Justia Constitutional Law Opinion Summaries

Several individuals, all enthusiasts of distilling spirits, and a non-profit organization devoted to legalizing at-home hobby distilling, sought to challenge longstanding federal laws prohibiting the operation of home distilleries. The plaintiffs, who had experience with lawful alcohol production for fuel or other beverages, expressed clear intent to distill spirits for personal consumption at or near their residences. They faced explicit warnings from federal authorities that such activity was illegal and punishable by substantial penalties, and that no permits would be issued for home-based distillation of consumable spirits.After contacting the Alcohol and Tobacco Tax and Trade Bureau (TTB) and receiving confirmation that home distilling would not be permitted, the plaintiffs filed suit in the United States District Court for the Northern District of Texas against the TTB and the U.S. Department of Justice. The district court dismissed several individual plaintiffs for lack of standing but allowed the claims of one individual and the non-profit organization to proceed. On the merits, the district court determined that federal statutes barring home distilling for beverage purposes violated the Constitution’s Commerce, Taxation, and Necessary and Proper clauses. The government appealed, and the dismissed plaintiffs cross-appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that all individual plaintiffs and the non-profit organization had standing to sue. On the merits, the Fifth Circuit ruled that the statutory prohibition on home distilleries and associated criminal penalties exceeded Congress’s constitutional authority under both the Taxation Clause and the Necessary and Proper Clause, as the prohibitions were not “plainly adapted” to raising revenue and represented an improper federal intrusion into matters reserved to the states. The Fifth Circuit affirmed the district court’s judgment and injunction against enforcement of the statutes, as modified. View "McNutt v. Dept of Justice" on Justia Law

The case concerns a defendant who was convicted of two counts of aggravated sexual assault against his niece, N.H., based on events that occurred between 2005 and 2011, when N.H. was a child. The charges alleged both oral and penetrative sexual contact. The main evidence at trial included N.H.’s testimony describing multiple assaults, with a focus on specific incidents that occurred in the defendant’s barn, particularly an incident when N.H. was in the sixth grade. N.H. also testified that the assaults stopped when she was around eleven or twelve years old.After the jury convicted the defendant on both counts in the Superior Court, Addison Unit, Criminal Division, the defendant appealed. He argued that there was insufficient evidence to prove that N.H. was under thirteen at the time of the barn assault (Count Two), that the trial court’s jury instruction on reasonable doubt violated his constitutional rights, and that the admission of prior-bad-act evidence was an abuse of discretion. The trial court had previously denied his motion for acquittal on Count Two, finding there was enough evidence for the jury to find him guilty beyond a reasonable doubt.The Vermont Supreme Court reviewed the case. It held that the evidence was sufficient for a reasonable jury to conclude that N.H. was under thirteen at the relevant time, affirming the denial of acquittal. However, the Court determined that the trial court’s instruction defining “beyond a reasonable doubt” as “great certainty” impermissibly lowered the government’s burden of proof, violating the defendant’s federal due process rights. This was deemed plain error, requiring reversal of the convictions and a remand for a new trial. The Court did not address the evidentiary issue regarding prior bad acts. The main holding is that defining “beyond a reasonable doubt” as “great certainty” constitutes plain error warranting reversal and a new trial. View "State v. Kolts" on Justia Law

Jessie Farmer pleaded guilty in 2016 to two counts of using a communication facility to distribute methamphetamine, for which he received the statutory maximum sentence of 96 months’ imprisonment and one year of supervised release. After completing his prison term, Farmer began supervised release in 2024. The probation office later alleged that Farmer committed multiple violations of his release conditions, including missing drug tests and testing positive for drugs. The government petitioned to revoke his supervised release based on these violations.The United States District Court for the Western District of Arkansas reviewed the petition. Farmer argued that because he had already served the statutory maximum prison term for his offense, any additional imprisonment after revocation would violate his Fifth and Sixth Amendment rights unless a jury found the violations beyond a reasonable doubt. The district court denied Farmer’s motion to dismiss, found by a preponderance of the evidence that he committed ten violations, revoked his supervised release, and imposed a new prison sentence of twelve months, the statutory maximum for his supervised release violation.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether Farmer’s revocation sentence under 18 U.S.C. §§ 3583(e) and 3583(g) violated his constitutional rights to due process and trial by jury. The court concluded that the relevant Supreme Court guidance, particularly the controlling concurrence in United States v. Haymond, does not require application of the Apprendi line of cases to supervised release revocations under these sections. The Eighth Circuit held that the district court’s revocation and sentence did not violate Farmer’s constitutional rights, because the statutes did not require punishment for a new offense, preserved judicial discretion, and limited the sentence to the original statutory maximum. The judgment of the district court was affirmed. View "United States v. Farmer" on Justia Law

