Justia Constitutional Law Opinion Summaries

Michael Connor was convicted in 2013 after a bench trial in Livingston County, Illinois, of five counts of predatory criminal sexual assault of a child. The offenses involved his daughter and stepdaughter, occurring when they were between five and seven years old. The statutory penalty was six to sixty years per count, to be served consecutively, but if convicted of assaulting multiple victims, the law required a mandatory life sentence. After his conviction, Connor received the mandatory life term.After his direct appeal was unsuccessful, Connor pursued postconviction relief in Illinois state court, arguing that his trial counsel was constitutionally ineffective during plea negotiations by failing to inform him that he faced a mandatory life sentence. He claimed this omission led him to reject an 18-year plea offer. At an evidentiary hearing, Connor testified that he would have accepted the plea had he known about the life sentence. The trial judge, however, found this testimony not credible, noting that Connor had repeatedly asserted his innocence and had unequivocally stated at sentencing that he would not have pleaded guilty even if aware of the outcome. The trial court denied postconviction relief, and the Illinois Appellate Court affirmed, finding no reasonable probability that Connor would have accepted the plea but for counsel’s alleged errors.Connor then sought federal habeas relief in the United States District Court for the Central District of Illinois, which was denied. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the denial. The Seventh Circuit held that federal habeas relief was not warranted because Connor failed to rebut, by clear and convincing evidence, the state court's credibility finding that he would not have accepted the plea. The judgment of the district court was affirmed. View "Connor v. Greene" on Justia Law

In this case, the petitioner was convicted and sentenced to death for the murder and robbery of two men in a Kentucky convenience store in 1987. After being identified as a suspect, he confessed to the crimes but later asserted an insanity defense at trial. His mental health was evaluated by state experts, who found him competent and not suffering from a mental illness that would have excused his conduct. At trial, the defense presented testimony from the petitioner and a psychologist, but the jury found him guilty on all counts and recommended the death penalty. The penalty phase included limited mitigation evidence and testimony.Following his conviction and sentencing, the petitioner pursued direct appeals and post-conviction relief in Kentucky state courts, including before the Kentucky Supreme Court, and sought certiorari from the United States Supreme Court, which was denied multiple times. He then filed a federal habeas corpus petition in the United States District Court for the Eastern District of Kentucky, asserting several constitutional claims, including ineffective assistance of counsel, improper jury instructions on the insanity defense, and cumulative error. The district court denied relief, but granted certificates of appealability on several issues.On appeal, the United States Court of Appeals for the Sixth Circuit first held that the Antiterrorism and Effective Death Penalty Act (AEDPA) is constitutional, rejecting the argument that it unconstitutionally restricts federal habeas review. Applying AEDPA deference, the court found that the Kentucky Supreme Court’s decisions regarding the jury instructions and most of the ineffective assistance of counsel claims were neither contrary to nor unreasonable applications of clearly established federal law. Claims not subject to AEDPA deference failed under de novo review because the petitioner could not show prejudice. The cumulative error claim was found to be procedurally defaulted. Accordingly, the Sixth Circuit affirmed the denial of the habeas petition in full. View "Sanders v. Plappert" on Justia Law

A sheriff’s deputy in Virginia arrested an individual for skateboarding on a public road and suspected public intoxication. During the arrest, the deputy punched the individual in the face multiple times, causing significant injuries, including facial fractures and a brain hemorrhage. The individual sued the deputy for excessive force under the Fourth Amendment and for common law battery. The deputy argued that the force he used was necessary because the individual resisted arrest and that, regardless, he was entitled to qualified immunity because he did not violate clearly established law.The United States District Court for the Western District of Virginia reviewed the case on the deputy’s motion for summary judgment. The district court examined the record, including body camera footage, and found that several key facts were disputed, such as whether the individual had surrendered and ceased resisting before the deputy continued to use force. The court held that if a jury found in favor of the individual on these disputed facts, it would be clearly established that the level of force used was excessive. Therefore, the district court denied the deputy’s motion for summary judgment, including his claim of qualified immunity.On appeal, the United States Court of Appeals for the Fourth Circuit addressed its jurisdiction to review the denial of qualified immunity at this interlocutory stage. The court explained that it could not review the district court’s factual determinations but could consider whether, taking the facts most favorably to the plaintiff, the deputy was entitled to qualified immunity as a matter of law. The Fourth Circuit held that, under the facts as viewed by the district court, prior precedent clearly established that the deputy’s actions would constitute excessive force. As a result, the appellate court affirmed the district court’s denial of qualified immunity. View "Barricks v. Wright" on Justia Law

