Justia Constitutional Law Opinion Summaries

In 1981, Dennis Sochor murdered Patricia Gifford after she refused his sexual advances; her body was never recovered. Sochor, who had fled the state after seeing himself on television, was apprehended in Georgia five years later and confessed multiple times to the crime. At trial, the jury found him guilty of kidnapping and first-degree murder, recommending a death sentence by a 10-2 vote. The trial court imposed the death penalty, finding four aggravating factors and no mitigating circumstances.On direct appeal, the Supreme Court of Florida affirmed Sochor’s conviction and sentence but was later instructed by the United States Supreme Court to conduct a harmless error analysis regarding one aggravator. After doing so, the Florida court again affirmed. Sochor's conviction and sentence became final in 1993. Since then, he has pursued numerous postconviction challenges in both state and federal courts, all unsuccessful. After the Governor signed a death warrant in June 2026, Sochor filed a sixth successive postconviction motion in the Circuit Court for Broward County, raising two claims: a Brady/Giglio violation concerning a 2022 letter to his brother, and a facial challenge to Florida’s lethal injection protocol. The circuit court summarily denied both claims as untimely, procedurally barred, and without merit.The Supreme Court of Florida reviewed the summary denial de novo and affirmed the circuit court’s ruling. The court held that Sochor’s method-of-execution claim was untimely because the evidence on which it relied had been discoverable since at least 2017, and that the claim was meritless because similar challenges to Florida’s lethal injection protocol had repeatedly been rejected. The court also denied Sochor’s motion for a stay of execution and declined to hold oral argument or entertain a motion for rehearing. View "Sochor v. State" on Justia Law

James Aren Duckett, a police officer, was convicted nearly forty years ago of the sexual battery and first-degree murder of eleven-year-old Teresa McAbee. On the night of May 11, 1987, Duckett was the only officer on patrol in Mascotte, Florida and was the last person seen with Teresa in his patrol car. Circumstantial evidence, including tire tracks and comingled fingerprints from the victim and Duckett on his patrol car, implicated him. Teresa’s body was found the next morning, and a medical examiner determined she had been sexually assaulted, strangled, and drowned. The jury found Duckett guilty and recommended a death sentence, which the trial court imposed after finding aggravating circumstances.Duckett’s conviction and sentence were affirmed by the Supreme Court of Florida in 1990. He subsequently sought postconviction relief several times in both state and federal courts, but all motions and petitions were denied. After a death warrant was signed in 2026, Duckett filed for postconviction DNA testing, which the circuit court granted. He then filed his fifth successive postconviction motion under Rule 3.851, raising claims of actual innocence and alleged constitutional violations. Before DNA testing results were available, the circuit court summarily denied his motion and declined to stay his execution. Duckett appealed and requested a stay, which the Supreme Court of Florida granted to allow completion of DNA testing.The Supreme Court of Florida reviewed the circuit court’s summary denial de novo. Duckett’s DNA testing results were found inconclusive, and his claims of actual innocence and constitutional violations lacked merit under Florida law. The Court affirmed the circuit court’s denial of Duckett’s fifth successive postconviction motion, denied his habeas petition, and lifted the stay of execution. No rehearing would be considered, and the mandate issued immediately. View "Duckett v. State" on Justia Law

