Justia Constitutional Law Opinion Summaries

James Mason Heaps, a gynecological oncologist at UCLA, was prosecuted for multiple charges arising from medical examinations involving seven former patients. The allegations included sexual battery by fraud, sexual exploitation, and sexual penetration of an unconscious person during gynecological exams. The jury ultimately convicted Heaps on several counts involving two victims, acquitted him on others, and was unable to reach verdicts on some charges. Sentencing followed with an aggregate prison term of 11 years.The Superior Court of Los Angeles County presided over the trial and subsequent jury deliberations. During deliberations, a note was sent by the jury foreperson expressing concerns that Juror No. 15 lacked sufficient English proficiency to participate and had prematurely decided the case. The judicial assistant, rather than the judge, addressed the note directly with the jurors—speaking in both English and Spanish—without notifying counsel or making a record of the exchanges. Defense counsel was not informed of the note or these communications, and the trial proceeded to verdict. On appeal, the settled statement process included testimony and declarations clarifying the sequence of events, but key details remained unclear.The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the case. It held that the trial court’s failure to notify counsel about the jury’s note and the judicial assistant’s ex parte communications with the jury during deliberations deprived the defendant of his Sixth Amendment right to counsel at a critical stage. The appellate court found that the prosecution had not met its burden to demonstrate, beyond a reasonable doubt, that this constitutional error was harmless. As a result, the judgment was reversed and the case remanded for a new trial. View "P. v. Heaps" on Justia Law

Two individuals, one a Nigerian citizen and another a Jamaican citizen, were held in U.S. immigration detention for extended periods following the completion of criminal sentences or pending immigration proceedings. Both petitioned for writs of habeas corpus in the United States District Court for the Western District of Pennsylvania, challenging their prolonged detention without individualized bond hearings as violations of their Fifth Amendment rights. The District Court granted both petitions, ordered bond hearings, and both individuals were subsequently released on bond.Following their success, each petitioner sought attorneys’ fees and costs under the Equal Access to Justice Act (EAJA). The District Court found that the government’s position in opposing the habeas petitions was not "substantially justified" and awarded fees: $18,224.58 to the Nigerian petitioner and $15,841.60 to the Jamaican petitioner. The government appealed these fee awards to the United States Court of Appeals for the Third Circuit.The United States Court of Appeals for the Third Circuit addressed whether a habeas corpus petition challenging immigration detention under 28 U.S.C. § 2241 qualifies as a “civil action” under the EAJA, thus entitling prevailing parties to attorneys’ fees and costs. The Third Circuit held that such habeas actions are indeed “civil actions” within the meaning of the EAJA, relying on longstanding legal tradition and statutory interpretation. The court further affirmed that the government’s position in the Nigerian petitioner’s case was not substantially justified, due to the lengthy detention without a bond hearing. Accordingly, the Third Circuit affirmed the District Court’s awards of attorneys’ fees and costs to both petitioners. View "Michelin v. Warden Moshannon Valley Correctional Center" on Justia Law

Fourteen children who were removed from their biological parents by New York City officials are the plaintiffs in this case. After their removal, relatives sought certification to become foster or adoptive parents for these children, but their applications were denied due to criminal history or reports of child abuse or mistreatment. The children allege that New York’s certification scheme violates their substantive due process rights to family integrity and freedom from harm, and that procedural due process was violated because they were not given notice or an opportunity to challenge the denial of a relative’s application.The United States District Court for the Eastern District of New York dismissed the complaint. It ruled that the plaintiffs lacked standing, reasoning that most of the children did not have a cognizable injury since they were living with relatives, and others could not trace their separation from relatives to the defendants. The district court also found that the plaintiffs were asserting the rights of third-party relatives rather than their own, and that prudential standing barred their claims. The court did not address the procedural due process claims directly.On appeal, the United States Court of Appeals for the Second Circuit held that the plaintiffs have standing to pursue both substantive and procedural due process claims. The court found that denial of certified placement with a relative constituted a concrete and particularized injury, traceable to the defendants, and redressable by a favorable ruling. The court also determined that the plaintiffs were asserting their own rights, not those of their relatives, and rejected the district court’s prudential standing analysis. However, some claims were deemed moot: two plaintiffs are now in the care of a relative foster parent and another has aged out of foster care. Only one plaintiff has standing to challenge the adoption certification rules. The Second Circuit reversed in part, affirmed in part, and remanded the case for further proceedings. View "B.B. v. Hochul" on Justia Law

