Justia Constitutional Law Opinion Summaries

After being involved in an eviction proceeding in Hillsborough County, Florida, an individual deposited funds into the court registry, as required by state law. Over time, he changed addresses and updated his contact information in the state’s e-filing system, but did not always update his address with the county court. The county clerk attempted to notify him of unclaimed funds by mailing letters to an outdated address (despite repeated returned mailings) and by publishing notice in a local Spanish-language newspaper with very limited circulation in the county. The funds were eventually declared abandoned and forfeited to the county under a Florida statute.The United States District Court for the Middle District of Florida granted summary judgment in favor of the county clerk. The district court found that publication in the local newspaper constituted constitutionally sufficient notice and that the forfeiture did not amount to an unconstitutional taking because statutory schemes for escheatment of abandoned property are generally permissible.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court held that the statute’s notice procedure is not facially unconstitutional because there are situations where publication alone may suffice—for instance, when the property owner is unknown. However, the court found the clerk’s application of the statute to this individual was unconstitutional. The clerk had access to alternative means of contact (including email and a valid mailing address in the state’s e-file system) but failed to use them, relying instead on methods not reasonably calculated to provide notice. The court also determined that the individual had not abandoned the funds, since he never received constitutionally adequate notice, and thus the county’s appropriation of the funds constituted an unconstitutional taking. The Eleventh Circuit affirmed in part, reversed in part, and remanded for further proceedings. View "Warner v. Hillsborough County Clerk of Courts" on Justia Law

The defendant was charged with capital murder and other offenses in 1993. Throughout the proceedings, concerns arose regarding his mental competency and his ability to represent himself. On two occasions, the trial court declared a doubt as to the defendant’s competency and held hearings, concluding both times that he was competent. During the second such hearing in July 1994, the defendant represented himself, which meant no counsel was appointed despite statutory requirements. The medical experts at the hearing offered differing views: one expert found the defendant competent to stand trial but not to represent himself, while the other found him unable to cooperate rationally with counsel. The defendant was ultimately convicted and sentenced to death.After direct appeal, the Supreme Court of California found reversible error in the trial court’s failure to appoint counsel during the 1994 competency proceedings and remanded the case, instructing the trial court to determine if a retrospective competency hearing was feasible. If feasible, a hearing would be held; if not, the reversal would stand.On remand, the Kern County Superior Court found that a retrospective hearing was feasible, conducted the hearing, and a jury found the defendant competent at the relevant time, leading to reinstatement of the judgment. The defendant appealed again, arguing that feasibility was not established.The Supreme Court of California held that the trial court erred in finding a retrospective competency hearing feasible. The court emphasized that such hearings are generally disfavored and that the prosecution had not met its burden to show sufficient and reliable evidence existed to determine the defendant’s competence nearly two decades later, especially given the unavailability of key witnesses and the compromised development of evidence due to the lack of appointed counsel in 1994. As a result, the Supreme Court reversed the reinstated judgment, subject to retrial if the defendant is then found competent. View "P. v. Lightsey" on Justia Law

Derek Fields was involved in a violent kidnapping in September 2015, during which he and his co-defendants abducted Adrian Harris, inflicted physical harm, and demanded ransom. Fields was arrested within days alongside his co-defendants and indicted on several charges, including kidnapping, making a ransom demand, and firearm offenses. The government extended multiple plea offers, each carrying substantial prison time, but Fields consistently rejected them, viewing sentences over twenty years as tantamount to a life sentence. After his motion to suppress evidence was denied, Fields proceeded to trial, was convicted on all counts, and originally sentenced to 53 years. On appeal, his conviction under one firearm statute was vacated pursuant to United States v. Davis, 588 U.S. 445 (2019), and he was resentenced to 43 years.After his conviction became final, Fields filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Northern District of Indiana, arguing that his last counsel was constitutionally ineffective for failing to adequately advise him about an alleged 37-year plea offer presented during jury selection. The district court denied the motion without an evidentiary hearing, focusing primarily on a different plea agreement attached to Fields’s reply brief, and concluded that Fields failed to show prejudice because he did not establish a reasonable probability he would have accepted the offer and received a lower sentence.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo for legal questions and for abuse of discretion regarding the lack of an evidentiary hearing. The Seventh Circuit assumed, for argument’s sake, that the alleged 37-year plea offer existed and that counsel’s advice was inadequate, but found that Fields did not demonstrate a reasonable probability he would have accepted the plea or received a lower sentence. The court therefore affirmed the district court’s denial of Fields’s § 2255 motion without an evidentiary hearing. View "Fields v. USA" on Justia Law

