Justia Constitutional Law Opinion Summaries

Curtis Squire was indicted on a federal charge for possessing a firearm as a convicted felon after police found a handgun in his home during a search related to a shooting investigation. Although the firearm was not linked to the shooting and state charges were dropped, Squire was charged under 18 U.S.C. § 922(g)(1) due to his prior felony convictions, which included drug trafficking, firearm offenses, obstruction of justice, burglary, and unauthorized use of a motor vehicle.The United States District Court for the Eastern District of Louisiana denied Squire’s motion to dismiss the indictment. Squire’s motion argued, among other things, that § 922(g)(1) was unconstitutional as applied to him under the Second Amendment, particularly following New York State Rifle & Pistol Ass’n v. Bruen and United States v. Rahimi. He contended that his right to possess a firearm in his home was protected by historical tradition. After the denial, Squire pleaded guilty without a plea agreement and was sentenced to fifty-two months’ imprisonment and three years of supervised release. He preserved his right to appeal and timely did so.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and considered whether the Second Amendment protects a convicted drug trafficker from being dispossessed of a firearm in his home. The court held that, in light of historical tradition and its own precedent, Congress may disarm individuals convicted of dangerous offenses like drug trafficking, even within the home. The court clarified that this holding is narrow and does not address whether Congress may disarm individuals in the home based on non-dangerous convictions. The Fifth Circuit affirmed the judgment of conviction and sentence. View "USA v. Squire" on Justia Law

In June 2000, a woman identified as M.M. was attacked in her barracks at Fort Hood, where she was stabbed multiple times and sexually assaulted by an unknown assailant. The investigation initially went cold after DNA collected at the scene did not match any suspects. Nearly two decades later, forensic genetic genealogy linked the DNA to Allen James, who had been stationed at Fort Hood and matched the description of the attacker. He was indicted and ultimately convicted by a jury for attempted murder based on DNA evidence and M.M.'s testimony.Proceedings in the United States District Court for the Western District of Texas resulted in James's conviction for attempted murder. At sentencing, the district court used the 2023 Sentencing Guidelines Manual, which prescribed a higher advisory range than the 1998 Manual that was in effect when the offense occurred. James was sentenced to 200 months’ imprisonment and three years of supervised release. He appealed, arguing insufficient evidence of intent to kill, erroneous jury instructions regarding intent, and a violation of the Ex Post Facto Clause due to use of the later Guidelines Manual.The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court held that the evidence was sufficient for a rational jury to find specific intent to kill, and the jury instructions, while imperfect, did not constitute reversible error because any defect was invited by James’s own proposed language and did not result in manifest injustice. However, the court found plain error in the district court’s application of the later Guidelines Manual, in violation of the Ex Post Facto Clause, as this resulted in a higher sentencing range. The Fifth Circuit affirmed James’s conviction, vacated his sentence, and remanded for resentencing under the correct Guidelines Manual. View "USA v. James" on Justia Law

A man was charged with Incest in Montana after his daughter, a minor, alleged that he had sexually abused her over a period of years. The allegations first arose when the daughter disclosed the abuse during a private conversation with her stepfather, who subsequently reported the matter to authorities. Forensic interviews with the daughter revealed detailed descriptions of sexual acts and physical sensations. During the investigation, it was discovered that the daughter’s brother had pornography on his phone, and there were vague suggestions of inappropriate touching between the siblings. The defense argued that these were possible alternative sources for the daughter's sexual knowledge, seeking to rebut the State’s anticipated argument that such knowledge must have come from the defendant’s alleged abuse.The case proceeded to trial in the Fourth Judicial District Court, Missoula County. Before trial, the State moved to exclude evidence of the pornography and alleged sibling touching under Montana’s rape shield statute. The District Court granted the State’s motion, finding the proposed evidence speculative, lacking a clear connection to the daughter’s knowledge, and carrying a risk of undue prejudice. The court stated it would reconsider if the daughter’s trial testimony established a relevant foundation, but no such foundation emerged during testimony. The jury ultimately convicted the defendant, and he was sentenced to 100 years, with 85 years suspended.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court’s exclusion of the evidence violated the defendant’s constitutional rights to present a defense and confront witnesses. The Supreme Court found that the District Court properly balanced the protections of the rape shield statute with the defendant’s constitutional rights, did not act arbitrarily or unreasonably, and that the excluded evidence was speculative and lacked a sufficient connection to the charged conduct. Thus, the conviction was affirmed. View "State v. Olson" on Justia Law

