Justia Constitutional Law Opinion Summaries

The defendant pleaded guilty in 2014 to multiple offenses, including two counts of attempted murder and a firearm enhancement, as part of a plea deal. He agreed to a stipulated sentence of 25 years in prison, which included the upper term for attempted murder. He also admitted a prior prison term enhancement. Years later, after legislative changes invalidated certain prison prior enhancements and amended sentencing rules for upper terms, the defendant was resentenced under Penal Code section 1172.75. The trial court dismissed the prison prior enhancement and reduced his controlled substance conviction to a misdemeanor, lowering his overall sentence to 23 years and 4 months.At the Orange County Superior Court, the judge imposed the upper term for attempted murder during the original sentencing pursuant to the plea agreement. During resentencing under section 1172.75, the court removed the prison prior enhancement but reimposed the upper term for attempted murder without requiring a jury finding or defendant stipulation regarding aggravating factors. The defendant appealed, arguing that recent amendments to Penal Code section 1170, subdivision (b)—requiring a jury finding or stipulation for upper term sentencing—should apply retroactively at resentencing.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that section 1172.75, subdivision (d)(4), allows reimposition of the upper term at resentencing if it was originally imposed, even without a jury finding or stipulation. The court also found no Sixth Amendment violation because no new judicial factfinding occurred, and rejected the defendant’s Equal Protection claim, concluding that the Legislature had rational reasons to treat resentencing under section 1172.75 differently from other statutes. The judgment was affirmed. View "People v. McAlister" on Justia Law

Cody Henderson, a resident of New Holland, Ohio, was stopped and cited by police officers on multiple occasions while driving his black Prius. On September 13, 2022, he was stopped for speeding, and later cited for several infractions including expired registration. On September 22, officers again stopped him for driving with expired tags, impounded his car, and conducted an inventory search. Henderson objected, refused to comply with officer instructions, and was arrested for obstruction of official business. The search revealed hemp-related substances, which were later determined to be legal, and all charges were dismissed. Henderson subsequently filed a federal lawsuit alleging violations of his constitutional rights and state-law claims.The United States District Court for the Southern District of Ohio dismissed the claims against Officer Pate (who had died prior to the suit) and against the Village of New Holland. Most claims against Officer Lawless were also dismissed, except for Henderson’s Fourth Amendment and malicious prosecution claims. The district court denied qualified immunity to Officer Lawless on these remaining claims, allowing them to proceed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that Officer Lawless had probable cause for the traffic stop, inventory search, and subsequent arrest for obstruction of official business. The inventory search was found lawful under the Fourth Amendment, as it followed standardized procedures and was not pretextual. The court also determined that the state-law malicious prosecution claim failed because probable cause existed for the arrest. Accordingly, the Sixth Circuit reversed the district court’s denial of qualified immunity and dismissed the remaining claims against Officer Lawless. View "Henderson v. Village of New Holland" on Justia Law

The plaintiffs in this case are residents of Hillman Ridge Road in Brown County, Ohio. They experienced a cessation of direct mail delivery to their homes after 2017, following an incident involving a neighbor and a mail carrier. As a result, they were required to retrieve their mail from a distant location and travel to a nearby town for parcels. Other delivery services continued to serve their properties, and the Postal Service continued direct delivery on similar roads in the area. The plaintiffs argued that the Postal Service’s refusal to deliver directly to their homes constituted unconstitutional, unreasonable discrimination.The plaintiffs filed suit in the United States District Court for the Southern District of Ohio, naming the United States Postal Service and two officials as defendants. They asserted a “class of one” equal protection claim, alleging that the Postal Service’s actions violated their constitutional rights. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction. The district court held that the plaintiffs’ dispute belonged exclusively before the Postal Regulatory Commission, not in federal district court, and granted the dismissal. Plaintiffs then appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. It held that Congress intended for claims concerning unreasonable discrimination in mail service—such as those under 39 U.S.C. § 403(c)—to be addressed first by the Postal Regulatory Commission under the administrative procedures of the Postal Accountability and Enhancement Act. The court found that the statutory scheme precludes district court jurisdiction over such claims, even those framed as constitutional issues. The court affirmed the district court’s dismissal for lack of jurisdiction, holding that plaintiffs must pursue their claim through the Commission before seeking judicial review. View "Klein v. USPS" on Justia Law

A suspect was interviewed by police regarding a homicide after being advised of his Miranda rights. He stated he understood those rights and initially agreed to speak with the officers, but during the interview, he made an ambiguous comment about whether he should continue without an attorney. Rather than clarifying whether the suspect actually wanted counsel, the officers continued questioning without pause. The suspect made admissions during the interview, and evidence from that interview was later used to convict him at trial for first-degree murder and tampering with evidence.Prior to trial in the Superior Court for the State of Alaska, Third Judicial District, Kodiak, the defendant moved to suppress his statements from the interview, arguing that his ambiguous reference to counsel required the officers to stop and clarify whether he wanted an attorney. The superior court denied the motion to suppress, finding that the defendant had knowingly waived his Miranda rights and that the ambiguous statement did not require clarification. The defendant was convicted by a jury. On appeal, the Alaska Court of Appeals reversed the conviction, holding that under the Alaska Constitution, police are required to stop and seek clarification when a suspect makes an ambiguous post-waiver reference to counsel.The Supreme Court of the State of Alaska reviewed the case after the State petitioned for hearing, asking the court to adopt the federal standard from Davis v. United States, which does not require a “stop and clarify” rule. The Alaska Supreme Court held that, under article I, sections 9 and 11 of the Alaska Constitution, law enforcement officers must stop questioning and clarify any ambiguous request for counsel—even after a suspect has waived Miranda rights. The court affirmed the decision of the court of appeals, reversed the conviction, and required suppression of the defendant’s statements made after the ambiguous request. View "State v. Ridenour" on Justia Law

