Justia Constitutional Law Opinion Summaries

During the summer of 2018, housing advocates interacted with tenants at the Yale Park Apartment Complex in Omaha, documenting alleged building code violations and submitting complaints to the City. Based largely on this information, the City’s Chief Housing Inspector applied for and received an inspection warrant. Subsequent searches led to the closure of the complex, and tenants were forced to relocate. The City later provided AB Realty, LLC—the owner—and Kay and Janae Anderson with a list of violations and barred reopening until repairs were made. AB Realty attempted to challenge the closure through the Property Management Appeals Board and faced ongoing notices and prosecution for code violations. After completing repairs and reopening the complex in 2021, AB Realty and the Andersons initiated a lawsuit.The United States District Court for the District of Nebraska granted the defendants’ motion to dismiss in part and stayed proceedings pending the outcome of Kay Anderson’s criminal trial. After a state-court jury convicted Kay on a few counts but acquitted him of most, the district court dismissed the remaining claims against the City of Omaha and associated defendants.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The court held that the search warrant, even excluding disputed information, was supported by probable cause based on the complaints and evidence of violations. It further determined that violations of Nebraska state law regarding warrants did not sustain a federal constitutional claim under 42 U.S.C. § 1983. The court also found AB Realty’s procedural due process allegations insufficiently specific to identify constitutionally protected interests or responsible parties. Finally, the court ruled that AB Realty failed to plead either a per se or regulatory taking under the Fifth Amendment, as the City did not physically appropriate the property and the closure for code violations did not constitute a regulatory taking. All claims against all defendants were dismissed. View "AB Realty, LLC v. Lane" on Justia Law

A prison inmate was transferred from Phillips State Prison in Georgia, where he had stabbed a high-ranking member of the Bloods gang, to Baldwin State Prison after being placed in protective custody due to the imminent threat of retaliation. The transfer request cited his need for mental health services and mentioned the risk posed by his known enemy, but did not specify risks at Baldwin. Upon arriving at Baldwin, the inmate was placed in the general population, and after briefly requesting protective custody—which he later withdrew—he was stabbed to death by another inmate, allegedly a Bloods member. The parents and estate of the deceased sued five Georgia Department of Corrections officials, alleging that each was deliberately indifferent to the risk of harm under the Eighth Amendment.The United States District Court for the Middle District of Georgia initially dismissed certain wrongful death claims as time-barred, but allowed Eighth Amendment claims by the estate against all five defendants to proceed. The district court ultimately granted summary judgment in favor of the defendants, holding that each was entitled to qualified immunity because there was no violation of clearly established law and no evidence of subjective awareness by any defendant that their conduct caused a substantial risk of harm.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s rulings de novo. The Eleventh Circuit affirmed the district court’s judgment, holding that none of the defendants possessed the requisite subjective knowledge that their actions or inactions placed the inmate at substantial risk of serious harm. Applying the deliberate indifference standard established in Wade v. McDade and Farmer v. Brennan, the court concluded that all defendants were protected by qualified immunity, as there was no constitutional violation. View "McClinton v. Warden" on Justia Law

A nonprofit organization planned to run several political advertisements critical of socialism and the Democratic Socialists of America ahead of the 2025 New York City Mayoral Election. New York’s independent expenditure disclosure law, which requires entities spending money on political elections to register and disclose information about their expenditures, was interpreted by state regulators to cover these advertisements, as the only citywide candidate affiliated with the DSA was running for mayor. The organization feared enforcement of the law against its ads and sought judicial relief.After filing its complaint in the United States District Court for the Southern District of New York, the organization moved for a preliminary injunction to prevent the State from enforcing the disclosure law against its advertisements before the upcoming election. The district court denied this emergency motion. The organization then appealed the denial to the United States Court of Appeals for the Second Circuit while the underlying challenge to the law was stayed in the district court at the organization’s request.The United States Court of Appeals for the Second Circuit dismissed the appeal as moot. The court explained that the motion for preliminary injunction sought relief only for an injury related to the 2025 mayoral election, which had already occurred, making it impossible for the appellate court to grant effectual relief. The court further held that the “capable of repetition, yet evading review” exception to mootness did not apply because the underlying action remained pending in the district court, and thus could still be litigated and reviewed in the future. The appeal was therefore dismissed for lack of a live controversy, with instructions that any future appeals concerning preliminary injunctions in this matter would be heard by the same panel. View "Am. Future Fund, Inc. v. N.Y. Bd. of Elections" on Justia Law

