Justia Constitutional Law Opinion Summaries

On December 14, 2021, the Fifth Circuit issued an opinion in this case, upholding the district court's rejection of Plaintiff's challenge to an ATF rule determining that bump stocks are "machineguns" for purposes of the National Firearms Act (NFA) and the federal statutory bar on the possession or sale of new machine guns.However, after a majority of the eligible circuit judges voted in favor of hearing the case en banc, the court vacated its prior opinion so the entire court could hear the case. View "Cargill v. Garland" on Justia Law

In 2018, Cuenca pleaded guilty to false imprisonment of his girlfriend and to a related charge of resisting arrest resulting in serious bodily injury to an officer. The court imposed a split sentence: three years of formal probation plus county jail time that amounted to a single day, net of credit for time served. Two years later, while on probation, Cuenca was charged with assault and criminal threats arising out of a physical altercation with a male friend, A jury found Cuenca guilty of a lesser offense of assault. The court revoked probation and sentenced Cuenca to county jail for an aggregate term running a total of five years and two months for the three felony convictions in both cases. Cuenca pursued consolidated appeals.The court of appeal affirmed the convictions and sentence, rejecting an argument that Napa County’s failure to grant county jail inmates the same opportunities that state prison inmates have to earn rehabilitation program credits violated his constitutional right to equal protection. Napa County need not put forward evidence of the actual reasons justifying its policy choice; the challenged classification is presumed to be rational. View "In re Cuenca" on Justia Law

Alcoa Officers arrested an obviously inebriated Colson following a report that, while driving her SUV, she chased her 10-year-old son in a field and then crashed in a ditch, and transported her to a hospital. Colson then withdrew her consent. to a blood draw. Colson defied repeated orders to get back into the cruiser. During the struggle, an officer's knee touched Colson’s knee, followed by an audible “pop.” Colson started screaming “my fucking knee” but continued to resist. Once Colson was in the cruiser, officers called a supervisor, then took Colson to the jail where a nurse would perform the blood draw. Colson never asked for medical care. At the jail, Colson exited the vehicle and walked inside, with no indication that she was injured. As she was frisked, Colson fell to the ground and said “my fucking knee.” Jail nurse Russell asked Colson to perform various motions with the injured leg and compared Colson’s knees, commented “I don’t see no swelling,” and then left. A week later, Colson was diagnosed with a torn ACL, a strained LCL, and a small avulsion fracture of the fibular head. Colson pleaded guilty to resisting arrest, reckless endangerment, and DUI.Colson sued; only a claim for failure to provide medical care for her knee injury survived. The Sixth Circuit held that the officers were entitled to qualified immunity on that claim. View "Colson v. City of Alcoa" on Justia Law

The First Circuit vacated the judgment of the trial judge denying Defendants' motion for a new trial based on improper comments by the prosecutor, holding that the district court's denial of the new trial motions was plain error.Defendants Edward Canty, III and Melquan Jordan were prosecuted on charges that they had conspired to distribute and possess with intent to distribute both heroin and cocaine base. During their criminal trial, the prosecutor made four types of improper comments during the opening and closing statements and at rebuttal, to which Defendants did not object. After they were convicted Defendants moved for a new trial based on the improper comments by the prosecutor. The trial judge denied the motions under plain error review. The First Circuit vacated the decision below, holding that the fairness, integrity, and public reputation of the proceedings were seriously affected, requiring remand for a new trial. View "United States v. Canty" on Justia Law

A family who owned and operated a medical practice ("Defendants") suffered $25,000 in damages when a pipe in an adjacent office started leaking. The family hired a lawyer ("Plaintiff") to help them compel the neighboring office owner to pay for the damages. When the neighboring office owner refused to pay, Plaintiff recommended they sue. Two of the three family members agreed, but Plaintiff listed all three parties as plaintiffs. Over the course of the litigation, Defendants paid Plaintiff nearly $68,000 in legal fees. Defendants asked Plaintiff to cease all nonessential work on the case while another family member, a barred attorney, attempted to resolve the matter. Plaintiff refused to allow Defendants' family member to help until she formally substituted in and then settled the case.Plaintiff sued Defendants for breach of contract. Defendants cross-claimed that Plaintiff breached his fiduciary duties, committed malpractice and failed to execute a written fee agreement. Plaintiff then filed his own cross-complaint naming Defendants and their family member-lawyer and Defendants filed this SLAPP action to strike portions of Plaintiff's cross-complaint.The trial court granted the family-member lawyer's motion but denied Defendants' motions. On appeal, the Second Appellate District reversed the trial court's denial of the Defendant's SLAPP motions and remanded for the court to determine whether Plaintiff has demonstrated a probability of prevailing on the causes of action against each individual Defendant. View "Bowen v. Lin" on Justia Law

