Justia Constitutional Law Opinion Summaries

Police responded to a house fire in Grand Forks, North Dakota, where an officer observed Antonio Medina behaving evasively and distancing himself from law enforcement. Medina left the scene in his red Ford Explorer and later returned on foot. Officers located Medina’s unattended, unlocked vehicle in a commercial parking lot nearby. Through the window, they observed keys, a cut straw with white residue, and a box for a digital scale. Officers conducted a warrantless search of the vehicle, seizing the straw, an electronic scale with residue, and small baggies. The residue tested positive for cocaine.Medina was charged with possession of a controlled substance and possession of drug paraphernalia, both class A misdemeanors. He moved to suppress the evidence, arguing the search was unconstitutional. The Northeast Central Judicial District Court denied the motion, ruling the automobile exception to the Fourth Amendment’s warrant requirement applied because there was probable cause to believe the vehicle contained evidence of a crime. Medina entered a conditional guilty plea, reserving his right to appeal the denial of his suppression motion. The North Dakota Supreme Court previously remanded the case for correction of the criminal judgment to specify that the plea was conditional, as required by state procedural rules. After the district court entered an amended judgment, Medina appealed again.The Supreme Court of the State of North Dakota reviewed whether the warrantless search was justified under the automobile exception. The court held the exception applied because the vehicle, though parked and unoccupied, was readily mobile and located in a public commercial lot. The court found probable cause based on Medina’s suspicious behavior and the drug-related items visible inside the vehicle. The court concluded that the search was valid under the automobile exception and affirmed the amended judgment. View "State v. Medina" on Justia Law

The petitioner, a citizen of Sierra Leone and lawful permanent resident, was convicted in the District of Columbia in 2014 of attempted first-degree sexual abuse and kidnapping. The factual basis for his conviction included both forceful digital penetration and forceful penile penetration. After serving his prison sentence, the Department of Homeland Security initiated removal proceedings, alleging that his conviction qualified as an aggravated felony under the Immigration and Nationality Act, specifically as “rape” or “an attempt to commit an aggravated felony,” and also as a crime of violence.In removal proceedings before the Immigration Judge, the petitioner admitted the factual allegations but disputed that his conviction was an aggravated felony, arguing that the D.C. statute criminalized digital penetration, which he claimed was not covered by the generic federal definition of rape. The Immigration Judge ordered removal, finding the conviction constituted attempted rape. The Board of Immigration Appeals affirmed, relying on its precedent that the generic definition of rape included digital penetration, and dismissed other removability grounds as unnecessary. The Board also denied the petitioner’s requests for a waiver of inadmissibility, but remanded for further consideration of his claim under the Convention Against Torture, directing the Immigration Judge to consider aggregate risks of torture. After additional hearings, the Immigration Judge again denied relief, and the Board affirmed, declining to revisit removability.The United States Court of Appeals for the Eleventh Circuit reviewed only the Board’s removability determination. It held that the generic federal definition of “rape” under 8 U.S.C. § 1101(a)(43)(A) does not include digital penetration, joining other circuits. Consequently, the Board erred in concluding the petitioner’s conviction categorically matched the federal definition of rape. The court vacated the Board’s decision and remanded for further proceedings on other removability grounds. View "Barrie v. Attorney General" on Justia Law

