Justia Constitutional Law Opinion Summaries

Michael Lovelace was charged with multiple felonies, including rape and aggravated kidnapping, along with special sentencing enhancements and aggravating factors under California Rules of Court, rule 4.421(c). Lovelace challenged the constitutionality of the rule 4.421(c) residual clause, which allows for consideration of any other factors that reasonably relate to the defendant or the circumstances under which the crime was committed. He argued that this clause violated the separation of powers and due process principles.The trial court denied Lovelace's motion to set aside the information, leading him to seek interlocutory review by petition for a writ of prohibition. The Court of Appeal of the State of California, First Appellate District, Division Four, issued an order to show cause and held oral arguments. Following the Supreme Court's decision in People v. Lynch, which provided guidance on the interpretation and application of Senate Bill 567 amendments to section 1170, subdivision (b)(2), the court took supplemental briefing.The Court of Appeal granted writ relief, holding that the rule 4.421(c) residual clause is unconstitutionally vague and exceeds the Judicial Council’s delegated authority to adopt rules promoting uniformity in sentencing. The court found that the clause grants prosecutors and juries open-ended power to define sentencing criteria on an ad hoc basis, violating the separation of powers clause of the California Constitution. The court directed the trial court to vacate its order denying Lovelace's section 995 motion and to enter a new order sustaining the motion to the extent it seeks to invalidate the residual clause. The court prohibited the trial court from allowing a jury to consider any findings based on the rule 4.421(c) residual clause. View "Lovelace v. Superior Court" on Justia Law

Police stopped Martin Devalois for a traffic violation. During the stop, a drug-sniffing dog alerted to narcotics in Devalois’s rental vehicle. Instead of complying with the police request to exit the car, Devalois initiated a high-speed chase that ended in a crash. Police searched the vehicle and found a small amount of marijuana and a gun. Devalois, a convicted felon, was charged with illegally possessing a firearm. He moved to suppress the gun, arguing that the police unconstitutionally prolonged the traffic stop to conduct the dog sniff. The district court denied his motion, and a jury found him guilty.The United States District Court for the Northern District of Indiana held a suppression hearing where the court found the police officer’s testimony credible and determined that the officer did not extend the length of the stop. The district court denied Devalois’s motion to suppress the gun, and the jury subsequently found him guilty of the firearm charge. Devalois was sentenced to 92 months’ imprisonment and appealed the denial of his motion to suppress.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the district court’s factual finding that the officer did not prolong the traffic stop was not clearly erroneous. The court held that the officer’s actions during the stop were within the mission of the traffic stop and did not unlawfully extend its duration. The court also held that the dog sniff did not violate the Fourth Amendment as it was conducted while the officer was still diligently pursuing the stop’s mission. Consequently, the search of the vehicle and the seizure of the gun were lawful. The Seventh Circuit affirmed the district court’s decision denying Devalois’s motion to suppress the gun. View "United States v. Devalois" on Justia Law

The case involves Shamond Jenkins, who was convicted of robbing a Centier Bank branch in South Bend, Indiana, in December 2020. Jenkins was identified as a suspect in three robberies in northern Indiana between December 2020 and January 2021. During a traffic stop on January 8, 2021, Jenkins was found with cash, including a bait bill from the South Bend robbery, and was wearing red-and-white Air Jordan sneakers similar to those worn by the robber. Jenkins was charged with multiple counts, including the South Bend bank robbery, to which he pleaded not guilty.In the district court, Jenkins was found guilty of the South Bend bank robbery but not guilty of the Granger Centier Bank robbery. The jury could not reach a unanimous decision on the Check Into Cash robbery. Jenkins objected to the Presentence Investigation Report's recommendations, including an enhancement for obstructing justice by presenting false testimony and the inclusion of juvenile adjudications in his criminal history. The district court overruled these objections and sentenced Jenkins to 100 months in prison.The United States Court of Appeals for the Seventh Circuit reviewed Jenkins's appeal. Jenkins argued that the evidence was insufficient to convict him, that his Fifth and Sixth Amendment rights were violated due to the face mask he had to wear during the trial, and that the district court erred in applying a sentencing enhancement for perjury and in counting his juvenile convictions. The Seventh Circuit found no error in the district court's decisions. The court held that the face mask did not render the in-court identifications unduly suggestive or violate Jenkins's confrontation rights. The court also upheld the sufficiency of the evidence and the sentencing decisions, affirming Jenkins's conviction and sentence. View "USA v Jenkins" on Justia Law

