Justia Constitutional Law Opinion Summaries

A group of individuals, including the petitioner, became involved in a series of drug-related activities centered around a home in Parkersburg, West Virginia. After the petitioner purchased drugs from Tiffany McCune, he became dissatisfied with their quality, leading to several confrontations and exchanges between the parties. The situation escalated when the petitioner returned to the McCune home, forcibly entered, and assaulted Tiffany with a pistol. During the ensuing chaos, Darren Salaam Sr., who was present in the house, was shot in the back and later died from his wounds. The petitioner fled the scene but was later apprehended. Upon arrest, he made racially charged statements, and photographs taken at booking displayed his swastika and Aryan Brotherhood tattoos.The Circuit Court of Wood County presided over the petitioner’s jury trial. The jury convicted him of felony murder, finding that the underlying felony was burglary. The petitioner was sentenced to life without the possibility of parole. During the trial, the court admitted evidence of the petitioner’s tattoos and statements, as well as Tiffany McCune’s statements to police and a 9-1-1 call, over the petitioner’s objections on various evidentiary and constitutional grounds. The petitioner’s post-trial motions for acquittal and a new trial—primarily challenging the sufficiency of the evidence on the burglary element—were denied.On appeal, the Supreme Court of Appeals of West Virginia reviewed the evidentiary rulings for abuse of discretion and the constitutional claims de novo. The court held that the tattoo evidence was relevant to motive and not unfairly prejudicial, Tiffany’s statements were admissible as excited utterances and not testimonial under the Confrontation Clause, and the evidence was sufficient to support the felony murder conviction. The court affirmed the circuit court’s judgment. View "State v. Thompson" on Justia Law

A national trade association representing large online businesses challenged a recently enacted California statute designed to protect minors’ privacy and well-being online. The law imposes specific requirements on businesses whose online services are likely to be accessed by children under eighteen, including obligations regarding data use, age estimation, and restrictions on certain user interface designs known as “dark patterns.” Before the law took effect, the association brought suit in the United States District Court for the Northern District of California, arguing that several provisions were unconstitutional on First Amendment and vagueness grounds, and sought a preliminary injunction to prevent enforcement.The district court initially enjoined the entire statute, finding the association was likely to succeed on its facial First Amendment challenge. On the State’s appeal, the United States Court of Appeals for the Ninth Circuit vacated most of the injunction, affirming only as to a specific requirement regarding Data Protection Impact Assessments and related inseverable provisions, and remanded for the district court to analyze the association’s other facial challenges and the issue of severability under the Supreme Court’s clarified standards in Moody v. NetChoice, LLC. On remand, the district court again enjoined the entire statute and, in the alternative, seven specific provisions.On further appeal, the United States Court of Appeals for the Ninth Circuit held that the association did not meet its burden for a facial challenge to the law’s coverage definition or its age estimation requirement, vacating the injunction as to those. However, the court affirmed the preliminary injunction as to the law’s data use and dark patterns restrictions on vagueness grounds, finding the provisions failed to clearly delineate prohibited conduct. The court vacated the injunction as to the statute’s remainder and remanded for further proceedings on severability. View "NETCHOICE, LLC V. BONTA" on Justia Law

The case involves a defendant who was convicted of two counts of felony murder after setting fire to his estranged girlfriend’s apartment, resulting in the deaths of her two roommates. The relationship between the defendant and his girlfriend was tumultuous, and on the night of the incident, after a series of arguments and threatening communications, the defendant poured gasoline on the apartment couch and set it ablaze. Surveillance footage placed him at the scene, and an arson investigator determined that accelerant had been used. Following his arrest, the defendant was interrogated by police and ultimately confessed to pouring the gasoline but denied intending to kill anyone.In Multnomah County Circuit Court, the defendant moved to suppress statements made during his police interrogation, arguing they were involuntary, and filed a demurrer contending that Oregon’s felony-murder statute, ORS 163.115(1)(b), violated due process by either creating an impermissible presumption regarding the mental state or by imposing strict liability for murder. The trial court denied both motions, finding the confession was voluntary under the totality of the circumstances and that the statute did not violate due process. The defendant was convicted, and the Oregon Court of Appeals affirmed, agreeing with the trial court’s rulings.The Supreme Court of the State of Oregon reviewed both issues. It held that the trial court did not err in declining to suppress the confession, emphasizing that, under the totality of the circumstances, the statements were voluntary and not the product of coercion or improper inducement. The court further held that Oregon’s felony-murder statute, as previously interpreted in State v. Blair, does not violate the Due Process Clause because it does not create a conclusive presumption regarding mental state or impose unconstitutional strict liability. The Supreme Court of Oregon affirmed the decisions of both the Court of Appeals and the circuit court. View "State v. Monaco" on Justia Law

