Justia Constitutional Law Opinion Summaries

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In 1998, Haden pleaded no contest to infliction of corporal injury on a spouse and admitted a special allegation of personal use of a deadly weapon The trial court found true special allegations under the Three Strikes Law and sentenced him to 25 years to life. Haden had two robbery convictions in North Dakota The court of appeal affirmed, finding that the convictions could constitute strikes although the elements of robbery under North Dakota law differed from those under California law. Haden unsuccessfully sought habeas relief several times. In 2015, Haden filed another habeas petition, arguing that under the U.S. Supreme Court’s 2017 “Descamps” decision, the court made improper factual findings when treating the North Dakota convictions as strikes. In 2016, the California Supreme Court denied his petition “without prejudice to any relief … after this court decides” Gallardo. The 2017 Gallardo decision rejected the court's own 2006 “McGee” decision and held that a trial court considering whether to impose a sentence enhancement based on a defendant’s prior conviction may not make factual findings concerning the defendant’s conduct to impose the enhancement. In 2018, Haden filed another habeas petition, arguing the imposition of the North Dakota robberies as strikes contravened Gallardo because the court examined the record to determine the factual nature of those convictions. The court of appeal denied relief. Gallardo does not apply retroactively to Haden’s conviction. View "In re Haden," on Justia Law

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Michael Bettasso was convicted by jury of driving under the influence (DUI) of alcohol causing injury, hit and run driving causing death, driving with a suspended license, and second degree implied malice murder. The jury also found true a great bodily injury enhancement associated with the DUI count. Bettasso was sentenced to a total term of 19 years to life. On appeal, Bettasso challenged the sufficiency of the evidence supporting the second degree murder conviction and also contended the trial court prejudicially erred by failing to instruct the injury on vehicular manslaughter as a lesser included offense of murder. In the published portion of its opinion, the Court of Appeal held that vehicular manslaughter was not a lesser included offense of murder. In the unpublished portion, the Court rejected Bettasso’s substantial evidence challenge, and accordingly affirmed the judgment. View "California v. Bettasso" on Justia Law

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Steven Chambers appealed his conviction entered upon his "Alford" plea to battery with intent to commit a serious felony. Chambers was initially charged with forcible rape against a young woman. Pursuant to I.R.E. 412, Chambers moved to introduce evidence of a purportedly false allegation "N.S." made against a different individual approximately six months after her alleged rape by Chambers. The State objected to the admission of such evidence. After a Rule 412 hearing, the district court excluded evidence of the purportedly false allegation. The Idaho Court of Appeals heard Chambers’ appeal and held that false allegations made after the charged conduct could be admissible. However, the appellate court concluded that Chambers had failed to prove falsity at the Rule 412 hearing. After its review, the Idaho Supreme Court concluded the district court erred when it determined that Rule 412 contained a temporal requirement that the false allegation must precede the events giving rise to the charge. Further, the district court abused its discretion by applying the wrong balancing test. The Supreme Court announced guidelines and procedure for the district court to use on remand to determine whether evidence of the purportedly false allegation was admissible. Judgment of conviction was vacated and the matter remanded for further proceedings. View "Idaho v. Chambers" on Justia Law

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Plaintiff filed a 42 U.S.C. 1983 action against three police officers after plaintiff was shot and seriously injured while he was assisting the police apprehend a fugitive. Plaintiff alleged a section 1983 claim for involuntary servitude under the Thirteenth Amendment to the U.S. Constitution and a violation of substantive due process under the Fourteenth Amendment, as well as claims for negligence, wantonness, failure to train/supervise, and false imprisonment under Alabama state law. In this case, the officers told plaintiff that they would "throw some charges on [him]" if he did not agree to participate in a ruse to capture the fugitive. Plaintiff claimed that the threat of physical violence is what ultimately overcame his will and forced him to participate in the ruse. The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the officers based on qualified immunity, holding that the officers did not violate the Thirteenth or Fourteenth Amendment. Even assuming that there was a constitutional violation, the court held that it was not clearly established at the time that all objectively reasonable officers in their position would have known that what they said to plaintiff violated the Constitution's prohibition against involuntary servitude or its "nebulous" doctrine of substantive due process. Likewise, the court held that the officers are entitled to discretionary-function immunity on the state law claims. View "King v. Pridmore" on Justia Law

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New Jersey and New York agreed more than 50 years ago to enter into the Waterfront Commission Compact. Congress consented to the formation of the Waterfront Commission Compact, under the Compacts Clause in Article I, section 10, of the U.S. Constitution, 67 Stat. 541. In 2018, New Jersey enacted legislation to withdraw from the Compact. To prevent this unilateral termination, the Waterfront Commission sued the Governor of New Jersey in federal court. The district court ruled in favor of the Commission. The Third Circuit vacated. The district court had federal-question jurisdiction over this dispute because the Complaint invoked the Supremacy Clause and the Compact (28 U.S.C. 1331) but that jurisdiction does not extend to any claim barred by state sovereign immunity. Because New Jersey is the real, substantial party in interest, its immunity should have barred the exercise of subject-matter jurisdiction. View "Waterfront Commission of New York Harbor v. Governor of New Jersey" on Justia Law

