Justia Constitutional Law Opinion Summaries

An inmate at an Illinois women’s prison was repeatedly sexually assaulted by her assigned counselor, who used his authority over her access to her daughter as leverage. After the inmate’s cellmate reported the abuse to a prison investigator, the investigator and the prison warden, instead of moving to protect the victim, devised a plan to use her as unwitting “bait” to catch the counselor in the act. This plan failed, and the abuse continued. The prison’s toxic culture, where staff-on-inmate sexual abuse was widespread and often ignored, provided the backdrop for these events.In the United States District Court for the Central District of Illinois, the inmate filed a civil rights lawsuit under 42 U.S.C. § 1983 against the counselor (who defaulted), the investigator, and the warden, alleging Eighth Amendment violations for cruel and unusual punishment. The district court denied summary judgment for the investigator and warden on qualified immunity and liability, and a jury found all three defendants liable, awarding the plaintiff $19.3 million in compensatory and punitive damages. The district court also excluded evidence suggesting the plaintiff might have consented to the abuse, and denied the investigator and warden’s post-trial motions for judgment as a matter of law or a new trial.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s denial of judgment as a matter of law and denial of qualified immunity for the investigator and warden, holding that no reasonable official could have thought their response was appropriate. However, the appellate court reversed in part, ordering a new trial on compensatory and punitive damages (but not liability) against the investigator and warden, due to insufficient evidence supporting liability before they learned of the abuse, exclusion of relevant evidence affecting punitive damages, and failure to use a special verdict form to distinguish between theories of liability. The attorney fee award was also vacated and remanded for reconsideration. View "Doe v Macleod" on Justia Law

A man was found shot and killed on a snow-covered trail in Saint Louis County, Minnesota. The investigation quickly focused on three individuals: the appellant, his girlfriend, and another accomplice. Key evidence included the murder weapon, Facebook messages discussing plans to harm the victim, and DNA on the weapon matching the appellant. The girlfriend, who was an eyewitness, testified to having seen the appellant shoot the victim. Law enforcement obtained a warrant to search multiple Facebook accounts—those of the appellant, his girlfriend, and the other accomplice—uncovering messages implicating the appellant.After initially pleading guilty to first-degree murder, the appellant challenged the conviction in postconviction proceedings. The Minnesota Supreme Court in Bonnell v. State vacated the guilty plea, remanding the case for trial. Before trial, the appellant moved to suppress evidence from the Facebook searches, arguing that the warrant lacked specificity. The Saint Louis County District Court denied the motion and admitted the evidence at trial, over defense objection. The jury convicted the appellant of first-degree premeditated murder.On direct appeal, the Supreme Court of Minnesota held, as a matter of first impression, that a sender of an electronic message does not retain a reasonable expectation of privacy in a copy of the message stored in the recipient’s separate and independent account or device. Thus, the appellant’s Fourth Amendment protections were not triggered by searches of his accomplices’ Facebook accounts. However, the appellant did have a reasonable expectation of privacy in his own Facebook accounts, and the warrant authorizing those searches was invalid for lack of particularity. Despite this error, the court concluded it was harmless beyond a reasonable doubt because the remaining evidence was overwhelming. The court also found that any errors in admitting certain prior bad acts evidence were harmless. The conviction was affirmed. View "State of Minnesota vs. Bonnell" on Justia Law

