Justia Constitutional Law Opinion Summaries

Several teachers, students, parents, and their organizations challenged Oklahoma’s H.B. 1775, specifically subsection B, which restricts public school employees from making certain “discriminatory concepts” a required part of courses. These concepts include assertions about inherent superiority, moral character, responsibility, and psychological distress based on race or sex, among others. If violated, educators could face suspension or revocation of their teaching credentials. Plaintiffs argued that subsection B was unconstitutionally vague under the Fourteenth Amendment and violated students’ First Amendment right to receive information.The United States District Court for the Western District of Oklahoma reviewed the case. It granted judgment on the pleadings against the plaintiffs on their First Amendment claims, finding no protected right in curricular speech and no plausible right-to-receive-information claim. The court partially granted a preliminary injunction, finding that the use of “require” and two of the prohibited concepts (those using “treatment” and “treat”) were likely unconstitutionally vague, and enjoined enforcement of those parts. The court denied injunctive relief for the remaining language, and both parties appealed. The Oklahoma Supreme Court later declined to answer certified questions regarding the statute’s interpretation.The United States Court of Appeals for the Tenth Circuit reviewed the injunction. The court held that the District Court abused its discretion in finding vagueness in subsection B. It interpreted the statute as prohibiting teaching or requiring teaching of the listed discriminatory concepts as correct principles, not banning abstract discussion or instruction about related history or figures. The court determined that the statute’s language was sufficiently clear and not likely vague. It vacated the preliminary injunction, affirmed in part, reversed in part, and remanded for further proceedings. The court declined to address the First Amendment right-to-receive-information claims due to lack of appellate jurisdiction. View "Black Emergency Response Team v. Drummond" on Justia Law

Kevin Lackey was convicted in 1993 by a Michigan jury of criminal sexual conduct and breaking and entering after he was accused of sexually assaulting an eleven-year-old girl in her home. The incident involved an assailant who allegedly entered through a window, abducted the victim from her bedroom, and assaulted her on the back porch before fleeing. Police quickly responded, gathered statements, and relied on a police dog that tracked from the crime scene to Lackey’s nearby residence. Lackey matched the physical description given by the victim and her mother. After serving 22 years in prison, his convictions were vacated due to significant issues with the dog-tracking evidence, and the prosecutor chose not to retry the case.Following the vacatur of his convictions, Lackey filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan. He alleged that several investigating officers fabricated evidence, maliciously prosecuted him, and suppressed exculpatory material, thereby violating his constitutional rights. The district court granted summary judgment in favor of the officers, finding them entitled to qualified immunity, and Lackey settled his remaining claims against another defendant before final judgment was entered.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that Lackey failed to show the officers violated clearly established constitutional rights. The court found no genuine dispute as to material fact that would defeat qualified immunity on claims of fabrication of evidence, malicious prosecution, or suppression of exculpatory evidence. Specifically, the court concluded there was probable cause supporting Lackey’s arrest and prosecution, and no evidence that the officers withheld material information or fabricated evidence in a way that affected the outcome of the trial. The judgment in favor of the officers was therefore affirmed. View "Lackey v. Hurley" on Justia Law

Police officers in Miami-Dade surveilled a house known for prior drug activity and a recent drive-by shooting. They observed Olson Joseph getting a haircut on the front lawn and later noticed he was carrying a concealed handgun in his sweatshirt pocket. The officers detained Joseph at gunpoint, removed the firearm, and conducted records checks, revealing Joseph was a felon without a concealed-carry permit. About twenty minutes after the stop, Joseph was transported to the station. He was subsequently charged in federal court with possession of a firearm and ammunition by a felon in violation of 18 U.S.C. § 922(g)(1).The United States District Court for the Southern District of Florida denied Joseph’s motion to dismiss the indictment, rejecting his argument that § 922(g)(1) violated the Second Amendment. The court also denied his motion to suppress the gun, finding the encounter was a Terry stop and that the officers had reasonable suspicion based on Joseph’s gun possession, his presence in a high-crime area, and proximity to a house associated with a recent homicide and drug activity. Joseph entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that, under circuit precedent, § 922(g)(1) does not violate the Second Amendment and affirmed denial of the motion to dismiss. However, the court found that the officers lacked reasonable suspicion for the stop, since Florida’s 2015 concealed-carry statute amendment made carrying a concealed weapon presumptively lawful, and Joseph’s conduct did not indicate criminal activity. The court vacated Joseph’s conviction, reversed the partial denial of the suppression motion, and remanded for further proceedings. View "USA v. Olson" on Justia Law

