Justia Constitutional Law Opinion Summaries

Christopher Thigpen applied for and received unemployment benefits from the Minnesota Department of Employment and Economic Development (DEED) for 104 weeks spanning March 2020 to March 2022. During this period, Thigpen was employed as a personal care assistant, earning weekly wages, but reported to DEED each week that he had not worked or received other income. This misrepresentation led to Thigpen receiving overpayments totaling $39,605 in standard and pandemic unemployment benefits. In April 2022, DEED reviewed his account, confirmed his employment during the relevant period, and determined that he had obtained the overpayments due to misrepresentation. As a result, DEED assessed a penalty of 40 percent of the overpaid amount, imposed 1 percent monthly interest, and barred Thigpen from receiving any future unemployment benefits until repayment, subject to a statutory ten-year cancellation period.Thigpen appealed the determination before an unemployment law judge, arguing that he did not intend to defraud DEED and misunderstood the forms. After multiple evidentiary hearings, the unemployment law judge found Thigpen’s explanations not credible, upheld the finding of misrepresentation, and applied the statutory penalty, interest, and benefit ineligibility.Thigpen requested certiorari review from the Minnesota Court of Appeals, challenging the sufficiency of evidence, burden of proof, denial of due process, and constitutionality of the penalties under the Excessive Fines Clauses of the U.S. and Minnesota Constitutions. The Court of Appeals rejected all arguments, specifically finding the penalties proportionate and comparable to those for similar offenses in Minnesota and other states.On further appeal, the Minnesota Supreme Court affirmed the Court of Appeals, holding that the penalty, interest, and benefit ineligibility for unemployment benefit misrepresentation do not violate the Excessive Fines Clauses, as they are not grossly disproportionate to the gravity of the offense and are consistent with penalties in Minnesota and other jurisdictions. View "Thigpen vs. Best Home Care LLC" on Justia Law

A police officer stopped a vehicle driven by the appellant for traffic violations and discovered that his driver’s license had been canceled. During the stop, the officer smelled a strong odor of marijuana coming from the vehicle. Citing only the odor as justification, the officer conducted a warrantless search of the car. During the search, the officer found ammunition in a locked safe in the backseat. The appellant was prohibited by law from possessing ammunition and was subsequently charged with that offense, as well as with driving after cancellation.The trial court, the Scott County District Court, granted the appellant’s motion to suppress the ammunition, ruling that the search violated his constitutional rights. This ruling came after the Minnesota Supreme Court’s decision in State v. Torgerson, which held that the smell of marijuana alone is not sufficient to establish probable cause for a warrantless vehicle search. The State appealed. The Minnesota Court of Appeals reversed the district court’s decision, holding that the good-faith exception to the exclusionary rule applied because, at the time of the search, officers could reasonably have relied on existing appellate precedent that arguably permitted such searches.The Supreme Court of Minnesota, reviewing the case, rejected the application of the good-faith exception. The court held that there was no binding appellate precedent specifically authorizing warrantless vehicle searches based solely on the smell of marijuana at the time of the search, and previous Minnesota Supreme Court decisions had emphasized the need to evaluate the totality of the circumstances. The court concluded that the good-faith exception did not apply, reversed the decision of the Court of Appeals, and remanded the case to the district court for further proceedings. View "State of Minnesota vs. Douglas" on Justia Law

