Justia Constitutional Law Opinion Summaries

An individual was indicted in Oregon for unauthorized use and possession of a stolen vehicle, alleged to have occurred in August 2021. After the charges were initially dismissed without prejudice in October 2022 due to the state's inability to appoint counsel, the same charges were refiled in April 2024. Upon arraignment, the defendant requested appointed counsel and was found eligible, but no attorney was available. Despite multiple hearings over several months to appoint counsel, the defendant remained unrepresented and subject to pretrial release conditions, including mandatory court appearances and restrictions on travel.In December 2024, a volunteer attorney entered a limited appearance to file a motion to dismiss based on the lack of counsel, arguing violations of Oregon's constitutional right to counsel. The Multnomah County Circuit Court denied the motion, noting the case was in "suspended animation" due to the absence of counsel. The defendant then petitioned the Supreme Court of Oregon for mandamus relief. While briefing was ongoing, the trial court ultimately dismissed the criminal case without prejudice in April 2025, citing lack of available attorneys.The Supreme Court of Oregon reviewed the mandamus petition and found the case was moot since the underlying criminal charges had already been dismissed. However, the court exercised its discretion under ORS 14.175 to address the recurring legal issue. On the merits, the court held that the state violated the defendant's right to counsel under Article I, section 11 of the Oregon Constitution by failing to appoint counsel post-arraignment for an extended period. The court determined that dismissal without prejudice is an appropriate remedy for such violations and established a general rule: if an eligible defendant is unrepresented for more than 60 consecutive days in a misdemeanor case or 90 consecutive days in a felony case post-arraignment, dismissal without prejudice is required. The alternative writ of mandamus was dismissed as moot. View "State v. Roberts" on Justia Law

A seventeen-year-old defendant was charged with murder after stabbing another individual during an altercation in a Grand Forks, North Dakota apartment parking lot. The victim died from the stab wound. With the assistance of counsel, the defendant entered into a plea agreement, pleading guilty to murder. The agreement stipulated a sixty-year sentence with twenty years suspended, and permitted the defendant to request a downward departure to as low as fifteen years. During the plea hearing, the court confirmed the defendant’s understanding of the plea and its consequences, and accepted the plea as voluntary.The District Court of Grand Forks County, Northeast Central Judicial District, presided over the case. At sentencing, the court reviewed investigative reports, victim impact statements, and arguments from both sides. The court considered the defendant’s age and behavior, including social media posts related to the incident. Ultimately, the court imposed a sixty-year sentence with twenty years suspended, consistent with the plea agreement, without granting a downward departure. The defendant did not object to the adequacy of the plea colloquy or move to withdraw the guilty plea before sentencing.The Supreme Court of North Dakota reviewed the appeal. The defendant argued that the plea was not knowing, voluntary, or intelligent due to an insufficient Rule 11 colloquy, and that the forty-year sentence was cruel and unusual punishment. The court applied the obvious error standard, finding that the District Court erred by not adequately establishing a factual basis for the plea, but concluded the error did not affect the defendant’s substantial rights. The court further held that the forty-year sentence was not grossly disproportionate to the offense and did not violate the Eighth Amendment. The Supreme Court affirmed the amended criminal judgment. View "State v. Haskins" on Justia Law

