Justia Constitutional Law Opinion Summaries

The case involves Tamarcus Ellis, who was tried and convicted for conspiracy to traffic methamphetamine and actual drug trafficking in Greensboro, North Carolina. During his four-day trial in federal court, a government witness, Malcolm Russell, appeared intimidated while testifying. The U.S. Marshals Service reported that individuals in the gallery were making audible noises and gestures perceived as signaling disagreement with Russell’s testimony. Based on this, the district court partially closed the courtroom for approximately one hour during Russell’s testimony, excluding most members of the public but allowing Ellis’ family and defense counsel’s family to remain.After Ellis was convicted and sentenced to 480 months’ imprisonment by the United States District Court for the Eastern District of North Carolina, he appealed. Ellis argued that the partial closure violated his Sixth Amendment right to a public trial, asserting this was structural error requiring automatic reversal and a new trial.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. The court acknowledged that the closure was not trivial and implicated the Sixth Amendment’s Public Trial Clause. It applied the modified Waller test for partial courtroom closures, which requires a “substantial reason” for the closure, that the closure be no broader than necessary, consideration of reasonable alternatives, and adequate findings by the trial court. The Fourth Circuit found that the district court had a substantial reason to partially close the courtroom to prevent witness intimidation, tailored the closure appropriately, considered alternatives, and made sufficient findings on the record. Therefore, the Fourth Circuit held that the partial closure did not violate Ellis’ Sixth Amendment right to a public trial and affirmed the district court’s judgment. View "US v. Ellis" on Justia Law

Two individuals were found shot and killed in a car in Baltimore City after a planned marijuana sale. The investigation led police to Montay D. Shuler, who was observed near the scene, arrested, and interrogated. During a custodial interview, after being advised of his Miranda rights, Mr. Shuler denied involvement in the shooting. At trial, Mr. Shuler testified, admitting that he shot both victims but claimed self-defense. The State introduced his prior custodial statement, in which he denied involvement, for the purpose of impeaching his trial testimony.Mr. Shuler was tried in the Circuit Court for Baltimore City. The jury acquitted him of first- and second-degree murder but convicted him of voluntary manslaughter and several related offenses. Mr. Shuler requested a jury instruction requiring the jury to find his custodial statement voluntary before considering it. The trial court denied this request, reasoning there was no evidence the statement was involuntary. On appeal, the Appellate Court of Maryland affirmed, holding that no voluntariness instruction was required because the statement was only used for impeachment, was exculpatory, and there was no evidence of involuntariness.The Supreme Court of Maryland reviewed the case. It held that the trial court was not required to give the requested voluntariness instruction because Mr. Shuler did not present “some evidence” that his custodial statement was involuntary under either Maryland common law or constitutional standards. The Court clarified that the right to a voluntariness instruction is not limited to inculpatory statements or those offered in the State’s case-in-chief but must be generated by evidence of involuntariness. Even assuming error in failing to give the instruction, the Supreme Court of Maryland held the error was harmless beyond a reasonable doubt given the weight of the evidence and the jury’s verdict. The judgment of the Appellate Court was affirmed. View "Shuler v. State" on Justia Law

Police stopped a vehicle driven by the defendant for a window tint infraction in Boston. During the stop, officers observed the passenger making a suspicious motion toward the glove compartment. After ordering both occupants out of the car and conducting pat frisks, police discovered the glove compartment was locked and repeatedly requested the defendant provide the car key, which she refused. Officers attempted to handcuff her, leading to a brief physical struggle. Believing she had hidden the key on her person, officers conducted multiple searches, including two by female officers, but did not find the key. After a police dog indicated the presence of a firearm in the glove compartment, officers continued to urge the defendant to surrender the key, warning of potential damage to her car if they towed and searched it without the key. The defendant then handed over the key, and officers found a firearm and pills in the glove compartment.In the Superior Court, the defendant moved to suppress the evidence from the glove compartment, arguing it was the fruit of unlawful searches of her person. The judge found that while the initial stop, exit orders, and patfrisk were lawful, the subsequent more intrusive searches violated the defendant’s constitutional rights because they were not justified by officer safety concerns. However, the judge denied the motion, concluding the defendant had voluntarily consented to the search of the glove compartment by providing the key, and that the consent was sufficiently attenuated from the unlawful searches.The Supreme Judicial Court of Massachusetts reviewed the denial of the motion to suppress. It held that the searches of the defendant’s person were unlawful because they were conducted for an investigatory purpose unrelated to her arrest, violating statutory and constitutional protections. The Court further concluded that the defendant’s consent to search the glove compartment, given immediately following the unlawful and coercive searches, was not sufficiently attenuated from the misconduct and therefore was not valid. The order denying the motion to suppress was reversed. View "Commonwealth v. Dobson" on Justia Law

