Justia Constitutional Law Opinion Summaries

Petitioner-appellant Jemere Guillory was convicted in California state court of multiple offenses arising from an investigation into a shooting in San Diego. In Guillory’s direct appeal of his conviction, the state appellate court rejected his argument that his Sixth Amendment right to a public trial had been violated by the alleged exclusion of his family members from the courtroom during jury selection. In subsequent state habeas proceedings, Guillory sought to re-raise this claim, but with new evidence consisting of declarations from two family members who had been excluded from the courtroom, as well as his own declaration. The state court of appeal denied his petition on the state law grounds that it was untimely and that his public trial claim had previously been raised and rejected on the merits. Guillory then sought federal habeas relief under 28 U.S.C. § 2254, but the district court denied the petition. According to the district court, Guillory’s procedural default in his state habeas petition barred any federal review of his Sixth Amendment public trial claim. The Ninth Circuit Court of Appeals agreed that the augmented version of Guillory’s public trial claim presented in his state habeas petition was procedurally defaulted, but the same could not be said of the properly exhausted public trial claim that Guillory presented on his direct appeal in state court. The Court therefore vacated the district court’s order and remanded for further proceedings. View "Guillory v. Allen" on Justia Law

Plaintiff-appellant Amber Machowski was an individual with a disability who used a wheelchair for mobility. Defendant 333 N. Placentia Property, LLC, was the owner of a property in Fullerton, California, on which a business establishment known as City Market Liquor II was located. When Machowski attempted to patronize the store, she encountered architectural barriers that prevented her from making full use and enjoyment of the premises. Machowski sued Defendant, asserting claims under the Americans with Disabilities Act, and the Unruh Civil Rights Act. The complaint sought injunctive relief, statutory damages under the Unruh Act, and reasonable attorney’s fees and costs. After Defendant failed to respond to the complaint, Machowski applied for the entry of default judgment, seeking injunctive relief and statutory damages. Machowski’s application for default judgment did not seek an award of attorney’s fees. Instead, it advised the district court that “plaintiff will separately file a motion for her attorney fees and costs once this application is granted and judgment has been entered.” The district court declined to exercise supplemental jurisdiction over Machowski’s Unruh Act claim, granted default judgment on her ADA claim, ordered injunctive relief, and sua sponte awarded Machowski $1000 in attorney’s fees under Central District of California Local Rule 55-3. Machowski timely appealed the fee award. The Ninth Circuit held that where, as here, a prevailing party advises the district court that it is opting out of the fee schedule and will seek by motion, an award of reasonable attorney's fees, the district court abuses its discretion by disregarding the plaintiff's choice and sua sponte awarding fees under the fee schedule. Accordingly, the fee award was vacated and the matter remanded for further proceedings. View "Machowski v. 333 N. Placentia Property, LLC" on Justia Law

A sheriff’s deputy sexually abused J.T.H.’s 15-year-old son. J.T.H., who also worked in law enforcement, threatened to sue for the abuse. Before long, Spring Cook, a child-welfare investigator, showed up at his door after someone had apparently called the child-abuse hotline and accused J.T.H. (and his wife) of neglect. The parents asked for the case to be reassigned to an investigator from another county, but Cook kept it for herself. Cook ultimately issued a preliminary written finding of neglect. Unsatisfied with the outcome, the parents requested a formal administrative review. Cook was the circuit manager, so she reviewed and upheld her own finding. The second step required Cook, the parents, and their attorney to appear before Missouri’s Child Abuse and Neglect Review Board. Following that meeting, the Board concluded that Cook’s findings of “neglect were unsubstantiated.” The parents sued Cook for allegedly retaliating against them for exercising their First Amendment rights. The magistrate judge, acting by consent of the parties, concluded that neither absolute nor qualified immunity applied. The Eighth Circuit reversed: "the availability of absolute immunity depends on 'the nature of the function performed,' not the type of claim brought. ... So even if there is a general right to be free of retaliation, the law is not clearly established enough to cover the 'specific context of the case': retaliatory investigation. Cook is entitled to qualified immunity for both investigative acts." View "J.T.H. v. Cook" on Justia Law

Isaiah Hammett was killed during the St. Louis Metropolitan Police Department’s (SLMPD) execution of a search warrant at his grandfather’s home. Hammett’s surviving mother and grandfather, Gina Torres and Dennis Torres (Dennis), brought Fourth Amendment excessive force and unlawful seizure claims under 42 U.S.C. § 1983, conspiracy claims under 42 U.S.C. §§ 1983 and 1985, and state law wrongful death and infliction of emotional distress claims against the City of St. Louis and multiple SLMPD officers.The district court denied the City and defendant officers’ motion for summary judgment on these claims, and they appealed. The Eighth Circuit determined it lacked jurisdiction to review the denial of qualified immunity "if at the heart of the argument is a dispute of fact." The Court found that in their essence, defendants' arguments were related to the of the sufficiency of the evidence, and whether certain opinion testimony presented at trial created a genuine issue of fact. To the extent that defendants asserted arguments beyond the scope of the Court's jurisdiction, the Eighth Circuit dismissed their appeal. On the few arguments that remained, the Court reversed the district court's denial of the defendant officers' qualified immunity claims: Dennis was not seized for purposes of the Fourth Amendment; (2) the City could not have conspired with itself through the defendant officers acting within the scope of their employment; and (3) the intracorporate conspiracy doctrine did not apply to § 1983 conspiracy claims. Judgment was dismissed in part, reversed in part, and remanded for further proceedings. View "Torres v. Coats" on Justia Law