During the COVID-19 pandemic, the Wisconsin legislature enacted a statute granting immunity to health care providers from civil liability for certain acts or omissions occurring between March 12, 2020, and July 11, 2020. Savannah Wren, whose pregnancy was considered high risk, experienced the stillbirth of her child after multiple visits to Columbia St. Mary’s Hospital. She alleged negligent care and subsequently filed suit for medical malpractice, wrongful death, and negligent infliction of emotional distress against the hospital and associated medical professionals.The Milwaukee County Circuit Court considered the defendants’ motion to dismiss based on the immunity provided by WIS. STAT. § 895.4801. Wren challenged the statute’s constitutionality on several grounds, including vagueness, overbreadth, and violations of her rights to redress, jury trial, due process, and equal protection. The circuit court struck her supplemental equal protection claim and ultimately dismissed her complaint with prejudice, finding the statute constitutional.Upon appeal, the Wisconsin Court of Appeals reversed the dismissal. It held that § 895.4801 was facially unconstitutional because it deprived litigants of their right to a jury trial under Article I, Section 5 of the Wisconsin Constitution, and concluded that the statute was not narrowly tailored to serve a compelling state interest.The Supreme Court of Wisconsin reviewed only whether § 895.4801 facially violates the state constitutional right to a jury trial. The court held that because the legislature has the authority to abrogate or suspend common law causes of action under Article XIV, Section 13, and because the statute eliminated Wren’s causes of action during the specified period, her right to a jury trial did not attach. The court concluded that § 895.4801 does not implicate the constitutional jury trial right, reversed the court of appeals’ decision, and remanded for further proceedings on other unresolved issues. View "Wren v. Columbia St. Mary's Hospital Milwaukee, Inc." on Justia Law

The case involved a defendant who was charged in two separate criminal complaints, filed by different prosecutors, for conduct arising out of the same incident. The first complaint, brought by a city prosecutor in county court, alleged violations of municipal ordinances—specifically assault and battery, and disorderly conduct. The defendant entered a no contest plea to disorderly conduct as part of a plea agreement, and the assault and battery charge was dismissed with prejudice. Shortly before this plea, the county attorney’s office had filed a separate complaint charging the defendant with felony assault based on the same incident. After the case was later amended to charge first degree felony assault, the defendant argued that prosecuting the felony charge would violate double jeopardy protections.In the District Court for Douglas County, the defendant filed a plea in bar, contending that double jeopardy attached to the dismissed municipal assault and battery charge, thus barring the subsequent felony prosecution. The district court denied the plea, finding that jeopardy never attached to the dismissed charge because the defendant did not plead guilty or face trial on that offense, and the dismissal did not entail a determination of the merits.On appeal, the Nebraska Supreme Court reviewed the denial of the plea in bar de novo. The court held that jeopardy did not attach to the municipal assault and battery charge because the defendant did not enter a plea to that charge, nor did the court make any factual findings regarding it. The court further explained that a dismissal with prejudice pursuant to a plea agreement does not amount to an acquittal or the attachment of jeopardy unless the court resolves factual elements of the offense. Accordingly, the Nebraska Supreme Court affirmed the district court’s denial of the plea in bar, holding that double jeopardy protections did not bar the felony assault prosecution. View "State v. Holland" on Justia Law

