Justia Constitutional Law Opinion Summaries

A politically active resident of East Cleveland, Ohio, who had long used a sound truck to broadcast political messages, supported a challenger in a mayoral primary. After this involvement, city officials began enforcing rarely used parking and noise ordinances against him. The plaintiff was warned, cited, had his truck impounded, and was prosecuted for a noise violation. He alleged that these actions were motivated by his support for the challenger and criticism of the administration. The plaintiff, along with his company, brought claims under 42 U.S.C. § 1983 against the city, the mayor, the mayor’s chief of staff, and the police chief, asserting First Amendment retaliation and prior-restraint violations, as well as Fourth and Fourteenth Amendment claims.The United States District Court for the Northern District of Ohio resolved all claims in favor of the defendants. Some claims—including First Amendment retaliation claims against the mayor and chief of staff—were dismissed at the pleading stage, while others were resolved at summary judgment. The court found that the ordinances were facially valid and that the plaintiff had either failed to establish the required elements for his claims or had forfeited certain arguments on appeal.On appeal, the United States Court of Appeals for the Sixth Circuit revived certain First Amendment retaliation claims. It held that the district court erred in applying the probable cause requirement to the retaliation claims against the mayor and chief of staff, reversing their dismissal. The court affirmed summary judgment for the police chief on qualified immunity grounds, finding no clearly established law that would make him liable as a conduit for another’s retaliatory motive. As to the city, the court vacated summary judgment on retaliation, remanding for further proceedings on whether municipal policy directly caused a constitutional violation. The court affirmed the district court on all other claims, including the prior-restraint and Fourth Amendment seizure claims, and noted that the plaintiff had forfeited his selective enforcement arguments on appeal. View "Fambrough v. City of E. Cleveland" on Justia Law

In this case, the defendant allowed two sixteen-year-old girls who had run away from a treatment facility to stay in his home for ten days. During that period, he provided them with drugs and made repeated sexual advances, subjecting one girl to sexual contact. He later pleaded guilty to attempted sexual assault and distributing a controlled substance to a minor. A Sex Offender Management Board evaluator determined, using the Sexually Violent Predator Assessment Screening Instrument, that the defendant met the criteria of a sexually violent predator (SVP), largely based on his risk assessment score. The district court designated him as an SVP and sentenced him to fifteen years in prison, finding that the SVP designation was not punishment but rather intended to protect the community.The Colorado Court of Appeals affirmed the district court’s decision. The appellate division held that the SVP designation was not “punishment” under the Eighth Amendment, relying on prior precedent and distinguishing a recent case involving juvenile sex offender registration. The division noted some tension between the precedents, but concluded that the previous holding that SVP designation was not punishment remained controlling, as the juvenile case did not expressly overrule it.The Supreme Court of Colorado reviewed whether the SVP designation constitutes criminal punishment under the Eighth Amendment and, if so, whether it is cruel and unusual as applied. The court held that the Colorado General Assembly did not intend the SVP designation to be punitive, and that its effects do not, by the “clearest proof,” outweigh this nonpunitive intent. After analyzing statutory intent and applying the Mendoza-Martinez factors, the court concluded that the SVP designation and its accompanying requirements do not amount to punishment under the Eighth Amendment. Accordingly, the Supreme Court of Colorado affirmed the judgment of the court of appeals. View "Beagle v. People" on Justia Law

The defendant was charged with three counts of sexual assault and pleaded not guilty. During the jury trial, the prosecution submitted instructions for lesser-included attempt offenses, and the court accepted them over the defense’s objection. The jury received verdict forms allowing them to find the defendant not guilty of both the completed and attempted offenses, or guilty of one or the other, but could not indicate acquittal on the main charge while deadlocked on the lesser charge. After several days of deliberation, the jury notified the court in writing that it had reached a unanimous verdict on the main charges but was deadlocked on the lesser-included attempt offenses. The court confirmed the jury’s meaning through clarifying questions.Defense counsel requested revised verdict forms to allow the jury to separately indicate its decisions on the completed and attempted offenses, and also asked to poll the jury. The Larimer County District Court denied both requests and declared a mistrial on all charges. The defendant sought review under Colorado Appellate Rule 21, arguing that an ordinary appellate remedy was inadequate and he would otherwise suffer irreparable harm.The Supreme Court of Colorado, En Banc, reviewed the trial court’s decision for abuse of discretion. It found that the jury’s communication constituted a spontaneous and unequivocal partial verdict—namely, acquittal on the charged offenses. The trial court’s order for a complete mistrial violated the defendant’s right against double jeopardy under the Colorado Constitution. The Supreme Court held that the trial court abused its discretion by failing to accept the partial verdict and instead declared a mistrial as to all offenses. On remand, the defendant may be retried only for the attempt offenses, not for the completed sexual assault charges. View "People v. Mena" on Justia Law

