Justia Constitutional Law Opinion Summaries

In this case, the United States Court of Appeals for the Fourth Circuit reversed and remanded a district court's dismissal of claims brought by Charles Willis Short, the husband and estate administrator of Victoria Christine Short, who died by suicide while in custody at the Davie County Detention Center. Mr. Short filed a lawsuit under 42 U.S.C. § 1983 against several employees of the Davie County Sheriff’s Department, alleging violations of the Fourteenth Amendment for deliberate indifference to Ms. Short’s risk of suicide. The district court dismissed all of Mr. Short's claims, applying a subjective standard for determining deliberate indifference.The Fourth Circuit disagreed with the lower court's application of the subjective standard, relying on the Supreme Court's decision in Kingsley v. Hendrickson, which established an objective standard for determining deliberate indifference in cases involving pretrial detainees. The court decided that pretrial detainees can state a Fourteenth Amendment claim for deliberate indifference to an excessive risk of harm on an objective standard, finding that the allegations in the complaint were sufficient to state a claim under any standard. Therefore, the court reversed the district court’s dismissal of the claims and remanded the case for further proceedings. View "Short v. Hartman" on Justia Law

In a case involving former U.S. President Donald J. Trump, the U.S. Court of Appeals for the District of Columbia Circuit has partially upheld and partially vacated a lower court's order restricting Trump's public statements about the trial. The case stems from Trump being indicted for conspiring to overturn the 2020 presidential election through unlawful means and for obstructing the election’s certification. Trump had posted numerous statements on social media attacking potential witnesses in the case, the judge, and the prosecution team. The lower court issued an order restraining the parties and their counsel from making public statements that "target" the parties, counsel and their staffs, court personnel, and "any reasonably foreseeable witness or the substance of their testimony." On appeal, the District of Columbia Circuit affirmed the order insofar as it prohibited all parties and their counsel from making public statements about known or reasonably foreseeable witnesses concerning their potential participation in the investigation or in the criminal proceeding. The court also upheld the order to the extent it prohibited parties and their counsel from making public statements about counsel in the case other than the Special Counsel, members of the court’s staff and counsel’s staffs, or the family members of any counsel or staff member, if those statements were made with the intent to materially interfere with the trial or with the knowledge that such interference was highly likely to result. However, the court vacated the order to the extent it covered speech beyond these categories. The court found that the order was justified by a sufficiently serious risk of prejudice to an ongoing judicial proceeding, that no less restrictive alternatives would adequately address that risk, and that the order was narrowly tailored to ensure the fair administration of justice while also respecting Trump's First Amendment rights. View "USA v. Donald Trump" on Justia Law

Derrick Durrell Jones, a convicted felon, pleaded guilty to possession of a firearm and appealed his conviction to the United States Court of Appeals for the Fifth Circuit. Jones argued that the law under which he was convicted, 18 U.S.C. § 922(g)(1), was unconstitutional because it violated the Commerce Clause and the Second Amendment. Addressing the Commerce Clause argument, the court stated that their circuit precedent has consistently upheld the constitutionality of § 922(g)(1), and that Jones had not presented any Supreme Court decisions that had expressly overruled this.In response to the Second Amendment argument, the court noted that Jones' challenge came in light of a new test for assessing the constitutionality of a statute under the Second Amendment as set forth by the Supreme Court in New York State Rifle & Pistol Ass’n, Inc. v. Bruen. However, the court pointed out that it had previously held that § 922(g)(1) did not violate the Second Amendment, and a concurring opinion in Bruen had stated that the decision should not cast doubt on prohibitions on the possession of firearms by felons. The court also observed that there was no binding precedent holding that § 922(g)(1) was unconstitutional, and that two other federal circuits have reached conflicting conclusions on the issue.Given these considerations, the court concluded that Jones had failed to demonstrate that the district court’s application of § 922(g)(1) constituted clear or obvious error, and thus affirmed the decision of the lower court. View "USA v. Jones" on Justia Law

