Justia Constitutional Law Opinion Summaries

The case involves a man who was convicted of first-degree murder in Broward County, Florida, after a fatal shooting during a domestic dispute with his girlfriend. The key evidence during trial was a confession obtained by police after the man initially invoked his right to counsel but later agreed to speak with detectives. This confession was not admitted as direct evidence at his second trial but was used extensively to impeach his testimony when he took the stand in his own defense. The prosecution also presented substantial physical and eyewitness evidence, including the testimony of two individuals present at the scene and expert forensic analysis.After his conviction, the defendant challenged the use of his statement in postconviction proceedings. The Florida trial court denied his motion for a new trial, and the Florida Fourth District Court of Appeal affirmed. The defendant later argued in a state postconviction proceeding that his trial counsel was ineffective for failing to challenge the statement on the grounds that it was coerced, in violation of the Due Process Clause. The state postconviction court, adopting the State’s response, found that the defendant was not prejudiced by any alleged error of his counsel, as the other evidence against him was overwhelming. The Fourth DCA affirmed without opinion.The United States Court of Appeals for the Eleventh Circuit reviewed the denial of federal habeas corpus relief. The court held that the state court had adjudicated the prejudice prong of the ineffective assistance claim on the merits, entitling its decision to deference under the Antiterrorism and Effective Death Penalty Act. The Eleventh Circuit found that the state court’s determination—that the outcome would not have been different even if the statement had been excluded—was neither contrary to nor an unreasonable application of federal law. Accordingly, the denial of habeas relief was affirmed. View "Calder v. Secretary, Florida Department of Corrections" on Justia Law

In 2014, Russia invaded and subsequently asserted control over Crimea, an area internationally recognized as part of Ukraine. Ukrainian businesses operating in Crimea—including an electricity distributor and a group of petrol station owners—had their assets seized and operations transferred to Russian-controlled entities without compensation. These businesses, having made investments under Ukrainian law and while the 1998 Agreement Between the Government of the Russian Federation and the Cabinet of Ministers of Ukraine on the Encouragement and Mutual Protection of Investments (“Investment Treaty”) was in effect, pursued arbitration against Russia for expropriation and treaty violations.The Ukrainian companies initiated separate arbitrations under the Investment Treaty’s arbitration clause. The arbitral tribunals found Russia liable for breaches and awarded significant damages to the companies. Russia challenged the arbitral jurisdiction and the awards in foreign courts, but those efforts were unsuccessful. The companies then filed petitions in the United States District Court for the District of Columbia to enforce the awards under the New York Convention and the Federal Arbitration Act. Russia moved to dismiss, arguing the courts lacked subject-matter and personal jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The District Court rejected Russia’s arguments, finding jurisdiction appropriate under the FSIA’s arbitration exception and personal jurisdiction proper upon valid service.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed whether the District Court correctly exercised jurisdiction. The appellate court held that the FSIA’s arbitration exception applied because the companies established the existence of an arbitration agreement, a qualifying arbitral award, and a treaty potentially governing enforcement. The court further held that foreign states are not entitled to the Fifth Amendment’s due process protections against personal jurisdiction. The judgments of the District Court were affirmed. View "Stabil LLC v. Russian Federation" on Justia Law

The defendant pleaded guilty to criminal confinement and interfering with reporting a crime, resulting in a five-year sentence: two years served through time already served and work release, followed by three years of probation. The plea agreement specified that violating any court-sponsored program, such as work release, would result in revocation and execution of the sentence. In 2023, the defendant failed to return to the work release facility, prompting his community corrections case manager to file a petition seeking revocation of his work release placement. The petition, however, did not mention probation or request revocation of the suspended portion of his sentence.After the defendant was later arrested and pleaded guilty to failure to return to lawful detention, the trial court addressed both the work release violation and, upon the State’s oral request, the defendant’s probation. Despite the defendant’s counsel objecting that revoking probation without a specific petition violated due process, the trial court revoked both his work release privileges and his probation, ordering the remainder of his sentence executed in the Department of Correction.On appeal, the Indiana Court of Appeals affirmed the trial court, holding that the court had statutory authority to revoke probation and that due process was satisfied through the plea agreement and the notice provided by the work release revocation petition. The defendant sought further review.The Indiana Supreme Court granted transfer, vacated the Court of Appeals opinion, and reversed the probation revocation. The Court held that due process requires that the State may only seek sanctions identified in the revocation petition or for which the defendant has actual notice. Because there was no petition or adequate notice seeking probation revocation, the trial court’s order revoking probation was improper. View "Ewing v. State" on Justia Law