Jessica McKee, a pretrial detainee at the Steele County Detention Center in Minnesota, suffered from Crohn’s disease. During her detention, she communicated with jail medical staff, including Nurse Jessica Brady, regarding various medical needs. McKee requested accommodations such as a lower bunk due to alleged seizures and pain, dietary changes to address her Crohn’s disease, and access to her prescription medication. Brady denied the bunk request due to lack of documentation, approved dietary changes as requested by McKee, and communicated with outside care providers to obtain medical records. When McKee reported worsening symptoms, Brady called her for an in-person evaluation and referred her to the emergency room, where McKee was hospitalized and suffered complications.McKee filed a lawsuit under 42 U.S.C. § 1983, asserting that Brady was deliberately indifferent to her serious medical needs in violation of her Fourteenth Amendment rights. Nurse Brady moved for summary judgment on the basis of qualified immunity. The United States District Court for the District of Minnesota denied Brady’s motion, finding that a reasonable jury could conclude that Brady was deliberately indifferent to McKee’s medical needs.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment de novo. The Eighth Circuit concluded that McKee failed to show that Brady’s actions violated a clearly established constitutional right. The court found that Brady responded to each of McKee’s requests, followed appropriate procedures within her authority, and was not deliberately indifferent as defined by precedent. The court further determined that any negligence did not rise to the level of a constitutional violation. Accordingly, the Eighth Circuit held that Brady was entitled to qualified immunity and reversed the district court’s order denying summary judgment. View "McKee v. Brady" on Justia Law

A 21-year-old man engaged in sexually explicit communications and exchanged illicit images with a 15-year-old minor through Snapchat. The minor’s parents discovered the messages, reported them to authorities in Sarpy County, Nebraska, and provided the minor’s phone and Snapchat details. Law enforcement in Nebraska obtained search warrants from local judges to gather information from Snap Inc. in California and Google in California related to the suspect’s account. The investigation identified the suspect’s location in Kansas City, Missouri, and federal authorities subsequently obtained and executed a search warrant at his residence, seizing electronic devices that contained child pornography.After the investigation, a federal grand jury indicted the defendant on multiple counts related to child pornography. Prior to entering a guilty plea, the defendant moved to suppress all evidence obtained in the case, arguing that the Nebraska judges lacked authority to issue search warrants for data held outside Nebraska, and that the evidence collected was therefore obtained in violation of his constitutional rights. A magistrate judge in the United States District Court for the Western District of Missouri recommended denying the motion, and the district court adopted that recommendation.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the motion to suppress, applying a mixed standard of review: clear error for factual findings and de novo for legal conclusions. The court held that Nebraska law expressly authorized state judges to issue search warrants for service on out-of-state entities. The court also found that the federal rules concerning the territorial limits of federal magistrate judges did not apply to state judges. Additionally, even if there were defects in the warrants, the Leon good-faith exception would apply because law enforcement reasonably relied on the judges’ determinations. The Eighth Circuit affirmed the district court’s denial of the suppression motion. View "United States v. Peterson" on Justia Law

