Justia Constitutional Law Opinion Summaries

In June 2022, Karen Read was indicted for murder in Massachusetts. She pled not guilty, and the trial in Norfolk County Superior Court ended in a mistrial due to a non-unanimous jury verdict. The case attracted significant public attention and demonstrators gathered near the courthouse. The demonstrators' behavior, including loud protests and displaying materials directed at trial participants, raised concerns about the fairness of the trial.The state court issued an order creating a 200-foot buffer zone around the courthouse to prevent demonstrations during the trial. This order was challenged in state court but upheld by the Massachusetts Supreme Judicial Court. Before the retrial, the Commonwealth sought a broader order, which the state court granted, expanding the buffer zone to include additional areas around the courthouse. This new order was based on evidence of disruptions during the first trial, including noise from demonstrators that could be heard by jurors.A group of demonstrators filed for a preliminary injunction in the District of Massachusetts to challenge the expanded buffer zone. The district court denied the motion, finding that the order was likely narrowly tailored to serve a significant governmental interest. The plaintiffs then appealed to the United States Court of Appeals for the First Circuit.The First Circuit noted that the plaintiffs clarified they did not challenge the order as applied to courthouse property or seek to engage in noisy protests. They only sought to demonstrate quietly on public property without interfering with trial participants. The court vacated the district court's denial of the preliminary injunction and remanded the case for further proceedings to determine if the order's lack of a mens rea requirement rendered it insufficiently tailored. The court suggested that the state court could amend the order to include a mens rea requirement to address the First Amendment concerns. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law

The case involves the appellant, Gregory Smith, challenging the Municipality of Anchorage's decision to abate unauthorized campsites in Davis Park. The Anchorage Municipal Code (AMC) outlines procedures for campsite abatement, including posting a notice and allowing for an appeal to the superior court. In June 2022, the Municipality posted a notice in Davis Park, advising that the area was not legal for storage or shelter and that any personal property would be removed and disposed of as waste after ten days. Smith and five others appealed the abatement, arguing it violated due process and the Eighth Amendment.The superior court dismissed the appeal, agreeing with the Municipality that its jurisdiction was limited to reviewing the legal sufficiency of the posted notice, not the abatement decision itself. The court noted that the appellants did not challenge the notice's compliance with the Code, thus leaving no issues for the court to decide. The court also observed that the appellants' claims were not without merit and suggested that a civil suit could address their concerns.The Supreme Court of the State of Alaska reviewed the case and concluded that the superior court's jurisdiction was not limited to the notice's legal sufficiency. The court held that the superior court has jurisdiction to review the substantive decision to abate the campsite, including constitutional challenges. The court reversed the superior court's decision and remanded the case for further consideration of the constitutional issues raised by Smith. The court also directed the superior court to determine if the administrative record was sufficient for meaningful appellate review and to take necessary steps to ensure it has an adequate record. View "Smith v. Municipality of Anchorage" on Justia Law

Yako Collins was convicted of first-degree sexual assault in 2009 and sentenced to 25 years with five years suspended. Collins requested referral to a three-judge sentencing panel, arguing that his lack of significant criminal history and good character warranted a sentence outside the presumptive range. The superior court denied his request, and Collins appealed.The Alaska Court of Appeals in Collins I identified two non-statutory mitigating factors that could justify referral to the three-judge panel: the defendant's lack of a history of unprosecuted offenses and normal prospects for rehabilitation. The court remanded the case to the superior court for reconsideration. While the case was pending, the Alaska Legislature amended the relevant statutes in 2013, explicitly rejecting these mitigating factors as standalone bases for referral. The superior court, applying the amended statutes, affirmed Collins's original sentence, and Collins appealed again.In Collins II, the Court of Appeals concluded that the 2013 legislative amendments merely clarified existing law and did not violate the ex post facto clause. The court held that Collins could not seek referral to the three-judge panel based solely on the factors identified in Collins I but could argue for referral based on the totality of circumstances.The Alaska Supreme Court reviewed the case and held that the 2013 amendments could not be applied retroactively to Collins, as they were substantive changes to the law. The court emphasized the separation of powers and the prohibition on ex post facto laws, concluding that the legislature could not retroactively overrule a binding judicial interpretation. The case was remanded to the Court of Appeals to determine whether the 2013 amendments were procedural or substantive. View "Collins v. State of Alaska" on Justia Law

