Justia Constitutional Law Opinion Summaries

Plaintiffs, low-income African-American women whose children attend public schools in Mississippi, filed suit against state officials, alleging that the current version of the Mississippi Constitution violates the "school rights and privileges" condition of the Mississippi Readmission Act. The district court held that the suit was barred by the Eleventh Amendment and dismissed. Although the Fifth Circuit agreed that a portion of the relief plaintiffs seek is prohibited by the Eleventh Amendment, the court held that the suit also partially sought relief that satisfied the Ex parte Young exception to sovereign immunity. Accordingly, the court affirmed in part, and vacated and remanded in part. View "Williams v. Reeves" on Justia Law

Kendrick Shelvy appealed his burglary conviction, challenging the sufficiency of the evidence presented against him at trial. Because the Mississippi Supreme Court found sufficient evidence to support the verdict and because the verdict was not against the overwhelming weight of the evidence, it affirmed conviction. View "Shelvy v. Mississippi" on Justia Law

The Eleventh Circuit reversed the district court's grant of summary judgment in favor of Worldplay on plaintiff's claim of retaliation under Title VII of the Civil Rights Act. The court held that the district court erroneously applied the court's decision in Gowski v. Peake, 682 F.3d 1299, 1312 (11th Cir. 2012), and required plaintiff to show that the alleged retaliation was sufficiently pervasive to alter the conditions of her employment. However, the proper standard in a retaliation case is the one set out by the Supreme Court in Burlington Northern & Santa Fe Railway Co. v. White, 548 U.S. 53, 57 (2006), where the retaliation is material if it well might have dissuaded a reasonable worker from making or supporting a charge of discrimination. In this case, the court held that a jury must decide plaintiff's retaliation claim and thus remanded for a jury trial. View "Monaghan v. Worldpay US, Inc." on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first degree murder and of conspiracy to commit murder and sentencing Defendant to death, holding that there was no prejudicial error in the proceedings below. Specifically, the Supreme Court held (1) the admission of Defendant's surreptitiously recorded jailhouse statement did not violate Defendant's Sixth Amendment right to counsel, his Fifth Amendment right to counsel and privilege against self-incrimination, his Fourth Amendment right to be free from unreasonable detention, his rights under the Sixth Amendment's confrontation clause, or attendant protections under Evidence Code sections 352 and 1101; (2) one instance of prosecutorial misconduct committed at the guilt phase was not prejudicial; and (3) Defendant was not entitled to relief on his remaining claims of guilt phase and penalty phase error. View "People v. Fayed" on Justia Law

Plaintiff filed suit against the sheriff and sheriff's deputies, alleging that they violated his constitutional right to be free from unreasonable searches and seizures and his right to due process. The Eighth Circuit affirmed the district court's grant of summary judgment to defendants, holding that the deputies were entitled to qualified immunity because a reasonable officer could believe that the location of the keys to a seized vehicle was reasonably related to the suspected crime because it could provide evidence that plaintiff himself placed the car on the property rather than someone else; the seizure of antique handguns, guns in unopened boxes, and holsters were covered under the second warrant authorizing the seizure of any and all handguns in plaintiff's home; the second warrant was sufficiently particular; the sheriff was entitled to summary judgment on claims against him in his individual capacity and in his official capacity; and plaintiff had an adequate state court remedy to obtain the return of the seized items. View "Thiel v. Korte" on Justia Law

The Supreme Court affirmed Defendant's death sentences that were imposed after a second penalty phase, holding that there was no error or abuse of discretion. Defendant was convicted of two counts of first-degree murder and sentenced to death for each murder. The trial court granted a new penalty phase during postconviction proceedings on the grounds that counsel rendered ineffective assistance. After a second penalty phase, a death sentence was again imposed for each murder. The Supreme Court affirmed, holding (1) the trial court did not err by failing to instruct the jury that it must determine beyond a reasonable doubt whether the aggravators were sufficient to impose death and outweighed the mitigators; (2) none of the prosecutor's allegedly improper comments during closing argument rose to the level of fundamental error; (3) competent, substantial evidence supported the finding of the especially heinous, atrocious, or cruel aggravator; (4) the trial court did not abuse its discretion in rejecting two statutory mitigating circumstances presented with respect to both errors; and (5) the sentences of death were proportionate. View "Bright v. State" on Justia Law