VVF Intervest, L.L.C., a contract manufacturer based in Kansas, produced bar soap for High Ridge Brands (HRB), the brand owner. HRB, an "asset light" entity, directed VVF to ship the soap from Kansas to a third-party distribution center in Columbus, Ohio. Subsequently, HRB resold most of the product to national retailers, and the soap was shipped out of Ohio to various locations. Between 2010 and 2014, VVF paid Ohio’s commercial-activity tax (CAT) on its gross receipts from these sales to HRB.After making these payments, VVF sought a refund from the Ohio tax commissioner, arguing that its gross receipts should not be sitused to Ohio since the products left the state soon after arrival. The tax commissioner denied the refund, emphasizing that the relevant sale for tax purposes was VVF’s sale to HRB, not HRB’s subsequent sales to retailers. VVF appealed to the Ohio Board of Tax Appeals, which held that the Columbus distribution center was merely an interim stop and that the gross receipts should not be sitused to Ohio. The board also found that VVF had not adequately preserved an alternative statutory argument regarding services and declined to rule on constitutional claims.The Supreme Court of Ohio reviewed the appeal and reversed the Board of Tax Appeals’ decision. The court held that under R.C. 5751.033(E), VVF’s gross receipts from sales to HRB are properly sitused to Ohio because HRB, as the purchaser, received the goods in Ohio. The court dismissed VVF’s alternative statutory argument for lack of jurisdiction and rejected VVF’s constitutional challenges under the Due Process, Commerce, and Equal Protection Clauses. Thus, VVF is not entitled to a refund of the CAT paid on these transactions. View "VVF Intervest, L.L.C. v. Harris" on Justia Law

The defendant was involved in a fatal shooting during a drug transaction in Hartford, Connecticut. He testified at trial that he acted in self-defense, claiming the victim drew a gun on him during a dispute. However, other witnesses contradicted this account, and no gun was found on or near the victim. After the shooting, the defendant fled the scene and did not report the incident to the police. He was later arrested and charged with murder.The case was tried before the Superior Court in the judicial district of Hartford. At trial, the defendant testified in his own defense. The prosecutor, with approval from the trial court, cross-examined the defendant regarding his failure to report to police that he had acted in self-defense prior to his arrest. The defense objected, arguing that the questioning infringed upon the defendant’s right to remain silent, but the trial court overruled the objection, reasoning that, by testifying, the defendant waived his Fifth Amendment right regarding silence and that his failure to report was inconsistent with a claim of self-defense. The jury found the defendant guilty of murder, and he was sentenced to fifty years in prison.On direct appeal to the Supreme Court of Connecticut, the defendant argued that the trial court committed plain error by allowing the prosecutor to cross-examine him about his prearrest silence. The Supreme Court of Connecticut held that the trial court did not commit plain error because established case law allows impeachment using a defendant’s prearrest, pre-Miranda silence, particularly when the defendant testifies and claims self-defense. The Court concluded that the circumstances did not present an obvious or egregious error requiring reversal. The judgment of conviction was affirmed. View "State v. Thorpe" on Justia Law

Parker Noland operated a construction debris removal business in Flathead County, Montana, but was ordered by the Montana Public Service Commission to cease operations due to lacking a required Class D motor carrier certificate. Noland formed PBN LLC and applied for the certificate, but withdrew his application after finding the administrative process—including requests for sensitive financial information by competitors—too burdensome. He then limited his business to activities not requiring the certificate. Subsequently, Noland filed suit in the Eleventh Judicial District Court of Flathead County, seeking a declaratory judgment that two provisions of the Montana Motor Carrier law, known as the public convenience and necessity (PCN) provisions, were unconstitutional under both the Montana and United States Constitutions.The District Court granted summary judgment in favor of the State of Montana and Evergreen Disposal, Inc., which had intervened. The court held that Noland lacked standing to bring an as-applied constitutional challenge, reasoning he sought to vindicate only a future injury and had not shown how the statutes would be unconstitutionally applied to him. However, the court found Noland had standing to bring a facial challenge, but ruled against him, concluding the provisions were not facially unconstitutional because some applicants had previously received Class D certificates.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s rulings de novo. The Montana Supreme Court affirmed the District Court’s decision that Noland lacked standing for an as-applied challenge, holding that he failed to demonstrate a concrete injury or how the statutes were applied to him. The Court reversed the District Court’s denial of Noland’s facial challenge, holding that he had standing to challenge the statute’s constitutionality on its face, since the procedural requirements themselves could constitute injury regardless of outcome. The case was remanded for further consideration of the facial constitutional challenges. View "Noland v. State" on Justia Law