Twin brothers, both Black international students, were enrolled as doctoral candidates at the University of Mississippi’s Department of Pharmacy Administration. One brother, Bennard, disagreed with changes to his faculty mentorship arrangement, objected to mandatory in-person meetings, and declined to complete a required program assessment called the Abilities Transcript. After being repeatedly warned and given extensions, he was placed on provisional status for failing to complete the requirement, which also caused the loss of his graduate assistantship. Bennard and his brother each filed lawsuits against the University and several faculty members, alleging constitutional, statutory, and contract violations related to academic sanctions and alleged discriminatory treatment.The United States District Court for the Northern District of Mississippi consolidated the brothers’ cases. It dismissed Bennard’s claims against the University on sovereign-immunity grounds, dismissed his remaining federal claims under Rule 12(b)(6) for failure to state a claim, and declined to exercise supplemental jurisdiction over his individual-capacity state contract claims. Bennard appealed, while his brother’s appeal was dismissed for failure to prosecute.The United States Court of Appeals for the Fifth Circuit reviewed Bennard’s remaining claims. The court held that sovereign immunity barred claims against the University, claims against one defendant in her official capacity, and official-capacity state-law contract claims; those dismissals must be without prejudice. The court further found that Bennard failed to plausibly allege First or Fourteenth Amendment violations, and that the faculty defendants were entitled to qualified immunity on individual-capacity claims. The court affirmed the district court’s refusal to exercise supplemental jurisdiction over the remaining contract claims and upheld consolidation of the cases and dismissal of moot preliminary injunction motions. The judgment was affirmed as modified to clarify the proper form of dismissal for sovereign-immunity-barred claims. View "Eriakha v. University of MS" on Justia Law

Rodney Brown was charged with Hobbs Act robbery and brandishing a firearm during a crime of violence after he robbed a convenience store, threatening a cashier and her son, and stealing money and personal items. The robber left a soda bottle at the scene, which, along with a mask found nearby, was tested for DNA. Law enforcement obtained Brown’s DNA and had it analyzed by a private lab. At trial, a DNA analyst from the lab testified that Brown’s DNA matched the evidence, but the analyst had not personally performed the hands-on lab work generating the DNA profiles.In the United States District Court for the Southern District of Florida, a jury found Brown guilty on both counts. At sentencing, the court classified Brown as a career offender under the United States Sentencing Guidelines, using the 2023 version of the Guidelines, which treated Hobbs Act robbery as a crime of violence. This resulted in an increased sentencing range, and Brown was sentenced to 324 months in prison.On appeal to the United States Court of Appeals for the Eleventh Circuit, Brown argued for the first time that his Confrontation Clause rights were violated by the DNA analyst’s testimony, and that the Ex Post Facto Clause was violated when the district court used a later version of the Guidelines Manual. The Eleventh Circuit held that the district court did not plainly err in permitting the DNA analyst’s testimony, since the analyst independently reviewed and analyzed the DNA profiles and did not merely act as a surrogate for other lab personnel. However, the court found plain error in sentencing Brown under the 2023 Guidelines Manual, as the offense occurred before the relevant amendment. The court affirmed Brown’s convictions, vacated his sentence, and remanded for resentencing under the correct Guidelines version. View "USA v. Brown" on Justia Law

