Justia Constitutional Law Opinion Summaries

Law enforcement authorities investigating a graduate student at a university for rape served a search warrant on a major electronic service provider seeking data linked to the student’s university email account. Along with the warrant, the authorities obtained a nondisclosure order (NDO) that prohibited the provider from disclosing the existence of the warrant or the investigation to the target, the university, or others for 90 days. The provider did not contest the restriction as it applied to the target, but sought to modify the NDO so it could inform a trusted contact at the university about the warrant, arguing that doing so would not compromise the investigation and was required under state law and the First Amendment.In the Superior Court of Los Angeles County, the provider’s motion to modify the NDO was denied. The court based its decision on a sealed affidavit supporting the warrant and NDO, finding that several statutory criteria justifying nondisclosure were satisfied. The court also rejected the provider’s proposal to notify a university contact, expressing concern about its lack of jurisdiction over the university and the possibility of unauthorized disclosure. The NDO was later extended, but ultimately lifted after the student was arrested.The California Court of Appeal, Second Appellate District, Division Four, reviewed the provider’s petition for a writ of mandate. The court held that the trial court complied with the California Electronic Communications Privacy Act by making the required findings before issuing the NDO, and that the NDO satisfied strict scrutiny under the First Amendment. The court reasoned that the NDO served a compelling governmental interest in protecting an ongoing criminal investigation and was narrowly tailored, as allowing disclosure to a university contact posed unacceptable risks. The petition for writ of mandate was denied, and each party was ordered to bear its own costs on appeal. View "Microsoft Corp. v. Superior Ct." on Justia Law

Myelicia Rodgers, a clerk at a United States post office in Crestview, Florida, was accused of tampering with and stealing mail while working alone during early morning shifts. After suspicions arose due to complaints about opened mail, the Office of Inspector General conducted an investigation. Rodgers was observed via video and in person engaging in suspicious activities, including taking greeting cards into restricted areas, opening packages, and removing mail. Test letters with cash and gift cards were used in the investigation, some of which went missing, and Rodgers was caught taking and hiding one such letter. Upon being confronted, Rodgers admitted to opening some letters but denied stealing their contents.A grand jury indicted Rodgers on counts of mail tampering and theft by a postal employee. She waived her right to a jury and opted for a bench trial in the United States District Court for the Northern District of Florida. At trial, the government presented multiple witnesses and video evidence. Rodgers did not testify or call any witnesses in her defense. After the prosecution rested, Rodgers moved for a judgment of acquittal, which the district court denied. The district court explicitly informed Rodgers of her right not to testify and assured her that her silence would not be considered in determining guilt. Rodgers’s counsel argued that her silence should not be taken as evidence against her, and the court reiterated that it would base its decision solely on the evidence presented.The United States Court of Appeals for the Eleventh Circuit reviewed whether the district court drew an adverse inference from Rodgers's decision not to testify. The court held that the district court did not consider Rodgers’s silence as evidence of guilt and properly respected her Fifth Amendment rights. Therefore, the Eleventh Circuit affirmed Rodgers’s conviction. View "USA v. Rodgers" on Justia Law

A completed driver reexamination request was submitted to the Department of Motor Vehicles (DMV) by a confidential reporter, prompting the DMV to initiate a review of Richard Louis Brown’s driving qualifications. Brown was notified that he must submit a medical evaluation. His physician, a new provider to Brown, recommended a driving test but did not advise against driving. Following a reexamination, Brown failed a driving test, and his license was suspended. A second hearing officer later reinstated his license, finding no medical basis for the initial suspension and stating that Brown should not have been required to take the tests.Brown filed a petition for writ of mandate in the Superior Court of Sacramento County, seeking disclosure of the reporter’s identity and criminal sanctions against the reporter for alleged false information. The DMV opposed, explaining the confidentiality policy for reporters is intended to promote road safety and prevent retaliatory actions. The trial court denied the petition, applying a public interest balancing test and finding that the interest in maintaining reporter confidentiality outweighed the interest in disclosure. Judgment was entered against Brown, who then appealed.The California Court of Appeal, Third Appellate District, held that due process was not violated by the DMV’s nondisclosure of the reporter’s identity. The court found that the risk of erroneous deprivation was low because the suspension was based on Brown’s failed driving test, not the reporter’s complaint, and Brown received notice and two hearings. The court concluded that neither federal nor California constitutional due process required disclosure of the reporter’s identity under the circumstances and affirmed the superior court’s judgment denying Brown’s petition. View "Brown v. Dept. of Motor Vehicles" on Justia Law