In this case, the petitioner was convicted of first-degree murder and robbery for an offense committed at age 17, resulting in a mandatory sentence of life imprisonment without parole under Massachusetts law. Decades later, following developments in constitutional law, the Massachusetts Supreme Judicial Court held that life-without-parole sentences for juveniles were unconstitutional and ordered that such sentences be modified to life with the possibility of parole. As a result, the petitioner’s sentence was changed; he became parole eligible, was granted parole, and was released.After this modification, the petitioner sought to file a second habeas corpus petition in federal court under 28 U.S.C. § 2254. The United States District Court for the District of Massachusetts ruled that this petition was “second or successive” under 28 U.S.C. § 2244(b) and thus subject to its “gatekeeping” requirements, concluding that the addition of parole eligibility did not constitute a new judgment for purposes of federal habeas law.On appeal, the United States Court of Appeals for the First Circuit reviewed de novo whether the sentence modification constituted a new judgment. The court held that the change from life without parole to life with parole eligibility was a material change, making the sentence a new judgment under federal law. The court reasoned that, because the petitioner’s current custody was authorized by this new judgment, his second-in-time habeas petition did not trigger the restrictions of § 2244(b).Therefore, the First Circuit reversed the district court’s decision, holding that the petitioner need not obtain pre-authorization to file his habeas petition, and remanded for further proceedings. View "Donovan v. Massachusetts Parole Board" on Justia Law

Israel Ruiz was convicted by an Illinois jury of first-degree murder and aggravated discharge of a firearm for an offense he committed at age 18 in 1998. In 2000, he received a 40-year prison sentence without the possibility of parole for murder and a concurrent 15-year sentence for the firearm offense. In 2019, Illinois enacted a law (Public Act 100-1182) allowing parole eligibility for young adults convicted of first-degree murder committed under age 21, but only for those sentenced on or after June 1, 2019. Ruiz, sentenced before that date, is ineligible for parole under the Act.Ruiz filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Northern District of Illinois, Eastern Division, against Illinois’s governor and other state officials. He alleged that the Act’s prospective application violated his rights under the Equal Protection Clause and the Eighth Amendment. The district court granted the defendants’ motion to dismiss, holding that established Seventh Circuit precedent foreclosed Ruiz’s Fourteenth Amendment claim and that the Act’s prospective-only application did not render his sentence cruel or unusual under the Eighth Amendment. Ruiz appealed.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s dismissal de novo. It held that the Act’s limitation to offenders sentenced on or after its effective date did not violate the Equal Protection Clause, as rational-basis review permits such prospective legislative distinctions, consistent with prior circuit decisions such as United States v. Speed and United States v. Sanders. The court also held that Ruiz’s sentence was not unconstitutional under the Eighth Amendment, as Supreme Court precedent limiting life without parole for offenders under 18 did not apply to Ruiz. The Seventh Circuit affirmed the district court’s judgment. View "Ruiz v. Pritzker" on Justia Law

Police were surveilling a suspect in an unrelated crime when they observed the suspect with another individual, Dubuc, in a parking lot. After Dubuc and the suspect exited Dubuc’s vehicle and began walking toward a store, police arrested the suspect on an outstanding warrant and detained Dubuc, asking if he had anything illegal on his person. Dubuc admitted to carrying a concealed handgun without a permit. Police handcuffed Dubuc and seized the firearm, subsequently charging him with felony carrying a concealed weapon. There was no indication that police had any reasonable suspicion Dubuc was involved in criminal activity prior to detaining him.Dubuc moved to suppress the evidence obtained from the search, arguing that the stop and subsequent search violated his constitutional rights due to lack of reasonable suspicion. The State argued that the search was permissible, analogizing to situations where police search vehicle passengers during traffic stops. After a hearing, the Second Judicial District Court in Washoe County found that police lacked individualized reasonable suspicion to detain and search Dubuc, as there were no specific articulable facts connecting him to criminal activity. The district court suppressed Dubuc’s statements and the physical evidence obtained, and the State appealed.The Supreme Court of Nevada reviewed the district court’s decision de novo, considering both legal conclusions and factual findings. The court held that police may not detain or search a companion of a suspect solely based on association or officer safety concerns, absent individualized suspicion of criminal involvement. The court explicitly rejected the “automatic companion rule,” reaffirming that constitutional protections require reasonable suspicion particularized to the person searched. The Supreme Court of Nevada affirmed the district court’s order suppressing the evidence and statements obtained from Dubuc. View "State v. Dubuc" on Justia Law