A fire captain who served as vice president of a local firefighters’ union was also a member of the Jefferson Parish Fire Civil Service Board. The union previously paid for legal counsel for members appearing before the Civil Service Board, but stopped doing so after the Louisiana Board of Ethics issued an advisory opinion, and later a binding declaratory opinion, stating that such payments violated Louisiana law while any union officer served on the board. The union challenged the Board of Ethics’ interpretation in state court, arguing that it misapplied state law, and then filed a federal lawsuit claiming this restriction violated its First Amendment rights.The United States District Court for the Eastern District of Louisiana granted the union a preliminary injunction on First Amendment grounds, preventing enforcement of the ethics board’s opinion against the union. The district court also declined to abstain under the doctrines established in Younger v. Harris and Railroad Commission of Texas v. Pullman Co. The Louisiana defendants appealed, arguing the district court should have abstained and that granting the injunction was an abuse of discretion. While the appeal was pending, all relevant state court proceedings concluded, and, just before oral argument, the fire captain resigned from the Civil Service Board.The United States Court of Appeals for the Fifth Circuit found that the case was moot due to the resignation, as neither party retained a legally cognizable interest in the outcome. The court determined that no live controversy remained, rejected arguments that mootness exceptions applied, and ruled that the appeal and the entire case must be dismissed for lack of jurisdiction. The court vacated the preliminary injunction and remanded to the district court with instructions to dismiss the case. View "Jefferson Parish Firefighters Association, Local 1374 v. Roberts" on Justia Law

A West Virginia defendant was indicted in 2018 on multiple sexual offense charges involving a seven-year-old girl. Prior to trial, the court granted the defendant’s motions to exclude a video interview of the victim and records from her therapy sessions, limiting both the State and the defense from introducing certain hearsay evidence. During opening statements at the first trial, defense counsel referenced specific statements made by the victim in the excluded materials, suggesting an alternative perpetrator. The State objected after the opening statements, arguing that the defense had violated pretrial evidentiary rulings. The trial court found that the defense’s actions had gone “far afield” of its orders and, over the defendant’s objection, granted the State’s motion for a mistrial.The defendant moved to dismiss the indictment on double jeopardy grounds, arguing that the mistrial was not required by “manifest necessity.” The trial court denied the motion, finding that the defense had created the necessity for a mistrial. The Supreme Court of Appeals of West Virginia later affirmed, holding that the defendant’s right against double jeopardy was not violated because defense counsel’s conduct in opening statement created a manifest necessity for the mistrial. The defendant subsequently filed a federal habeas petition in the United States District Court for the Northern District of West Virginia, which granted relief, concluding that the defense had not violated any pretrial orders and that manifest necessity was lacking.On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court’s judgment. The Fourth Circuit held that, under the highly deferential standard of review required by AEDPA, the state court’s conclusion that manifest necessity justified the mistrial was neither contrary to nor an unreasonable application of clearly established Supreme Court precedent. The case was remanded with instructions to deny the habeas petition. View "Wood v. Straughn" on Justia Law

