Justia Constitutional Law Opinion Summaries

After observing a traffic violation, a sheriff’s deputy attempted to stop a driver who did not immediately pull over, instead proceeding to an apartment complex known for high criminal activity. The deputy observed the driver, who had prior narcotics and weapons convictions, behaving evasively and refusing to answer questions. Both the initial deputy and another responding officer detected the odor of marijuana emanating from the vehicle. During a frisk for weapons, an officer found what was believed to be a marijuana blunt in the driver’s pocket; the driver did not claim it was legal hemp. A subsequent warrantless search of the vehicle uncovered a firearm. The driver was indicted for carrying a concealed weapon and possession of a stolen firearm.In the Superior Court of Forsyth County, the defendant moved to suppress evidence from the searches, arguing that the odor and sight of marijuana could not, in light of the legalization of industrial hemp, provide reasonable suspicion or probable cause. The trial court denied the motion, citing the driver’s failure to stop, the high-crime location, prior convictions, evasive conduct, and the odor of marijuana as sufficient under the totality of the circumstances. The jury found the defendant guilty of carrying a concealed weapon but not guilty of possessing a stolen firearm.The North Carolina Court of Appeals affirmed, holding that the trial court did not err in denying the motion to suppress and that the defendant received a fair trial. On discretionary review, the Supreme Court of North Carolina held that under the totality of the circumstances—including but not limited to the odor of marijuana—officers had reasonable suspicion to frisk the defendant and probable cause to search the car. The odor of marijuana remains a relevant factor despite the existence of legal hemp. The decision of the Court of Appeals was modified and affirmed. View "State v. Rowdy" on Justia Law

The defendant was charged with two counts of assault with a deadly weapon and one count of possession of a firearm by a felon after an incident in which he confronted his former girlfriend and her uncle, brandished a firearm, struck his former girlfriend with the weapon, and fired several shots in their direction, though no one was injured. The defendant, his attorney, and the State entered into written stipulations acknowledging the defendant’s prior felony conviction and that he possessed a firearm during the incident. Both stipulations were discussed and consented to by the defendant in open court through separate colloquies with the trial judge.A jury in Superior Court, Durham County, found the defendant guilty of possession of a firearm by a felon and two counts of misdemeanor assault with a deadly weapon. The trial court sentenced him to consecutive terms. On appeal, the defendant argued that his counsel’s closing argument included an implicit admission of guilt to the firearm charge without his knowing consent, which he claimed was per se prejudicial under State v. Harbison and State v. McAllister. The Court of Appeals, in a divided opinion, found the record did not establish whether the defendant knowingly consented to his attorney’s admission of guilt and remanded for an evidentiary hearing on the issue of consent.The Supreme Court of North Carolina reviewed the case and reversed the Court of Appeals. The Supreme Court held that the defendant expressly consented on the record to the stipulations concerning his prior felony and firearm possession, following thorough colloquies. The Court further found that defense counsel’s actions did not exceed the scope of those stipulations nor did counsel explicitly or implicitly concede guilt beyond what the defendant had authorized. Therefore, the per se ineffective assistance of counsel rule from Harbison and McAllister was not triggered. The judgment of the Court of Appeals was reversed. View "State v. Nunnally" on Justia Law

