he was denied others after background checks revealed his prior commitment. In 2023, he was indicted under federal law for possessing firearms as a person previously committed to a mental institution and for making false statements to firearms dealers by denying his commitment history. The United States District Court for the Northern District of Indiana reviewed Rose’s case and dismissed the counts related to possession of firearms by a previously committed person under 18 U.S.C. §922(g)(4). The district court reasoned that this statute, as applied to someone no longer suffering from mental illness, was inconsistent with the Second Amendment, particularly in light of recent Supreme Court decisions emphasizing individualized assessments of current danger rather than permanent disabilities based on past conditions. The United States Court of Appeals for the Seventh Circuit considered the government’s appeal. The court determined that the district court should not have dismissed the indictment without an evidentiary hearing to assess Rose’s current mental health and dangerousness. The Seventh Circuit held that, after recent Supreme Court decisions, the constitutionality of §922(g)(4) as applied depends on whether the defendant currently poses a credible threat to the safety of others. Because the record lacked evidence concerning Rose’s present mental condition, the appellate court vacated the district court’s order and remanded for further proceedings to develop the necessary facts. View "USA v Rose" on Justia Law

RINNAI AMERICA CORP. V. SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

2026-07-02T08:31:35-08:00

A regional air quality agency responsible for the South Coast Air Basin, an area with some of the nation’s worst ozone pollution, amended its regulations to phase in zero nitrous oxide (NOx) emissions standards for certain appliances, such as water heaters, boilers, and process heaters. The agency determined that only widespread adoption of zero emissions standards across stationary sources could bring the region into compliance with federal ozone requirements imposed by the Clean Air Act (CAA). The rule’s implementation was staggered over several years, with the goal of achieving significant NOx reductions. Plaintiffs, including manufacturers and industry groups, challenged this rule, arguing that it was preempted by the federal Energy Policy and Conservation Act (EPCA), which sets national energy efficiency standards for consumer products. The United States District Court for the Central District of California considered the plaintiffs’ facial preemption challenge. The district court granted summary judgment to the air quality agency, finding that the rule did not concern the “energy use” of appliances as defined by EPCA, but instead addressed air pollution and health risks. The court concluded that the rule did not trigger EPCA’s preemption provisions. On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the case de novo. The Ninth Circuit affirmed the district court’s decision, holding that EPCA does not preempt the agency’s amended rule because nothing in EPCA’s text, structure, or history indicates Congressional intent to interfere with state and local efforts to achieve federal air quality standards under the CAA. The court also found that plaintiffs had not shown any EPCA language preempting CAA-based emissions regulations, and distinguished its earlier decision in California Restaurant Association v. City of Berkeley as inapplicable here. Finally, the court held that the facial challenge failed because the rule applies to some products not covered by EPCA, and thus was not unconstitutional in every application. The judgment for the agency was affirmed. View "RINNAI AMERICA CORP. V. SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT" on Justia Law

McInnis v. Bolin

2026-07-02T07:30:58-08:00

Jquan Leearthur McInnis, then a juvenile, shot and killed Gustav Christianson and an infant, J.R., by firing seven shots into a car in downtown Minneapolis. Evidence gathered by investigators included statements made by McInnis to associates and forensic evidence showing the sequence of shots. After being apprehended and advised of his Miranda rights, McInnis initially denied involvement but eventually confessed to the shootings after invoking his right to remain silent. He maintained that he did not intend to kill Christianson and was unaware of the infant’s presence. The case was tried in a Minnesota state court, where McInnis moved to suppress his confession, arguing it was obtained after he had invoked his Fifth Amendment rights. The trial court denied the motion, concluding that McInnis had not unequivocally invoked his right to remain silent. The trial proceeded on stipulated evidence, including the confession, and McInnis was convicted of two counts of first-degree murder and sentenced to two consecutive life terms with the possibility of parole. On appeal, the Minnesota Supreme Court agreed that the confession should have been suppressed but determined that its admission was harmless beyond a reasonable doubt, given the other overwhelming evidence of guilt. McInnis then sought a writ of habeas corpus from the United States District Court for the District of Minnesota, arguing that the Minnesota Supreme Court unreasonably applied federal law on harmless error. The district court denied relief but granted a certificate of appealability on the harmless error issue. On appeal, the United States Court of Appeals for the Eighth Circuit held that McInnis failed to show that the Minnesota Supreme Court’s harmless error determination was contrary to or an unreasonable application of clearly established federal law. The Eighth Circuit affirmed the district court’s denial of the habeas petition. View "McInnis v. Bolin" on Justia Law

McCaffrey v. Anderson

2026-07-02T06:42:12-08:00

Derek Anderson sought to incorporate a new town called West Hills in Summit County, Utah, along Highway 248. To comply with Utah’s municipal incorporation code, Anderson followed a process involving proposals, notices, hearings, and multiple boundary adjustments. The incorporation procedure allows certain landowners, defined as "specified landowners" based on property size or value, to request exclusion from the proposed municipality during two specific windows: after initial notice and after the first public hearing. Anderson modified the proposed boundaries several times, and in doing so added some landowners after both opt-out windows had closed, depriving them of the statutory opportunity to request exclusion. Summit County’s Third District Court reviewed the case after these landowners, including Jennifer McCaffrey and others, sued to stop the incorporation election. They argued that the incorporation code violated the Uniform Operation of Laws Clause of the Utah Constitution by allowing some landowners to request exclusion while denying this right to others who were added later. The district court applied rational basis review and found that the code’s classification failed this standard, reasoning that the timing for boundary locking was arbitrary and allowed sponsors to manipulate which landowners had exclusion rights. The court granted summary judgment to the landowners and enjoined the Lieutenant Governor from certifying the incorporation petition. The Supreme Court of the State of Utah reviewed the appeal. The Court held that, under rational basis review, the legislative scheme for exclusion rights was constitutional. It found that the statutory cutoff for opt-outs was a reasonable means to ensure finality and prevent endless boundary modifications, and that the classification had a rational connection to legitimate legislative objectives. The Court reversed the district court’s ruling and reinstated the Lieutenant Governor’s certification of the incorporation petition for the 2026 general election. View "McCaffrey v. Anderson" on Justia Law

D.W. v. United States

2026-07-02T06:33:34-08:00

One afternoon, a group of seven individuals, including the appellant, were standing near a breezeway at an apartment complex in Southeast Washington, D.C. Police officers, who were on routine patrol and not responding to any specific report of criminal activity, stopped near the complex and began approaching the group from about 100 feet away. Upon noticing the officers, the appellant and another man immediately fled at a full sprint through the complex. The officers pursued the appellant, who led them on a chase over fences and through yards, ultimately dropping a firearm as he was apprehended. The police recovered the weapon, and the appellant was charged with several firearm-related offenses. The case was first reviewed by the Superior Court of the District of Columbia. At a suppression hearing, the appellant moved to exclude the gun, arguing the officers lacked reasonable suspicion for his seizure. The trial court found that the seizure occurred when an officer grabbed the appellant’s leg as he attempted to scale a second fence. The court concluded that the officers had reasonable articulable suspicion to justify the seizure, relying on the appellant’s immediate flight upon seeing police, the extended and desperate nature of the chase, and testimony that the apartment complex was a high-crime area. The appellant was convicted at a stipulated trial after the suppression motion was denied. On appeal, a panel of the District of Columbia Court of Appeals vacated the convictions, finding an absence of reasonable suspicion. The court then granted en banc rehearing and vacated the panel’s opinion. The en banc District of Columbia Court of Appeals held that, under the totality of the circumstances, the officers had reasonable articulable suspicion to seize the appellant, primarily due to his unprovoked flight upon seeing police, the particularized testimony about crime at the complex, and the desperation evident in his flight. The court affirmed the convictions. View "D.W. v. United States" on Justia Law

Reed v. Muoio

2026-07-02T06:08:49-08:00

The Legislature enacted a statute in 2014 mandating that police vehicles acquired after March 1, 2015 and used primarily for traffic stops be equipped with mobile video recording systems (MVRS). At the same time, the Legislature increased the surcharge for driving while intoxicated (DWI) offenses by $25, directing the additional funds to cover the cost of MVRS installation. In 2015, Deptford Township challenged the MVRS mandate before the Council on Local Mandates, arguing that the surcharge was insufficient to cover the costs and that the statute constituted an unfunded mandate. Deptford did not challenge the legality of the surcharge itself. The Council determined that the MVRS mandate was an unfunded mandate because there was a significant disparity between the anticipated costs and the funds generated by the surcharge. The Council declared the MVRS statute unconstitutional and also found the $25 surcharge provision “nugatory,” or without legal effect. In 2021, class actions were filed by individuals subjected to the surcharge, alleging its continued collection was unconstitutional. The complaints were consolidated in the Superior Court, which dismissed them. The Appellate Division affirmed, finding that the Council had exceeded its authority by invalidating the surcharge, because it was a funding mechanism and not an unfunded mandate. The Supreme Court of New Jersey reviewed whether judicial review of the Council’s decisions was available and whether the Council had authority to invalidate the surcharge. The Court held that the Council is subject to judicial review when it acts beyond its constitutionally defined authority. It found that the Council’s power ended after it determined the MVRS mandate was unfunded, and it was not authorized to invalidate the $25 surcharge. The Court affirmed the Appellate Division’s judgment. View "Reed v. Muoio" on Justia Law

In re: Busby v. City of Tuskegee

2026-07-02T05:30:44-08:00

A group of individuals who had received traffic citations under a local ordinance enacted by the City of Tuskegee permitting automated photographic enforcement of traffic laws brought suit against the City, certain city officials, and JENOPTIK, the company involved in the installation and operation of the enforcement devices. The plaintiffs challenged the validity of the ordinance, raised constitutional concerns, and sought declaratory and injunctive relief as well as damages, including tort claims for negligence, invasion of privacy, and fraud. The City later enacted resolutions cancelling outstanding citations, refunding fines, and ultimately suspending enforcement of the ordinance. The case was initially filed in the Macon Circuit Court. The City and JENOPTIK moved to dismiss, arguing lack of a justiciable controversy, mootness, lack of standing, and other grounds, including lack of personal jurisdiction over JENOPTIK. The trial court denied these motions to dismiss, treating them as motions under Rule 12 and excluding extraneous materials, but did not provide detailed reasoning. On review, the Supreme Court of Alabama held that because the plaintiffs either paid the fines or failed to contest the citations under the administrative procedures provided in the ordinance, and because the City subsequently nullified the citations and provided for reimbursement, their claims challenging the legality of the ordinance were moot. The Court directed the trial court to dismiss those claims. However, the Supreme Court denied the petitions insofar as they sought dismissal of the plaintiffs’ tort claims, holding that the City and JENOPTIK did not demonstrate a clear right to mandamus relief on those claims at this stage. The Court likewise declined to dismiss the tort claims against JENOPTIK for lack of personal jurisdiction based on the current record. View "In re: Busby v. City of Tuskegee" on Justia Law

Spencer v. Vapor Technology Association

2026-07-02T05:30:43-08:00

The plaintiffs, a trade association and a vape shop operator, filed suit challenging an Alabama law regulating electronic nicotine delivery systems (ENDS), which includes e-cigarettes and vapes. The law, effective June 1, 2025, established strict requirements for the sale of ENDS, including a product directory listing only approved products, mandates that products be manufactured in the United States or have federal FDA marketing authorization, and imposed significant penalties for violations. The plaintiffs claimed these regulations would cause them immediate and irreparable harm, including loss of profits, employees, and potential closure of their businesses due to prohibitions and penalties outlined in the law. The Montgomery Circuit Court initially granted a temporary restraining order (TRO) in favor of the plaintiffs, finding they would suffer irreparable harm and had no adequate remedy at law because the State defendants were protected by sovereign immunity. After a hearing, the court denied the plaintiffs’ motion for a preliminary injunction but extended the TRO pending appeal. The State defendants appealed, challenging the plaintiffs’ standing, while the plaintiffs cross-appealed the denial of the preliminary injunction. The Supreme Court of Alabama reviewed both appeals. It held that the plaintiffs had standing, as they faced concrete, particularized, and actual harm directly resulting from the enforcement of the Alabama law. However, the Court found the plaintiffs did not demonstrate a reasonable likelihood of success on the merits of their constitutional claims, including implied preemption and dormant Commerce Clause challenges. The Court determined that the Alabama Act was not preempted by federal law and served legitimate state interests related to health and safety. Therefore, the Supreme Court of Alabama affirmed the trial court's denial of the preliminary injunction. View "Spencer v. Vapor Technology Association" on Justia Law

MONTGOMERY v. STATE OF TEXAS

2026-07-02T04:46:56-08:00

The appellant was charged in two separate cases with theft from a person and evading arrest with a vehicle. He pled guilty to both charges and received deferred adjudication for ten years as part of a plea agreement, which also resulted in the State not pursuing habitual-offender enhancement. After being arrested for additional offenses, the State filed a petition to proceed to adjudication, alleging violations of the appellant’s community supervision, which was later amended to include further infractions. The appellant objected to the hearing being conducted virtually, citing concerns under the Due Process and Equal Protection Clauses as well as the Confrontation Clause. The trial court in Tarrant County held the hearing via Zoom, overruled the appellant’s objections, and adjudicated him guilty of both offenses, revoking his probation. The appellant filed motions for a new trial and notices of appeal, which were denied. On appeal to the Second Court of Appeals, he argued that the virtual hearing violated his rights under the Confrontation Clause and the Fourteenth Amendment. The appellate court found that the virtual hearing did not significantly impair his participation and concluded there was no violation of Due Process. It further held that the Confrontation Clause did not apply to revocation proceedings, reasoning that these are not criminal prosecutions as contemplated by the Sixth Amendment, and affirmed the trial court’s rulings. Upon review, the Court of Criminal Appeals of Texas considered only the Confrontation Clause issue. The court held that the Confrontation Clause does not apply to hearings on motions to enter adjudication of guilt and probation revocation, as such proceedings are not criminal prosecutions under the Sixth Amendment. Accordingly, the court affirmed the judgment of the Second Court of Appeals. View "MONTGOMERY v. STATE OF TEXAS" on Justia Law

