Justia Constitutional Law Opinion Summaries

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In this case, Albert Jackson was alone in a parked car when two officers approached him. The officers boxed him in, shined flashlights on him, and questioned him, while observing that he was wearing a bulky jacket on a hot night and seemed nervous. The officers did not have any reason to suspect criminal activity, but they stopped and detained Jackson due to his behavior. The officers found a gun in Jackson's possession, leading to his arrest. Jackson challenged his arrest, arguing that his detention violated his Fourth Amendment rights. The trial court disagreed and denied his motion to suppress the evidence.The Court of Appeal of the State of California Second Appellate District Division Eight held that the officers' actions amounted to an unjustified detention. The court found that a reasonable person in Jackson's position would not feel free to leave due to the officers' display of authority. The court noted that the officers did not have any specific and articulable facts suggesting that criminal activity was afoot. Wearing a bulky jacket on a hot night, appearing surprised and nervous, and sitting awkwardly in a car do not amount to reasonable suspicion of criminal activity. The court also rejected the prosecution's argument that the area was a high-crime area, stating that the officer's words did not suggest this.The court reversed the judgment, vacated the conviction, and remanded the matter for the trial court to vacate its order denying Jackson’s motion to suppress the evidence and to enter a new order granting that motion. The court concluded that Jackson's detention was invalid and violated the Fourth Amendment. View "People v. Jackson" on Justia Law

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In the case before the Supreme Court of Appeals of West Virginia, the Board of Education of the County of Cabell challenged two state laws that required the Board to include funding for the Cabell County Public Library and the Greater Huntington Park and Recreation District in its excess levy proposals. The Board argued that these laws violated the equal protection guarantees of the West Virginia Constitution because they imposed funding requirements on the Board that were not required of other county boards of education.The court agreed with the Board, finding that the laws did indeed create a discriminatory classification. The court noted that 53 other county boards were free to seek voter approval of excess levy funding without such restrictions. The court could not find a compelling state interest to justify this unequal classification.The court also addressed a second issue related to equalization payments for fiscal years 2024 and 2025. The court concluded that although the Board was required to make annual payments to the Library and the Park District, it was not required to make equalization payments for these fiscal years.The court reversed the lower court's decision and remanded the case with instructions to dismiss the respondents’ Verified Petition for Writ of Mandamus. View "Board of Education v. Cabell County Public Library" on Justia Law

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The United States Court of Appeals For the First Circuit examined a case where the defendant, Derek Gerrish, challenged the constitutionality of a search of his vehicle during his pretrial release on several state criminal charges. During this period, Gerrish was subjected to at least six different bail conditions, five of which allowed for searches of his person, vehicle, or residence at any time without reasonable suspicion. The search in question led to the discovery of fentanyl and other contraband, resulting in Gerrish pleading guilty to possession with intent to distribute fentanyl.Gerrish argued that the search of his vehicle was unconstitutional, despite the terms of his bail conditions. The district court denied his motion to suppress the evidence, citing two reasons: the officers had reasonable suspicion of criminal activity, and Gerrish's bail conditions permitted such a search.On appeal, the defendant argued that both of the district court's reasons were incorrect. The appeals court, however, only focused on the bail condition rationale, as it found it conclusive. The court noted that Gerrish knowingly agreed to bail conditions authorizing searches without suspicion and did not challenge the reasonableness of these conditions. Furthermore, it emphasized that the issue at hand was not the search itself, but the bail conditions that authorized it.The court rejected Gerrish's argument that such bail conditions could not be imposed pre-trial or pre-guilty plea, referring to precedent which stated that acceptance of such conditions significantly diminishes a defendant's reasonable expectation of privacy. It also dismissed Gerrish's claim of a conflict with a Ninth Circuit decision, stating that Maine law requires "least restrictive" bail conditions tailored to the defendant's individual circumstances, thereby eliminating the Ninth Circuit's concerns about mandatory waiver of rights.The judgment of the district court was thus affirmed. View "United States v. Gerrish" on Justia Law