Officers responding to reports of suspected drug activity at a public housing development in Asheville, North Carolina, began surveilling individuals frequenting the area. One individual, Jermaine Derrick Carson, Jr., was observed as a passenger in a vehicle whose driver had a suspended license. Weeks later, during a joint law enforcement operation targeting crime near downtown bars, officers recognized the same vehicle at a gas station and initiated a traffic stop before it returned to the housing complex. During the stop, officers detected the odor of marijuana and observed drug paraphernalia in the car. Carson was frisked and found to possess a loaded firearm.After Carson was indicted for possession of a firearm by a convicted felon in the United States District Court for the Western District of North Carolina, he moved to suppress the firearm, arguing that the traffic stop was unlawfully prolonged and that the frisk lacked reasonable suspicion. A magistrate judge held an evidentiary hearing, during which officers testified and body camera footage was reviewed. The magistrate judge recommended denial of the suppression motion, finding the officers had probable cause to search the vehicle after the detection of marijuana and that the frisk was lawful. The district court adopted the recommendation, denied the motion, and subsequently accepted Carson’s conditional guilty plea, sentencing him to 24 months imprisonment.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision, applying de novo review for legal questions and clear error for factual findings. The court held that the officers had independent reasonable suspicion—specifically, the detection of marijuana odor—which justified the extension of the stop and the search. Additionally, the frisk was permissible due to reasonable suspicion of illegal drugs in the vehicle. The Fourth Circuit affirmed the district court’s denial of Carson’s suppression motion. View "US v. Carson" on Justia Law

Kenneth Deal was appointed to the City of Monroe, North Carolina’s board of adjustment, a quasi-judicial municipal body responsible for handling certain appeals and permits. After completing one three-year term, he was reappointed to a second term. However, during this second term, the City Council voted to remove him from the board without cause or prior notice. Deal was not present at the meeting where the removal occurred, nor was he informed that his removal would be considered.Deal filed suit in the United States District Court for the Western District of North Carolina, alleging that the City violated his procedural due process rights when it deprived him of his board seat without notice or an opportunity to be heard. He sought relief under 42 U.S.C. § 1983 and requested a declaratory judgment to void his removal. Deal moved for partial summary judgment on liability, while the City sought summary judgment on all claims. The district court granted summary judgment in favor of the City, concluding that Deal did not have a constitutionally protected property interest in his board seat because the City Council retained discretion to remove board members at any time, with or without cause.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit affirmed the district court’s decision, holding that Deal lacked a constitutionally protected property interest in his seat. The court reasoned that because the City had broad discretion under its code and state law to appoint, remove, or even abolish the board, Deal’s interest in his seat did not amount to a legitimate claim of entitlement protected by the Fourteenth Amendment. The court rejected Deal’s reliance on state cases and found that local discretion was dispositive, affirming the district court’s judgment. View "Deal v. City of Monroe" on Justia Law

A South Carolina budget provision, known as the “Proviso,” prohibits public schools from using state funds to teach certain concepts related to race and sex. Several Black students, the South Carolina State Conference of the NAACP (SC NAACP), and author Ibram Kendi challenged the Proviso, alleging it led to the removal of an Advanced Placement African American Studies (AP AAS) course and one of Kendi’s books from school libraries. The students and SC NAACP asserted that eliminating the AP AAS course infringed upon students’ First Amendment right to receive information, while Kendi claimed the book’s removal constituted viewpoint discrimination. Plaintiffs further alleged that the Proviso was void for vagueness and violated the Equal Protection Clause.The United States District Court for the District of South Carolina dismissed the complaint for lack of Article III standing. The court concluded that the individual students did not allege a concrete injury as they had not actually enrolled in AP AAS, and found that even a student who had enrolled failed to establish that her injury was traceable to the Proviso rather than an unrelated curriculum review. The district court also held that Kendi’s injury was not redressable because the school district cited an alternative, unchallenged rationale for removing his book.The United States Court of Appeals for the Fourth Circuit affirmed in part, reversed in part, vacated in part, and remanded. It affirmed dismissal with respect to a student who had graduated and another who had not taken concrete steps to enroll in AP AAS. However, it held that SC NAACP adequately alleged standing for at least one member with an ongoing injury, and Kendi sufficiently alleged standing for his viewpoint discrimination claim. The court vacated dismissal of other claims and remanded for the district court to address unresolved standing and merits questions. View "South Carolina State Conference of the NAACP v. Weaver" on Justia Law