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Calvin Barnes petitioned the Alabama Supreme Court for a writ of habeas corpus to direct the Mobile Circuit Court to vacate its orders revoking his bail and denying his motion to reinstate his bail. The Supreme Court determined the circuit court erred by basing the revocation on an unsupported and unsubstantiated belief that Barnes intended to delay his trial setting and had become a flight risk, rather than on evidence satisfying the requirements for revocation in Rule 7.5. Furthermore, the circuit court erred in denying Barnes's request to reinstate his pretrial bail -- a right to which he was entitled under the law, regardless of the heinousness of the crime he was accused of committing. Because the Supreme Court determined the circuit court acted beyond its authority, the Supreme Court granted the petition and issued the writ. View "Ex parte Calvin Barnes." on Justia Law

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Following an incident at President Trump's 2019 Social Media Summit involving Appellee Brian Karem, a journalist with a hard pass, and Sebastian Gorka, a Summit attendee, the Press Secretary suspended Karem's pass for thirty days on the ground that his conduct violated "professional journalistic norms." The DC Circuit affirmed the district court's grant of a preliminary injunction enjoining the enforcement of the suspension of Karem's hard pass credentials based on Fifth Amendment due process grounds. The court held that Karem is likely to succeed on his due process claim because, on this record, he lacked fair notice that the White House might punish his purportedly unprofessional conduct by suspending his hard pass for a month. The court also held that the remaining preliminary injunction factors counsel in favor of affirmance where Karem stands to suffer immediate irreparable harm absent an injunction, and the balance of the equities and the public interest factors also favor an injunction. The court limited the scope of the injunction to run only to the Press Secretary, rather than the Press Secretary and the President. View "Karem v. Trump" on Justia Law

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In 1984, petitioner Lionel Scott pleaded guilty to third degree assault in Minnesota and admitted during his plea colloquy that he personally and intentionally pressed a warm or hot iron against his victim's face, inflicting a discernible burn mark that required medical treatment and was still somewhat visible four months later. In 1999, Scott was convicted in California of several sex offenses. The sentencing court imposed a Three Strikes law sentence of 75 years to life based, in part, on the court's finding that Scott's earlier Minnesota conviction constituted a "serious felony" (and therefore a "strike") because Scott "personally used a deadly or dangerous weapon" (the iron) in the commission of the offense. In making this finding, the trial court relied solely on the elements of the Minnesota offense and the plea colloquy establishing the factual basis for Scott's guilty plea. In 2019, Scott petitioned for habeas relief, arguing he was entitled to relief under California v. Gallardo, 4 Cal.5th 120 (2017), which held that a sentencing "court considering whether to impose an increased sentence based on a prior qualifying conviction may not"—consistent with a defendant's Sixth Amendment right to a jury trial—"make disputed findings about 'what a trial showed, or a plea proceeding revealed, about the defendant's underlying conduct.' " The California Supreme Court issued an order to show cause directing the Department of Corrections and Rehabilitation to show why Scott was not entitled to relief pursuant to Gallardo, and why Gallardo should not have applied retroactively on habeas corpus to final judgments of conviction." Persuaded by In re Milton, 42 Cal.App.5th 977 (2019), the Court of Appeal concluded Gallardo did not apply retroactively. Nonetheless, the Court would have concluded Scott was not entitled to relief under Gallardo because the sentencing court based its findings regarding Scott's Minnesota conviction on undisputed facts "admitted by [Scott] in entering [his] guilty plea," a practice expressly permitted by Gallardo. Accordingly, Scott's petition was denied. View "In re Scott" on Justia Law

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The Supreme Court vacated the judgment of the intermediate court of appeals affirming the judgment of the circuit court convicting Defendant of assault in the second degree, holding that Defendant's constitutional right to cross-examine witnesses was violated when the circuit court prevented defense counsel from cross-examining the complainant about a potential source of bias. On appeal, Defendant argued that the circuit court erred in precluding the defense from cross-examining the complainant about disciplinary action the complainant might have faced as a United States Marine for instigating a fight in violation of its code of conduct provisions. Defendant further argued that the court erred in allowing a police officer to testify as to the contents of a security video that recorded the altercation but that had subsequently been destroyed. The ICA affirmed. The Supreme Court reversed, holding that because the defense was prevented from questioning the complainant about a potential source bias, the jury did not have sufficient information from which to make an informed appraisal of the complainant's motives or bias. The Court also provided guidance concerning the admissibility of other evidence as to the contents of a destroyed video recording under Haw. R. Evid. R. 1004 and 403. View "State v. Miranda" on Justia Law

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During the Coronavirus pandemic, Texas Governor Abbott postponed the May 2020 primary runoff elections to July 14; doubled the period for early voting by personal appearance; and declared that election officials would issue further guidance on social distancing and other precautions. The Democratic Party sought injunctive and declaratory relief that those eligible to vote by mail include all “eligible voter[s], regardless of age and physical condition . . . if they believe they should practice social distancing in order to hinder the known or unknown spread of a virus or disease.” The state trial court granted a preliminary injunction; an interlocutory appeal stayed the injunction. Texas Attorney General Paxton issued a statement, indicating that fear of contracting the Virus unaccompanied by a qualifying sickness or physical condition does not constitute a disability under the Texas Election Code for purposes of receiving a ballot by mail. The plaintiffs filed federal claims that Texas’s rules for voting by mail discriminate by age, restrict political speech, are unconstitutionally vague, and that Paxton’s open letter was a threat constituting voter intimidation. The Fifth Circuit denied relief, referring to the district court’s “audacity” in entering a sweeping preliminary injunction, weeks before the election, that requires officials to distribute mail-in ballots to any eligible voter who wants one. The Constitution principally entrusts the safety and the health of the people to politically accountable state officials The spread of the Virus has not given unelected federal judges a roving commission to rewrite state election code. View "Texas Democratic Party v. Abbott" on Justia Law