A city councilmember in Stevenson, Washington, participated in a protest outside the Skamania County Courthouse on International Transgender Day of Visibility. During the demonstration, she exposed her breasts with the phrase “MY BODY IS NOT A SIN” written on her chest as a form of protest. Police officers approached her regarding potential violation of Washington’s indecent exposure law (RCW 9A.88.010), but she asserted her actions were protected by the First Amendment and was neither arrested nor charged.A local resident filed a recall petition in Skamania County Superior Court, alleging that the councilmember committed malfeasance and violated her oath of office by engaging in indecent exposure, which the petitioner argued justified her removal from office. The Skamania County Superior Court found the recall charge factually and legally sufficient, determining that malfeasance simply required the commission of an unlawful act, and certified the ballot synopsis. The court reasoned that it was ultimately up to voters to decide if the conduct amounted to a violation of the law.The Supreme Court of the State of Washington reviewed the case. The court held that the recall petition was neither factually nor legally sufficient. It found that there was no evidence the councilmember intended to violate the law, as indecent exposure under RCW 9A.88.010 requires intentional open and obscene exposure, and the facts indicated she believed her conduct was lawful protest. Furthermore, the court concluded her actions were constitutionally protected expressive conduct. The court also determined that there was no factual or legal basis for a violation of the oath of office, as her conduct was not related to her official duties. The Supreme Court of the State of Washington reversed the superior court’s ruling and dismissed the recall petition. View "In re Recall of Lauser" on Justia Law

A violent series of confrontations between residents of two Southeast D.C. neighborhoods resulted in several shootings, including two murders and multiple assaults, during 2016 and 2017. One defendant, a resident of Wahler Place, was implicated in these violent acts and was connected to the crimes through witness identifications, forensic ballistics, cell phone location data, and his possession of the firearm used in the shootings. The second defendant, an employee of the Metropolitan Police Department and longtime acquaintance of the first defendant, used her access to police databases to search for information related to the shootings and communicated with the first defendant after each incident.Following an investigation, both individuals were indicted in the Superior Court of the District of Columbia and faced numerous charges. The first defendant moved to suppress evidence based on alleged Fourth Amendment violations related to the seizure and search of his vehicle and cell phones, but the trial court denied these motions. After an eleven-week jury trial, the first defendant was convicted of multiple counts, including murder, assault with intent to kill, firearm offenses, and obstruction of justice. The second defendant was acquitted of the most serious charges but convicted of being an accessory after the fact (AAF) and obstruction of justice. Both appealed.The District of Columbia Court of Appeals affirmed the first defendant’s convictions for murder, assault, and related firearm offenses, concluding that the evidence was sufficient and that the searches satisfied Fourth Amendment exceptions or were admissible under the good-faith exception. However, the court reversed the second defendant’s AAF convictions, holding that the government failed to prove she had actual knowledge of the principal’s crimes when she provided assistance. The court also vacated all obstruction of justice convictions for both defendants, finding the statute did not apply to the proceedings at issue. The case was remanded for further proceedings consistent with these rulings. View "Jennings & Turner v. United States" on Justia Law

On a December evening, a Metropolitan Police Department officer responded to reports of disorderly groups in Southeast Washington, D.C., an area associated with frequent gun-related incidents. The officer observed four men walking and overheard a comment he interpreted as referring to gun violence. He monitored the group and began interacting with them, including Allen Grant, who voluntarily stated he had no guns. Grant carried a satchel, which he moved behind his back when questioned, prompting repeated requests from the officer to see it. Grant denied having anything in the satchel, continued walking, and ultimately threw the satchel over a fence. Another officer found a gun inside the satchel, after which Grant fled and was arrested approximately thirty minutes later.The Superior Court of the District of Columbia presided over the suppression hearing on Grant's motion to exclude evidence from the satchel, arguing an unlawful seizure. The trial court found that Grant had not been seized before discarding the satchel, as he continued walking and ultimately ran, and there was no show of force by officers. The trial court characterized the interaction as an investigatory conversation and denied the motion to suppress. Grant was subsequently convicted by a jury on several firearm-related charges and sentenced to imprisonment and supervised release.The District of Columbia Court of Appeals reviewed the case and affirmed the trial court’s denial of the suppression motion. The Court held that Grant was not seized within the meaning of the Fourth Amendment prior to discarding the satchel, as he did not submit to the officer’s show of authority. The evidence found in the satchel was not the fruit of an illegal seizure. The Court applied a de novo review to legal issues and deferred to factual findings unless clearly erroneous. The order denying suppression was affirmed. View "Grant v. United States" on Justia Law