The appellant was convicted of delivery of methamphetamine, second or subsequent offense, and received a suspended sentence with three years of supervised probation. Conditions of probation included obeying Department of Corrections rules and completing any treatment required by his probation officer. After seven months, the State filed a petition to revoke probation, alleging that the appellant left required inpatient treatment at Southwest Counseling Service without completing it. The probation officer’s affidavit detailed that he left treatment against staff advice, had missed office visits, continued to use methamphetamine, and had fled from the probation office, resulting in new criminal charges.The District Court of Carbon County held a probation revocation hearing. Although the appellant initially admitted violating probation, he later claimed his attendance at inpatient treatment was voluntary. The court proceeded to an evidentiary hearing, where the probation officer testified about the appellant’s ongoing drug use, failure to attend required evaluations, and his departure from treatment. The court found by a preponderance of the evidence that he violated probation by not completing required treatment, revoked his probation, and imposed the underlying six to ten-year prison sentence, citing willful violations and unsuitability for continued probation. The appellant appealed, arguing that his due process rights were violated when the State relied on other uncharged probation violations during the dispositional phase.The Supreme Court of Wyoming reviewed the case under the plain error standard because the due process argument was not raised below. The court held there was no due process violation, explaining that written notice is required only for the specific alleged probation violation that forms the basis for revocation, not for other conduct considered during the dispositional phase. The court affirmed the district court’s order revoking probation and imposing the prison sentence, finding no clear or unequivocal rule of law was violated. View "Bustos v. The State of Wyoming" on Justia Law

The defendant was convicted after a jury trial of aggravated eluding, reckless driving, driving under suspension, and failing to stop at a stop sign, all arising from an incident in Sioux Falls, South Dakota. Law enforcement responded to a call about a family dispute, with the caller reporting that the defendant was driving a red Toyota Camry. Officers observed the vehicle and identified the defendant as the driver, who then fled at high speed through residential neighborhoods. The defendant later testified that he was not involved, did not own or drive the Camry, and denied fleeing from police.The Circuit Court of the Second Judicial Circuit, Minnehaha County, presided over the trial. Prior to trial, the defendant moved to exclude statements related to the BOLO alert and the caller’s association of him with the Camry, arguing hearsay and character evidence grounds. The court denied these motions, reasoning that the BOLO and information about the vehicle were relevant to the officers’ actions and not unduly prejudicial. During trial, officers testified about the BOLO and caller’s statements, and defense counsel made a continuing objection referencing Crawford v. Washington. The jury returned guilty verdicts on all counts, and the defendant was sentenced with all terms suspended.The Supreme Court of the State of South Dakota reviewed the case. The defendant argued that admitting the caller’s statement violated his Sixth Amendment right to confrontation and constituted inadmissible hearsay. The court held that the defendant had not properly preserved the Confrontation Clause issue for appeal, as he failed to provide sufficient facts or request a determination about whether the caller’s statement was testimonial. Regarding hearsay, the court found that, even if error occurred, it was not prejudicial because the officers’ identification testimony and dash camera videos provided strong, independent evidence of the defendant’s identity. The Supreme Court affirmed the conviction. View "State v. Clifford" on Justia Law