Several residents and a public interest foundation sought to block a county’s implementation of an ordinance that authorized the issuance of $25 million in general revenue bonds. The bonds were intended to fund the final phase of a sewer and wastewater treatment project serving only the southernmost part of the county. The ordinance provided for an annual ad valorem tax on all taxable property in the county to support repayment. The plaintiffs argued the ordinance violated the state constitution by levying a county-wide tax for a benefit limited to a specific geographic area.The Oconee County Circuit Court considered the county’s motion to dismiss, which argued that the plaintiffs lacked standing, that the action was untimely, and that the ordinance was constitutional. The circuit court rejected the county’s arguments on standing and timeliness but granted the motion to dismiss by concluding the ordinance was constitutional. The plaintiffs appealed, and the county cross-appealed, asserting the action should be barred as untimely.The Supreme Court of South Carolina reviewed the case. It held that the plaintiffs’ action was barred by the twenty-day statute of limitations in South Carolina Code section 11-15-30, which requires any action challenging the issuance of bonds to be filed within twenty days of filing the official record of bond proceedings. The Court determined the plaintiffs’ challenge was “on account of” the bond issuance, as the ordinance authorizing the bonds and their use were inseparable. Because the plaintiffs filed their action more than four months after the required record was filed with the clerk of court, the Supreme Court held the action was untimely. The judgment of the circuit court was affirmed as modified, with the Supreme Court declining to address other issues, including standing and constitutionality. View "SC Public Interest Foundation v. Oconee County" on Justia Law

The defendant was convicted of malice murder and robbery following the death of a woman with whom he had a deteriorating relationship. Evidence at trial showed that he had threatened her life in the days leading up to the incident, and witnesses testified to his hostile intent. On the day of the crime, the victim left a friend’s house to check her mail and did not return. The defendant’s brother testified that the defendant went to their shared apartment with the intention of confronting the victim, gagged and bound her, and transported her in her vehicle. Physical evidence at the scene, including matching boot prints and DNA, corroborated the brother’s account. The defendant’s girlfriend and other witnesses provided additional evidence regarding his whereabouts. The victim’s body and belongings were found along a highway, and the medical examiner confirmed death by blunt force trauma. The defendant testified in his own defense, providing an alternate account of his movements.The Superior Court of Burke County presided over the trial, during which a jury found the defendant guilty of both charges. After sentencing, the defendant filed several post-trial motions, including motions for new trial. There was an extended delay in post-conviction proceedings, with issues regarding missing transcripts and unavailable evidence. Ultimately, the trial court denied the defendant’s motions for new trial, finding no prejudice from the delay and rejecting claims of ineffective assistance of counsel.The Supreme Court of Georgia reviewed the case on appeal. The court held that the evidence was sufficient to support both convictions under constitutional and statutory standards. The court further held that the defendant’s claims of ineffective assistance of counsel failed because there was no objectively unreasonable performance or resulting prejudice. The court also found no due process violation from the prosecution’s conduct or from the post-conviction delay, as no actual prejudice was demonstrated. The judgment was affirmed. View "JOHNSON v. THE STATE" on Justia Law

