Justia Constitutional Law Opinion Summaries

Defendant Jeffrey Lord, Sr. was convicted by jury of making criminal threats and obstructing an executive officer by threat or violence. The trial court placed him on probation for five years. He appealed, arguing there was insufficient evidence to support his conviction for making criminal threats because the threat did not cause the victim sustained fear. He further sought to have his case remanded for resentencing in light of the new two-year limit on terms of probation for certain felonies. After review, the Court of Appeal affirmed Lord’s conviction but reversed and remanded for resentencing. View "California v. Lord" on Justia Law

On November 3, 2020, a strong majority of the voters of Mississippi approved Initiative 65, which established a legal medical-marijuana program. The Petitioners challenged the Secretary of State’s approval of the initiative for inclusion on the ballot, arguing it would have been impossible for the petition seeking to place Initiative 65 on the ballot to be properly certified as meeting Miss. Const. art. 15, section 273 prerequisites by the Secretary of State. As the petition was certified in error, the Petitioners contended that all subsequent actions were void. “Remaining mindful of both the November 3, 2020 election results and the clear language in section 273 seeking to preserve the right of the people to enact changes to their Constitution,” the Mississippi Supreme Court held that the text of section 273 failed to account for the possibility that the State’s representation in the United States House of Representatives and corresponding congressional districts would be reduced. “[T]he intent evidenced by the text was to tie the twenty percent cap to Mississippi’s congressional districts, of which there are now four. In other words, the loss of congressional representation did, indeed, break section 273 so that, absent amendment, it no longer functions.” A majority of the Mississippi Court reversed the Secretary of State’s certification if Initiative 65, and held that any subsequent proceedings on it were void. View "In Re Initiative Measure No. 65" on Justia Law

After plaintiff's murder conviction was vacated when another person confessed to the murder, plaintiff filed suit against the City of Baltimore, the Baltimore Police Department, and others, alleging violations of his federal and state civil rights which led to his wrongful imprisonment for the murder. After a ten-day trial, the jury returned a $15 million verdict in favor of plaintiff. Defendant Goldstein, one of the officers at the scene of the murder, appealed.The Fourth Circuit affirmed the district court's denial of motions for judgment as a matter of law or a new trial under Rules 50 and 59 of the Federal Rules of Civil Procedure, because there was evidence from which a reasonable jury could have found police misconduct. The court found no error in the district court's jury instructions, taken as a whole, because they complied with the law and the district court's earlier rulings. Finally, although the district court improperly admitted hearsay evidence, the error, in the context of the record as a whole, was harmless. Accordingly, the court affirmed the jury's verdict and the district court's denial of Rule 50 and 59 motions. However, the court reversed the district court's dismissal of plaintiff's claim against the Baltimore Police Department under Monell v. Department of Social Services of City of New York, 436 U.S. 658 (1978) where the district court did not explain why the allegations of the complaint that were sufficient earlier no longer were. Rather, the district court's dismissal seems to be based on the verdict issued against Defendant Goldstein. If the City does in fact indemnify Goldstein and the judgment is satisfied, the Monell claim would be moot. View "Burgess v. Goldstein" on Justia Law