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A private Catholic high school in Madison, Wisconsin, sued the city and other defendants, claiming that the city's decision to deny the school permission to install lights for nighttime athletic events violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Free Exercise Clause of the U.S. Constitution. The school also claimed a vested property right under Wisconsin law.In the United States Court of Appeals for the Seventh Circuit, the school argued that the city's actions amounted to unequal treatment and a substantial burden on its religious exercise. However, the court found that the school, as a master plan institution under the city's Campus-Institutional District ordinance, was not comparably situated to other institutions that had been granted lighting permits. The court also ruled that the city's denial of the permit did not amount to a substantial burden on the school's religious exercise under RLUIPA.Furthermore, the court found that the school's Free Exercise claim provided no additional protections beyond those under RLUIPA and thus could be dismissed. Lastly, the court rejected the school's vested rights claim, as the lighting permit application did not conform to the municipal zoning requirements in effect at the time. Consequently, the court affirmed the lower court's summary judgment in favor of the city. View "Edgewood High School of the Sacred Heart, Incorpor v. City of Madison, Wisconsin" on Justia Law

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In this case, a group of individual donors and two independent-expenditure organizations challenged certain campaign finance regulations enacted in Alaska after voters passed Ballot Measure 2, aimed at shedding light on "dark money" in the state's elections. The plaintiffs argued that these regulations violated their First Amendment rights. The two regulations at issue were: (1) a requirement for individual donors to report contributions exceeding an annual aggregate of $2,000 to an entity making expenditures for a candidate in prior or current election cycles, and (2) a requirement for political advertisements to disclose certain identifying information about donors in any communications intended to influence the election of a candidate.Applying exacting scrutiny, the United States Court of Appeals for the Ninth Circuit held that both regulations were substantially related and narrowly tailored to the government's interest in providing the electorate with accurate, real-time information. This interest was deemed sufficiently important in the campaign finance context. The court dismissed the plaintiffs' arguments that the reporting requirement was duplicative of existing criminal laws and overly burdensome. It also rejected their contention that the disclaimer requirement for political advertisements was unconstitutionally discriminatory against out-of-state speakers.The court concluded that the plaintiffs had not shown that the district court abused its discretion in denying their motion for a preliminary injunction. Therefore, the district court's denial of the preliminary injunction was affirmed. The court, however, did not consider the remaining factors for a preliminary injunction as they were unnecessary for this holding. View "SMITH V. HELZER" on Justia Law

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In Kansas, Miles Loren Martin was convicted of possession of methamphetamine and possession of a controlled substance without a drug-tax stamp. Martin appealed, arguing that these convictions violated constitutional protections against double jeopardy and a Kansas statute prohibiting multiple convictions for the same conduct.The Kansas Supreme Court rejected Martin's argument. It held that possession of methamphetamine and failure to affix a drug-tax stamp were not the same offenses under the Kansas statute, because the former carried a higher penalty than the latter, and because the latter required an element (failure to affix the stamp) not required for the former. Consequently, the legislature had not prohibited multiple punishments for these offenses.The court also held that Martin's convictions did not violate the Double Jeopardy Clauses of the U.S. and Kansas Constitutions. It reasoned that the legislature intended to impose multiple punishments for the offenses because they targeted different conduct (possession of an illegal narcotic versus failure to pay a drug tax) and carried different penalties.On Martin's challenge to the search of his pill bottle, the court found that the search fell within the exception for a search incident to a lawful arrest. The court noted that the officer had a legitimate basis to arrest Martin before the search and that the arrest followed shortly after the search. The court also found that the search of the bottle did not exceed the permissible scope of a search incident to arrest. View "State v. Martin" on Justia Law

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In the case before the Supreme Court of the State of Kansas, the appellant, Gabrielle Griffie, appealed her conviction for unlawful assembly under Wichita Municipal Code of Ordinances (W.M.O.) § 5.73.030(1). The conviction was premised on the City of Wichita's disorderly conduct ordinance, W.M.O. § 5.24.010, which defines disorderly conduct as "one or more of the following acts that the person knows or should know will alarm, anger or disturb others or provoke an assault or other breach of the peace", including "using fighting words or engaging in noisy conduct tending to reasonably arouse alarm, anger or resentment in others."Griffie challenged the constitutionality of the "noisy conduct" provision, arguing it was unconstitutionally overbroad under the First Amendment. Both the district court and the Court of Appeals held the provision constitutional. However, the Supreme Court of the State of Kansas disagreed. Applying the substantial overbreadth doctrine used by Kansas courts to adjudicate First Amendment overbreadth challenges, the court concluded the "noisy conduct" provision within W.M.O. § 5.24.010(c) is unconstitutionally overbroad because it prohibits a substantial amount of protected activity in relation to the provision's plainly legitimate sweep.However, the court found that it was not necessary to strike the entire subsection, as there was a satisfactory method of severing the unconstitutional "noisy conduct" provision from the constitutional "fighting words" provision within the same subsection. Accordingly, the court reversed the judgments of the Court of Appeals and the district court. View "City of Wichita v. Griffie" on Justia Law