The case involves a Nevada-domiciled trust, managed by a Nevada family trust company, whose trustee petitioned the Second Judicial District Court of Nevada to seal confidential information and close all court proceedings under NRS 164.041 and NRS 669A.256. The district court sealed nearly all documents and concealed the existence of the case, citing concerns over revealing personal, financial, and business information, and later provided limited case information after media inquiries. Several media organizations, having reported on the matter—especially due to its connection to Rupert Murdoch and control over major media holdings—sought intervention to access court records and proceedings, arguing that the First Amendment presumption of public access applied.The probate commissioner recommended allowing media intervention but denying access, and the district court entered an order adopting this recommendation. The court interpreted the statutes as granting automatic and comprehensive confidentiality, finding that privacy and security concerns—heightened by the parties’ public profiles—constituted a compelling interest for sealing and closure. The district court also concluded it lacked discretion to consider redaction as an alternative and held that the statutes’ confidentiality provisions justified the broad closure, even after the Nevada Supreme Court’s decision in Falconi v. Eighth Judicial District Court recognized a First Amendment presumption of access in civil and family court proceedings.The Supreme Court of Nevada reviewed the district court’s decision, holding that NRS 164.041 and NRS 669A.256 permit only provisional sealing and require judicial discretion. The statutes do not automatically justify blanket sealing or closure, nor do they displace the common law or constitutional presumption of openness. The court found that the district court failed to make specific, non-speculative factual findings to justify the sealing and closure and did not adequately consider less restrictive alternatives. The Supreme Court granted the petition for a writ of mandamus, directing the district court to vacate its sealing order and conduct the required analysis for each document and hearing transcript. View "New York Times Co. v. District Court" on Justia Law

Juan Carlos Alvarez, a member of the Southwest Cholos gang, was convicted of capital murder for his involvement in two separate fatal shootings in Houston, Texas in June 1998. The first incident resulted in the deaths of Adrian and Michael Aguirre at an apartment complex, while the second led to the murder of sixteen-year-old Jose Varela and Hugo Perez. Alvarez was identified through eyewitness accounts, testimony from co-participants, forensic evidence, and his own admissions to police. The prosecution presented overwhelming evidence, including ballistics linking Alvarez’s firearm to the shootings and DNA evidence connecting his shotgun to one of the victims. At trial, Alvarez was represented by two attorneys; the defense focused on challenging witness credibility and provided mitigation evidence through family members and a psychologist.On appeal, Alvarez’s counsel raised numerous claims in the Texas Court of Criminal Appeals (TCCA), which affirmed the conviction and death sentence. Subsequent state habeas proceedings involved multiple attorneys and filings, including claims of ineffective assistance of counsel and issues regarding consultation with the Mexican consulate. Alvarez also asserted the introduction of tainted DNA evidence and misconduct by the Houston Crime Lab. The TCCA dismissed some of these habeas applications as an abuse of the writ, finding certain claims procedurally barred. Alvarez then sought federal habeas relief in the United States District Court for the Southern District of Texas, which denied all claims and refused to grant investigative funding or a certificate of appealability.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of habeas relief, analyzing three certified claims: deprivation of counsel due to one attorney allegedly sleeping during trial, ineffective assistance for failing to present additional mitigation evidence, and claims regarding tainted DNA evidence. The Fifth Circuit held that Alvarez was not constitutionally deprived of counsel since his second attorney was actively engaged, and there was no unreasonable application of federal law or unreasonable factual determination by the state courts. It also found no ineffective assistance in the mitigation phase and concluded the DNA-related claims were procedurally barred and, alternatively, meritless. The Fifth Circuit affirmed the district court’s judgment denying habeas relief. View "Alvarez v. Guerrero" on Justia Law