Justia Constitutional Law Opinion Summaries

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Defendant was convicted of five sex-related crimes involving minors. When defense counsel returned a few minutes late from a lunch break on the third day of defendant's six-day trial, he missed a small part of the testimony of the 12th of 13 government witnesses. Counsel had missed 7 minutes of a trial that lasted 31.4 hours. In this case, the parties agreed that it was Sixth Amendment error for inculpatory testimony to be taken in the absence of defense counsel. The court held that the harmless error rule was applicable to this brief absence of counsel from the courtroom. The court explained that the error that occurred when the trial resumed before counsel returned from lunch was harmless beyond a reasonable doubt because overwhelming evidence offered while counsel was present went to and proved the charges in Counts 2–5, which were the only counts relevant to the testimony given during counsel's absence; the same questions were repeated and not objected-to after counsel returned to the courtroom; and there was no reasonable doubt that counsel's brief absence was harmless. Accordingly, the court affirmed the judgment. View "United States v. Roy" on Justia Law

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Petitioner, sentenced to death for his involvement in a murder-for-hire, sought a certificate of appealability (COA) to challenge the district court's denial of his habeas petition. The court denied a COA as to the procedural default ruling because the grounds petitioner cited for cause were either not raised in the district court or sought an extension of Martinez/Trevino beyond the realm of ineffective assistance claims for which there was no supporting authority. The court also concluded that petitioner failed to met the COA standard for any of his claims relating to the failure to disclose the circumstances surrounding a codefendant's confession; claims relating to the denial of petitioner's right to present mitigating evidence; claims of error for the trial court to allow the prosecution to introduce evidence of past adjudicated offenses; and a claim that petitioner did not pull the trigger in the victim's murder. Accordingly, the court denied the application of COA. View "Prystash v. Davis" on Justia Law

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Mark Moore and two others filed suit against the Arkansas Secretary of State, challenging certain Arkansas statutes that set the filing deadline for individuals who wish to appear on the general election ballot as independent candidates. Plaintiffs sought a declaratory judgment that the filing deadline is unnecessarily early and thus violates the First and Fourteenth Amendments, as well as 42 U.S.C. 1983. Plaintiffs sought to enjoin the Secretary from enforcing this deadline against Moore. The district court granted the Secretary's motion for summary judgment and denied Moore's motion for reconsideration. The court concluded that the district court correctly noted that the March 1 filing deadline for independent candidates imposes a burden "of some substance" on Moore's First and Fourteenth Amendment rights and that Arkansas has a compelling interest in timely certifying independent candidates for inclusion on the general election ballot. The court concluded, however, that the district court erred in determining that there was no genuine dispute of material fact whether the March 1 deadline is narrowly drawn to serve that compelling interest. In this case, there exists a genuine factual dispute whether the verification of independent candidate petitions would conflict with the processing of other signature petitions under the former May 1 deadline. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Moore v. Martin" on Justia Law

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In 2009, Appellant was convicted of aggravated kidnapping and sexual intercourse without consent. In 2011, Appellant filed a complaint against certain participants in his 2009 criminal trial, alleging that the victim unlawfully taped a conversation between the victim and Appellant, and the taping and subsequent use of the taped conversation by Defendants violated his constitutional rights under the Fourth Amendment and the federal wiretap statute. The federal magistrate dismissed the complaint with prejudice for failure to state a claim. A federal district court judge affirmed. Appellant then filed a complaint in a Montana district court, alleging that the victim had recorded their telephone conversation and Defendants had used the taped conversation in violation of Montana’s privacy in communications state and his state and federal constitutional rights. The district court granted summary judgment to Defendants, concluding that Appellant’s case was barred by the statute of limitations and the doctrine of res judicata. The court also declared Appellant a vexatious litigant and imposed a pre-filing order on him. The Supreme Court affirmed, holding that the district court (1) properly applied the statute of limitations and doctrine of res judicata, and (2) did not abuse its discretion in finding Appellant to be a vexatious litigant and imposing a pre-filing order. View "Belanus v. Potter" on Justia Law

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In 2015 Appellant Gabriel Pardo was convicted of Manslaughter, Leaving the Scene of a Collision Resulting in Death (LSCRD), Reckless Driving, and six counts of Endangering the Welfare of a Child. The charges arose from his involvement in a fatal hit-and-run collision with a bicyclist, Phillip Bishop, in 2014. The principal issue raised in this appeal was whether Pardo’s conviction for LSCRD violated his Due Process rights, as he contends that the LSCRD statute imposes strict liability. Pardo also contended that the Superior Court erred by adding a voluntary intoxication instruction to the pattern jury instruction for manslaughter, by denying his motion for judgment of acquittal, and by denying his request for a missing evidence instruction. The Supreme Court concluded that the statute governing LSCRD did not impose strict liability because it required the State to prove beyond a reasonable doubt that a defendant had knowledge that he or she was involved in a collision. Because the Court found Pardo’s other arguments without merit, it affirmed his conviction and sentence. View "Pardo v. Delaware" on Justia Law