Defendant-appellant Caesar Vaca lied to detectives when he told them he had never possessed a gun. He had pleaded guilty to a crime more than 20 years earlier that involved the use of one. The issue presented for the Eighth Circuit Court of Appeals was whether evidence of the prior conviction was admissible. The district court said yes, and the Eighth Circuit affirmed. View "United States v. Vaca" on Justia Law

Herbert Green previously appealed the denial of his motion to suppress drugs and firearms discovered in his apartment during a law enforcement search outside the scope of the police’s warrant. The Eighth Circuit Court of Appeals remanded the case to the district court to make factual findings necessary to determine whether the independent source doctrine supported denial of Green’s motion to suppress. After additional briefing and an evidentiary hearing, the district court found law enforcement would have requested and obtained a federal warrant to search the apartment notwithstanding the protective sweep. Based on this finding, the Eighth Circuit held that the independent source doctrine justified the district court’s denial of suppression. View "United States v. Green" on Justia Law

Defendant Austin Burnett appealed the Vermont criminal division’s order revoking his probation. After review, the Vermont Supreme Court affirmed the court’s determination that defendant violated probation conditions prohibiting him from possessing or using a device with access to the internet or having a social-media account and from possessing or using pornography. However, the Supreme Court reversed the court’s determination that defendant violated a condition governing where he could reside, and remanded for the court to reconsider its disposition without that violation. View "Vermont v. Burnett" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of a panel of the court of appeals affirming Defendant's conviction of possession of more than 3.5 grams of methamphetamine with intent to distribute, possession of a firearm within ten years of a prior felony conviction, and two counts of drug paraphernalia possession, holding that insufficient evidence supported Defendant's firearm possession conviction.On appeal, Defendant raised six allegations of error. The Supreme Court reversed in part, holding (1) the panel erred when it refused to consider for the first time on appeal the legal appropriateness of an intent-to-distribute instruction and the instruction's permissive inference was legally inappropriate, but this error was not prejudicial; (2) Defendant's constitutional challenges failed; (3) there was insufficient evidence to support Defendant's firearm conviction; and (4) Defendant was not entitled to relief on his remaining claims of error. View "State v. Valdez" on Justia Law

Defendant-appellant Manuel Reynoso was convicted by jury on a gun-possession charge and two drug charges. On appeal, Reynoso challenged his convictions on several grounds. On the same day the district court sentenced Reynoso, the U.S. Supreme Court decided Rehaif v. United States, 139 S. Ct. 2191 (2019), which established that the felon-in-possession statute required the government to show not only that the defendant knew he possessed a gun but also that he knew he had previously been convicted of a crime punishable by more than a year of imprisonment. Reynoso contended on appeal that his felon-in-possession conviction had to be overturned due to the government’s failure to make the additional showing Rehaif required. Because Reynoso did not raise that argument in the district court, the Circuit Court of Appeals for the District of Columbia reviewed his claim for only plain error. After the appellate court heard oral argument in this case, the Supreme Court granted review in another case to consider whether a person might be entitled to plain-error relief on appeal in a case involving a Rehaif error, Greer v. United States, 141 S. Ct. 2090 (2021). Greer held that Rehaif errors at trial normally will not qualify as plain errors of a kind warranting relief in appeals from felon-in-possession convictions. In accordance with Greer, the Court of Appeal concluded the district court’s Rehaif error in this case did not amount to plain error. The Court also rejected Reynoso’s other challenges to his convictions, thus affirming the district court. View "United States v. Reynoso" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the circuit court convicting Defendant on the charge of first-degree intentional homicide with use of a dangerous weapon and being a felon in possession of a firearm, holding that Defendant's Sixth Amendment right to counsel was not violated.At issue was whether Defendant's constitutional right to counsel was violated when a jail inmate secretly recorded conversations with Defendant and when the State admitted those recordings into evidence. The court of appeals reversed on grounds of ineffective assistance of counsel, concluding that trial counsel's failure to seek suppression of the recording fell below an objective standard of reasonableness. The Supreme Court reversed, holding that Defendant's Sixth Amendment right to counsel was not violated because Defendant was not acting as a State agent when he recorded his conversations with Defendant. View "State v. Arrington" on Justia Law