Mohsen Mahdawi, a Lawful Permanent Resident and undergraduate student at Columbia University, was arrested during his naturalization interview in Vermont. He was detained and served with a Notice to Appear, indicating that the U.S. Secretary of State had determined he was removable under the Immigration and Nationality Act. Mahdawi filed a habeas petition, claiming his arrest and detention were in retaliation for his advocacy on the war in Gaza, violating his First and Fifth Amendment rights. The district court issued a temporary restraining order (TRO) preventing his removal from Vermont and later granted his release on bail, finding he was neither a flight risk nor a danger to the community.The United States District Court for the District of Vermont initially granted Mahdawi’s emergency motion for a TRO and later extended it. The court also granted his motion for release on bail pending the resolution of his habeas petition. The government sought an emergency stay of these orders, arguing that the district court lacked jurisdiction over Mahdawi’s habeas petition and the authority to order his release.The United States Court of Appeals for the Second Circuit reviewed the case and denied the government’s motion for a stay. The court found that the government was unlikely to succeed on its arguments that the district court lacked jurisdiction over Mahdawi’s habeas petition and the authority to order his release. The court also concluded that the government had not demonstrated irreparable injury and that the balance of equities tipped in favor of denying the stay. Consequently, the government’s motion for a stay and request for a writ of mandamus were both denied. View "Mahdawi v. Trump" on Justia Law

In this case, Jae Michael Bernard was convicted of unlawful possession of a firearm by a person convicted of a misdemeanor crime of domestic violence. Bernard had a prior conviction in 2002 for domestic abuse assault causing injury. In September 2021, investigators found firearms and ammunition at his residence. Bernard pleaded guilty in June 2022 but later moved to withdraw his plea and dismiss the indictment, arguing that 18 U.S.C. § 922(g)(9) is unconstitutional under the Second Amendment.The United States District Court for the Northern District of Iowa denied Bernard's motion to dismiss the indictment. Bernard then entered a conditional guilty plea, reserving his right to appeal the denial of his motion. The district court sentenced him to thirty-seven months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Bernard's appeal was based on a facial challenge to the constitutionality of § 922(g)(9). The court noted that a facial challenge requires showing that no set of circumstances exists under which the statute would be valid. The court held that § 922(g)(9) is consistent with the historical tradition of firearm regulation, which allows disarming individuals who present a credible threat to the physical safety of others. The court found that the statute is constitutional in at least some of its applications, as it targets individuals convicted of crimes involving actual or attempted violence or the threatened use of a deadly weapon.The Eighth Circuit affirmed the district court's judgment, concluding that § 922(g)(9) is not unconstitutional on its face. View "United States v. Bernard" on Justia Law

Two property owners in the extraterritorial jurisdiction (ETJ) of College Station, Texas, challenged city ordinances regulating off-premise signage and driveway construction. They argued that these regulations, imposed without granting them the right to vote in city elections, violated the Texas Constitution's requirement for a "republican form of government." The plaintiffs sought a declaration that the ordinances were void and unenforceable.The trial court dismissed the case with prejudice, agreeing with the City that the form of local government is a political question for the legislature, not the courts. The plaintiffs appealed, but while the appeal was pending, the legislature amended the law to allow ETJ residents to unilaterally opt out of a city's ETJ. The Court of Appeals for the Sixth District of Texas affirmed the trial court's dismissal, not addressing the new statutory opt-out provision.The Supreme Court of Texas reviewed the case and determined that the legislative change provided a nonjudicial remedy that could moot the plaintiffs' constitutional claims. The court vacated the lower court judgments and remanded the case to the trial court with instructions to abate the proceedings, allowing the plaintiffs a reasonable opportunity to complete the opt-out process. The court emphasized the importance of judicial restraint and constitutional avoidance, noting that the new law offered a means of relief that should be pursued before addressing broader constitutional questions. View "ELLIOTT v. CITY OF COLLEGE STATION, TEXAS" on Justia Law

In the fall of 2021, the League of United Latin American Citizens of Iowa (LULAC) filed a petition against the Iowa Secretary of State, the Iowa Voter Registration Commission, and several county auditors. LULAC challenged a 2008 permanent injunction from a different case, which prohibited the dissemination of voter registration forms in languages other than English under the Iowa English Language Reaffirmation Act. LULAC argued that the injunction was wrongly decided and sought its dissolution, along with a declaration that the Act allowed for non-English voting materials.The Iowa District Court for Polk County granted LULAC’s requests, dissolving the King injunction and issuing a declaratory judgment that the Act did not apply to voting materials. The court held that voting materials were necessary to secure the right to vote and thus fell within the rights exception of the Act.The Iowa Supreme Court reviewed the case and focused on the issue of standing. The court concluded that LULAC lacked standing to challenge the King injunction and the Secretary of State’s interpretation of the law. The court reasoned that LULAC’s general interest in the proper interpretation and enforcement of the law, as well as its resource diversion in response to the injunction, did not constitute a legally cognizable injury. The court emphasized that standing requires a specific personal or legal injury, which LULAC failed to demonstrate. Consequently, the Iowa Supreme Court reversed the district court’s decision and remanded the case for dismissal. View "League of United Latin American Citizens of Iowa v. Iowa Secretary of State" on Justia Law