In 1977, a 14-year-old was questioned by police in Peoria, Illinois, about the murder of two teenagers. Over roughly two days, police and a polygraph examiner interrogated him, at times using harsh tactics. He eventually confessed and was convicted of first-degree murder. The state appellate court later overturned the conviction, finding the confession involuntary. He was retried, convicted again, and served decades in prison before being released on parole in 2006. In 2014, he was pardoned by the governor. Years later, he filed a civil suit under 42 U.S.C. § 1983 against 16 former police officers, the City of Peoria, and the polygrapher, alleging unlawful detention, coercion of his confession, and destruction and fabrication of evidence.The United States District Court for the Central District of Illinois denied summary judgment to the defendants, concluding that material factual disputes precluded resolution of the unlawful detention claim, that clearly established law would have put the officers and the polygrapher on notice their interrogation tactics were unconstitutional, and that a reasonable jury could find evidence destruction and fabrication in violation of established law.On appeal, the United States Court of Appeals for the Seventh Circuit reversed. The court held the officers were entitled to qualified immunity for the unlawful detention claim, finding they had arguable probable cause based on the totality of the circumstances. The court also found no evidence the officers destroyed evidence in bad faith or at a time when its exculpatory value was apparent, and held there was no clearly established law making their actions unconstitutional at the relevant times. Additionally, the court concluded that the coercion claim failed because no then-existing precedent put the unconstitutionality of the officers’ interrogation methods “beyond debate.” Finally, the court held the officers were entitled to absolute immunity for testimony at trial, even if it was consistent with allegedly fabricated evidence not introduced at trial. Accordingly, the district court’s denial of immunity was reversed. View "Savory v Andrews" on Justia Law

A public interest law firm known for its advocacy on religious liberty and free speech was included on a list of "hate groups" published by the Southern Poverty Law Center (SPLC) in 2015, and has remained on the list since. In February 2019, Michigan’s Attorney General and the then-Director of the Michigan Department of Civil Rights issued a press release responding to the SPLC’s latest "Hate Map," noting an increase in such groups and announcing new state initiatives. Although the press release did not name the law firm, it linked to the SPLC report. The law firm alleged that it suffered reputational, economic, and organizational harm as a result, claiming a chilling effect on its First Amendment rights and seeking declaratory and injunctive relief against the officials.The United States District Court for the Western District of Michigan initially found that the law firm had adequately pleaded standing, as the press release arguably conferred the state’s “imprimatur” on the SPLC’s list, potentially harming the law firm’s reputation. The court denied the officials’ motion to dismiss at the pleading stage. However, following discovery and summary judgment motions, the district court concluded that the law firm failed to present sufficient evidence of a cognizable injury in fact traceable to the defendants’ actions or likely to be redressed by the requested relief, and granted summary judgment for the officials on standing grounds.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment ruling de novo. The Sixth Circuit held that the law firm had not demonstrated that the officials’ press release caused it any incremental reputational or economic injury beyond that resulting from the SPLC’s designation, nor that any such injury was ongoing or likely to recur. The court further found the law firm’s diversion-of-resources theory forfeited and unsupported. The judgment for the defendants was affirmed. View "Am. Freedom Law Center v. Nessel" on Justia Law

The dispute centers on a property owner that purchased a vacant and dilapidated parcel in Nashville’s East Bank district, intending to redevelop it into a multi-family residential project in accordance with local zoning rules. The owner submitted a building permit application that, according to its allegations, fully complied with all applicable zoning requirements. However, in mid-2022, the local government placed an indefinite “development hold” on the property, effectively barring any consideration or approval of the permit. The stated reason was that authorities were assessing possible routes for a planned major roadway that might require acquisition of part of the property. As a result, the owner claims the property has become undevelopable and unsellable, resulting in millions of dollars in carrying costs.After unsuccessful efforts to have the hold lifted, the owner filed suit in state court, alleging violations of the Takings and Due Process Clauses of the U.S. Constitution and the Tennessee Constitution. The case was removed to the United States District Court for the Middle District of Tennessee, where the defendants moved to dismiss on several grounds, including untimeliness and qualified immunity. The district court, on its own initiative, dismissed the complaint for lack of “jurisdictional” ripeness, reasoning that there had been no final decision on the permit application.On appeal, the United States Court of Appeals for the Sixth Circuit considered only the ripeness issue. The court held that the owner’s claims were both constitutionally and prudentially ripe because the local government’s development hold constituted a definitive, final decision barring any development of the property. The appellate court reversed the district court’s dismissal and remanded the case for further proceedings on the remaining issues. View "SW Nashville EB Owner, LLC v. Metro. Gov't of Nashville & Davidson Cnty." on Justia Law