A fifth-grade student, J.S., attended a local Oklahoma elementary school where, in August 2022, the administration implemented a policy segregating fifth-grade students into all-boys and all-girls homerooms. J.S. was placed in the boys’ class, taught by Mr. McClain. During the initial weeks, Mr. McClain allegedly targeted J.S. with severe discipline, derogatory language, and inappropriate sexual comments. After J.S. and his parents complained about this treatment and the sex-segregated policy, J.S. was removed from his classroom and placed on a modified schedule, then ultimately withdrawn from the school by his parents, who cited ongoing retaliation and lack of safety. The parents also filed a Title IX complaint, but alleged that the school’s investigation was inadequate and retaliatory actions followed, including public shaming and further mistreatment of J.S.The United States District Court for the Eastern District of Oklahoma granted in part and denied in part various defendants’ motions to dismiss, finding some claims barred by qualified immunity but allowing others to proceed. The court found that school district officials and Mr. McClain could not claim qualified immunity on certain equal protection and retaliation claims, but dismissed some due process and conspiracy claims.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s denial of qualified immunity. The Tenth Circuit held that school officials were entitled to qualified immunity on the procedural due process claim but not on the equal protection claim related to sex-based class segregation. Principal Anderson and Mr. Blair were properly denied qualified immunity on retaliation claims, while others were dismissed. Mr. McClain was granted qualified immunity on the substantive due process claim but not on the equal protection claim for alleged sexual harassment. The court affirmed in part, reversed in part, dismissed in part for lack of jurisdiction, and remanded for further proceedings. View "Stepp v. Lockhart" on Justia Law

The case concerns Brad Wendt, who owned two firearms stores in Iowa and also served as the Chief of Police for the small city of Adair. As police chief, Wendt had the authority to write official letters (“law letters”) that allowed his stores to acquire machine guns for the Adair Police Department or for demonstration purposes. Over several years, Wendt wrote numerous law letters to acquire ninety machine guns, some of which he resold for significant profit. Evidence showed that these acquisitions and demonstrations were not genuinely for police department use or potential future purchase but were instead for personal gain and to facilitate sales to other firearms dealers. Wendt also arranged for machine guns to be acquired and demonstrated by other dealers without legitimate department interest.After a jury trial in the United States District Court for the Southern District of Iowa, Wendt was convicted on multiple counts, including making false statements, conspiracy to make false statements and defraud the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), and illegal possession of a machine gun. The district court sentenced him to sixty months in prison, imposed a fine, and ordered the forfeiture of firearms. Wendt moved for acquittal or a new trial, but the district court denied these motions.On appeal to the United States Court of Appeals for the Eighth Circuit, Wendt challenged his convictions and sentence. The Eighth Circuit affirmed the convictions and sentence related to false statements and conspiracy, finding that the jury instructions fairly reflected the law and that there was no ambiguity requiring special instruction. However, the court found that the statute criminalizing possession of a machine gun was unconstitutionally vague as applied to Wendt in his role as police chief. The court reversed his conviction for illegal possession of a machine gun, remanded for vacatur of that conviction, but affirmed the remaining convictions and sentence. View "United States v. Wendt" on Justia Law