In this case, Randon L. Miller, the owner of Sushi Brokers, LLC, a sushi restaurant in Scottsdale, Arizona, was cited and arrested by Scottsdale Police Officer Christian Bailey for violating a COVID-19 emergency executive order prohibiting on-site dining issued by the Arizona Governor. The charges were later dismissed. Miller subsequently brought a lawsuit against Officer Bailey and the City of Scottsdale, alleging constitutional violations including retaliatory arrest in violation of the First Amendment, and false arrest in violation of the Fourth Amendment.The United States Court of Appeals for the Ninth Circuit upheld the district court’s summary judgment in favor of Officer Bailey and the City of Scottsdale. The court held that Officer Bailey had probable cause to arrest Miller under Arizona Revised Statutes § 26-317 for violating the emergency order, given that officers had observed on-site dining at the restaurant and there were prior calls reporting violations. The court also rejected Miller’s argument that the warnings he received prior to the enactment of an executive order requiring notice and an opportunity to comply before any enforcement action did not qualify. The court found that Miller had sufficient notice and opportunity to comply given the challenges presented by the COVID-19 pandemic. View "MILLER V. CITY OF SCOTTSDALE" on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of Darren J. Ackerman’s motion to suppress evidence of firearms discovered in his basement. The police had entered his home on the information that Ackerman had tried to choke his girlfriend, was possibly on drugs, and might be holding their infant daughter hostage. They found him at the bottom of the basement stairs, holding his daughter, and upon arresting and handcuffing him, they performed a protective sweep of the basement, during which they found firearms in a room adjoining the area of his arrest.Ackerman argued that the search was not a valid protective sweep as the rooms searched did not adjoin the place of his arrest. The court, however, determined that the arrest occurred at the bottom of the stairs, where Ackerman first submitted to the officers' authority. The court concluded that the room where the firearms were found immediately adjoined the area at the bottom of the stairs, and thus, the protective sweep complied with the Fourth Amendment.The court followed the "protective sweep" exception to the Fourth Amendment, which allows officers to conduct a quick and limited search of premises, incident to an arrest and conducted to protect the safety of police officers or others. The court used the two-prong test from the Supreme Court case Maryland v. Buie to determine the constitutionality of the protective sweep. The first prong allows officers to look in closets and other spaces immediately adjoining the place of arrest from where an attack could be launched, and the second prong allows officers to search areas where they believe a danger may be present based on articulable facts. View "United States v. Ackerman" on Justia Law

The case involved a group of firearm and ammunition dealers and a business organization who appealed a decision by the United States District Court for the Northern District of New York. The appellants claimed that New York's commercial regulations on the sale of firearms and ammunition violated their customers' Second Amendment rights and that several provisions of New York law conflicted with federal law. Additionally, they claimed they lacked standing to challenge New York’s licensing scheme for semiautomatic rifles, its background-check requirement for ammunition purchases, and its firearm training requirement for concealed-carry licenses. The United States Court of Appeals for the Second Circuit affirmed the district court's decision, holding that the appellants failed to present evidence to support their claims. The court also affirmed that the appellants lacked standing to challenge the regulations as individuals. View "Gazzola v. Hochul" on Justia Law

In a consolidated case before the United States Court of Appeals for the Second Circuit, plaintiffs Ivan Antonyuk, Corey Johnson, Alfred Terrille, Joseph Mann, Leslie Leman, Lawrence Sloane, Jimmie Hardaway Jr., Larry A. Boyd, Firearms Policy Coalition Inc., Second Amendment Foundation Inc., Brett Christian, Micheal Spencer, and His Tabernacle Family Church Inc., sought to challenge certain provisions of New York's Concealed Carry Improvement Act ("CCIA"). The CCIA regulates the public carriage of firearms and includes licensing requirements and prohibitions on carrying firearms in "sensitive" and "restricted" locations. The plaintiffs argued that the provisions violated their First and Second Amendment rights.The court affirmed the preliminary injunction against the enforcement of certain provisions of the CCIA, but vacated the injunction in other respects. Specifically, the court upheld district court's injunctions with respect to the social media disclosure requirement, the application of restricted locations provision to private property open to the general public, and the application of the same provision to Pastor Spencer, the Tabernacle Family Church, its members, or their agents and licensees.However, the court vacated the injunctions in all other respects, concluding that either the district court lacked jurisdiction or that the challenged laws do not violate the Constitution on their face. The court rejected the plaintiffs' challenges to the CCIA's licensing requirements and sensitive locations provisions, holding that the laws did not infringe on the plaintiffs' Second Amendment rights.The court also held that the CCIA's restricted locations provision, which makes it a crime to possess firearms in a "restricted location", did not violate the plaintiffs' First and Second Amendment rights. Instead, the court found the provision to be a reasonable regulation consistent with the Second Amendment's protection of the right to keep and bear arms.The court's decision affirms in part, vacates in part, and remands the case for further proceedings. View "Antonyuk v. Chiumento" on Justia Law