The case concerns a defendant who was convicted of multiple serious offenses, including two counts of first-degree murder, following a shooting in Rochester, New York, that resulted in two deaths and one victim being paralyzed. The investigation linked the defendant to the crime through eyewitness identifications and forensic evidence, such as shell casings and fingerprints on a handgun magazine. After the incident, police located and arrested the defendant at an apartment where he had stayed overnight. A subsequent search of the apartment, conducted with the tenant’s consent, yielded a 9-millimeter handgun hidden in a toilet tank, which was later used as evidence against the defendant.After his conviction in Monroe County, the defendant moved to suppress the handgun, arguing that his arrest was unconstitutional under Payton v. New York because police coerced him to exit the apartment without a warrant, and that the tenant’s consent to search was not voluntary or sufficiently attenuated from the unlawful arrest. The Supreme Court denied suppression, finding no Payton violation, concluding the defendant lacked standing, and determining the consent was voluntary. The Appellate Division, Fourth Department, found a Payton violation due to the coercive nature of the arrest but held that suppression was not warranted because the tenant’s consent was voluntary and attenuated from the illegality.The New York Court of Appeals reviewed the case and affirmed the Appellate Division’s conclusion that there was a Payton violation, based on overwhelming police force and coercion. The Court clarified that both the Fourth Amendment and New York Constitution prohibit such constructive entries. However, it found that the Appellate Division applied the wrong legal standard to assess voluntariness of the tenant’s consent, confusing voluntariness with attenuation. The Court of Appeals remitted the case for the Appellate Division to apply the correct standard regarding the handgun as to count nine, while holding any error was harmless on the remaining counts. The order was thus modified and otherwise affirmed. View "People v Shaw" on Justia Law

On a December morning in 2008, a house fire in Green Cove Springs, Florida, led to the discovery of Maria Ruiz’s burned and bloodied body. The home had recently been occupied by Leo Louis Kaczmar III, his family members, and Ruiz. Investigators found gasoline was used to start the fire. Kaczmar arrived at the scene, presenting a gas receipt and claiming he had been fishing, but admitted being alone with Ruiz in the hours before the fire. Post-indictment, Kaczmar discussed his case with fellow inmate William Filancia, who later worked with law enforcement. Undercover Detective Humphrey posed as "Carlos" to elicit incriminating statements from Kaczmar.At trial in the Circuit Court, the State presented extensive evidence, including witness testimony, video showing Kaczmar purchasing gasoline before the fire, and DNA evidence linking Ruiz’s blood to Kaczmar’s sock. Kaczmar’s defense called one witness regarding his truck’s search. The jury convicted Kaczmar of murder, arson, and attempted sexual battery, recommending death. The Florida Supreme Court affirmed the conviction but reversed the death sentence due to insufficient proof on aggravating factors, remanding for a new penalty phase. At resentencing, the jury unanimously recommended death, and the court imposed it. This was affirmed on appeal, with a rehearing denied.Kaczmar then sought postconviction relief in the circuit court, alleging ineffective counsel and various due process violations. The circuit court vacated his death sentence based on counsel’s failure to object to the judge’s mention of a prior death sentence, but denied all other claims. On appeal, the Supreme Court of Florida reversed the grant of penalty-phase relief, finding no prejudice from the judge’s statement, and affirmed denial of all other claims. Kaczmar’s habeas petition was also denied. The Court ordered reinstatement of his death sentence. View "State of Florida v. Kaczmar" on Justia Law

In July 2011, Roschell Lamb reported to police that she had been raped by a stranger who dragged her into a shed and assaulted her. The police investigation initially yielded no suspects, and the case went dormant until 2018, when Roy Nichols was identified as a suspect through DNA evidence. After locating Lamb in 2023, the State charged Nichols with rape. Nichols claims the encounter was consensual and seeks to introduce evidence that he and Lamb had a prior sexual relationship, specifically alleging they had sex weeks before the incident.The Craighead County Circuit Court held an in camera hearing regarding Nichols’s motion to introduce evidence of the alleged prior sexual encounter. Nichols testified about the supposed prior relationship, and his mother and sister claimed Lamb had visited their home looking for Nichols around the time of the alleged rape. The circuit court found Nichols’s testimony about prior consensual sexual conduct probative of consent and allowed him to testify about it and cross-examine Lamb on the topic, but excluded testimony from Nichols’s mother and sister. The State appealed this evidentiary ruling.The Supreme Court of Arkansas reviewed the circuit court’s decision for abuse of discretion. It concluded the circuit court erred because Nichols’s claim was uncorroborated, only marginally probative, and highly prejudicial. The Court held that Arkansas’s rape-shield statute generally prohibits introduction of evidence of prior sexual conduct unless it is acutely probative and corroborated. The Court also found that Nichols’s Confrontation Clause argument was unavailing, as he could challenge Lamb’s credibility through other means. The Supreme Court of Arkansas reversed the circuit court’s ruling and remanded the case for proceedings consistent with its opinion. View "STATE OF ARKANSAS v. NICHOLS" on Justia Law