An eight-year-old child, N.R., alleged that her father, Gerald Roberson, had sexually abused her over several years, with the most recent incident occurring two months before she was taken by her mother to a hospital for a sexual assault examination. While the examination found no physical evidence of abuse, N.R. gave a detailed statement about repeated abuse and indicated that Roberson threatened her to keep her silent. Roberson was charged with multiple serious offenses relating to sexual abuse of a child.The State moved before trial to allow N.R. to testify remotely using closed-circuit television (CCTV), citing a Delaware statute permitting such testimony for children under certain conditions. After a hearing that included expert testimony from N.R.’s counselor about the child’s fear and likely inability to communicate in her father’s presence, the Superior Court found that remote testimony was warranted and that the statute permitting it did not violate the Delaware Constitution. The court also denied Roberson’s request for a limiting instruction after the prosecutor, during closing arguments, asked the jury to consider why a child would endure the ordeal of reporting and testifying if her claims were untrue. The jury convicted Roberson on all counts, and he was sentenced to 125 years in prison.The Supreme Court of the State of Delaware reviewed whether the statutory procedure allowing child witnesses to testify by CCTV violated the state constitutional right to confront witnesses “face to face,” and whether the prosecutor’s closing argument constituted impermissible vouching for the witness’s credibility. The Court held that the statute does not violate the Delaware Constitution, relying on precedent that interprets the confrontation right to allow such procedures in the interest of protecting child victims while preserving the defendant’s right to cross-examination. The Court also found that the prosecutor’s comments did not amount to misconduct. The judgment of the Superior Court was affirmed. View "Roberson v. State" on Justia Law

A 13-year-old male student at a Virginia Beach middle school received a sexually explicit photo from a female classmate and, several months later, showed the image to other students during the school day. After teachers reported the incident, the assistant principal removed the student from class, questioned him, and searched his phone’s photo gallery. The school resource police officer was notified and began a criminal investigation. The student ultimately showed the explicit photo to the officer, was read his Miranda rights, arrested, and charged in juvenile court with possession of child pornography. The juvenile court found sufficient evidence for guilt but deferred disposition; the charge was dismissed after the student completed court-imposed conditions.The student, through his mother and later counsel, sued the assistant principal, the school resource officer, the Virginia Beach School Board, and the City of Virginia Beach in the United States District Court for the Eastern District of Virginia. He alleged violations of his Fourth, Fifth, and Fourteenth Amendment rights, as well as conspiracy and Monell claims. The district court granted summary judgment to all defendants, finding the phone search reasonable under New Jersey v. T.L.O., the confession voluntary, no evidence of unlawful conspiracy, and no underlying constitutional violations to support Monell liability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that the assistant principal’s search of the student’s phone was justified at its inception and reasonable in scope under T.L.O., and that Riley v. California did not displace this standard in the school context. The court also held the student’s confession was voluntary under the Fifth and Fourteenth Amendments, found no evidence of a conspiracy to violate constitutional rights, and determined Monell liability could not attach absent an underlying constitutional violation. The court therefore affirmed summary judgment for all defendants. View "O.W. v. Carr" on Justia Law

The case concerns a man convicted of the 1989 murders of his girlfriend and her daughter in Arizona. He was found guilty by a jury and subsequently sentenced to death by a judge. The sentencing judge identified multiple aggravating factors, including the especially cruel nature of the crimes, multiple victims, and prior violent felonies. The judge also found statutory and non-statutory mitigating factors, such as the defendant’s impaired capacity, troubled childhood, and psychological issues. After his conviction and sentencing were affirmed on direct appeal by the Arizona Supreme Court, the defendant sought postconviction relief in state court through three separate petitions. His first petition did not raise an ineffective assistance of counsel (IAC) claim and was handled by counsel later conceded to be ineffective. A second petition, raising the IAC claim, was denied as untimely. A third petition argued he was intellectually disabled and therefore ineligible for execution, but that claim was rejected after an evidentiary hearing.In federal court, the petitioner’s IAC claim was initially deemed procedurally defaulted by the United States District Court for the District of Arizona. Subsequent Supreme Court and Ninth Circuit decisions, including Martinez v. Ryan, allowed for the possibility that ineffective postconviction counsel could excuse such defaults. The Ninth Circuit originally remanded for an evidentiary hearing, but the United States Supreme Court reversed, holding that federal courts may not expand the state court record based on ineffective state postconviction counsel.On remand, the United States Court of Appeals for the Ninth Circuit considered only evidence properly submitted in state court under procedural rules. The Ninth Circuit found the petitioner demonstrated “cause” to excuse the procedural default but failed to show “prejudice,” as his underlying IAC claim was not “substantial.” Although counsel’s performance was deficient, the new mitigating evidence was unlikely to have changed the sentencing outcome, given the weight of aggravating factors and Arizona precedent. The Ninth Circuit affirmed the district court’s denial of habeas relief. View "RAMIREZ V. THORNELL" on Justia Law

