Justia Constitutional Law Opinion Summaries

In this case, a young woman was fatally shot on a Providence street in August 2021 while standing with her boyfriend beside her parked car. The shooting involved a dark sedan that sped by and fired multiple shots, striking the victim. The case remained unsolved for several months until, in December 2021, police stopped a vehicle for traffic violations. The defendant, seated in the rear, was among the occupants. After observing suspicious behavior and a lowered window in inclement weather, officers retraced the vehicle’s route and found a satchel containing a firearm. Forensic testing later matched the gun to shell casings from the murder scene and identified the defendant as the primary DNA contributor. Investigators also obtained incriminating information from an associate of the defendant, including phone communications linking him to the crime.After the defendant was indicted on multiple charges related to the murder and weapon offenses, he filed pretrial motions in Providence County Superior Court to suppress cell phone records obtained via search warrant and DNA evidence from a buccal swab he had consented to during police questioning. Following an evidentiary hearing, the Superior Court denied both motions. At trial, the jury convicted the defendant of most counts, and the trial justice sentenced him to two consecutive life terms plus additional years. The defendant appealed, arguing that the cell phone warrant lacked probable cause and that his consent to the DNA swab was not voluntary.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s judgment. It held that the affidavit supporting the cell phone warrant, when considered in totality, established probable cause. It further held that the defendant’s consent to the buccal swab was voluntary under the totality of the circumstances. The court found no constitutional violations and upheld the convictions. View "State v. Pinkerton" on Justia Law

A man checked into a hotel room in New Jersey in April 2021 and later moved to a larger room, turning in his key for the first room. After the initial room was cleaned, hotel staff discovered two handguns and letters with distinctive handwriting in the room’s safe. Police, notified by the hotel manager, linked the man to the room and discovered he had an outstanding arrest warrant. After a standoff, police arrested the man in his new hotel room. A search warrant was obtained and, upon execution, police found large quantities of various drugs, drug packaging materials, cash, and additional evidence hidden above the room’s ceiling tiles, including drug trafficking paraphernalia and letters matching those previously found.A federal grand jury indicted the man for being a felon in possession of firearms, possessing fentanyl and methamphetamine with intent to distribute, and possessing a firearm in furtherance of a drug-trafficking crime. He moved to suppress the evidence obtained from the hotel room, arguing the search exceeded the warrant’s scope. The United States District Court for the District of New Jersey denied the motion, finding probable cause supported the warrant and, alternatively, the good-faith exception applied. At trial, the court allowed a detective to give lay opinion testimony about drug trafficking based on his experience. The jury found the defendant guilty on all charges, and he was sentenced to 192 months’ imprisonment.On appeal, the United States Court of Appeals for the Third Circuit reviewed three claims: that the search of the ceiling was improper, that improper lay opinion testimony was admitted, and that the court erred in denying a spoliation instruction related to missing body camera footage. The Third Circuit held the search did not violate the Fourth Amendment, the admission of some improper lay opinion testimony was harmless given overwhelming evidence, and the denial of a spoliation instruction was not an abuse of discretion. The court affirmed the convictions and sentence. View "USA v. Evans" on Justia Law

Nathan was emergently detained and subsequently subjected to involuntary commitment proceedings under Wisconsin law after reporting auditory hallucinations that suggested self-harm. During the circuit court hearings, Nathan’s counsel indicated that Nathan was not contesting the commitment or involuntary medication orders, and the court accepted this stipulation after some discussion on the record. Nathan expressed a desire for release but ultimately agreed to the commitment, particularly after assurances regarding his likely discharge timeline.Following entry of the six-month commitment and involuntary medication orders by the Sheboygan County Circuit Court, Nathan filed a post-disposition motion arguing his due process rights were violated because the court did not conduct a colloquy to ensure his stipulation was made knowingly, intelligently, and voluntarily. The circuit court denied this motion. Nathan appealed both the entry of the orders and the denial of his post-disposition motion. The Wisconsin Court of Appeals affirmed the circuit court’s orders.The Wisconsin Supreme Court reviewed whether constitutional due process requires a circuit court to conduct a colloquy before accepting a stipulation to orders for commitment and involuntary medication. The Court held that due process does not require such a colloquy in this context. The absence of a colloquy is not a structural constitutional error; rather, a due process violation would arise only if a waiver of fundamental rights was not entered knowingly, intelligently, and voluntarily. Because Nathan did not otherwise challenge the validity of his waiver, the Supreme Court affirmed the Court of Appeals’ decision. View "Sheboygan County v. N. A. L." on Justia Law