A Texas-based company distributed files online that enabled the 3D printing of functional, untraceable firearms. After New Jersey’s Attorney General issued a cease-and-desist letter and the state legislature enacted a statute prohibiting the distribution of such files to unlicensed individuals, the company and an affiliated nonprofit restricted New Jersey residents from accessing these files. The plaintiffs challenged the actions, alleging violations of the First, Second, and Fourteenth Amendments.Initially, the plaintiffs filed suit in the Western District of Texas, which dismissed the case for lack of personal jurisdiction. Plaintiffs then filed a similar suit in the District of New Jersey, alleging the statute constituted criminal censorship. After complex procedural maneuvers—including appeals and transfers between Texas and New Jersey, and requests for retransfer—the litigation proceeded in the District of New Jersey, which consolidated the relevant cases.The United States Court of Appeals for the Third Circuit reviewed the District of New Jersey’s decision to dismiss the complaint with prejudice. The Third Circuit affirmed the lower court’s rulings. It held that the district court did not abuse its discretion in denying retransfer to Texas. The court further held that the plaintiffs lacked standing to bring a Second Amendment claim, as there were no allegations that any plaintiff or member was prevented from 3D-printing a firearm. The court also found the statute was not void for vagueness under the Due Process Clause, as it provided fair notice of prohibited conduct. Finally, the court held that plaintiffs failed to plead sufficient facts showing that the computer code at issue was expressive and entitled to First Amendment coverage, as the complaint did not detail the nature or expressive use of the files. The dismissal with prejudice was affirmed. View "Defense Distributed v. Attorney General New Jersey" on Justia Law

A driver was cited for failing to display license plates on his vehicle, an infraction under a municipal ordinance. The matter was transferred from municipal court to the District Court of Stark County for a jury trial. Before trial, the defendant filed multiple motions, including to disqualify both the prosecutor and judge, to continue or stay the proceedings, and to dismiss the case, most of which were denied. Ultimately, a jury found that the defendant had committed the violation. Following these proceedings, the district court designated the defendant as a vexatious litigant, citing his numerous and largely meritless filings. After the jury’s verdict, the defendant appealed the vexatious litigant order to the Supreme Court of North Dakota, arguing that the district court lacked jurisdiction because he claimed the underlying proceeding was criminal, not civil, and further contending that the vexatious litigant designation violated his constitutional rights. He also challenged the district court’s findings, asserting abuse of discretion. The City of Dickinson responded by seeking sanctions, alleging the defendant’s appellate brief cited fictitious cases. The Supreme Court of North Dakota held that the underlying proceeding was a noncriminal infraction under state law, so the district court had jurisdiction to issue a vexatious litigant order under the applicable administrative rule. The Court determined that the district court did not abuse its discretion in designating the defendant a vexatious litigant, finding ample evidence of frivolous and burdensome litigation tactics. The constitutional challenges were rejected, as the vexatious litigant rule provided sufficient procedural safeguards. Additionally, the Court found that the defendant’s use of fictitious case citations warranted sanctions and ordered him to pay $500 to the City. The district court’s vexatious litigant order was affirmed. View "City of Dickinson v. Helgeson" on Justia Law

The case concerns divorced parents who share a minor child. After their 2019 divorce, the mother was awarded primary residential responsibility, with the judgment affirmed on appeal. In 2024, the father moved to modify the custody arrangement, citing a material change in circumstances and seeking joint, and later, primary residential responsibility. Following hearings in 2025, the District Court of Burleigh County granted the father primary residential responsibility, established a parenting plan for the mother, and entered a second amended judgment. The mother appealed, arguing that the district court erred by modifying custody without finding a material change in circumstances, violated her due process rights, improperly delegated authority to the child and a counselor regarding parenting time, and suspended child support without adequate findings. She also asserted cumulative errors and alleged parental alienation. The Supreme Court of North Dakota found that the district court’s findings on the material change of circumstances, best interests factors, and award of primary residential responsibility were not clearly erroneous. The court determined that most of the mother’s arguments were inadequately briefed and thus were not considered on appeal, except for her claim regarding the delegation of parenting time authority. The Supreme Court of North Dakota held that the district court improperly delegated its authority over parenting time to both the minor child and her therapist, allowing them to determine the conditions and occurrence of the mother’s contact with the child. The court found that the district court failed to provide sufficient findings or a clear link between the mother’s conduct and potential harm to the child that would justify such a restriction. The Supreme Court affirmed the judgment in part, reversed it in part, and remanded for further proceedings limited to parenting time. View "Vetter v. Vetter" on Justia Law

A group of residents and an association challenged actions taken by the Harris Ranch Community Infrastructure District No. 1 (CID) in Boise, Idaho. The dispute arose after the CID’s board adopted resolutions in 2021 authorizing payments to a developer for infrastructure projects—such as roadways, sidewalks, and stormwater facilities—and issued a general obligation bond to finance those payments. The residents objected to the projects, arguing they primarily benefited the developer, imposed higher property taxes on homeowners, and allegedly violated the Idaho Community Infrastructure District Act (CID Act) as well as state and federal constitutional provisions. Previously, the District Court of the Fourth Judicial District reviewed the matter after the residents filed a petition challenging the board’s decisions. The district court ruled in favor of the CID and the developer, concluding most of the residents’ claims were either time-barred under the CID Act’s statute of limitations or had been waived because they were not preserved before the CID board. The court also found that the remaining claims failed on their merits, holding that the challenged projects qualified as “community infrastructure,” the stormwater facilities satisfied ownership requirements, and the CID was not the alter ego of the City of Boise. On appeal, the Supreme Court of the State of Idaho affirmed the district court’s decision. The Supreme Court clarified that, given the lack of formal administrative proceedings under the CID Act, the preservation doctrine did not apply to bar the residents’ arguments. Nonetheless, the Supreme Court held that any challenge to the CID’s original formation and the 2010 bond election was time-barred. The court further held that the roadways and stormwater facilities qualified as community infrastructure, the CID’s actions did not violate constitutional requirements regarding taxation or lending of credit, and the CID was not the alter ego of the city. The Supreme Court awarded costs on appeal to the CID and the developer but denied attorney fees to all parties. View "Doyle v. The Harris Ranch Community Infrastructure District No. 1" on Justia Law