The case arose after the Wyoming Legislature amended the election code to require voters who wished to change their party affiliation before a primary election to do so at least 96 days prior to the primary. Several individuals were affected by this new deadline: some were unable to vote for their preferred candidates in the 2024 primary because they could not change party affiliation after the cutoff, while others, who ran for office, were unsuccessful in their respective primaries. The plaintiffs challenged the constitutionality of the 96-day party affiliation deadline, arguing it violated their rights under the Wyoming Constitution to open, free, and equal elections, untrammeled exercise of suffrage, and equal political rights.The District Court of Laramie County granted summary judgment in favor of the Secretary of State, holding that the statutes establishing the 96-day party affiliation deadline were a valid exercise of legislative authority to regulate elections and did not violate constitutional voting rights or equal protection. The plaintiffs appealed only the district court’s ruling on the party affiliation deadline.The Supreme Court of Wyoming reviewed the case de novo, considering only legal questions as the facts were stipulated. The Court held that the right to vote in Wyoming, including in primary elections, is fundamental, but that the legislature is also constitutionally charged with securing the purity of elections. Employing a balancing approach informed by the Anderson-Burdick standard, the Court found the 96-day deadline imposed only a slight burden on voting rights, justified by the state’s legitimate interest in preventing party raiding and ensuring orderly elections. The Court further held that the deadline did not violate equal protection, as all electors had an equal opportunity to affiliate before the cutoff, and distinctions drawn between new registrants and previously registered voters were not constitutionally impermissible. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Malcom v. Gray" on Justia Law

Brian Pyle sought a writ of mandamus to compel several South Dakota law enforcement agencies and officials to provide him with investigative records regarding the disappearance and death of his son, Ryan. Ryan was reported missing in August 2020, and his remains were found in November 2020 near the Snake Creek Recreation Area. Pyle alleged that he had made numerous requests for medical records and investigative reports, but had not received any documents. He cited Marsy’s Law in the South Dakota Constitution, asserting that as a victim or relative of a victim, he was entitled to these records.The Circuit Court of the First Judicial Circuit, Charles Mix County, initially issued a peremptory writ requiring the respondents to answer. The State, representing all respondents, moved to quash the writ, arguing that the requested records contained confidential criminal justice information exempt from disclosure by law, and that Pyle had not exhausted administrative remedies for accessing such records. The State also contended that, since law enforcement found no evidence of foul play and concluded no crime had occurred, Marsy’s Law did not apply. After a hearing, in which no testimony or evidence was presented, the circuit court granted the State's motion, quashed the writ, and denied Pyle's application, finding Pyle was not a victim under Marsy’s Law and that no mandatory duty existed to disclose the records.On appeal, the Supreme Court of the State of South Dakota reviewed the circuit court’s decision for abuse of discretion and questions of law de novo. The Supreme Court held that Marsy’s Law requires a crime to have occurred for someone to be considered a victim and to invoke its rights. Because law enforcement determined no crime had been committed, Pyle was not entitled to the records under Marsy’s Law. Further, the Supreme Court found that South Dakota statutes exempt criminal investigative records from mandatory disclosure. The circuit court’s decision was affirmed. View "Pyle v. S.D. Division Of Criminal Investigation" on Justia Law