In December 2024, Colton Kenneth Defoe was stopped by a McKenzie County Sheriff’s officer due to an outstanding warrant. The officer cleared Defoe’s vehicle of other passengers and used a K-9 unit to inspect the car, which resulted in an alert for narcotics. A search revealed a plastic baggie and a bindle, both containing methamphetamine residue, and a plastic tube with burn marks. Although Defoe and his passengers denied possession, lab tests confirmed methamphetamine in both the baggie and the bindle, while the tube yielded inconclusive results. No gabapentin was detected, contrary to initial suspicions.Defoe was charged in the District Court of McKenzie County, Northwest Judicial District, with possession of methamphetamine, possession of drug paraphernalia, and driving under suspension. Two additional charges were dismissed before trial. The jury found Defoe guilty on all counts, and the district court entered judgment. Defoe appealed, arguing improper jury instructions deprived him of due process and that there was insufficient evidence to support his convictions. He did not object to the jury instructions at trial but argued the issue in his Rule 29 motion for acquittal, which was denied.The Supreme Court of North Dakota reviewed the appeal. It held that Defoe had not preserved any challenge to the jury instructions for appellate review, as he failed to object distinctly and specifically as required under N.D.R.Crim.P. 30(c). The Court also found no plain error in the instructions, concluding they accurately stated the law and did not mislead the jury. Additionally, the Court determined that substantial evidence supported the jury’s verdicts. The criminal judgment was affirmed. View "State v. Defoe" on Justia Law

On the afternoon of July 31, 2022, a shooting occurred at a BP gas station in Overland Park, Kansas. Surveillance video captured Zarrell Semaj Finley retrieving an AK-47 from a backpack and shooting Shaquille Jackson multiple times following a brief physical struggle over the backpack. Finley then fled the scene with others, leaving Jackson, who later died from his wounds. During a subsequent police interview, Finley admitted to drinking heavily before the incident and claimed he acted in self-defense, believing Jackson was armed and posed a threat. Finley's sister testified that the firearm belonged to her, and Finley had been drinking on the day of the shooting.In Johnson District Court, Finley was charged with first-degree premeditated murder and criminal possession of a weapon by a convicted felon, to which he pleaded guilty to the weapons charge. The murder charge proceeded to trial, where the jury found Finley guilty, and the court imposed a life sentence. At trial, the court denied Finley’s requests for jury instructions on voluntary intoxication and heat of passion voluntary manslaughter. The court also declined to instruct on voluntary manslaughter based on defense of an occupied vehicle, but did instruct on imperfect self-defense voluntary manslaughter and other lesser included offenses.The Supreme Court of the State of Kansas reviewed Finley’s direct appeal. The court held that the district court properly refused Finley’s requested jury instructions because the evidence did not support a finding of impairment sufficient for voluntary intoxication, nor was there legally sufficient provocation for heat of passion manslaughter or factual basis for a defense of an occupied vehicle instruction. The court found that any prosecutorial errors during closing argument were harmless beyond a reasonable doubt. Finally, it concluded that sufficient evidence supported the jury’s finding of premeditation. The court affirmed Finley’s conviction. View "State v. Finley " on Justia Law

