Justia Constitutional Law Opinion Summaries

The defendant was convicted in Texas state court in 2004 for assault causing bodily injury to a family member, which qualifies as a misdemeanor crime of domestic violence under Texas law. The incident involved the defendant pushing his wife during an argument and, when she attempted to call 911, striking her in the face while trying to knock the phone from her hand. Based on this conviction, he was later indicted under 18 U.S.C. § 922(g)(9) for possessing a firearm after being convicted of a misdemeanor crime of domestic violence.Before the United States District Court for the Western District of Texas, the defendant moved to dismiss the indictment, raising two constitutional challenges: that the statute exceeds Congress’s power under the Commerce Clause, and that, as applied to him, it violates the Second Amendment. The district court denied the motion. The defendant then entered a conditional guilty plea, reserving the right to appeal the denial of his motion to dismiss, and was sentenced to imprisonment and supervised release.The United States Court of Appeals for the Fifth Circuit reviewed the case. It rejected the Commerce Clause challenge, extending the reasoning from United States v. Alcantar to § 922(g)(9). The court then addressed the as-applied Second Amendment challenge, applying the historical tradition test articulated in New York State Rifle & Pistol Ass’n v. Bruen and clarified in United States v. Rahimi. The Fifth Circuit concluded that § 922(g)(9), as applied to the defendant, is consistent with the nation’s historical tradition of disarming individuals found to threaten the physical safety of others. The court found that the statute’s rationale and burden are supported by historical analogues and that the defendant’s conduct was sufficiently dangerous to warrant disarmament. The judgment of the district court was affirmed. View "USA v. Allred" on Justia Law

The case concerns a man accused of kidnapping and sexually assaulting a woman in Maui in 1989. The prosecution’s case relied heavily on circumstantial evidence and expert testimony from an FBI agent, who analyzed hair and fiber samples. The expert testified that hair found in the defendant’s car was “consistent with” originating from the complainant, and that fibers found on her clothing were “consistent with” coming from the car’s seat cover and carpet. The defense challenged the complainant’s credibility but did not contest the expert testimony. The jury convicted the defendant, and he was sentenced to forty years. Nearly thirty years later, a letter from the Department of Justice revealed that the expert’s testimony about hair analysis overstated the science and was invalid. The defense then argued that both the hair and fiber testimony should be deemed unreliable based on scientific developments.The Circuit Court of the Second Circuit held a hearing and found that the hair analysis testimony exceeded the bounds of science but ruled the error harmless beyond a reasonable doubt due to other corroborative evidence. The court did not rule on fiber analysis. The Intermediate Court of Appeals (ICA) affirmed the denial of post-conviction relief, applying the State v. McNulty “newly discovered evidence” test. The ICA found that the fiber testimony was not impeached by the DOJ letter and considered the hair evidence cumulative, so it declined to address whether the new evidence would probably change the result at retrial.The Supreme Court of Hawai‘i reviewed the case and held that when scientific advances later invalidate expert testimony presented at trial, the “false evidence” standard applies, not the “newly discovered evidence” standard. The court found both the hair and fiber testimony materially false, took judicial notice of landmark scientific reports, and concluded there was a reasonable possibility the false evidence contributed to the conviction. The defendant’s due process rights were violated, and the court vacated the lower courts’ decisions, remanding for a new trial. View "Granillo v. State" on Justia Law

In 2009, the appellant was convicted of violating California Penal Code section 288.4, subdivision (b), for arranging and attending a meeting with a minor with the intent to commit a sexual offense. The sentencing court imposed felony probation, jail time, and required him to register as a sex offender. In 2024, the appellant sought removal from the sex offender registry, arguing that the statutory scheme’s classification—placing his offense in tier three, which requires lifetime registration—violated his constitutional rights to equal protection. He contended there was no rational basis for imposing lifetime registration for his offense when other, allegedly more serious offenses, such as lewd acts under section 288, subdivision (a), did not require lifetime registration.The Superior Court of Los Angeles County reviewed the writ petition and denied relief. The court found that the Legislature could rationally distinguish between the appellant’s offense, characterized as a predatory “child luring” crime involving planning and a demonstrated unnatural interest in children, and the offenses he cited for comparison. The court explained that the statutory scheme was motivated by a legitimate governmental purpose: managing the risk of recidivism among offenders deemed most likely to reoffend and protecting public safety.The California Court of Appeal, Second Appellate District, Division Three, affirmed the lower court’s order. The appellate court held that under rational basis review, the Legislature had a conceivable and legitimate reason for classifying section 288.4, subdivision (b), offenses as warranting lifetime registration. The court emphasized that equal protection is not violated when the Legislature draws distinctions based on plausible risk assessments and societal interests, even if some other offenses are not treated identically. The appellate court concluded that the statutory classification survived constitutional scrutiny and awarded costs on appeal to the respondent. View "Muradyan v. Bonta" on Justia Law

