Justia Constitutional Law Opinion Summaries

The case concerns a defendant who was released from custody on the express condition that he appear at a scheduled adjudicatory hearing related to an unrelated felony. He failed to appear at the specified time and place, leading the State to charge him with the felony offense of Bail Jumping under Montana law. The defendant was arrested about ten weeks after missing the hearing. He pled not guilty and subsequently moved to dismiss the charge, arguing both that the statute was unconstitutionally vague—particularly regarding the requirement that his failure to appear be “without lawful excuse”—and that the State had failed to allege sufficient facts to establish probable cause, since it did not affirmatively show he lacked a lawful excuse.The Twentieth Judicial District Court of Montana denied the defendant’s motion to dismiss. The defendant then entered a plea agreement, reserving his right to appeal the denial of his motion. He admitted to the facts constituting the offense, including that he did not have a lawful excuse for missing the hearing.On appeal, the Supreme Court of the State of Montana reviewed whether Montana’s bail-jumping statute is unconstitutionally vague and whether the State must allege facts negating the existence of a lawful excuse to establish probable cause. The Supreme Court held that the statute provides fair notice and sufficient guidelines to defendants and law enforcement, and is not unconstitutionally vague as applied to the defendant’s conduct. The Court also held that the State is not required to allege or prove the absence of a lawful excuse in its charging documents; rather, the existence of a lawful excuse is an affirmative defense for which the defendant carries the initial burden of production. The Court affirmed the judgment of the District Court. View "State v. Trombley" on Justia Law

The case concerns the suspension of a driver’s license by the California Department of Motor Vehicles (DMV) after the driver, stopped for erratic driving and suspected of being under the influence of alcohol, refused a chemical test when properly advised of the consequences. At the administrative hearing regarding his suspension, the DMV’s hearing officer introduced evidence, asked clarifying questions, and ruled on objections, all while stating she was acting as a neutral factfinder rather than as an advocate for the DMV. The driver argued that the hearing officer’s dual roles violated his due process rights by making her both a prosecutor and adjudicator.After the DMV sustained the license suspension, the driver petitioned the Superior Court of Alameda County for a writ of mandate, claiming that the hearing officer functioned as both advocate and judge, creating an unconstitutional risk of bias. The trial court denied the petition, finding that the DMV’s current policy required hearing officers to act only as neutral decisionmakers and that no due process violation occurred.The California Court of Appeal, First Appellate District, Division Five, reviewed the denial. The court clarified that due process requires an impartial adjudicator but does not prohibit the same person from developing the evidence and making a decision in an administrative setting, so long as there is no disqualifying interest or extraordinary evidence of bias. The court held that the DMV’s current structure does not violate due process, as hearing officers are presumed impartial and their actions in presenting evidence do not turn them into advocates. The judgment of the trial court was affirmed. The court expressly declined to follow recent decisions adopting an “appearance of bias” standard and reinforced that only an actual, constitutionally intolerable risk of bias triggers a due process violation. View "Chi v. Dept. of Motor Vehicles" on Justia Law

In this case, the defendant was convicted in Oregon in 2001 of attempted unlawful sexual penetration in the first degree and sexual abuse in the second degree. After completing his sentence, including probation, in 2014, he moved to Montana in 2016 and registered as a sexual offender as required by law. In 2023, the Montana Department of Justice attempted to verify his address, but the verification was returned undeliverable. The defendant left a voicemail reporting a new address but did not update his registration in person, as required by the current statute.The State of Montana charged the defendant in 2024 with failure to register as a sexual offender, expressly citing the 2023 version of the Sexual or Violent Offender Registration Act (SVORA) in its charging documents. The defendant moved to dismiss, arguing that retroactive application of the 2023 SVORA to his pre-2007 conviction violated the Ex Post Facto Clause of the Montana Constitution. The Second Judicial District Court agreed and dismissed the charge, concluding that applying the 2023 SVORA retroactively was unconstitutional.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s dismissal de novo. The Supreme Court affirmed, holding that because the State charged the defendant under the 2023 SVORA—and this Court has previously held that the post-2007 version of SVORA is punitive and cannot be applied retroactively to convictions predating its enactment—the prosecution could not stand. The Court emphasized that the State could not rely on older versions of SVORA not cited in the charging documents and did not address arguments regarding restoration of rights, limiting its decision to the ex post facto violation. The order of dismissal was affirmed. View "State v. Pratt" on Justia Law