In this case, the defendant was convicted of first-degree murder and robbery with a firearm for the 1991 killing of a police officer during a traffic stop. After initial convictions and a direct appeal, a new penalty phase was ordered, and the defendant was again sentenced to death in 1996. The trial court found two aggravating factors, including that the murder was committed during a robbery and to hinder law enforcement, outweighing the mitigating circumstances related to the defendant’s age, confession, courtroom behavior, and difficult childhood. The Florida Supreme Court affirmed the convictions and death sentence, which became final in 2001. Over the following decades, the defendant pursued numerous unsuccessful challenges to the conviction and sentence in state and federal courts.Following the signing of a death warrant in January 2026, the defendant filed a sixth successive motion for postconviction relief in the Circuit Court for St. Lucie County. He raised three claims: newly discovered evidence of jury influence by uniformed officers, a claim of intellectual disability based on a recent IQ test, and a challenge to the constitutionality of Florida’s death warrant process. The circuit court summarily denied all claims, as well as related motions for a juror interview, to declare the intellectual disability standard unconstitutional, and for late-filed public records requests.On review, the Supreme Court of Florida affirmed the circuit court’s denial of postconviction relief, denied the habeas corpus petition, and denied the motions for a stay of execution. The Court held that the claims of improper jury influence and intellectual disability were untimely and procedurally barred, the request for a juror interview and public records were properly denied as untimely and speculative, and that the intellectual disability claim was also legally insufficient. The Court further declined to extend Eighth Amendment protections beyond current U.S. Supreme Court precedent. View "Kearse v. State" on Justia Law

A woman was reported to military authorities at Joint Base San Antonio Lackland by a concerned parent in April 2022. The parent alleged that the woman sent explicit text messages to her thirteen-year-old son, provided him a cell phone, and facilitated meetings between him and her own twelve-year-old daughter. An investigation revealed that the woman encouraged and orchestrated sexual activity and explicit exchanges between the children. She was charged with several federal sex offenses but, pursuant to a plea agreement, pleaded guilty to a single offense—Sexual Performance by a Child—under the Assimilative Crimes Act (ACA), which incorporates Texas Penal Code § 43.25 into federal law.The United States District Court for the Western District of Texas classified her conviction as a Class A felony by reference to the Texas statute’s penalties. The Presentence Report (PSR) and the district court applied 18 U.S.C. § 3583(k), which governs supervised release for enumerated federal sex offenses, sentencing her to 325 months in prison and thirty years of supervised release. She appealed her sentence, arguing that the proper statutory maximum for supervised release should be five years under 18 U.S.C. § 3583(b), not the five years to life provided by § 3583(k). The government responded that the sentence was permissible, as it did not exceed the Texas statutory maximum and that the most analogous federal offense fell within § 3583(k).The United States Court of Appeals for the Fifth Circuit held that § 3583(k) applies only to the specific federal offenses enumerated within it and not to offenses assimilated under the ACA. The court found the statutory text unambiguous and determined that the supervised release term for the assimilated state offense was subject to the general five-year maximum set by § 3583(b). The court vacated the thirty-year supervised release term and remanded for resentencing within the proper statutory maximum. View "USA v. Swarner" on Justia Law

During his murder trial, the defendant chose to testify in his own defense, claiming self-defense in the fatal stabbing. Partway through his testimony, the trial was interrupted by a 24-hour overnight recess. Before the break, the trial judge instructed the defendant’s attorneys not to “manage” or shape his ongoing testimony during the recess but clarified that the defendant was not barred from speaking with his lawyers about other matters, such as sentencing or trial strategy. After the recess, the defendant resumed testifying and was later convicted of murder.Upon appeal, the Texas Court of Criminal Appeals reviewed the trial judge’s conferral order. The appellate court found that the order was constitutionally permissible because it only restricted discussions specifically about managing the defendant’s ongoing testimony, not all attorney-client consultations. The appellate court emphasized that the order did not prevent the defendant from consulting his attorneys on other protected matters, such as plea negotiations or trial strategy, and was therefore a proper exercise of the trial court’s discretion.The Supreme Court of the United States addressed whether a qualified order limiting discussion of a defendant’s ongoing testimony during a midtestimony overnight recess violates the Sixth Amendment right to counsel. The Supreme Court held that such a qualified order is constitutional, so long as it prohibits only discussion of testimony for its own sake and does not prevent consultation on other protected topics, including trial strategy, plea discussions, or evidentiary issues. The Court distinguished this qualified order from a total ban on attorney-client discussions and affirmed that the order properly balanced the defendant’s right to counsel against the integrity of unaltered trial testimony. The judgment of the Texas Court of Criminal Appeals was affirmed. View "Villarreal v. Texas" on Justia Law