A prisoner who challenges a state’s proposed method of execution under the Eighth Amendment must identify a readily available alternative method that would significantly reduce the risk of severe pain. Nance brought suit under 42 U.S.C. 1983 to enjoin Georgia from executing him by lethal injection, the only method of execution that Georgia now authorizes. Nance proposes death by firing squad—a method currently approved by four other states. The Eleventh Circuit held that Nance could advance his method-of-execution claim only by a habeas petition. The Supreme Court reversed. Section 1983 remains an appropriate vehicle for a prisoner’s method-of-execution claim where the prisoner proposes an alternative method not authorized by the state’s death-penalty statute. Both section 1983 and the federal habeas statute enable a prisoner to complain of “unconstitutional treatment at the hands of state officials.” When a prisoner seeks relief that would “necessarily imply the invalidity of his conviction or sentence,” he must proceed in habeas. Here, Georgia would have to change its statute to carry out Nance’s execution by firing squad, so an order granting relief would not “necessarily prevent” the state from implementing the execution. The state has a pathway forward even if the proposed alternative is unauthorized by present state law. Section 1983 can compel changes to state laws when necessary to vindicate federal constitutional rights. It would be strange to read state-by-state discrepancies into how section 1983 and the habeas statute apply to federal constitutional claims. View "Nance v. Ward" on Justia Law

The State of .New York makes it a crime to possess a firearm without a license. An individual who wants to carry a firearm outside his home may obtain an unrestricted license to “have and carry” a concealed “pistol or revolver” if he can prove that “proper cause exists.” An applicant satisfies the “proper cause” requirement if he can “demonstrate a special need for self-protection distinguishable from that of the general community.” New York residents who unsuccessfully applied for unrestricted licenses to carry a handgun in public based on their generalized interest in self-defense challenged the “proper cause” requirement.The Supreme Court reversed the dismissal of the suit. New York’s "proper cause" requirement violates the Fourteenth Amendment by preventing law-abiding citizens with ordinary self-defense needs from exercising their Second Amendment right to keep and bear arms in public for self-defense. The “historical evidence from antebellum America does demonstrate that the manner of public carry was subject to reasonable regulation, but none of these limitations on the right to bear arms operated to prevent law-abiding citizens with ordinary self-defense needs from carrying arms in public for that purpose.” The Court stated that the "constitutional right to bear arms in public for self-defense is not a second-class right, subject to an entirely different body of rules than the other Bill of Rights guarantees.” The exercise of other constitutional rights does not require individuals to demonstrate to government officers some special need. View "New York State Rifle & Pistol Association., Inc. v. Bruen" on Justia Law

In his trial for assaulting his uncle with a knife, defendant-appellant Shayne Armajo sought to introduce evidence of his uncle’s assaults in order to bolster a self-defense claim. The issue defendant’s appeal presented for the Tenth Circuit’s consideration was whether the district court abused its discretion when it ruled that this was a permissible use under Rule 404(b) but nevertheless excluded most of the proffered evidence under Rule 403 because its probative value was substantially outweighed by the risk of undue prejudice. Evidence of a victim’s prior violent acts may be admissible in a self-defense case to prove the defendant’s state of mind, but it is subject to Rule 403’s balancing test. As applied here, the Court found the district court reasonably concluded that the probative value of the victim’s alleged assaults was substantially outweighed by the risk of unfair prejudice. Consequently, the Court held the district court did not abuse its discretion when it excluded the contested evidence. View "United States v. Armajo" on Justia Law

In March 2017, three North Seattle banks were robbed. Police administered a variety of photomontages to witnesses. Some aspects of the photomontage process complied with best practices generally recognized by new scientific research; some aspects of that process did not; and some aspects of that process fell into a gray area on which the scientific literature was in dispute. Defendant John Stites, a/k/a Christopher Lee Derri, moved to suppress the identifications resulting from those photomontages on federal constitutional grounds; the trial court denied his motion, and he was convicted of all three robberies. The issue this case presented for the Washington Supreme Court’s review asked whether trial courts had to consider new scientific research, developed after the 1977 Manson v. Brathwaite, 432 U.S. 98, decision, when applying that federal due process clause test. To this, the Supreme Court answered yes: courts must consider new, relevant, widely accepted scientific research when determining the suggestiveness and reliability of eyewitness identifications under Brathwaite. Considering this research, the Supreme Court concluded all three of the challenged identification procedures were suggestive. Under the totality of circumstances, however, the identifications were nonetheless reliable. Defendant’s convictions were affirmed. View "Washington v. Derri" on Justia Law

Police received reports of a gunshot fired from the roof of a building. Officers responded to the scene within two minutes, at which point they observed Defendants exiting a building. While officers were not sure which building the shots were fired from, the building Defendants were exiting was in the immediate area. Officers noticed one of the Defendants bladed his body away from them, and both Defendants had their hands in their pockets. When asked to remove their hands from their pockets, Defendants complied. However, at this point, officers noticed a bulge in one of the Defendant's pockets. A passerby informed officers that he had seen Defendants coming down from the building's rooftop. Officers frisked one of the Defendants, recovering a firearm.Defendants entered guilty pleas each to a single count of being a felon in possession of a firearm in violation of 18 U.S.C. Sections 922(g)(1) and 2, preserving their right to appeal the court's adverse decision on their motion to suppress.The Second Circuit affirmed the district court's denial of Defendants' motion to suppress, finding that the police had reasonable suspicion to initiate a pedestrian stop as well as to conduct a pat-frisk of the Defendant who had a bulge in his pocket. View "United States v. Hawkins" on Justia Law