A man was convicted of sex trafficking a minor after police located the missing child in an apartment where he was staying. The police had responded to a missing persons report filed by the minor’s father, who believed the child was endangered. Investigators traced the minor’s Snapchat activity to an IP address at the apartment and, after gaining access from a tenant in the building, entered the unlocked apartment briefly to ask about the missing child. During this encounter, the defendant emerged from a bedroom. Subsequent evidence, including text messages from a phone recovered from the minor, supported the prosecution’s case.The United States District Court for the District of Massachusetts denied the defendant’s motion to suppress evidence related to the police entry and admitted several text messages and emails as evidence. During jury selection, the court temporarily sealed the courtroom while questioning potential jurors about sensitive matters, with defense counsel expressly stating there was no objection. At the close of trial, the court mistakenly allowed alternate jurors into the deliberation room but promptly removed them and instructed the jury to disregard any statements by the alternates and restart deliberations if needed. The defendant was convicted by a jury and sentenced to 180 months’ imprisonment plus supervised release.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the police entry was justified under the emergency-aid exception, the temporary courtroom sealing did not violate the public trial right due to waiver, and the evidentiary rulings were not an abuse of discretion. The court also found no reversible error in the alternate juror incident, as there was no showing of prejudice. The First Circuit affirmed the district court’s judgment. View "United States v. Rowell" on Justia Law

Three individuals living with well-managed HIV, whose infections are controlled by daily medication and who have undetectable viral loads, sought to join or rejoin the U.S. Army. They were denied enlistment based on Department of Defense and Army policies that list HIV infection as a disqualifying medical condition, alongside numerous other chronic or communicable diseases. A nonprofit organization, Minority Veterans of America, also supported their challenge. The plaintiffs argued that these policies violate their equal protection rights under the Fifth Amendment and are arbitrary and capricious in violation of the Administrative Procedure Act.The United States District Court for the Eastern District of Virginia granted summary judgment to the plaintiffs. The court issued a permanent injunction barring the Military from denying accession to asymptomatic HIV-positive individuals with undetectable viral loads, prohibiting enforcement of HIV-specific policy provisions, and ordering reevaluation of prior decisions made under these policies. The district court concluded that the Military’s justifications—based on medical, cost, and diplomatic concerns—were irrational, arbitrary, and capricious.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the judgment. Applying rational basis review with heightened deference to military judgments, the Fourth Circuit found that the Military’s policies were rationally related to legitimate military purposes, including maintaining deployable, medically fit servicemembers, minimizing complications from chronic conditions, controlling costs, and addressing diplomatic issues with foreign host nations. The court distinguished this case from Roe v. Department of Defense, which concerned policies for current servicemembers rather than initial entry. The Fourth Circuit held that the Military’s HIV accession policy did not violate the Fifth Amendment or the APA and reversed the district court’s judgment, remanding with instructions to enter judgment for the Military. View "Wilkins v. Hegseth" on Justia Law