Marquis Kennedy sought employment as a police officer with the City of Arlington, Texas, and enrolled in the Arlington Police Academy after passing a physical exam. During a mandatory training exercise known as Gracie Survival Tactics, which involved intense self-defense scenarios, Marquis reportedly complained of fatigue, thirst, and lightheadedness, but was not permitted breaks or water. He continued participating, allegedly due to fear of failing and repeating the training. During the final scenario, Marquis signaled distress, but the instructors continued the exercise until he could not proceed. After the simulation ended, Marquis requested an ambulance, was assisted to a break room, and subsequently suffered cardiac arrest. Emergency services were called, and Marquis was taken to a hospital, where he died two days later. The autopsy listed cardiac arrest as the cause of death, likely due to atherosclerotic cardiovascular disease.Kennedy, Marquis’s widow, brought suit in the United States District Court for the Northern District of Texas against the City and several officers, asserting Fourth and Fourteenth Amendment violations under 42 U.S.C. § 1983, including claims for excessive force, deliberate indifference to medical needs, bystander liability, and municipal liability for failure to train officers. The City moved to dismiss and submitted video evidence of the training, which Kennedy referenced in her claims. The magistrate judge recommended dismissal of all claims, finding no plausible constitutional violation, no constitutional seizure, and no duty of medical care in an employment setting. The district court adopted these findings and dismissed the case.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that Kennedy failed to plausibly allege a Fourth Amendment seizure or substantive due process violation, and that no constitutional duty of medical care existed in this employment context. The court also found no basis for bystander or municipal liability. View "Kennedy v. City of Arlington, Texas" on Justia Law

Two individuals were found sleeping in a parked car outside a casino in Kalispell, Montana, prompting an employee to request law enforcement both conduct a welfare check and ask the occupants to leave the premises. Flathead County Sheriff’s Deputies approached the vehicle, spoke with the occupants—Christina Torres and Randy Joe Fish—and requested Fish’s identification. After Fish provided his name and date of birth, a warrant check revealed Fish had an outstanding arrest warrant. Fish was arrested, and a subsequent search uncovered less than 0.1 gram of methamphetamine in his pocket.Fish was charged with Felony Criminal Possession of Dangerous Drugs in the Eleventh Judicial District Court, Flathead County. He moved to suppress the methamphetamine evidence, arguing the officers conducted a Terry stop without sufficient justification since they requested his name absent reasonable suspicion of illegal activity, thus violating his constitutional rights. The State responded that the interaction did not amount to a seizure, or alternatively, that the officers had particularized suspicion to investigate a possible trespass. After an evidentiary hearing, the District Court denied Fish’s suppression motion, concluding there was no Terry violation because the deputies acted appropriately given the circumstances and the property owner’s request.The Supreme Court of the State of Montana reviewed the District Court’s denial of the suppression motion. It presumed Fish was seized for constitutional analysis but found the initial police contact was justified under the community caretaker doctrine. When the welfare check was complete, the deputies had particularized suspicion to investigate trespass due to the request to remove Fish from the property. The Court held the officers’ actions did not violate the Fourth Amendment or Article II, Section 11 of the Montana Constitution and affirmed the District Court’s denial of Fish’s motion to suppress. View "State v. Fish" on Justia Law

Ronald Heath was sentenced to death for the 1989 murder of Michael Sheridan in Alachua County, Florida. Heath and his brother Kenneth conspired to rob Sheridan after meeting him at a bar, and the crime escalated when Heath stabbed Sheridan and instructed Kenneth to shoot him. Evidence at trial included testimony from Kenneth and physical evidence linking Heath to the victim’s property. The jury convicted Heath of first-degree murder and related offenses, recommending death by a vote of ten to two. The trial court imposed the death sentence, finding aggravating circumstances outweighed mitigating factors.Following affirmance of his conviction and sentence by the Supreme Court of Florida and denial of certiorari by the United States Supreme Court, Heath pursued multiple postconviction challenges in state and federal courts, all of which were unsuccessful. After his death warrant was signed in January 2026, Heath filed a second successive motion for postconviction relief in the Circuit Court of Alachua County. He raised claims regarding Florida’s lethal injection protocol, secrecy in clemency proceedings, his psychological age due to traumatic incarceration, and the nonunanimous jury recommendation. The circuit court summarily denied all claims and associated public records requests.The Supreme Court of Florida reviewed Heath’s appeal and habeas petition. It affirmed the circuit court’s summary denial of postconviction relief and public records requests, finding Heath’s claims were either speculative, procedurally barred, untimely, or insufficient under relevant legal standards. The Court held Heath failed to demonstrate a substantial and imminent risk with the execution protocol, did not raise a colorable clemency claim, and was not entitled to relief based on psychological age or nonunanimous jury vote. The Court also denied Heath’s habeas petition and his motion for a stay of execution. View "Ronald Palmer Heath v. State of Florida" on Justia Law

