Justia Constitutional Law Opinion Summaries

A man was arrested without a warrant after taking his three-month-old daughter to the hospital, where doctors suspected abuse. He denied harming the child during initial police questioning. The child died that evening, and an autopsy the next day concluded her death was a homicide due to traumatic brain injury. Two days after his arrest, and at least 64 hours into his warrantless detention, the man waived his Miranda rights and made statements to a detective that included several explanations for his daughter’s injuries, including that he shook her. A magistrate later found probable cause and authorized a criminal complaint.The man was convicted by a jury in the Ingham Circuit Court of felony murder and first-degree child abuse. The Michigan Court of Appeals affirmed his conviction, and the Michigan Supreme Court denied leave to appeal. Years later, the trial court granted the man’s motion for relief from judgment due to ineffective assistance of counsel, leading to a new trial. Before the retrial, the prosecution sought to admit his statements from the prolonged detention. The trial court, following a hearing, ruled the statements were voluntary under the factors from People v Cipriano and thus admissible, despite acknowledging that the man had been detained in violation of the Fourth Amendment under Riverside Co v McLaughlin. The Michigan Court of Appeals denied leave to appeal this ruling.The Michigan Supreme Court held that when an arrestee is detained in violation of the Fourth Amendment’s requirement for a prompt judicial determination of probable cause, any statements made must be excluded unless the prosecution proves the statements were sufficiently attenuated from the unconstitutional detention. Voluntariness under Cipriano is a separate inquiry. The Supreme Court vacated the trial court’s order admitting the statements and remanded for determination under the proper standard. View "People v. Sanders" on Justia Law

A defendant, who was 15 years old at the time of the offense, was convicted in 1988 of first-degree felony murder, armed robbery, and felony-firearm following a bench trial. He received a sentence of life without parole for the murder conviction. After the United States Supreme Court decided in *Miller v. Alabama* that mandatory life without parole sentences for juveniles are unconstitutional, and in *Montgomery v. Louisiana* that this rule applies retroactively, the prosecution moved to reimpose the defendant’s life without parole sentence under Michigan law. At his resentencing hearing, the defendant presented expert psychological evidence suggesting his capacity for rehabilitation, while the prosecution presented no witnesses. The trial court reimposed the life without parole sentence, stating the prosecution did not bear the burden of proof.The Michigan Court of Appeals later vacated the amended sentence after the Michigan Supreme Court held in *People v. Taylor* that the prosecution bears the burden of proof at such hearings. On remand, the prosecution requested that the defendant be compelled to undergo a psychological evaluation by its expert or, alternatively, that the defense’s psychological evidence be excluded. The trial court granted this request, and the Court of Appeals affirmed that decision.The Michigan Supreme Court held that if a defendant intends to introduce expert psychological evidence at a Miller resentencing hearing, the trial court may require the defendant to submit to a psychological examination by a prosecution expert, consistent with the constitutional right against self-incrimination. However, evidence from this compelled examination is admissible only as rebuttal and not during the prosecution's case-in-chief. The court also clarified that the second Miller hearing is a new proceeding and vacated any order incorporating the record from the prior hearing. The case was remanded to the trial court for proceedings consistent with these rulings. View "People v. Black" on Justia Law

Two long-term employees of a township senior center lost their jobs when a newly elected board, led by a candidate from the opposing political party, reorganized the center's leadership structure. The plaintiffs, both Republicans, had campaigned for the losing Republican candidate in the local election. After the incoming Democratic supervisor and board took office, they voted to eliminate the plaintiffs' positions as part of a broader reorganization, creating new roles and appointing others, including one individual who had also supported the Republican candidate.After their terminations, the plaintiffs filed suit in Illinois state court, naming the township and certain officials as defendants. They alleged, among other claims, that their First Amendment rights had been violated because their political activity was a motivating factor in their dismissals. The defendants removed the case to the United States District Court for the Northern District of Illinois. Following partial dismissal of claims, only the First Amendment retaliation and breach of implied contract claims against the township remained. After discovery, the district court granted summary judgment for the township, finding plaintiffs had not shown that their political activity was a motivating factor in the terminations, nor had they rebutted the township's evidence of legitimate reasons for the reorganization.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit held that the plaintiffs had not produced sufficient evidence that their political activity motivated their terminations. The court found that the undisputed evidence showed neither the new supervisor nor the trustees knew of the plaintiffs' political involvement, and there were valid, non-retaliatory reasons for the personnel changes. The court affirmed the district court’s grant of summary judgment for the township. View "Fox v DuPage Township" on Justia Law