Andrew Burgess Gregg was charged with aggravated robbery, attempt to influence a public servant, false reporting, and four habitual criminal counts in Mesa County, Colorado. After a jury convicted him of the substantive offenses, the trial court discharged the jury and scheduled a hearing to determine his habitual criminal status under Colorado’s prior sentencing statute, which required the judge to make such findings. Before that hearing, the United States Supreme Court issued its decision in Erlinger v. United States, holding that facts increasing a sentence under the Armed Career Criminal Act—specifically, whether prior convictions arose from separate criminal episodes—must be determined by a jury, not solely by a judge.Gregg moved to dismiss the habitual criminal counts, arguing that Erlinger rendered Colorado’s statute unconstitutional and that empaneling a new jury would violate the Double Jeopardy Clause. The People opposed, asserting that jeopardy had not yet attached to the habitual counts and that a second jury could properly decide the matter. The Mesa County District Court granted Gregg’s motion, finding it could not empanel a new jury for the habitual counts because jeopardy had attached.The Supreme Court of Colorado reviewed the case in an original proceeding. The court held that Colorado’s former habitual criminal sentencing statute is not facially unconstitutional and can be constitutionally applied by allowing a jury to determine whether prior convictions arose out of separate and distinct episodes, with a judge then reviewing for sufficiency of the evidence. The court also held that the Double Jeopardy Clause does not bar empaneling a second jury to decide habitual criminal counts when the first jury was discharged after adjudicating only the substantive offenses. The Supreme Court made the order to show cause absolute and reinstated Gregg’s habitual criminal charges for jury assessment. View "People v. Gregg" on Justia Law

Law enforcement authorities investigating a graduate student at a university for rape served a search warrant on a major electronic service provider seeking data linked to the student’s university email account. Along with the warrant, the authorities obtained a nondisclosure order (NDO) that prohibited the provider from disclosing the existence of the warrant or the investigation to the target, the university, or others for 90 days. The provider did not contest the restriction as it applied to the target, but sought to modify the NDO so it could inform a trusted contact at the university about the warrant, arguing that doing so would not compromise the investigation and was required under state law and the First Amendment.In the Superior Court of Los Angeles County, the provider’s motion to modify the NDO was denied. The court based its decision on a sealed affidavit supporting the warrant and NDO, finding that several statutory criteria justifying nondisclosure were satisfied. The court also rejected the provider’s proposal to notify a university contact, expressing concern about its lack of jurisdiction over the university and the possibility of unauthorized disclosure. The NDO was later extended, but ultimately lifted after the student was arrested.The California Court of Appeal, Second Appellate District, Division Four, reviewed the provider’s petition for a writ of mandate. The court held that the trial court complied with the California Electronic Communications Privacy Act by making the required findings before issuing the NDO, and that the NDO satisfied strict scrutiny under the First Amendment. The court reasoned that the NDO served a compelling governmental interest in protecting an ongoing criminal investigation and was narrowly tailored, as allowing disclosure to a university contact posed unacceptable risks. The petition for writ of mandate was denied, and each party was ordered to bear its own costs on appeal. View "Microsoft Corp. v. Superior Ct." on Justia Law

Myelicia Rodgers, a clerk at a United States post office in Crestview, Florida, was accused of tampering with and stealing mail while working alone during early morning shifts. After suspicions arose due to complaints about opened mail, the Office of Inspector General conducted an investigation. Rodgers was observed via video and in person engaging in suspicious activities, including taking greeting cards into restricted areas, opening packages, and removing mail. Test letters with cash and gift cards were used in the investigation, some of which went missing, and Rodgers was caught taking and hiding one such letter. Upon being confronted, Rodgers admitted to opening some letters but denied stealing their contents.A grand jury indicted Rodgers on counts of mail tampering and theft by a postal employee. She waived her right to a jury and opted for a bench trial in the United States District Court for the Northern District of Florida. At trial, the government presented multiple witnesses and video evidence. Rodgers did not testify or call any witnesses in her defense. After the prosecution rested, Rodgers moved for a judgment of acquittal, which the district court denied. The district court explicitly informed Rodgers of her right not to testify and assured her that her silence would not be considered in determining guilt. Rodgers’s counsel argued that her silence should not be taken as evidence against her, and the court reiterated that it would base its decision solely on the evidence presented.The United States Court of Appeals for the Eleventh Circuit reviewed whether the district court drew an adverse inference from Rodgers's decision not to testify. The court held that the district court did not consider Rodgers’s silence as evidence of guilt and properly respected her Fifth Amendment rights. Therefore, the Eleventh Circuit affirmed Rodgers’s conviction. View "USA v. Rodgers" on Justia Law

A completed driver reexamination request was submitted to the Department of Motor Vehicles (DMV) by a confidential reporter, prompting the DMV to initiate a review of Richard Louis Brown’s driving qualifications. Brown was notified that he must submit a medical evaluation. His physician, a new provider to Brown, recommended a driving test but did not advise against driving. Following a reexamination, Brown failed a driving test, and his license was suspended. A second hearing officer later reinstated his license, finding no medical basis for the initial suspension and stating that Brown should not have been required to take the tests.Brown filed a petition for writ of mandate in the Superior Court of Sacramento County, seeking disclosure of the reporter’s identity and criminal sanctions against the reporter for alleged false information. The DMV opposed, explaining the confidentiality policy for reporters is intended to promote road safety and prevent retaliatory actions. The trial court denied the petition, applying a public interest balancing test and finding that the interest in maintaining reporter confidentiality outweighed the interest in disclosure. Judgment was entered against Brown, who then appealed.The California Court of Appeal, Third Appellate District, held that due process was not violated by the DMV’s nondisclosure of the reporter’s identity. The court found that the risk of erroneous deprivation was low because the suspension was based on Brown’s failed driving test, not the reporter’s complaint, and Brown received notice and two hearings. The court concluded that neither federal nor California constitutional due process required disclosure of the reporter’s identity under the circumstances and affirmed the superior court’s judgment denying Brown’s petition. View "Brown v. Dept. of Motor Vehicles" on Justia Law

