Justia Constitutional Law Opinion Summaries

In this case, the petitioner was convicted of capital murder and sentenced to death following a 2003 armed robbery in Houston, Texas, during which a restaurant employee was killed. Key evidence included eyewitness testimony, statements from co-defendants and jailhouse informants, and information about the petitioner’s criminal history and conduct in prison. The prosecution’s case centered on the petitioner being the sole gunman, though there was conflicting testimony about whether a second person entered the restaurant.The Texas Court of Criminal Appeals affirmed the conviction and sentence on direct appeal and denied state habeas relief, finding the petitioner’s subsequent and additional habeas claims to be procedurally barred as an abuse of the writ. The petitioner then sought federal habeas relief in the United States District Court for the Southern District of Texas, raising thirteen claims, including allegations of false evidence, inconsistent prosecutorial theories, Brady violations, ineffective assistance of counsel, and racial bias. The district court denied relief on the merits where permitted and found the remaining claims procedurally barred due to default under Texas law, ruling that the petitioner had not shown cause, actual prejudice, or a fundamental miscarriage of justice to excuse the default.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether a certificate of appealability (COA) should issue for the claims dismissed as procedurally barred. The court held that the petitioner failed to show that jurists of reason could debate the district court’s procedural rulings. The court concluded that the claims were subject to an adequate and independent state procedural bar, and the petitioner had not demonstrated cause and prejudice or actual innocence to overcome that bar. The Fifth Circuit therefore denied the application for a certificate of appealability. View "Marshall v. Guerrero" on Justia Law

The case concerns Del Orrin Crawford, who was involved in a deadly altercation outside the South Fork Saloon in Martin City, Montana, on August 26, 2022. After a dispute regarding a golf cart escalated, Crawford fired a handgun, resulting in the death of Whisper Sellers and serious injury to Douglass Crosswhite. Crawford fled the scene, called 911 multiple times claiming self-defense, and was later apprehended by law enforcement. Upon arrest, Crawford surrendered unarmed, and the firearm he used was not immediately recovered. Law enforcement questioned Crawford about the firearm’s location and conducted further interrogation after transporting him to the sheriff’s office.The Eleventh Judicial District Court in Flathead County presided over Crawford’s jury trial. Crawford moved to suppress two sets of statements made to law enforcement after he invoked his right to counsel. The court denied most of his motion, suppressing only statements related to his alcohol consumption before his second Miranda advisement. Crawford was subsequently convicted by the jury of Deliberate Homicide, Attempted Deliberate Homicide, Assault with a Weapon, and Tampering with Physical Evidence, and sentenced to 100 years in prison.On appeal, the Supreme Court of the State of Montana reviewed whether the district court erred in admitting Crawford’s statements regarding the firearm’s location after he requested counsel and whether it was correct in finding that Crawford reinitiated conversation and knowingly waived his right to counsel before making further statements. The Supreme Court held that even if admitting the statements about the firearm’s location was erroneous, any error was harmless beyond a reasonable doubt due to cumulative admissible evidence. The Court further held that Crawford voluntarily reinitiated conversation and validly waived his right to counsel before providing additional statements. The judgment of conviction was affirmed. View "State v. Crawford" on Justia Law

