Justia Constitutional Law Opinion Summaries

Pierre Robinson and Derrick Swanson, members of the Evans Mob gang in Chicago, were charged with murdering rival gang members to enhance their status within the gang. Swanson entered a cooperation agreement and pleaded guilty, while Robinson went to trial. At Robinson's trial, his cousin Anise, who had previously identified him as the shooter in a recorded statement and grand jury testimony, claimed memory loss and could not identify him in court. The district court admitted her prior statements as evidence. Robinson was convicted by a jury after a four-day trial.In the United States District Court for the Northern District of Illinois, Robinson was convicted of murder in aid of racketeering and sentenced to life in prison. Swanson, who cooperated with the government, received a 30-year sentence and five years of supervised release. Swanson's sentence included a condition allowing probation officers to search his workplace, which he contested as inconsistent with the oral pronouncement of his sentence.The United States Court of Appeals for the Seventh Circuit reviewed the case. Robinson argued that the admission of Anise's statements violated his Confrontation Clause rights and that his trial counsel was ineffective. The court held that Robinson had an adequate opportunity to cross-examine Anise, thus satisfying the Confrontation Clause. The court also found that Robinson's counsel's performance did not fall below an objective standard of reasonableness. Swanson's challenge to his supervised release condition was rejected, as the written judgment did not contradict the oral pronouncement. The Seventh Circuit affirmed the district court's judgments. View "United States v. Swanson" on Justia Law

Aaron Pulsifer was terminated from his position as Dean of Students and Assistant Principal at Westshore Christian Academy. He subsequently filed a lawsuit against the Academy, alleging various state and federal employment discrimination claims based on race and sex. Pulsifer claimed that his termination was retaliatory, following his complaints about unequal treatment and concerns regarding the school's main funder. The Academy argued that Pulsifer's role involved significant religious functions, invoking the ministerial exception to preclude judicial review of his claims.The United States District Court for the Western District of Michigan granted summary judgment in favor of the Academy. The court held that Pulsifer's position involved important religious duties, thus falling under the ministerial exception, which prevents courts from intervening in employment disputes involving key religious employees. Pulsifer appealed the decision, arguing both procedural and substantive errors.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court found that the district court had properly converted the Academy's motion to dismiss into a motion for summary judgment and provided Pulsifer with a reasonable opportunity to respond. On the substantive issue, the Sixth Circuit agreed with the lower court, holding that Pulsifer's role at the Academy included vital religious duties such as leading devotions, conducting prayers, and guiding students' spiritual development. These responsibilities placed him within the ministerial exception, precluding judicial review of his employment discrimination claims.The Sixth Circuit affirmed the district court's judgment, emphasizing that the ministerial exception applies to employees who perform essential religious functions, regardless of their involvement in secular administrative tasks. View "Pulsifer v. Westshore Christian Academy" on Justia Law

The defendant was found guilty of felony possession of a firearm after a bench trial, having waived his right to a jury trial. The case arose from a traffic stop on December 5, 2020, where the defendant was stopped for driving past a stop bar at a traffic light. During the stop, the defendant refused to provide identification and was subsequently arrested. A search of his vehicle revealed marijuana and a loaded firearm. The defendant challenged the traffic stop, his arrest, and the vehicle search as violations of his Fourth Amendment rights and argued that his conviction was not supported by sufficient evidence.The United States District Court for the Southern District of Ohio denied the defendant's motion to suppress the evidence. The court found that the initial traffic stop was supported by probable cause, the arrest was justified by probable cause, and the vehicle search was permissible under the automobile exception. The court also found sufficient evidence to support the conviction based on the stipulated facts presented during the bench trial.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decisions. The appellate court agreed that the traffic stop was justified by probable cause due to the observed traffic violation. The arrest was deemed lawful based on probable cause for multiple offenses, including driving with a suspended license and refusing to provide identification. The search of the vehicle was upheld under the automobile exception, as the officers had probable cause to believe it contained illegal contraband. The court also found that the defendant's stipulation to all elements of the offense constituted a waiver of his right to challenge the sufficiency of the evidence. The conviction was affirmed. View "United States v. Watson" on Justia Law