The case concerns an apartment complex owner who challenged a school district’s policy for appealing property tax assessments. The district’s policy only targeted properties for appeal if an increase would yield at least $10,000 in additional annual tax revenue. This policy, in place since 2012, did not discriminate by property type and had led to appeals involving various categories, including residential and commercial properties. For the tax year at issue, the district’s consultant identified fifteen properties meeting the threshold, and the district later added the taxpayer’s property, making a total of sixteen appeals. The taxpayer’s property had recently been sold, and its assessed value was significantly below its stipulated fair market value.After the Chester County Board of Assessment Appeals denied the school district’s appeal, the district sought review in the Chester County Court of Common Pleas. At a de novo hearing, the parties stipulated to the property’s fair market value. The main issue was whether the district’s policy was constitutional, both on its face and as applied. The county court sided with the district, finding the policy neutral and not discriminatory. The Commonwealth Court reversed, holding that the district arbitrarily applied its policy by not appealing all properties meeting the threshold, failing to justify certain choices, and by not appealing some properties for reasons unrelated to value.The Supreme Court of Pennsylvania reviewed the case. It held that a taxing district’s use of a monetary threshold for selecting properties to appeal does not violate the state constitutional requirement of tax uniformity, so long as the policy is neutral and not based on impermissible classifications such as property type. The Court further found that the district’s application of its policy in this instance was not arbitrary or discriminatory under the Uniformity Clause or Equal Protection Clause. The judgment of the Commonwealth Court was vacated and the case remanded for consideration of any remaining issues. View "Downingtown Area SD v Chester Cnty Bd of Assmt." on Justia Law

After a fatal shooting on May 9, 2021, the defendant and the victim, who were friends, co-workers, and neighbors, were involved in an altercation at their apartment complex in DeKalb County, Georgia. The defendant admitted to shooting the victim multiple times, including a fatal shot to the head. Evidence showed both men had been drinking prior to the incident, and there were conflicting accounts about the presence of an argument or whether the victim was armed. Forensic evidence indicated that the victim was shot in the head at close range while lying on the ground, and no firearm was found on or near the victim.The defendant was indicted and tried in the Superior Court of DeKalb County on charges including malice murder and possession of a firearm during the commission of a felony. His first trial ended in a hung jury. At a second trial, a jury convicted him on all counts. The court sentenced him to life imprisonment for malice murder and a consecutive suspended term for the firearm offense. Following the denial of his amended motion for new trial, the defendant appealed.The Supreme Court of Georgia reviewed the case. It held that the evidence was constitutionally sufficient to support the convictions, as a rational jury could find guilt beyond a reasonable doubt and reject the self-defense claim. The court found no abuse of discretion in admitting the defendant’s post-arrest statements, determining he understood his rights and communicated effectively in English. Although the court expressed concern over the shackling of the defendant during trial without specific findings, it concluded any error was harmless since the shackles were not visible to jurors. The exclusion of the victim’s blood alcohol content was deemed harmless error. Finally, the court determined that the verdict form did not violate due process. The Supreme Court of Georgia affirmed the convictions. View "KAM v. THE STATE" on Justia Law

Three individuals, including the appellant, devised a plan to rob a man from whom they had just purchased cocaine. The group entered the victim’s home; the appellant was armed with another accomplice’s gun. During the robbery, the appellant ordered an accomplice to restrain the victim on a sofa and directed the victim’s girlfriend to lie face-down on the floor. The girlfriend heard someone threaten to shoot the victim, followed by two gunshots. Testimony indicated that the victim tried to grab the appellant’s firearm during a momentary distraction, leading to a struggle in which the gun discharged. The appellant then shot the victim a second time. An autopsy showed the victim died from gunshot wounds to the face and chest.The Superior Court of Bibb County convicted the appellant of malice murder, among other charges. The appellant received a life sentence without parole. Two co-defendants pleaded guilty and testified against him. After conviction, the appellant, initially pro se and later with counsel, moved for a new trial. The trial court denied this motion following a hearing. The appellant then filed a timely appeal.The Supreme Court of Georgia reviewed the case. The appellant argued the trial court erred in rejecting his Batson challenge to the State’s use of peremptory strikes against black jurors and in refusing to instruct the jury on involuntary manslaughter. The Supreme Court held the prosecution provided facially race-neutral reasons for its peremptory strikes, and the trial court’s finding of no discriminatory intent was not clearly erroneous. The Court also found any error in refusing an involuntary manslaughter instruction was harmless because the jury’s malice murder verdict necessarily entailed a finding of intent to kill. The Supreme Court of Georgia affirmed the conviction. View "HAYWOOD v. THE STATE" on Justia Law

The plaintiff claimed he was born in Laredo, Texas, and used a U.S. passport for travel. After reporting his passport stolen in Mexico and later recovering it, he attempted to re-enter the United States, where the passport was retained. Over the following years, he submitted four separate passport applications, each denied by the Department of State. The agency cited concerns including a birth certificate filed by a birth attendant suspected of submitting false records, the existence of a conflicting Mexican birth certificate, and insufficient early life documentation to prove a U.S. birthplace. The plaintiff failed to provide requested records or adequate explanations for the discrepancies.After the repeated denials, the plaintiff petitioned the United States District Court for the Southern District of Texas for a writ of mandamus and declaratory relief, asserting claims under 8 U.S.C. § 1503(a), the Administrative Procedure Act (APA), the Mandamus Act, and constitutional provisions. The district court granted the defendant's motion to dismiss, finding the claims time-barred, jurisdictionally barred, or insufficiently pleaded.The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court held that the plaintiff’s claim under 8 U.S.C. § 1503(a) was untimely, as it was not brought within five years of the first final administrative denial, and equitable tolling was not warranted. The court affirmed that the APA and Mandamus Act claims were jurisdictionally barred because § 1503(a) provides an adequate remedy, regardless of whether the plaintiff timely pursued it. The court also held that the constitutional claims failed to state a claim, as no independent constitutional right to the relief sought existed beyond the statutory remedy. The Fifth Circuit affirmed the district court’s dismissal of all claims. View "Cortez v. Rubio" on Justia Law