The case concerns a defendant who was charged with abusing his elderly stepfather, resulting in both mental injury and physical harm. The elderly victim, who had declining health and required assistance, was subjected to several years of verbal threats, intimidation, and, on at least one occasion, physical assault when the defendant struck him in the face. The victim’s daughter and other family members observed concerning behavior, including an incident where the defendant shook the victim in a manner described as threatening. The victim, before passing away, gave a recorded deposition detailing the abuse, his fear, and its emotional toll. The charges included abuse of an elderly person and first-offense partner or family member assault.Prior to trial, the defendant sought to enforce an alleged plea agreement, but the District Court found no such agreement had been accepted, following a hearing. Although a jury trial was scheduled, the defendant requested a bench trial, and the Tenth Judicial District Court, Fergus County, confirmed that he knowingly and voluntarily waived his right to a jury trial, albeit orally rather than in writing. After a two-day bench trial, the court found the defendant guilty on both counts and imposed a prison sentence. The defendant appealed, arguing insufficient evidence due to a lack of expert testimony on mental injury, an improper waiver of jury trial, and that the elder abuse statute was unconstitutionally vague and overbroad.The Supreme Court of the State of Montana held that expert testimony is not required to establish “mental injury” under the relevant statute, as a reasonable person standard applies and lay testimony was sufficient. The court found no manifest miscarriage of justice in accepting the oral waiver of a jury trial. The court also rejected the facial constitutional challenges, as the defendant’s conduct was clearly proscribed by statute. The judgment of the District Court was affirmed. View "State v. Pein" on Justia Law

The appellant was convicted of first-degree murder, robbery, and grand theft after brutally beating and killing a woman with whom he was temporarily staying. Evidence at trial established the appellant stole cash and the victim’s car, fled the state, and used an alias before being apprehended in Alabama and returned to Florida for prosecution. The jury convicted him and recommended the death penalty by a 10-2 vote. The trial court found aggravating factors including murder during a robbery and that the crime was especially heinous, atrocious, or cruel, outweighing mitigating circumstances, and imposed a sentence of death.The Supreme Court of Florida previously affirmed the convictions and sentence on direct appeal. The appellant later filed multiple unsuccessful postconviction motions in state and federal courts, including a motion based on the Florida Supreme Court’s decision in Hurst v. State, which was denied due to lack of retroactivity. After the Governor signed a death warrant, the appellant filed a successive motion for postconviction relief and a stay of execution in the Circuit Court for Polk County, raising claims regarding his age and cognitive decline, warrant timing, the warrant process, and the nonunanimous jury recommendation.The Supreme Court of Florida reviewed the circuit court’s summary denial of postconviction relief de novo. The Court affirmed the summary denial, holding the appellant’s claims were either procedurally barred or meritless. Specifically, it ruled there is no constitutional prohibition against executing elderly prisoners experiencing cognitive decline, the expedited warrant period does not violate due process or equal protection, the Governor’s discretion in signing death warrants is not unconstitutional, and a nonunanimous jury recommendation of death does not violate the Fifth, Sixth, or Eighth Amendments. The Court also denied the appellant’s request for a stay of execution. View "Beasley v. State" on Justia Law

In 2003, Samuel Anthony Cruz and several other members of the 7th Street gang were involved in two separate shooting incidents that resulted in the deaths of rival gang members. Cruz was charged with two counts of murder but entered a plea agreement in which he pleaded guilty to two counts of voluntary manslaughter, along with enhancements and gang participation. He was sentenced to a negotiated term of 21 years and eight months.Many years later, Cruz filed a petition under California Penal Code section 1172.6, seeking to vacate his manslaughter convictions and be resentenced on the grounds that legal standards for murder liability had changed. The Superior Court of Orange County issued an order to show cause and held an evidentiary hearing. At this hearing, the prosecution introduced transcripts from the 2007 trial of Cruz’s codefendant, Juan Becerra. Cruz objected to the use of these transcripts on due process grounds but did not challenge the factual findings or dispute this court’s prior opinions allowing such evidence. The trial court denied Cruz’s petition, finding he was an actual shooter in one killing and a direct aider and abettor in the other.Upon appeal, the California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the trial court’s consideration of a codefendant’s trial testimony violated Cruz’s right to due process. The court held that admission of this testimony did not violate procedural due process because Cruz had a full and fair opportunity to contest the evidence: he could have subpoenaed witnesses, testified on his own behalf, or introduced new evidence. The court affirmed the trial court’s order denying Cruz’s petition for vacatur and resentencing. View "P. v. Cruz" on Justia Law