In 1995, Glen Edward Rogers murdered Tina Marie Cribbs in Hillsborough County, Florida. Rogers was convicted of first-degree murder, armed robbery, and grand theft of a motor vehicle. He was sentenced to death, and his conviction and sentence were affirmed on direct appeal. Rogers has since filed multiple postconviction motions, all of which have been denied.Rogers' fourth successive postconviction motion raised three claims: (1) he was unconstitutionally deprived of the right to challenge his conviction and sentence due to a conflict of interest with his counsel, (2) newly discovered evidence of his childhood sexual abuse and trafficking would result in a life sentence on remand, and (3) Florida’s lethal injection procedures are cruel and unusual due to his porphyria diagnosis. The postconviction court summarily denied these claims as untimely, procedurally barred, and/or meritless.The Supreme Court of Florida reviewed the case and affirmed the postconviction court's denial. The court found that Rogers' conflict-of-counsel claim was procedurally barred and without merit, as there was no actual conflict of interest. The newly discovered evidence claim was also found to be procedurally barred and meritless, as the evidence could have been discovered with due diligence. Lastly, the court held that Rogers' method-of-execution claim was untimely and meritless, as he failed to demonstrate that Florida’s lethal injection protocol would cause him substantial and imminent risk of serious illness and needless suffering, and he did not identify a viable alternative method of execution.The Supreme Court of Florida denied Rogers' motion for a stay of execution and his request for oral argument, affirming the summary denial of his fourth successive postconviction motion. View "Rogers v. State" on Justia Law

In June 2020, the North Dakota Department of Health inspected ND Indoor RV Park, LLC and found several health, safety, and fire code violations. The Park was informed that its 2020 operating license would be revoked unless the violations were corrected. The Park did not address the violations, leading to the initiation of the license revocation process. The Park also requested a renewal of its license for 2021, which was denied due to the existing violations. The Park was allowed to operate until the hearing proceedings were final. The Park later withdrew its request for a hearing, and the Department of Health dismissed the renewal application and closed the case. Subsequently, the Park sold its property.The Park filed a complaint against the State of North Dakota, alleging regulatory taking, deprivation of substantive and procedural due process, inverse condemnation, unlawful interference with business relationships, systemic violation of due process, and estoppel. The State moved for judgment on the pleadings, claiming qualified immunity for individual defendants and lack of subject matter jurisdiction on the takings claims. The district court denied the State’s motion for summary judgment on the takings and due process claims but granted summary judgment on the unlawful interference claim. The remaining claims were dismissed by stipulation.The North Dakota Supreme Court reviewed the case. The court granted a writ of supervision, directing the district court to dismiss counts II and III because the individual defendants were entitled to qualified immunity. The court also directed the dismissal of counts I and IV for lack of subject matter jurisdiction, as the Park failed to exhaust administrative remedies. The court concluded that the Park could not prevail on its substantive and procedural due process claims and that the district court lacked jurisdiction over the takings claims. View "ND Indoor RV Park v. State" on Justia Law

AstraZeneca Pharmaceuticals LP and AstraZeneca AB challenged the Drug Price Negotiation Program created by the Inflation Reduction Act of 2022, which directs the Centers for Medicare & Medicaid Services (CMS) to negotiate prices for certain high-expenditure drugs. CMS issued guidance on selecting qualifying drugs for 2026, including Farxiga, manufactured by AstraZeneca. AstraZeneca sued the Secretary of the Department of Health and Human Services and the CMS Administrator, claiming the Negotiation Program violated procedural due process and that parts of CMS’s guidance violated the Administrative Procedure Act (APA).The United States District Court for the District of Delaware ruled that AstraZeneca failed to state a due process violation and lacked standing to pursue its APA claims. The court entered judgment in favor of the government.The United States Court of Appeals for the Third Circuit reviewed the case. The court found that AstraZeneca lacked Article III standing to challenge the CMS guidance under the APA because the company did not demonstrate a concrete and particularized injury. AstraZeneca's claims about the impact on its business decision-making and difficulty valuing Farxiga in negotiations were deemed hypothetical and conjectural.Regarding the due process claim, the court held that AstraZeneca did not have a protected property interest in selling its drugs at a market rate. The court noted that federal patent laws do not confer a right to sell at a particular price, and the Negotiation Program only sets prices for drugs reimbursed by CMS, not private market transactions. Consequently, the court affirmed the District Court’s judgment, granting summary judgment in favor of the government on both the APA and due process claims. View "AstraZeneca Pharmaceuticals LP v. Secretary United States Department of Health and H" on Justia Law