A resident of Alaska filed a lawsuit challenging amendments to the State’s predator control program. The resident claimed that after the changes were implemented, she observed a noticeable decrease in the brown bear population at Katmai National Park, where she frequently visited to view bears. She argued that the Board of Game violated its constitutional and statutory duties by not providing adequate notice and opportunities for public input before adopting the changes, which expanded the program to target bears.The Superior Court of Alaska, Third Judicial District, dismissed the complaint, concluding that the resident lacked standing and was not entitled to a declaratory judgment on the validity of the regulatory change. The court also awarded attorney’s fees to the Board of Game and the Commissioner of the Department of Fish & Game.The Supreme Court of the State of Alaska reviewed the case and held that the resident had standing because she demonstrated an injury to her interest in viewing bears at Katmai National Park, which was sufficient to show standing. The court also concluded that she was entitled to a declaratory judgment on the validity of the regulation. The Supreme Court reversed the dismissal of her complaint, vacated the associated award of attorney’s fees, and remanded the case for further proceedings. View "Bittner v. State of Alaska" on Justia Law

Two state senators filed a declaratory judgment action, arguing that Governor Phil Scott exceeded his authority by appointing Zoie Saunders as Secretary of Education on an interim basis without the Vermont Senate's advice and consent. The Governor appointed Saunders after the Senate rejected her initial nomination. The senators contended that the Governor's action bypassed the Senate's constitutional role.The Superior Court, Washington Unit, Civil Division, dismissed the suit on the merits. The court found that the Governor had the constitutional authority to make interim appointments without the Senate's advice and consent. It concluded that the relevant statutes did not apply to interim appointments and rejected the senators' arguments about bad faith and the invalidity of Saunders' actions.The Vermont Supreme Court reviewed the case and found it moot due to subsequent events. In November 2024, the Governor appointed Saunders as Secretary of Education while the Legislature was in recess, and her nomination was later submitted to the Senate for advice and consent. This appointment superseded the earlier interim appointment, rendering the controversy over the April 30 appointment no longer live. The court dismissed the appeal, noting that any opinion on the April 30 appointment would be advisory and that the case did not meet the criteria for the "capable of repetition, yet evading review" exception. View "McCormack v. Scott" on Justia Law

Debbie Mayfield, a former member of the Florida House of Representatives and Florida Senate, sought to run in a special election for Senate District 19 after the incumbent announced his resignation. Mayfield submitted the necessary paperwork to qualify for the ballot, but the Secretary of State and Director of the Division of Elections refused to place her on the ballot, citing a constitutional provision on term limits.The Circuit Court did not review the case. Mayfield directly petitioned the Supreme Court of Florida for writs of mandamus and quo warranto, arguing that the Secretary misinterpreted his authority and failed to fulfill his statutory duty.The Supreme Court of Florida reviewed the case and granted Mayfield's petition for mandamus relief. The court held that Mayfield had a clear legal right to appear on the ballot, as she had met all statutory requirements for qualification. The court found that the Secretary's role in reviewing candidate qualifications is ministerial and does not include the authority to assess a candidate's constitutional eligibility. The court also rejected the Secretary's interpretation of the term-limits provision, concluding that Mayfield's break in service meant she had not served more than eight consecutive years in the Senate. The court ordered the Secretary to place Mayfield on the ballot by a specified deadline and denied the petition for quo warranto as moot. View "Mayfield v. Secretary, Florida Department of State" on Justia Law

The case involves the appeals of Rolando Williamson, Hendarius Archie, Ishmywel Gregory, and Adrien Taylor, who were convicted of various drug distribution and conspiracy charges. Williamson argued that the district court erred in denying his motions to suppress evidence obtained from warrants to search his house and apartment, claiming the use of pole cameras violated the Fourth Amendment. Archie contended that the district court allowed improper opinion testimony from a case agent. Gregory challenged the district court’s findings on the type and amount of drugs attributable to him at sentencing. All defendants questioned the sufficiency of the evidence supporting their conspiracy convictions.The United States District Court for the Northern District of Alabama convicted the defendants on multiple counts. Williamson was sentenced to life imprisonment for several counts, including engaging in a continuing criminal enterprise and conspiracy to distribute drugs. Taylor was convicted of distributing methamphetamine and using a communication facility to commit a drug trafficking crime. Gregory was convicted of distributing cocaine and conspiracy to distribute drugs. Archie was convicted of conspiracy to distribute marijuana and possession of a firearm in furtherance of a drug trafficking crime.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the use of pole cameras did not violate Williamson’s Fourth Amendment rights as they surveilled areas exposed to the public. The court found that the case agent’s opinion testimony did not affect Archie’s substantial rights. The evidence was deemed sufficient to support each defendant’s conspiracy conviction. However, Williamson’s conspiracy conviction was vacated as it was a lesser-included offense of his continuing criminal enterprise conviction. Gregory’s sentence was vacated and remanded for resentencing as it exceeded the statutory maximum. The court affirmed the remaining convictions and sentences. View "United States v. Gregory" on Justia Law