Police officers responded to a call about a man, later identified as Xavier Leonard, who was found injured, disoriented, and partially clothed on the ground in a residential neighborhood. Leonard was unresponsive to questions and exhibited signs of being under the influence of drugs. After determining that Leonard lived nearby, officers noticed an open side door at his house and observed signs inside, such as a broken coffee table, that suggested possible violence or distress. The officers announced their presence and, receiving no response, entered the home to check for potential victims or suspects. While inside, they observed drugs and firearms, left after a brief search, and then obtained a search warrant based on their observations.Leonard was charged in the United States District Court for the Eastern District of Texas with firearm and drug offenses. He requested a motion to suppress the evidence obtained from his home. After his initial attorney declined to file the motion, deeming it frivolous, Leonard was appointed new counsel who proceeded with the suppression motion. The magistrate judge recommended granting the motion, finding that the evidence should be excluded. The district court adopted this recommendation and suppressed the evidence.The United States Court of Appeals for the Fifth Circuit reviewed the case after the government appealed. The government did not challenge the Fourth Amendment issue but argued that the exclusionary rule did not apply due to the good faith exception. The Fifth Circuit held that under its “close enough” doctrine, the officers’ actions were objectively reasonable given the circumstances, and the good faith exception precluded exclusion of the evidence. The court reversed the district court’s decision and remanded the case for further proceedings. View "United States v. Leonard" on Justia Law

The case concerns the non-reappointment of a local general registrar of elections in Lynchburg, Virginia. The plaintiff, previously appointed unanimously by a bipartisan electoral board, reapplied for her position after her term expired in 2023. By that time, the board’s partisan makeup had shifted to include two Republicans and one Democrat, reflecting state law. The board interviewed four candidates, including the plaintiff, but ultimately appointed a different candidate who was a registered Republican. The plaintiff, describing herself as an independent, alleged her non-reappointment was due to partisan bias rather than job performance.Following the board’s decision, the plaintiff sued the board and its two Republican members, alleging First Amendment violations tied to political animus. The United States District Court for the Western District of Virginia dismissed the claim against the board itself on sovereign immunity grounds, but allowed the suit against the individual members to proceed. After a jury trial, the verdict favored the defendants. The plaintiff then appealed, raising concerns about jury selection procedures and the exclusion of certain evidence.The United States Court of Appeals for the Fourth Circuit reviewed the appeal. It held that the district court did not abuse its discretion in managing voir dire, including its refusal to allow more pointed questioning about potential jurors’ political affiliations and beliefs. The Fourth Circuit also determined that the plaintiff had not preserved most evidentiary challenges for appellate review, as she failed to make sufficient proffers or obtain definitive rulings on excluded evidence. For the limited evidentiary exclusions properly preserved, the appellate court found no abuse of discretion. Thus, the Fourth Circuit affirmed the judgment in favor of the defendants. View "Gibbons v. Gibbs" on Justia Law

After an undercover police operation responding to an online advertisement for fentanyl, law enforcement negotiated a drug purchase with the defendant using text messages and a Voice Over Internet Protocol (VOIP) phone number. The defendant was identified and apprehended with nearly 1,000 fentanyl pills in his possession, and his cell phone was linked to the communications coordinating the sale. At the time, the defendant was already on probation for a similar drug offense. He ultimately entered a plea of no contest to felony possession of fentanyl for sale, admitting to an enhancement for a large quantity of contraband.The Alameda County Superior Court, following the plea agreement, placed the defendant on two years of formal probation with electronic monitoring. Over defense objection, the court imposed a “five-way” search condition, allowing warrantless searches of his person, property, vehicle, residence, and all electronic devices under his control, including the obligation to provide passwords. The search clause was justified by the court based on the defendant’s use of electronic devices to facilitate drug sales and obscure his identity. The defendant timely appealed, arguing that the electronics search condition was unconstitutionally overbroad and unreasonable.The California Court of Appeal, First Appellate District, Division Two, reviewed the probation condition’s constitutionality and reasonableness de novo. The court found the electronics search clause was neither overbroad nor unreasonable, given the direct involvement of electronic devices in the offense and the defendant’s criminal history. The court also rejected proposals from both the Attorney General and the defense to modify or narrow the condition, concluding that the clause was sufficiently tailored to the facts of the case and necessary for rehabilitation and public safety. The judgment was affirmed, and the search condition was upheld without modification. View "P. v. Flores" on Justia Law