Justia Constitutional Law Opinion Summaries

The defendant was arrested on October 2, 2021, for misdemeanor driving under the influence and was released after signing a citation promising to appear in court on December 14, 2021. The Riverside County District Attorney filed a misdemeanor complaint on November 17, 2021. The defendant failed to appear on the scheduled date, resulting in a bench warrant for her arrest. After a subsequent stop and another citation, she failed to appear again, leading to another bench warrant. In March 2024, the defendant voluntarily contacted the court, had her matters calendared, and pled not guilty. She later filed a motion to dismiss, arguing her Sixth Amendment right to a speedy trial had been violated due to delays.The Riverside County Superior Court denied the motion, finding the defendant’s own failures to appear contributed to the delay. The defendant then sought review by petitioning the Appellate Division of the Riverside County Superior Court. The Appellate Division, in a divided opinion, held that the prosecution’s failure to file a formal complaint within 25 days as required by Penal Code section 853.6 deprived the trial court of personal jurisdiction and automatically relieved the defendant of any obligation to appear. Based on this, it ordered the trial court to vacate its order and reconsider the motion to dismiss.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the Appellate Division’s decision. It held the lower court had abused its discretion by misinterpreting Penal Code section 853.6. The Court of Appeal clarified that the failure to file charges within 25 days did not relieve a defendant of the obligation to appear or deprive the court of personal jurisdiction. The appellate court issued a writ directing the Appellate Division to vacate its opinion and reconsider the defendant’s writ petition consistent with this interpretation. View "People v. Superior Ct." on Justia Law

The plaintiffs in this case are the sons of Roberto Clemente, a renowned Puerto Rican baseball player, and two corporations they control. The dispute centers on the Commonwealth of Puerto Rico’s use of Clemente’s name and image on commemorative license plates and vehicle registration tags. Proceeds from these items were designated to fund a new “Roberto Clemente Sports District,” a public project that would replace an earlier initiative, Ciudad Deportiva, originally founded by Clemente. The plaintiffs allege that they hold trademark rights in Clemente’s name and that the Commonwealth’s actions were unauthorized and caused public confusion, with many mistakenly believing the Clemente family benefited financially from the program.The plaintiffs brought suit in the United States District Court for the District of Puerto Rico against the Commonwealth, several high-ranking officials, and the Puerto Rico Convention Center District Authority. Their claims included trademark infringement, false association, false advertising, and trademark dilution under the Lanham Act, as well as a takings claim under the Fifth and Fourteenth Amendments. The Commonwealth and the Authority moved to dismiss, arguing sovereign and qualified immunity and failure to state a claim. The district court granted both motions, dismissing all federal claims on immunity and merits grounds, and declined to exercise jurisdiction over non-federal claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court affirmed the dismissal of all claims against the Authority and all claims against the Commonwealth and its officials in their official capacities. It also affirmed dismissal of the false advertising and takings claims. However, the court vacated the dismissal of the Lanham Act claims for trademark infringement, false endorsement, and dilution against the Commonwealth officials in their personal capacities, holding those claims were plausibly alleged and not barred by qualified immunity at this stage, and remanded for further proceedings. View "Clemente Properties, Inc. v. Pierluisi-Urrutia" on Justia Law

Diamond Sands Apartments, LLC owns and operates a 360-unit apartment complex in Las Vegas, Nevada, where units are leased for long-term stays under agreements prohibiting unauthorized subletting. Clark County received numerous complaints regarding short-term rentals in certain units, which included disturbances such as loud parties. The County investigated and verified that some units were being rented for short-term stays through Airbnb. After notifying Diamond Sands of the violations and conducting follow-up inspections, the County issued two administrative citations assessing $2,000 fines for each violation, as permitted under its ordinance, which prohibits unauthorized short-term rentals and allows for fines between $1,000 and $10,000 per violation.Diamond Sands filed suit in the United States District Court for the District of Nevada, raising facial and as-applied challenges to the County’s ordinance under the Eighth Amendment’s Excessive Fines Clause. The company sought declaratory and injunctive relief, arguing that the ordinance unconstitutionally penalized property owners for short-term rental activity conducted by tenants. The district court denied Diamond Sands’ motion for a preliminary injunction, finding that the fines were not grossly disproportionate to the gravity of the violations and that Diamond Sands had not demonstrated a likelihood of success on the merits.The United States Court of Appeals for the Ninth Circuit reviewed the denial of the preliminary injunction for abuse of discretion and underlying legal issues de novo. The court held that the district court did not abuse its discretion, finding that Diamond Sands bore some culpability due to its knowledge and failure to prevent ongoing violations. The fines imposed were at the low end of the authorized range, and the ordinance aimed to deter harm to residents. The court also determined that Diamond Sands had not shown the ordinance was unconstitutional in every application. Therefore, the Ninth Circuit affirmed the district court’s denial of the preliminary injunction. View "DIAMOND SANDS APARTMENTS, LLC V. CLARK COUNTY NEVADA" on Justia Law

