Justia Constitutional Law Opinion Summaries

In 2018, a juvenile wardship petition alleged that E.J. committed several offenses, including assault with a deadly weapon other than a firearm. E.J. admitted to that charge as part of a negotiated disposition, and the juvenile court found the allegations true, dismissed the remaining counts, declared E.J. a ward of the court, and placed him on probation. In 2019, the court reduced the offense to a misdemeanor, terminated probation, discharged E.J. as a ward, and sealed the record. Despite these actions, E.J. remained subject to a statutory firearm prohibition until age 30 under Penal Code section 29820.In 2025, E.J. filed a motion in the Superior Court of San Bernardino County to terminate the firearm prohibition. The juvenile court denied the motion. E.J. appealed, arguing that Penal Code section 29820 was facially unconstitutional under the Second and Fourteenth Amendments, claiming it failed to align with the nation’s historical tradition of firearm regulation, improperly used age as a proxy for dangerousness, and did not provide a mechanism for individualized assessment regarding dangerousness.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that section 29820 is not facially unconstitutional. It found that firearm prohibitions based on juvenile adjudications for certain offenses are consistent with the historical tradition of firearm regulation and that the statute’s application based on prior adjudication—not age alone—does not offend the Second Amendment. The court also held that due process does not require an individualized assessment of dangerousness when the statute’s application is triggered solely by a prior adjudication. The court further found that any as-applied challenge was forfeited because it was not raised in the trial court or in E.J.’s opening brief. The order was affirmed. View "In re E.J." on Justia Law

A criminal complaint was filed against an individual in July 2024, alleging multiple counts of lewd acts, forcible lewd acts, and continuous sexual abuse of four minors, all of whom are his grandchildren. The prosecution also alleged a multiple victim enhancement. At an initial arraignment, the magistrate court set bail and imposed protective orders. Later, the prosecution moved to have the defendant held without bail, citing the danger he posed to the community. At a Humphrey hearing, the prosecution presented testimony and evidence suggesting repeated sexual abuse over many years, including admissions by the defendant. The magistrate court found this evidence reliable and determined that nonfinancial conditions of release would not protect the public or victims, ordering the defendant held without bail.The defendant challenged the no-bail order in the Superior Court of Fresno County through a petition for writ of habeas corpus. He argued the magistrate court abused its discretion, particularly in considering the prosecution’s request for remand without bail absent a change in circumstances, and asserted there was insufficient evidence to support a finding of substantial likelihood of great bodily harm. The superior court issued an order to show cause on these specific issues but ultimately denied the petition after considering the parties’ responses.Upon further review, the California Court of Appeal, Fifth Appellate District, was directed by the California Supreme Court to address whether Penal Code section 292 constitutes an impermissible legislative extension of the constitutional terms “acts of violence” and “great bodily harm,” and whether, absent section 292, clear and convincing evidence supported denial of bail. The appellate court held that section 292 is a valid legislative implementation, not an invalid extension, of the bail exception in article I, section 12 of the California Constitution. The court further found that substantial evidence supported the finding that the defendant’s release would pose a substantial likelihood of great bodily harm, and denied the petition for writ of habeas corpus. View "In re Bergstrom" on Justia Law

Four women incarcerated at the Huron Valley Correctional Facility in Michigan suffered from persistent, painful rashes between 2016 and 2019. Despite repeated complaints, medical staff—contracted through Corizon Health—failed to diagnose scabies, instead providing ineffective treatments and attributing the condition to environmental factors like improper laundering. It was only after an outside dermatologist intervened that scabies was correctly identified, prompting prison-wide treatment efforts. However, these efforts were delayed and, in some cases, inadequate, resulting in prolonged suffering for the affected inmates.After their experiences, the four women filed suit in the United States District Court for the Eastern District of Michigan against multiple defendants, including high-level Michigan Department of Corrections officials and Wayne State University medical officers, alleging Eighth Amendment violations and state-law negligence. The district court found that the women’s complaint plausibly alleged “clearly established” Eighth Amendment violations by all defendants and denied the officials’ request for qualified immunity. The court also rejected a claim of state-law immunity, finding that the officials could be the proximate cause of the inmates’ injuries under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denials. The Sixth Circuit held that existing precedent did not “clearly establish” that the non-treating prison officials’ reliance on contracted medical providers was so unreasonable as to violate the Eighth Amendment. Thus, it reversed the district court’s denial of qualified immunity on the federal damages claims. However, the appellate court affirmed the denial of state-law immunity, finding the plaintiffs adequately pleaded proximate cause under Michigan law. The case was remanded for further proceedings consistent with these holdings. View "Machelle Pearson v. MDOC" on Justia Law