A multi-state utility company operating a gas-fired power plant in Washington alleged that the state's Climate Commitment Act (CCA) impermissibly discriminated against interstate commerce by allocating no-cost greenhouse gas emissions allowances only for electricity sold to Washington customers. Under Washington’s Clean Energy Transformation Act (CETA) and the CCA, utilities serving in-state customers receive no-cost allowances to offset compliance costs, while electricity exported to customers in other states does not receive this benefit. The company argued that this scheme increased costs for its non-Washington customers and potentially its shareholders, as out-of-state sales from the Washington facility required purchasing emissions allowances at auction.The United States District Court for the Western District of Washington reviewed the complaint and found that the electricity generated for export was not subject to CETA’s decarbonization mandates, distinguishing it from in-state electricity. The district court concluded that the two categories were not similarly situated for purposes of Dormant Commerce Clause analysis. The court reasoned that utilities serving Washington customers were already subject to more aggressive decarbonization requirements under CETA, justifying the allocation of no-cost allowances under the CCA. The district court dismissed the complaint with prejudice, finding no plausible claim of unconstitutional discrimination, and denied the motion for preliminary injunction as moot.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal and denial of the injunction. The Ninth Circuit held that because the regulatory schemes governing in-state and exported electricity are distinct, the emissions associated with each are not similarly situated. Therefore, Washington’s allocation of no-cost allowances did not violate the Dormant Commerce Clause. The court further held that dismissal without leave to amend was appropriate, as any amendment would be futile. The decision was affirmed. View "PACIFICORP V. SIXKILLER" on Justia Law

A town administrator in Grand Chute, Wisconsin, was terminated by a newly elected faction on the town’s Board of Supervisors. The administrator, who had served since 2008, claimed his firing was retaliation for cooperating with a state Department of Justice investigation into alleged corruption by a newly elected supervisor. That supervisor had previously been involved in litigation against the town and was later indicted, though ultimately acquitted, on unrelated corruption charges. The administrator’s relationship with the new board members deteriorated, and he was perceived as politically aligned with their rivals and critical of their policies.The administrator sued the Town and individual supervisors in the United States District Court for the Eastern District of Wisconsin under 42 U.S.C. § 1983, asserting First Amendment retaliation. The supervisor also filed a counterclaim alleging the administrator had set him up for prosecution. The district court granted summary judgment for the defendants in both actions, finding the administrator’s termination did not violate the First Amendment and that qualified immunity applied due to unclear precedent regarding the firing of policymaking officials for political speech. The court also rejected the supervisor’s counterclaim, finding no evidence of state action or differential treatment required for an equal protection class-of-one claim.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The Seventh Circuit affirmed, holding that the individual defendants were entitled to qualified immunity because existing precedent did not clearly establish that firing a policymaking official under these circumstances violated the First Amendment. The court also affirmed dismissal of the counterclaim, finding neither a viable First Amendment retaliation nor an equal protection claim. View "March v. Wolff" on Justia Law

Arizona amended its election laws in 2022, introducing two provisions: one requires county recorders to cancel a voter’s registration in their county if the voter registers in a new county (“Cancellation Provision”), and the other criminalizes knowingly providing a “mechanism for voting” to someone registered in another state (“Felony Provision”). Three organizations engaged in voter registration and education activities claimed these provisions would interfere with their efforts, and sought to enjoin enforcement. They argued that the Cancellation Provision would lead to improper removal of voters and that the Felony Provision was vague and could chill their constitutionally protected activities.The United States District Court for the District of Arizona granted a preliminary injunction, barring enforcement of both provisions. The Arizona Attorney General appealed. A three-judge panel of the United States Court of Appeals for the Ninth Circuit vacated the injunction, finding that the organizations lacked standing for the Cancellation Provision and were unlikely to succeed on the merits regarding the Felony Provision. The case was then reheard en banc after the prior panel’s opinion was vacated.The United States Court of Appeals for the Ninth Circuit, sitting en banc, held that the organizations lacked standing to challenge the Cancellation Provision because they did not clearly show that it directly affected or interfered with their core activities, as required by FDA v. Alliance for Hippocratic Medicine. The court further held that the organizations had standing to challenge the Felony Provision due to a credible threat of prosecution, but were unlikely to succeed on the merits, as the statutory context indicated that “mechanism for voting” likely refers only to a ballot or ballot envelope, not to voter registration or education activities. The court vacated the preliminary injunction and remanded the case. View "ARIZONA ALLIANCE FOR RETIRED AMERICANS V. MAYES" on Justia Law

