Justia Constitutional Law Opinion Summaries

The case involves a defendant who was charged with felony grand theft and, as part of a plea agreement, admitted to additional probation violations and a misdemeanor. He agreed to serve jail time contingent on possible release to a treatment program, subject to assessment. The trial court subsequently placed him on probation with several conditions, including one that permitted the probation department to transfer him to jail for up to 120 days—without court involvement—if he failed to successfully complete a treatment program. This condition further stated that he would not receive credit for time spent in treatment unless he completed the program.After the trial court imposed these conditions, including the challenged provision, the defendant’s probation was revoked due to his absconding from treatment, and a warrant was issued for his arrest. He was later apprehended and appealed the probation condition, arguing that it unlawfully delegated judicial authority to the probation department and was unconstitutionally vague regarding custody credits. Although the trial court later terminated his probation and credited him for all time spent in custody and treatment, the appeal continued based on the public interest and recurring nature of the legal questions presented.The California Court of Appeal, First Appellate District, Division Three, held that the trial court’s probation condition unconstitutionally delegated excessive judicial authority to the probation department by allowing it to determine and impose significant sanctions without court oversight. The court further concluded that, in the absence of a knowing and intelligent waiver, the defendant could not be denied custody credits for time spent in residential treatment, even if he did not successfully complete the program. Because these issues are likely to recur, the appellate court reached the merits but ultimately dismissed the appeal as moot, since the defendant had already received the credits in question. View "P. v. Emrick" on Justia Law

The case centers on a petitioner who was convicted of murder and related crimes following a 2016 jury trial. The conviction stemmed from a shooting incident in New London, Connecticut, in which several eyewitnesses, including Alice Phillips, identified the petitioner as the perpetrator. Phillips’ credibility was challenged at trial, but she remained an important witness for the prosecution. After the trial, it came to light that Phillips had previously provided false testimony regarding expected consideration for her cooperation in a different, unrelated murder trial prosecuted by the same state’s attorney’s office.Following his conviction, the petitioner filed a habeas petition in the Superior Court for the judicial district of Tolland, arguing that his due process rights were violated when the prosecutor failed to disclose Phillips’ prior false testimony. The habeas court denied his petition, and the Appellate Court dismissed his appeal, reasoning that the prosecutor in the petitioner’s trial had no obligation to seek out impeachment material from unrelated cases absent a specific request from the defense.On appeal, the Connecticut Supreme Court held that the state’s attorney’s office is a single entity for Brady v. Maryland purposes. Therefore, the prosecutor was responsible for disclosing exculpatory or impeachment evidence known to other prosecutors in the same office, including the information about Phillips’ false testimony in the unrelated case. However, the Supreme Court concluded that the nondisclosure was immaterial because Phillips was not the only eyewitness, her credibility was effectively challenged at trial, and there was significant additional evidence implicating the petitioner.Accordingly, the Connecticut Supreme Court vacated the Appellate Court’s determination regarding the scope of the prosecutor’s disclosure obligations but affirmed the judgment in all other respects, finding no Brady violation as the suppressed evidence was not material to the outcome. View "Vega v. Commissioner of Correction" on Justia Law

Oscar Hudspeth, a member of the Oglala Sioux Tribe, was convicted by a jury of two sex abuse offenses involving his young stepdaughter, D.J., which occurred when she was between five and seven years old and living in his home. The prosecution’s evidence included D.J.’s testimony about the abuse and statements Hudspeth made during a post-polygraph interview with an FBI agent, where he admitted to inappropriate touching. Prior to trial, both parties agreed to exclude any reference to the polygraph test from evidence, and the district court admitted a redacted version of the interview transcript omitting mention of the polygraph.In the United States District Court for the District of South Dakota, Hudspeth moved to either exclude the entire interview or, alternatively, to ensure all polygraph references were redacted. When it became clear that a redacted version would be admitted, Hudspeth changed his position, seeking to admit the entire interview, including polygraph references, to provide context for his admissions. The district court admitted the redacted interview and excluded polygraph references, noting that Hudspeth had earlier agreed to the exclusion. Hudspeth was ultimately found guilty and sentenced to the mandatory minimum term.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether excluding polygraph references violated Hudspeth’s constitutional right to present a complete defense. The court held that the exclusion did not violate his constitutional rights or constitute an abuse of discretion. It found that polygraph evidence is generally unreliable and disfavored, and that the exclusion was neither arbitrary nor disproportionate. The court concluded that even if there was error, it was harmless beyond a reasonable doubt due to the strength of the prosecution’s case. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Hudspeth" on Justia Law