Several women incarcerated at a Michigan prison developed painful, persistent rashes between 2016 and 2019. Their complaints were largely ignored by prison staff, and medical providers initially misdiagnosed the condition, ruling out scabies, a highly contagious skin infestation. The prison’s contracted health care provider, Corizon Health, and its infectious disease coordinator were tasked with managing infectious diseases but failed to control the outbreak. Only after an outside dermatologist diagnosed scabies did prison officials begin widespread treatment and quarantine measures, though these efforts were not immediately effective. Four inmates who suffered from these conditions filed suit, seeking damages and injunctive relief against both the medical providers and high-level prison officials who had not directly treated them.The United States District Court for the Eastern District of Michigan denied motions for judgment on the pleadings by the Michigan Department of Corrections and Wayne State Officials. The district court held that the inmates had plausibly alleged that all defendants, including non-treating prison officials, committed clearly established Eighth Amendment violations and were not entitled to qualified immunity. The court also found that the gross negligence claims could proceed under Michigan law, as the complaint adequately alleged that the officials proximately caused the harms.On appeal, the United States Court of Appeals for the Sixth Circuit determined that, under existing precedent, non-treating prison officials’ reliance on contracted medical providers did not clearly constitute an Eighth Amendment violation. The court reversed the district court’s denial of qualified immunity on the inmates’ federal damages claims against these officials, finding no clearly established law requiring them to override medical judgments. However, the court affirmed the denial of state-law immunity, concluding that proximate cause under Michigan law could not be resolved at the pleading stage. The case was remanded for further proceedings consistent with these rulings. View "BLC Lexington SNF, LLC v. Townsend" on Justia Law

A man on probation was investigated for allegedly diverting customer payments from his employer to himself. Law enforcement learned that, as a condition of his probation, he had agreed to allow searches of his person, residence, and electronic devices, but his probation terms specifically excluded “financial accounts or transactions” from warrantless searches. During the investigation, officers arrested him, seized his phone, and searched several banking applications, including Apple Pay. Information from Apple Pay revealed the existence of certain bank accounts, which led officers to obtain a warrant to search those accounts and gather further evidence.In the Superior Court of Orange County, the defendant moved to suppress the evidence obtained from the bank accounts and to quash the warrant, arguing that the Apple Pay search exceeded the scope of his probation terms and that the subsequent warrant was based on unlawfully obtained information. The prosecution argued the motion was more properly a motion to traverse the warrant, contending that Apple Pay was not a “financial account” and that the warrant was supported by probable cause. The trial court denied the suppression and quash motions.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. It held that the defendant’s motion should be treated as a motion to traverse the warrant, as the warrant affidavit omitted material information about the probation search limitations. The court found that Apple Pay is a “financial account” under the plain meaning of the probation terms. Because the information about the bank accounts was obtained through an unlawful search of a financial account, it was improperly included in the warrant application. The appellate court ordered the trial court to vacate its earlier order and grant the motion to suppress the evidence obtained from the bank accounts. View "Meiner v. Superior Court" on Justia Law