Elgin met Garbutt at an international convention. Garbutt, who holds dual citizenship, moved from Belize into Elgin’s Gary, Indiana home and worked on her successful campaign to become Trustee of Calumet Township. Elgin hired Garbutt to work at the Trustee’s Office as her “executive aide” at a salary of $60,000 per year. Garbutt’s unofficial duties included Elgin’s political campaign work. He understood that he should not perform political work at the Township Office but began to do so. Elgin also hired her friend Shelton, who also worked on Elgin’s campaign. Elgin and Garbutt had a falling out. Elgin demoted Garbutt, docked his salary barred him from attending meetings, and took away his government car. Garbutt eventually began a partnership with an FBI agent who directed him to conduct warrantless searches of his co‐workers’ offices.Elgin took a plea deal, Shelton was convicted of conspiracy to commit wire fraud and conspiracy to commit honest services wire fraud, after learning, mid‐trial, about the warrantless searches. The district court denied Shelton's post‐trial motion for relief. The Sixth Circuit reversed. The district court erred in finding that Shelton lacked any reasonable expectation of privacy in her office. Garbutt’s document collection, undertaken at the direction of the FBI, violated her Fourth Amendment rights. No warrant would have issued without the information gathered as a result of the unlawful searches; the evidence obtained from the search authorized by that warrant should have been suppressed. View "United States v. Shelton" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court denying Defendant's motion filed under Kan. Stat. Ann. 60-1507 seeking a new trial based on allegations of ineffective assistance of both trial and appellate counsel, holding that Defendant was not entitled to relief on his claims.Defendant was convicted of two counts of aggravated criminal sodomy. His conviction was affirmed on direct appeal. Thereafter, Defendant brought this motion seeking a new trial based on allegations of ineffective assistance of both his trial counsel and appellate counsel. The district court denied the motion. The court of appeals reversed. The Supreme Court reversed, holding (1) the district court's findings of fact were supported by substantial competent evidence; (2) the findings of fact supported the district court's legal conclusion; and (3) Defendant received effective assistance of counsel during both his trial and during appellate proceedings. View "Khalil-Alsalaami v. State" on Justia Law

Four years after his release from prison, and after completing three years of supervised release, plaintiff was told he would have to serve another 27 months in jail based on an erroneous release from prison because he had a consecutive misdemeanor to serve. Plaintiff filed a writ of habeas corpus and the district court ruled that he must serve the remainder of his sentence. Plaintiff appealed, but the district court failed to act on the appeal until December 2013, at which point it dismissed the petition as moot because plaintiff had been released from jail upon completion of his sentence.Plaintiff then filed a 42 U.S.C. 1983 action alleging that his spontaneous incarceration deprived him of due process under the Fifth Amendment. The district court dismissed the case based on claim preclusion in light of plaintiff's prior unsuccessful habeas corpus action. The DC Circuit reversed and, on remand, the district court granted summary judgment for the District.The DC Circuit affirmed the district court's judgment that plaintiff failed to establish a pattern of constitutional violations or to demonstrate deliberate indifference. The court explained that plaintiff's evidence fails to show either that the District had a relevant custom of unconstitutional actions or that the District acted with deliberate indifference. However, the court vacated the entry of summary judgment for the District on the claim of unconstitutional policy because the nature and contours of the alleged policy present a number of disputed issues of material fact. Accordingly, the court remanded for further proceedings. View "Hurd v. District of Columbia" on Justia Law

The Supreme Court reversed Defendant's conviction of operating while intoxicated (OWI), holding that Mitchell v. Wisconsin, 588 U.S. __, __, 139 S. Ct. 2525 (2019) (plurality opinion), applies to cases of suspected driving while under the influence of controlled substances, in addition to alcohol-related cases.Defendant caused an accident while driving recklessly. Defendant, who was injured, was taken to the hospital strongly smelling of marijuana. A police officer dispatched to the hospital performed a blood test of Defendant, who was sedated, after a medical professional certified that Defendant was unable to consent or refuse blood testing. Defendant filed a motion to suppress the testing, but the motion was overruled. Defendant appealed, arguing that the warrantless blood draw violated Iowa Code 321J.7, the Fourth Amendment to the federal Constitution, and Iowa Const. art. I, 8. The Supreme Court reversed, holding (1) the State complied with section 321J.7; (2) because the parties did not have an opportunity to make a record under the Mitchell standard, the case must be remanded; and (3) article I, section 8 does not provide greater protection from warrantless blood draws than the Mitchell standard. View "State v. McGee" on Justia Law

