Justia Constitutional Law Opinion Summaries
Montanans Securing Reproductive Rights v. Knudsen
In this case, petitioners Montanans Securing Reproductive Rights and Samuel Dickman, M.D., sought a declaratory judgment on original jurisdiction against the Montana Attorney General and the Montana Secretary of State. The petitioners argued that the Attorney General wrongly determined that their proposed ballot issue was legally insufficient, had no authority to attach a fiscal statement to the ballot issue, and that their ballot statements complied with Montana Code Annotated sections 13-27-212 and -213.The Supreme Court of Montana held that the Attorney General did err in concluding that the proposed ballot issue was legally insufficient, as it did not violate the separate-vote requirement of Article XIV, Section 11, of the Montana Constitution. The proposal effects a single change to the Montana Constitution on a single subject: the right to make decisions about one's own pregnancy, including the right to abortion.The court also found that the Attorney General exceeded his authority by appending a fiscal statement to the proposed ballot issue because the budget director's fiscal note did not indicate that the issue would have a fiscal impact.Finally, the court declined to rule on the compliance of the petitioners’ ballot statements with Montana Code Annotated sections 13-27-212 and -213, directing the Attorney General to prepare a ballot statement in line with statutory requirements and forward it to the Montana Secretary of State.The court essentially concluded that the proposed ballot issue was legally sufficient and did not require separate votes for its multiple components, as they were all closely related to the central issue of reproductive rights. The court also confirmed that the Attorney General had overstepped his authority by attaching a fiscal statement to the ballot issue. View "Montanans Securing Reproductive Rights v. Knudsen" on Justia Law
Garrick v. Moody Bible Institute
The case involves Janay Garrick, a former instructor at Moody Bible Institute, who alleged sex discrimination and other Title VII violations. Garrick claimed that she was subjected to hostile treatment due to her gender and the Institute's religious beliefs. Moody argued that her suit was barred by Title VII’s religious exemptions and the First Amendment doctrine of church autonomy. The district court denied Moody's motion to dismiss in part, leading to Moody's appeal.However, the United States Court of Appeals for the Seventh Circuit dismissed the appeal for lack of jurisdiction. The court reasoned that it could only review a small class of interlocutory orders under the collateral order doctrine, and Moody's appeal did not fit within this class. The court found that the district court's denial of Moody's motion to dismiss was not conclusive, did not resolve important questions separate from the merits of the case, and would not effectively be unreviewable on appeal from a final judgment.The appellate court also emphasized that Moody's defense, based on the doctrine of church autonomy, was not separate from the merits of Garrick's gender discrimination claims. Furthermore, the court noted that Moody's argument that it would experience irreparable harm without immediate review was unavailing, as the district court could limit discovery to instances of discriminatory treatment not implicated by Moody's religious beliefs. The court concluded that religious autonomy to shape and control doctrine would not be threatened by the further progression of Garrick's lawsuit. View "Garrick v. Moody Bible Institute" on Justia Law
United States v. Alvarado
The case involved Ricardo Alvarado, who was convicted of possessing a firearm as a felon under 18 U.S.C. § 922(g)(1). His crime was reported by officers who responded to a call that a man was carrying what appeared to be a machine gun in a mobile home park. Alvarado was found with a Ruger AR-556 semi-automatic rifle, and upon investigation, officers discovered that he had two prior felony convictions. He was sentenced to 104 months' imprisonment, including a four-level sentencing enhancement for reckless endangerment.Alvarado appealed his conviction and sentence. He contended that his conviction violated the Second Amendment based on the standard articulated in New York State Rifle & Pistol Ass’n v. Bruen, an issue he raised for the first time on appeal. He also argued that the evidence did not support a sentencing enhancement for reckless endangerment.The United States Court of Appeals for the Sixth Circuit affirmed Alvarado’s conviction but vacated his sentence and remanded the case to the district court for resentencing. The court found that the constitutionality of § 922(g)(1) under Bruen was subject to reasonable dispute and would not disturb Alvarado’s conviction on plain error review. However, the court found that the district court erred in applying a sentencing enhancement for reckless endangerment. Without record evidence of anyone in proximity to Alvarado’s line of fire, or otherwise facing an imminent risk of harm, the Government could not satisfy Tennessee’s zone of danger requirement. Consequently, Alvarado's sentence was vacated. View "United States v. Alvarado" on Justia Law