An inmate at Red Onion State Prison in Virginia, who is a Sunni Muslim, requested accommodations to observe both the Ramadan fast and to maintain a diet prepared according to Jewish Kashrut law, as he sincerely believed both were religious requirements. The prison had an Orthodox Jewish Kosher Diet (OJKD) and a Common Fare menu, but in 2020 could not provide a version of the OJKD that also allowed for Ramadan fasting on short notice. The inmate was offered a choice between maintaining the OJKD without fasting or switching to the Common Fare menu to fast, but with restrictions on switching back. He tried to fast by saving OJKD meals for sunset, but this led to food poisoning. By 2021, the prison had created a Ramadan-compliant OJKD.The United States District Court for the Western District of Virginia granted summary judgment to the prison officials on all claims. The court held that the officials were protected by Eleventh Amendment immunity for damages in their official capacities and found that damages were not available under RLUIPA. The court also found the request for injunctive relief moot after the policy change. The remaining claims for damages under the Constitution were dismissed on qualified immunity grounds, as the court determined the rights were not clearly established or that there was no constitutional violation.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the denial of a discovery motion and agreed that injunctive and declaratory relief were moot, and that summary judgment was proper on the Establishment Clause and Equal Protection claims. However, the Fourth Circuit held that the inmate’s right to a religious diet consistent with his sincerely held beliefs was clearly established and that the district court erred by failing to apply the proper standard to his Free Exercise claim. The court reversed in part, vacated in part, and remanded for the district court to consider whether the failure to accommodate in 2020 was reasonably related to legitimate penological interests under the Turner standard. View "Roberts v. Engelke" on Justia Law

Police officers responded to an anonymous 911 call reporting that individuals inside a white Mercedes sedan parked near the pool area of an apartment complex might be selling or possessing narcotics. The officers received this information through their department’s computer-aided dispatch system. Upon arrival, the officers stopped their marked police vehicles in the roadway, positioning themselves such that one car was partially in front of the Mercedes and another behind. They exited their vehicles, approached the Mercedes, and immediately smelled marijuana. Williams, the defendant, admitted to smoking marijuana, after which he and the other occupants were directed to exit the vehicle. In the ensuing search, officers found a handgun, and Williams admitted ownership.The United States District Court for the Western District of North Carolina denied Williams’ motion to suppress the evidence found during the search. The district court found that Williams was not seized when the officers stopped their cars, reasoning that there was physical room for him to leave and a reasonable person would have felt free to do so. The court further concluded that the officers had reasonable suspicion to seize Williams after smelling marijuana and that the search was supported by probable cause. Williams was subsequently convicted of being a felon in possession of a firearm after a bench trial.On appeal, the United States Court of Appeals for the Fourth Circuit held that Williams was seized for Fourth Amendment purposes when the officers blocked his vehicle with their marked patrol cars, as a reasonable person would not have felt free to leave under the circumstances. The court further held that the officers lacked reasonable suspicion to justify this seizure based solely on the anonymous tip and the fact the encounter occurred in a high-crime area. The court reversed the district court’s denial of the suppression motion, vacated Williams’ conviction, and remanded for further proceedings. View "US v. Williams" on Justia Law