Calvary Chapel Belfast v. University of Maine System

2026-07-01T15:00:03-08:00

A religious nonprofit organization sought to purchase a former university campus property after being selected as the winning bidder in a competitive process conducted by a state university system. Following the public announcement of the award, there was significant public opposition to the sale, particularly due to the religious nature of the winning bidder. Two unsuccessful bidders filed administrative protests, raising both procedural and substantive objections, including criticism of the university's decision to sell to a religious organization. The university's designated official initially denied these protests, but upon further internal review, a higher-level administrator determined that a flaw in the bid evaluation process—specifically, the failure to consider cost-saving proposals for existing infrastructure—warranted rescinding the award and restarting the process. In the new round, the property was awarded to a different bidder who scored higher under revised criteria. The original winning bidder, the religious organization, challenged the university's decision in the United States District Court for the District of Maine, alleging violations of the Equal Protection and Free Exercise Clauses of the U.S. Constitution. The district court denied the plaintiff’s motions for a temporary restraining order and a preliminary injunction, finding that the plaintiff failed to show a likelihood of success on the merits of either claim. The court credited testimony that the university’s decision was motivated by cost-saving considerations rather than religious bias, and found no clear evidence of procedural irregularity or pretext. On appeal, the United States Court of Appeals for the First Circuit reviewed the denial of the preliminary injunction for abuse of discretion. The Court affirmed the district court’s decision, holding that the lower court applied the correct legal standards and did not clearly err in its factual findings. The Court concluded that the plaintiff failed to demonstrate a likelihood of success on the merits of its constitutional claims. View "Calvary Chapel Belfast v. University of Maine System" on Justia Law

United States v. Shelton

2026-07-01T13:00:39-08:00

A Michigan physician was charged with twenty-one counts of unlawfully distributing controlled substances to his patients. Over several years, he prescribed large quantities of medications to individuals who exhibited signs of drug-seeking behavior, failed drug screens, engaged in doctor shopping, and requested specific highly abused drugs. The physician often ignored red flags such as patients’ substance abuse histories and failed to perform required physical examinations. His practices led to at least one patient’s overdose death. Evidence at trial included expert testimony that his prescribing was inappropriate and outside the usual course of professional practice. The case was first tried in the United States District Court for the Eastern District of Michigan, but the initial trial ended in a mistrial. A retrial was delayed and declared a mistrial due to the COVID-19 pandemic. The third trial proceeded in March 2023, with the district court requiring witnesses to wear masks while testifying. After a 13-day trial, a jury convicted the physician on all counts. Post-trial motions for acquittal or a new trial were denied, and the physician was sentenced to twenty years on the count involving death, with concurrent sentences on the remaining counts. He appealed, challenging the sufficiency of the evidence, the authority of the Attorney General to regulate prescribing, the jury instructions, and the mask mandate’s constitutionality. The United States Court of Appeals for the Sixth Circuit reviewed the appeal. It held that sufficient evidence supported the convictions, the jury instructions accurately reflected the law and were not misleading or confusing, and the district court’s mask mandate did not constitute reversible error under the Confrontation Clause. The court found no plain error in the regulatory and constitutional challenges and affirmed the district court’s judgment in its entirety. View "United States v. Shelton" on Justia Law

Hernandez-Castrodad v. Steidel-Figueroa

2026-07-01T13:00:03-08:00

Plaintiffs had their property taken by the Commonwealth of Puerto Rico through eminent domain. They received over two million dollars in compensation, including interest accrued up to the time of payment. However, they alleged a second violation occurred when the court-administered disbursement process failed to notify them of further accrued interest and deducted a 15% administrative fee from that interest. They challenged these practices as unconstitutional takings and violations of due process, seeking declaratory and equitable relief against the Administrator of the Administration of Tribunals. The United States District Court for the District of Puerto Rico initially dismissed most claims, finding plaintiffs lacked standing because they had not alleged an attempt to withdraw the accrued interest, making their injury speculative. After reconsideration, the court revived the claim challenging the deduction of administrative fees, but limited relief to prospective injunctive relief due to Eleventh Amendment constraints. The court ultimately granted summary judgment to the defendant, finding the administrative fee reasonable and not an unconstitutional taking, as plaintiffs provided no evidence to the contrary. The United States Court of Appeals for the First Circuit reviewed the case and confronted jurisdictional issues arising from Puerto Rico’s Title III bankruptcy under PROMESA. The court held that the administrative fee claim was void for violating the automatic stay provisions, as it amounted to a demand for property of the debtor (the Commonwealth), and dismissed that portion of the appeal. Regarding the interest claim, the court affirmed the district court’s dismissal, ruling plaintiffs lacked standing because they failed to allege they sought disbursement or challenged existing procedures. The First Circuit thus dismissed the appeal from summary judgment and affirmed the district court's dismissal. View "Hernandez-Castrodad v. Steidel-Figueroa" on Justia Law

People v. Castro

2026-07-01T12:03:04-08:00

The case concerns a late-night car crash in Bloomington, San Bernardino County, where Steven Richard Castro collided with a parked vehicle, injuring its occupant. Neighbors restrained Castro, who tried to flee, and emergency personnel transported him to the hospital due to his combative behavior. CHP Officer Pope, stationed at the hospital on another matter, was notified about Castro's arrival and subsequently observed Castro sedated and unresponsive in the ER. Pope noted the smell of alcohol and, after gathering information from witnesses and the victim, arrested Castro on suspicion of DUI causing injury. Without seeking a warrant, Pope ordered a blood draw, relying on implied consent law. The blood test showed a high BAC. In the San Bernardino County Superior Court, Castro moved to suppress the blood test results, arguing that a warrant should have been obtained. The magistrate denied the motion, citing exigent circumstances per Mitchell v. Wisconsin, reasoning that Officer Pope’s time in the hospital justified the warrantless blood draw. Castro renewed his suppression request in a pretrial motion, but the court again found the officers’ actions constitutional based on the totality of circumstances and Castro’s unconsciousness, leading Castro to enter a no contest plea. The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the record did not support a finding of exigency sufficient to excuse the failure to obtain a warrant for the blood draw. The court emphasized that Mitchell v. Wisconsin does not create a categorical rule for unconscious DUI suspects and, following its reasoning in People v. Alvarez, found no evidence that obtaining a warrant would have interfered with other pressing duties. The judgment was reversed, and the matter remanded with directions to grant the suppression motion and permit Castro to withdraw his plea. View "People v. Castro" on Justia Law

CLARK v. THE STATE

2026-07-01T10:30:53-08:00

A man was convicted for malice murder and related offenses stemming from a murder-for-hire scheme in 2000, where the victim was killed in her Georgia apartment. The prosecution argued that the murder was orchestrated by the victim’s father-in-law, who opposed her marriage, and that the appellant was the hired killer, with testimony from accomplices and witnesses supporting this theory. The appellant's trial was marked by difficulties in securing expert witnesses and conducting mitigation investigations due to funding shortfalls in Georgia’s indigent defense system, which hampered his defense’s ability to prepare. Eventually, he was convicted on several counts and initially sentenced to death, with subsequent modifications after further proceedings. After conviction, the appellant’s attorneys from the Capitol Defender’s Office filed a motion for a new trial, later amended and supplemented by other attorneys from the same office. The Superior Court of Fulton County partially granted the motion, ordering a new trial solely on the issue of “mental retardation” for sentencing purposes, due to the late development of evidence related to this issue, which was attributed to a breakdown in indigent defense funding. Later, a new judge re-sentenced the appellant to life without parole in accordance with that order. Other grounds for a new trial were denied, and the appellant retained private counsel to pursue his appeal. The Supreme Court of Georgia reviewed the case and determined that, because this appeal was the appellant’s first opportunity to raise ineffective assistance of counsel claims (having been continuously represented by the same public defender’s office), the record was insufficiently developed on this issue. The Court vacated the trial court’s judgment in part and remanded the case for an evidentiary hearing on the ineffective assistance claims. Other claims regarding denial of a continuance and competency to stand trial were rejected, as the appellant failed to show harm or preserve those issues. Judgment was affirmed in part and vacated and remanded in part. View "CLARK v. THE STATE" on Justia Law

MILLER v. THE STATE

2026-07-01T10:13:05-08:00

The case involves a defendant who was convicted of malice murder and other related crimes following the fatal shooting of a convenience store owner late at night. Surveillance footage captured the movements of three assailants before and after the shooting, and law enforcement linked the defendant to the crime through evidence including a matching vehicle, clothing, cell phone records, and an anonymous tip. During the investigation, police obtained multiple search warrants that led to the seizure of various pieces of evidence, such as cell phones and ammunition. The defendant challenged the legitimacy of these warrants, arguing that the affidavits supporting them included material misrepresentations and omissions by police. After being indicted and tried in the Superior Court of DeKalb County, the defendant was convicted on all counts and sentenced to life imprisonment without parole for malice murder, with additional consecutive sentences for other offenses. The trial court merged some counts and vacated others as required by law. The defendant moved for a new trial, which was denied after a hearing. He then appealed, arguing that the trial court erred in denying his motion to suppress evidence due to alleged false statements in the search warrant affidavits and that his right to confront witnesses was violated by the admission of substitute expert testimony. The Supreme Court of Georgia reviewed the case. The court held that the trial court had not properly applied the standard from Franks v. Delaware for assessing whether false statements in warrant affidavits were made knowingly, intentionally, or with reckless disregard for the truth. The Supreme Court of Georgia vacated the trial court’s judgment on the motion to suppress and remanded the case for further proceedings consistent with the proper Franks analysis, leaving other issues unresolved pending that review. View "MILLER v. THE STATE" on Justia Law

Novartis Pharmaceuticals Corp. v. Hanaway

2026-07-01T07:31:06-08:00

A pharmaceutical manufacturer participating in the federal 340B Drug Pricing Program challenged a Missouri law that prohibits manufacturers from restricting the delivery of discounted 340B drugs to contract pharmacies associated with covered entities. The manufacturer argued that its policy of limiting deliveries to only one contract pharmacy conflicted with Missouri’s statute, which requires delivery to all contract pharmacies designated by covered entities. The manufacturer sought declaratory and injunctive relief, claiming the Missouri statute violated the dormant Commerce Clause and was preempted by federal law. The United States District Court for the Western District of Missouri granted a motion to dismiss the manufacturer’s preemption claims, finding Missouri’s statute did not conflict with federal patent or drug exclusivity laws or the 340B Program, and that Eighth Circuit precedent foreclosed the field preemption argument. The court denied the motion to dismiss the dormant Commerce Clause claim, but ultimately denied the manufacturer’s motion for a preliminary injunction, concluding the manufacturer was unlikely to succeed on the merits of its claims, had not shown irreparable harm, and that the balance of equities and public interest weighed against preliminary relief. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of preliminary injunction under the abuse of discretion standard. The appellate court affirmed the district court’s decision, holding that the Missouri statute regulates only in-state delivery of 340B drugs and does not impermissibly control extraterritorial commerce, discriminate against interstate commerce, or impose excessive burdens in relation to local benefits. The court also found the manufacturer’s preemption claims foreclosed by Eighth Circuit precedent and concluded the statute is neither field nor conflict preempted. The district court’s denial of preliminary injunctive relief was affirmed. View "Novartis Pharmaceuticals Corp. v. Hanaway" on Justia Law

Texas Tobacco Barn v. HHS

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

Texas Tobacco Barn operated a laboratory and retail shop in Lubbock, Texas, manufacturing and selling e-liquids and vape products. After applying for authorization to sell over 2,200 vape products, including Barn Brewed Beetle Juice e-liquids, the FDA denied approval and warned that these products were considered “adulterated” and “misbranded.” Despite assurances from Texas Tobacco Barn that it would cease sales, a subsequent FDA inspection revealed continued sale of unauthorized products. The FDA initiated proceedings seeking a civil penalty of $19,192 for violations. The enforcement action began with an administrative hearing before an HHS administrative law judge (ALJ), who reviewed evidence including inspection photos and testimony from an FDA inspector. Texas Tobacco Barn admitted that the e-liquids lacked FDA authorization but disputed the inspector’s findings and challenged the FDA’s regulatory authority. The ALJ concluded that the FDA proved its case by a preponderance of the evidence and imposed the civil penalty. On appeal, the HHS Departmental Appeals Board affirmed the ALJ’s ruling, agreeing the ALJ lacked jurisdiction to address constitutional challenges but offering advisory comments on those defenses. Reviewing the agency’s final decision, the United States Court of Appeals for the Fifth Circuit considered Texas Tobacco Barn’s statutory and constitutional arguments. The court rejected the nondelegation challenge, citing its own precedent and Supreme Court guidance clarifying FDA’s explicit authority to regulate vape products. However, the Fifth Circuit held that the administrative process violated Texas Tobacco Barn’s Seventh Amendment right to a jury trial. The court determined that civil penalties for FDCA violations are legal in nature and do not fall under the public-rights exception that would permit agency adjudication without a jury. As a result, the Fifth Circuit granted the petition and vacated the agency’s decision. View "Texas Tobacco Barn v. HHS" on Justia Law

State v. Hagberg

2026-06-30T13:38:34-08:00

The defendant, a seventy-year-old man with a long history of alcohol use, was stopped by law enforcement after driving erratically and making multiple traffic violations. He was observed to be impaired, failed a field sobriety test, and later refused breath and blood tests, leading to a warrant for a blood draw that revealed a blood alcohol content over three times the legal limit. Investigation revealed he was driving with a suspended license and had three prior DUI convictions. He was charged with felony DUI (fourth or subsequent offense) and driving while suspended, but the latter charge was dismissed in exchange for his guilty plea to the DUI charge. The Montana Sixteenth Judicial District Court sentenced him to thirteen months with the Department of Corrections, recommended placement in an alcohol treatment program, and imposed a consecutive four-year suspended sentence. The court also imposed the statutory minimum fine of $5,000 but suspended half of it due to the defendant’s financial circumstances. The defendant appealed the imposition of the fine, arguing that the statute mandating the fine was unconstitutional based on recent case law. He maintained that the fine should not have been imposed without proper consideration of his ability to pay. The Supreme Court of the State of Montana held that the defendant did not waive his right to appellate review of the fine by agreeing to it in the plea agreement, as subsequent case law developments questioned the constitutionality of the statute. The Court reaffirmed that the sentencing court must impose the mandatory fine under the statute, then determine the defendant’s ability to pay, and may suspend any portion of the fine accordingly. The Supreme Court affirmed the imposition of the $5,000 fine but vacated the portion of the judgment relating to the fine and remanded to the District Court for explicit findings on the defendant’s ability to pay before determining how much of the fine should be suspended. View "State v. Hagberg" on Justia Law