Police in Bloomington, Minnesota, stopped a vehicle after observing a suspended object hanging from the rearview mirror and learning that the vehicle’s registered owner, Damion Kent Hallmon, had a suspended license. Hallmon was driving, accompanied by his fiancée, Ieisha McGrone, and their two children. During the stop, police observed a bag that appeared to contain marijuana, prompting a search of the vehicle. In a handbag on the front passenger seat, officers found a loaded pistol. Both Hallmon and McGrone made statements regarding the gun, with Hallmon ultimately admitting ownership and describing the firearm. Hallmon was arrested and charged with being a felon in possession of ammunition.Before trial in the United States District Court for the District of Minnesota, Hallmon moved to suppress the evidence and statements from the stop, and to dismiss the indictment on Second Amendment grounds. A magistrate judge recommended denial of the suppression motions, and the district court adopted this recommendation and denied the dismissal motion. At trial, the government presented testimony that the ammunition traveled in interstate commerce. Hallmon attempted to introduce recorded jail calls with McGrone, but the district court excluded them as hearsay. The jury found Hallmon guilty, and the district court imposed a two-level sentencing enhancement for obstruction of justice, sentencing him to 74 months’ imprisonment and three years’ supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that the stop, search, and seizure were constitutional; Hallmon was not in custody for Miranda purposes when making statements; sufficient evidence supported the interstate commerce element; exclusion of the jail calls was proper; the obstruction of justice enhancement was warranted; and existing circuit precedent foreclosed Hallmon’s Second Amendment challenge. View "United States v. Hallmon" on Justia Law

An administrative law judge (ALJ) at the International Trade Commission (ITC) issued a protective order during a dispute between Qualcomm and Apple, requiring recipients of confidential business information, including expert witness Gregory Sidak, to return or destroy that information after the case ended. However, the ALJ who issued the order had been appointed solely by the ITC chairman, not by the full commission as required by the Constitution’s Appointments Clause. The ITC later ratified the ALJ’s appointments but did not ratify past actions taken by those ALJs. Years after the underlying case ended, the ITC began investigating Sidak for allegedly violating the protective order’s requirements. Sidak participated in the investigation by exchanging letters and affidavits, but eventually sued, arguing that the protective order was void because it was issued by an unconstitutionally appointed ALJ and never ratified, and sought to enjoin the ITC from enforcing it against him.The United States District Court for the District of Columbia found in Sidak’s favor, holding that the protective order could not lawfully be used as the basis for the investigation or for imposing sanctions on him. It permanently enjoined the ITC from taking further action against Sidak based on the challenged order. The ITC appealed the district court’s decision.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s judgment. The court held that Sidak had standing, that the district court had subject-matter jurisdiction, and that Sidak had a right of action under the Constitution. The court further held that Sidak’s challenge was both timely and ripe, rejecting the ITC’s arguments that the claim was either too early or too late. The court also concluded that the district court did not abuse its discretion in granting permanent injunctive relief. View "J. Sidak v. United States International Trade Commission" on Justia Law

The defendant was convicted by a jury of first-degree felony murder, aggravated burglary, attempted aggravated robbery, two counts of aggravated assault, and criminal possession of a weapon after a 2016 home invasion and homicide. Following a mistrial at his first proceeding, a second trial resulted in convictions on all charges. At his original sentencing, the district court calculated the defendant’s criminal history score as A, in part based on a 2003 criminal-threat conviction, and imposed a life sentence without parole eligibility for 653 months, plus consecutive sentences on the remaining counts.On appeal from the original sentencing, the Supreme Court of Kansas affirmed the convictions but vacated the sentence. The court concluded that the district court erred in including the 2003 conviction in the criminal history score, as the statute under which it was obtained had been found unconstitutional in part by the Supreme Court of Kansas in State v. Boettger, 310 Kan. 800 (2019). The court remanded the case for resentencing with instructions not to include the 2003 conviction. On remand, the district court recalculated the criminal history score as B and resentenced the defendant accordingly, reducing the parole eligibility period and other determinate sentences. The court denied the defense’s renewed motion for a departure sentence.The Supreme Court of Kansas reviewed the appeal from resentencing. The defendant raised, for the first time, constitutional challenges to the Kansas Sentencing Guidelines Act, arguing that it violated his jury trial rights by permitting a judge to determine prior convictions that enhance punishment. The court declined to review these unpreserved claims, finding that settled law foreclosed relief. The defendant’s claim for additional jail credit was rendered moot by a nunc pro tunc order from the district court. The Supreme Court of Kansas affirmed the judgment of the district court. View "State v. Smith " on Justia Law

A man residing with his mother was involved in her killing and decapitation in Stone County, Mississippi. The discovery of the crime followed a welfare check initiated by family concerns after they had not heard from the mother. When law enforcement arrived, the defendant initially resisted entry but then permitted officers into the home, where further investigation led to the discovery of the mother's body and head on the property. The defendant later confessed to the killing during both a police interview and a recorded phone call. Evidence showed a history of mental illness, conflict between the defendant and his mother over financial issues, and extensive injuries related to the crime.The Stone County Circuit Court found the defendant incompetent to stand trial at first, but, following psychiatric treatment, later deemed him competent. Before trial, the defense moved to suppress evidence obtained during the initial warrantless search, but the court denied the motion. At trial, the defense presented an insanity defense with expert testimony, while the State offered its own expert in rebuttal. The defendant was ultimately convicted by a jury of first-degree murder and sentenced to life imprisonment. Post-trial motions challenging the weight of the evidence, the denial of certain jury instructions, evidentiary rulings, and restrictions on closing arguments were denied by the trial court.Upon review, the Supreme Court of Mississippi affirmed the conviction and sentence. The court held that the trial court correctly denied lesser-included-offense instructions because the evidence overwhelmingly indicated deliberate design. The court determined the warrantless search was lawful under the inevitable discovery doctrine. Objections to the admission of video evidence and limitations on closing argument were either procedurally barred or, if error, harmless. The jury’s verdict was found not to be against the overwhelming weight of the evidence. View "Johnson v. State of Mississippi" on Justia Law