The case concerns a fatal incident following an argument among Katrina Carvalho, her sister Regina, and Regina’s boyfriend, Vintell Johnson. After dinner, the three argued in Johnson’s apartment complex parking lot. Witnesses testified that Johnson shoved both sisters, and Carvalho was seen pointing a gun at Johnson and another bystander. Moments later, gunshots were heard, and Johnson was fatally wounded. The prosecution charged Carvalho with first-degree murder with the use of a deadly weapon. At trial, Carvalho’s defense was that another person, specifically Regina, may have fired the shots, and she highlighted weaknesses in the police investigation and the possibility of alternative suspects.The Second Judicial District Court, Washoe County, presided over the second trial after a mistrial was declared in the first due to late evidence disclosure. During closing arguments, the district court repeatedly interrupted, admonished, and ultimately sanctioned defense counsel for arguing that the evidence equally implicated Regina. The court instructed the jury not to consider Regina’s guilt or speculate about her involvement, effectively preventing the defense from fully presenting its alternative-suspect theory. The jury found Carvalho guilty, and she was sentenced to life in prison with the possibility of parole after 28 years.The Supreme Court of the State of Nevada reviewed the appeal. It held that the district court abused its discretion by foreclosing Carvalho’s opportunity to present an alternative-suspect defense, violating her due process right to a meaningful opportunity to present a complete defense. The court ruled that while a jury should not be asked to determine the guilt of someone other than the defendant, it is permissible for the defense to argue that reasonable doubt exists because the evidence supports an alternative suspect. The Supreme Court reversed the conviction and remanded the case for a new trial before a different department. View "CARVALHO VS. STATE" on Justia Law

On February 13, 2024, law enforcement found the body of Teangela Tate, who had died from gunshot wounds, near an interstate ramp in North Little Rock, Arkansas. Nearby, two young children were discovered: one deceased (MV1) from blunt-force trauma and environmental exposure, and another (MV2) alive but barely responsive. Evidence at the scene and subsequent investigation linked Willie Leon Mott, Jr. to the victims, including blood and shell casings in Mott’s house and his mother’s car, cell phone records showing travel to and from the crime scene, and DNA tests. Mott was arrested later that day, and during his incarceration, he attempted to have his mother destroy his cell phone.The Pulaski County Circuit Court presided over Mott’s trial. After the prosecution rested, Mott moved for directed verdicts, arguing insufficient evidence for each count and challenging the constitutional validity of a portion of Arkansas’s capital-murder statute. The circuit court denied these motions, finding the evidence sufficient and the statute not vague. Mott rested without presenting witnesses and renewed his motions, which were again denied. He received life sentences for first-degree murder, capital murder, and attempted capital murder.The Supreme Court of Arkansas reviewed the appeal. Applying the substantial evidence standard, the court determined that the jury’s verdicts were supported by the evidence, including circumstantial evidence and Mott’s actions to conceal his involvement. The court also reaffirmed prior decisions that the statutory language “under circumstances manifesting extreme indifference to the value of human life” is not unconstitutionally vague. The court affirmed the circuit court’s rulings and Mott’s convictions and sentences. View "MOTT v. STATE OF ARKANSAS" on Justia Law

A pedestrian was severely injured when struck by a Southeastern Pennsylvania Transportation Authority bus while crossing an intersection in Philadelphia. The injuries required a partial left foot amputation and extensive ongoing medical care. The plaintiff retained counsel on the understanding that they would challenge the constitutionality of the statutory cap limiting damages recoverable from Commonwealth parties, set at $250,000 under Pennsylvania’s Sovereign Immunity Act. The complaint alleged negligence by SEPTA, which admitted liability; the parties then stipulated to a jury verdict with damages totaling $7 million, but SEPTA moved to reduce the award to the statutory cap.The Court of Common Pleas of Philadelphia County granted SEPTA’s motion to mold the verdict to $250,000 and denied delay damages, finding itself bound by prior Pennsylvania Supreme Court precedent, specifically Zauflik v. Pennsbury School District, which had upheld similar caps. The plaintiff appealed to the Commonwealth Court, which affirmed the trial court in an unpublished opinion. The Commonwealth Court reasoned that the damages cap did not violate the right to a jury trial or the constitutional right to a remedy, holding that the cap affected only the ultimate recovery, not the ability to prosecute the claim or access a jury trial.The Supreme Court of Pennsylvania, Eastern District, reviewed the case, focusing on whether the damages cap violates the Pennsylvania Constitution’s right to a jury trial or to a remedy. The court held that, as applied in this case, the statutory cap does not violate either constitutional right. The cap limits the remedy but does not restrict access to a jury trial or the process itself. The court affirmed the Commonwealth Court’s order, concluding that the legislature has authority to set such liability limits and that the cap is constitutional, even if it results in little or no recovery for the plaintiff. View "Freilich v. SEPTA" on Justia Law