A patient suffered an injury during knee surgery in March 2022 and, together with his wife, filed a medical malpractice lawsuit against the operating surgeon and the orthopedic clinic in January 2023. Iowa law requires medical malpractice plaintiffs to serve a certificate of merit affidavit within sixty days after the defendant’s answer to the lawsuit. The plaintiffs served a certificate of merit within the deadline. However, the document was not sworn before an authorized officer and did not include the phrase “penalty of perjury” as required by Iowa statutes. Over a year later, the plaintiffs served an amended certificate that met the affidavit requirements, but it was well past the statutory deadline.After the defendants answered and discovery proceeded for more than a year, the defendants moved to dismiss in the Iowa District Court for Polk County, arguing that the timely certificate did not comply with statutory requirements. The district court found that the initial certificate was neither a true affidavit nor a permissible substitute under the relevant statutes. The court also concluded that the late-filed, proper affidavit could not cure the statutory violation because it was not filed within the required sixty days and there was no extension by agreement or motion. The district court dismissed the case.The Iowa Supreme Court reviewed the appeal. It held that substantial compliance with the certificate of merit affidavit requirement means providing either a true affidavit executed before an authorized person or a statement under penalty of perjury within sixty days. The plaintiffs failed to do either within the deadline, and their later submission could not cure the defect. The court also rejected arguments that the defendants had waived the affidavit requirement or that the statutory scheme violated the Iowa Constitution. The decision of the district court was affirmed. View "Rarick v. Smidt" on Justia Law

The case involves a defendant who was alleged to have sexually assaulted a woman near the Red River in Fargo, North Dakota. The prosecution charged him with gross sexual imposition (GSI) by sexual contact, attempted GSI by sexual act, felonious restraint, and preventing arrest. At trial, the victim testified that the defendant forced her to the ground, pulled down her pants, and attempted but failed to penetrate her anus, while also engaging in other sexual contact. The jury was instructed to unanimously agree on the specific acts underlying each charge but was not required to specify which acts supported each conviction. The jury found the defendant guilty on all counts.Following the verdict, the District Court of Cass County sentenced the defendant to concurrent 20-year terms for GSI and attempted GSI, along with additional time for the other convictions. The defendant objected to being sentenced on both GSI and attempted GSI, arguing this constituted double jeopardy because both charges stemmed from the same criminal conduct. The court also declined to award good time credit for pretrial detention, reasoning that the defendant’s conduct while in jail did not merit such credit.On appeal, the Supreme Court of North Dakota reviewed whether the double jeopardy clause was violated and whether the defendant was entitled to good time credit for pretrial detention. The court held that imposing sentences for both GSI and attempted GSI violated the prohibition against double jeopardy, as the convictions could have been based on the same act, and the attempt merged into the completed offense. However, the court held that the defendant was not eligible for good time credit before sentencing. As a result, the Supreme Court of North Dakota vacated the sentence for attempted GSI and affirmed the judgment in all other respects. View "State v. Baker" on Justia Law

The petitioner, a Honduran national, entered the United States in 2010 and was served with a notice of removal for lacking lawful admission or parole. After her first master calendar hearing, she requested and received a transfer to North Carolina. She subsequently retained counsel, who conceded removability and submitted an asylum application. Over several years, her removal proceedings were administratively closed and later reopened at the government’s request, leading to repeated postponements and delays, mostly due to procedural matters and circumstances beyond her control, such as pregnancy and exposure to COVID-19. Just weeks before a key hearing and associated filing deadline, her longtime attorney withdrew, citing lack of cooperation, and the immigration judge allowed this withdrawal without findings or explanation.Following the attorney’s withdrawal, the petitioner sought additional time to secure new counsel, explaining she had only learned of the withdrawal about a month before the hearing and was unable to find an attorney to prepare her case. Despite her objections and the fact this was her first such request, the immigration judge denied her request for a continuance and proceeded with the merits hearing, during which she represented herself. The judge found her testimony not credible and ordered her removal to Honduras. The Board of Immigration Appeals affirmed the judge’s decision, concluding she had “sufficient time to retain counsel” and did not establish a violation of her statutory or due process rights.The United States Court of Appeals for the Fourth Circuit reviewed the Board’s decision and held that the immigration judge violated the petitioner’s statutory right to counsel under the Immigration and Nationality Act by not granting her a reasonable and realistic opportunity to obtain new representation after her attorney’s withdrawal. The court granted the petition for review, vacated the final order of removal, and remanded to the Board to determine whether this violation prejudiced the petitioner. View "Rodriguez-Solis v. Blanche" on Justia Law