State v. Jones

2026-06-30T13:35:03-08:00

Police responded to a domestic violence call involving the defendant after his girlfriend reported he had a firearm. Officers later found a purple handgun along the route the defendant had taken, and DNA evidence linked the gun to him. He was charged with felony domestic violence, misdemeanor unlawful carrying of a handgun, and felony unlawful carrying of a handgun by a felon with a prior conviction within the past fifteen years. The charging documents listed his two previous Texas felony convictions—one for Felon in Possession of a Weapon in 2014 and another for Aggravated Assault–Family Member in 2017—as the basis for the firearm charges. The Tippecanoe Superior Court dismissed both handgun-related charges, finding that the charging information was not sufficiently specific, did not constitute an offense, and that the statute used to enhance his charge was unconstitutionally vague under both federal and state constitutions. The trial court referenced an unrelated but identical dismissal for another defendant and issued a final judgment, allowing the State to appeal directly. The Indiana Supreme Court reviewed the case under its mandatory jurisdiction following a trial court finding of unconstitutionality. The court held that the charging information for both the misdemeanor and felony handgun counts was sufficiently certain and constituted an offense under Indiana law, as it included the necessary elements and identified the prior convictions. The court further held that the trial court had misapplied the relevant statute and that the enhancement to a felony did not require the prior out-of-state conviction to be substantially similar to an Indiana offense, only that it was a felony within fifteen years. The Indiana Supreme Court reversed the trial court’s dismissal of both handgun charges and remanded for further proceedings. View "State v. Jones" on Justia Law

Bender v. Village of Mariemont

2026-06-30T12:30:38-08:00

A woman was the primary caregiver for her friend, residing in her friend’s condominium for several years. After the friend passed away, ownership of the condo transferred to a living trust, and the caregiver became trustee. She continued living in the condo for a month to recover from illness and remove her belongings. The friend’s nephew contacted local police, claiming the right to evict her, and presented officers with a superseded will listing him as a beneficiary but not mentioning the condo. The officers accompanied the nephew to the condo, told the caregiver she had ten minutes to leave, threatened her with arrest, pushed her out, and took her key. The United States District Court for the Southern District of Ohio reviewed the case after the caregiver sued various parties, alleging Fourth Amendment violations. The court granted summary judgment to some defendants but denied it for the officers, reasoning that the caregiver, as trustee, held a possessory interest in the condo, and the officers’ actions constituted active participation in an eviction without proper legal authority. The court relied on Sixth Circuit precedent to find the seizure unreasonable and the right clearly established. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that the caregiver had a possessory interest in the condo at the time of the eviction, the officers actively participated in the eviction, and their conduct was unreasonable under the Fourth Amendment because there was no court order or exigent circumstances justifying the seizure. The court further held that existing precedent clearly established the unlawfulness of the officers’ actions. The Sixth Circuit affirmed the district court’s denial of summary judgment, leaving the officers subject to further proceedings. View "Bender v. Village of Mariemont" on Justia Law

Lopez Collazo v. Ruiz-Feliciano

2026-06-30T12:00:03-08:00

After the 2020 mayoral election in Maricao, Puerto Rico, the Popular Democratic Party candidate, Wilfredo Ruiz-Feliciano, assumed office, replacing the New Progressive Party incumbent. Odette López Collazo, a longstanding NPP member who had served as Internal Auditor since 1994, was not reappointed by the new mayor. López Collazo alleged that her non-reappointment was due solely to her political affiliation and constituted political discrimination in violation of her First and Fourteenth Amendment rights. She also asserted related claims against other municipal officials regarding the failure to pay out her accrued leave, but only the claim against Ruiz-Feliciano for political discrimination remained at issue in this appeal. The United States District Court for the District of Puerto Rico granted summary judgment in favor of Ruiz-Feliciano. The court concluded that First Amendment protections against political discrimination did not apply to a decision not to hire or reappoint, and further reasoned that because the Internal Auditor position was a “trust” position under Puerto Rico law, the mayor could hire and fire at will, including for political reasons. López Collazo moved for reconsideration, which was denied, and then sought partial final judgment under Rule 54(b) to appeal. After resolving procedural questions regarding finality, all claims but the political discrimination claim against Ruiz-Feliciano were dismissed with prejudice, and the appeal proceeded. The United States Court of Appeals for the First Circuit reviewed the district court’s grant of summary judgment de novo. The Court of Appeals held that First Amendment protections do apply to a failure to hire or reappoint a public employee, and that legislative classification of a position as a “trust” position is not dispositive in determining whether political affiliation is an appropriate requirement. The appellate court vacated the district court’s summary judgment and remanded for further proceedings. View "Lopez Collazo v. Ruiz-Feliciano" on Justia Law

STATE v. CULLINS

2026-06-30T09:04:22-08:00

Deanthony Cullins was indicted on multiple counts, including malice murder and aggravated assault, stemming from a June 2022 incident in which he was accused of shooting at a vehicle, resulting in the death of Dy’Sheae Hall. Cullins claimed self-defense. In the lead-up to trial, the State sought a continuance days before the scheduled date, citing late receipt of deposition transcripts, but the trial court denied the request. The State also filed an untimely motion to admit other acts evidence, which was denied. During trial, the prosecutor questioned a detective about Cullins’s refusal to make a statement to police, prompting the defense to object on grounds that the questioning improperly commented on Cullins’s right to remain silent. The defense moved for a mistrial, suggesting the prosecutor’s conduct was intentional to provoke a mistrial, and the trial court granted the mistrial. After the mistrial, Cullins filed a plea in bar, arguing that retrial should be barred under the Double Jeopardy Clause because the State had intentionally provoked the mistrial. The Superior Court of DeKalb County held a hearing and found that the prosecutor’s actions were deliberate, noting the State’s lack of readiness for trial, the benefit to the State of a second chance, and the seasoned experience of those involved. The trial court concluded that the State had goaded the defense into seeking a mistrial. On appeal, the Supreme Court of Georgia reviewed whether the trial court clearly erred in finding that the State had intentionally provoked a mistrial. The Supreme Court determined there was evidence to support the trial court’s findings and that they were not clearly erroneous. The Court affirmed the grant of the plea in bar, holding that retrial was barred because the prosecutor’s conduct was intended to provoke a mistrial for a more favorable opportunity to convict. View "STATE v. CULLINS" on Justia Law

Utah Political Watch v. Musselman

2026-06-30T08:32:44-08:00

A journalist with over twenty-five years of experience covering the Utah Legislature previously received media credentials while working for established news organizations. After founding an independent news outlet, he applied for a media credential under a new policy that categorically excluded bloggers, independent media, and freelance journalists from receiving credentials. This exclusion prevented him from accessing restricted areas and events within the Capitol that were available only to credentialed journalists, limiting his ability to gather news directly from legislative press conferences and availabilities. The plaintiff filed suit in the United States District Court for the District of Utah against legislative officials, alleging that the credentialing policy was unconstitutional as both facial and as-applied viewpoint discrimination under the First Amendment, along with claims of retaliation, prior restraint, and vagueness. The district court dismissed all claims, including denying a preliminary injunction as moot. The court reasoned, in part, that there was no protected speech implicated by the policy and that the plaintiff’s continued reporting without a credential undercut the retaliation claim. On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the district court erred in dismissing both the facial and as-applied viewpoint discrimination claims. The appellate court found that the plaintiff plausibly alleged denial of access based on his viewpoint and that the exclusion from a government-created forum for journalists implicated protected speech. The court remanded those claims for further proceedings. The Tenth Circuit affirmed the district court’s dismissal of the retaliation, prior restraint, and vagueness claims, finding no plausible allegation of chilling effect and determining the policy did not regulate expression sufficiently to support a prior restraint or vagueness challenge. View "Utah Political Watch v. Musselman" on Justia Law

Trump v. Barbara

2026-06-30T07:15:10-08:00

Several parents, some acting on behalf of their children, challenged a presidential executive order issued in January 2025. The order declared that children born in the United States to parents who were unlawfully or temporarily present would not be considered “subject to the jurisdiction” of the United States, and therefore would not be entitled to citizenship under the Fourteenth Amendment or the Immigration and Nationality Act. The plaintiffs argued that this order violated both the Constitution and the INA, as it denied citizenship to children based solely on the immigration status of their parents at the time of birth. The United States District Court for the District of New Hampshire reviewed the case and agreed with the plaintiffs. It provisionally certified a nationwide class of children affected by the order and issued a preliminary injunction, blocking enforcement of the executive order. The government appealed, and the Supreme Court of the United States granted certiorari before judgment from the United States Court of Appeals for the First Circuit. The Supreme Court held that children born in the United States to parents who are unlawfully or temporarily present are “subject to the jurisdiction” of the United States, and are entitled to citizenship at birth under the Fourteenth Amendment’s Citizenship Clause. The Court based its holding on the historical understanding of citizenship rooted in the English common law, the repudiation of Dred Scott v. Sandford, and the precedent established in United States v. Wong Kim Ark. The Court affirmed the judgment of the District Court, upholding birthright citizenship for these children. View "Trump v. Barbara" on Justia Law

National Republican Senatorial Committee v. Federal Election Commission

2026-06-30T07:15:07-08:00

A group of candidates and political party committees, including then-Senate candidate JD Vance and various Republican campaign committees, challenged federal limits on coordinated campaign expenditures by political parties under the Federal Election Campaign Act (FECA). These limits restrict the amount a party can spend in direct coordination with a candidate’s campaign. Plaintiffs argued that the restrictions violate the First Amendment, especially given modern developments in campaign finance law and enforcement tools such as earmarking and disclosure requirements. JD Vance maintained standing to challenge the law, as he had an active Statement of Candidacy and a campaign committee, despite later becoming Vice President. The case was first reviewed by the en banc United States Court of Appeals for the Sixth Circuit, which upheld FECA’s coordinated-expenditure limits. The Sixth Circuit relied primarily on the Supreme Court’s 2001 precedent, Federal Election Commission v. Colorado Republican Federal Campaign Committee (Colorado II), which had previously sustained these limits against First Amendment challenges. However, several Sixth Circuit judges questioned whether Colorado II remained good law in light of more recent Supreme Court decisions, including McCutcheon v. Federal Election Commission and Federal Election Commission v. Ted Cruz for Senate. The Supreme Court of the United States granted certiorari and ultimately reversed the Sixth Circuit. The Court held that FECA’s limits on political-party coordinated expenditures violate the First Amendment. Applying rigorous scrutiny, the Court determined that the limits are not necessary, narrowly tailored, or proportionate to the government’s interest in preventing circumvention of candidate contribution limits, especially given the effectiveness of existing earmarking rules and disclosure laws. The Court explicitly overruled Colorado II, concluding that subsequent precedents have rendered it obsolete. The judgment of the Sixth Circuit was reversed and the case remanded for further proceedings. View "National Republican Senatorial Committee v. Federal Election Commission" on Justia Law

West Virginia v. B. P. J.

2026-06-30T07:15:06-08:00

A state law in West Virginia prohibited male students, as determined by biological sex, from participating on female sports teams. A student who is a biological male but identifies as female and has taken puberty blockers and hormones sought to participate on the girls’ cross-country and track-and-field teams and brought suit against West Virginia officials, alleging violations of Title IX and the Equal Protection Clause. Similarly, Idaho passed a law barring male students from female sports teams; a transgender woman who is a biological male but identifies as female and had taken hormones challenged Idaho’s law after trying out for collegiate women’s sports. Both states justified their laws by referencing inherent physical differences between the sexes and concerns for safety and competitive fairness in women’s sports. The United States District Court for the Southern District of West Virginia granted summary judgment for the state, finding no violation of Title IX or the Equal Protection Clause. The United States Court of Appeals for the Fourth Circuit reversed the ruling on the Title IX claim and remanded for further factual findings on the Equal Protection claim. Meanwhile, in Idaho, the United States District Court for the District of Idaho issued a preliminary injunction against enforcement of the statute; the United States Court of Appeals for the Ninth Circuit affirmed that decision, finding a likely violation of the Equal Protection Clause. The Supreme Court of the United States reversed both appellate court decisions. It held that Title IX permits schools to maintain separate men’s and women’s sports teams determined by biological sex and does not require exceptions for transgender athletes, regardless of puberty blockers or hormone use. The Court further held that the Equal Protection Clause does not bar states from limiting female sports teams to biological females, finding the sex-based classification substantially related to important government interests in safety and competitive fairness. The cases were remanded for further proceedings consistent with this opinion. View "West Virginia v. B. P. J." on Justia Law

LOVERIDGE v. US

2026-06-30T07:02:25-08:00

Three property owners in Oregon alleged that the federal government committed a taking of their property rights under the Fifth Amendment when the Surface Transportation Board (STB) issued a Notice of Interim Trail Use or Abandonment (NITU) involving a railroad corridor that crossed their properties. The corridor, previously used for freight trains by the Port of Tillamook Bay Railroad (POTB), was also leased to the Oregon Coast Scenic Railroad (OCSR), which operated a scenic passenger-excursion service both before and after the NITU was issued. After severe storm damage in 2007, POTB ceased freight operations, but OCSR continued using the corridor under its lease, which extended at least until 2026. The United States Court of Federal Claims previously found that a taking had occurred due to the issuance of the NITU. The case then proceeded to a valuation phase to determine just compensation. The Court of Federal Claims ruled that the property owners did not meet their burden to prove that the NITU caused a reduction in the fair market value of their land. The court found that the “before” condition for valuation properly included OCSR’s ongoing operations, and that the property owners failed to show an actual market value loss resulting from the NITU and the new trail-use easement. On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Court of Federal Claims’ judgment. The Federal Circuit held that the “before” condition for compensation must reflect the ongoing encumbrance of the scenic railroad’s operations, as the lease and use by OCSR would have existed regardless of the NITU. The court also concluded that the property owners had not proven with reasonable certainty any diminution in market value attributable to the NITU or the trail easement, and thus were not entitled to compensation. The judgment was affirmed. View "LOVERIDGE v. US " on Justia Law

Balink v. Nathan

2026-06-30T06:32:55-08:00

Several proposed initiatives regarding Colorado’s congressional redistricting were submitted for review by the state’s Title Board. Initiative #241 sought to replace the Colorado constitutional independent congressional redistricting commission with an identical commission established by statute, but made its effectiveness contingent on the passage of Initiative #242. Initiative #242, in turn, proposed to create a new temporary congressional district map for the 2028 and 2030 elections, and would only take effect if Initiative #241 was also adopted. Initiative #328, which was similar in structure to #242 but provided a different map, was likewise conditioned on the passage of Initiative #241. The Title Board, after initial hearings, determined by unanimous vote that both Initiative #241 and #242 each contained a single subject and set their respective titles. Motions for rehearing were denied by a two-to-one vote. Petitioner Robert Balink challenged these decisions before the Colorado Supreme Court, arguing that conditioning the effectiveness of each measure on the passage of the other violated the constitutional single subject rule. For Initiative #328, the Title Board declined to set a title, finding that it did not constitute a single subject because it was expressly contingent on the passage of a separate measure, and denied a rehearing. On review, the Supreme Court of Colorado held that an initiative violates the single subject requirement of article V, section 1(5.5) of the Colorado Constitution and section 1-40-106.5, C.R.S., when its effectiveness is conditioned on the passage of a separate initiative. The court reasoned that such interdependence creates multiple subjects, as each measure’s effect is not properly and necessarily connected to the other. As a result, the court reversed the Title Board’s decision to set titles for Initiatives #241 and #242 and affirmed the Board’s refusal to set a title for Initiative #328. View "Balink v. Nathan" on Justia Law