A father’s three children were taken into emergency custody by the Alaska Office of Children’s Services (OCS) in 2019 while he was incarcerated in another state. After his release, OCS worked with him but ultimately petitioned to terminate his parental rights, primarily due to the length of his incarceration and concerns about his progress toward reunification. In January 2023, a superior court terminated the parental rights of both parents. The following July, one child, Serena, was adopted by her foster family, and the court closed her child in need of aid (CINA) case, releasing her into her adoptive parents’ custody.The father appealed the termination of his parental rights. In December 2023, the Supreme Court of the State of Alaska reversed the termination order, finding OCS had not made reasonable efforts to reunify the family. On remand, the superior court reopened Serena’s CINA case but left her in the adoptive parents’ custody. The father was appointed counsel in the adoption case. However, more than one year after the adoption decree, the CINA case was declared moot at the request of the guardian ad litem, who cited Alaska’s statutory one-year limit on challenging adoption decrees. The father argued that the one-year bar did not apply because the adoptive parents had not “taken custody” of Serena and that his due process and right to effective counsel were violated.The Supreme Court of the State of Alaska affirmed the dismissal of the CINA case as moot. It held that the one-year statutory bar to challenging adoptions applied because Serena’s adoptive parents had taken custody. The court found no due process violation, as the father had notice, counsel, and opportunity to be heard, and rejected his ineffective assistance of counsel claim, finding no constitutional deficiencies. View "Jonah B. v. State" on Justia Law

Police investigating suspected drug trafficking received information from a confidential informant about two individuals selling drugs. Surveillance linked the suspects to multiple addresses. The investigation included controlled drug buys and installation of a pole camera outside an apartment building. On April 4, 2023, the informant reported a possible deceased person inside one of the apartments. Surveillance footage showed the suspects and another individual entering and exiting the building. Police detained the suspects at a traffic stop and seized keys. Officers then entered the apartment building without a warrant, finding a deceased person in the second-floor apartment and, upon entering the third-floor apartment, discovering drug paraphernalia and contraband.The Providence County Superior Court held a hearing on the defendant’s motion to suppress evidence obtained during the warrantless search and seizure. The trial justice denied the motion, concluding that the police were responding to a sudden emergency involving a possible death and acted rationally to protect citizens from harm and prevent destruction of property. The defendant was subsequently found guilty on all charges following a bench trial and sentenced to twenty-five years, with twenty years to serve and five years suspended. The defendant appealed.The Supreme Court of Rhode Island reviewed the denial of the motion to suppress under the Fourth Amendment and article 1, section 6 of the Rhode Island Constitution, applying the totality of the circumstances standard and deferring to factual findings unless clearly erroneous. The Court held that police had no constitutionally permissible reason to enter the third-floor apartment after finding the deceased in the second-floor apartment and that the exigency justifying entry had evaporated. The Court concluded that the error was not harmless, vacated the conviction, and remanded for a new trial. View "State v. Moronta" on Justia Law

The defendant was arrested in connection with a fatal shooting and, following his arrest, was given Miranda warnings. Police initially did not interrogate him because they believed he was intoxicated. The next day, during a videorecorded interrogation, the defendant waived his rights but later invoked his right to counsel, stating he needed appointed counsel. Police then left, purportedly to locate an attorney, but after more than two hours returned and informed the defendant that no attorney was available and he did not have the money to hire one. The defendant expressed confusion and asked clarifying questions. Police indicated that unless the defendant agreed to speak without an attorney, they could not discuss the case further. The defendant ultimately agreed to speak without counsel, was given Miranda warnings again, and made incriminating statements.The Wayne Circuit Court, after reviewing the interrogation video, granted the defendant’s motion to suppress the statements. The court found that police communications had frustrated the required Miranda advice by suggesting that the defendant’s right to counsel depended on his ability to pay, thereby undermining his rights. The trial court also found that police had reinitiated interrogation after the defendant invoked his right to counsel.The Michigan Court of Appeals reversed the suppression order, holding that the defendant’s waiver was voluntary, knowing, and intelligent, and that police had not violated his constitutional rights. The defendant sought further review.The Michigan Supreme Court held that the defendant’s Fifth Amendment rights under Miranda were violated. The Court found that police undermined the required advice of rights by suggesting that the right to counsel depended on the defendant’s ability to pay and that the prosecution failed to show the defendant reinitiated the interrogation. The Court reversed the Court of Appeals’ judgment and remanded for further proceedings, ordering suppression of the defendant’s post-invocation statements. View "People Of Michigan v. Fenderson" on Justia Law