A substitute teacher employed by a staffing agency regularly worked in a school district where her child was a student. After a dispute arose between her and her child’s teacher, she filed an ethics complaint regarding the teacher’s conduct with the Arkansas Department of Education. Subsequently, the school district informed the staffing agency that she should not substitute at the school during the investigation, and later extended this prohibition to all district schools. She was still able to work at other schools in the county contracted with the agency. The state ultimately found her complaint baseless.She filed suit alleging that the district and two administrators retaliated against her in violation of federal and state law, including the Rehabilitation Act, 42 U.S.C. § 1983, and the Arkansas Civil Rights Act. The Saline County Circuit Court granted her partial summary judgment, finding liability on her claims, and the jury awarded compensatory and punitive damages. The court also issued a permanent injunction preventing the district from barring her employment as a substitute.The Supreme Court of Arkansas reviewed the case and held that her Rehabilitation Act claim failed because she was not an employee of the district, as required for such claims. For her § 1983 and Arkansas Civil Rights Act claims, the court found she had not established liability against the district or the administrators. Specifically, she did not show that the district acted under an official policy or custom, nor did her speech constitute a matter of public concern protected by the Constitution in the context of a government contractor relationship. The court also vacated the permanent injunction, as no substantive claim survived.The Supreme Court of Arkansas reversed the circuit court’s summary judgment rulings, the jury’s damages award, and the order granting a permanent injunction, and remanded for entry of judgment in favor of the appellants. View "BENTON SCHOOL DISTRICT v. GREER" on Justia Law

Twin infants who are eligible for tribal membership were placed in emergency foster care with licensed, non-tribal foster parents after being born with serious medical issues. The county obtained temporary legal custody of the children through a Child in Need of Protection or Services (CHIPS) proceeding, and the children were eventually moved from the foster parents’ home to the home of maternal relatives who are members of the same tribe as the children. The foster parents, after learning of the planned move, sought to intervene permissively in the CHIPS case, filed a third-party custody petition, and moved to stay the placement change, arguing in part that tribal placement preference statutes were unconstitutional.The Minnesota District Court denied the foster parents’ motions to intervene and for a stay, and dismissed the third-party custody petition without considering their constitutional arguments. The Minnesota Court of Appeals affirmed in part, reversed in part, and remanded. It directed the district court to reconsider intervention and third-party custody, and addressed the constitutionality of the Minnesota Indian Family Preservation Act (MIFPA), finding it constitutional. On remand, the district court again denied intervention and dismissed the third-party custody petition, concluding the foster parents were not proper parties and could not file such petitions in the ongoing CHIPS proceeding.The Minnesota Supreme Court consolidated the appeals. It held that the district court did not abuse its discretion in denying permissive intervention, as such intervention was not in the children’s best interests. The court also held that a third-party custody petition is not available in juvenile court CHIPS proceedings and may only be brought as a petition to transfer custody by a party to the action. Because the foster parents were not parties, the court declined to address their constitutional challenges to ICWA and MIFPA, and vacated the Court of Appeals’ discussion of those constitutional issues. The court affirmed in part, vacated in part, and remanded for further proceedings. View "In the Matter of the Welfare of the Children of: L.K." on Justia Law

The appellant was convicted by a jury in 2018 of several offenses, including aggravated assault, sexual assault, assault on a peace officer, escape, and criminal possession of dangerous drugs. After initially having court-appointed counsel, he retained private attorneys under a fixed-fee contract, with his grandmother paying $150,000 upfront. Ten months later, the relationship between the appellant and his retained counsel deteriorated to the point of a complete breakdown, leading counsel to seek withdrawal. The court held a hearing, found an irreconcilable breakdown, allowed withdrawal, and appointed new counsel. The appellant was then represented by court-appointed attorneys through his trial and sentencing. His conviction and subsequent claims of error, including those relating to ineffective assistance of counsel, were affirmed on direct appeal, and his petition for certiorari was denied by the United States Supreme Court.In postconviction proceedings before the Eighteenth Judicial District Court, the appellant asserted numerous grounds for relief, focusing on claims of ineffective assistance by retained trial counsel (for seeking withdrawal but keeping the fixed fee) and by appellate counsel (for not arguing that separate counsel should have been appointed at the withdrawal hearing). After a bench trial and extensive litigation, the District Court denied all claims, finding no constitutional violations. The court also noted that the appellant’s dispute over fees had been separately resolved through mediation and civil proceedings.The Supreme Court of the State of Montana reviewed the case. It held that the circumstances did not demonstrate a structural denial of counsel warranting a presumption of prejudice under United States v. Cronic, nor did the fixed-fee contract create an actual conflict of interest resulting in ineffective assistance under Strickland v. Washington. The Court further found that appellate counsel was not constitutionally ineffective for failing to raise the claim regarding appointment of separate counsel at the withdrawal hearing. The Supreme Court affirmed the District Court’s denial of postconviction relief. View "Briggs v. State" on Justia Law

