Justia Constitutional Law Opinion Summaries

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

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

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

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

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

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

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

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

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

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