Law enforcement initiated a multi-agency investigation in Millville, New Jersey, following a series of shootings, aiming to address local gun violence and weapons trafficking. The defendant was not initially linked to the violence but became a subject after a wiretap intercepted calls about a potential firearm purchase. Surveillance led police to search an apartment they saw the defendant enter; they recovered heroin, cocaine, drug paraphernalia, and two revolvers. Though one witness initially connected a weapon to the defendant, he later recanted. The defendant was arrested and charged with controlled dangerous substances (CDS) and weapons offenses.The Superior Court, Law Division, handled pretrial motions to limit references to search warrants and the Organized Crime Bureau, with the State agreeing to certain restrictions. During trial, the prosecutor referenced the television show The Wire in opening statements, drawing parallels to organized crime. State witnesses made repeated references to gun violence, weapons trafficking, and the Organized Crime Bureau. Despite objections, the State and its witnesses repeatedly mentioned the search warrant. The jury acquitted the defendant of weapons charges but convicted him of CDS offenses. The Superior Court, Appellate Division, affirmed the convictions, finding no reversible errors either individually or cumulatively.The Supreme Court of New Jersey reviewed whether the prosecutor’s references to The Wire, gun violence, and the search warrant, as well as to the Organized Crime Bureau, deprived the defendant of a fair trial. The Court held that, while no single error warranted reversal on its own, the cumulative effect of these improper references undermined the fairness of the proceedings and deprived the defendant of his constitutional right to a fair trial. Accordingly, the judgment was reversed and the matter remanded for a new trial. View "State v. Butler" on Justia Law

A young man, referred to as Jared, was charged with battery to a law enforcement officer after an incident in which he threatened his family and police, and struck an officer. Following his arrest, concerns about Jared’s mental health led to a competency evaluation. He was diagnosed with schizophrenia and found incompetent to stand trial. While initially taking prescribed medication inconsistently in jail, Jared later refused medication in a mental health institution, resulting in disruptive and aggressive behavior. The State, through a Department of Health Services doctor, sought and obtained a Milwaukee County Circuit Court order for involuntary medication to restore Jared’s competency for trial.On appeal, Jared challenged the involuntary medication order, arguing that neither the statutory requirements under Wisconsin law nor the constitutional standards articulated in Sell v. United States were met. The Wisconsin Court of Appeals reversed, finding the circuit court’s findings on both the statutory and Sell factors clearly erroneous and concluding that the State had not sufficiently established any of the four Sell factors necessary for involuntary medication.The Supreme Court of Wisconsin reviewed the case to clarify the standard of appellate review for each of the Sell factors and to determine whether the circuit court’s application of those factors and the statutory requirements was correct. The Supreme Court held that the question of whether an important governmental interest exists (Sell factor one) is reviewed de novo, while the remaining three Sell factors (significant furtherance of the interest, necessity, and medical appropriateness) are findings of fact reviewed for clear error. The Supreme Court found that the State’s interest in prosecuting Jared was important and not sufficiently diminished by special circumstances. It further held that the lower court’s findings on the remaining Sell factors and the statutory requirements were not clearly erroneous. The Supreme Court reversed the Court of Appeals, reinstating the circuit court’s order for involuntary medication. View "State v. J. D. B." on Justia Law