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The defendant-appellant, Alex Oliveras, was sentenced to sixty-three months' imprisonment and a three-year supervised release term for possessing cocaine with intent to distribute and possessing a firearm in furtherance of drug trafficking. On appeal, Oliveras challenged the imposition of a special condition of his supervised release that allowed for suspicionless searches by a probation officer.The United States Court of Appeals for the Second Circuit held that the "special needs" doctrine of the Fourth Amendment permits, when sufficiently supported by the record, the imposition of a special condition of supervised release that allows suspicionless searches of the defendant's person, property, vehicle, place of residence, or any other property under their control by a probation officer. However, the court also found that the district court exceeded its discretion in imposing that special condition here. The court explained that the district court failed to make the individualized assessment required to support the special condition under 18 U.S.C. § 3583(d), including a sufficient explanation as to how the condition was reasonably related in this particular case to the applicable statutory factors under 18 U.S.C. § 3553(a) and involved no greater deprivation of liberty than was reasonably necessary under those factors. Therefore, the Court of Appeals vacated the Search Condition and remanded the case to the district court for further consideration of whether it is necessary to impose the Search Condition in this particular case and, if so, for the district court to explain the individualized basis for imposing the Search Condition. View "United States v. Oliveras" on Justia Law

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The case before the Supreme Court of Texas concerned the City of Dallas and the Employees’ Retirement Fund of the City of Dallas. The issue at hand was whether a city ordinance could confer a third party the perpetual right to veto categories of future lawmaking. The Court of Appeals held that the City of Dallas could not amend Chapter 40A of its code of ordinances unless the board of trustees of the Employees’ Retirement Fund agreed to the amendment. However, the Supreme Court of Texas found that such delegation of lawmaking authority was not permissible.The Supreme Court of Texas based its ruling on the principle that a legislative body cannot bind its successors, and on the constitutional principle forbidding the city council from giving away its authority to legislate. The court determined that the board’s veto in § 40A-35(a) was unenforceable and cannot prevent an otherwise valid ordinance from taking effect.However, the court did not resolve whether the City must hold an election that submits § 8-1.5(a-1) to the voters before it can enforce that provision. The court declined to address this question and remanded the case back to the Court of Appeals for further consideration. View "THE CITY OF DALLAS v. THE EMPLOYEES' RETIREMENT FUND OF THE CITY OF DALLAS" on Justia Law

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In the United States Court of Appeals for the Sixth Circuit, Alison Kareem brought a case against the Ohio Secretary of State, the Cuyahoga County Board of Elections, and the Cuyahoga County Prosecuting Attorney. Kareem challenged two Ohio state election laws, which prohibited her from displaying her marked ballot to others as a violation of her First Amendment rights. Kareem refrained from displaying a photograph of her marked ballot online due to these laws. The district court granted summary judgment to the defendants, arguing that Kareem lacked Article III standing.The Appeals Court, however, reversed the district court's order and remanded it for further proceedings. The court held that Kareem had demonstrated a credible threat of enforcement of the Ohio laws, which constituted an injury in fact, a requirement for Article III standing. The court found that Kareem's fear of enforcement, given the possible criminal punishment, the defendants' public statements that displaying marked ballots was illegal, and past instances of enforcement, was not merely subjective or self-imposed. The court also found that Kareem's alleged violation of her First Amendment rights was fairly traceable to the defendants and that the relief she requested was likely to remedy her alleged injury, thus meeting the causation and redressability requirements of Article III standing. The court did not rule on the merits of Kareem's First Amendment claims, leaving that for the district court to decide. View "Kareem v. Cuyahoga County Board of Elections" on Justia Law