Justia Constitutional Law Opinion Summaries

A former elected county prosecutor in Kentucky’s 21st Judicial Circuit was charged with Honest Services Wire Fraud, violations of the Travel Act, and Federal Program Bribery. The charges stemmed from an arrangement with a young woman, M.H., who repeatedly faced legal troubles. Evidence showed that the prosecutor agreed to help her with matters such as getting warrants withdrawn, charges reduced, and release from jail, in exchange for sexual acts and explicit images. The FBI discovered the scheme, leading to federal prosecution. At trial, the government presented incriminating text messages, testimony from M.H., and law enforcement, while the defendant claimed he did not solicit images and that M.H. was assisting in investigations—a claim disproved by evidence.The United States District Court for the Eastern District of Kentucky oversaw the jury trial, which resulted in convictions on all counts. The court sentenced the defendant to 41 months in prison and imposed supervised release conditions, including refraining from excessive alcohol use. On appeal to the United States Court of Appeals for the Sixth Circuit, the defendant challenged the exclusion of certain testimony about Kentucky law, sufficiency of the evidence on several elements, the federal funding nexus for the bribery charge, the supervised release condition, and the sentencing court’s refusal to consider “collateral consequences.”The Sixth Circuit held that the district court did not abuse its discretion or violate constitutional rights in excluding expert legal opinion testimony and that the jury was properly instructed on the meaning of “official acts.” The court found overwhelming evidence supporting the verdict, including proof of a quid pro quo and an interstate nexus. The federal funding requirement was satisfied by evidence that the state received sufficient funds. The supervised release condition and sentencing decisions were not plainly erroneous. The Sixth Circuit affirmed the district court’s judgment in all respects. View "United States v. Goldy" on Justia Law

Jason Florence, while on supervised release for a prior federal child pornography conviction, was found in possession of a smartphone containing child pornography during an unscheduled home visit by his probation officer. The conditions of his supervised release prohibited him from possessing such devices without his probation officer's knowledge. A forensic analysis of the confiscated phone revealed over one hundred images and two videos of child pornography, some accessed shortly before the search. Florence admitted ownership of the phone and provided its passcode, and other evidence linked him to the device and the illicit materials.This case was tried before the United States District Court for the Western District of Kentucky. The parties stipulated to Florence’s prior convictions and the terms of his supervised release. After a two-day trial, a jury convicted Florence of possessing child pornography and found that the material depicted minors under 12 years old. At sentencing, the district court determined that Florence’s prior conviction triggered a statutory mandatory minimum sentence of ten years’ imprisonment under 18 U.S.C. § 2252A(b)(2), and imposed a life term of supervised release. Florence objected, arguing that Fifth and Sixth Amendment rights required the jury to find the fact of his prior conviction, and he challenged the admission of his probation officer’s credibility testimony and the reasonableness of his sentence.On appeal, the United States Court of Appeals for the Sixth Circuit held that the district court did not err in finding the fact of Florence’s prior conviction and applying the mandatory minimum, citing the narrow exception in Almendarez-Torres v. United States, which allows a judge to find the fact of a prior conviction. The court found any error in admitting the probation officer’s credibility testimony harmless, given the overwhelming evidence of guilt. Finally, the Sixth Circuit held that the life term of supervised release was both procedurally and substantively reasonable. The judgment of the district court was affirmed. View "United States v. Florence" on Justia Law