A municipal tax collector initiated a bank execution action against an individual to collect unpaid personal property taxes owed by a business with which the individual was previously associated. The individual had moved to California years earlier and claimed that she never received notice of the tax debt or an opportunity to contest it, despite providing her new address to the tax collector. Previous bank executions had been initiated, but the individual continued to assert lack of notice. In the 2021 action, the trial court found that the tax collector failed to comply with statutory notice requirements and that the individual had not been afforded due process, leading the court to grant her exemption from the execution.Following the 2021 judgment, the tax collector withdrew its appeal and attempted a new bank execution after sending written demand to the individual's California address, but did not provide a new tax bill or opportunity to challenge it. The individual again moved for exemption. The Superior Court concluded that the new execution was a collateral attack on the previous judgment and was barred by doctrines of res judicata and collateral estoppel. The Appellate Court affirmed, finding that the issue of notice and opportunity to challenge the tax debt had been actually litigated and necessarily determined in the prior action.Upon review, the Connecticut Supreme Court held that collateral estoppel barred the municipal tax collector from relitigating whether it could execute on the individual's funds without first providing adequate notice and an opportunity to challenge the underlying tax debt. The Court determined that both independent, alternative grounds supporting the earlier judgment were entitled to preclusive effect and declined to create a public policy exception for municipal tax collection actions. The Supreme Court affirmed the judgment of the Appellate Court. View "Torrington Tax Collector, LLC v. Riley" on Justia Law

Steve Boria was indicted for leading a gang involved in distributing narcotics and committing violent acts. He distributed crack cocaine and was involved in a firearm discharge. After most co-defendants pleaded guilty, Boria opted to plead guilty as well. On the night before his plea hearing, he took medications for sleeping problems and bipolar disorder. During the plea colloquy before the United States District Court for the Southern District of New York, the magistrate judge inquired about his medication use, confirmed he felt clearheaded, and verified his understanding of the proceedings. Both defense counsel and the government had no objections to Boria’s competence. Boria responded cogently to the court’s questions and the court found his plea voluntary and knowing, subsequently sentencing him to fifteen years.Boria’s counsel failed to file a timely notice of appeal after sentencing. The district court found this constituted ineffective assistance of counsel, vacated the judgment, and re-entered it to allow Boria to appeal. Boria then timely appealed the amended judgment.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not violate Federal Rule of Criminal Procedure 11 or Boria’s constitutional rights. The appellate court found the district court’s inquiry sufficient to ensure Boria’s understanding and voluntariness of the plea, as Boria’s conduct during the hearing raised no concerns regarding his competency. Additionally, the Second Circuit determined that Boria failed to show plain error, as there was no reasonable probability he would not have pleaded guilty but for the alleged procedural error. Accordingly, the Second Circuit affirmed the judgment of the district court. View "United States v. Boria" on Justia Law

Empower Oversight Whistleblowers & Research, a nonprofit organization, filed a motion to intervene in a closed grand jury proceeding and sought to unseal Department of Justice applications for non-disclosure orders related to a 2017 grand jury subpoena for Google account records. At the time of the subpoena, Jason Foster, Empower’s founder, was the Chief Investigative Counsel for the Senate Judiciary Committee, investigating alleged misconduct at the Department. Google notified Foster in 2023 that a subpoena and non-disclosure order had been issued and extended multiple times. Empower argued that the applications should be unsealed, claiming they were judicial records subject to public access under common law and the First Amendment, and that grand jury secrecy had been waived due to public disclosures.The United States District Court for the District of Columbia permitted Empower to intervene but granted only partial unsealing. It held that the applications were ancillary grand jury records protected by Federal Rule of Criminal Procedure 6(e)(6), limiting unsealing to jurisdictional and legal standard sections. The court found no waiver of secrecy, as disclosures were not sufficiently public to meet the threshold established by precedent. Most of the documents remained sealed, and Empower appealed.The United States Court of Appeals for the District of Columbia Circuit reviewed for abuse of discretion and affirmed the district court’s decision. The appellate court held that the applications were covered by Rule 6(e)(6), which displaces any common law or First Amendment right of access, and that grand jury secrecy had not been waived by the disclosures identified by Empower. The court also declined to review new evidence (the December 2024 OIG report) not presented to the district court but remanded the case for the lower court to consider whether to allow Empower to amend its motion and supplement the record with the OIG report. View "In re: Application of the United States for an Order Pursuant to 18 U.S.C. 2705(b)" on Justia Law