In 2002, an individual disappeared from her home in Ada, Oklahoma, and her ex-boyfriend quickly became a suspect. Evidence implicating him included his presence at her home, strange phone calls to her family, and physical injuries. Law enforcement discovered blood in his car and house, and, after consulting with his attorney, he led officers to the woman’s body, which was buried and showed signs of gunshot wounds. He subsequently pleaded guilty to murder in Oklahoma state court and was sentenced to life without parole.Many years later, following the Supreme Court’s ruling in McGirt v. Oklahoma, which clarified that certain areas in Oklahoma are Indian country and subject to federal—not state—jurisdiction for major crimes involving Native Americans, the state court vacated his conviction. As a member of a federally recognized tribe and with the crime occurring within the Chickasaw Nation Reservation, only the federal government could prosecute him. A federal grand jury indicted him for murder in Indian country and for causing death while violating federal firearm statutes. The United States District Court for the Eastern District of Oklahoma dismissed one firearm count as time-barred, and a jury convicted him on the remaining counts.On appeal, the United States Court of Appeals for the Tenth Circuit considered three main arguments: (1) alleged failures in the jury selection process under the Jury Selection and Service Act, (2) denial of a motion to suppress statements about the location of the victim’s body, and (3) denial of a motion to compel disclosure of communications between the government and former defense counsel. The Tenth Circuit held that the defendant failed to comply with the procedural requirements for challenging jury selection, that Rule 410 of the Federal Rules of Evidence did not apply to his statements to law enforcement, and that any error in denying document disclosure was harmless. The convictions were affirmed. View "United States v. Mullins" on Justia Law

In this case, the defendant was convicted in 1993 of multiple violent sex offenses. Many years later, he filed a pro se motion in 2023, arguing that the district court had ordered a psychological evaluation three months before trial but failed to include the evaluation in the record or consider it at sentencing, as he alleged was required by statute. He claimed this omission meant the sentencing phase was never properly concluded, thereby depriving the court of jurisdiction to impose his sentence. His appointed attorney expanded these arguments, suggesting the evaluation implied a finding of incompetence to stand trial and that this raised constitutional concerns about his conviction’s validity.The Sedgwick District Court summarily denied the motion. The judge found that the evaluation occurred before trial and was not required to be part of the sentencing record. The court also determined that the evaluation was not related to the defendant’s competence to stand trial, but rather to the potential for a mental disease or defect defense. The court took judicial notice of a prior, similar claim by the defendant and noted that his allegations were unsupported.Reviewing the case, the Supreme Court of the State of Kansas first determined the nature of the defendant’s postconviction motion, construing it as a motion to correct an illegal sentence under K.S.A. 22-3504, rather than a habeas corpus motion. The court rejected constitutional arguments as improper for this procedural vehicle. On the merits, the court held that procedural errors alleged by the defendant, such as failing to consider the psychological evaluation, did not divest the district court of subject-matter jurisdiction over sentencing. The court further held that failure to consider certain statutory factors does not render a sentence illegal under the relevant statute. The Supreme Court of Kansas affirmed the district court’s denial of the illegal-sentence motion. View "State v. Denney " on Justia Law