A public agency adopted an ordinance to increase water service rates after following procedural steps, such as conducting a cost-of-service analysis, notifying the public, and holding hearings as required by Proposition 218 of the California Constitution. After adopting the new rates, the agency initiated a validation action in court to confirm the validity of the ordinance, providing notice to interested parties by publication in a local newspaper, as authorized by statute. No one responded to contest the action within the required time, so the court entered default judgment upholding the ordinance.Subsequently, an individual who had previously submitted administrative claims to the agency challenging the rates filed a class action and mandamus lawsuit seeking refunds and declaratory and injunctive relief, alleging violations of Proposition 218 and constitutional rights. The agency responded with a demurrer, arguing that the plaintiff's claims were barred by the prior validation judgment and the statutory scheme requiring such challenges be brought through validation procedures. The Marin County Superior Court agreed, sustaining the demurrer without leave to amend and finding that the plaintiff's opportunity to challenge the rates had been foreclosed by the unchallenged validation judgment.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that under Government Code section 53759 and the related validation statutes, any legal challenge to ordinances adopting water service fees must be brought through specified validation proceedings, including constitutional claims. Since the plaintiff neither intervened in the agency's validation action nor filed a timely reverse validation action, her claims were barred. The court also found that due process was satisfied by the published notice required by statute, and that mandamus proceedings are not exempt from these requirements. The appellate court affirmed the judgment in favor of the agency. View "Hiller v. Marin Municipal Water Dist." on Justia Law

The defendant, who was a minor at the time he was arrested, was charged in district court by direct filing with several serious offenses, including first degree murder and attempted first degree murder. He was initially detained at a Division of Youth Services (DYS) facility. After turning eighteen, he was transferred to the county jail by law enforcement. The day after his transfer, the defendant objected, asserting that the transfer was unlawful and unconstitutional, and argued that the district court had discretion to keep him in DYS custody. He also claimed that his transfer to county jail violated his right to equal protection because another defendant in a different case had been allowed to remain in DYS custody after turning eighteen.The La Plata County District Court reviewed the People’s motion to transfer the defendant to county jail. After a hearing, the district court concluded that section 19-2.5-305(4)(g) of the Children’s Code required the defendant’s transfer to county jail upon turning eighteen and provided no discretion to rule otherwise. The court expressed discomfort with the result but determined it was bound by the statute. The defendant then sought relief in the Supreme Court of Colorado through an original proceeding.The Supreme Court of Colorado held that section 19-2.5-305(4)(g) plainly and unambiguously requires a person who turns eighteen while detained on charges filed directly in district court to be transferred to county jail, leaving no discretion for the district court to order continued DYS custody. The court further held that the defendant’s equal protection rights were not violated because he was not similarly situated to the other defendant who remained in DYS custody. Consequently, the Supreme Court discharged its order to show cause and remanded the case for further proceedings. View "People v. Lawrence" on Justia Law

An assistant principal at a Colorado high school received an anonymous tip through the Safe2Tell program reporting that a student, identified as “T.J.,” was seen smoking marijuana in a biology class around 12:30 p.m. The tip included a description of the student and his location during the alleged incident. The assistant principal confirmed that the only student known as “T.J.” at the school, T.J.W., was present in the described class at the specified time and matched the physical description provided. After bringing T.J.W. to his office and without observing any signs of drug use, the assistant principal searched T.J.W.’s backpack and found a marijuana vape pen.Subsequently, the People filed a delinquency petition against T.J.W. for possession of marijuana or marijuana concentrate. T.J.W. moved to suppress the evidence, arguing the search was unlawful because it was based solely on an anonymous tip with no corroboration of criminal activity. The District Court for Douglas County held a suppression hearing and granted the motion, finding that the search violated the Fourth Amendment as the tip was insufficiently corroborated to establish reasonable suspicion.The Supreme Court of Colorado reviewed the district court’s suppression order on interlocutory appeal. The court applied the two-part test from New Jersey v. T.L.O., focusing on whether the search was “justified at its inception.” It found that the anonymous Safe2Tell tip was sufficiently corroborated by the assistant principal’s verification of T.J.W.’s identity, location, and physical characteristics, creating reasonable suspicion. The Supreme Court of Colorado held that the search was justified at its inception and reversed the district court’s order suppressing the evidence, remanding for further proceedings. View "People ex rel. T.J.W." on Justia Law

Two police officers stopped a vehicle at night in a high-crime area of Denver because it lacked a front license plate. The officers observed the driver and the passenger, Troy J. Baker, making movements with their elbows above their shoulders, which they interpreted as "furtive" and possibly indicative of concealing contraband. After obtaining the occupants’ names, the officers learned that Baker had recently been arrested for possession of a weapon by a previous offender (POWPO). With backup present, Baker was removed from the vehicle and patted down. Shortly thereafter, police searched the passenger compartment and found a handgun under the seat Baker had occupied. Additional searches discovered drugs and more contraband in the vehicle.The District Court for the City and County of Denver conducted a suppression hearing, during which it found the initial stop justified due to the missing license plate but concluded that the detention and subsequent vehicle search exceeded the stop’s original justification. The district court was not persuaded that the observed movements constituted sufficient grounds for a protective sweep and found no specific, articulable facts supporting a reasonable belief that the occupants were dangerous. As a result, the district court suppressed all evidence obtained from the search.The Supreme Court of Colorado reviewed the case on interlocutory appeal. It held that the officers acted within constitutional limits. The court determined that the combination of the observed movements, Baker’s recent POWPO arrest, and the high-crime setting provided an objectively reasonable basis for a protective sweep of the passenger compartment. The subsequent search of the vehicle was also found lawful under the automobile exception, as probable cause existed to believe the vehicle contained evidence of a crime. The Supreme Court of Colorado reversed the district court’s suppression order and remanded for further proceedings. View "People v. Baker" on Justia Law