The petitioner was convicted of continuous sexual abuse of a child, involving at least twenty acts against a minor between November 2019 and August 2020. Sentenced in March 2022, he appealed his conviction, which was affirmed by the North Dakota Supreme Court in November 2022. In March 2023, he filed his first postconviction relief petition, which was denied by the District Court of Ward County and affirmed on appeal in March 2024. On April 29, 2025, the petitioner filed a second postconviction relief petition, alleging constitutional violations based on alleged withholding of evidence and false testimony by the State, citing Glossip v. Oklahoma, 604 U.S. 226 (2025).After the State answered the petition—raising the statute of limitations, res judicata, and misuse of process as affirmative defenses—it moved for summary disposition on the basis of misuse of process but omitted the statute of limitations in its motion. The district court, however, ordered briefing on the statute of limitations and the impact of Glossip. Neither party scheduled a hearing, and the court ultimately granted summary disposition and dismissed the petition as untimely.The Supreme Court of North Dakota reviewed the appeal. It held that the State preserved the statute of limitations defense by raising it in its answer, and the district court could properly consider that defense even though it was not included in the State’s summary disposition motion. The Court determined that the petitioner forfeited his hearing request by failing to schedule it, and that the district court provided adequate notice and opportunity to respond regarding the statute of limitations issue. The Court found the petitioner failed to show that his claim fell within an exception to the statute of limitations for a new interpretation of law. The Supreme Court of North Dakota affirmed the district court’s dismissal of the petition. View "Archambault v. State" on Justia Law

The case concerns James Guzman, who was convicted of the murder of David Colvin. Guzman has been tried three times for Colvin's murder, with the most recent conviction occurring in 2016. Following this conviction, Guzman has undergone four penalty-phase proceedings, each resulting in a death sentence. The current appeal focuses on the fourth penalty phase and the resulting death sentence, which followed a unanimous jury recommendation. During that penalty phase, Guzman moved to disqualify the judge based on her prior employment at the law firm (Rice and Rose) that represented him in his first appeal, though she did not work on his case or any criminal matters at the firm.Previously, the Circuit Court for the Seventh Judicial Circuit conducted the penalty phase, presided over jury selection, and ruled on Guzman's motion to disqualify the judge, finding it legally insufficient. The jury found four aggravating factors and recommended death, and the judge imposed the sentence after considering both aggravating and mitigating circumstances. Guzman appealed, raising issues regarding the judge’s disqualification, the jury instructions on victim impact testimony, and the constitutionality of the death penalty.The Supreme Court of Florida reviewed the case and affirmed the lower court’s decisions. The Court held that Guzman’s motion to disqualify the judge was legally insufficient, as the allegations did not establish an objectively reasonable fear of bias or prejudice. The Court also found Guzman’s challenge to the jury instructions regarding victim impact testimony was unpreserved and, even if preserved, meritless, since the instructions given were adequate. Finally, the Court rejected Guzman’s argument that the death penalty is inherently cruel and unusual, citing longstanding precedent. The disposition by the Supreme Court of Florida was to affirm Guzman’s sentence of death. View "Guzman v. State of Florida" on Justia Law

A masked individual entered Plato’s Closet in Jonesboro, Arkansas, threatened employees with what appeared to be a handgun, and stole $598 before fleeing in a gray Mercury sedan. Shortly after, law enforcement stopped Pierre Wright, who was driving a vehicle matching the description. Officers found clothing matching the suspect’s, an imitation firearm, and a Plato’s Closet bag containing $598 in the car. Additional evidence, including GPS and cell-phone data, further linked Wright to the crime.The State charged Wright with aggravated robbery and theft of property and sought to classify him as a habitual offender based on prior Tennessee convictions. At trial in the Craighead County Circuit Court, Wright moved for directed verdicts, arguing insufficient evidence of his identity as the robber. The circuit court denied these motions, and the jury found Wright guilty. During sentencing, the State introduced certified records of Wright’s prior Tennessee convictions—one for aggravated robbery and two for aggravated burglary—and argued that the Tennessee aggravated-burglary offenses were comparable to Arkansas’s aggravated residential burglary, making Wright eligible for a mandatory life sentence under Arkansas Code Annotated section 5-4-501(d). The circuit court agreed and imposed the life sentence.On appeal to the Supreme Court of Arkansas, Wright raised three arguments: the sufficiency of the evidence, the comparability of his Tennessee convictions to Arkansas offenses for sentencing enhancement, and the propriety of his mandatory life sentence. The Supreme Court of Arkansas held that the evidence was sufficient to support the convictions, that the circuit court did not abuse its discretion in finding the Tennessee aggravated-burglary convictions comparable to the Arkansas statute, and that the mandatory life sentence was proper. The Court affirmed the judgment and sentence. View "WRIGHT v. STATE OF ARKANSAS" on Justia Law

