Justia Constitutional Law Opinion Summaries

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This case presented the question of whether defendants in criminal cases could have their cases dismissed for lack of jurisdiction because verdicts were rendered or sentences imposed on less than all counts of an indictment or accusation, or one or more counts were “dead- docketed.” The Georgia Supreme Court concluded it did: dead-docketing, while a common and longstanding practice in Georgia courts, had almost no statutory authority and none that would allow different treatment here. "And precedent from our Court of Appeals has for decades made clear that when a count is dead-docketed, the case remains pending in the trial court." Such a case cannot be appealed as a final judgment under OCGA 5-6-34 (a) (1); instead, it required a certificate of immediate review, which Demarquis Seals did not seek. The Supreme Court therefore affirmed the Court of Appeals’ dismissal of his appeal. View "Seals v. Georgia" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals determining that Wisconsin's incapacitated driver provision contained within the implied consent statute, Wis. Stat. 343.305, was unconstitutional, holding that the incapacitated driver provision is unconstitutional beyond a reasonable doubt.The court of appeals determined that the incapacitated driver provision is unconstitutional but additionally determined that the application of the good faith exception to the exclusionary rule allowed for the admission of blood test evidence that Defendant sought to suppress. The Supreme Court agreed with the judgment of the court of appeals, holding (1) the incapacitated driver provision is unconstitutional beyond a reasonable doubt; and (2) the good faith exception to the exclusionary rule applied under the facts of this case, and the evidence resulting from Defendant's blood draw need not be suppressed. View "State v. Prado" on Justia Law

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The Supreme Court conditionally affirmed Defendant's drug-related convictions, second offense, holding that, consistent with this Court's opinion in State v. Wright, __ N.W.2d __ (Iowa 2021), filed today, law enforcement officers conducted an unreasonable seizure and search when they seized and searched garbage bags left out for collection without first obtaining a warrant.On appeal, Defendant argued that two sheriff's deputies violated his federal and state constitutional rights to be free from unreasonable searches and seizures when they seized and searched a trash bag outside Defendant's residence without first obtaining a warrant. The Supreme Court agreed, holding that remand was required in order for the district court to hold a hearing on Defendant's motion to suppress evidence without consideration of the evidence and information obtained during a trash pull used to support their warrant application. View "State v. Hahn" on Justia Law

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The Supreme Court rejected Defendant's constitutional challenge to Iowa Code 321J.16 and joining the majority of courts holding that it is not an unconstitutional penalty to admit into evidence Defendant's refusal to submit to a breath test, holding that the best course is to overrule State v. Pettijohn, 899 N.W.2d 1, 38-39 (Iowa 2017).After denying Defendant's motion in liming to exclude evidence of her refusal to submit to a breathalyzer test Defendant was convicted of driving while intoxicated. On appeal, Defendant challenged the constitutionality of section 321J.16, which allows into evidence a defendant's test refusal. Specifically, Defendant argued that Pettijohn, which held that a search warrant was required for a breathalyzer test of an intoxicated boater, should be extended to drunken driving cases. The Supreme Court (1) overruled Pettijohn and held that search warrants are not required for breathalyzer tests of either boaters or drivers when law enforcement has probable cause to believe that intoxicated boating or driving has occurred; and (2) it is not an unconstitutional penalty to admit into evidence a defendant's refusal to submit to a breath test. View "State v. Kilby" on Justia Law

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The Supreme Court conditionally affirmed Defendant's convictions and remanded for the district court to hold a hearing on Defendant's motion to suppress evidence, holding that the peace officer in this case conducted an unreasonable search and seizure by taking a citizen's opaque trash bags left outside for collection, opening the trash bags, and rummaging through the papers and effects contained therein.Despite an ordinance making it unlawful for any person to take solid waste placed out for collection, Officer Brandon Heinz, without probable cause or warrant, took Defendant's garbage bags and searched through them during the dark of night. Heinz subsequently applied for and was granted a search warrant based on the evidence obtained from the warrantless seizure and search of Defendant's trash bags. Defendant was subsequently charged with several drug-related counts. The district court denied Defendant's motion to suppress, and Defendant was found guilty. The court of appeals affirmed. The Supreme Court held that Heinz conducted an unreasonable search and seizure in violation of Iowa Const. art. I, 8 and that remand was required for a suppression hearing without consideration of the evidence obtained during the trash pulls used to support the warrant application. View "State v. Wright" on Justia Law