Sockwell Corners, LLC owned a parcel of land zoned as agricultural-residential in Newton County. The company, along with proposed purchasers and developers, sought to have the property rezoned. The Newton County Board of Commissioners denied their rezoning application on July 16, 2024. The applicants then filed a verified complaint in the Superior Court of Newton County, arguing that the county’s zoning ordinance was unconstitutional as applied to their property. After a bench trial, the Superior Court ruled against the applicants, rejecting their as-applied constitutional challenge in an order dated August 7, 2025.The applicants appealed directly to the Supreme Court of Georgia, asserting that appellate jurisdiction was proper due to the constitutional issues raised and on the basis that recent statutory amendments permitted a direct appeal under OCGA § 5-6-34(a)(14), which they claimed allowed direct review of final judgments or orders reviewing zoning decisions. The Supreme Court asked for supplemental briefing on whether the discretionary application procedures of OCGA § 5-6-35 should have been followed instead.The Supreme Court of Georgia held that the recent legislative amendments to the Zoning Procedures Law and the Appellate Practice Act did not abrogate its prior precedent, specifically Diversified Holdings, LLC v. City of Suwanee, 302 Ga. 597 (2017). That precedent requires appeals from superior court decisions reviewing local administrative agency decisions—such as the denial of a rezoning request for a specific property—to proceed by discretionary application. The Court found that the statutory amendments did not modify the relevant language or the nature of the decisions at issue. Because the appellants failed to file a discretionary application as required, the Supreme Court of Georgia dismissed the appeal. View "SOCKWELL CORNERS, LLC v. NEWTON COUNTY" on Justia Law

The case concerns the conviction of a man for the malice murder of his wife, who was found shot and burned in the carport of their home in January 2013. The evidence at trial showed that the defendant was close to the crime scene at the time of the murder, behaved suspiciously upon arrival (not asking about his wife but instead expressing concern over possessions in the house), and had a possible motive linked to an ongoing relationship with another woman. Evidence indicated that the murder weapon was likely a shotgun owned by the couple, and there was no sign of burglary, as valuables were left untouched. The defendant argued that intruders committed the crime, but the prosecution presented circumstantial evidence suggesting his guilt.After an extensive investigation, the defendant was arrested in December 2018 and tried in October 2021. The Superior Court of Coffee County jury found him guilty of malice murder, and he was sentenced to life in prison. Following the conviction, the defendant filed a motion for a new trial, which was denied after hearings. He appealed, arguing that the evidence was insufficient for conviction and that his constitutional right to a speedy trial was violated during the nearly 34-month delay between arrest and trial. The appeal was transferred to the Supreme Court of Georgia.The Supreme Court of Georgia held that the evidence was sufficient to support the conviction when viewed in the light most favorable to the verdict, rejecting the alternative hypothesis of a burglar as unreasonable based on the facts. However, the Court found that the trial court erred in its application of the legal framework for evaluating the speedy trial claim, specifically by not properly calculating the length of the delay and failing to attribute responsibility for pre-pandemic delays. The Supreme Court vacated the trial court’s order denying the motion to dismiss and remanded the case for proper consideration of the speedy trial claim. View "SHEFFIELD v. THE STATE" on Justia Law

Law enforcement confronted a man after receiving reports from his wife that he had used his cellphone to secretly record his 13-year-old stepdaughter while she was undressing in the bathroom, and that a hidden camera had captured him engaging in sexual activity outside his stepdaughters’ bedroom doors. The wife provided police with video evidence, and prior incidents of similar behavior had also been reported. When detectives approached the man at his workplace and asked to see his phone, he handed it to them. Police immediately informed him that they were seizing the device. The next day, investigators obtained a warrant to search the contents of the phone, which revealed incriminating photos and videos. Based on this evidence, the man was indicted on multiple counts related to sexual exploitation and voyeurism of minors.The case proceeded in the District Court of the Fourth Judicial District, Ada County. The defendant moved to suppress the evidence from the cellphone, arguing its seizure violated his Fourth Amendment rights because it was taken without a warrant or a recognized exception. At a suppression hearing, the court heard testimony about the risk that evidence could be quickly deleted and the practicalities of obtaining a warrant. The district court denied the motion, finding the seizure justified by exigent circumstances due to the imminent risk of evidence being destroyed, and concluded the police acted reasonably in timing and duration. The defendant entered a conditional guilty plea, preserving his right to appeal.On appeal, the Supreme Court of the State of Idaho reviewed whether the warrantless seizure met constitutional standards. The court held that the seizure was justified by the exigency of potential destruction of evidence, that probable cause existed, and that the police acted in compliance with the Fourth Amendment. The judgment of the district court was affirmed. The issue of parole conditions was deemed moot because those conditions were removed in an amended judgment. View "State v. Smith" on Justia Law