USA v. Banks

2026-06-30T06:31:05-08:00

A man was stopped by police late at night after an officer observed him allegedly fail to signal 100 feet before making a left turn, as required by Illinois law. After he parked in a strip mall lot, officers initiated a traffic stop and asked for his license and proof of insurance. The driver’s insurance card was expired, prompting him to exit the car to call someone for updated proof. While the stop was ongoing, another officer arrived with a drug-sniffing dog, which alerted to narcotics outside the vehicle. Police then searched the car and found a handgun hidden in the center console, but no drugs. The driver was arrested and charged with being a felon in possession of a firearm. The United States District Court for the Central District of Illinois denied the defendant’s motion to suppress the handgun, finding the officer’s testimony credible enough to establish reasonable suspicion for the traffic stop and that the stop was not impermissibly prolonged. It also found the dog’s alert provided probable cause to search the vehicle. At trial, the court denied the defendant’s motion for a directed verdict, ruling there was sufficient evidence for the jury to convict him. The defendant’s post-trial motion for a new trial was also denied. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the district court did not clearly err in crediting the officer’s testimony about the traffic violation, that the duration of the stop was not unreasonably extended, and that the dog’s alert provided probable cause for the search. The court also found that there was sufficient evidence to support the conviction for knowing possession of a firearm by a felon. The judgment was affirmed. View "USA v. Banks" on Justia Law

Miller v. McDonald

2026-06-30T06:30:03-08:00

In this case, several Amish parents, Amish community schools, and a representative of Amish schools in New York challenged New York's school immunization law, which, since 2019, no longer provides a religious exemption to the vaccination requirement for students attending public, private, or parochial schools. The plaintiffs allege that their faith prohibits vaccination, and their schools were fined for failing to comply with the immunization law. The plaintiffs asserted that the law violated their rights under the Free Exercise Clause of the First Amendment and their parental free-exercise rights recognized in Wisconsin v. Yoder. The United States District Court for the Western District of New York dismissed the plaintiffs’ complaint, finding they failed to plausibly allege a constitutional violation. The court relied on Second Circuit precedent holding that the repeal of religious exemptions for school vaccination laws, while maintaining medical exemptions, does not violate the Free Exercise Clause. The district court also denied the request for a preliminary injunction as moot. The plaintiffs appealed, and the United States Court of Appeals for the Second Circuit initially affirmed the dismissal. After the Supreme Court vacated the Second Circuit’s judgment and remanded for reconsideration in light of Mahmoud v. Taylor, the Second Circuit reviewed supplemental briefing and recent authorities. The Second Circuit again affirmed the district court’s judgment, holding that New York's immunization law is neutral and generally applicable, and thus constitutional under rational basis review. The court also held that the law does not impose a burden “of the same character” as the parental free-exercise burdens addressed in Yoder and Mahmoud, so strict scrutiny does not apply. The Second Circuit concluded that plaintiffs failed to state a viable Free Exercise or Yoder-type claim, and affirmed the dismissal of their suit. View "Miller v. McDonald" on Justia Law

Williams v. Nathan

2026-06-30T05:31:39-08:00

Two proposed statewide initiatives in Colorado sought to alter the process and timing of congressional redistricting and to replace the existing congressional district map for the 2028 and 2030 election cycles. Both initiatives were similar in structure and aimed to temporarily allow mid-decade redistricting by amending the state constitution to enable new congressional maps for two election cycles, with authority returning to the independent redistricting commission after the 2030 federal census. The initiatives also included detailed statutory language setting forth the new temporary map to be used, with one initiative designed to favor Democratic candidates and the other designed to favor Republican candidates, according to the briefing. After the proponents submitted final versions of their initiatives, the Title Board, a state body responsible for setting the ballot title and submission clause, held hearings and set titles for each measure. Motions for rehearing alleging violations of the single subject and clear title requirements were denied by the Title Board. Petitioners then appealed to the Colorado Supreme Court, invoking its jurisdiction to review Title Board determinations under state law. The Supreme Court of Colorado reviewed the actions of the Title Board under a deferential standard, overturning its findings only in a clear case. Upon examining the initiatives, the court concluded that both measures violated the single subject requirement of the Colorado Constitution and applicable statutes. The court held that temporarily allowing mid-decade redistricting and adopting specific new congressional maps for two election cycles were distinct and separate subjects, not necessarily or properly connected. Because the initiatives combined these separate subjects, they were susceptible to log rolling and could mislead voters. The court reversed the actions of the Title Board, ordered the titles stricken, and directed that the measures be returned to their proponents. View "Williams v. Nathan" on Justia Law

Fasano v. Delaware Department of Natural Resources and Environmental Control

2026-06-29T10:33:00-08:00

A former superintendent of two state parks was investigated after a GPS device flagged his use of a state vehicle for speeding. When initially questioned, he denied being the driver and suggested another employee was responsible, later admitting he was the driver after being shown proof. He explained his actions by citing a dissociative episode related to post-traumatic stress disorder. The Department of Natural Resources and Environmental Control (DNREC) first suspended him for three days pending further review but later recommended his termination, citing additional alleged misconduct, including misuse of a state vehicle for personal errands, disabling a GPS tracker, and inappropriate computer use, although some charges—like GPS disabling and computer misuse—were not substantiated. The employee contested his termination through a “dual appeal” to the Delaware Division of Human Resources (DHR) and the Merit Employee Relations Board (MERB). DHR found his appeal untimely. MERB initially dismissed the appeal on timeliness grounds, but the Superior Court of Delaware reversed, finding the appeal timely and remanded the case for a new hearing. At the second MERB hearing, a Department of Justice attorney who had previously represented DNREC now advised MERB and drafted its written decision upholding the termination, finding the employee violated policies and was untruthful. The Superior Court affirmed MERB’s decision, holding it was supported by substantial evidence and that no due process violation occurred, relying on the Delaware Supreme Court’s decision in Blinder, Robinson & Co. v. Bruton. The Supreme Court of the State of Delaware found that procedural due process was violated when the same attorney represented both the prosecuting agency and later the adjudicatory board in the same case. The Court held that this “personal commingling of advocacy and adjudication” created an intolerable risk of bias and reversed the Superior Court’s judgment, remanding the matter for a new hearing before MERB. View "Fasano v. Delaware Department of Natural Resources and Environmental Control" on Justia Law

CENTER FOR AZ v AZ SECRETARY OF STATE

2026-06-29T09:02:35-08:00

Arizona voters adopted a statute requiring organizations engaging in independent election-related media spending to disclose the identities of major donors and the original sources of funds used for such communications. The law includes an opt-out provision allowing donors to prevent their contributions from being used for campaign media spending, and imposes thresholds for disclosure and reporting. Plaintiffs, consisting of two nonprofit organizations and two anonymous individuals who donate to such organizations, challenged the law’s constitutionality, alleging it violated their rights to free speech and privacy under the Arizona Constitution. The Superior Court for Maricopa County dismissed the plaintiffs’ complaint for failure to state a legally valid claim, but permitted an amended complaint to add an as-applied challenge. After defendants again moved to dismiss, the court granted the motion, and the Arizona Court of Appeals affirmed the dismissal, finding plaintiffs had not sufficiently alleged that the statute was unconstitutional on its face or as applied. Upon review, the Supreme Court of Arizona held that the plaintiffs failed to sufficiently allege that the statute is facially unconstitutional under either the Speak Freely Clause or the Private Affairs Clause of the Arizona Constitution. The court developed an Arizona-specific standard for evaluating compelled disclosure laws, requiring that such laws meaningfully further election integrity or transparency and not unreasonably burden protected expression. The court found that the plaintiffs did not plausibly allege that the statute burdens protected expression in a substantial number of its applications. However, the Supreme Court of Arizona determined that the plaintiffs sufficiently alleged an as-applied challenge under the Speak Freely Clause, based on specific allegations of threats and harassment related to campaign media spending. The court affirmed the lower courts’ dismissal of all facial and privacy claims, reversed the dismissal of the as-applied free speech claim, and remanded that claim for further proceedings. View "CENTER FOR AZ v AZ SECRETARY OF STATE" on Justia Law

Trump v. Cook

2026-06-29T07:15:11-08:00

In August 2025, the President attempted to remove a sitting member of the Board of Governors of the Federal Reserve System, Lisa Cook, citing allegations of mortgage fraud that predated her tenure. This was the first time in the Federal Reserve’s history that a Governor was purportedly fired. Cook, whose term was scheduled to run until 2038, received a letter from the President stating that her integrity was in question due to potential misconduct, and that her immediate removal was necessary. Cook filed suit, arguing both that the alleged misconduct did not constitute “cause” for removal under the governing statute, and that she had not been given the required process—namely, notice and an opportunity to respond—before her termination. The United States District Court for the District of Columbia issued a preliminary injunction preventing Cook’s removal, finding she was likely to succeed on her claims that the purported “cause” did not satisfy the statutory standard, and that she had not received constitutionally or statutorily required pre-termination process. The United States Court of Appeals for the District of Columbia Circuit declined to stay the injunction, with a concurrence emphasizing the due process issue. The Government then sought a stay from the Supreme Court. The Supreme Court of the United States denied the Government’s application for a stay. The Court held that the President’s power to remove Federal Reserve Governors is subject to judicial review and that “cause” for removal must be substantial and related to the Governor’s official duties, reflecting the Federal Reserve’s need for independence. Most importantly, the Court ruled that Governors are entitled by statute to notice and an opportunity to respond before removal. Because Cook was not afforded these protections, her removal could not stand pending further litigation. The Court declined to address broader constitutional questions, deciding the case on statutory grounds. View "Trump v. Cook" on Justia Law

Trump v. Slaughter

2026-06-29T07:15:09-08:00

After President Trump began his second term in 2025, he dismissed two Democratic commissioners from the Federal Trade Commission (FTC), Rebecca Slaughter and Alvaro Bedoya, citing that their continued service conflicted with his administration’s priorities. He did not allege any statutory cause for their removal, instead asserting authority under Article II of the Constitution. Slaughter sued, arguing her removal was unlawful under the relevant statute, the Administrative Procedure Act, and the Constitution. Bedoya’s claims were dismissed as moot after he resigned, leaving only Slaughter’s case at issue. The United States District Court for the District of Columbia granted summary judgment in Slaughter’s favor, finding that President Trump’s action was ultra vires because the relevant statute allows removal of FTC commissioners only for “inefficiency, neglect of duty, or malfeasance in office.” The court relied on the Supreme Court’s prior decision in Humphrey’s Executor v. United States, which had recognized such statutory protections for FTC commissioners. The court issued a permanent injunction prohibiting interference with Slaughter’s ability to perform her duties. The United States Court of Appeals for the District of Columbia Circuit denied the government’s motion for a stay pending appeal, finding that Humphrey’s Executor controlled the issue. The Supreme Court of the United States reversed. It held that the FTC’s statutory provision limiting removal of commissioners to “for cause” is unconstitutional because it impermissibly restricts the President’s authority to remove executive officers. The Court overruled Humphrey’s Executor to the extent it permitted such statutory insulation for executive officers, reaffirming that officers exercising executive power must be removable by the President at will to preserve the Constitution’s separation of powers. The case was remanded for further proceedings consistent with this holding. View "Trump v. Slaughter" on Justia Law

Chatrie v. United States

2026-06-29T07:15:07-08:00

A man robbed a credit union in Midlothian, Virginia in May 2019. Police learned from witnesses and surveillance that the robber appeared to use a cell phone but could not identify him. To find leads, the officers applied for a geofence warrant, compelling Google to provide anonymized location data for all cell phones within a 150-meter radius of the credit union around the time of the crime. The warrant described a three-step process: first, Google would produce anonymized data for all devices within the geofence for an hour; second, police would narrow the list and receive additional location data for those devices; third, police would further narrow the list and obtain identifying information. Ultimately, Google provided the identities of three users, including the petitioner, whose movements matched those of the robber. The United States District Court for the Eastern District of Virginia found the geofence warrant “plainly violates the rights enshrined in [the Fourth] Amendment” but denied the motion to suppress the evidence, applying the good-faith exception to the exclusionary rule. A divided panel of the United States Court of Appeals for the Fourth Circuit affirmed, but on the ground that no Fourth Amendment search had occurred because the petitioner had no reasonable expectation of privacy in the Location History data given to Google. On rehearing en banc, the Fourth Circuit affirmed in a one-sentence opinion, dividing evenly on the search question. The Supreme Court of the United States held that police conduct a Fourth Amendment search when they acquire an individual’s cell-phone Location History data from Google, because a person has a reasonable expectation of privacy in such information. The Court vacated the Fourth Circuit’s judgment and remanded the case for further proceedings to determine whether the warrant satisfied the Fourth Amendment’s requirements of particularity and probable cause at each stage of the search process. View "Chatrie v. United States" on Justia Law

State v. Thornton

2026-06-26T12:36:52-08:00

Two men were convicted in the Circuit Court for Baltimore City on charges related to the 2019 murder of Donnell Brockington, who was surrounded and fatally shot multiple times by a group of six individuals. After the suspects fled, four, including the two respondents, were apprehended when their vehicle crashed. Police recovered several firearms, and DNA evidence linked both respondents to a Desert Eagle 9mm pistol found in the vehicle. At trial, a State firearms examiner testified that certain ammunition components were fired from that pistol, but neither respondent challenged the reliability of the examiner’s methodology or requested a Daubert hearing. After trial, the Supreme Court of Maryland decided Abruquah v. State, clarifying the limits on firearms identification testimony. The Appellate Court of Maryland reversed the respondents’ convictions on plain-error review, concluding that the firearms examiner’s unqualified testimony was exactly the kind prohibited by Abruquah. Additionally, one respondent challenged the trial court’s decision to close the courtroom during jury deliberations and partially restrict attendance during the verdict, arguing it violated the Sixth Amendment. The Appellate Court found these closures de minimis and rejected the public trial claim. The Supreme Court of Maryland held that the admission of the firearms examiner’s unqualified opinion was not “clear or obvious” error for plain-error review purposes, since the law was unsettled both at trial and on appeal; Abruquah was a case-specific ruling, not a categorical ban on such testimony. The Court also concluded that the courtroom closures were not de minimis but were justified under Waller v. Georgia, given the trial court’s findings of escalating spectator misconduct and concern for juror safety. The Supreme Court reversed the Appellate Court’s judgment on the convictions, affirmed its ruling on the public trial issue, and remanded for further proceedings. View "State v. Thornton" on Justia Law