Ryan Mendoza checked into a Pittsburgh hotel for a two-night stay, receiving a receipt indicating his departure date as February 25. The hotel had a posted noon checkout time, and guests could leave either by visiting the front desk or simply walking out. By noon on February 25, Mendoza had not checked out at the front desk, so hotel staff placed him on a “due-out” list and inspected his room. Later that afternoon, the hotel manager discovered a backpack with packages of white powder and called the police. Around 5:20 p.m., officers entered the room without a warrant and confirmed with the manager that Mendoza’s stay had ended and he no longer had rights to the room. Mendoza returned to the hotel at 10:00 p.m. and was arrested.In the United States District Court for the Western District of Pennsylvania, Mendoza moved to suppress the evidence obtained during the warrantless search of the hotel room, arguing that he retained a Fourth Amendment privacy interest in the room because he had not formally checked out. The District Court denied the motion, finding that Mendoza did not have a reasonable expectation of privacy in the room after checkout time, based on hotel policies and practices.The United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and exercised plenary review over its legal determinations. The Third Circuit held that Mendoza’s expectation of privacy in the hotel room five hours after checkout time was not objectively reasonable. The court emphasized that, absent any communication about a late checkout or ambiguous circumstances, society does not recognize an expectation of privacy in a hotel room well after checkout time. Accordingly, the Third Circuit affirmed the District Court’s denial of the motion to suppress. View "USA v. Mendoza" on Justia Law

Early in the morning, a security guard at a hotel in Oklahoma City called 911 to report an unauthorized individual, Dawawn McCoy, refusing to leave a guest’s room and appearing unable to walk. Sergeant Cassidy of the Oklahoma City Police Department responded, found McCoy noncompliant and apparently under the influence, and requested medical evaluation. After medical personnel determined McCoy did not need immediate attention and he refused care, police were instructed to arrest him for trespassing. Cassidy called for additional officers, and together the officers attempted to handcuff McCoy, who resisted physically by pulling his hands in and kicking. The officers used pepper spray and a taser to subdue him. Once handcuffed, McCoy was rolled onto his stomach and restrained further. For approximately ninety seconds, according to the district court’s findings, McCoy had stopped resisting but officers continued to apply force by holding a knee on his back and pressing his legs upward. McCoy stopped responding verbally and showed signs of medical distress. Officers later attempted resuscitation and administered Narcan, but McCoy died six days later in the hospital.In the United States District Court for the Western District of Oklahoma, LaQuita Bruner, as administrator of McCoy’s estate, brought suit against the officers under 42 U.S.C. § 1983 for excessive force and deliberate indifference to medical needs. The district court granted summary judgment for the officers on the deliberate indifference claim but denied it as to the excessive force claim, finding that a reasonable jury could conclude excessive force was used after McCoy was subdued.On interlocutory appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of qualified immunity on the excessive force claim. The court held that, based on the facts found by the district court, the officers’ continued use of force after McCoy was subdued was objectively unreasonable and violated clearly established Fourth Amendment law. The case was remanded for further proceedings. View "Bruner v. Cassidy" on Justia Law

The defendant pleaded guilty to one count of sexual misconduct, a conviction that triggers registration requirements under the Sex Offender Registration Act (SORA). At the time of his plea, he was not notified of these obligations, and neither the Board of Examiners of Sex Offenders nor the sentencing court took the steps required by statute to initiate SORA registration. Approximately five years passed before the Board became aware of his conviction. During this period, the defendant remained unregistered and worked at a facility for juveniles. Once the oversight was discovered, a full SORA proceeding was conducted, resulting in his classification as a level one sex offender, which carries the least restrictive requirements and a twenty-year registration period ordered nunc pro tunc from the date of his release.After the SORA hearing, the defendant moved to dismiss the proceedings, arguing that the delay violated his substantive due process rights, and alternatively sought to be designated an unclassified offender. The Supreme Court denied these requests but reduced his risk level from two to one after declining to assess points for release without supervision based on his conduct during the delay. The Appellate Division affirmed, noting that the delay did not prejudice the defendant and, in fact, benefited him by lowering his risk level.The New York Court of Appeals reviewed the case and held that a defendant must demonstrate prejudice to his ability to present his case at the SORA hearing to establish a substantive due process violation for delayed proceedings. Because the defendant did not suffer prejudice—instead, he received a less onerous classification due to the delay—the Court of Appeals concluded that the delay did not violate his substantive due process rights and affirmed the order of the Appellate Division. View "People v Collier" on Justia Law