Law enforcement officers responded to a report of an open door at Chad Taylor’s townhouse in Boone County, Kentucky. Inside, they found signs of recently fired gunshots, including bullet holes and spent shell casings. After obtaining search warrants, officers found ammunition and methamphetamine in Taylor’s possession. Taylor admitted to using methamphetamine and exhibited paranoid, erratic behavior, claiming people were watching him. The following day, Taylor was found at his home with a loaded Glock 19, and ballistics matched it to the earlier gunfire. Taylor had prior felony convictions for drug trafficking, intimidation, and misdemeanor domestic battery.A grand jury indicted Taylor for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The United States District Court for the Eastern District of Kentucky initially detained Taylor but later released him on conditions due to his history of substance abuse and the risk he posed. Taylor moved to dismiss the indictment, arguing that the statute was unconstitutional both facially and as applied. The district court denied the motion, finding Taylor dangerous based on his prior convictions, and subsequently sentenced him to 30 months’ imprisonment after he pled guilty but reserved his right to appeal the constitutional issue.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the constitutionality of § 922(g)(1) as applied to Taylor in light of recent circuit precedent. The appellate court held that the dangerousness assessment required for firearm disqualification is distinct from the assessment for pretrial detention. Applying the standard set forth in United States v. Williams, the court found that Taylor’s offense conduct and criminal history—including felony drug trafficking, intimidation, and domestic battery—demonstrated that he was dangerous. The court affirmed the district court’s judgment, holding that § 922(g)(1) is constitutional as applied to Taylor. View "United States v. Taylor" on Justia Law

Several individuals and two retailers challenged California’s statutory scheme regulating switchblade knives, arguing that these laws violate the Second Amendment. The relevant regulations define switchblades as certain knives with blades of at least two inches that open automatically, and prohibit, among other conduct, carrying such knives concealed in public. The plaintiffs brought a facial constitutional challenge, asserting a right to keep and bear switchblades under the Second Amendment.In the United States District Court for the Southern District of California, the judge granted summary judgment in favor of the state. The district court concluded that switchblades are not protected by the Second Amendment because they are not commonly used for self-defense and are considered dangerous and unusual. Although this finding was deemed dispositive, the district court also found that California failed to show its regulations were consistent with the nation’s history and tradition of arms regulation, but nonetheless upheld the law based on the initial analysis.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the summary judgment de novo. Applying the framework from New York State Rifle & Pistol Association v. Bruen, the Ninth Circuit assumed, without deciding, that the Second Amendment’s text covered the plaintiffs’ conduct. At the historical inquiry step, the court held that switchblades are relevantly similar to Bowie knives and other weapons historically regulated due to their association with violence and crime, and that California’s prohibition on concealed carry of switchblades is analogous to longstanding restrictions on the concealed carry of such weapons. The Ninth Circuit therefore affirmed the district court’s judgment, holding that plaintiffs’ facial challenge failed because they could not show that the switchblade regulations are unconstitutional in all their applications. View "Knife Rights, Inc. v. Bonta" on Justia Law

The case involves a defendant who was charged with the first-degree premeditated murder of his former romantic partner, with whom he shared a child. The victim was found dead in their shared residence from a gunshot wound. Surveillance footage and testimony indicated the defendant had access to the residence and was present in the vicinity during the relevant time. He was interviewed by police on the day of the crime, during which he denied leaving his girlfriend’s hotel room the night before and denied owning any guns. The initial trial ended with a hung jury. Before a second trial, the defendant moved to suppress statements made during the police interview, arguing violations of his Fifth Amendment rights.In the Wyandotte District Court, the defendant’s motion to suppress was denied after a hearing. The court found that the pre-Miranda portion of the interview was not custodial and that the defendant’s post-Miranda statement did not constitute an unequivocal invocation of the right to silence. The second trial proceeded, and the jury found the defendant guilty of first-degree murder. He was sentenced to life in prison, prompting this direct appeal.The Supreme Court of the State of Kansas reviewed the case. The court held that the defendant was subjected to a custodial interrogation prior to receiving Miranda warnings, making admission of his pre-Miranda statements erroneous. However, the court determined that the error was harmless because the same statements were properly admitted post-Miranda and supported by other evidence. The court further held that the defendant’s statement after receiving Miranda warnings (“No, ’cause I don’t know where this is going”) was ambiguous and did not clearly invoke his right to remain silent. Therefore, the admission of his post-Miranda statements was not error. The court affirmed the judgment of the district court. View "State v. McCullough " on Justia Law

A state trooper observed David Davalos commit a traffic violation by failing to signal a lane change. The trooper initiated a stop as Davalos pulled into the driveway of the home he shared with his parents. The driveway was open, with no fence or gate, and was adjacent to a public sidewalk and street. After blocking Davalos’s car, the officer instructed Davalos to exit the vehicle, which he did, leaving the driver’s side door open. The officer, concerned for his safety and unable to see into the car due to heavily tinted windows, approached and smelled marijuana, saw ashes, and noticed the driver’s side door appeared tampered with. After Davalos admitted to recently smoking marijuana and possessing a small amount, the officer searched the car and discovered marijuana and a firearm.Davalos was charged with possession of a firearm by a convicted felon in the United States District Court for the Western District of Texas. Prior to trial, he moved to suppress the evidence from the warrantless search, arguing the search violated the Fourth Amendment because the car was within the home’s curtilage and no exigent circumstances existed. A magistrate judge found the driveway was not part of the curtilage and recommended denying the motion, concluding the officer had probable cause and exigent circumstances justified the search. The district court adopted this recommendation, and Davalos entered a conditional guilty plea preserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Fifth Circuit held that the officer’s actions were permissible under the Fourth Amendment. The court found that probable cause and exigent circumstances justified the warrantless search of the car, regardless of curtilage questions, and affirmed the denial of Davalos’s motion to suppress. The judgment of the district court was affirmed. View "United States v. Davalos" on Justia Law