Bracey v. Superintendent Rockview SCI

2026-06-26T09:00:11-08:00

In 1995, a man was convicted by a jury in the Dauphin County Court of Common Pleas for first-degree murder following the shooting death of another individual related to a drug deal. Two key prosecution witnesses, both facing pending charges themselves, testified against him in exchange for plea agreements. The prosecution did not disclose all pending charges against these witnesses, though defense counsel was able to impeach their credibility based on other known charges. Despite this, the jury convicted the defendant, who was sentenced to life imprisonment. He unsuccessfully challenged his conviction on direct appeal and through multiple post-conviction proceedings in state court. After eventually discovering the full extent of the witnesses' pending charges, the petitioner filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Middle District of Pennsylvania, asserting a Brady violation. The District Court denied the petition as untimely under the statute of limitations, and subsequent requests for a certificate of appealability were also denied. Following a significant change in Third Circuit law announced in Dennis v. Secretary, Pennsylvania Department of Corrections, the petitioner sought to reopen his federal habeas case under Federal Rule of Civil Procedure 60(b)(6). After a remand for further analysis, the District Court again denied the Rule 60(b)(6) motion, finding that the factors for extraordinary relief were not met. The United States Court of Appeals for the Third Circuit reviewed the denial, applying an abuse-of-discretion standard and weighing the Cox factors. The Court held that, although the materiality and diligence factors favored the petitioner, the remaining factors—likelihood of success, finality and comity, lack of actual innocence, and non-capital sentence—strongly disfavored relief. The Third Circuit affirmed the District Court’s denial of the Rule 60(b)(6) motion. View "Bracey v. Superintendent Rockview SCI" on Justia Law

State of Iowa v. Schadl

2026-06-26T06:05:34-08:00

In July 2024, police in Iowa investigated a report that Eric Schadl, a person prohibited from possessing firearms due to a prior conviction, had a gun in his home. Schadl admitted to owning a .22 caliber rifle and having a 2010 misdemeanor domestic abuse assault conviction, which barred him from firearm possession under Iowa law. He was charged under Iowa Code § 724.26(2)(a), which imposes a lifetime firearm ban on individuals convicted of a misdemeanor crime of domestic violence. Schadl moved to dismiss the charge in Iowa District Court for Dubuque County, arguing the statute violated his right to keep and bear arms under both the Iowa and Federal Constitutions. The district court denied his motion, finding the statute constitutional under intermediate scrutiny. Schadl then asked the court to reconsider, arguing that strict scrutiny applied under the Iowa Constitution’s Amendment 1A, and that recent United States Supreme Court decisions had changed the federal standard. The district court reaffirmed its prior ruling, this time stating the statute survived even under strict scrutiny. Schadl entered a conditional guilty plea, reserving the right to appeal the constitutional issue, and was sentenced to a suspended sentence with probation. On appeal, the Supreme Court of Iowa reviewed whether the lifetime firearm ban, as applied to Schadl, violated Amendment 1A of the Iowa Constitution, which requires all firearm restrictions to survive strict scrutiny. The court rejected Schadl’s facial challenge but found for him on his as-applied challenge, holding that the State failed to prove the indefinite ban was narrowly tailored to serve a compelling public safety interest, especially given Schadl’s fourteen years without reoffending. The court concluded the State had not met its burden under strict scrutiny and reversed Schadl’s conviction, remanding the case to the district court for dismissal. View "State of Iowa v. Schadl" on Justia Law

Gregory v. State of Iowa

2026-06-26T06:05:33-08:00

Several individuals incarcerated in Iowa correctional institutions challenged the constitutionality of Iowa Code section 904.310A, as amended in 2018, which prohibits the Iowa Department of Corrections from using funds to distribute or make available any commercially published material to inmates when such material is sexually explicit or features nudity. The plaintiffs, representing themselves and later joined by counsel, argued that this prohibition infringed on their rights to free speech under the United States and Iowa Constitutions. The amended statute and corresponding regulations resulted in the closure of reading rooms and a bar on materials with nudity, even when not sexually explicit. The challenged policy did not apply to personal photographs, only to commercially published materials. The Iowa District Court for Polk County initially granted a partial injunction, permitting the distribution of materials featuring mere, non-sexually explicit nudity, but ultimately denied most of the plaintiffs’ constitutional claims following a bench trial. The court applied the Turner v. Safley standard, requiring prison regulations that burden inmates’ constitutional rights to be reasonably related to legitimate penological interests. The court found that, while the regulation was more restrictive than prior policy, the State presented sufficient evidence—including expert testimony and examples of staff harassment and inmate safety issues—to support the connection between the ban and legitimate interests in institutional safety and order. As a result, the court denied the plaintiffs’ claims for declaratory and injunctive relief. On appeal, the Iowa Supreme Court conducted a de novo review and affirmed the district court’s judgment. The Supreme Court held that the Turner reasonableness standard, rather than strict scrutiny, applies to inmates’ free speech claims under both federal and state constitutions. The Court concluded that the regulation is justified by legitimate penological interests in staff and inmate safety, and that the ban is not an exaggerated response to those concerns. The judgment was affirmed. View "Gregory v. State of Iowa" on Justia Law

State v. N. K. B.

2026-06-26T05:53:53-08:00

A woman, referred to as Naomi, was charged with felony battery by a prisoner after slapping a nurse while incarcerated in the Milwaukee County jail. At her initial court appearance, concerns were raised about her competency to stand trial, and the Milwaukee County Circuit Court ordered a competency evaluation. Upon finding Naomi incompetent but likely to regain competence with treatment, the court committed her to the Department of Health Services (DHS) for treatment. The court originally found her incompetent to refuse medication and, after applying the standards from Sell v. United States, ordered involuntary medication to restore competency. Naomi appealed, and the court stayed the order. Subsequently, after DHS raised concerns about Naomi’s dangerousness, the court vacated its earlier order and issued a new involuntary medication order based solely on Naomi’s dangerousness, relying on WIS. STAT. § 51.61(1)(g)3. Naomi challenged the legal authority for this order, arguing that someone committed only under WIS. STAT. § 971.14 for competency restoration could not be involuntarily medicated on dangerousness grounds under § 51.61(1)(g)3. The Wisconsin Court of Appeals agreed with Naomi, rejecting the State’s arguments that various statutory and case law authorities permitted the order. The Supreme Court of Wisconsin reviewed the matter and affirmed the Court of Appeals. The court held that WIS. STAT. § 51.61(1)(g)3. does not authorize a court to order involuntary medication for an individual committed exclusively under WIS. STAT. § 971.14. The court based its decision on statutory language, context, and history, finding that § 971.14 provides a separate, more stringent process for involuntary medication orders in the context of competency restoration, and that § 51.61(1)(g)3. cannot be used as an alternative basis for such orders. View "State v. N. K. B." on Justia Law

Fischer v. Southeast Community College

2026-06-26T05:08:04-08:00

Two individuals—a student enrolled in a nursing program and a prospective paramedic student—challenged a community college’s policy requiring proof of COVID-19 vaccination for participation in certain clinical programs. The student alleged she was removed from the nursing program after failing to provide proof of vaccination and not receiving a clear response to her request for a medical exemption. She also claimed that the college placed her in clinical rotations at facilities with strict vaccination requirements, while other students were placed at locations accommodating the unvaccinated. The prospective paramedic student did not complete the vaccination requirement, did not seek an exemption, and was told that proof of vaccination or a successful exemption was necessary for acceptance. The District Court for Lancaster County allowed amendment of the initial complaint, but ultimately dismissed the amended complaint for lack of subject matter jurisdiction and failure to state a claim. The court found that the contract and negligence claims were barred by sovereign immunity, that the due process and equal protection claims lacked sufficient factual allegations to proceed, and that the “ultra vires” claim was not cognizable. The court denied further leave to amend, finding amendment would be futile. A timely postjudgment motion to alter or amend was denied, and the plaintiffs appealed. The Nebraska Supreme Court, after reviewing for plain error due to briefing deficiencies, found no plain error in the lower court’s dismissal of the case. The Court concluded that the district court properly dismissed all claims and that the appeal was timely. The Supreme Court affirmed the judgment of the district court. View "Fischer v. Southeast Community College" on Justia Law

Merriott v. City of Bossier City

2026-06-25T15:30:30-08:00

An online journalist residing in Bossier Parish, Louisiana, attended several Bossier City Council meetings in 2023 to speak on a petition for term limits for city officials. At these meetings, the City Council enforced a policy governing public comment, which barred “personal, impertinent or slanderous remarks” and prohibited “boisterous” conduct. The policy was repeatedly invoked to interrupt the journalist’s remarks, and after a contentious meeting, several councilmembers met privately to discuss further restricting public comment. The journalist later filed an open meetings complaint and sued the city and individual councilmembers under federal and state law, alleging violations of the First Amendment and Louisiana’s Open Meetings Law. The United States District Court for the Western District of Louisiana granted the defendants’ motion to dismiss, rejecting all of the journalist’s claims under Rule 12(b)(6). The court found that the policy did not violate constitutional or statutory rights and that the conduct described did not support actionable claims. On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo. The court held that the City Council’s policy was facially overbroad and unconstitutionally vague under the First and Fourteenth Amendments, as its prohibitions on “personal, impertinent or slanderous remarks” and “boisterous” conduct lacked clear definitions and chilled protected speech. The court also found that the policy constituted viewpoint and content discrimination, except as to the prohibition on “boisterous” conduct, which was deemed viewpoint neutral. The court determined that the journalist had plausibly alleged First Amendment retaliation and an Open Meetings Law violation against certain councilmembers, but not against one councilmember or for civil penalties. Accordingly, the Fifth Circuit affirmed the district court’s dismissal in part and reversed in part, remanding for further proceedings. View "Merriott v. City of Bossier City" on Justia Law

Scott v. City of Daytona Beach

2026-06-25T12:31:58-08:00

Four individuals who regularly engage in panhandling in Daytona Beach, Florida, challenged the city’s 2019 ordinance that imposed wide-ranging restrictions on panhandling. They argued that the law, which defined panhandling as in-person requests for immediate donations, and which banned or restricted this conduct in various locations and circumstances, violated their First Amendment rights. Each plaintiff relied on panhandling for basic needs and had faced threats, arrests, or other enforcement actions as a result of the ordinance. The United States District Court for the Middle District of Florida reviewed the case and granted summary judgment in favor of the plaintiffs. The court found that the ordinance’s challenged provisions were content-based, failed strict scrutiny, and thus violated the First Amendment. It issued a declaratory judgment, a universal injunction against enforcement of the challenged provisions, and awarded damages as agreed by the parties. The City of Daytona Beach appealed these decisions. On appeal, the United States Court of Appeals for the Eleventh Circuit held that the ordinance imposed content-based restrictions on speech by targeting only in-person requests for immediate donations, distinguishing them from other types of solicitation. The court found that several provisions could not withstand strict scrutiny, as the city had less speech-restrictive means to achieve its public health and safety goals. However, the Eleventh Circuit determined that the plaintiffs had standing to challenge only some, not all, of the ordinance’s provisions and that the district court’s remedy was overbroad. The appellate court affirmed the district court’s ruling as to the provisions where at least one plaintiff had standing, vacated it in other respects, and remanded for further proceedings consistent with its opinion. The damages award was affirmed because at least one provision was found unconstitutional. View "Scott v. City of Daytona Beach" on Justia Law

USA v Morgan

2026-06-25T12:30:56-08:00

James Morgan was investigated by law enforcement for several years due to his online activity, which included posting instructions for making dangerous homemade weapons and advocating for violence against government officials and minority groups. His posts, while often protected speech, were accompanied by demonstrations of weapons such as pipe bombs, acid sprayers, and flamethrowers. In late 2023, federal agents sought and obtained a search warrant from a magistrate judge in the Eastern District of Wisconsin to search Morgan’s property, including a trailer parked in the Western District, based on an affidavit detailing his conduct and apparent intent to commit acts dangerous to human life. After executing the warrant, agents found pipe bombs in Morgan’s trailer. He was indicted by a grand jury in the Western District of Wisconsin for possession of unregistered destructive devices under 26 U.S.C. § 5861(d). Morgan moved in the United States District Court for the Western District of Wisconsin to suppress the evidence, arguing the magistrate lacked authority to issue an extra-district warrant under Federal Rule of Criminal Procedure 41(b), and to dismiss the indictment, claiming the statute exceeded Congress’s taxing power. The district court denied both motions, finding the affidavit provided probable cause that Morgan’s activities constituted domestic terrorism under Rule 41(b)(3) and that established precedent foreclosed his constitutional challenge. Morgan entered a conditional guilty plea, reserving his right to appeal. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The court held the affidavit supplied probable cause that Morgan’s activities met the statutory definition of domestic terrorism, authorizing the magistrate’s extra-district warrant under Rule 41(b)(3). It also concluded that Morgan’s constitutional challenge to 26 U.S.C. § 5861(d) was foreclosed by Supreme Court and Seventh Circuit precedent, upholding the statute as a valid exercise of Congress’s taxing power. View "USA v Morgan" on Justia Law

Amacher v. City of Tullahoma

2026-06-25T12:30:39-08:00

An elected official in a Tennessee city, after selling her home and residing outside city limits for an extended period, faced a legal challenge to her eligibility to serve based on the city’s residency requirement. The challenge was initiated after a citizen petition, supported by over two hundred signatures, prompted the district attorney to file a quo warranto petition seeking her removal from office. Although she later purchased an unimproved lot in the city and began construction of a new home, questions remained about her intent to return and her actual residency during the contested period. The Tennessee state court found her claims of living on the undeveloped property unconvincing but ultimately determined that her efforts to build a residence demonstrated just enough intent to return, allowing her to retain her office. Following this outcome, the official sued two citizens, the city, the mayor, and the city administrator in the United States District Court for the Eastern District of Tennessee, alleging First Amendment retaliation and conspiracy for their roles in initiating the removal proceedings, along with a state law malicious prosecution claim. The district court granted summary judgment to the defendants on the federal claims, holding that she failed to show a conspiracy or retaliation connected to her protected speech, and declined to exercise jurisdiction over the state law claim. On appeal, the United States Court of Appeals for the Sixth Circuit held that, when a claim of First Amendment retaliation is based on the initiation of a civil action such as a quo warranto petition, the plaintiff must show a lack of probable cause for that action. The court concluded that probable cause existed to support the quo warranto petition, as there were reasonable grounds to doubt the official’s residency. Therefore, the court affirmed summary judgment for the defendants and found no abuse of discretion in the district court’s handling of discovery deadlines. View "Amacher v. City of Tullahoma" on Justia Law