During a lawful traffic stop in Philadelphia, police officers observed a vehicle with a malfunctioning brake light. Upon contacting the driver, Devaghn Hawkins-Davenport, the officers requested that he lower his tinted windows, making the interior visible. One officer saw a firearm lying in plain view on the front passenger seat. The officer quickly seized the firearm for safety and asked Hawkins-Davenport whether he had a license to carry it; Hawkins-Davenport responded that he did not. He was then arrested and charged with offenses related to carrying firearms without a license.Hawkins-Davenport filed a pre-trial motion to suppress the firearm and statements made during the stop, arguing that the stop and subsequent search violated his constitutional rights. The Philadelphia County Court of Common Pleas held a suppression hearing and granted the motion, finding no evidence of danger to the officers beyond the presence of the firearm and noting Hawkins-Davenport’s cooperation during the stop. The suppression court concluded there was no reasonable suspicion or probable cause justifying the seizure of the firearm or the statements.The Commonwealth appealed, and the Superior Court of Pennsylvania reversed the suppression order. The Superior Court determined that officer safety during traffic stops justified the precautionary removal of a firearm seen in plain view and accessible to the driver, regardless of licensure status or other indicia of danger. The court found this was a minimal intrusion necessary for officer safety and permitted under established precedent.On further appeal, the Supreme Court of Pennsylvania affirmed the Superior Court’s order. The Court held that during a lawful traffic stop, an officer who observes a firearm in plain view and within reach of the driver may seize the weapon as a reasonable safety precaution before ascertaining licensure status. The disposition affirmed the reversal of the suppression order. View "Commonwealth v. Hawkins-Davenport" on Justia Law

The case concerns Melvin Trotter, who was convicted of the 1986 first-degree murder of Virgie Langford, a 70-year-old store owner. Trotter stabbed and robbed Langford, resulting in her death several hours after emergency surgery. Following a jury’s recommendation, Trotter was sentenced to death; this sentence was initially reversed, but after a new penalty phase, the trial court again imposed the death penalty, finding multiple aggravating factors and both statutory and nonstatutory mitigation. Trotter’s conviction and sentence became final in 1997, and he has unsuccessfully challenged his death sentence in various state and federal courts since then.After the Governor signed his death warrant in January 2026, Trotter filed a successive motion for postconviction relief and a motion for stay of execution in the Circuit Court for Manatee County. He raised two claims: first, that alleged failures by the Florida Department of Corrections to follow lethal injection procedures violated his constitutional rights, and second, that executing him at age 65 constituted cruel and unusual punishment due to his advanced age. The circuit court summarily denied both claims and denied the stay of execution.On appeal, the Supreme Court of Florida reviewed the circuit court’s summary denial de novo. The Court held that Trotter’s claims regarding lethal injection procedures were speculative and failed to demonstrate a substantial and imminent risk of serious harm, nor did he identify an alternative method of execution as required by precedent. The Court also rejected Trotter’s argument for a categorical exemption from execution based on age, reaffirming prior holdings that only those under 18 at the time of the crime are exempt. The Supreme Court of Florida affirmed the circuit court’s denial of postconviction relief, denied Trotter’s habeas petition as procedurally barred and lacking merit, and declined to stay the execution. View "Trotter v. State" on Justia Law

The defendant, a native and citizen of Jamaica, repeatedly entered the United States unlawfully after being removed several times due to criminal convictions, including firearms and drug offenses. In May 2023, he was apprehended at the Ambassador Bridge in Detroit and charged with unauthorized reentry following his removal subsequent to conviction for an aggravated felony, violating 8 U.S.C. § 1326. This constituted his eleventh felony conviction and fifth felony immigration conviction under § 1326.After being indicted in the United States District Court for the Eastern District of Michigan, the defendant moved to dismiss the charge, arguing that § 1326 violates the Fifth Amendment’s equal protection guarantee by discriminating against Mexican and other Latino immigrants. The district court rejected his motion, finding that he failed to link the legislative history and intent of the 1929 Act and its predecessors to the 1952 Immigration and Nationality Act, which codified § 1326. The court also determined that he did not provide evidence of disparate impact or invidious discriminatory purpose regarding § 1326’s enforcement, and adopted the analysis from United States v. Carrillo-Lopez, 68 F.4th 1133 (9th Cir. 2023). The district court sentenced him to 51 months’ imprisonment and he timely appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s refusal to dismiss the indictment de novo and its factual findings for clear error. The appellate court held that the defendant failed to establish discriminatory intent or disparate impact under the Arlington Heights framework. The court emphasized that the legislative history of the 1929 Act is not controlling for § 1326, and Congress is not required to purge previous discriminatory intent when enacting new legislation. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Myrie" on Justia Law