Parents and teachers in California challenged state policies that require schools to keep information about students’ gender transitioning confidential from parents unless the students consent. The parents objected to being excluded from knowledge and decisions regarding their children’s gender presentation at school, especially when those actions conflicted with their religious beliefs or their desire to participate in their children’s mental health care. Several parents described situations in which they were not informed about their children’s gender identity at school until after significant mental health crises occurred. Teachers objected to being compelled to use students’ preferred names and pronouns contrary to the wishes of parents and their own beliefs.The case was initiated in the United States District Court for the Southern District of California, where two teachers first challenged district policies. As litigation unfolded, the case expanded to include state officials as defendants and parents as additional plaintiffs. The District Court certified parent and teacher classes, granted summary judgment for the plaintiffs, and entered a permanent injunction that prohibited schools from withholding information from parents and required adherence to parental directions on names and pronouns. The District Court also ordered state-created instructional materials to include notice of the rights protected by the injunction.The United States Court of Appeals for the Ninth Circuit granted a stay of the injunction pending appeal, expressing procedural concerns about class certification under Federal Rule of Civil Procedure 23 and skepticism regarding the merits of the constitutional claims.The Supreme Court of the United States vacated the Ninth Circuit’s stay as to the parent plaintiffs, concluding that the parents seeking religious exemptions are likely to succeed on their Free Exercise and Due Process claims. The Court found the parents face irreparable harm and that equities favor them. The procedural objections raised by the Ninth Circuit were deemed unlikely to prevail. The application to vacate was otherwise denied. View "Mirabelli v. Bonta" on Justia Law

The case concerns an individual who, after discovering an intruder in his family’s former home, shot and killed the man. The house in question had not been occupied by any family member for roughly a decade, but the defendant continued to pay taxes and utilities and visited the property for maintenance. On the day of the incident, the defendant entered his old bedroom and encountered the victim, leading to a confrontation in which the defendant shot the victim, claiming self-defense. Forensic evidence was consistent with both the prosecution’s and the defense’s theories of how the shooting occurred.A DeKalb County grand jury initially indicted the defendant for malice murder, felony murder, aggravated assault, and possession of a firearm during the commission of a felony. After a 2019 jury acquitted him of malice murder but could not reach a verdict on the remaining counts, a partial mistrial was declared. Following reindictment, a second jury trial in 2022 resulted in convictions on the remaining counts. The trial court sentenced the defendant to life with parole for felony murder and an additional five years for the firearm offense, merging the aggravated assault conviction for sentencing. The trial court denied his motion for new trial, and the defendant appealed to the Supreme Court of Georgia.The Supreme Court of Georgia affirmed the convictions. It held that, while the trial court’s jury instructions on self-defense and defense of habitation were not optimally ordered, they correctly stated the law when read as a whole. The Court further found no ineffective assistance of counsel for failing to object to the prosecutor’s comments during closing argument and concluded that, although the court erred in charging the jury about the State’s burden as only a “prima facie” case, the error did not affect the outcome given the overwhelming evidence and proper instructions on the burden of proof elsewhere. View "MEDINA v. THE STATE" on Justia Law