A man’s wife called 911 to request a welfare check after her husband threatened to harm himself. The dispatcher relayed to law enforcement that the man had made similar threats in the past, was not acting like himself, and was last known to be at a riverfront house. When the responding officer arrived, he found the man’s vehicle at the property but received no response to repeated knocks and announcements at multiple doors. The officer entered the house several times after announcing himself, ultimately discovering a suicide note and pill bottle. Upon further entry, the officer encountered the man in his bedroom. After a brief exchange in which the man repeatedly ordered the officer to leave, the man retrieved a rifle and advanced toward the officer, ignoring commands to stop. The officer fired, fatally wounding the man.The personal representative of the man’s estate filed suit in South Carolina state court against the responding officer, the county sheriff, and the sheriff’s office, alleging violations of the Fourth Amendment for unlawful entry and excessive force, as well as a claim for failure to train. The case was removed to the United States District Court for the District of South Carolina. The district court granted summary judgment to the defendants on all federal claims, holding that the officer’s entries and use of force were objectively reasonable and that he was entitled to qualified immunity. The court also found no basis for municipal liability and remanded the state-law claims to state court.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officer’s warrantless entries were justified under the emergency aid exception, given the objectively reasonable belief that the man was at risk of serious harm. The court also concluded that the use of deadly force was objectively reasonable under the circumstances. Accordingly, all federal claims were properly dismissed. View "Crosby v. Colleton County Sheriff's Office" on Justia Law

Curtis Whateley, a Virginia resident, applied for a personalized license plate with the characters “FTP&ATF,” intending the message “Fuck the Police & Alcohol, Tobacco, and Firearms.” The Virginia Department of Motor Vehicles (DMV) initially issued the plate but subsequently recalled it after a complaint about its vulgarity and perceived encouragement of violence. Whateley appealed the DMV’s decision through its internal administrative process without success and then filed suit against the DMV Commissioner, arguing that the recall violated his First Amendment rights by restricting his political expression.The United States District Court for the Western District of Virginia granted the Commissioner’s motion to dismiss, finding that the personalized license plate was government speech, not subject to ordinary First Amendment protections. The district court relied primarily on the Supreme Court’s decision in Walker v. Texas Division, Sons of Confederate Veterans, Inc., which held that specialty license plate designs in Texas constituted government speech. The court acknowledged differences between Texas's specialty plates and Virginia's personalized character combinations but determined that Walker supported treating Virginia’s plates as government speech.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit concluded that the personalized character combinations on Virginia’s vanity plates constitute private speech rather than government speech. The court applied the factors outlined in Walker and subsequent Supreme Court cases, finding that the history, public perception, and extent of government control over the messages indicated private expression. Therefore, the Fourth Circuit vacated the district court’s dismissal and remanded the case for further proceedings, holding that Virginia’s regulation of personalized plate messages is subject to First Amendment scrutiny. View "Whateley v. Lackey" on Justia Law

In this matter, the South Carolina Department of Social Services (DSS) received a report in December 2022 alleging that Gerardo Pimienta sexually abused his then-stepdaughter, AP, in August 2020 when she was twelve. AP reported to her mother the next day, but her mother did not inform authorities at the child’s request. In 2023, after AP disclosed the incident to her therapist, DSS initiated proceedings, seeking a finding of abuse and an order placing Pimienta on the Central Registry of Child Abuse and Neglect. At trial, AP testified about the touching, as did her mother and Pimienta, who denied any inappropriate conduct. No physical evidence was presented. The DSS complaint and AP’s testimony differed slightly on details, but AP maintained the abuse occurred.The Family Court for Dorchester County heard the case in February 2025. Pimienta argued that the statutory burden of proof—preponderance of the evidence—was unconstitutional and that DSS failed to prove abuse even under that standard. The family court found AP credible, determined that the preponderance of the evidence supported a finding of sexual abuse, and ordered Pimienta’s placement on the Central Registry. The court also upheld the statutory burden of proof as constitutional. Pimienta appealed directly to the Supreme Court of South Carolina.The Supreme Court of South Carolina affirmed the family court’s order. The Court held that the preponderance of the evidence standard set forth in section 63-7-1650(E) is constitutional in intervention proceedings, distinguishing the case from parental rights termination cases where a higher standard is required. The Court also found that Pimienta failed to show the family court’s factual findings were unsupported by the evidence. The family court’s judgment was affirmed. View "Department of Social Services v. Pimienta" on Justia Law

Federal agents obtained a warrant to search the defendant’s mobile home in Moline, Illinois, for evidence of drug trafficking. The warrant was based on an affidavit describing a lengthy investigation into a drug organization operating between Arizona and the Quad Cities area. Key facts included intercepted packages containing money and drugs, suspicious phone calls linked to the defendant, phone records connecting him to individuals involved in the drug operation, and utility records showing a person of interest lived with him. In addition, agents conducted two searches of trash outside his residence, finding small amounts of discarded marijuana, mail addressed to the defendant and his housemate, vacuum-seal bags, and a shipping box. When agents executed the warrant, they discovered marijuana and over eight hundred grams of methamphetamine.In the United States District Court for the Central District of Illinois, the defendant moved to suppress evidence obtained during the search, arguing the warrant lacked probable cause. The district court acknowledged that the information connecting the defendant’s address to the drug organization was somewhat stale and attenuated, but ultimately found that the marijuana recovered from the trash alone supplied probable cause for the search under United States v. Leonard. The defendant entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the motion to suppress. The court applied a standard giving great deference to the issuing magistrate judge but reviewed legal conclusions de novo. The Seventh Circuit affirmed the denial, holding that officers reasonably relied on the warrant in good faith because the affidavit’s information, taken as a whole, came close enough to establishing probable cause for drug trafficking. The court did not rely solely on the marijuana found in the trash but emphasized the broader context of the ongoing investigation and ties to the defendant’s residence. View "USA v. Jones" on Justia Law