Police officers in Rosenberg, Texas conducted a high-risk stop of a white Dodge Charger matching the description of a vehicle involved in a report of armed suspects. The only occupants were Michael Lewis and Regina Armstead, an elderly couple. Lewis had a dialysis-related stent in his left forearm, which could be damaged by placing handcuffs on that arm. During the stop, Lewis was handcuffed for about six minutes, reportedly experiencing pain. He later discovered his stent had been damaged and required surgery. Armstead informed an officer that Lewis was a dialysis patient, and Lewis claimed he told officers about his condition both before and after being handcuffed, though his statements were inconsistent.Lewis and Armstead filed suit in the United States District Court for the Southern District of Texas against the City, the police department, and the officers, including an excessive force claim. After a magistrate judge’s recommendation, the district court granted qualified immunity on most claims but denied it on Lewis’s excessive force claim against the five officers, finding a genuine dispute of material fact as to when the officers were informed about Lewis’s medical condition. The officers appealed the denial of qualified immunity.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of qualified immunity de novo. The Fifth Circuit held that the officers did not violate any clearly established law by briefly handcuffing Lewis during a high-risk stop, regardless of whether they had advance notice of his medical condition. The court found that relevant precedent did not place the constitutional question beyond debate under the circumstances, and thus, the officers were entitled to qualified immunity. The Fifth Circuit reversed the district court’s denial of qualified immunity. View "Lewis v. Delgado" on Justia Law

Tony Lee Johnson, a convicted felon on supervised release, was arrested by law enforcement officers after he violated his release conditions by failing drug tests. The arrest was executed at Johnson’s residence when he and his girlfriend, Beatrice Simmons, were found in his vehicle. After Johnson was removed and arrested, Simmons was temporarily detained but not handcuffed. Officer Pringle, suspecting Johnson might be hiding something, conducted a warrantless search of the vehicle's driver area and center console, discovering a loaded handgun. Simmons stated she was unaware of the firearm and confirmed she was on parole for a prior drug offense.The United States District Court for the Northern District of Texas held a hearing on Johnson’s motion to suppress the handgun, which he argued was seized in violation of his Fourth Amendment rights. The district court denied the motion, finding the search constitutional under the protective-sweep exception outlined in Michigan v. Long, reasoning that Simmons posed a potential threat to officer safety due to her criminal history, relationship with Johnson, and emotional proximity to the arrest. Johnson then entered a conditional guilty plea, reserving his right to appeal the denial of the suppression motion, which led to his appeal to the Fifth Circuit.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The Fifth Circuit held that the warrantless search was not justified under the protective-sweep exception because no specific, articulable, contemporaneous facts suggested Simmons was potentially dangerous or would access a weapon. The court reversed the district court’s denial of the suppression motion and vacated Johnson’s conviction and sentence. View "United States v. Johnson" on Justia Law

On the evening of Black Friday in 2021, two employees at a T-Mobile store in Columbus, Ohio were robbed at gunpoint by a masked individual who forced them into a back room, demanded phones and money, and sprayed them with mace before fleeing. Unbeknownst to the robber, a bait phone with a GPS tracker was included among the stolen items, allowing police to quickly locate and apprehend him after a high-speed chase. The suspect, Kevin Daniels, was arrested and, after waiving his Miranda rights during interrogation, admitted to the crime. A search of his vehicle found the stolen goods, a gun, and the disguise used in the robbery.The United States District Court for the Southern District of Ohio presided over Daniels’s trial. He was indicted on three counts: Hobbs Act robbery, brandishing a firearm during a crime of violence, and felon-in-possession of a firearm. After a jury convicted him on all counts, the district court calculated a sentencing guidelines range of 78 to 97 months for the robbery and possession offenses, and imposed the mandatory minimum 7-year sentence for the firearm offense, resulting in a total sentence of 181 months. Daniels raised various pretrial and sentencing challenges, including suppression of statements, issues with counsel, discovery violations, and objections to guideline enhancements.The United States Court of Appeals for the Sixth Circuit reviewed Daniels’s appeal, which included constitutional, evidentiary, instructional, and sentencing claims. The court held that Daniels knowingly and voluntarily waived his Miranda rights, that the district court did not abuse its discretion in denying substitution of counsel, and that there was no reversible error related to discovery or jury instructions. The court also affirmed the application of the physical-restraint and bodily-injury enhancements, and found no error in the calculation of Daniels’s criminal history score. The judgment of the district court was affirmed. View "United States v. Daniels" on Justia Law