In 2022, the City of Sacramento proposed a new storm drainage fee to fund repairs, maintenance, and improvements to its storm drainage system. The fee was calculated based on parcel size and land use, expected to generate approximately $20 million annually, with City-owned properties contributing about $496,000. The City conducted an election, mailing ballots to property owners, including itself, as it owned one percent of the properties. The fee was approved with 22,178 votes in favor and 20,229 against. Without the City's votes, the fee would not have passed.Dessins LLC, a property owner who voted against the fee, filed a petition for writ of mandate and complaint against the City and the City Council, arguing that the City's votes should not have counted. The Superior Court of Sacramento County ruled in favor of the City, concluding that the City was entitled to vote in the election. Dessins then appealed the decision.The California Court of Appeal, Third Appellate District, reviewed the case. The court held that the City, as a property owner of properties subject to the fee, was entitled to vote under article XIII D, section 6, subdivision (c) of the California Constitution. The court found that the plain language of the provision allowed the City to vote and that the City's vote did not subvert the purposes of Proposition 218. The court affirmed the judgment of the lower court, allowing the storm drainage fee to stand. View "Dessins v. City of Sacramento" on Justia Law

Plaintiffs-Appellants Thomas Sheppheard, Tyler Randall, and Adam Perry, on behalf of minor child J.P., filed a class action lawsuit against the Governor of West Virginia and the Acting Cabinet Secretary of the West Virginia Department of Homeland Security. They sought relief under the Eighth and Fourteenth Amendments, alleging unconstitutional conditions of overcrowding, understaffing, and deferred maintenance in West Virginia's prisons, jails, and juvenile centers. They claimed these conditions amounted to deliberate indifference to their health and safety.The United States District Court for the Southern District of West Virginia dismissed the case for lack of standing. The court found that the plaintiffs failed to establish that their injuries were traceable to the actions of the Governor or the Secretary, or that their injuries would be redressed by a favorable decision. The court noted that the issues were largely due to funding decisions by the West Virginia legislature, which was not a party to the suit. The court also highlighted that the Commissioner of the West Virginia Division of Corrections and Rehabilitation, not the Governor or the Secretary, had the authority to address the conditions in the facilities.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal. The appellate court agreed that the plaintiffs lacked standing because they could not show that their injuries were caused by the Governor's or the Secretary's actions. The court also found that the requested relief, such as appropriations and policy changes, could not be granted by the court as it lacked the power to compel the Governor or the Secretary to take such actions. The court emphasized that the plaintiffs' injuries were not redressable through the requested judicial intervention. View "Sheppheard v. Morrisey" on Justia Law

Defendants James Vlha and Travis Schlotterbeck were convicted for conspiring to manufacture firearms for sale without a federal license and for selling a firearm to a felon, respectively. They engaged in manufacturing and selling semiautomatic AR-15 firearms without a license in Bellflower, California, and sold these firearms to undercover agents and a confidential informant believed to be a felon. They were charged under 18 U.S.C. § 922(a)(1)(A) and § 922(d)(1). Defendants moved to dismiss the indictment, arguing the statutes violated the Second Amendment, but the district court denied their motion. They entered conditional pleas and appealed the decision.The United States District Court for the Central District of California denied the defendants' motion to dismiss the indictment. The defendants then entered conditional pleas, preserving their right to appeal the district court's decision. They timely appealed to the United States Court of Appeals for the Ninth Circuit.The United States Court of Appeals for the Ninth Circuit affirmed the convictions. The court held that the Second Amendment does not protect the conduct regulated by 18 U.S.C. § 922(a)(1)(A) because requiring commercial firearm manufacturers to obtain licenses does not meaningfully constrain would-be purchasers from obtaining firearms. The court also held that Schlotterbeck’s facial and as-applied challenges to 18 U.S.C. § 922(d)(1) fail because the prohibition on selling firearms to felons does not meaningfully constrain the possessory rights of felons, who do not have possessory rights under the Second Amendment. The court concluded that the text of the Second Amendment does not cover the conduct regulated by these statutes, and thus, the defendants' constitutional challenges fail. The convictions were affirmed. View "USA V. VLHA" on Justia Law

Law enforcement officers suspected Bandak Wiyual Deng of involvement in a shooting at a park on February 10, 2022. Surveillance video showed an individual matching his characteristics exiting a car with what appeared to be a gun. The car, a black Ford Taurus, lacked a license plate or paper registration tag. A confidential informant recorded a conversation with Deng, where Deng mentioned needing a gun for a funeral and a previous shooting. On the day of the funeral, officers stopped Deng, found marijuana and a gun in his car, and Deng admitted to using drugs and touching the gun.The United States District Court for the Southern District of Iowa upheld the government's peremptory strikes of two prospective jurors and refused to admit parts of Deng's interview with law enforcement. Deng's motion for a judgment of acquittal, arguing that 18 U.S.C. § 922(g)(3) violated the Second Amendment, was denied. The jury convicted Deng.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not clearly err in overruling Deng’s objections to the peremptory strikes, as the government provided race-neutral explanations. The court also found that any potential error in the district court's evidentiary rulings was harmless, given the ample evidence supporting Deng’s conviction. Finally, the court affirmed the denial of Deng’s motion for a judgment of acquittal, rejecting his facial challenge to the constitutionality of 18 U.S.C. § 922(g)(3). The judgment was affirmed. View "United States v. Deng" on Justia Law