Davis v. Guerrero

2026-06-25T09:30:53-08:00

The petitioner was convicted of the rape and murder of a 15-year-old girl. After initially being sentenced to death, the Texas Court of Criminal Appeals (CCA) granted him a new sentencing trial. At the resentencing, the state introduced evidence of his affiliation with Satanism, including personal writings and expert testimony, to argue he posed a future danger. The petitioner claimed this violated his First Amendment rights. He was again sentenced to death. Following the resentencing, the petitioner’s First Amendment claim was rejected on direct appeal by the CCA, and his ineffective assistance of counsel (IAC) claims were denied by the state habeas court. The CCA adopted the habeas court’s findings. The petitioner then pursued federal habeas relief, but the United States District Court for the Western District of Texas found his claims were either procedurally defaulted or reasonably rejected by the state courts, and denied relief. The petitioner was granted a certificate of appealability on his First Amendment and IAC claims. The United States Court of Appeals for the Fifth Circuit reviewed the case. Applying the highly deferential standard mandated by the Antiterrorism and Effective Death Penalty Act (AEDPA), the court concluded that the CCA’s rejection of the First Amendment claim was not contrary to or an unreasonable application of clearly established Supreme Court precedent. The court distinguished the evidence admitted in this case from the Supreme Court’s decision in Dawson v. Delaware and found it was relevant to the question of future dangerousness, not just to abstract beliefs. The court further held that no relief was warranted on the IAC claims because counsel’s performance was not objectively unreasonable and the state habeas court’s findings were not clearly erroneous. The Fifth Circuit affirmed the district court’s denial of habeas relief. View "Davis v. Guerrero" on Justia Law

Bjerke v. North Dakota Legislative Assembly

2026-06-25T09:13:01-08:00

Two North Dakota residents, who were involved in sponsoring a 2022 ballot initiative that established legislative term limits in the North Dakota Constitution, challenged a subsequent action by the Legislative Assembly. In 2025, the Assembly adopted Senate Concurrent Resolution 4008 to propose a constitutional amendment that would alter those term limits and repeal the provision prohibiting the Assembly from making such proposals. The Secretary of State accepted the resolution and planned to place the measure on the November 2026 general election ballot. The petitioners argued that the Assembly’s action exceeded its constitutional authority and sought a writ to prevent the measure from appearing on the ballot. Prior to this proceeding, the North Dakota Supreme Court had granted a writ of mandamus in Hendrix v. Jaeger, requiring the Term Limits Initiative to be placed on the 2022 ballot, resulting in voter approval and the addition of term limits to the constitution. After the Assembly adopted S.C.R. 4008, the petitioners filed directly in the North Dakota Supreme Court for declaratory and injunctive relief. The Secretary of State took no position on the constitutionality of the resolution but argued he lacked authority to withhold it from the ballot. The Legislative Assembly opposed the petition, disputing the petitioners’ standing and the ripeness of the issue. The Supreme Court of North Dakota exercised its discretionary original jurisdiction, finding that the petitioners had standing and that the matter was ripe for review because it concerned compliance with mandatory constitutional procedures. The court held that the Assembly’s adoption of S.C.R. 4008 violated Article XV, Section 4 of the North Dakota Constitution, which expressly prohibits the legislature from proposing amendments that alter or repeal legislative term limits, reserving that power to the people by initiative. The court declared S.C.R. 4008 and the proposed measure void ab initio, enjoined the Secretary of State from placing it on the ballot, and denied attorney’s fees. View "Bjerke v. North Dakota Legislative Assembly" on Justia Law

State v. Smith

2026-06-25T07:20:13-08:00

The case concerns a defendant who was charged and convicted of felony lewd and lascivious conduct after an incident involving an eighteen-year-old victim who was staying overnight at a friend’s house, where the defendant was also present. During the night, the defendant engaged in sexual contact with the sleeping victim, including touching her breast and genitals, and masturbating over her. The victim disclosed the incident days later, and the defendant subsequently admitted his actions. The jury found the defendant guilty of the felony offense and not guilty of the lesser-included misdemeanor. The court sentenced him to two-to-four years, with all but ninety days suspended, and imposed probation. After sentencing, the defendant appealed, raising a constitutional challenge to the proportionality of his sentence and arguing it was disproportionate to his conduct, which he characterized as “misdemeanor-level.” The Vermont Supreme Court, in an earlier direct appeal, reviewed the proportionality argument for plain error due to lack of preservation and did not find plain error. Following that decision, the defendant filed a motion for sentence reconsideration under Vermont Rule of Criminal Procedure 35 in the Superior Court, Windham Unit, Criminal Division, arguing his sentence violated the Vermont Constitution and seeking a reduction based on mitigating factors. The Superior Court denied the motion, concluding it lacked authority under Rule 35(a) to address constitutional challenges to the underlying conviction and that the arguments presented had already been considered at sentencing. On further appeal, the Vermont Supreme Court affirmed, holding that Rule 35(a) cannot be used to collaterally attack a conviction or to challenge the constitutionality of the statute of conviction, and that the defendant’s sentence was within the statutory limits. The Court also held that the trial court did not abuse its discretion in denying sentence reduction under Rule 35(b). View "State v. Smith" on Justia Law

State v. Ogden

2026-06-25T07:17:56-08:00

A man was stopped by South Dakota wildlife conservation officers while boating on the Missouri River between South Dakota and Nebraska in July 2024. The officers noticed possible impairment and, after a field sobriety test, arrested him for boating under the influence and other offenses. The events in question took place near the Nebraska shoreline, beyond the centerline of the river’s designed channel. The defendant moved to dismiss the charges in the Magistrate Court of the First Judicial Circuit, Union County, South Dakota, arguing the state lacked jurisdiction because the incident happened on the Nebraska side of the river. After an evidentiary hearing, the magistrate court found that the arrest occurred on the Nebraska side, and concluded that South Dakota’s statutes giving conservation officers jurisdiction to the furthermost shoreline were preempted by the federally approved 1989 South Dakota-Nebraska Boundary Compact, which fixes the state boundary at the centerline of the Missouri River. The magistrate court dismissed the case for lack of jurisdiction. The State of South Dakota sought appellate review. The Supreme Court of the State of South Dakota first determined that the State’s petition for intermediate appeal was timely and that it had appellate jurisdiction. The Supreme Court held that the magistrate court did not abuse its discretion by receiving testimony and evidence to resolve the jurisdictional issue. The Supreme Court further held that, based on federal law and the 1989 Compact, South Dakota does not have concurrent jurisdiction over the Missouri River beyond the centerline of the designed channel unless there is an agreement or reciprocal legislation with Nebraska, which does not exist. As a result, the Supreme Court affirmed the magistrate court’s order dismissing the charges for lack of jurisdiction. View "State v. Ogden" on Justia Law

In re Child of Mindy P.

2026-06-25T07:08:52-08:00

The case involved a mother whose parental rights to her youngest child were terminated by the Maine District Court. The Department of Health and Human Services initiated a child protection proceeding in June 2023, citing concerns about the mother's mental health, substance abuse, and neglect. The mother missed the preliminary hearing, and the child remained in the Department’s custody. Shortly before a scheduled jeopardy hearing, the mother’s attorney, without prior motion or notice to the mother, orally requested the appointment of a guardian ad litem (GAL) for the mother. The court, relying solely on representations of counsel and without a hearing or evidence, appointed a GAL with broad authority to make binding decisions on the mother’s behalf. Following this, several hearings took place, including a jeopardy hearing and judicial review hearings. There was ongoing confusion among the court and the mother’s attorneys regarding whether direction should be taken from the mother or the GAL, especially when their positions diverged. In August 2025, at the termination hearing, the mother’s GAL consented to termination of parental rights on the mother’s behalf, over the mother’s absence and without her knowledge of the GAL’s intent to consent. The District Court entered the termination order based on the GAL’s consent, and the mother appealed. The Maine Supreme Judicial Court reviewed the case. It held that the process used to appoint the GAL violated the mother’s due process rights because she was not afforded notice or an opportunity to be heard before the GAL’s appointment and before her decision-making authority was delegated. The Court further concluded that this error was prejudicial and required the judgment to be vacated. The case was remanded for a proper competency hearing and new proceedings beginning with the jeopardy phase, ensuring the mother’s due process rights are protected moving forward. View "In re Child of Mindy P." on Justia Law

Roberts v. State of Florida

2026-06-25T07:04:53-08:00

In December 2017, William Roberts had an argument with his girlfriend, Elizabeth Hellstrom, after which she became unresponsive but was later revived. The next day, Roberts informed a friend that Elizabeth was dead and placed in the trunk of her car, also expressing an intent to commit suicide using a propane tank. Law enforcement was alerted and found Elizabeth’s body in her vehicle and evidence of violence in the camper she shared with Roberts. Roberts was indicted for first-degree murder, and the State sought the death penalty based on his prior violent felony conviction and the especially heinous nature of the crime. Following indictment, Roberts was represented by court-appointed counsel but expressed dissatisfaction and chose to waive his right to a jury trial and his presence at trial, both of which the trial court found to be knowing and voluntary. The case proceeded as a bench trial in the Circuit Court in and for Lake County, which found Roberts guilty of first-degree premeditated murder. During the penalty phase, Roberts waived the presentation of mitigating evidence, and the court eventually sentenced him to death, giving great weight to the statutory aggravators and only slight weight to limited mitigating factors. Roberts appealed to the Supreme Court of Florida, raising multiple claims including the admission of collateral crime evidence, the trial court’s rejection of a statutory mitigator, the use of certain penalty phase evidence, constitutional challenges to the death penalty and Florida’s sentencing scheme, and the lack of a contemporaneous competency hearing. The Supreme Court of Florida held that the trial court did not abuse its discretion in admitting evidence or in its mitigator findings, found no constitutional violation, and affirmed the sufficiency of the nunc pro tunc competency determination. The conviction and death sentence were affirmed. View "Roberts v. State of Florida" on Justia Law

Mullin v. Doe

2026-06-25T06:45:11-08:00

Several Syrian and Haitian nationals challenged the United States Secretary of Homeland Security’s decision to terminate Temporary Protected Status (TPS) designations for Syria and Haiti. TPS provides humanitarian relief for foreign nationals who cannot safely return to their countries. Syria’s TPS status, granted in 2012 due to civil war, was set for termination in 2025 following changes in the country’s government and improved conditions. Haiti’s TPS status, in place since a 2010 earthquake, was also scheduled for termination in 2026, with the government citing improved conditions and foreign policy considerations. In the United States District Court for the Southern District of New York, Syrian plaintiffs sued under the Administrative Procedure Act (APA), and the court granted interim relief, postponing termination. The United States Court of Appeals for the Second Circuit denied the government’s request for a stay. Separately, Haitian plaintiffs in the United States District Court for the District of Columbia brought APA and constitutional equal protection claims, alleging racial motivation behind the termination. That court also granted interim relief, and the United States Court of Appeals for the District of Columbia Circuit declined to issue a stay. The government petitioned for a stay and certiorari before judgment, after which the Supreme Court consolidated the cases for review. The Supreme Court of the United States held that the TPS statute bars judicial review of any non-constitutional claims related to the designation, extension, or termination of TPS for a foreign state. The Court also concluded that the equal protection claim brought by the Haitian plaintiffs was unlikely to succeed, finding insufficient evidence that race was a motivating factor in the termination decision. As a result, the Supreme Court reversed the interim relief granted by both district courts and remanded the cases for further proceedings. View "Mullin v. Doe" on Justia Law

Wolford v. Lopez

2026-06-25T06:45:07-08:00

Three residents of Maui County, Hawaii, each possessing a concealed-carry firearm permit, along with an organizational plaintiff, challenged a Hawaii statute that prohibits carrying firearms on private property open to the public unless the owner gives express, affirmative consent. This law, enacted after a Supreme Court decision recognized a constitutional right to carry handguns outside the home for self-defense, significantly limited the places where permit holders could lawfully carry. The statute imposed new burdens: permit holders had to obtain explicit permission before entering everyday establishments like stores and restaurants, reversing the traditional rule where entry was presumed permissible unless expressly forbidden. At the trial level, the United States District Court for the District of Hawaii enjoined enforcement of the law as applied to private property open to the public, finding it unconstitutional. The United States Court of Appeals for the Ninth Circuit reversed this injunction, allowing Hawaii’s law to remain in effect. The full Ninth Circuit denied a request for rehearing en banc, with several judges dissenting. The Supreme Court of the United States reviewed the case and held that Hawaii’s law violates the Second and Fourteenth Amendments. The Court found that the restriction fell within the plain text of the Second Amendment, creating a significant burden on the right to carry firearms for self-defense. The Court determined that Hawaii’s historical analogues—laws from the colonial and early state periods—were not sufficiently similar, as they primarily targeted unauthorized hunting, not self-defense in public establishments. The Supreme Court reversed the Ninth Circuit’s decision and remanded for further proceedings, holding that states cannot adopt default property rules that broadly prohibit carrying firearms on public-facing private property without individualized, express consent. View "Wolford v. Lopez" on Justia Law

People v. Castro-Velasquez

2026-06-25T06:31:31-08:00

In 2020, a home was broken into and the resident, Z.H., was assaulted by an unknown individual. Z.H. later suggested to police that the perpetrator might be a classmate she had seen on the bus, eventually identifying the respondent as that classmate. A detective sought and obtained a Colorado Rule 41.1 order, supported by reasonable suspicion, to collect DNA evidence from the respondent. The detective contacted the respondent and instructed him to come to the police station, but when that did not occur, detectives went to his home the next morning. There, they questioned the respondent about the assault, obtained inculpatory statements, and subsequently transported him to collect the DNA sample as authorized. The respondent was charged with several offenses related to the assault. He moved to suppress the statements made during the home encounter, arguing a violation of his Fourth Amendment rights and Colorado’s Rule 41.1, as interpreted in People v. Harris. The trial court denied the suppression motion, and the respondent was convicted by a jury. On appeal, the Colorado Court of Appeals reversed, holding that the execution of the Rule 41.1 order—and thus the protections against interrogation—began when the respondent was seized at his home, making his statements inadmissible. The Supreme Court of Colorado reviewed the case and affirmed the appellate court’s decision. The court held that execution of a Rule 41.1 order begins when a reasonable person in the suspect’s position would not feel free to leave, marking the point at which interrogation is prohibited without probable cause. Because the detectives interrogated the respondent after he was seized for the purpose of collecting nontestimonial identification evidence, the court concluded that his statements must be suppressed. The judgment of the Colorado Court of Appeals was therefore affirmed. View "People v. Castro-Velasquez" on Justia Law