Two plainclothes detectives in Baltimore, acting on a tip about drug activity, observed Robert Gary Moore and another individual near a parked vehicle. When approached, Moore dropped a plastic bag and fled but was apprehended. The police recovered the bag, which was later analyzed in a laboratory report stating it contained cocaine. During Moore’s trial for possession and possession with intent to distribute, the State introduced two chain-of-custody reports: one disclosed before trial and another (the ECU report) disclosed only mid-trial. The latter did not mention the chemist who performed the analysis, raising questions about whether the correct bag was tested. Moore’s counsel did not object to the late disclosure or use the discrepancy in his defense. Moore was convicted by a jury.After his conviction was affirmed on appeal by Maryland’s intermediate appellate court, Moore sought postconviction relief in Maryland state court, arguing that the State’s belated disclosure of the ECU report violated his due process rights under Brady v. Maryland and that his counsel was ineffective. The Maryland trial court initially granted relief under Brady but, upon remand from the intermediate appellate court for further factfinding, ultimately denied both claims, finding that disclosure during trial did not constitute suppression under Brady. Moore’s application for leave to appeal this denial was rejected.Moore then filed a federal habeas petition in the United States District Court for the District of Maryland. The district court found a Brady violation and granted habeas relief, ordering Moore’s conviction vacated unless retried within sixty days. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the state court had unreasonably applied federal law and that a Brady violation warranted habeas relief. However, it held that federal district courts lack authority to vacate state convictions directly and thus vacated the district court’s order, remanding for a new order consistent with the proper bounds of federal habeas relief. View "Moore v. State of Maryland" on Justia Law

A petitioner sought a declaratory judgment regarding the legal sufficiency of a proposed constitutional ballot initiative, known as Ballot Issue 4. This initiative aimed to amend the Montana Constitution to limit the powers and privileges of "artificial persons"—including corporations, nonprofit corporations, limited liability companies, unincorporated associations, and certain foreign entities—by expressly restricting their ability to engage in election and ballot issue activities. The initiative would revoke all powers previously granted to artificial persons under Montana law, regrant only those necessary for lawful business or charitable purposes, and specifically prohibit election-related activities except for certain political committees. The petitioner contended that all provisions of the initiative were integral to a unified purpose: preventing artificial persons from participating in political spending.The Montana Attorney General, supported by amici, determined that Ballot Issue 4 was legally insufficient because it violated the separate-vote requirement of Article XIV, Section 11, of the Montana Constitution. According to the Attorney General, the initiative encompassed multiple changes that were not closely related, including broad revocations and regrants of powers to artificial persons, and affected diverse areas of law beyond the stated intent. The petitioner challenged this determination, arguing that the initiative constituted a single, unified scheme and that none of its provisions could sensibly be considered separately.The Supreme Court of the State of Montana exercised original jurisdiction to review the Attorney General’s legal sufficiency determination. The Court held that Ballot Issue 4 violated the separate-vote requirement because it proposed more than one substantive constitutional change—specifically, both limiting artificial persons’ powers to those expressly provided and revoking and regranting powers in a manner that extended beyond election-related activities. The Court affirmed the Attorney General’s rejection of the initiative and denied the petitioner’s request to declare it legally sufficient. View "Transparent Election Initiative v. Knudsen" on Justia Law