New Jersey enacted laws that ban the possession of so-called “assault firearms”—including a list of over thirty models and types of semi-automatic rifles, such as the AR-15, and any firearm “substantially identical” to those listed—as well as laws restricting possession of “large capacity ammunition magazines” (LCMs), defined as magazines holding more than ten rounds. The statutes contain narrow exemptions, mostly for military, police, and certain target-shooting purposes, but in practice, they amount to a near-total prohibition on civilian possession of these weapons and magazines. Gun owners and advocacy groups challenged both sets of laws under the Second Amendment, and one group also raised a Takings Clause claim after New Jersey amended the LCM law in 2018 to further reduce the permitted capacity.The United States District Court for the District of New Jersey consolidated three related lawsuits and ruled on cross-motions for summary judgment. The District Court found New Jersey’s ban on the Colt AR-15 unconstitutional under the Second Amendment but upheld the LCM restrictions and rejected the Takings Clause challenge. The plaintiffs and the State appealed.The United States Court of Appeals for the Third Circuit, sitting en banc, applied the Supreme Court’s Second Amendment framework from New York State Rifle & Pistol Association v. Bruen and related cases. The Third Circuit held that the Second Amendment protects possession of semi-automatic rifles and large-capacity magazines, as both are “in common use for lawful purposes.” The court concluded New Jersey’s ban on semi-automatic rifles and its LCM restrictions are inconsistent with the Nation’s tradition of firearm regulation and thus violate the Second Amendment. The court modified the District Court’s order to invalidate the ban as to all semi-automatic rifles, reversed the ruling upholding the LCM provisions, and remanded for further proceedings, including as to other weapons regulated by the statutes. View "Association of New Jersey Rifle and Pistol Clubs I v. Attorney General" on Justia Law

A property in Hollis was owned by a trust with Wisarat Manutsom as trustee. The trustee, often traveling abroad, provided various mailing addresses—including in California, Manchester (New Hampshire), and later Maine—as well as an email address, to the town for tax-related correspondence. Mark Copp was authorized to act for the trust and provided his Manchester address. Over several years, the town sent multiple certified mail notices regarding unpaid property taxes and impending tax liens and deeds to these addresses; some were signed for and received, but several were returned as undeliverable. The town also communicated about the delinquent taxes by email. In 2019, after more undelivered certified mailings and no payment for 2016 taxes, the town executed a tax deed transferring ownership to itself, then sent post-deed notices by regular mail and, years later, by certified mail and email.The plaintiff sued in the Superior Court, alleging the town’s notice regarding the 2016 and 2018 tax liens and the 2016 tax deed was constitutionally deficient under the Fourteenth Amendment. The Superior Court granted summary judgment to the town, finding the notice sufficient. The plaintiff's motion for reconsideration was denied, and she appealed.The Supreme Court of New Hampshire reviewed the case de novo. It held that the town’s failure to take additional reasonable steps—such as emailing notice—after certified notices of the impending 2016 tax deed were returned undelivered, and before executing the deed, violated the plaintiff’s due process rights. The court also found the town’s notice of the 2016 tax lien insufficient because it relied on an address that had repeatedly failed. However, notice of the 2018 tax lien, sent to both Manchester and Maine addresses, was deemed sufficient. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Manutsom v. Town of Hollis" on Justia Law

A firefighter with sixteen years of service in the Chicago Fire Department (“CFD”) was terminated after an investigation revealed that he had posted racially offensive and derogatory content on his public Facebook account. He openly identified himself as a CFD firefighter on his page, which included photos in uniform, and his posts targeted Black and Asian Americans, groups served by the CFD. The posts prompted complaints from members of the public, leading to an Office of Inspector General investigation. The investigation concluded that the firefighter’s posts undermined public trust and recommended his dismissal, which the Fire Commissioner approved. The firefighter unsuccessfully challenged his termination through arbitration.He then sued the City of Chicago and two CFD officials in the United States District Court for the Northern District of Illinois, Eastern Division, alleging his termination violated his First Amendment rights and challenging the City’s social media policy as unconstitutionally vague and overbroad. The district court granted summary judgment for the City, holding that the firefighter’s posts were not protected by the First Amendment because they did not address matters of public concern. Alternatively, the court found that, even if the posts did touch on public concern, the City’s interest in departmental efficiency and maintaining public trust outweighed his free speech interests.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that the district court erred in its analysis of public concern, concluding that the posts could be seen as addressing matters of public concern. However, applying the Pickering balancing test, the appellate court held that the City’s interests in preserving public trust, especially given the firefighter’s public identification with the CFD and the nature of his posts, outweighed his speech interests. The court affirmed summary judgment in favor of the City. View "Inendino v Nance-Holt" on Justia Law