Two Hawaii residents challenged two aspects of the state's “shall-issue” firearm licensing regime. The first challenged provision required that a handgun acquisition permit be used within thirty days of issuance or else the applicant must restart the process. The second provision required that, after purchasing a firearm, certain owners must bring it to a police station for inspection and registration in specific circumstances. Plaintiffs alleged that these requirements imposed undue burdens on their ability to acquire firearms, in violation of the Second Amendment.The United States District Court for the District of Hawaii granted summary judgment to the plaintiffs. The district court found both requirements facially unconstitutional under the Second Amendment, applying intermediate scrutiny as was then the circuit precedent. The court permanently enjoined the state from enforcing the challenged provisions. After this ruling, the Supreme Court decided New York State Rifle & Pistol Ass’n v. Bruen, which changed the standard for Second Amendment claims to a “text, history, and tradition” test.On appeal, the United States Court of Appeals for the Ninth Circuit, sitting en banc, considered the impact of Bruen and subsequent Supreme Court cases. The Ninth Circuit noted that Bruen distinguished between “may-issue” and “shall-issue” licensing regimes and, in footnote 9, characterized objective, non-abusive “shall-issue” regimes as presumptively constitutional. The court concluded that the two challenged Hawaii requirements were objective, non-discretionary, and did not amount to abusive practices that would deny ordinary citizens their Second Amendment rights. At most, the provisions imposed only modest, procedural burdens and did not materially impede firearm acquisition.The Ninth Circuit therefore reversed the district court’s injunction and remanded for further proceedings, holding that Hawaii’s “shall-issue” regime, as applied here, comports with the Second Amendment. View "YUKUTAKE V. LOPEZ" on Justia Law

Desroisiers was stopped by police while driving a Chevrolet Trailblazer with her mother as a passenger. The vehicle lacked an inspection sticker, prompting a police sergeant to initiate a traffic stop. The vehicle was registered but not to Desroisiers, who was on pre-conviction bail requiring her to commit no criminal act. During the encounter, Desroisiers resisted requests for documentation, accused the officer of harassment, and refused to comply with commands to be handcuffed. She crossed her arms, attempted to pull away, dropped to the ground after being handcuffed, and later stuck her foot outside the cruiser door, requiring officers to push it in. Footage showed her thrashing inside the cruiser.The Aroostook County Superior Court held a jury trial and admitted relevant evidence, including body camera footage. Desroisiers moved for judgments of acquittal on the charge of refusing to submit to arrest or detention, arguing the evidence showed only passive resistance, not physical force. The court denied the motions. The jury convicted her of refusing to submit to arrest or detention by using physical force against a law enforcement officer, operating an unregistered vehicle, and violating a condition of release. Desroisiers subsequently renewed her acquittal motions, which were again denied, and she timely appealed.The Maine Supreme Judicial Court reviewed the case. It interpreted the statutory phrase “uses physical force against a law enforcement officer” to include any muscular effort directed toward an officer’s attempt to detain, not just violent or injurious acts. The court held that Desroisiers’s crossing her arms, pulling away, and obstructing the cruiser door constituted physical force under the statute, affirming her convictions for refusing to submit to arrest and violating a condition of release. However, the court found insufficient evidence that Desroisiers was the current owner required to register the vehicle, vacating her conviction for operating an unregistered vehicle. View "State of Maine v. Desrosiers" on Justia Law