Police in Pittsburgh responded late at night to two ShotSpotter alerts that indicated five gunshots were fired near a specific residential address. Officer Powers arrived at the scene within seconds of the second alert and saw a parked car with its headlights on, occupied by the appellant in the driver’s seat and a woman in the passenger seat. As the officer approached with emergency lights on, the appellant exited the car and began walking toward a nearby house, while the passenger made movements inside the car. The officer ordered the appellant to return, and when he did not comply, police drew their weapons and forcibly detained him. Evidence subsequently obtained led to charges including driving under the influence and driving with a suspended license.The Court of Common Pleas of Allegheny County denied the appellant’s motion to suppress evidence, finding the investigative detention was supported by reasonable suspicion. At trial, the court found the appellant guilty on all charges. On appeal, the Superior Court affirmed, reasoning that the combination of the ShotSpotter alerts, the appellant’s proximity in time and space to the reported shots, his presence as one of only two people at the scene, his conduct upon police arrival, and the late hour supported reasonable suspicion for the stop.The Supreme Court of Pennsylvania reviewed whether the Superior Court gave too much weight to the appellant’s proximity to the ShotSpotter alerts in evaluating reasonable suspicion. The Supreme Court held that, although there was insufficient record support to consider the area a high-crime area, the totality of the circumstances—including the ShotSpotter alerts indicating gunfire, the rapid police arrival, the appellant and his companion being the only people present, and their evasive behaviors—provided reasonable suspicion for the investigative detention. The court therefore affirmed the Superior Court’s order upholding the denial of suppression. View "Commonwealth v. Foster" on Justia Law

Two individuals were arrested by the Bentonville Police Department in Arkansas and appeared before a state district court judge two days and one day after their respective arrests. During these initial hearings, the judge set bail amounts for each individual without providing them with legal representation. Only after setting bail did the judge determine that they were indigent and appoint counsel for future proceedings. Both individuals remained incarcerated for several weeks before ultimately pleading guilty and being sentenced to time served.Following their experiences, these individuals, acting on behalf of a class of similarly situated pretrial detainees, filed suit in the United States District Court for the Western District of Arkansas. They alleged that the judge’s practice of setting bail without first appointing counsel violated their rights under the Sixth and Fourteenth Amendments. They sought declaratory and injunctive relief requiring that indigent defendants be provided with counsel at the start of their initial bail hearings. The district court denied motions to dismiss, certified the class, and ultimately granted summary judgment in favor of the plaintiffs. The district court held that the plaintiffs’ right to counsel attached at the initial hearing and that the bail-setting constituted a critical stage, thus granting declaratory and injunctive relief against the judge.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The Eighth Circuit held that the plaintiffs lacked Article III standing because they failed to show an ongoing or imminent injury that could be redressed by the prospective relief sought. The court found that the possibility of facing the same situation again was too speculative and that the requested relief would not redress any past harm already suffered. As a result, the Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of standing. View "Farella v. Anglin" on Justia Law

The plaintiffs challenged two provisions of New York’s Concealed Carry Improvement Act (CCIA): one that criminalizes carrying firearms on private property open to the public unless the owner has explicitly permitted it (the Private Property Provision), and another that prohibits firearm possession in “sensitive locations,” specifically public parks (the Public Parks Provision). Plaintiffs argued that these provisions violate the Second and Fourteenth Amendments. The Private Property Provision was challenged as applied to places open to the public, while the Public Parks Provision was subject to a facial challenge, with plaintiffs later attempting, unsuccessfully, to add an as-applied challenge concerning rural parks.The United States District Court for the Western District of New York permanently enjoined the State from enforcing the Private Property Provision as applied to private property open to the public, finding it unconstitutional because it was not consistent with the nation’s historical tradition of firearms regulation. The district court, however, granted summary judgment to the State on the Public Parks Provision, concluding that it was facially constitutional since historical analogues supported restrictions on firearms in public parks. The district court declined to consider plaintiffs’ as-applied challenge to the parks provision, ruling that this argument had not been properly raised.The United States Court of Appeals for the Second Circuit reviewed both appeals. It affirmed the permanent injunction against the Private Property Provision, holding that the State failed to show that the restriction is consistent with the historical tradition of regulating firearms, as required by New York State Rifle & Pistol Association, Inc. v. Bruen. The court also affirmed the judgment in favor of the State on the Public Parks Provision, finding it constitutional as applied to urban parks, and declined to consider the as-applied challenge regarding rural parks since it had not been raised below. View "Christian v. James" on Justia Law