The defendant was convicted of voting in more than one state during the 2016 general election. He maintained residences in both New Hampshire and Massachusetts and was alleged to have voted in Holderness, New Hampshire by absentee ballot and in Belmont, Massachusetts in person. The State introduced evidence of his voting history in both states from 1996 to 2018 and sought to exclude statements by an acquaintance, William Botelho, who had previously admitted to voting in the defendant's name in Massachusetts.The Grafton County Superior Court allowed the State to admit the defendant’s prior voting records under New Hampshire Rule of Evidence 404(b) and excluded Botelho’s statements as inadmissible propensity evidence, also denying the defendant’s request for a Richards hearing regarding Botelho’s potential testimony. After a jury found the defendant guilty, the Superior Court denied his post-trial motions for dismissal based on territorial jurisdiction, judgment notwithstanding the verdict, and to set aside the verdict.The Supreme Court of New Hampshire found that the Superior Court erred in admitting the defendant’s prior voting history because the danger of unfair prejudice substantially outweighed its probative value, especially since the prior alleged acts were nearly identical to the charged crime. The court also held that evidence of Botelho’s confession to voting in the defendant’s name in the 2016 election was not evidence of other bad acts under Rule 404(b) and should not have been categorically excluded. The Supreme Court further ruled that, if Botelho asserts his Fifth Amendment rights on remand, the trial court must hold a Richards hearing.The Supreme Court affirmed the lower court’s denial of the defendant’s motions regarding territorial jurisdiction, sufficiency, and weight of the evidence, but reversed the conviction due to the evidentiary errors and remanded for further proceedings. View "State v. Rosen" on Justia Law

A married couple, acting on behalf of their minor child, challenged West Virginia’s compulsory vaccination law after their daughter was disenrolled from a public virtual school because she was not fully vaccinated. The parents sought a religious exemption from the vaccination requirement, but were informed that only medical exemptions—based on specific medical contraindications or precautions certified by a physician—are permitted under state law. After being denied a religious exemption, the parents filed suit, claiming that the absence of a religious exemption violated their First Amendment right to freely exercise their Christian faith. They requested a preliminary injunction to allow their daughter’s re-enrollment in the virtual academy during the litigation.The United States District Court for the Northern District of West Virginia granted the preliminary injunction, finding that the parents were likely to succeed on their free exercise claim. The district court applied the test from Employment Division, Department of Human Resources of Oregon v. Smith, concluding that the vaccination law was not generally applicable, and thus subject to strict scrutiny, which it found the law did not survive.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s grant of preliminary relief. The Fourth Circuit held that West Virginia’s compulsory vaccination law is a neutral and generally applicable measure enacted under the state’s police power to protect public health, as recognized in longstanding Supreme Court precedent including Jacobson v. Massachusetts and Prince v. Massachusetts. The court found that the medical exemption process does not constitute a “mechanism for individualized exemptions” that would undermine general applicability under cases such as Fulton v. City of Philadelphia. The Fourth Circuit concluded that the law is subject to rational basis review, which it easily satisfies, and that the Free Exercise Clause does not require religious exemptions simply because medical exemptions exist. The court reversed the district court’s preliminary injunction and remanded the case. View "Perry v. Marteney" on Justia Law