Law enforcement officers responded to a report of an open door at Chad Taylor’s townhouse in Boone County, Kentucky. Inside, they found signs of recently fired gunshots, including bullet holes and spent shell casings. After obtaining search warrants, officers found ammunition and methamphetamine in Taylor’s possession. Taylor admitted to using methamphetamine and exhibited paranoid, erratic behavior, claiming people were watching him. The following day, Taylor was found at his home with a loaded Glock 19, and ballistics matched it to the earlier gunfire. Taylor had prior felony convictions for drug trafficking, intimidation, and misdemeanor domestic battery.A grand jury indicted Taylor for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The United States District Court for the Eastern District of Kentucky initially detained Taylor but later released him on conditions due to his history of substance abuse and the risk he posed. Taylor moved to dismiss the indictment, arguing that the statute was unconstitutional both facially and as applied. The district court denied the motion, finding Taylor dangerous based on his prior convictions, and subsequently sentenced him to 30 months’ imprisonment after he pled guilty but reserved his right to appeal the constitutional issue.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the constitutionality of § 922(g)(1) as applied to Taylor in light of recent circuit precedent. The appellate court held that the dangerousness assessment required for firearm disqualification is distinct from the assessment for pretrial detention. Applying the standard set forth in United States v. Williams, the court found that Taylor’s offense conduct and criminal history—including felony drug trafficking, intimidation, and domestic battery—demonstrated that he was dangerous. The court affirmed the district court’s judgment, holding that § 922(g)(1) is constitutional as applied to Taylor. View "United States v. Taylor" on Justia Law

Several individuals and two retailers challenged California’s statutory scheme regulating switchblade knives, arguing that these laws violate the Second Amendment. The relevant regulations define switchblades as certain knives with blades of at least two inches that open automatically, and prohibit, among other conduct, carrying such knives concealed in public. The plaintiffs brought a facial constitutional challenge, asserting a right to keep and bear switchblades under the Second Amendment.In the United States District Court for the Southern District of California, the judge granted summary judgment in favor of the state. The district court concluded that switchblades are not protected by the Second Amendment because they are not commonly used for self-defense and are considered dangerous and unusual. Although this finding was deemed dispositive, the district court also found that California failed to show its regulations were consistent with the nation’s history and tradition of arms regulation, but nonetheless upheld the law based on the initial analysis.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the summary judgment de novo. Applying the framework from New York State Rifle & Pistol Association v. Bruen, the Ninth Circuit assumed, without deciding, that the Second Amendment’s text covered the plaintiffs’ conduct. At the historical inquiry step, the court held that switchblades are relevantly similar to Bowie knives and other weapons historically regulated due to their association with violence and crime, and that California’s prohibition on concealed carry of switchblades is analogous to longstanding restrictions on the concealed carry of such weapons. The Ninth Circuit therefore affirmed the district court’s judgment, holding that plaintiffs’ facial challenge failed because they could not show that the switchblade regulations are unconstitutional in all their applications. View "Knife Rights, Inc. v. Bonta" on Justia Law

The case involves a defendant who was charged with the first-degree premeditated murder of his former romantic partner, with whom he shared a child. The victim was found dead in their shared residence from a gunshot wound. Surveillance footage and testimony indicated the defendant had access to the residence and was present in the vicinity during the relevant time. He was interviewed by police on the day of the crime, during which he denied leaving his girlfriend’s hotel room the night before and denied owning any guns. The initial trial ended with a hung jury. Before a second trial, the defendant moved to suppress statements made during the police interview, arguing violations of his Fifth Amendment rights.In the Wyandotte District Court, the defendant’s motion to suppress was denied after a hearing. The court found that the pre-Miranda portion of the interview was not custodial and that the defendant’s post-Miranda statement did not constitute an unequivocal invocation of the right to silence. The second trial proceeded, and the jury found the defendant guilty of first-degree murder. He was sentenced to life in prison, prompting this direct appeal.The Supreme Court of the State of Kansas reviewed the case. The court held that the defendant was subjected to a custodial interrogation prior to receiving Miranda warnings, making admission of his pre-Miranda statements erroneous. However, the court determined that the error was harmless because the same statements were properly admitted post-Miranda and supported by other evidence. The court further held that the defendant’s statement after receiving Miranda warnings (“No, ’cause I don’t know where this is going”) was ambiguous and did not clearly invoke his right to remain silent. Therefore, the admission of his post-Miranda statements was not error. The court affirmed the judgment of the district court. View "State v. McCullough " on Justia Law