Justia Constitutional Law Opinion Summaries

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

Black Hawk County, Iowa, charges jail inmates daily fees and a booking fee. Rather than pursuing the standard civil reimbursement process, which includes judicial review, the County requires inmates to sign confessions of judgment upon release, acknowledging the debt and agreeing to payment terms. Inmates’ money is seized and applied toward the debt, and the confession allows the County to file for judgment without further judicial review. Leticia Roberts and Calvin Sayers, former inmates who signed these confessions under coercive circumstances, allege that the County’s process deprived them of an opportunity to challenge the jail fees and violated their Fourteenth Amendment due process rights. Roberts made payments out of fear of further enforcement, while Sayers made one payment and had money seized by jail officials.The United States District Court for the Northern District of Iowa dismissed Roberts and Sayers’s claims for lack of standing and failure to state a claim. The district court reasoned that their injury was not traceable to the confession of judgment policy because they would owe jail fees regardless, and any payments were voluntary. The court also denied their motion for a preliminary injunction and leave to amend the complaint.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The Eighth Circuit held that Roberts and Sayers had standing to seek damages and injunctive or declaratory relief, as they plausibly alleged injuries traceable to the County’s policy and a real threat of recurring harm. The appellate court found reasonable inferences that the confessions of judgment were coercive and not voluntary, and that the County’s actions deprived Roberts and Sayers of property without constitutionally adequate process. The Eighth Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "Roberts v. Thompson" on Justia Law

The case involves Bayan Aleksey, who was convicted and sentenced to death for the murder of a South Carolina state trooper during a traffic stop in 1997. After his conviction and sentence were affirmed on direct appeal, Aleksey filed a post-conviction relief application alleging ineffective assistance of counsel, which was denied. Following the United States Supreme Court’s decision in Atkins v. Virginia, establishing that intellectually disabled persons cannot be executed, Aleksey filed a second post-conviction relief application asserting intellectual disability as a bar to execution.The Orangeburg County post-conviction relief (PCR) court held a hearing to determine Aleksey’s intellectual disability. Aleksey submitted five affidavits, including the Hammock affidavit, as evidence of deficits in adaptive functioning. The PCR court excluded the Hammock affidavit because the affiant was unavailable for cross-examination, leaving only non-expert evidence on adaptive functioning. After reviewing IQ scores, expert testimony, and school records, the PCR court found Aleksey failed to prove intellectual disability by a preponderance of the evidence, as his developmental-period IQ scores were above the threshold, his adaptive deficits stemmed from ADHD and emotional disturbance rather than intellectual disability, and no intellectual disability diagnosis manifested during his developmental years.The Supreme Court of South Carolina reviewed whether the PCR court erred in its findings and evidentiary rulings. The Court affirmed the PCR court’s decision, holding that the finding Aleksey is not intellectually disabled was supported by the evidence and not against its preponderance. The Court also found no abuse of discretion in the exclusion of the Hammock affidavit, emphasizing the necessity of cross-examination for contested issues. The PCR court’s denial of relief was therefore affirmed. View "Aleksey v. State" on Justia Law

In this case, a young woman was fatally shot on a Providence street in August 2021 while standing with her boyfriend beside her parked car. The shooting involved a dark sedan that sped by and fired multiple shots, striking the victim. The case remained unsolved for several months until, in December 2021, police stopped a vehicle for traffic violations. The defendant, seated in the rear, was among the occupants. After observing suspicious behavior and a lowered window in inclement weather, officers retraced the vehicle’s route and found a satchel containing a firearm. Forensic testing later matched the gun to shell casings from the murder scene and identified the defendant as the primary DNA contributor. Investigators also obtained incriminating information from an associate of the defendant, including phone communications linking him to the crime.After the defendant was indicted on multiple charges related to the murder and weapon offenses, he filed pretrial motions in Providence County Superior Court to suppress cell phone records obtained via search warrant and DNA evidence from a buccal swab he had consented to during police questioning. Following an evidentiary hearing, the Superior Court denied both motions. At trial, the jury convicted the defendant of most counts, and the trial justice sentenced him to two consecutive life terms plus additional years. The defendant appealed, arguing that the cell phone warrant lacked probable cause and that his consent to the DNA swab was not voluntary.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s judgment. It held that the affidavit supporting the cell phone warrant, when considered in totality, established probable cause. It further held that the defendant’s consent to the buccal swab was voluntary under the totality of the circumstances. The court found no constitutional violations and upheld the convictions. View "State v. Pinkerton" on Justia Law

A man checked into a hotel room in New Jersey in April 2021 and later moved to a larger room, turning in his key for the first room. After the initial room was cleaned, hotel staff discovered two handguns and letters with distinctive handwriting in the room’s safe. Police, notified by the hotel manager, linked the man to the room and discovered he had an outstanding arrest warrant. After a standoff, police arrested the man in his new hotel room. A search warrant was obtained and, upon execution, police found large quantities of various drugs, drug packaging materials, cash, and additional evidence hidden above the room’s ceiling tiles, including drug trafficking paraphernalia and letters matching those previously found.A federal grand jury indicted the man for being a felon in possession of firearms, possessing fentanyl and methamphetamine with intent to distribute, and possessing a firearm in furtherance of a drug-trafficking crime. He moved to suppress the evidence obtained from the hotel room, arguing the search exceeded the warrant’s scope. The United States District Court for the District of New Jersey denied the motion, finding probable cause supported the warrant and, alternatively, the good-faith exception applied. At trial, the court allowed a detective to give lay opinion testimony about drug trafficking based on his experience. The jury found the defendant guilty on all charges, and he was sentenced to 192 months’ imprisonment.On appeal, the United States Court of Appeals for the Third Circuit reviewed three claims: that the search of the ceiling was improper, that improper lay opinion testimony was admitted, and that the court erred in denying a spoliation instruction related to missing body camera footage. The Third Circuit held the search did not violate the Fourth Amendment, the admission of some improper lay opinion testimony was harmless given overwhelming evidence, and the denial of a spoliation instruction was not an abuse of discretion. The court affirmed the convictions and sentence. View "USA v. Evans" on Justia Law

Nathan was emergently detained and subsequently subjected to involuntary commitment proceedings under Wisconsin law after reporting auditory hallucinations that suggested self-harm. During the circuit court hearings, Nathan’s counsel indicated that Nathan was not contesting the commitment or involuntary medication orders, and the court accepted this stipulation after some discussion on the record. Nathan expressed a desire for release but ultimately agreed to the commitment, particularly after assurances regarding his likely discharge timeline.Following entry of the six-month commitment and involuntary medication orders by the Sheboygan County Circuit Court, Nathan filed a post-disposition motion arguing his due process rights were violated because the court did not conduct a colloquy to ensure his stipulation was made knowingly, intelligently, and voluntarily. The circuit court denied this motion. Nathan appealed both the entry of the orders and the denial of his post-disposition motion. The Wisconsin Court of Appeals affirmed the circuit court’s orders.The Wisconsin Supreme Court reviewed whether constitutional due process requires a circuit court to conduct a colloquy before accepting a stipulation to orders for commitment and involuntary medication. The Court held that due process does not require such a colloquy in this context. The absence of a colloquy is not a structural constitutional error; rather, a due process violation would arise only if a waiver of fundamental rights was not entered knowingly, intelligently, and voluntarily. Because Nathan did not otherwise challenge the validity of his waiver, the Supreme Court affirmed the Court of Appeals’ decision. View "Sheboygan County v. N. A. L." on Justia Law