Law enforcement officers executed a search warrant at a residence where a firearm was discovered in a bag containing the defendant’s identification and two loaded magazines. The defendant was present in the bedroom with the bag and was on parole for a prior state offense. DNA swabs taken from the firearm, along with a sample from the defendant, were analyzed by the Pennsylvania State Police Crime Laboratory, which identified multiple DNA contributors but could not conclusively match the DNA to the defendant. The DNA evidence was then submitted to a private company using TrueAllele probabilistic genotyping software, which calculated an extremely high likelihood ratio indicating the DNA was much more likely to include the defendant as a contributor.The defendant moved to exclude the TrueAllele evidence in the United States District Court for the Middle District of Pennsylvania, arguing it was unreliable under Daubert v. Merrell Dow Pharmaceuticals, Inc. and Rule 702 of the Federal Rules of Evidence. After a two-day Daubert hearing featuring expert testimony from both sides, the District Court found that the government met its burden to demonstrate the reliability of TrueAllele and denied the motion to exclude. The District Court also rejected the defendant’s motion to dismiss the indictment on Second Amendment grounds. The defendant ultimately pleaded guilty, preserving his right to appeal these rulings, and was sentenced to 78 months of imprisonment, consecutive to an anticipated state sentence.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s Daubert ruling for abuse of discretion and its Second Amendment analysis de novo. The Third Circuit held that TrueAllele’s methodology was sufficiently reliable for admissibility, finding that it satisfied factors such as testability, low error rates, presence of governing standards, peer review, and general acceptance in the relevant scientific community. The Court also affirmed the District Court’s rejection of the defendant’s constitutional and sentencing challenges, and the judgment was affirmed. View "USA v. Anderson" on Justia Law

A defendant accessed the internet using a publicly available Wi-Fi network operated by a local business, A&W, located near his home. Access to the Wi-Fi required users to acknowledge terms of service that, among other things, stated A&W did not actively monitor the network but could cooperate with legal authorities and disclose users’ activities in response to lawful requests. After A&W’s owner and their consultant noticed suspicious activity flagged by their firewall, they informed law enforcement, which then directed A&W to monitor and log the defendant’s internet activity for approximately one year. This surveillance included tracking over 255,000 webpage visits and collecting packet capture data. Information obtained through this monitoring led to the defendant’s identification, arrest, and conviction on charges of encouraging child sexual abuse.The case was first heard in the Lane County Circuit Court, where the defendant moved to suppress evidence obtained from the year-long monitoring. The trial court found A&W’s owner and consultant acted as state agents but ruled that the defendant had no protected privacy interest in his use of the public Wi-Fi network, and denied the suppression motion. After a stipulated facts trial, the court convicted the defendant. On appeal, the Oregon Court of Appeals affirmed, holding that the defendant did not have a constitutionally protected privacy interest in his internet browsing activities on the public network under the circumstances.The Supreme Court of the State of Oregon reversed the decision of the Court of Appeals in part, and reversed the judgment of the circuit court, remanding the case for further proceedings. The Supreme Court held that under Article I, section 9, of the Oregon Constitution, a person retains a right to privacy in their internet browsing activities even when accessing the internet via a public network, and that acknowledging terms of service like those present did not eliminate that privacy right. The year-long warrantless monitoring constituted a “search,” and the State failed to justify the lack of a warrant. View "State v. Simons" on Justia Law

In 2003, Robert Arnett was convicted in Pennsylvania for engaging in sexual activity with a fourteen-year-old, resulting in his plea of guilty to several offenses, including aggravated indecent assault and statutory sexual assault. He received a sentence of five to ten years’ incarceration. At the time, Pennsylvania’s sexual offender law—known as Megan’s Law—required Arnett to register as a sexual offender for life. After Arnett’s release, the law was replaced by successive statutes, culminating in the Sexual Offender Registration and Notification Act II (SORNA II), which continued to require his lifetime registration. Arnett, more than fifteen years after his sentence became final, filed a pro se petition under the Post Conviction Relief Act (PCRA), later amended by counsel, challenging SORNA II’s constitutionality.The York County Court of Common Pleas considered Arnett’s PCRA petition, holding a hearing without witness testimony. The court found SORNA II unconstitutional as applied to Arnett, granted his petition, and enjoined enforcement of the registration requirements. The Commonwealth appealed. The Superior Court determined that constitutional challenges to SORNA fall within the exclusive jurisdiction of the Supreme Court of Pennsylvania and transferred the appeal accordingly.The Supreme Court of Pennsylvania reviewed whether the PCRA is a proper mechanism for challenging the constitutionality of a non-punitive sexual offender registration statute like SORNA II. The court held that the PCRA, by its plain terms, is limited to challenges related to a conviction or sentence and does not provide a vehicle for relief from non-punitive collateral consequences such as SORNA II’s registration requirements. The court vacated the lower court’s order granting relief, dismissed Arnett’s petition under the PCRA, and declined to address whether other mechanisms—such as habeas corpus—may be used to challenge SORNA II, reserving that question for future cases. View "Commonwealth v. Arnett" on Justia Law