United States v. Garcia
The United States Court of Appeals for the Ninth Circuit affirmed the constitutionality of a pretrial release condition that temporarily barred two defendants from possessing firearms pending trial. The defendants, Jesus Perez-Garcia and John Thomas Fencl, were charged with various felony offenses. The district courts imposed a condition barring them from possessing firearms as part of their pretrial release, arguing that the restriction was necessary for public safety. The defendants appealed, arguing that this condition infringed on their Second Amendment rights.The Ninth Circuit disagreed, finding that the firearm condition was constitutional. The court reasoned that the Bail Reform Act of 1984's firearm condition on pretrial release is consistent with how courts have historically balanced the constitutional rights of pretrial detainees with public safety considerations. The court also pointed out that the nation has a long history of temporarily disarming criminal defendants facing serious charges and those deemed dangerous or unwilling to follow the law. Therefore, the court held that the temporary disarmament of the defendants was justified by this historical tradition. View "United States v. Garcia" on Justia Law
Goldstein v. Professional Staff Congress/CUNY
Six full-time professors at the City University of New York filed a lawsuit challenging New York’s Public Employees’ Fair Employment Act, known as the Taylor Law, alleging it violated their First Amendment rights to free speech and association. The professors argued that the law unfairly compelled them to be part of a bargaining unit represented exclusively by the Professional Staff Congress/CUNY (PSC), despite their vehement disagreement with PSC's political views, specifically on issues related to Israel and Palestine. They also challenged a specific section of the Taylor Law which allows PSC to decline representation of non-union employees in certain proceedings.The defendants filed motions to dismiss the claims, which were granted by the United States District Court for the Southern District of New York. The professors appealed, but the United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The appellate court agreed with the district court that the professors' claims were foreclosed by the Supreme Court’s decision in Minnesota State Board for Community Colleges v. Knight, and that the professors failed to allege that the contested section of the Taylor Law violates the First Amendment. Thus, the court concluded that the PSC's exclusive representation of the professors in collective bargaining did not violate the First Amendment, and that the limited fiduciary duty imposed by the contested section of the Taylor Law did not burden their First Amendment rights. View "Goldstein v. Professional Staff Congress/CUNY" on Justia Law
State v. Glaum
The Supreme Court of North Dakota affirmed the district court's decision in a case involving Defendant Joseph Glaum, who appealed an amended criminal judgment and the denial of his request to withdraw his conditional guilty pleas. Glaum claimed that the court had abused its discretion in denying his request to withdraw his pleas, arguing that the court had misapplied the factors for considering a motion to withdraw a guilty plea under N.D.R.Crim.P. 11. He also made claims of ineffective assistance of counsel and asserted that the six issues preserved for appeal by his conditional pleas were wrongly decided by the court.The court found that the district court did not abuse its discretion in weighing the factors outlined in State v. Lium, and did not clearly err in determining that Glaum did not meet his burden to show a fair and just reason to withdraw his conditional guilty pleas. The court also concluded that the record was inadequate to determine Glaum’s ineffective assistance of counsel claims.Glaum further argued that his right to a speedy trial under the federal constitution was violated. The court applied the balancing test announced in Barker v. Wingo to evaluate this claim, considering the accused’s assertion of his right to a speedy trial, the length of the delay, the reason for the delay, and whether there was any prejudice to the accused. Upon balancing these factors, the court found that Glaum had not shown a violation of his right to a speedy trial under the Sixth Amendment to the United States Constitution.Finally, the court affirmed the district court's decision to grant the State’s motion to amend the information and denied Glaum’s motion for continuance, finding that the court did not act in an arbitrary, unreasonable, or unconscionable manner, or misinterpret or misapply the law. View "State v. Glaum" on Justia Law
People v. Jackson
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
Board of Education v. Cabell County Public Library
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
United States v. Gerrish
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
Edgewood High School of the Sacred Heart, Incorpor v. City of Madison, Wisconsin
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