On October 18, 2022, a fatal shooting occurred in the parking lot of The Ridge apartment complex in Little Rock, Arkansas. The evidence at trial established that Ferrad McCoy traveled with Mason Abraham from Memphis to Little Rock, where Abraham, as the passenger in a white Infiniti, shot and killed Broderick Blueford. Law enforcement later pursued the same vehicle on Interstate 40, resulting in a high-speed chase and crash. Both McCoy and Abraham fled on foot but were apprehended nearby. Physical evidence, including firearms, shell casings, a cell phone, and a hoodie matching McCoy’s attire, as well as video footage and cell phone records, linked both men to the crime and location.The Pulaski County Circuit Court presided over a jury trial in which McCoy was convicted of capital murder, first-degree unlawful discharge of a firearm from a vehicle, and firearm enhancements. He received life imprisonment plus additional years for the enhancements. McCoy challenged the sufficiency of the evidence and objected to the admission of several items, including photographs, firearms, video footage, and a “BOLO” flyer. He also raised issues regarding jury instructions and the Confrontation Clause.The Supreme Court of Arkansas reviewed the case, applying the substantial evidence standard and broad discretion for evidentiary rulings. The Court held that there was substantial evidence to support the convictions, properly admitted the contested evidence, and found no reversible error in the circuit court’s rulings. The Court also determined that McCoy’s jury instruction and Confrontation Clause arguments were either waived or without merit. The convictions and sentences imposed by the Pulaski County Circuit Court were affirmed. View "MCCOY v. STATE OF ARKANSAS" on Justia Law

The defendant was charged with deliberate homicide following an arrest in March 2021. Initially released on bond, he was later taken into custody after missing a required hearing. At a pretrial release revocation hearing, the State was represented by then-Deputy County Attorney Brett Linneweber. Over time, the defendant changed attorneys multiple times, displaying distrust toward counsel and initially refusing to accept any plea agreement. Ultimately, after negotiations, he agreed to plead guilty to mitigated deliberate homicide in exchange for a binding sentencing recommendation and dismissal of other charges. Before the plea hearing, Judge Linneweber, who had since been appointed to the bench, was assigned to the case. Although he had previously appeared for the State in a related proceeding, he determined his involvement was minimal and did not recuse himself, accepting the defendant’s guilty plea.After his plea, the defendant filed a motion for Judge Linneweber’s disqualification, which was referred to the Montana Supreme Court. Judge Linneweber then recused himself, and the motion was denied as moot. The defendant later sought to withdraw his guilty plea, citing involuntariness, ineffective assistance of counsel, newly discovered evidence, and pressure to accept the plea, but did not explicitly raise the disqualification issue as a basis for withdrawal. The Thirteenth Judicial District Court denied the motion, finding no evidence that the plea was not knowing or voluntary and that the new evidence could have been discovered earlier.The Supreme Court of the State of Montana reviewed whether the failure to recuse constituted good cause for plea withdrawal. The Court held that Judge Linneweber’s prior involvement as counsel required disqualification by statute and rule. The failure to recuse was a due process violation and constituted good cause to withdraw the guilty plea. The Court reversed the District Court’s order and remanded for further proceedings. View "State v. Notafraid" on Justia Law