Three documents related to a criminal case in Davidson County were filed and sealed without a written order by the presiding judge, who subsequently recused herself. After the case was transferred to a new trial court, a news organization sought to intervene and unseal the documents, which included a motion for judicial disqualification and supporting affidavits. The documents were not listed on the public docket, and the clerk’s office explained that they were marked “Filed Under Seal” by the preparer, but no formal order authorized the seal.The Criminal Court for Davidson County allowed the news organization to intervene but denied its motion to unseal the documents. The trial court found that more compelling interests were at stake, including the risk of publishing unsupported claims, potential embarrassment or burden to involved persons, and possible delays or denials of due process. The court ordered that the documents remain sealed and later issued a separate order citing confidentiality under Supreme Court rules. The news organization then sought review in the Tennessee Court of Criminal Appeals, which denied both an extraordinary appeal and a writ of certiorari, concluding that interlocutory appeal was not available to media intervenors in criminal cases.The Supreme Court of Tennessee granted review to address the availability of interlocutory appeals for media intervenors and the standard for sealing judicial records. The court held that such appeals are available to media intervenors when judicial proceedings are closed or records are sealed. The court further ruled that sealing judicial records protected by the First Amendment requires a written order identifying a compelling interest and that the seal must be narrowly tailored. After conducting a de novo review, the court found no compelling interest justifying the seal and ordered the documents to be made public, reversing the Court of Criminal Appeals. View "State of Tennessee v. Johnson" on Justia Law

An individual was charged with a felony offense in Cook County, Illinois, and as a result, the Illinois State Police suspended his Firearm Owner’s Identification (FOID) card under state and federal law. After the felony charge was dismissed, he successfully appealed to the Illinois State Police for reinstatement of his FOID card. However, before the administrative process concluded, he filed a lawsuit in the circuit court of Randolph County, alleging his constitutional rights were violated by the suspension of his FOID card and seeking its reinstatement, as well as a broad injunction preventing future suspensions based solely on criminal charges.After the plaintiff’s FOID card was reinstated, the defendant argued that the case was moot. Nevertheless, the circuit court denied summary judgment on that ground, invoking the public interest exception to the mootness doctrine. The court then ruled that section 8(n) of the Firearm Owners Identification Card Act was facially unconstitutional to the extent that it authorized suspension or revocation of FOID cards for individuals charged, but not convicted, of felonies. The court issued declaratory and injunctive relief affecting all similarly situated individuals, not just the plaintiff.The Supreme Court of the State of Illinois reviewed the case on direct appeal, vacated the trial court’s judgment, and remanded with directions to dismiss the action. The Supreme Court held that the case was moot because the plaintiff’s FOID card had already been reinstated and no established exception to the mootness doctrine applied. The Court further held that the trial court erred by granting relief beyond the plaintiff’s as-applied claim, improperly expanding the case into a facial constitutional challenge and issuing remedies for nonparties. The Supreme Court expressed no opinion on the underlying constitutional issues. View "Bright v. Yenchko" on Justia Law

A Medicaid recipient in her late 80s, suffering from serious health conditions, applied in 2019 for 24-hour at-home personal care services through New York’s Medicaid program. The state, which provides varying levels of in-home care to eligible Medicaid recipients, partners with private managed long-term care plans (MLTCPs) to assess needs and offer care plans. The plaintiff was initially offered only eight hours of daily care by all MLTCPs she applied to, though she believed she required around-the-clock assistance. Under New York’s regulations, individuals cannot immediately appeal the initial level of care offered; they must first enroll in the plan, request an increase, and only appeal if that request is denied. The plaintiff followed this process and ultimately received 24-hour care after subsequent assessments, but with a delay and a gap in retroactive reimbursement for services.The United States District Court for the Southern District of New York granted summary judgment to the defendants—the State's Health Commissioner and the MLTCP—holding that the plaintiff did not have a cognizable property interest in a particular level of care, and therefore no due process rights were implicated. The court also denied class certification. The plaintiff appealed these decisions.The United States Court of Appeals for the Second Circuit reviewed the case de novo. The Second Circuit disagreed with the District Court’s conclusion regarding the existence of a property interest. It held that New York’s laws, regulations, and practices substantially restrict discretion in determining eligibility for 24-hour personal care services, thereby creating a property interest for qualifying Medicaid recipients and triggering due process protections. However, the court determined that New York’s current appeals procedures, though delayed, are constitutionally adequate because the delay is modest, expedited procedures exist for urgent cases, and the overall private interests at stake are sufficiently protected. On this alternative ground, the Second Circuit affirmed the District Court’s grant of summary judgment to the defendants. View "Bellin v. McDonald" on Justia Law