Four individuals, including Ronald Suber, were engaged in stealing catalytic converters from vehicles. During one theft, police were alerted and pursued the suspects. Anna Hurst was apprehended and confessed, while Suber and others escaped. Soon after, Suber expressed anger over Hurst’s arrest. Suber and another accomplice, Tori Balfour, met Hurst and Brian May at a convenience store. Surveillance footage confirmed their meeting, and Balfour testified that Suber accused Hurst and May of talking to police. Later, in a cornfield, Balfour claimed Suber shot Hurst and fired at May. Suber allegedly disposed of evidence and returned to his cousin’s house. May, wounded, sought help from a local resident, and Hurst’s body was found in the cornfield. DNA and ballistic evidence were collected, but the murder weapon was not recovered.The Superior Court of the State of Delaware held a jury trial where Balfour testified against Suber after receiving a plea deal. May did not appear for trial. The prosecution elicited testimony from detectives suggesting that May identified Suber as the shooter in a photo lineup, although May was unavailable for cross-examination. The defense did not object to this testimony. The jury found Suber guilty of first-degree murder and related charges, and he was sentenced to life imprisonment plus additional time.The Supreme Court of the State of Delaware reviewed Suber's appeal, focusing on the use of indirect hearsay evidence that implicated Suber as the shooter through May’s supposed identification without direct testimony. The State conceded that this violated Suber’s constitutional confrontation rights. Applying the plain error standard, the Supreme Court determined the error was prejudicial to Suber’s substantial rights and undermined the fairness of the trial, given the central role of the indirect hearsay in corroborating the accomplice’s testimony. The Supreme Court vacated Suber’s convictions and remanded the case for further proceedings. View "Suber v. State" on Justia Law

Mahmoud Khalil, an Algerian citizen and lawful permanent resident, was arrested in March 2025 by Homeland Security agents at his New York City apartment and charged as removable under the Immigration and Nationality Act’s foreign-policy provision. Khalil, a Columbia University student and vocal advocate for Palestinian rights, was accused of having activities with potentially adverse foreign policy consequences for the United States. After his arrest, he was quickly transferred from New York to New Jersey, and then to Louisiana. His attorney initially filed a habeas petition in the Southern District of New York, seeking to enjoin his detention and removal, arguing retaliation against protected speech, and due process violations.The Southern District of New York, finding Khalil was already detained in New Jersey when the petition was filed, transferred the case to the U.S. District Court for the District of New Jersey. The New Jersey District Court asserted jurisdiction, denied the government’s motion to dismiss, and determined that the INA did not strip it of subject-matter jurisdiction. The court granted Khalil’s motion for a preliminary injunction on the foreign-policy removal charge, ordered that he not be removed, and later ordered his release from custody. Meanwhile, an immigration judge in Louisiana found Khalil removable on both foreign-policy and fraud charges and ordered his removal, resulting in conflicting mandates.Reviewing the case, the U.S. Court of Appeals for the Third Circuit held that the District Court had habeas jurisdiction, as the petition was properly transferred and related back to Khalil’s district of confinement. However, the Third Circuit found that 8 U.S.C. § 1252(b)(9) of the INA strips the District Court of subject-matter jurisdiction over claims arising from removal actions, channeling such claims into a petition for review of a final order of removal in the court of appeals. As a result, the Third Circuit vacated and remanded with instructions to dismiss Khalil’s habeas petition. View "Khalil v. President United States of America" on Justia Law