The case centers on a defendant who was convicted by a jury of multiple offenses resulting from his involvement in a shootout with police officers in San Diego. During jury selection, the prosecution exercised a peremptory challenge to remove a prospective juror (Juror 1), who was believed to be a Latina, based on the prosecutor’s belief that she was confused about the concept of intent. The defendant objected, arguing that the peremptory challenge was being used to exclude Hispanic or Latina jurors. The trial court adopted the prosecution’s rationale, found that Juror 1 was confused about intent, and overruled the objection.The Superior Court of San Diego County presided over the trial and issued the challenged judgment, sentencing the defendant to a lengthy prison term. The defendant appealed, asserting that the trial court’s finding about Juror 1’s confusion was unsupported by the record. On appeal, the prosecution argued that the trial court’s factual finding was supported by substantial evidence and that the defendant had forfeited certain arguments for not making more specific objections during trial.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. Applying de novo review as mandated by statute, the appellate court concluded that the record did not support the trial court’s finding that Juror 1 was confused about intent. The court further held that the prosecutor’s justification—juror confusion—was a presumptively invalid reason for a peremptory challenge under section 231.7 of the Code of Civil Procedure, and that the trial court failed to properly confirm the asserted behavior occurred. Because there was no substantial evidence to support the prosecutor’s stated reason, the appellate court held that the judgment must be reversed and remanded for a new trial. View "People v. Aguilar" on Justia Law

A group of individuals traveling through Kansas were stopped by Kansas Highway Patrol (KHP) troopers while driving on interstate highways, primarily I-70. In each instance, the drivers and passengers were from out of state, often driving to or from Colorado, and were stopped for alleged traffic violations. After the initial traffic stop was concluded, troopers used a tactic known as the “Kansas Two-Step”—they would briefly disengage, then reinitiate conversation in an attempt to gain consent for further questioning or searches. These stops often led to extended detentions and searches, but no contraband was discovered. The troopers testified that they considered the drivers’ out-of-state status, travel to or from Colorado, and other factors in developing reasonable suspicion.The individuals sued under 42 U.S.C. § 1983 in the United States District Court for the District of Kansas, alleging violations of their Fourth Amendment rights against unreasonable searches and seizures and their constitutional right to travel. Some plaintiffs also brought damages claims, resulting in jury verdicts in their favor. For their claims for injunctive relief, the district court conducted a bench trial and found that KHP had a pattern and practice of targeting out-of-state drivers and using the Two-Step in a manner violating the Fourth Amendment. The court granted a permanent injunction, requiring changes in KHP’s training, documentation, consent procedures, and supervision.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed whether the plaintiffs had standing for injunctive relief and whether the district court abused its discretion in issuing the injunction. The Tenth Circuit held that the plaintiffs had standing because there was a substantial risk they would be stopped again and that KHP had a pattern of unconstitutional conduct. However, the Tenth Circuit found that the injunction was overly broad regarding the use of a driver’s state of origin and the Two-Step tactic. The court affirmed the injunction in part, reversed it in part, and remanded for further proceedings. View "Shaw v. Smith" on Justia Law

A law enforcement officer stopped the defendant for traffic violations. During the stop, a certified drug detection dog conducted a sniff of the defendant’s vehicle and alerted near the driver’s door. Based on this alert, the officer searched the vehicle and discovered methamphetamine and drug paraphernalia. The defendant was subsequently charged with drug possession offenses. Prior to trial, the defendant moved to suppress the evidence, arguing that the search was unconstitutional because the drug dog’s field alerts over the previous two weeks had resulted in the recovery of drugs only 43% of the time, suggesting the alert was not a sufficiently reliable indicator of the presence of drugs.The District Court of the Third Judicial District, Canyon County, reviewed the suppression motion. The court considered evidence of the dog’s training, certification, and performance in controlled environments, where the dog had demonstrated 100% accuracy. The district court found that the dog’s performance in controlled settings, along with the officer’s explanations for field alerts that did not yield drugs, established the dog’s reliability under the totality of the circumstances. The court denied the motion to suppress, concluding the dog’s alert provided probable cause for the search. The defendant entered a conditional guilty plea, preserving his right to appeal the suppression ruling.On appeal, the Supreme Court of the State of Idaho reviewed whether the district court properly denied the suppression motion. The Idaho Supreme Court held that under the United States Supreme Court decision in Florida v. Harris, proof of a drug dog’s reliability in controlled certification or training programs can provide sufficient reason to trust its alert. The Court concluded that the dog’s field performance alone does not undermine probable cause when the dog’s training and certification are uncontested and reliable, affirming the conviction. View "State v. Barritt" on Justia Law