A 12-year-old seventh-grade student was accused by a classmate of inappropriate touching at school. The following day, two police officers, neither previously known to the student, removed him from class for questioning. The first interrogation took place in a small, closed office used by the school resource officer, with one officer questioning the child and another, fully uniformed and armed, standing in front of the door. No Miranda warnings were given, and the student was not told he could leave, refuse to answer, or contact his parents. He eventually admitted that he may have accidentally touched the other student. Less than an hour later, questioning continued in a school suspension cubicle, where multiple authority figures, including the officers and an assistant principal, stood around him and asked more direct questions, resulting in a similar admission.The State charged the student with Fourth Degree Sexual Assault. Before trial in the Manitowoc County Circuit Court, the student sought to suppress his statements to law enforcement, arguing violations of Miranda v. Arizona and involuntariness. The circuit court denied suppression, finding the interrogations non-custodial and voluntary. After a bench trial, the court adjudicated the student delinquent. The Wisconsin Court of Appeals affirmed, holding that Miranda did not apply because the student was not in custody and that his statements were voluntary.The Supreme Court of Wisconsin reviewed the case. It concluded that the student was in custody for Miranda purposes during both interrogations and that the lack of Miranda warnings rendered his statements inadmissible. However, the court found that admitting the statements was harmless error: the essential evidence was provided by other witnesses, and the statements were not crucial to the finding of delinquency. The Supreme Court of Wisconsin affirmed the decision of the court of appeals. View "State v. K. R. C." on Justia Law

Two men entered a Pittsburgh home in 2014 during a robbery, confronting the residents, Leonard Butler and Tina Chapple. Both victims were forced into the basement at gunpoint. While one perpetrator, later identified as Derek Lee, pistol-whipped Butler and took his watch, Butler struggled with the other participant, Paul Durham, resulting in Butler’s death by gunfire. The investigation linked Lee to the scene via a rental vehicle and a victim’s identification. Lee was charged and a jury found him guilty of second-degree murder, robbery causing serious bodily injury, and conspiracy, but not first-degree murder. By law, second-degree murder in Pennsylvania—felony murder—carries a mandatory sentence of life without parole, which was imposed.Lee did not file a direct appeal but, after post-conviction proceedings restored his rights, he moved to modify his sentence, arguing that mandatory life without parole for felony murder was unconstitutional under both the United States and Pennsylvania Constitutions. The Allegheny County Court of Common Pleas denied relief, as did the Pennsylvania Superior Court, which found itself bound by prior case law holding that such a sentence was not cruel and unusual punishment, particularly for adults, and that the state constitution provided no broader protection than its federal counterpart.The Supreme Court of Pennsylvania reviewed whether a mandatory life without parole sentence for all felony murder convictions, without individualized assessment of culpability, violates the Eighth Amendment or Article I, Section 13 of the Pennsylvania Constitution. The Court held that, although the sentence does not violate the Eighth Amendment as currently interpreted by the U.S. Supreme Court, Article I, Section 13 provides greater protection. The Court concluded that mandatory life without parole for all felony murder convictions, absent consideration of individual culpability, constitutes cruel punishment under the Pennsylvania Constitution. The order of the Superior Court was reversed, the sentence vacated, and the case remanded for resentencing, with a 120-day stay for legislative action. View "Commonwealth v. Lee" on Justia Law