A man was convicted in 2008 after pleading no contest to rape and other forcible sex offenses committed against a woman at knifepoint. He was sentenced under California Penal Code section 667.6, subdivision (c), to an aggregate term of 50 years in prison, consisting of full, consecutive terms for each offense and a weapon enhancement, pursuant to a plea agreement. After serving 15 years, he received a youth offender parole hearing under Penal Code section 3051, subdivision (b)(1), which allows such hearings for offenders who committed their crimes at age 25 or younger. The victim participated in the hearing to oppose parole, and parole was denied, but a new hearing was set.The victim and a crime victims’ advocacy organization filed a petition for writ of mandate in the Superior Court of Los Angeles County, seeking to block the parole hearing and to prevent enforcement of section 3051 for any prisoner sentenced under section 667.6, subdivisions (c) or (d). They argued that section 3051 was unconstitutional as applied to such offenders because it amended a voter initiative statute (Proposition 83) without the required two-thirds legislative approval or voter approval, in violation of the California Constitution. The superior court assumed the victim had standing but not the advocacy group, and denied the petition, finding that Proposition 83 did not substantively amend section 667.6, subdivision (c).The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. It held that Proposition 83 made only technical, not substantive, changes to section 667.6, subdivisions (c) and (d), and that the statutory scheme for consecutive sentencing of sex offenses was not integral to the initiative’s goals. Therefore, the enactment of Penal Code section 3051 was not an unconstitutional amendment. The appellate court affirmed the judgment denying the petition. View "Jessica M. v. Cal. Dept. of Corrections & Rehabilitation" on Justia Law

A grand jury indicted Nathan Chasing Horse on several felonies, including charges related to sexual offenses against a minor. This case received significant public and media attention. During both the renewed grand jury proceedings and the criminal trial, the real name of "S. Doe," an alleged victim who was a minor at the time of the offenses, was repeatedly disclosed in open court and in publicly filed documents. As the trial began, the district court issued a decorum order asking the media not to publish the victim’s full name, then clarified orally that this was a mandatory prohibition. The district court threatened contempt for noncompliance and ultimately excluded the Las Vegas Review-Journal and its journalists from the courtroom when they refused to agree to the restriction.The Eighth Judicial District Court of Nevada imposed these restrictions and removals. The Review-Journal sought emergency relief from the Supreme Court of Nevada, arguing that the orders constituted an unconstitutional prior restraint and violated their right of access to court proceedings. The district court justified its actions by citing Nevada statutes and Marsy's Law, although there was no evidence the victim had invoked these statutory protections, and the statutes themselves did not authorize prior restraint on the press.The Supreme Court of the State of Nevada held that the district court manifestly abused its discretion by imposing a prior restraint on publication of the victim’s identity after that information was already public, and by excluding the journalists from the courtroom. The court found that the restrictions did not serve an interest of the highest order, were not narrowly tailored, and failed to apply evenhandedly. The Supreme Court granted the petition for a writ of mandamus, vacating the district court’s restrictions and exclusion order. View "LAS VEGAS REVIEW-JOURNAL, INC VS. DIST. CT." on Justia Law

In June 2023, Colorado enacted a law prohibiting the purchase, sale, transfer, and possession of unserialized firearms, frames, receivers, and firearm parts kits, as well as the manufacture of firearm frames or receivers by most people. Several individuals and two associations representing Colorado gun owners sued, alleging that the statute infringes their Second Amendment rights. The individual plaintiffs had previously purchased or owned firearm parts kits and intended to continue similar activities but for the new law. The associations represent gun owners in Colorado and were acting on behalf of similarly situated members.The United States District Court for the District of Colorado reviewed the plaintiffs’ motion for a preliminary injunction. It determined that one individual plaintiff had standing to challenge the possession prohibition, but found that the claims relating to future acquisition were not ripe due to an overlapping federal regulation, and that claims challenging the manufacturing prohibition lacked standing because the plaintiffs’ conduct was not covered by that provision. The court denied the preliminary injunction, concluding that the possession prohibition was a presumptively constitutional condition on the commercial sale of firearms that did not implicate the plain text of the Second Amendment.The United States Court of Appeals for the Tenth Circuit reviewed the case. It held that the plaintiff had standing to challenge both the possession and acquisition prohibitions, but not the manufacturing prohibition. The court found that the district court erred in treating the possession prohibition as a condition on commercial sales, since the law regulated possession regardless of how the item was acquired. The Tenth Circuit reversed the district court’s denial of a preliminary injunction as to the possession prohibition, holding that this provision regulates possession, not just commercial sales. The court remanded for further proceedings, directing the district court to address the merits of the acquisition prohibition claim in the first instance. View "National Association for Gun Rights v. Polis" on Justia Law