Several individuals arrested in Lancaster County, Pennsylvania, were detained pending trial after cash bail was set at their preliminary arraignments. At these arraignments, which were conducted via video without counsel present, the Magisterial District Judges allegedly imposed bail without considering the defendants’ ability to pay or other required factors under state law. Because they could not afford bail, the plaintiffs remained incarcerated. They brought a class action against four Magisterial District Judges (in their official capacities), Lancaster County, and the Warden of the county prison, alleging violations of their rights to equal protection, due process, and counsel.The United States District Court for the Eastern District of Pennsylvania first dismissed the plaintiffs’ Sixth Amendment claim, holding that the right to counsel attaches at the preliminary arraignment but does not require counsel’s presence at that proceeding, relying on Supreme Court precedent. The District Court later abstained from hearing the equal protection and due process claims under the doctrine established in Younger v. Harris, reasoning that federal intervention would improperly intrude upon ongoing state criminal proceedings and that state courts could address the plaintiffs’ bail-related claims.On appeal, the United States Court of Appeals for the Third Circuit reviewed both rulings. The Third Circuit held that Younger abstention was inappropriate because the plaintiffs did not seek to enjoin ongoing state criminal prosecutions but rather challenged procedures ancillary to those prosecutions—specifically, the process by which bail was set. Therefore, the District Court’s abstention was vacated and the matter remanded for further proceedings on the equal protection and due process claims. However, the Third Circuit affirmed the dismissal of the Sixth Amendment claim, holding that the preliminary arraignment under Pennsylvania law is not a “critical stage” requiring the presence of counsel, even though the right to counsel attaches at that point. View "Hartmann v. Chudzik" on Justia Law

After a major healthcare system filed for bankruptcy in 2024, a Senate committee initiated an investigation to understand the causes. The committee subpoenaed the system’s former CEO, who had overseen its operations, to testify at a hearing about the bankruptcy. The CEO objected, arguing that the committee’s actions—including the subpoena and subsequent contempt proceedings—violated his Fifth Amendment rights, particularly after he formally invoked those rights and refused to appear. The committee nevertheless proceeded, holding hearings and passing both civil and criminal contempt resolutions, with the full Senate adopting the criminal contempt resolution unanimously.The CEO then filed suit in the United States District Court for the District of Columbia against the committee and most of its members, seeking to declare their actions unlawful and to quash the subpoena. He also asked the court to enjoin further punishment for his refusal to testify. The committee moved to dismiss the case, relying on the Speech or Debate Clause of the Constitution, which protects legislative acts from judicial inquiry. The district court agreed, dismissing the case for lack of jurisdiction and denying the CEO’s request for jurisdictional discovery, finding the challenged actions fell squarely within the protected legislative sphere.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court held that the Speech or Debate Clause absolutely barred the suit because the conduct challenged—issuing the subpoena, conducting the hearing, and voting on contempt resolutions—were core legislative acts. The court further determined that the CEO’s invocation of the Fifth Amendment did not deprive these acts of their legislative character, nor did allegations about the senators’ motives create an exception. The court affirmed the district court’s dismissal and its denial of discovery. View "De la Torre v. Cassidy" on Justia Law

The defendant in this case used an encrypted filesharing site to acquire hundreds of videos containing child sexual abuse material (CSAM), which he then uploaded to his Google Drive account and stored on his computer. In October 2020, Google’s automated software identified some of these files as likely CSAM and, following federal law, sent so-called “CyberTip” reports to the National Center for Missing & Exploited Children (NCMEC). NCMEC’s automated system, in turn, forwarded the reports and files to law enforcement, specifically a detective in the Metropolitan Police Department in Washington, D.C. The detective initially viewed some of the CSAM files without a warrant, then consulted a federal prosecutor and sought a warrant to review the files. A magistrate judge, however, advised that no warrant was needed, citing the “private search” doctrine, and the detective proceeded accordingly. Subsequent searches led to further evidence and ultimately to the defendant’s arrest and indictment for possession and transportation of CSAM.The United States District Court for the District of Columbia denied the defendant’s motions to suppress the evidence, reasoning that even if there was a Fourth Amendment violation when the detective first viewed the files without a warrant, suppression was unwarranted under the good-faith exception and independent-source doctrine. The court also rejected the argument that the residential search warrant only permitted seizure, not search, of digital devices. After an eight-day trial, a jury convicted the defendant on multiple counts related to possession and transportation of CSAM. The court further declined to reduce the sentencing offense level as requested by the defendant.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s judgment. The appellate court held that, even assuming a Fourth Amendment violation occurred when the detective viewed the files without a warrant, suppression was not warranted because the government later obtained lawful authority from a magistrate judge and the detective acted in good faith. The court also found the residential search warrant authorized both seizure and search of digital devices and upheld the sentencing determination. View "USA v. Johnson" on Justia Law