A man was accused of surreptitiously recording his 13-year-old stepdaughter with his cellphone while she was undressing in the bathroom. His wife reported the incident to police, providing video evidence from a hidden camera that appeared to show him engaging in inappropriate conduct outside his stepdaughters’ bedrooms. Detectives confronted the man at his workplace, and after he indicated he wanted a lawyer, he handed over his cellphone when asked by police. The officers immediately informed him they were seizing the device but did not search it until obtaining a warrant the next day. Upon searching the phone, police found incriminating photos and videos, leading to a grand jury indictment on charges including video voyeurism and sexual exploitation of a child.The District Court of the Fourth Judicial District, Ada County, reviewed the defendant’s motion to suppress the cellphone and its contents, arguing the seizure was a Fourth Amendment violation due to the lack of a warrant or valid exception. At a suppression hearing, the court heard testimony from the detective about his concern that evidence could be quickly deleted if the phone was not seized immediately. The district court denied the motion to suppress, concluding that exigent circumstances justified the warrantless seizure because of the imminent risk that evidence would be destroyed.On appeal, the Supreme Court of the State of Idaho reviewed the district court’s denial of the motion to suppress. The Idaho Supreme Court held that the warrantless seizure of the cellphone was justified under the Fourth Amendment’s exigent circumstances exception due to the risk of imminent destruction of evidence. The court clarified that this exception applied based on the totality of the circumstances and did not create a per se rule for all cellphone cases. The judgment of the district court was affirmed. The court also found that any issues regarding parole conditions were moot due to their removal from the amended judgment. View "State v. Smith" on Justia Law

Michael Donnell Lee was arrested shortly after the shooting death of Aaron James Grant in Atlanta, which occurred in the early morning hours of June 15, 2022. Following his arrest, Lee participated in a custodial interview at the Atlanta Police Department, during which he made incriminating statements to Detective Charles Sendling. The interrogation was recorded, and during the interview, Lee confirmed his understanding of his Miranda rights and explicitly stated that he did not wish to speak with the detective without a lawyer, effectively invoking his constitutional rights to counsel and to remain silent.Prior to trial, the State of Georgia filed a motion in limine in the Superior Court of Fulton County, seeking to admit Lee’s incriminating statements as evidence. The trial court denied the State’s motion, ruling that the statements were inadmissible under Miranda v. Arizona and Edwards v. Arizona, because Lee had invoked his rights and had not reinitiated communication with law enforcement before further interrogation occurred. The trial court found that Lee’s subsequent questions to the detective about the charges did not demonstrate a willingness or desire to engage in a generalized discussion about the investigation.On interlocutory appeal, the Supreme Court of Georgia reviewed the trial court’s suppression ruling de novo, considering whether Lee’s conduct following his invocation of rights constituted a valid reinitiation of communication permitting further interrogation. The Supreme Court of Georgia held that Lee’s clarifying questions about the charges did not amount to reinitiation under the standards set forth in Miranda and Edwards. Furthermore, Lee’s agreement to speak to the detective was precipitated by improper interrogation rather than by his own considered deliberation. Therefore, the Supreme Court affirmed the trial court’s suppression of Lee’s statements. View "THE STATE v. LEE" on Justia Law