The defendant in this case was arrested following a traffic stop and charged with several offenses, including receiving or transferring a stolen motor vehicle and possession of a controlled substance. He was released on his own recognizance the same day and remained at liberty under court-imposed conditions. More than three years elapsed between his arrest and the district court’s decision on his motion to dismiss for violation of his right to a speedy trial. During this period, delays were attributed to procedural extensions, COVID-19-related jury trial suspensions, and significant systemic backlog in the local court system, which the district court found was exacerbated by prosecutorial policy.The district court, applying the four-factor test from Barker v. Wingo and New Mexico precedent, found that the length of delay was presumptively prejudicial, most of the delay was attributable to the State, and the defendant had adequately asserted his right to a speedy trial. The court also found that the defendant suffered particularized prejudice and alternatively presumed prejudice due to governmental indifference. As a result, the district court dismissed the charges with prejudice. The State appealed.The New Mexico Court of Appeals reversed, finding that the defendant did not show particularized prejudice and that the other Barker factors did not all weigh heavily enough against the State to excuse the absence of such a showing. The Court of Appeals weighed the State’s culpability as only “moderately to heavily” against it and reduced the impact of the defendant’s assertions of his right, viewing them as largely pro forma.The Supreme Court of the State of New Mexico reversed the Court of Appeals, holding that the first three Barker factors—length of delay, reasons for delay, and assertion of the right—each weighed heavily against the State. The Court concluded that, under New Mexico law, when these three factors weigh heavily against the State, a showing of particularized prejudice is not required, and the defendant’s right to a speedy trial was violated. The Court remanded for dismissal with prejudice. View "State v. Schuster" on Justia Law

Two days after a double homicide occurred in Bernalillo County, New Mexico, a vehicle registered in New Mexico was stopped in Wheeler County, Texas, for an equipment violation. The defendant was a passenger in the vehicle. During the stop, the Texas deputy sheriff questioned the driver, who eventually admitted there was marijuana in the car. The deputy conducted a probable cause search, detained the defendant, and discovered a handgun, later linked to the New Mexico homicides.The defendant was indicted in New Mexico on charges related to the homicides and other crimes. He moved to suppress the physical evidence and statements obtained during the Texas stop, arguing the search violated both the U.S. Constitution and Article II, Section 10 of the New Mexico Constitution. The State argued Texas law should govern the admissibility of the evidence, as the search occurred in Texas and was lawful there. The District Court of Bernalillo County disagreed, applying New Mexico’s exclusionary rule and suppressing the evidence, relying on New Mexico cases concerning evidence gathered by federal agents within New Mexico.The Supreme Court of the State of New Mexico reviewed whether the district court correctly applied New Mexico’s constitutional exclusionary rule to evidence obtained in another state, where the search complied with that state’s law but would violate New Mexico’s constitution. The court held that Article II, Section 10 of the New Mexico Constitution governs the admissibility of evidence in New Mexico courts, regardless of whether the evidence was obtained by out-of-state law enforcement in compliance with their own laws. Evidence gathered in violation of Article II, Section 10 is inadmissible in New Mexico courts. The court affirmed the district court’s order suppressing the evidence. View "State v. Causey" on Justia Law

A special education administrator was employed by a Wisconsin state agency that facilitated educational services across multiple school districts. After a couple years, her supervisors, following directives from the Wisconsin Department of Public Instruction, pushed staff to adopt an “equity mindset,” which involved examining personal biases and working to disrupt systems influenced by white supremacy. The administrator disagreed with the perceived ideological requirements and refused to fully embrace the equity mindset, leading to concerns from the Department of Public Instruction, pressure on the agency, and her eventual demotion to a lower-paying job.The administrator filed suit in the United States District Court for the Eastern District of Wisconsin, alleging violations of Title VII and the Equal Protection Clause, claiming discrimination and retaliation based on her race. She also asserted a First Amendment claim, alleging retaliation based on her speech and beliefs. The district court granted summary judgment to the defendants on the Title VII and Equal Protection claims, finding no evidence that race was a motivating factor in her demotion, as the ideological requirements were applied to employees of all races. The court rejected her First Amendment claims regarding her speech and insufficiently pleaded her beliefs-based claim.The United States Court of Appeals for the Seventh Circuit reviewed the case. It affirmed the district court’s summary judgment on the Title VII and Equal Protection claims, holding that no reasonable jury could find her race was the cause of her demotion and that she did not engage in an objectively reasonable protected activity for retaliation purposes. However, the Seventh Circuit determined she adequately pleaded a First Amendment claim based on retaliation for her beliefs and remanded that claim for further proceedings. View "Spengler v Cooperative Educational Service Agency 7" on Justia Law