Two men, Jamal Cruz and Rokiem Henley, attended a nightclub in Providence with friends. After the club closed, Cruz had a brief verbal disagreement with two other men, including Terrel Barros and Stephen Bodden. As Cruz and Henley were leaving, Bodden confronted Cruz outside, followed by gunshots that injured Henley and fatally wounded Cruz. Police officers nearby responded quickly, saw Bodden and Barros get into a car, and arrested both men. Barros was subsequently charged and convicted of first-degree murder and several related offenses, largely based on Cruz’s dying identification, eyewitness testimony, and evidence presented at trial.Following his conviction, Barros filed an application for postconviction relief in the Rhode Island Superior Court, alleging several constitutional violations, actual innocence, and the existence of newly discovered evidence. During the postconviction hearing, Barros introduced testimony from Gloria Parajon, Bodden’s cousin, who stated that Bodden had privately confessed to her, on multiple occasions, that he was the shooter. The hearing justice found Parajon’s testimony to be newly discovered, credible, and not merely cumulative, and concluded it could change the verdict at a new trial. The Superior Court granted Barros’s application for postconviction relief and vacated his conviction.On review, the Supreme Court of Rhode Island determined that the Superior Court did not err in admitting Parajon’s testimony as a statement against penal interest under Rule 804(b)(3) of the Rhode Island Rules of Evidence, and that her statements were sufficiently corroborated. The Supreme Court affirmed the judgment of the Superior Court, holding that Barros was entitled to postconviction relief based on newly discovered evidence, and remanded the case for further proceedings. View "Barros v. State of Rhode Island" on Justia Law

A seventeen-year-old individual planned and carried out a violent attack resulting in the death of one person and serious injuries to two others. After purchasing a knife, he attended a dinner and sleepover with friends. Late at night, he attacked and fatally stabbed one victim, then proceeded to injure two others. The police apprehended him at the scene. He was charged with first-degree murder and two counts of attempted first-degree murder. The jury convicted him on all counts. Because he was a juvenile at the time, a separate sentencing hearing was held to consider mitigating factors under Florida law.The Circuit Court for Palm Beach County sentenced him to life without parole (LWOP) for each count, with the two attempted murder sentences running concurrently but consecutively to the murder sentence. The court announced that he would be eligible for judicial review after serving 25 years on the murder conviction, and again after serving another 25 years on the consecutive sentences for attempted murder. The defendant challenged his sentence, arguing that consecutive LWOP sentences for offenses committed in a single episode violated the Eighth Amendment, relying on Graham v. Florida. The Circuit Court denied relief, and on direct appeal, the Fourth District Court of Appeal upheld the sentences, holding that the structure provided a meaningful opportunity for release consistent with constitutional requirements. The Fourth District certified conflict with the Second District Court of Appeal’s decision in Mack v. State, which had found such consecutive sentences unconstitutional.The Supreme Court of Florida reviewed the case and held that the Eighth Amendment’s requirement of a “meaningful opportunity for release” from Graham v. Florida does not apply to juveniles convicted of homicide offenses. Instead, sentencing for juvenile homicide offenders is governed by Miller v. Alabama and Jones v. Mississippi, requiring individualized sentencing but permitting discretionary LWOP. The Court approved the Fourth District’s result, disapproved Mack, and upheld the sentences. View "Johnson v. State of Florida" on Justia Law