Defendant Michael Young was charged by bill of information with simple burglary for the 2016 burglary of a B.J.’s Country Stop. The burglar entered the store by breaking the glass door with a brick. He took the cash drawer from the register and left. The store’s surveillance camera recorded the burglary. In video recorded at another Stop on the evening before the burglary, the manager of the burglarized Stop saw a male who she thought resembled the burglar, wearing a similar white t-shirt and black basketball shorts with red and white stripes just as was seen in the video of the burglary. A unanimous jury found him guilty as charged. The trial court denied defendant’s motions for post-verdict judgment of acquittal and new trial, and sentenced defendant to serve 12 years imprisonment at hard labor. The Louisiana Supreme Court reversed, finding that the fact that the jurors observed the videos did not justify the exclusion of additional evidence from the defense on the question of whether defendant was the person in the videos. “That evidence was clearly relevant, and the trial court erred in excluding it. Considering the importance of the video surveillance evidence in the State’s case-in-chief, and the lack of any other evidence connecting defendant to the burglary,” the Supreme Court could not conclude beyond a reasonable doubt that the exclusion of evidence that defendant had extensive tattoos was harmless. View "Louisiana v. Young" on Justia Law

Defendant James Bourgeois, an elected member of the Lafourche Parish Council, was found guilty by a unanimous jury of filing or maintaining false public records. The charge arose from the allegation that defendant had falsely asserted in his Parish Council election qualifying form that he was domiciled in Lafourche Parish. The trial court sentenced him to a suspended sentence of three years imprisonment at hard labor with two years of probation. The court of appeal reversed the conviction and vacated the sentence because it found the evidence insufficient to prove that defendant falsely represented his domicile on his qualifying form. There was no dispute that the election qualifying form was a public record and that defendant filed it. The sole question for the Louisiana Supreme Court was whether the evidence, when viewed under the due process standard of Jackson v. Virginia, was sufficient to prove the form contained a false statement with regard to defendant’s domicile. The Supreme Court determined the State’s case “was not so lacking that it should not have even been submitted to the jury. The State introduced evidence from which the jury could rationally find that defendant had abandoned his domicile in Lafourche Parish and established a new domicile in Jefferson Parish by the time he filed his election qualifying form. The jury was not forced to speculate to reach this conclusion, as the court of appeal found.” Accordingly, judgment was reversed and defendant’s conviction and sentence were reinstated. View "Louisiana v. Bourgeois" on Justia Law

Defendant Walter Perell Fisher, Jr. was taking a bath at his girlfriend’s residence when officers of the St. Tammany Parish Narcotics Task Force accompanied by a parole officer arrived to conduct a “residence check.” The residence check pertained to two probationers who also resided there, Richard Dantin and his fiancee Kristie Smith. Dantin and Smith were on probation for operating a clandestine methamphetamine lab and numerous convictions for possession and distribution of controlled dangerous substances. In response to questioning by the parole officer, Dantin revealed that he had a small quantity of methamphetamine and a pipe on his person. Officers obtained a search warrant for the residence, and found controlled dangerous substances and paraphernalia in the common areas and bedrooms. In the bedroom belonging to Samantha Irwin, defendant’s girlfriend, officers found a single, loose prescription promethazine pill on a cluttered nightstand. In the pocket of a jacket hanging in Irvin’s closet, officers found an opaque container with less than a gram of methamphetamine inside and a bottle of Adderall prescribed to Irvin. She told officers that defendant had no knowledge of the methamphetamine or the promethazine pill in her room. No contraband was found in the bathroom where defendant was taking a bath. A jury found defendant guilty as charged of possession of methamphetamine, and possession of a legend drug without a prescription, based on the methamphetamine found in the jacket pocket and the single promethazine pill found on the nightstand. The trial court adjudicated defendant as a third-felony offender and sentenced him to consecutive terms of 10 years imprisonment at hard labor for possession of a legend drug without a prescription (then the statutory maximum for the offense and his offender class), and four years imprisonment at hard labor for possession of methamphetamine. After review, the Louisiana Supreme Court found the evidence was insufficient to support defendant’s convictions, and vacated them. The Court entered a judgment of acquittal on both charges in his favor. View "Louisiana v. Fisher" on Justia Law