Justia Constitutional Law Opinion Summaries

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

Late one night, three police officers responding to a report of a recent nearby shooting observed a man walking on the street. The man appeared to have an L-shaped bulge in his right jacket pocket, which the officers believed could be a firearm. When the officers pulled their marked cruiser alongside him and asked if he had a gun, the man did not respond and instead fled on foot, clutching and “fiddling” with his pocket as he ran. After a brief pursuit, he surrendered, and officers conducted a pat-down, discovering a handgun in his jacket pocket.Before trial in the Superior Court of the District of Columbia, the defendant moved to suppress the gun, arguing that it was found as a result of an unlawful seizure and search in violation of the Fourth Amendment. The trial court denied the suppression motion, finding that the officers did not seize the defendant until after his flight and that, at that point, they had reasonable articulable suspicion to stop and frisk him based on his behavior, the observed bulge, his flight, and actions during the pursuit. The court then found the defendant guilty of unlawful possession of a firearm and related charges following a stipulated trial.On appeal, the defendant limited his argument to whether the officers had reasonable articulable suspicion to stop and frisk him when he surrendered. The District of Columbia Court of Appeals concluded that, considering the totality of the circumstances—including the recent shooting in the area, the observed bulge consistent with a firearm, the defendant’s apparent panic and evasive behavior, his flight, and his actions while fleeing—officers had reasonable articulable suspicion to justify the stop and frisk. The court affirmed the convictions, finding no Fourth Amendment violation. View "Doby v. United States" on Justia Law

The defendant was convicted in Texas state court in 2004 for assault causing bodily injury to a family member, which qualifies as a misdemeanor crime of domestic violence under Texas law. The incident involved the defendant pushing his wife during an argument and, when she attempted to call 911, striking her in the face while trying to knock the phone from her hand. Based on this conviction, he was later indicted under 18 U.S.C. § 922(g)(9) for possessing a firearm after being convicted of a misdemeanor crime of domestic violence.Before the United States District Court for the Western District of Texas, the defendant moved to dismiss the indictment, raising two constitutional challenges: that the statute exceeds Congress’s power under the Commerce Clause, and that, as applied to him, it violates the Second Amendment. The district court denied the motion. The defendant then entered a conditional guilty plea, reserving the right to appeal the denial of his motion to dismiss, and was sentenced to imprisonment and supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case. It rejected the Commerce Clause challenge, extending the reasoning from United States v. Alcantar to § 922(g)(9). The court then addressed the as-applied Second Amendment challenge, applying the historical tradition test articulated in New York State Rifle & Pistol Ass’n v. Bruen and clarified in United States v. Rahimi. The Fifth Circuit concluded that § 922(g)(9), as applied to the defendant, is consistent with the nation’s historical tradition of disarming individuals found to threaten the physical safety of others. The court found that the statute’s rationale and burden are supported by historical analogues and that the defendant’s conduct was sufficiently dangerous to warrant disarmament. The judgment of the district court was affirmed. View "USA v. Allred" on Justia Law

The case concerns a man accused of kidnapping and sexually assaulting a woman in Maui in 1989. The prosecution’s case relied heavily on circumstantial evidence and expert testimony from an FBI agent, who analyzed hair and fiber samples. The expert testified that hair found in the defendant’s car was “consistent with” originating from the complainant, and that fibers found on her clothing were “consistent with” coming from the car’s seat cover and carpet. The defense challenged the complainant’s credibility but did not contest the expert testimony. The jury convicted the defendant, and he was sentenced to forty years. Nearly thirty years later, a letter from the Department of Justice revealed that the expert’s testimony about hair analysis overstated the science and was invalid. The defense then argued that both the hair and fiber testimony should be deemed unreliable based on scientific developments.The Circuit Court of the Second Circuit held a hearing and found that the hair analysis testimony exceeded the bounds of science but ruled the error harmless beyond a reasonable doubt due to other corroborative evidence. The court did not rule on fiber analysis. The Intermediate Court of Appeals (ICA) affirmed the denial of post-conviction relief, applying the State v. McNulty “newly discovered evidence” test. The ICA found that the fiber testimony was not impeached by the DOJ letter and considered the hair evidence cumulative, so it declined to address whether the new evidence would probably change the result at retrial.The Supreme Court of Hawai‘i reviewed the case and held that when scientific advances later invalidate expert testimony presented at trial, the “false evidence” standard applies, not the “newly discovered evidence” standard. The court found both the hair and fiber testimony materially false, took judicial notice of landmark scientific reports, and concluded there was a reasonable possibility the false evidence contributed to the conviction. The defendant’s due process rights were violated, and the court vacated the lower courts’ decisions, remanding for a new trial. View "Granillo v. State" on Justia Law