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The Supreme Court affirmed Defendant's convictions and sentences for conspiracy to distribute a controlled substance and for aiding and abetting a robbery, holding that the district court did not violate Defendant's right to confrontation when it allowed a witness to testify via two-way interactive video.The Supreme Court affirmed Defendant's convictions, holding that the district court did not err when it (1) overruled Defendant's confrontation objection to the testimony of the witness at issue, who had tested positive for COVID-19 and was experiencing symptoms; (2) determined that the foundation was sufficient to admit the witness's testimony regarding his translation of Spanish words spoken by Defendant; (3) admitted certain Facebook messages; and (4) sentenced Defendant. Lastly, there was sufficient evidence to support Defendant's convictions. View "State v. Comacho" on Justia Law

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T.O. and his parents appealed the district court's dismissal of their claims arising under the Fourth and Fourteenth Amendments, Title II of the Americans with Disabilities Act, and section 504 of the Rehabilitation Act of 1974. Plaintiffs' claims arose from a primary school disciplinary incident experienced by T.O.The Fifth Circuit affirmed the district court's dismissal of the substantive due process claim, concluding that the facts simply do not suggest that T.O. was the subject of a random, malicious, and unprovoked attack, which would justify deviation from Fee v. Herndon, 900 F.2d 804. In this case, an aide removed T.O. from his classroom for disrupting class, and the teacher used force only after T.O. pushed and hit her. Even if the teacher's intervention were ill-advised and her reaction inappropriate, the court cannot say that it did not occur in a disciplinary context. Furthermore, the court has consistently held that Texas law provides adequate, alternative remedies in the form of both criminal and civil liability for school employees whose use of excessive disciplinary force results in injury to students in T.O.'s situation.The court also concluded that plaintiffs' Fourth Amendment claims fail because this court has not conclusively determined whether the momentary use of force by a teacher against a student constitutes a Fourth Amendment seizure. In regard to the ADA and section 504 claims, the court concluded that the amended complaint failed to allege facts permitting the inference that either the teacher's actions or the school district's actions were based on T.O.'s disability. Finally, the district court did not abuse its discretion by denying leave to amend. Accordingly, the court affirmed the district court's rulings. View "T.O. v. Fort Bend Independent School District" on Justia Law

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The Fifth Circuit affirmed the district court's denial of Defendant Clark and Cox's motion to dismiss on the basis of qualified immunity for claims of failure to treat and the wrongful death of Hirschell Wayne Fletcher, Jr., who died from previously sustained head trauma while in custody.The court agreed with plaintiffs that between when paramedics Clark and Cox arrived and allegedly failed to treat Fletcher, but before he was formally transported, a reasonable person in Fletcher's position—surrounded and confronted by five officers—may not have thought he was free to leave, and was therefore detained. In this case, plaintiffs alleged that Clark, Cox, and the surrounding officers harassed and laughed at Fletcher until he was transported to the detention facility, all without any medical treatment. As alleged, the court concluded that such conduct supports that the paramedics may have been both subjectively aware of, and disregarded, Fletcher's serious risk of injury. Furthermore, it is undisputed that, at the time Clark and Cox allegedly failed to treat Fletcher, the law was clearly established that pretrial detainees have a Fourteenth Amendment right to medical care. View "Kelson v. Clark" on Justia Law

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Defendant Michael Coleman appealed from the denial of his petition for resentencing under Penal Code section 1170.91. That section allowed a current or former servicemember who might be suffering from sexual trauma or substance abuse (among other conditions) as a result of his or her military service to obtain a new sentencing hearing. Defendant contended he pleaded and proved a qualifying condition, and that the trial court erred by ruling otherwise. After review, the Court of Appeal agreed, and reversed the trial court. View "California v. Coleman" on Justia Law

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In 2013, a jury found defendant-respondent James Ambrosia Williams guilty of child abuse and that he had personally inflicted great bodily injury on the child, who was under the age of five. The trial court found defendant had a prior strike conviction, a prior serious felony conviction, and two prior prison terms. It imposed an aggregate term of 22 years in state prison, including a five-year enhancement for the prior serious felony conviction. Defendant appealed to the Court of Appeal, and judgment was affirmed. At the time defendant was sentenced, Penal Code section 1385 generally authorized judges and magistrates to order an action dismissed in the interests of justice on their own motion or upon the application of the prosecuting attorney but specifically barred them from striking any prior serious felony conviction in connection with imposition of a five- year enhancement. Four years after defendant was sentenced, Senate Bill No. 1393 (Reg. Sess. 2017-2018) amended the statute to delete the prohibition. In an unreported minute order dated September 30, 2019, and without the parties present, the sentencing judge recalled defendant’s sentence and struck the five-year punishment for the section 667 serious felony enhancement. The rest of defendant’s sentence remained unchanged. The State appealed. The Court of Appeal vacated the sentence: the trial court set forth the authority it relied upon for its decision but did not articulate a factual basis for exercising its discretion to strike the punishment for the prior serious felony enhancement. The matter was remanded for the sentencing court to articulate its basis for exercising discretion to strike the punishment. View "California v. Williams" on Justia Law