A defendant was convicted by a jury in Dodge County, Georgia, in 1990 for the murder and armed robbery of a grocery store owner. The crime involved a violent stabbing, and after his arrest, the defendant confessed, stating that he committed the acts for money to buy drugs and because of a confrontation with the victim earlier that day. He was seventeen years old at the time, and the trial court sentenced him to death for murder and to life imprisonment for armed robbery.After his convictions were affirmed by the Supreme Court of Georgia on direct appeal, the defendant pursued habeas corpus relief in the Superior Court of Butts County, raising claims including ineffective assistance of counsel. His initial habeas petition was denied in 1997, and a subsequent application for appeal was also denied. The defendant later discovered that his trial counsel had simultaneously served as a Special Assistant Attorney General in unrelated Department of Transportation matters and filed a second habeas petition asserting a conflict of interest. The habeas court initially dismissed the petition as successive, but the Supreme Court of Georgia remanded for further consideration. The habeas court ultimately found the conflict-of-interest claim was not procedurally barred but denied relief on the merits, concluding the defendant had not shown that an actual conflict adversely affected counsel’s performance.The Supreme Court of Georgia reviewed the denial of the second habeas petition. It held that, even assuming a potential conflict existed, the defendant failed to demonstrate that his counsel’s dual roles caused an actual conflict that significantly and adversely affected his representation, as required by the standard set forth in Cuyler v. Sullivan. The court affirmed the habeas court’s judgment, finding no basis to presume prejudice or apply a more stringent standard. View "GIBSON v. HEAD" on Justia Law

A former participant in a Zen Buddhist center’s residential training programs asserted wage-and-hour claims against the center and two of its leaders, arguing he was owed various wages and penalties for work performed during his time in the center’s programs. The center operates multiple facilities, offers residential programs, and generates income from guest activities and commercial events. The plaintiff undertook tasks such as guesthouse cleaning, kitchen work, gardening, and guest cooking, receiving modest stipends and room and board. After leaving the center, he filed his claims, alleging unpaid minimum and overtime wages and other statutory violations.The Labor Commissioner held in favor of the plaintiff and found the center, as well as the two individual leaders, liable for significant amounts. The center and the individuals appealed to the Superior Court of California, County of San Francisco. The trial court denied the plaintiff’s motion to dismiss the individual appeals on the ground that only the center, not the individuals, was required to post an appeal bond. The trial court subsequently granted summary judgment for the defendants, holding that the “ministerial exception” of the First Amendment barred the plaintiff’s wage-and-hour claims due to the religious nature of the organization and the plaintiff’s role as a minister.On appeal, the California Court of Appeal, First Appellate District, Division Two, reversed the summary judgment. The court held that the ministerial exception does not categorically bar wage-and-hour claims by ministers against religious organizations in the absence of evidence that adjudicating the claims would require resolving ecclesiastical questions or interfere with religious autonomy. The court affirmed the trial court’s denial of the motion to dismiss the individual appeals, holding that only the employer (the center) was required to post the statutory undertaking, not the individual leaders. The judgment was thus reversed in part and affirmed in part. View "Ehrenkranz v. S.F. Zen Center" on Justia Law

Scott Williams was elected to serve on the Addison Community School Board for a six-year term and was chosen by his fellow board members to act as president for one year. During his presidency, Williams had a dispute with a staff member, leading to allegations that he harassed staff and improperly requested confidential information. Following an investigation and resolution drafted by board members, the Board voted to censure Williams and remove him from the presidency. Williams was not informed of the allegations against him before the meeting where his removal was voted upon.Williams filed suit in the United States District Court for the Eastern District of Michigan, alleging, among other claims, a violation of the Fair and Just Treatment clause of the Michigan Constitution and asserting that the school district was liable under respondeat superior. The district court granted summary judgment to the defendants on all claims, including the federal constitutional claims, and denied Williams’s motion for partial summary judgment on his Fair and Just Treatment claim. The district court chose to exercise supplemental jurisdiction over the state law claims after dismissing the federal claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the district court abused its discretion by retaining supplemental jurisdiction over Williams’s Fair and Just Treatment claim. The appellate court found that the state law claim presented a novel and complex issue under Michigan law, particularly because Michigan courts have not yet determined whether a private right of action exists under the Fair and Just Treatment clause. The court held that, given the dismissal of all federal claims and the complexity of the remaining state constitutional issue, the district court should have declined to exercise supplemental jurisdiction. As a result, the Sixth Circuit vacated the district court’s judgment on the Fair and Just Treatment claim and remanded with instructions to dismiss this claim without prejudice. View "Williams v. Addison Community Schools" on Justia Law