A state prisoner challenged the denial of his federal habeas corpus petition after being convicted of several charges, including aggravated rape, in Massachusetts. The prosecution’s case was based on the victim’s testimony, physical evidence, and expert and witness accounts, while the defendant claimed the sexual encounter was consensual. During jury deliberations, seven not-guilty verdicts were returned on some charges, but deliberations continued on the remaining counts. After the weekend recess, a Facebook post by a former police officer urged community members to attend the next court session to support the victim, and a small demonstration took place at the courthouse with attendees wearing teal ribbons. The defense raised concerns about potential juror exposure to these influences, but the judge declined an individual juror inquiry, instead asking general questions about their ability to continue serving.Following conviction, the defense contacted jurors, and one juror reported seeing the Facebook post, being aware of the demonstration, and claimed that these factors led to greater weight being given to the victim’s testimony on the last day of deliberations. The trial court held an evidentiary hearing, found that some jurors were aware of the post and demonstration, but concluded that exposure was brief, not discussed during deliberations, and not prejudicial. The trial court specifically discredited the juror’s account of actual prejudice. The Massachusetts Appeals Court affirmed, and the Supreme Judicial Court declined review.In federal habeas proceedings, the U.S. District Court for the District of Massachusetts denied relief, holding that the state court’s examination of extraneous influence claims met federal constitutional standards and that its factual findings were owed deference. The United States Court of Appeals for the First Circuit affirmed, holding that the state court’s decision was neither contrary to nor an unreasonable application of clearly established Supreme Court precedent, and that its factual determinations were reasonable. The denial of habeas relief was affirmed. View "Adames-Garcia v. Divris" on Justia Law

A Jamaican citizen who entered the United States on a work visa married a U.S. citizen and later experienced domestic violence from his spouse, who was eventually arrested. After his visa expired, removal proceedings were initiated, and an immigration judge ordered his removal. Under the Violence Against Women Act (VAWA), survivors of domestic violence have a one-year deadline to file a motion to reopen removal proceedings. On the last day of this period, the petitioner’s counsel attempted to file the motion electronically, but the system rejected it. When he tried to file in person, a court clerk refused to accept the paper copy, insisting it be filed electronically. After continued unsuccessful attempts, the motion was finally mailed and accepted, but after the deadline.The Immigration Judge denied the motion to reopen, finding it untimely and concluding that the petitioner did not provide sufficient proof he was prevented from timely filing. The Board of Immigration Appeals (BIA) affirmed, with the majority agreeing that the record did not support the claim of impeded filing and that no exception to the deadline applied. One BIA member dissented, noting clear evidence of repeated filing attempts thwarted by the court.The United States Court of Appeals for the Fourth Circuit reviewed both the Immigration Judge and BIA decisions. Applying de novo review to legal and constitutional questions and substantial evidence review to factual findings, the Fourth Circuit held that the record compelled the conclusion that the petitioner was prevented from timely filing. The court found this defect rendered the proceedings fundamentally unfair and prejudiced the petitioner’s case, thus violating his Fifth Amendment due process rights. The court granted the petition for review, reversed the BIA’s denial, and remanded for further proceedings. View "Burey v. Blanche" on Justia Law

The case involves an individual who broke the windows of a parked vehicle at a grocery store in Monrovia and entered the driver’s seat. The owner of the vehicle had kept a long knife under the seat for protection. After fleeing the scene, the individual was observed by police carrying a scooter, complied initially with commands, but then removed a knife from his waistband, dropped it, and ran before eventually being apprehended. The knife was 14 inches long with an eight-inch blade.Following these events, the Los Angeles County Superior Court charged the individual with felony vandalism and carrying a concealed dirk or dagger, with additional allegations regarding the amount of property damage and prior criminal conduct. A jury found the individual guilty on both counts and found true the allegation of damages exceeding $400. The court dismissed certain sentencing allegations and imposed a total sentence of two years in county jail. The defendant filed a timely appeal challenging both the constitutionality of California Penal Code section 21310, which prohibits carrying a concealed dirk or dagger, and the sentencing decision.The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. The court held that Penal Code section 21310 is constitutional under the Second Amendment. Applying the framework set out in New York State Rifle & Pistol Association, Inc. v. Bruen, the court found that bans on carrying concealed dirks or daggers are consistent with the nation’s historical tradition of arms regulation. The court also determined that the defendant forfeited his sentencing challenge by failing to object at the time of sentencing, in accordance with California procedural law. The judgment of the Superior Court was affirmed. View "P. v. Miranda" on Justia Law

A traveler arriving in the United States from Bolivia was subject to inspection by U.S. Customs and Border Protection at Washington Dulles International Airport. The officer requested that the traveler unlock his two iPhones, which he did. Within approximately two minutes, the officer accessed the photo galleries, including hidden folders, and discovered sexually explicit images of prepubescent girls. The traveler was subsequently arrested and indicted by a federal grand jury in the United States District Court for the Eastern District of Virginia on multiple counts relating to child pornography.The defendant moved to suppress the evidence obtained from the search of his phones, arguing that the search violated the Fourth Amendment. The district court held an evidentiary hearing, during which the officer explained her suspicions. The court denied the motion to suppress, finding that either individualized suspicion was present or, alternatively, that the officer acted in good faith. The defendant entered a conditional guilty plea to all counts, preserving his right to appeal the suppression ruling. He was sentenced to 18 years in prison and 25 years of supervised release.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether manual searches of cell phones at the border are “routine” and thus exempt from the requirement of individualized suspicion under the Fourth Amendment. The Fourth Circuit held that manual searches of cell phones at the border are routine border searches and do not require individualized suspicion, distinguishing such searches from forensic searches, which are nonroutine and require some level of individualized suspicion. The court affirmed the district court’s denial of the motion to suppress. View "US v. Cardozo" on Justia Law