A minister sought to hold a small prayer event on the lower section of the Eastern Steps of the United States Capitol, advocating for various causes including opposition to federal funding of abortion. Under federal regulations, public demonstrations on these Steps are generally prohibited unless sponsored by a member of Congress, with violations carrying criminal penalties. The minister, unable to secure sponsorship, faced the threat of arrest and had previously been arrested for similar conduct.After protracted litigation and partial settlement, the parties stipulated to key facts and proceeded to cross-motions for summary judgment in the United States District Court for the District of Columbia. That court ruled in favor of the minister on his First Amendment claim, holding that the lower section of the Eastern Steps was a traditional public forum and that the regulations at issue suppressed more speech than necessary. The district court entered a permanent universal injunction, barring enforcement of the regulations against anyone wishing to demonstrate on the lower Steps. The Capitol Police Board appealed, and the district court later limited the injunction to the minister and up to 14 others pending appeal.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo regarding summary judgment and for abuse of discretion as to the injunction. The appellate court disagreed with the district court’s forum classification, holding that the Eastern Steps constitute a nonpublic forum because of their specialized function and physical integration with the Capitol. Nevertheless, the court held that the regulation’s requirement of congressional sponsorship for demonstrations was unreasonable, as it granted unbridled discretion to members of Congress, violating First Amendment protections. The court affirmed summary judgment for the minister but vacated the universal injunction, remanding for the district court to determine the proper scope of injunctive relief in light of recent Supreme Court guidance limiting universal injunctions. View "Mahoney v. United States Capitol Police Board" on Justia Law

A man was stopped by law enforcement while riding as a passenger in a car due to a traffic infraction. During the stop, officers identified him and found that he was on felony probation. The officers searched a backpack at his feet, which contained a significant quantity and variety of illegal narcotics, as well as items suggestive of drug distribution. The man denied ownership of the backpack, claiming it belonged to his girlfriend. Subsequent investigation revealed that he was subject to a probation agreement that included both waiver of his Fourth Amendment rights and consent to searches by law enforcement.He was charged in two separate cases with various drug-related offenses, including possession with intent to deliver and possession of drug paraphernalia. The cases were consolidated in the District Court of the Fourth Judicial District, Ada County. He moved to suppress the evidence found in the backpack, arguing that the search was unconstitutional. The district court denied his motion, finding that he lacked standing to challenge the search due to the express waiver of his Fourth Amendment rights in his probation agreement.After trial, a jury found him guilty on multiple counts, and he was sentenced to a unified fifteen-year term, with five years fixed. On appeal to the Supreme Court of the State of Idaho, he argued that the district court erred in treating his waiver as a categorical bar to standing, particularly since officers did not know of the waiver at the time of the search.The Supreme Court of the State of Idaho affirmed the district court’s denial of the motion to suppress. The Court held that an express waiver of Fourth Amendment rights in a probation agreement extinguishes any legitimate expectation of privacy and therefore precludes standing to challenge the search, overruling its prior decision in State v. Maxim, 165 Idaho 901, 454 P.3d 543 (2019), to the extent it held otherwise. View "State v. Al-Mafrachi" on Justia Law

Two candidates for public office in the November 2026 Delaware general election challenged the constitutionality of the state’s permanent absentee voting statute. They argued that the statute unlawfully expanded absentee voting beyond the categories permitted by the Delaware Constitution and that the Department of Elections failed to adequately verify the continued eligibility of permanent absentee voters, thereby enabling ineligible individuals to vote by absentee ballot.Previously, the Court of Chancery of the State of Delaware considered cross-motions for summary judgment. The plaintiffs sought declaratory and injunctive relief to prevent use of the permanent absentee voting process for the 2026 election. The Court of Chancery found that the statute did not expand the constitutionally enumerated categories of absentee voters but rather limited permanent absentee status to a subset of those groups. The court further held that the statute did not permit voting by those ineligible to vote absentee and that the Department’s procedures for maintaining the permanent absentee list, though not perfect, did not render every application of the statute unconstitutional. The Court of Chancery thus granted summary judgment to the defendants.On appeal, the Supreme Court of the State of Delaware reviewed the case de novo and affirmed the decision of the Court of Chancery. The Supreme Court held that the permanent absentee voting statute neither expanded absentee voting eligibility beyond the categories set by the Delaware Constitution nor permitted ineligible individuals to vote by absentee ballot. The Court also held that the plaintiffs failed to meet the high burden required for a facial constitutional challenge, as the statute could be applied constitutionally. Therefore, the Supreme Court affirmed the judgment upholding the statute. View "Hocker v. Albence" on Justia Law