The case concerns Deonte Kitchens, who was convicted of malice murder, multiple violations of Georgia’s Street Gang Terrorism and Prevention Act, and related offenses after the shooting death of Alveno Culver. The evidence at trial established that Kitchens, along with associates, approached Culver—who was not affiliated with any gang—while Culver was in his car at a large street gathering in Macon. Witnesses testified that Kitchens shot Culver after suspecting him of involvement in an earlier incident targeting a drug house tied to Kitchens’s gang activities. Additional evidence linked Kitchens to the “Get Dat Money” gang, including text messages, drawings, and expert testimony, and indicated the shooting was an act of gang retaliation.Following conviction in the Superior Court of Bibb County, Kitchens moved for a new trial, arguing, among other points, that his constitutional right to a speedy trial had been violated. In an earlier appeal, the Supreme Court of Georgia found the trial court had made factual errors and legal misapplications regarding the speedy trial claim, vacated part of its order, and remanded for proper analysis. On remand, the trial court again denied relief after applying the correct legal framework. Kitchens appealed again, reasserting the speedy trial claim, contesting the sufficiency of the gang-related evidence, and raising claims about undisclosed witness statements and ineffective assistance of counsel.The Supreme Court of Georgia reviewed the trial court’s handling of the speedy trial claim under the deferential abuse-of-discretion standard and concluded that the lower court did not err in denying the claim. The court also found the evidence sufficient to support the gang convictions, held that the State was not required to disclose unrecorded oral statements, and determined Kitchens had not shown constitutionally deficient performance by his trial counsel. Accordingly, the Supreme Court of Georgia affirmed the judgment. View "KITCHENS v. THE STATE" on Justia Law

In early 2021, a night shift manager at a motel in Clayton County was found dead in one of the motel rooms, which was accessible only to staff and construction crew due to ongoing renovations. Witnesses described an agitated man with dreadlocks on the premises, who was later identified as the appellant. Surveillance footage and witness testimony placed this individual at the scene, interacting with the victim shortly before the body was discovered. Forensic evidence linked the appellant to the crime through DNA found on clothing and shoes, and the medical examiner concluded the cause of death was ligature strangulation, with blunt force trauma as a contributing factor. After being apprehended near the crime scene, the appellant gave conflicting accounts to police, admitting to an altercation but denying the killing.A Clayton County grand jury indicted the appellant on multiple charges, including malice murder and felony murder. Before trial, some counts were dismissed. A jury in the Superior Court of Clayton County found the appellant guilty on all remaining charges, and he was sentenced to life imprisonment without parole. The appellant filed a motion for a new trial, which the trial court denied after briefing and a hearing.The Supreme Court of Georgia reviewed the case. The appellant argued several errors: improper admission of hearsay evidence, failure to instruct the jury on “grave suspicion,” omission of a charge requiring corroboration of out-of-court statements, failure to instruct on voluntariness factors for custodial statements, and improper admission of a surveillance video without proper foundation. The Court found no abuse of discretion or plain error. It held that the officer’s testimony about the surveillance footage was not hearsay, the jury instructions were sufficient, and any error in admitting the surveillance video was harmless given cumulative evidence. The Court affirmed the convictions and sentence. View "GREEN v. THE STATE" on Justia Law

The case involved a defendant who was convicted by a jury of attempt to commit murder, assault in the first degree, and violation of a protective order following a violent altercation with his girlfriend. After the jury returned a guilty verdict and orally confirmed unanimity in open court, the judge discharged the jurors from their oath and asked them to return to the jury room. There, during an off-the-record conversation, one juror expressed feeling "a little guilty about the attempted murder charge," but did not elaborate and was not questioned further at that time.Two days after the verdict, the trial judge disclosed the juror's remark to counsel and held a hearing to question the juror. The juror confirmed that she had unequivocally agreed with the verdict during the court proceedings. Defense counsel neither requested a poll of the jury nor raised concerns about jury unanimity during that hearing. On appeal, the Connecticut Appellate Court affirmed the defendant’s conviction, concluding that the juror’s remark did not indicate a lack of unanimity and that the defendant’s right to poll the jury had not been violated, as no timely request for polling had been made and the jury had already been discharged.The Supreme Court of Connecticut reviewed the case. It held that the jury had indeed been discharged before the juror’s remark was made, as the jurors had been released from their oath and exposed to possible outside influences, including communication from the judge. As a result, no poll could have been conducted under the applicable rules, even if the remark had been disclosed immediately. The court further held that the juror’s expression of feeling "a little guilty" did not amount to evidence of a nonunanimous verdict or constitutional violation. The Supreme Court of Connecticut affirmed the judgment of the Appellate Court. View "State v. Angel A." on Justia Law