Law enforcement officers sought and obtained a no-knock search warrant for a residence in an area known as Kent Bottom, Maryland, based on an affidavit describing the area's reputation for drug activity, criminal histories of individuals associated with the area, and surveillance of suspected drug transactions near the property. The affidavit included descriptions of drug-related incidents from as far back as 2006 involving the residence, as well as more recent but less direct observations of possible drug activity in the general vicinity of the house. The more recent surveillance involved suspected hand-to-hand transactions outside the residence and people entering and leaving the property, but did not directly connect current criminal activity to the interior of the home.After the search, officers recovered drugs and a firearm from a vehicle parked outside the residence. The defendant, who was found inside the house, was charged with several drug and firearm offenses. He moved to suppress the evidence, arguing that the warrant lacked probable cause because the affidavit failed to establish a meaningful connection between the alleged criminal activity and the specific residence. The United States District Court for the District of Maryland denied the motion, reasoning that the history and geography of drug activity in Kent Bottom, along with the observed conduct near the residence, provided a sufficient basis for probable cause.The United States Court of Appeals for the Fourth Circuit reversed. It held that the warrant affidavit did not provide a substantial basis for probable cause to search the residence because the facts were either too old, not specifically tied to the home, or both, and therefore failed to establish a fair probability that evidence of a crime would be found inside the house at the time of the search. The court also determined that the good-faith exception did not apply, as the affidavit was so lacking in indicia of probable cause that no reasonable officer could rely on it. The court reversed the district court’s denial of the motion to suppress, vacated the conviction, and remanded for further proceedings. View "US v. Griffin" on Justia Law

The defendant was indicted on multiple counts of statutory sexual offense with a child and indecent liberties with a child. Over a period of approximately fifty months, the defendant was represented by five different court-appointed attorneys, each of whom either withdrew due to conflicts, personal reasons, or at the defendant’s request. Dissatisfied with his representation, the defendant twice filed handwritten documents titled “Waiver of Counsel,” with the first explicitly requesting to proceed pro se with standby counsel. The trial court conducted a colloquy with the defendant to assess whether he knowingly, intelligently, and voluntarily wished to waive his right to counsel, ultimately finding that he did and assigning standby counsel. The defendant represented himself at trial, with standby counsel examining witnesses upon the State's motion. The jury convicted him on several counts, and he was sentenced to a minimum of seventy-five years.After conviction, the defendant appealed. The North Carolina Court of Appeals vacated the judgments and remanded for a new trial, holding that the defendant had neither knowingly nor voluntarily waived his right to counsel, and therefore, his convictions could not stand.Upon review, the Supreme Court of North Carolina reversed the decision of the Court of Appeals. The Supreme Court held that, under the totality of the circumstances—including the defendant’s two written waivers, his in-court statements, and his consistent course of conduct—the defendant clearly and unequivocally expressed his intent to proceed without counsel. The Court further held that the trial court’s colloquy, while not perfectly precise as to the full range of potential punishments, substantially complied with statutory requirements because both the misstated and actual sentences amounted to more than the defendant’s natural life. Accordingly, the Supreme Court determined that the waiver of counsel was valid and reinstated the trial court’s judgment. View "State v. McGirt" on Justia Law