Renton police and SWAT officers executed a search warrant at the apartment where Cristian Magaña Arévalo was staying with his family, seeking evidence related to the murder of Jason Hobbs. Officers ordered everyone out using a bullhorn, separated Magaña Arévalo from his family, restrained him with zip ties, and placed him in a patrol car before transporting him to a nearby parking lot. There, he was transferred to an officer’s work truck and questioned about Hobbs’s murder without receiving Miranda warnings. The officer told him he was “not under arrest” and asked if he would talk, which Magaña Arévalo agreed to. Two days later, he was interviewed again in a noncustodial setting, also without Miranda warnings.In King County Superior Court, Magaña Arévalo moved to suppress both statements, arguing the first was obtained during a custodial interrogation without Miranda warnings and the second was tainted by the initial violation. The court held a CrR 3.5 hearing and ruled both statements admissible, finding neither interrogation custodial or coerced. The jury convicted Magaña Arévalo of first degree murder, and the court sentenced him to prison. On appeal, the Washington Court of Appeals found the December 1 interrogation was custodial and that admitting the statement was error, but held the error was harmless beyond a reasonable doubt because of other strong evidence, including the December 3 statement and physical evidence.The Supreme Court of the State of Washington reviewed both parties’ petitions. It held that considering the totality of the circumstances—including restraints, isolation, police presence, and ethnicity—Magaña Arévalo was in custody during the December 1 interrogation, and admitting his statement without Miranda warnings violated his constitutional rights. However, the court found the December 3 statement was voluntary, noncustodial, and not tainted by the earlier violation. Applying a clarified harmless error standard, the court affirmed the Court of Appeals, holding the constitutional error was harmless beyond a reasonable doubt. View "State v. Magana-Arevalo" on Justia Law

Ajay, a recent immigrant from India with limited English proficiency, was investigated for alleged sexual assault and attempted sexual assault against a child under 14 in Reno, Nevada. The accusations stemmed from an incident involving a 13-year-old boy, A.P., whom Ajay met at his workplace and with whom he allegedly engaged in sexual acts. During a custodial police interrogation, Detective DeSantis read Ajay his Miranda rights in English. Ajay repeatedly expressed confusion, stated he was not good in English, and requested to speak in Hindi or have an interpreter. Despite this, DeSantis continued explaining the rights in English, using props and hypotheticals, until Ajay acquiesced and the interrogation proceeded, resulting in a confession.Ajay moved to suppress his statements before the Second Judicial District Court, Washoe County, arguing he had not knowingly and intelligently waived his Miranda rights due to his limited English proficiency. At a pretrial hearing, Ajay testified through an interpreter, detailing his lack of formal English education and unfamiliarity with the American legal system. The district court denied his motion, finding the waiver valid and voluntary, citing DeSantis’s efforts to clarify the warnings and Ajay’s apparent understanding.On appeal, the Supreme Court of Nevada reviewed whether Ajay’s Miranda waiver was knowing and intelligent. The court found that Ajay's limited English skills and explicit requests for an interpreter demonstrated he did not understand his rights. The court held that law enforcement must recognize when a language barrier prevents meaningful waiver and provide an interpreter as necessary. The district court’s admission of Ajay’s confession was not harmless beyond a reasonable doubt given its significance at trial. Therefore, the Supreme Court of Nevada reversed the conviction and remanded for further proceedings. View "Ajay v. State" on Justia Law

Anthony Lee was accused of assaulting Amy Groff at his home near Sequim, Washington. After an evening spent together, Lee became angry with Groff, allegedly due to her drug use, theft, and verbal abuse. When they returned home, Lee reportedly fired a gun in the air, struck Groff in the head with the gun, pushed her out of his truck, kicked and hit her, and then shot at her as she ran away. Groff was later found by police with visible injuries and recounted the assault to officers.Lee was charged in the Clallam County Superior Court with two counts of second degree assault with a deadly weapon, each based on separate alleged acts: one for beating Groff with the gun and another for shooting at her. At trial, the judge admitted Groff’s statements to police under the excited utterance exception to hearsay, and instructed the jury not to consider any judicial comments as opinions on the evidence. The jury found Lee guilty on both counts, and the trial court determined the assaults were distinct acts, rejecting Lee’s double jeopardy argument. Lee appealed, raising the double jeopardy issue and, for the first time, challenging the trial judge’s comment on the evidence. The Washington Court of Appeals affirmed both convictions, finding no double jeopardy violation and no manifest constitutional error regarding the judicial comment.The Supreme Court of the State of Washington reviewed the case and held that, under the unit of prosecution analysis and considering all relevant factors, Lee’s assaultive acts constituted a single course of conduct. Therefore, two convictions for second degree assault violated double jeopardy principles. The court reversed on that issue, ordering one conviction and its firearm enhancement to be vacated. On the comment on the evidence issue, the court affirmed, finding no manifest constitutional error that would permit review for the first time on appeal. View "State v. Lee" on Justia Law