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This case involved an appeal from a district court judge’s denial of relief in a pre-trial application for writ of habeas corpus. Appellant was under indictment for three charges of aggravated sexual assault of a child, and, in a consolidated trial, a jury had found him guilty of those offenses. Having elected to go to the jury for punishment, Appellant chose to testify. When he stood to approach the witness stand, it became apparent to the jury that he was shackled. Appellant asked for a mistrial, and the trial court took that request under advisement, meanwhile allowing the punishment proceedings to continue. After Appellant had testified on direct-examination, and following brief cross-examination by the State, the trial court interrupted the proceedings to announce that it had decided to grant a mistrial, but only as to the punishment phase of trial. Before the trial court was able to empanel a new jury to assess punishment, however, Appellant filed a combined application for writ of habeas corpus and motion to reinstate his pre-trial bond. He argued that, by granting a mistrial, the trial court had necessarily restored the cases to their pre-trial status, and that he should therefore be released on bond pending trial. The trial court denied both the writ application and the motion. On appeal from denial of the writ application, the court of appeals sustained Appellant’s claim. In an unpublished opinion, it reversed the order denying habeas relief and remanded the cases to the trial court presumably to retry them from scratch, including a new guilt phase of trial. The Court of Criminal Appeals granted the State’s petition for discretionary review to address the question whether, under the present bifurcated system, when irremediable error or misconduct occurs during a jury trial, but not until the punishment phase, trial courts should have the authority to grant a mistrial as to the punishment phase of trial only. The Court reversed the court of appeals and remanded for further proceedings. View "Ex parte Pete" on Justia Law

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Appellant was charged with aggravated sexual assault of a child and indecency with a child by sexual contact. Appellant waived his right to a jury trial and pleaded not guilty at a bench trial to the charges. Appellant filed a motion for new trial alleging ineffective assistance of counsel on the basis that his trial counsel had erroneously promised him that he would receive probation if he was found guilty by the trial court. This advice was erroneous because, under the former law that applied to appellant’s offenses that were committed in 2001, only a jury could recommend a probated sentence if he was found guilty of the offenses. The issue this case presented centered on the standard courts should employ for assessing whether a defendant was prejudiced from his attorney’s deficient performance with respect to the defendant’s decision to waive a jury trial in favor of a bench trial. The Court of Criminal Appeals found two possible alternatives for the prejudice standard in this type of case: (1) a court could consider solely how the deficient performance affected the defendant’s decision to waive the jury; or (2) a court could consider the totality of the record so that the deficient performance is gauged against how it affected the outcome of the proceedings by comparing the outcome of the bench trial that actually did occur with the probable outcome of the jury trial that did not occur. In his sole ground in his petition for discretionary review, Appellant argued the Court of Criminal Appeals should employ the first alternative. The Court concluded, however, that the second alternative appropriately applied here. The court of appeals properly determined that appellant was not prejudiced by counsel’s erroneous advice. Accordingly, the Court of Criminal Appeals affirmed the court of appeals’ judgment. View "Miller v. Texas" on Justia Law

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The issue presented for the Supreme Court’s review in this case centered on whether the Pennsylvania Board of Probation and Parole (the “Board”) abused its discretion if it fails to consider whether to grant a convicted parole violator (“CPV”) credit for time spent at liberty on parole. Also for consideration was whether the Board had to provide a contemporaneous statement explaining the rationale behind its decision to grant or deny credit to a CPV. In 2010, following his guilty plea to possession with intent to deliver (“PWID”), Appellant was sentenced to two to four years of imprisonment, with a maximum sentence date of December 9, 2013. On December 12, 2011, the Board released Appellant on parole. In 2013, while still on parole, Appellant was arrested and charged with various criminal offenses. He ultimately pled guilty to PWID and was sentenced to one to three years of imprisonment. Appellant subsequently waived his right to a parole revocation hearing and admitted that he violated his parole by committing a crime. The Board accepted Appellant’s admission and recommitted him in accord with his original 2011 sentence. The Supreme Court held that the Board abuses its discretion in failing to consider whether to grant CPVs credit for time spent at liberty on parole under the plain language of Subsection 6138(a)(2.1) of the Parole Code, 61 Pa.C.S. sec. 6138(a)(2.1). Additionally, in order to effectuate the intent of the General Assembly in enacting Subsection 6138(a)(2.1), the Court held that the Board must provide a contemporaneous statement explaining its rationale for denying a CPV credit for time spent at liberty on parole. In this case, because the Board’s decision to deny Appellant such credit was based upon its erroneous belief that Appellant was automatically precluded from receiving credit under Subsection 6138(a)(2.1), the Board abused its discretion. View "Pittman v. PA Board of Prob. & Parole" on Justia Law

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Appellant Raghunandan Yandamuri, acting pro se, appealed the two death sentences he received after a jury convicted him of two counts of first-degree murder and related offenses for the kidnapping of a ten-month-old baby and the murders of the baby and her grandmother. After reviewing the trial court record, the Pennsylvania Supreme Court concluded the sentence imposed was not the product of passion, prejudice or any other arbitrary factor, but rather was based on the evidence presented at trial. Furthermore, the Court concluded the evidence supported at least one aggravating circumstance for each of the murders committed. The judgment of sentence was therefore affirmed. View "Pennsylvania v. Yandamuri" on Justia Law

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After a jury trial, Appellant was convicted of two counts of murder in the first degree for shooting and killing two deputies. Appellant was sentenced to death. Appellant’s convictions were affirmed on direct appeal. Thereafter, the motion court granted Appellant post-conviction relief and remanded the case for a new penalty phase. After the penalty phase retrial, the jury recommended that Appellant be sentenced to death on each count. The trial court sentenced Appellant in accordance with the jury’s recommendation. Appellant’s death sentences were affirmed on direct appeal. Appellant then filed a Mo. R. Crim. P. motion for post-conviction relief, alleging several claims of ineffective assistance of trial and appellate counsel. The motion court overruled the motion. The Supreme Court affirmed, holding that the motion court did not clearly err in finding that Appellant failed to establish that he was provided ineffective assistance of trial or appellate counsel. View "Tisius v. State" on Justia Law