Several individuals and two organizations challenged a Missouri law enacted in 2022, House Bill No. 1878 (HB 1878), which amended the state’s voting requirements by mandating that voters present specific forms of photo identification or cast a provisional ballot under certain conditions. The organizations—the Missouri State Conference of the NAACP and the League of Women Voters of Missouri—along with the individuals, claimed that these provisions unconstitutionally burdened the right to vote and violated equal protection guarantees.Their petition for declaratory and injunctive relief was filed in the Circuit Court of Cole County. After a bench trial, the circuit court found that none of the individual plaintiffs had shown an actual or threatened injury, as each had either successfully voted since the law’s enactment or their alleged difficulties were speculative. The court also determined that the organizations had not established standing, either through a diversion of resources or by identifying any specific member adversely affected by the law. Despite these findings, the circuit court proceeded to rule on the merits, concluding the law was constitutional.The Supreme Court of Missouri, which has exclusive jurisdiction in cases involving the validity of state statutes, reviewed the matter. The Supreme Court affirmed the circuit court’s determination that the appellants lacked standing—meaning none of the plaintiffs demonstrated a concrete, personal stake in the outcome. The Supreme Court held that, because there was no justiciable controversy before the court, the circuit court erred by reaching and deciding the merits of the constitutional claims. Therefore, the Supreme Court reversed that portion of the judgment addressing the merits of the constitutional challenge. The case was thus resolved solely on the issue of standing. View "Missouri State Conference of the National Association for the Advancement of Colored People vs. State" on Justia Law

In 2022, Missouri enacted new legislation that imposed several restrictions on activities related to voter registration and absentee ballot applications. The law prohibited the payment or compensation of individuals for soliciting voter registration applications unless they were government employees, required anyone who solicited more than ten voter registration applications to register with the state, and mandated that solicitors be at least eighteen years old and registered Missouri voters. Additionally, the law completely banned the solicitation of voters to obtain absentee ballot applications. These provisions affected organizations whose work involves encouraging and assisting individuals in registering to vote and informing them about absentee voting.The Circuit Court of Cole County reviewed a lawsuit brought by two civic organizations challenging these provisions as unconstitutional. The organizations argued the restrictions violated rights to free speech, association, and due process under the Missouri Constitution. The court issued a preliminary injunction, and after trial, permanently enjoined enforcement of the provisions, finding them to be facially unconstitutional restrictions on core political speech, overbroad, content- and viewpoint-based, and unconstitutionally vague. The court concluded the state had not shown the provisions were narrowly tailored to serve a compelling governmental interest.On direct appeal, the Supreme Court of Missouri affirmed the circuit court’s judgment. The Supreme Court of Missouri held that the statutory provisions imposed facially unconstitutional restrictions on core political speech protected by article I, section 8 of the Missouri Constitution. The Court found the provisions neither served a compelling state interest nor were narrowly tailored, and instead captured substantial amounts of protected speech unrelated to any compelling interest. The judgment declaring the provisions unconstitutional was affirmed. View "State vs. League of Women Voters" on Justia Law

After the results of the 2020 United States census were certified to the governor of Missouri in August 2021, the Missouri General Assembly established new congressional districts in 2022, as required by the state constitution. In September 2025, the General Assembly passed House Bill 1 (“HB 1”), which repealed the 2022 congressional districts and established new ones, even though no new census had been certified. The governor signed HB 1 into law. A group of plaintiffs challenged the constitutionality of HB 1, arguing that article III, section 45 of the Missouri Constitution restricts the General Assembly to one redistricting following each decennial census certification.The Circuit Court of Cole County heard the case on stipulated facts and rejected the plaintiffs’ claim, finding that HB 1 was a valid exercise of the General Assembly’s legislative authority. The circuit court declared that article III, section 45 does not prevent the General Assembly from redistricting more frequently than once per decade.On appeal, the Supreme Court of Missouri reviewed the constitutional question de novo. The Court held that article III, section 45 obligates the General Assembly to redistrict upon certification of the decennial census but does not expressly prohibit mid-decade or more frequent congressional redistricting. The Court explained that, absent express constitutional restraint, the General Assembly’s legislative power remains plenary. The Court also found that the word “when” in section 45 acts as a trigger for mandatory redistricting but does not serve as a limitation on the legislature’s authority to redistrict at other times.The Supreme Court of Missouri affirmed the circuit court’s judgment, upholding HB 1 as constitutional and concluding that article III, section 45 does not restrict the General Assembly’s power to conduct mid-decade congressional redistricting. View "Luther vs. Hoskins" on Justia Law

Law enforcement officers executed a search warrant for methamphetamine at a rural Wisconsin property, where they believed Ryan Steinhoff, suspected of violent criminal activity, was present. During the early morning search, Steinhoff was found in a camper and, after initially appearing to comply with police orders, was tackled by an officer. In the course of his restraint, Steinhoff sustained a head injury from a rifle barrel, which required stitches. Body-camera footage captured the incident, but it was unclear whether the head injury was caused intentionally or accidentally.Steinhoff filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Wisconsin, alleging that Detective Kowalczyk and Investigator Malovrh used excessive force in violation of the Fourth Amendment. The district court granted summary judgment to Captain Ramberg, as Steinhoff conceded no excessive force was used by him. The court denied summary judgment to Investigator Malovrh on the claim regarding kneeling during handcuffing, and a jury later found in Malovrh’s favor on that issue. The district court granted summary judgment and qualified immunity to Detective Kowalczyk regarding the tackle, finding no clearly established law prohibiting his actions. The court also granted summary judgment to Investigator Malovrh on the rifle strike, concluding no reasonable jury could find the strike intentional.The United States Court of Appeals for the Seventh Circuit affirmed qualified immunity for Detective Kowalczyk, holding that his actions during a high-risk drug raid did not violate clearly established law. However, the appellate court reversed summary judgment for Investigator Malovrh, finding factual disputes about whether the rifle strike was intentional. The court remanded for a jury to resolve those disputes, as a blow to the head with a rifle could constitute excessive force if intentional. View "Steinhoff v Malovrh" on Justia Law