LAWYER v. STATE OF TEXAS

2026-06-25T04:39:53-08:00

A man was convicted of capital murder after killing his former partner and her ten-year-old daughter in their shared apartment, while her twin four-year-old sons were present but unharmed. The killings occurred shortly before a court hearing at which the man was facing charges for previous assaults against the same woman. After committing the murders, he attempted to clean the crime scene, fled to Tennessee, confessed to his uncle, and was arrested as he tried to escape police. During the trial’s punishment phase, evidence of the sexual assault of the child victim, the defendant’s disruptive behavior in jail, and threats to his attorneys was presented. The trial originated in the Criminal District Court No. 1 in Tarrant County, Texas, where a jury convicted the defendant of capital murder and sentenced him to death based on their answers to special punishment issues. The defendant raised multiple claims on appeal, including challenges to the sufficiency and form of the indictment, denial of a motion to suppress evidence related to a search warrant, alleged Confrontation Clause violations tied to expert testimony and hearsay statements admitted during the punishment phase, the admission of expert testimony about prison violence, and the constitutionality of the statute governing jury instructions in capital cases. The Texas Court of Criminal Appeals reviewed the case on automatic direct appeal. The court held that the defendant waived his challenge to the indictment by failing to object before trial, and that the omission in the search warrant affidavit was not material. The court found no Confrontation Clause violation regarding the expert’s testimony, and any error in admitting certain hearsay during punishment was harmless beyond a reasonable doubt. The court also determined that the prison violence testimony was admissible, and that the constitutional challenge to the jury instruction statute was not preserved for appeal. The court affirmed the conviction and sentence of death. View "LAWYER v. STATE OF TEXAS" on Justia Law

United States v. Hoover

2026-06-24T11:00:47-08:00

A law enforcement officer in Ohio stopped a driver after observing multiple traffic violations. Upon approaching the vehicle, the officer noticed drug paraphernalia and received a suspicious learner’s permit from the driver, whose appearance did not match the permit’s photo. Further investigation revealed that the passenger did have a valid driver’s license despite initially indicating otherwise. During questioning about drugs, the officer observed a firearm in the car, which led to a search that uncovered fentanyl and other drug-related materials. The driver was ultimately indicted on charges including possession of fentanyl with intent to distribute, possession of a firearm in furtherance of drug trafficking, and being a felon in possession of a firearm. The United States District Court for the Northern District of Ohio oversaw pretrial proceedings marked by the defendant’s attempts to change counsel and disputes regarding acceptance of responsibility in plea negotiations. The district court made statements suggesting it would not grant credit for acceptance of responsibility in any plea, even when plea negotiations remained open. A jury convicted the defendant on all charges, and after evidence surfaced that the defendant continued drug activity while detained, the district court denied a reduction for acceptance of responsibility and sentenced him to a total of 420 months in prison. On appeal, the United States Court of Appeals for the Sixth Circuit reviewed several claims, including improper judicial participation in plea negotiations, denial of a suppression motion, the constitutionality of the felon-in-possession statute as applied, career offender status, and the timing of resentencing. The Sixth Circuit held that although the district court violated Rule 11(c)(1) by improperly participating in plea discussions, the error was harmless because the defendant was not prejudiced. The court also affirmed the denial of the suppression motion, upheld the constitutionality of the firearm conviction, agreed with the career offender classification, and found no reversible error in the resentencing process. The convictions and sentences were affirmed. View "United States v. Hoover" on Justia Law

Ramos-Osario v. State of Indiana

2026-06-24T10:34:16-08:00

In the early morning hours, a police officer in Indianapolis heard gunfire and observed muzzle flashes coming from a black truck driven by Facundo Ramos-Osario. The officer initiated a traffic stop, and another officer arrived to assist. Ramos-Osario, the driver, was removed from the vehicle, handcuffed, and subjected to sobriety tests, which indicated intoxication. He later consented to a chemical test confirming a blood alcohol concentration above the legal limit. Ramos-Osario was charged with operating a vehicle with an alcohol concentration equivalent of .08 or more and operating while intoxicated, both as Class C misdemeanors. Before trial in Marion Superior Court, Ramos-Osario moved to suppress the evidence from the stop, arguing it was unconstitutional under both the Fourth Amendment and the Indiana Constitution. After a suppression hearing, where the officer who conducted the stop testified about his observations, the magistrate found the stop constitutional and denied the motion. At Ramos-Osario’s bench trial, a different judge presided, and only the assisting officer testified. Ramos-Osario objected to the introduction of evidence from the stop, contending the State had not established reasonable suspicion at trial. The objections were overruled, and Ramos-Osario was convicted. On appeal, the Indiana Court of Appeals reversed, holding the State failed to establish the stop’s constitutionality at trial since the suppression hearing evidence was not incorporated. The Indiana Supreme Court reviewed the case and held that the State is not required to prove constitutional compliance a second time at trial if it has already done so at a pretrial suppression hearing. The trial and appellate courts may consider both suppression hearing evidence and trial evidence when evaluating constitutional compliance. The Court affirmed Ramos-Osario’s conviction, finding the stop did not violate his state or federal constitutional rights. View "Ramos-Osario v. State of Indiana" on Justia Law

Braggs v. Commissioner, Alabama Department of Corrections

2026-06-24T10:32:51-08:00

A group of inmates incarcerated within Alabama’s state prison system filed a class action challenging the adequacy of mental health care provided by the Alabama Department of Corrections (ADOC). The plaintiffs, who suffer from serious mental illnesses, alleged that overcrowding, understaffing, and a series of systemic failures resulted in constitutionally deficient mental health services, contributing to a suicide rate far above the national average. Key alleged deficiencies included improper identification and classification of mental health needs, inadequate treatment plans, insufficient psychotherapy, lack of proper suicide risk management, improper use of segregation for mentally ill inmates, and the imposition of disciplinary sanctions for manifestations of mental illness. The United States District Court for the Middle District of Alabama managed the litigation in multiple phases. After a seven-week bench trial, the court found the ADOC liable under the Eighth Amendment for deliberate indifference to inmates’ serious mental health needs. The court then held extensive remedial proceedings, including further hearings and negotiations, and entered a comprehensive, system-wide remedial injunction. The court made detailed factual findings and, to comply with the Prison Litigation Reform Act (PLRA), issued particularized findings that the relief ordered was necessary, narrowly drawn, and the least intrusive means to remedy the constitutional violations. The court also adopted a monitoring plan to ensure compliance, involving external experts and a transition to internal oversight. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s liability findings and most aspects of the remedial and monitoring orders, holding that system-wide relief was appropriate given the systemic nature of the violations. However, the appellate court reversed certain remedial provisions where it found the relief exceeded what was necessary to correct the constitutional violations, particularly with respect to suicide-proofing cells and some staffing requirements, and as applied to a women’s facility where violations were not established. The case was remanded for modification in those limited respects. View "Braggs v. Commissioner, Alabama Department of Corrections" on Justia Law

Ingram v. Hamilton

2026-06-24T10:31:20-08:00

A maximum security prison in Virginia faced a surge in near-fatal drug overdoses among inmates in May and June 2023. In response, prison officials implemented a policy requiring every inmate who accessed the no-contact video visitation rooms to undergo a strip search both before and after each visit. Marcus Ingram, an inmate who used these rooms to call his wife, was subjected to 26 strip searches in a single month as a result. The policy was based on uncorroborated tips from inmates suggesting that contraband was being circulated through these rooms, despite no evidence of any actual contraband being found in connection with the video visitation rooms. Ingram filed a pro se lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Virginia against the prison warden and the officer who conducted most of the searches. He alleged violations of his Fourth and Eighth Amendment rights, along with a claim of supervisory liability against the warden. The district court granted summary judgment to the defendants on the basis of qualified immunity, holding that the searches were reasonable due to the drug problem and that there was no evidence of harassment or intimidation. The court also dismissed the supervisory liability claim as there was no underlying constitutional violation. On appeal, the United States Court of Appeals for the Fourth Circuit assumed without deciding that some of the strip searches may have violated the Fourth Amendment. However, it held that the right at issue was not clearly established at the time, as neither controlling precedent nor a consensus of persuasive authority made the unconstitutionality of the policy beyond debate. Therefore, the Fourth Circuit affirmed the district court’s grant of qualified immunity to the defendants. View "Ingram v. Hamilton" on Justia Law

Brown v. People

2026-06-24T07:32:07-08:00

A man drove his truck through an alley at night and ran over two people who were sleeping under a blanket, resulting in one death and one serious injury. After being told by a witness that he had run over people, he denied it and drove away. Police later located him at his home, noting signs of alcohol consumption. Brown was charged with leaving the scene of an accident resulting in death and serious bodily injury, as well as being a habitual criminal based on prior convictions. The District Court of Colorado presided over his trial. The jury was instructed on the elements of leaving the scene offenses but was not required to find any culpable mental state, such as knowledge or intent, for these crimes. Brown was convicted by the jury of both offenses, and the judge, not the jury, made the habitual offender finding, which resulted in an enhanced sentence. Brown appealed to the Colorado Court of Appeals, arguing the absence of a culpable mental state in the jury instructions was erroneous and that the habitual offender statute was unconstitutional because a judge, not a jury, determined facts increasing his sentence. The Court of Appeals affirmed his convictions and sentence, relying on existing precedent. The Supreme Court of Colorado reviewed the case. It held that its prior decision in People v. Manzo remains good law: leaving the scene of an accident resulting in death or serious bodily injury is a strict liability offense that does not require proof of any culpable mental state. The court also held that Colorado’s earlier habitual offender statute was not facially unconstitutional and, even if there was error in the judge making the habitual offender finding, it was harmless beyond a reasonable doubt given the overwhelming evidence. The Supreme Court of Colorado affirmed the judgment of the court of appeals. View "Brown v. People" on Justia Law

Close v. City of Bellevue Iowa

2026-06-24T07:31:11-08:00

Angela Prichard endured months of harassment and stalking from her ex-husband, Christopher, including threats, vandalism, and surveillance. Despite multiple reports to police and both temporary and permanent restraining orders—each of which mandated Christopher’s arrest for violations—law enforcement officers did not take significant protective action. After a period away from her home, Angela returned despite warnings from the Chief of Police. A week later, Christopher fatally shot her. He was subsequently convicted of her murder. Angela’s family, including her sons, then sued the City of Bellevue and three police officers, alleging that the failure to protect Angela violated federal constitutional rights and Iowa law. The United States District Court for the Northern District of Iowa dismissed the complaint, determining that neither federal nor Iowa law created a duty for law enforcement to protect Angela from private violence under these circumstances. The court also denied the family’s post-judgment motion to amend their complaint, finding it was untimely and would have been futile because the proposed amendments did not present sufficient factual matter to plausibly state a claim. Reviewing the case, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The Eighth Circuit held that substantive due process under the United States Constitution does not impose an affirmative duty on the government to protect individuals from private violence, consistent with the Supreme Court’s decision in DeShaney v. Winnebago County Department of Social Services. The court also concluded that Iowa’s no-contact order statute does not create a private right of action against law enforcement for failing to enforce such orders. The court further rejected the family’s other state law claims, including those brought under the Iowa Slayer Statute and for intentional infliction of emotional distress, finding the facts alleged did not support those causes of action. The court found no abuse of discretion in denying leave to amend the complaint. View "Close v. City of Bellevue Iowa" on Justia Law

Bedford v. MO Dept of Social Services, Family Support Div.

2026-06-24T07:31:10-08:00

Several individuals who were non-custodial parents and owed more than $2,500 in child support had their driver’s licenses suspended by the Missouri Department of Social Services, Family Support Division (FSD), under a statutory scheme that, until 2023, did not require consideration of an individual’s ability to pay before suspending a license. The plaintiffs’ suspensions occurred in 2017 and 2018. Two plaintiffs’ suspensions were later stayed, and a third’s license was fully restored. They argued that the suspension policy violated their constitutional rights under the Fourteenth Amendment and the fundamental right to travel, seeking declaratory and injunctive relief and reinstatement of their licenses. The United States District Court for the Eastern District of Missouri first denied a preliminary injunction as moot and then partially dismissed the complaint. It rejected dismissal based on the Rooker-Feldman doctrine and Younger abstention, finding that plaintiffs’ claims were independent and no ongoing state proceeding existed. The court allowed only the procedural due process claim to proceed, dismissing other constitutional claims and claims against the governor. Later, the district court dismissed the case sua sponte for lack of subject matter jurisdiction, concluding that the plaintiffs lacked standing because their suspensions were stayed or lifted. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. It held that the plaintiffs lacked standing for declaratory relief because they did not allege ongoing or immediate injury, and their alleged harms were too speculative or unsupported. Any relief regarding Missouri’s prior statutory scheme was moot due to legislative amendments that now require consideration of ability to pay. The court affirmed the district court’s dismissal of the complaint for lack of subject matter jurisdiction and dismissed the appeal regarding the preliminary injunction as moot. View "Bedford v. MO Dept of Social Services, Family Support Div." on Justia Law

Wilansky v. Morton County, North Dakota

2026-06-24T07:31:09-08:00

During protests opposing the Dakota Access Pipeline in November 2016, Sophia Wilansky was severely injured when police fired an aerial warning munition that struck her arm. Earlier that night, officers had ordered Wilansky and another protester to disperse from a barricade on a closed bridge, warning that they would use less-lethal munitions if the order was ignored. When Wilansky and the other protester did not comply, officers fired various less-lethal munitions. After Wilansky began retreating, she was struck by the aerial munition, causing permanent injury to her left hand and forearm. Following the incident, Wilansky filed two lawsuits in the United States District Court for the District of North Dakota. She alleged, under 42 U.S.C. § 1983, that county and state officers used excessive force in violation of the Fourth and Fourteenth Amendments and that Morton County maintained unconstitutional policies or customs. During the litigation, the district court struck certain new allegations and defendants from one complaint and ordered Wilansky to file an amended complaint. Wilansky then filed a second lawsuit with additional allegations against the stricken defendants. The district court ultimately dismissed both cases with prejudice. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgments. The court held that Wilansky did not sufficiently plead that the officers’ actions amounted to a clearly established Fourth Amendment seizure, nor did her allegations meet the “shocks the conscience” standard required for a Fourteenth Amendment claim. The court further held that she failed to establish a pattern of unconstitutional conduct by Morton County as of the date of her injury. Finally, the Eighth Circuit concluded that the district court did not abuse its discretion in dismissing the claims with prejudice. View "Wilansky v. Morton County, North Dakota" on Justia Law