In 2009, the appellant was convicted of violating California Penal Code section 288.4, subdivision (b), for arranging and attending a meeting with a minor with the intent to commit a sexual offense. The sentencing court imposed felony probation, jail time, and required him to register as a sex offender. In 2024, the appellant sought removal from the sex offender registry, arguing that the statutory scheme’s classification—placing his offense in tier three, which requires lifetime registration—violated his constitutional rights to equal protection. He contended there was no rational basis for imposing lifetime registration for his offense when other, allegedly more serious offenses, such as lewd acts under section 288, subdivision (a), did not require lifetime registration.The Superior Court of Los Angeles County reviewed the writ petition and denied relief. The court found that the Legislature could rationally distinguish between the appellant’s offense, characterized as a predatory “child luring” crime involving planning and a demonstrated unnatural interest in children, and the offenses he cited for comparison. The court explained that the statutory scheme was motivated by a legitimate governmental purpose: managing the risk of recidivism among offenders deemed most likely to reoffend and protecting public safety.The California Court of Appeal, Second Appellate District, Division Three, affirmed the lower court’s order. The appellate court held that under rational basis review, the Legislature had a conceivable and legitimate reason for classifying section 288.4, subdivision (b), offenses as warranting lifetime registration. The court emphasized that equal protection is not violated when the Legislature draws distinctions based on plausible risk assessments and societal interests, even if some other offenses are not treated identically. The appellate court concluded that the statutory classification survived constitutional scrutiny and awarded costs on appeal to the respondent. View "Muradyan v. Bonta" on Justia Law

A father’s three children were taken into emergency custody by the Alaska Office of Children’s Services (OCS) in 2019 while he was incarcerated in another state. After his release, OCS worked with him but ultimately petitioned to terminate his parental rights, primarily due to the length of his incarceration and concerns about his progress toward reunification. In January 2023, a superior court terminated the parental rights of both parents. The following July, one child, Serena, was adopted by her foster family, and the court closed her child in need of aid (CINA) case, releasing her into her adoptive parents’ custody.The father appealed the termination of his parental rights. In December 2023, the Supreme Court of the State of Alaska reversed the termination order, finding OCS had not made reasonable efforts to reunify the family. On remand, the superior court reopened Serena’s CINA case but left her in the adoptive parents’ custody. The father was appointed counsel in the adoption case. However, more than one year after the adoption decree, the CINA case was declared moot at the request of the guardian ad litem, who cited Alaska’s statutory one-year limit on challenging adoption decrees. The father argued that the one-year bar did not apply because the adoptive parents had not “taken custody” of Serena and that his due process and right to effective counsel were violated.The Supreme Court of the State of Alaska affirmed the dismissal of the CINA case as moot. It held that the one-year statutory bar to challenging adoptions applied because Serena’s adoptive parents had taken custody. The court found no due process violation, as the father had notice, counsel, and opportunity to be heard, and rejected his ineffective assistance of counsel claim, finding no constitutional deficiencies. View "Jonah B. v. State" on Justia Law

Police investigating suspected drug trafficking received information from a confidential informant about two individuals selling drugs. Surveillance linked the suspects to multiple addresses. The investigation included controlled drug buys and installation of a pole camera outside an apartment building. On April 4, 2023, the informant reported a possible deceased person inside one of the apartments. Surveillance footage showed the suspects and another individual entering and exiting the building. Police detained the suspects at a traffic stop and seized keys. Officers then entered the apartment building without a warrant, finding a deceased person in the second-floor apartment and, upon entering the third-floor apartment, discovering drug paraphernalia and contraband.The Providence County Superior Court held a hearing on the defendant’s motion to suppress evidence obtained during the warrantless search and seizure. The trial justice denied the motion, concluding that the police were responding to a sudden emergency involving a possible death and acted rationally to protect citizens from harm and prevent destruction of property. The defendant was subsequently found guilty on all charges following a bench trial and sentenced to twenty-five years, with twenty years to serve and five years suspended. The defendant appealed.The Supreme Court of Rhode Island reviewed the denial of the motion to suppress under the Fourth Amendment and article 1, section 6 of the Rhode Island Constitution, applying the totality of the circumstances standard and deferring to factual findings unless clearly erroneous. The Court held that police had no constitutionally permissible reason to enter the third-floor apartment after finding the deceased in the second-floor apartment and that the exigency justifying entry had evaporated. The Court concluded that the error was not harmless, vacated the conviction, and remanded for a new trial. View "State v. Moronta" on Justia Law

The defendant was arrested in connection with a fatal shooting and, following his arrest, was given Miranda warnings. Police initially did not interrogate him because they believed he was intoxicated. The next day, during a videorecorded interrogation, the defendant waived his rights but later invoked his right to counsel, stating he needed appointed counsel. Police then left, purportedly to locate an attorney, but after more than two hours returned and informed the defendant that no attorney was available and he did not have the money to hire one. The defendant expressed confusion and asked clarifying questions. Police indicated that unless the defendant agreed to speak without an attorney, they could not discuss the case further. The defendant ultimately agreed to speak without counsel, was given Miranda warnings again, and made incriminating statements.The Wayne Circuit Court, after reviewing the interrogation video, granted the defendant’s motion to suppress the statements. The court found that police communications had frustrated the required Miranda advice by suggesting that the defendant’s right to counsel depended on his ability to pay, thereby undermining his rights. The trial court also found that police had reinitiated interrogation after the defendant invoked his right to counsel.The Michigan Court of Appeals reversed the suppression order, holding that the defendant’s waiver was voluntary, knowing, and intelligent, and that police had not violated his constitutional rights. The defendant sought further review.The Michigan Supreme Court held that the defendant’s Fifth Amendment rights under Miranda were violated. The Court found that police undermined the required advice of rights by suggesting that the right to counsel depended on the defendant’s ability to pay and that the prosecution failed to show the defendant reinitiated the interrogation. The Court reversed the Court of Appeals’ judgment and remanded for further proceedings, ordering suppression of the defendant’s post-invocation statements. View "People Of Michigan v. Fenderson" on Justia Law