In this case, the defendant was tried for attempted second-degree murder, first-degree assault, and second-degree assault related to an incident in which the victim was struck multiple times with a metal object, resulting in serious injuries. The first trial ended in a mistrial due to a deadlocked jury. At the second trial, a key witness who had previously testified did not appear, and the State introduced the transcript of this witness’s prior testimony. The defendant’s attorney agreed to the admission of the transcript, and the trial proceeded without the witness’s live testimony.Following conviction and sentencing, the defendant appealed to the Minnesota Court of Appeals. He argued that the district court violated his constitutional right to confront witnesses by admitting the prior testimony without securing a personal, on-the-record waiver of the confrontation right from him, as opposed to a waiver by his attorney. The Minnesota Court of Appeals rejected this argument, holding that any error was not plain because there was no binding authority requiring a defendant’s personal waiver of the confrontation right under these circumstances.The Supreme Court of Minnesota reviewed the case. It held that the district court did not plainly err by admitting the prior testimony without obtaining a personal waiver from the defendant. The court explained that there is no clear or binding legal authority holding that a defendant must personally waive the confrontation right, as opposed to allowing counsel to do so. Because any error by the district court was not “plain” under existing law, the court affirmed the conviction. The Supreme Court of Minnesota thus concluded that, on plain-error review, a district court does not plainly err by accepting counsel’s waiver of the confrontation right for the admission of prior testimony when no binding precedent requires a personal waiver from the defendant. View "State of Minnesota vs. Nelson" on Justia Law

After a fire destroyed a Michigan home in 2017, investigators determined it was intentionally set, focusing their investigation on the homeowner, Steve Karacson. Evidence included the smell of gasoline, multiple fire origins, cell phone location data placing Karacson near the house just before the fire, and a receipt for gas and gloves purchased hours before the incident. Karacson, who had fire insurance, claimed he was out of state but evidence contradicted this. He was subsequently charged with arson and insurance fraud.Following his plea of not guilty, Karacson sought to replace his court-appointed attorney due to disagreements and grievances. The trial court initially denied his request, but his attorney withdrew, and a second attorney was appointed. This relationship also deteriorated, leading Karacson to request self-representation. On the day of jury selection, after warnings from the court about the risks and complexities of self-representation, Karacson affirmed his desire to proceed pro se, with standby counsel available. After a lunch break, he again requested new counsel, which the court denied due to the timing. Karacson proceeded to represent himself, and a jury convicted him on all counts. He received a seven-year sentence.Karacson appealed to the Michigan Court of Appeals, alleging deprivation of counsel, among other claims. The court rejected his arguments, finding that he had knowingly and voluntarily waived his right to counsel and was not entitled to substitute counsel at trial. The Michigan Supreme Court denied leave to appeal and reconsideration. Karacson then petitioned the United States District Court for the Eastern District of Michigan for habeas relief, claiming a Sixth Amendment violation. The district court denied relief, finding the state court’s determination reasonable, but granted a certificate of appealability.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of habeas relief. The court held that under AEDPA’s highly deferential standard, the Michigan appellate court reasonably found Karacson’s waiver of counsel was knowing, intelligent, and voluntary. The court also determined that Karacson was not faced with a choice between unprepared counsel and no counsel, and thus was not deprived of a voluntary waiver. View "Karacson v. Shaver" on Justia Law