State v. Miles

2026-06-24T06:08:30-08:00

Police in Jersey City investigated a fatal shooting and, after receiving information from a confidential informant who identified two people by their nicknames and social media handles from surveillance footage, conducted a facial recognition technology (FRT) search using an Instagram profile photo. This search returned several possible matches, including the defendant. The police then interviewed several individuals, such as the defendant’s sister and ex-girlfriend, who identified the defendant from other surveillance images, but no witness identified him as the shooter or saw the shooting occur. Multiple men were present in the footage, and no video captured the shooting itself. After indictment for murder and weapons offenses, the defendant moved to compel discovery of various FRT-related materials, including proprietary information like the source code, relying on State v. Arteaga. The Superior Court, Law Division, granted the request for all thirteen items previously allowed in Arteaga. The State provided some limited FRT results but not all requested information, especially proprietary materials. The State then sought review from the Appellate Division, which denied leave to appeal, finding no abuse of discretion in the trial judge’s order and applying Arteaga. On further appeal, the Supreme Court of New Jersey held that discovery obligations in cases involving FRT are not automatically governed by Arteaga’s checklist but must be tailored to the case’s facts. The Court affirmed that the State must produce non-proprietary discovery identifying the FRT tools and materials used, and information about how those tools were used in the investigation and prosecution. However, the Court reversed without prejudice the order to produce proprietary FRT information, such as source code, finding the record insufficiently developed to determine a particularized need. The case was remanded for further proceedings. View "State v. Miles" on Justia Law

Cella v. Attorney General

2026-06-24T04:08:26-08:00

A group of registered voters in Massachusetts challenged the Attorney General’s certification of an initiative petition proposing to limit annual rent increases for residential properties. The petition would repeal the Statewide ban on rent control and instead institute a cap on rent increases, but it expressly exempted certain types of properties, including those in facilities operated solely for religious, educational, or nonprofit purposes. The Attorney General had certified that the petition did not contain excluded matters, issued the required summary, and the Secretary of the Commonwealth prepared the petition for circulation and potential inclusion on the November 2026 ballot after sufficient signatures. The plaintiffs filed a civil action in the Supreme Judicial Court for Suffolk County, seeking a declaration that the petition was invalid under the Massachusetts Constitution, an order quashing the certification, and an injunction preventing the petition from appearing on the ballot. The parties agreed to reserve and report the case to the full Supreme Judicial Court. The central argument was that the petition impermissibly “relates to religion, religious practices or religious institutions,” which is prohibited by Article 48 of the Amendments to the Massachusetts Constitution. The Supreme Judicial Court of Massachusetts reviewed the case de novo and concluded that, because the petition included an exemption for facilities operated solely for religious purposes, it “relates to religion” within the meaning of Article 48. The Court explained that the exemption makes religion a factor in the law’s application and would require governmental determinations about religious purpose, thereby conferring preferential treatment on religious institutions. The Court held that the petition is barred from the initiative process by Article 48 and directed that it may not be placed on the 2026 Statewide election ballot. The judgment was remanded for entry of a declaratory judgment and an injunction consistent with this holding. View "Cella v. Attorney General" on Justia Law

State v. Raeon A.

2026-06-24T04:04:16-08:00

A minor, R, began living with her biological father when she was around five or six years old. For several years, they resided together in the basement of a home owned by the father's parents. During this period, the father sexually abused R on a frequent basis, including both touching and attempted intercourse. When R was nine, she told a friend about the abuse, who then informed her mother. The next day, the mother's friend reported the allegations to the elementary school principal, who, as a mandated reporter, notified the Department of Children and Families and the police. Investigations followed, and R participated in interviews. Nearly eight years later, the father was tried for sexual assault and risk of injury to a child, and R testified about the abuse, including previously undisclosed incidents. The Superior Court for the judicial district of Ansonia-Milford at Milford conducted the trial. The jury found the father guilty of one count each of sexual assault in the first degree and risk of injury to a child, but not guilty on a second risk of injury count. He was sentenced to twenty years in prison, with fifteen years mandatory, and ten years of special parole. On direct appeal to the Connecticut Supreme Court, the defendant argued that the trial court improperly instructed the jury not to consider R’s delay in reporting the abuse when evaluating her credibility, claiming a violation of his constitutional rights. The Connecticut Supreme Court held that the instructional claim was not of constitutional magnitude and was therefore unreviewable under State v. Golding. The court also determined that the instruction was consistent with the law at the time of trial and did not constitute plain error. The judgment of conviction was affirmed. View "State v. Raeon A." on Justia Law

Ft. Detrick/W. Reed Army Med. Housing v. Wynn

2026-06-23T12:36:41-08:00

A landlord operating a multi-family apartment complex in Montgomery County, Maryland, filed a summary ejectment action against a civilian tenant for unpaid rent. The landlord did not possess a residential rental license, as required by county regulations, but claimed exemption from those requirements because the apartment complex was located on land originally acquired by the United States in 1941 for military purposes. The complex primarily housed servicemembers assigned to a nearby military medical center, but also leased to civilians when units were available. The District Court of Maryland sitting in Montgomery County found that the landlord was exempt from local licensure requirements based on correspondence from the county’s housing authority and entered judgment for possession and unpaid rent against the tenant. On appeal, the Circuit Court for Montgomery County reversed, ruling that the landlord was required to obtain a local rental license, at least for units leased to civilians, and vacated the judgment for possession and unpaid rent. The Supreme Court of Maryland reviewed whether the Enclave Clause of the United States Constitution preempted Montgomery County’s licensure requirements for this property. The court held that for the United States to obtain exclusive jurisdiction under the Enclave Clause, the State must consent, cede jurisdiction, and the United States must formally accept that jurisdiction. The record showed that, although the United States acquired title with state consent and cession, there was no evidence that the United States ever formally accepted exclusive jurisdiction as required by federal law at the time of acquisition. Thus, the Enclave Clause did not apply, and the landlord failed to prove exemption from county licensure. The Supreme Court of Maryland affirmed judgment for the tenant, holding that the landlord could not bring a summary ejectment action without demonstrating compliance with, or exemption from, local licensing requirements. View "Ft. Detrick/W. Reed Army Med. Housing v. Wynn" on Justia Law

Wilson v. State

2026-06-23T10:35:05-08:00

In 1999, the defendant pleaded guilty to Class B felony child molesting after allegations that he engaged in sexual conduct with his ex-wife’s twelve-year-old niece. The trial court accepted his plea, sentenced him to ten years (with three years suspended), and required him to register as a sex offender for ten years, consistent with the law at the time. However, legislative amendments enacted shortly before sentencing created a new “sexually violent predator” (SVP) category, which eventually imposed lifetime registration on those convicted of certain offenses, including the defendant’s. Years later, the defendant was classified as an SVP “by operation of law,” without a court hearing or individualized determination. After completing his sentence and years of registration, the defendant petitioned the Lawrence Superior Court in 2024 for removal of his SVP status, citing compliance with registration, successful completion of therapy, a stable work history, and lack of subsequent offenses. The trial court denied the petition and, after conducting an evidentiary hearing on the defendant’s motion to correct error, again denied relief, finding he remained a danger. The Indiana Court of Appeals affirmed, holding the opportunity to petition annually for reconsideration provided a meaningful review that satisfied constitutional requirements. The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. The Court held that the statute’s provision for annual petitions for review of SVP status precludes an ex post facto violation, as it ensures the opportunity for meaningful individualized review. The Court clarified that while expert evaluation is not always required, a hearing with expert testimony is necessary when the petitioner makes a prima facie showing of rehabilitation. In this case, the denial was affirmed because the defendant’s evidence did not meet that threshold. View "Wilson v. State" on Justia Law

Reyes v City of New York

2026-06-23T10:26:47-08:00

In this case, the plaintiff, an independent journalist, entered the publicly accessible lobby of a New York City police precinct and began recording police activity on his cellphone. Despite posted signs and verbal warnings from NYPD officers about a policy prohibiting video recording inside police facilities, the plaintiff continued recording. He was arrested, charged with trespass, and detained for about six hours, but the charge was ultimately dropped and not prosecuted. After his arrest, the plaintiff filed a lawsuit in the United States District Court for the Southern District of New York against the City of New York, claiming violations of his First Amendment rights and the rights established under both New York State and City laws, known as the Right to Record Acts (RTRAs). The District Court found the plaintiff unlikely to succeed on his First Amendment claim but likely to succeed under the RTRAs, granting a preliminary injunction against enforcement of the NYPD’s no-recording policy in precinct lobbies. The City appealed, and the United States Court of Appeals for the Second Circuit stayed most of the injunction and certified a question to the New York Court of Appeals regarding the scope of the RTRAs. The New York Court of Appeals, the state’s highest court, held that neither New York Civil Rights Law § 79-p nor New York City Administrative Code § 14-189 grants individuals the right to record police activity inside publicly accessible lobbies of police stationhouses. The court based its holding on the ambiguity in the statutory text regarding location, legislative history emphasizing public spaces rather than police facilities, and significant privacy and safety concerns. Accordingly, the court answered the certified question in the negative, concluding that the RTRAs do not apply to recording police activities inside police station lobbies. View "Reyes v City of New York" on Justia Law

Volokh v James

2026-06-23T10:26:14-08:00

In response to a mass shooting in Buffalo, New York, that was planned, publicized, and broadcast via social media, the state legislature enacted the Hateful Conduct Law (HCL). This statute requires social media networks conducting business in New York to provide a clear, easily accessible mechanism for users to report "hateful conduct" and to maintain a public policy describing how the network will address such reports. "Hateful conduct" is defined as using a social media network to vilify, humiliate, or incite violence against groups based on protected characteristics. Plaintiffs, including operators of social media platforms, challenged the law before it took effect, arguing that it would compel them to speak against certain content and chill protected expression. The United States District Court for the Southern District of New York granted a preliminary injunction, finding that the HCL likely violated the First Amendment by compelling social media networks to endorse the state’s definition of hateful conduct and to publish policies about it. The court determined that the law could have a chilling effect on free speech, even though it did not require removal of the content itself. The Attorney General appealed to the United States Court of Appeals for the Second Circuit, which determined that resolution of the constitutional issues depended on the proper interpretation of the HCL under New York law. The Second Circuit certified three questions to the New York Court of Appeals concerning the scope of the statute’s requirements. The New York Court of Appeals concluded that social media networks comply with the law if their reporting mechanism and public policy do not explicitly reference or define "hateful conduct," as long as users can report such conduct and learn how reports will be addressed. The court further held that the law does not require networks to respond to reports of hateful conduct. The certified questions were answered accordingly. View "Volokh v James" on Justia Law

Make The Road New York v. Mullin

2026-06-23T07:02:00-08:00

The case concerns a challenge to a 2025 policy by the Department of Homeland Security (DHS) that expanded the use of expedited removal nationwide. Under the new policy, certain noncitizens who lack valid documentation, have not been admitted or paroled, and cannot demonstrate at least two years of continuous presence in the United States are subject to expedited removal. The policy was accompanied by an internal memorandum providing guidance to immigration officers on its implementation. Plaintiffs, including Make the Road New York, alleged that some of their members were subject to removal under this policy and claimed it violated statutory and constitutional rights, specifically the Due Process Clause. The United States District Court for the District of Columbia reviewed the case and granted a stay under 5 U.S.C. § 705, halting the implementation and enforcement of the 2025 Designation and the accompanying memorandum. The district court found that the plaintiffs were likely to succeed on their due process claim, reasoning that the procedures at issue posed a substantial risk of erroneous deprivation of liberty interests for affected noncitizens, and that additional procedural safeguards were warranted. On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s stay. The appellate court held that the district court had jurisdiction, the plaintiffs had standing, and the challenge was timely. However, the D.C. Circuit concluded that the challenged directives did not violate due process under the applicable Mullane standard, which requires procedures reasonably calculated to provide notice and an opportunity to be heard, but not the additional protections the district court required. Finding that the plaintiffs were not likely to succeed on the merits, the D.C. Circuit vacated the district court’s stay. View "Make The Road New York v. Mullin" on Justia Law

Pung v. Isabella County

2026-06-23T06:45:08-08:00

The Pung family owned a home in Isabella County, Michigan, which was their primary residence for decades. After a disputed reassessment, the local tax assessor imposed an additional property tax on the family, even though a Michigan tax tribunal had previously determined that the family owed only the ordinary tax rate. The assessor sent the additional tax bill separately, and the family was unaware of its existence until after the foreclosure deadline. The County initiated foreclosure proceedings for a debt of $2,241.93 and ultimately sold the home, assessed at $194,400, at public auction for $76,008. The County initially kept all sale proceeds. The family challenged the foreclosure and sale in state court, arguing insufficient notice. Although the trial court agreed and set aside the foreclosure, the Michigan Court of Appeals reversed, finding that the County had sufficiently tried to notify the family. The property was lost, and the family later sued in federal court. The United States District Court for the Eastern District of Michigan granted partial summary judgment to the family on their Fifth Amendment claim, ordering the County to return only the surplus proceeds from the sale. The court rejected their Eighth Amendment Excessive Fines Clause claim. The United States Court of Appeals for the Sixth Circuit affirmed, reasoning that the auction price—not the fair market value—was the proper measure of compensation. The Supreme Court of the United States reviewed the case and held that "just compensation" under the Fifth Amendment, following a tax sale, is measured by the auction sale price, not the property’s hypothetical fair market value, provided the sale is fairly conducted in keeping with historical practice. The Court also rejected the claim under the Eighth Amendment, finding no violation of the Excessive Fines Clause. The judgment was vacated and remanded for further proceedings. View "Pung v. Isabella County" on Justia Law

Jackson v. Attorney General

2026-06-23T04:07:41-08:00

Two registered voters in Massachusetts challenged the Attorney General’s certification of an initiative petition designed to overhaul the state’s election system. The petition proposed replacing the existing partisan primaries and separate nomination process for nonparty candidates with a single, all-party primary. In this new system, all candidates, regardless of party affiliation, would appear on one ballot in September, and all voters could vote for any candidate. The two highest vote-getters would advance to the general election, with the option for voters to write in alternative candidates. After the petition was certified by the Attorney General, and sufficient signatures were collected, the measure was transmitted to the House of Representatives by the Secretary of the Commonwealth. As the Legislature did not enact the petition by the required deadline, it became eligible for placement on the statewide ballot, pending the collection of additional signatures. The plaintiffs filed their complaint directly in the Supreme Judicial Court for Suffolk County, seeking to invalidate the Attorney General’s certification on the grounds that the petition contained “excluded matters” under Article 48 of the Massachusetts Constitution, specifically that it was inconsistent with the “freedom of elections” guaranteed by Article 9 of the Massachusetts Declaration of Rights. A single justice reserved and reported the case to the full Supreme Judicial Court. The Supreme Judicial Court of Massachusetts held that the proposed initiative does not significantly interfere with the constitutional rights of voters or candidates, as all candidates still have equal access to the ballot and all voters retain the right to participate fully, including through write-ins. Applying rational basis review, the court found the petition reasonably related to legitimate state interests and affirmed the Attorney General’s certification, remanding for entry of judgment in accordance with its decision. View "Jackson v. Attorney General" on Justia Law