In the early hours of January 24, 2022, the defendant fatally shot one individual and seriously injured another outside a nightclub in Pawtucket, Rhode Island. He did not dispute that he fired the shots, but claimed at trial that he acted in defense of his cousins, whom he believed were in imminent danger after a physical altercation. The incident was captured on video, which at certain points contradicted the defendant’s account. During the trial, the main factual dispute centered on whether the defendant’s use of force was justified under the defense of others doctrine.The case was tried in the Providence County Superior Court. The jury found the defendant guilty of second-degree murder, discharging a firearm during a violent crime resulting in death, and firearm possession offenses, but acquitted him of charges related to the shooting of the second individual. The trial justice sentenced the defendant to a lengthy period of incarceration. During the trial, improper questions from the prosecutor regarding the defendant’s post-arrest silence were objected to and sustained, with the trial justice issuing cautionary instructions to the jury and ultimately denying the defense’s motion for a mistrial.On appeal, the Supreme Court of Rhode Island reviewed whether the trial justice erred in denying a mistrial after the prosecution impermissibly questioned the defendant about his exercise of the right to remain silent. The Supreme Court held that the prosecutor’s questions violated the defendant’s due process rights, as such use of post-arrest silence for impeachment is fundamentally unfair. The Court found that the cautionary instructions did not cure the prejudice resulting from these questions and concluded that a mistrial was warranted. Accordingly, the Supreme Court vacated the conviction and remanded the case for further proceedings. View "State v. Baker" on Justia Law

The petitioner was convicted of first-degree intentional homicide and related charges after a shooting at the Luna Lounge in Appleton, Wisconsin. Video evidence showed several people fleeing the scene, including the petitioner’s brother. Police interviewed three eyewitnesses—Watou Lee, Mikey Thao, and Ryan Thao—shortly after the incident. These witnesses described the shooter but did not explicitly identify the petitioner. However, police later received statements from other witnesses implicating the petitioner. The State did not disclose the initial interviews with Watou, Mikey, and Ryan to the defense and eventually destroyed the recordings, citing the witnesses’ fears for their safety. The defense only learned of the destroyed interviews after the witnesses were reinterviewed and those statements were provided. The petitioner moved to dismiss the charges or, alternatively, to bar the witnesses’ testimony, arguing violations of his due process rights under Brady v. Maryland and the principles set forth in California v. Trombetta and Arizona v. Youngblood.The Wisconsin Circuit Court denied the Brady claim but agreed the destruction of evidence violated due process, barring the State from calling the three witnesses at trial, though permitting the defense to do so. The petitioner did not object to this remedy and ultimately did not call the witnesses. He was convicted by a jury, and his conviction and denial of post-conviction relief were affirmed by the Court of Appeals of Wisconsin, with the Wisconsin Supreme Court declining review.On federal habeas review, the United States District Court for the Eastern District of Wisconsin denied relief, holding that the state appellate court did not act contrary to or unreasonably apply clearly established federal law. The United States Court of Appeals for the Seventh Circuit affirmed, holding that the state court’s application of Brady, Trombetta, and Youngblood was not objectively unreasonable and that the selected remedy did not violate clearly established federal law. View "Lee v Mlodzik" on Justia Law

During the inauguration of Vermont’s governor, a group of protesters, including Shela Linton, staged a sit-in at the state capitol to advocate for universal healthcare. When the building closed, police instructed the protesters to leave or face arrest for trespassing. Some complied, while others, including Linton, refused. Sergeant Jacob Zorn approached Linton, who remained seated and passively resisted. After multiple warnings, Zorn used a rear wristlock to lift Linton to her feet, causing her to exclaim in pain. Linton alleged that this action resulted in physical and psychological injuries.Linton filed a lawsuit under 42 U.S.C. §1983, claiming Zorn’s use of force violated her Fourth Amendment rights. The United States District Court for the District of Vermont granted summary judgment to Zorn, holding he was entitled to qualified immunity because it was not clearly established that his actions constituted excessive force in these circumstances. The United States Court of Appeals for the Second Circuit reversed, relying on its earlier decision in Amnesty America v. West Hartford, reasoning that the use of a rear wristlock on a passively resisting protester was clearly established as excessive force. The Second Circuit remanded the case for a jury trial.The Supreme Court of the United States reviewed the case and held that Zorn was entitled to qualified immunity. The Court determined that Amnesty America did not clearly establish, with the requisite specificity, that Zorn’s conduct—using a wristlock after repeated warnings—violated the Fourth Amendment. The Court emphasized that qualified immunity protects officials unless prior precedent places the constitutional question beyond debate and found that no case had clearly held such conduct unlawful in similar circumstances. Accordingly, the Supreme Court granted certiorari and reversed the judgment of the Second Circuit. View "Zorn v. Linton" on Justia Law