The case concerns a defendant who responded to an online advertisement posted by an undercover law enforcement officer posing as a woman offering sexual services, including access to two fictitious underage girls, one purportedly 12 years old. The defendant agreed to meet at a hotel to engage in sexual conduct with the supposed minors and was arrested upon arrival. He was charged with two counts of Sexual Abuse of Children under Montana law, with enhanced penalties based on the alleged ages of the victims.The Thirteenth Judicial District Court, Yellowstone County, denied the defendant’s motion to strike the mandatory sentencing enhancements, which imposed a 25-year parole restriction for offenses involving victims 12 years old or younger. The defendant subsequently pleaded guilty to one count of Attempted Sexual Abuse of Children, reserving the right to appeal the denial of his motion regarding the sentencing enhancement. The court imposed the State’s recommended sentence, including the mandatory enhancement, and dismissed the second count.The Supreme Court of the State of Montana reviewed whether the mandatory minimum sentence enhancement for sexual child abuse applies when the “victim” is a fictitious child created by law enforcement in a sting operation. The court held that the statutory language requiring enhanced penalties based on the age of “the victim” refers to actual, specified child victims, not to fictional or simulated victims. The court concluded that the Legislature’s use of different language in the statute—distinguishing between “a child” in defining the offense and “the victim” in penalty enhancements—demonstrates an intent to limit enhanced penalties to cases involving real children. The Supreme Court reversed the district court’s imposition of the mandatory enhancement and remanded for resentencing under the general penalty provision. View "State v. Schultz" on Justia Law

The case involves Pacific Bell Telephone Company and other utilities suing the County of Napa and the state Board of Equalization for a refund of property taxes and declaratory relief. The utilities argue that from 2018 to 2023, the tax rates used to compute the debt-service component of their property taxes were higher than those applied to other properties, violating the California Constitution's requirement that public utility property be taxed in the same manner as other property.In the lower court, the trial court sustained the respondents' demurrer to the utilities' complaint without leave to amend, based on the precedent set by the Sixth District Court of Appeal in County of Santa Clara v. Superior Court, which held that the California Constitution does not mandate that public utility property be taxed at the same rate as other property. The trial court entered judgment in favor of the respondents.The California Court of Appeal, First Appellate District, reviewed the case. The court affirmed the lower court's decision, agreeing with the reasoning in Santa Clara and another case, Pacific Bell Telephone Co. v. County of Merced. The court concluded that the constitutional provision does not require the same or comparable debt-service tax rates for public utility and nonutility property. The court also rejected the utilities' claim that the tax rates violated the principle of taxation uniformity embodied in the California Constitution. The judgment in favor of the respondents was affirmed. View "Pacific Bell Telephone Co. v. County of Napa" on Justia Law

Darian McKinney, a health and physical education teacher, was employed by the District of Columbia Public Schools (DCPS) for four years. During his tenure, he was investigated for sexual harassment, leading to a grievance he filed against DCPS. Both disputes were resolved through a Settlement Agreement, under which McKinney resigned but was allowed to reapply for teaching positions. However, when he reapplied, DCPS blocked his return, citing a failed background check.McKinney sued the District of Columbia, alleging that DCPS breached the Settlement Agreement by not fairly considering his employment applications and deprived him of property and liberty without due process. The United States District Court for the District of Columbia dismissed his complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Settlement Agreement did not obligate DCPS to fairly consider McKinney’s applications, only to allow him to apply. The court found no basis in the contract’s language or law for McKinney’s demand for fair consideration. Additionally, the court ruled that McKinney did not have a constitutionally protected property interest in his original job, the contingent job offers, or his eligibility for DCPS positions. The court also found that McKinney’s claim of deprivation of liberty without due process was forfeited as it was not raised in the lower court.The court affirmed the district court’s dismissal of McKinney’s complaint. View "Darian McKinney v. DC" on Justia Law