The case concerns a challenge brought by the District Attorney of Philadelphia against Act 40 of 2023, which created the position of a special prosecutor to investigate and prosecute crimes occurring within the Southeastern Pennsylvania Transportation Authority (SEPTA). Act 40 gives the special prosecutor concurrent jurisdiction with district attorneys in counties served by SEPTA, except in Philadelphia, where the special prosecutor has exclusive authority, able to preempt the Philadelphia District Attorney at their sole discretion. The Act also limits the ability of criminal defendants to challenge the special prosecutor’s authority and prescribes procedures for local law enforcement and funding related to prosecutions.The District Attorney filed a petition for review in the Commonwealth Court of Pennsylvania, seeking declaratory and injunctive relief, arguing that Act 40 unconstitutionally infringed upon his powers and jurisdiction, constituted an impermissible special law, violated equal protection and procedural notice requirements, and improperly restricted criminal defendants’ rights. The Commonwealth Court, in a split en banc opinion, rejected these constitutional challenges, finding that the General Assembly has broad authority to regulate the powers and duties of home rule municipalities and their officers, including district attorneys, and that Act 40 did not violate the Pennsylvania Constitution. Concurring and dissenting opinions argued that Act 40 was unconstitutionally vague, restricted criminal defendants’ rights, and improperly divested the District Attorney of his jurisdiction.On direct appeal, the Supreme Court of Pennsylvania affirmed the Commonwealth Court’s order. The Supreme Court held that Act 40 does not violate the Pennsylvania Constitution, finding no constitutional source for exclusive prosecutorial powers and confirming the General Assembly’s authority to prescribe the duties of city officers. The Court also held that Act 40 does not constitute an impermissible local or special law, nor violate equal protection, and that the District Attorney lacked standing to raise the rights of criminal defendants under Act 40. View "Krasner v. Sunday" on Justia Law

On the night of February 14, 2017, the victim and her boyfriend, along with their children, dined with the appellant, Ronald Jenkins, a longtime friend. After returning to their apartment and consuming alcohol and marijuana, the victim felt unwell and asked Jenkins to leave. Jenkins refused and then violently assaulted the victim, causing her to lose memory of the remainder of the evening. Surveillance footage later showed Jenkins carrying the unconscious victim into his motel room. The victim awoke the next morning, partially undressed and confused, with signs of injury. Medical and forensic evidence established the presence of Jenkins’s semen in the victim. Jenkins denied any wrongdoing during police interviews, including a conversation conducted with his attorney present.The criminal trial took place in the Dauphin County Court of Common Pleas. During the Commonwealth’s closing argument, the prosecutor referenced Jenkins’s retention of counsel during his interview with police, suggesting it reflected consciousness of guilt. Jenkins’s counsel objected and moved for a mistrial, arguing the prosecutor’s remarks improperly prejudiced the jury. The trial court denied the mistrial but issued a prompt curative instruction, emphasizing the right to counsel and directing the jury not to draw adverse inferences. Jenkins was convicted and sentenced. On appeal, the Superior Court affirmed, finding the prosecutor’s remarks improper but concluding the curative instruction and overwhelming evidence rendered any error harmless. One judge dissented, asserting the error was incurable.The Supreme Court of Pennsylvania addressed whether the prosecutor’s reference to Jenkins’s pre-arrest retention of counsel violated his right to a fair trial and whether such error was structural or subject to harmless error analysis. The Court held that the prosecutor’s comment was improper and impacted Jenkins’s due process right, but not a structural error requiring automatic reversal. Considering the timely curative instruction and overwhelming evidence, the error was harmless beyond a reasonable doubt. The judgment of the Superior Court was affirmed. View "Commonwealth. v. Jenkins" on Justia Law