A veteran who served in the Marine Corps, including a tour in Vietnam, began experiencing fatigue and underwent a medical evaluation at a Veterans Affairs Medical Center in 2010. His blood tests showed elevated lymphocyte counts. However, VA physicians in Florida diagnosed him with monoclonal B-cell lymphocytosis (MBL), not chronic lymphocytic leukemia (CLL), and did not inform him of a CLL diagnosis. Years later, after his condition worsened and he relocated to Tennessee, a VA oncologist diagnosed him with CLL and retroactively opined that his medical records met the diagnostic criteria for CLL since 2010. The veteran then applied for VA disability compensation. The VA assigned a 100% disability rating with an effective date of January 29, 2016, the date his claim was filed.The veteran appealed, arguing for an earlier effective date due to the alleged misdiagnosis and failure to inform him about his CLL. The Board of Veterans’ Appeals partially granted his request, assigning an effective date of January 29, 2015, but declined to go earlier, finding that the law did not allow equitable considerations to affect the effective date under 38 U.S.C. § 5110. The veteran then appealed to the United States Court of Appeals for Veterans Claims, raising arguments that the VA should be equitably estopped from enforcing § 5110’s effective date restrictions, and that those restrictions were unconstitutional as applied to him. The Veterans Court affirmed the Board’s decision.On further appeal, the United States Court of Appeals for the Federal Circuit affirmed the Veterans Court. The Federal Circuit held that equitable estoppel cannot override the effective date limitations of 38 U.S.C. § 5110, and that § 7331 does not create a statutory precondition to enforcement of § 5110. It also held that the statute’s effective date limitations were not unconstitutional as applied to the veteran’s circumstances. View "LEY v. COLLINS " on Justia Law

The case centers on the death of a two-year-old child, Hayden, who lived with his mother, Hailey, and her husband, Joseph. The family struggled financially, and Joseph was often home caring for Hayden while Hailey worked. On the morning of December 27, 2021, Hayden died after being repeatedly struck by Joseph and subsequently smothered by Hailey, according to Hailey’s testimony. Medical evidence indicated Hayden suffered extensive recent and past injuries consistent with ongoing physical abuse. Both Joseph and Hailey were indicted for capital murder. Hailey pleaded guilty to first-degree murder and received a life sentence, while Joseph pleaded not guilty and went to trial.The case was first tried in the Harrison County Circuit Court, Second Judicial District. A jury found Joseph guilty of capital murder and, after a penalty phase, unanimously sentenced him to death, finding he had attempted to kill Hayden and that the murder was committed during felonious child abuse and was especially heinous, atrocious, or cruel. Joseph’s post-trial motions for a new trial or judgment notwithstanding the verdict were denied.On direct appeal, the Supreme Court of Mississippi reviewed multiple claims of error, including the admission of expert and lay testimony, the exclusion of certain character evidence, the jury instructions regarding aggravating circumstances, the sufficiency of the evidence, and the proportionality and constitutionality of the death sentence. The Court applied heightened scrutiny due to the death penalty. It held that there was no reversible error in the admission of testimony, the aggravating circumstances were properly found, and the evidence was sufficient to support the jury’s findings. The Court affirmed Joseph’s conviction and death sentence, finding neither cumulative error nor constitutional infirmity. Claims of ineffective assistance of counsel were preserved for possible post-conviction relief but were not resolved on direct appeal. View "Heard v. State of Mississippi" on Justia Law

An inmate with a history of heart issues experienced unusually severe chest pain while incarcerated and took medication without relief. He promptly reported his symptoms to a corrections officer, expressing the need for immediate medical attention and warning of his medical vulnerability. The officer dismissed the complaint, ordering the inmate back to his cell, and allegedly threatened further discipline. Instead, the inmate sat in a nearby wheelchair. Another prison official later intervened and arranged for the inmate to be transported to the medical wing, resulting in an eight-minute delay from the initial complaint. After waiting about an hour in the medical wing without treatment, the inmate suffered a heart attack but ultimately recovered.The inmate initiated a lawsuit in the United States District Court for the Eastern District of Michigan, asserting that the officer’s conduct constituted deliberate indifference to his serious medical needs in violation of the Eighth Amendment and also violated his Fourteenth Amendment rights. The officer sought summary judgment on qualified immunity grounds. A magistrate judge recommended dismissing the Fourteenth Amendment claim but found that a reasonable jury could determine that the officer was deliberately indifferent and thus denied qualified immunity. The district court adopted this recommendation, concluding that there was sufficient evidence for the Eighth Amendment claim to proceed to trial.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether the officer was entitled to qualified immunity as a matter of law. The Sixth Circuit held that the officer did not violate a clearly established constitutional right because existing precedent did not put a reasonable officer on notice that failing to immediately respond to a prisoner’s oral complaint of chest pain, absent visible signs of medical distress, violated the Eighth Amendment. The court reversed the district court’s denial of summary judgment and remanded the case for entry of judgment in favor of the officer. View "Richardson v. Falk" on Justia Law