Kein Eastman was abducted at gunpoint from his grandmother’s house by Kenwyn Frazier, taken to an apartment in East St. Louis, and subjected to threats, beatings, and a gunshot over a piece of jewelry. Eastman fled the scene with a bloodied face and has not been seen since. Kenwyn and his brother Kendrick Frazier were charged with kidnapping and found guilty by a jury. They appealed on several grounds, including a violation of Kendrick’s Sixth Amendment right to his choice of counsel, the constitutionality of the federal kidnapping statute, the sufficiency of the evidence, and aspects of their sentencing.The United States District Court for the Southern District of Illinois denied the Fraziers' motion to dismiss the indictment and their post-trial motions for acquittal or a new trial. The court also applied a four-level sentencing enhancement, finding that Eastman sustained permanent or life-threatening bodily injury. Kendrick’s request for joint representation by attorney Beau Brindley was denied due to potential conflicts of interest, and he retained separate counsel.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court found no abuse of discretion in denying Kendrick’s choice of counsel, given the potential for conflicts of interest. The court upheld the constitutionality of the federal kidnapping statute, citing precedent that the use of instrumentalities of interstate commerce, such as cars and cellphones, suffices for federal jurisdiction. The court also found sufficient evidence to support Kendrick’s conviction for aiding and abetting the kidnapping. Lastly, the court affirmed the application of the sentencing enhancement, agreeing that the evidence supported the finding that Eastman sustained a permanent or life-threatening injury. View "United States v. Frazier" on Justia Law

Several members of the public requested records from the Seattle Police Department (SPD) regarding officers who attended the January 6, 2021, rally in Washington, DC. The officers involved filed a lawsuit to prevent the release of their identities, arguing that their identities should be exempt from disclosure based on statutory and constitutional privacy rights. They sought a preliminary injunction to prevent the release of their identities within those public records.The King County Superior Court denied the officers' motion for a preliminary injunction, determining that the officers failed to show that the information in the public records was likely exempt from disclosure. The court also denied the officers' motion to proceed under pseudonyms. The officers appealed, and the Court of Appeals reversed the denial of the preliminary injunction, concluding that the First Amendment prohibited the disclosure of the officers' identities. The Court of Appeals did not evaluate whether the disclosure would violate the officers' statutory right to privacy under the Public Records Act (PRA).The Supreme Court of the State of Washington reviewed the case and held that the officers did not demonstrate a likelihood of success on the merits that their identities were exempt based on either a statutory or constitutional right to privacy. The court concluded that the officers did not have a privacy interest in their identities as public employees who attended a highly publicized event. The court also held that the officers did not show a need to litigate under pseudonyms. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "John Does v. Seattle Police Dep't" on Justia Law

In this case, inmates at the Louisiana State Penitentiary (LSP) filed a class action lawsuit in 2015 against the warden, the Louisiana Department of Public Safety and Corrections, and other officials. The plaintiffs alleged that the defendants were deliberately indifferent to their serious medical needs, violating the Eighth Amendment, the Rehabilitation Act of 1973, and the Americans with Disabilities Act (ADA). The district court bifurcated the case into liability and remedy phases. After an eleven-day bench trial, the court found in favor of the plaintiffs on all claims. Subsequently, a ten-day trial on remedies concluded that the plaintiffs were entitled to permanent injunctive relief, but the court did not specify the relief in its judgment.The United States District Court for the Middle District of Louisiana entered a "Judgment" in favor of the plaintiffs and a "Remedial Order" outlining the appointment of special masters to develop remedial plans. The defendants appealed, arguing that the district court's judgment and remedial order were final and appealable under 28 U.S.C. § 1291 or, alternatively, under 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that the district court had not entered a final decision appealable under 28 U.S.C. § 1291, nor had it entered an injunction appealable under 28 U.S.C. § 1292(a)(1). The appellate court determined that the district court's actions were not final because they contemplated further proceedings, including the appointment of special masters and the development of remedial plans. Consequently, the Fifth Circuit dismissed the appeal for lack of jurisdiction and vacated the stay of the remedial order. View "Parker v. Hooper" on Justia Law