In this case from the Supreme Court of Iowa, the defendant, Stephen Arrieta, a truck driver, was pulled over at a weigh station after his vehicle failed a "PrePass" check. During the stop, an Iowa Department of Transportation officer requested a K-9 unit to conduct a free air sniff of the truck and trailer. The drug dog alerted to the presence of drugs in the sleeper compartment of the cab, and Arrieta admitted to having marijuana inside. Arrieta was subsequently charged with possession of a controlled substance.Arrieta appealed the denial of his motion to suppress the marijuana. His main argument was that the officer unlawfully extended the time of his stop, known as a Level 3 inspection, to allow the K-9 handler to arrive and search his truck. Arrieta cited Rodriguez v. United States, a Supreme Court case that ruled such extensions of traffic stops without reasonable suspicion of criminal activity are unconstitutional.The Supreme Court of Iowa agreed with Arrieta, finding that he was detained longer than necessary to complete the Level 3 inspection, in violation of the Fourth Amendment. The court concluded that the officer had effectively completed his tasks before the arrival of the K-9 unit and that the 25-minute delay until the K-9 unit's arrival was unjustified. As such, Arrieta was improperly detained when the free air sniff occurred, and any evidence obtained as a result of the search should have been suppressed.The court vacated the decision of the Court of Appeals and reversed and remanded the judgment of the district court. View "State of Iowa v. Arrieta" on Justia Law

In 2004, De’Andre Dampier was convicted of a capital murder committed during an auto-dealership robbery when he was 16 years old. He was sentenced to life in prison without parole, which was the only statutory sentence available at the time. In 2012, the United States Supreme Court ruled that imposing mandatory life-without-parole sentences on juveniles violates the Eighth Amendment. Based on this ruling, the Supreme Court of Mississippi granted Dampier’s request to seek post-conviction relief from his life-without-parole sentence. However, before the trial court addressed any of the factors from the US Supreme Court decision, it vacated Dampier’s life-without-parole sentence. Dampier then requested that a jury be convened to decide if he should be sentenced to life with or without parole, but the trial judge denied this request. After a hearing in which the trial judge considered the factors from the US Supreme Court decision, the judge reimposed a sentence of life in prison without parole.The Supreme Court of Mississippi affirmed the decisions of the lower courts, holding that Dampier did not have a statutory right to be sentenced by a jury. The court emphasized that the decision to be made by the trial court was whether Dampier was entitled to post-conviction relief from his life-without-parole sentence, imposed for a crime committed when he was a juvenile. The court also agreed with the lower courts that the trial judge did not err by denying Dampier’s request for jury sentencing. Furthermore, the court agreed with the lower courts that the trial court did not err by ruling that, after a careful consideration of the factors from the US Supreme Court decision, life without parole was an appropriate sentence for Dampier’s crime. View "Dampier v. State of Mississippi" on Justia Law

The United States Court of Appeals for the First Circuit affirmed the convictions of Rafael Cardona Sr. and Isaac Cardona for conspiracy to distribute and possess with intent to distribute cocaine and heroin. Isaac Cardona was also convicted of conspiracy to commit money laundering with intent to promote the carrying on of unlawful activity. The defendants raised several arguments on appeal.Rafael Cardona Sr. argued that his two convictions were multiplicitous in violation of the Double Jeopardy Clause. The court concluded that this argument was not reviewable because it was raised for the first time on appeal and not supported by good cause, as required under Federal Rules of Criminal Procedure 12(b)(3) and 12(c)(3).Isaac Cardona argued that the money laundering statute under which he was charged is unconstitutionally vague. The court determined that this argument was not reviewable because it was not raised before trial, as required by Rule 12(b)(3). Isaac Cardona also argued that there was insufficient evidence to support his money laundering conviction and that the court gave erroneous jury instructions on this charge. The court found sufficient evidence to support the conviction and concluded that the erroneous instructions did not affect his substantial rights.The case arose from surveillance footage, recorded communications between the defendants and other co-conspirators, and other evidence showing that the defendants conspired to distribute cocaine and heroin and that Isaac Cardona conspired to commit money laundering by using the proceeds of cocaine distribution to procure and resell heroin. View "US v. Cardona" on Justia Law