In January 2008, Michael L. King kidnapped Denise Amber Lee from her home, where she was caring for her two young children. King took her to his house, bound and sexually assaulted her over several hours, then forced her into his car to obtain supplies to dispose of her body. During this ordeal, Lee managed to call 911 while still bound in King’s car. King ultimately drove Lee to an abandoned construction site, shot her, and buried her. King was apprehended later that day after his car was identified by a witness. Forensic evidence linked King to the crime, and Lee’s body was recovered two days later.The case proceeded to the Circuit Court for Sarasota County, where a jury convicted King of first-degree murder, sexual battery, and kidnapping. The jury unanimously recommended the death penalty, and the trial court imposed a death sentence, finding four statutory aggravating factors and various mitigating circumstances. The Florida Supreme Court affirmed King’s conviction and sentence on direct appeal. King’s subsequent motions for postconviction relief in state and federal courts were denied. His challenges included claims of ineffective assistance of counsel, constitutional defects in Florida’s lethal injection procedures, and newly discovered mitigating evidence. These were consistently rejected by the lower courts, including the United States Court of Appeals for the Eleventh Circuit.After a death warrant was signed, King filed a successive postconviction motion and sought additional records, arguing that alleged irregularities in the execution protocol violated his Fourteenth and Eighth Amendment rights and that new evidence warranted relief. The Circuit Court for the Twelfth Judicial Circuit denied these claims. On appeal, the Supreme Court of Florida held that King was not entitled to additional public records, found his constitutional claims speculative and unsubstantiated, and determined his claims of newly discovered evidence were untimely, procedurally barred, and without merit. The court affirmed the denial of postconviction relief and denied a stay of execution. View "King v. State" on Justia Law

Four individuals alleged that they owned funds subject to Ohio’s unclaimed property regime and that their funds were set to escheat, or transfer, to the state as of January 1, 2026, due to recent amendments to Ohio’s Unclaimed Funds Act. The Act requires holders of unclaimed funds to remit those funds to the state after a period of dormancy, with additional amendments providing that funds held for ten years or more would escheat to the state, although owners would still have ten additional years to claim an equivalent amount, with interest, less expenses.The plaintiffs filed suit in the United States District Court for the Southern District of Ohio against state officials responsible for implementing the Act. They argued that the statutory regime violated the Takings Clause of the Fifth Amendment, the Due Process Clause of the Fourteenth Amendment, and various Ohio laws. The plaintiffs moved for a preliminary injunction to prevent the escheatment of their funds, claiming they received insufficient notice and would suffer irreparable harm. The district court denied the request, finding that the plaintiffs had not demonstrated irreparable harm, particularly since they could still claim the funds from the state after escheatment.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial for abuse of discretion. The Sixth Circuit affirmed, holding that the plaintiffs had not shown irreparable harm because they retained a statutory avenue to recover their funds with interest after escheatment and could seek a monetary judgment if their constitutional claims succeeded. The court further determined that the plaintiffs either had actual notice of their funds or failed to identify specific property at risk, so no likelihood of irreparable harm was shown. The Sixth Circuit affirmed the district court’s denial of a preliminary injunction. View "Bleick v. Maxfield" on Justia Law