When police responded to a call that Brown was shooting a gun inside her home, they found a rifle in Brown’s bedroom. There was no evidence that the gun had been fired in the house. Brown was charged with possessing a firearm without a Firearm Owners Identification (FOID) card, 430 ILCS 65/2(a)(1). Brown asserted that she kept the rifle for self-defense; that she was over 21; and that, although she did not possess a FOID card, she was a law-abiding citizen with no criminal record, history of mental illness, or other disqualifying condition and would have been eligible for a FOID card. She asserted that requiring her to go through the FOID process unconstitutionally infringed upon her fundamental right of self-defense in this “most private of areas.” The White County circuit court dismissed the charge, finding that, as applied to Brown, section 2(a)(1) was unconstitutional. The Illinois Supreme Court vacated, finding that the circuit court unnecessarily reached the constitutional challenge. The court held that the FOID Card Act did not apply to the act of possessing a firearm in the home as a matter of statutory interpretation and, therefore, could not apply to Brown. This was an alternative, nonconstitutional basis for dismissal. In addition, there were unresolved factual issues concerning Brown’s possession of the gun and eligibility for a FOID card, which were the basis of her challenge. View "People v. Brown" on Justia Law

The Colorado General Assembly unanimously adopted legislative rules that set the number of days to a legislative session to 120 days consecutively from the start of the regular session. The rules had one, single, narrow exception: when the Governor declares a state of disaster emergency and has activated the state’s emergency operations plan due to a public health emergency “infecting or exposing a great number of people to disease, agents, toxins, or other such threats.” The General Assembly agreed that in such circumstances, it would count only “working calendar days” toward the 120-day limit. Before the spring of 2020, this narrow exception had never been triggered. On March 14, 2020, recognizing the danger to the public and legislators posed by continuing to congregate at the State Capitol in light of the novel coronavirus spreading throughout the country, the General Assembly adjourned until March 30, 2020. Both chambers extended their adjournments. This suspension of the regular session was without precedent in state history; moreover, because the situation continued to escalate, the Colorado Supreme Court acknowledged the possibility that the legislature might not be able to convene safely before the originally scheduled adjournment sine die on May 6, 2020. Some have questioned whether the legislative rule counting only “working calendar days” during a declared public health disaster emergency ran afoul of article V, section 7 of the Colorado Constitution, such that legislation passed after May 6 in reliance on the rule could be challenged as void. Thus, the General Assembly petitioned the Supreme Court to exercise its original jurisdiction under article VI, section 3 to settle the issue raised. The Supreme Court determined the limitation on the regular legislative in article V, section to "one hundred twenty calendar days" was ambiguous as to whether those calendar days had to be counted consecutively. The Court further answered that the General Assembly reasonably resolved this ambiguity through its unanimous adoption of Joint Rules 23(d) and 44(g). "Together, these rules interpret article V, section 7 to count the 120 calendar days of a regular session consecutively, except in the extraordinary circumstance of a declared public health disaster emergency that disrupts the regular session, in which case only 'working calendar days' (i.e., calendar days when at least one chamber is in session) count toward the 120-day limit." The Court concluded that such an interpretation did not run afoul of either the text or underlying purposes of article V, section 7 and was therefore valid. View "In re Interrogatory on House Joint Resolution 20-1006" on Justia Law

On September 20, 2010, at age of 13 appellant, H.R., was adjudicated delinquent for indecent assault of a complainant less than 13 years of age. Appellant was placed on official probation and, pursuant to Section 6352 of the Juvenile Act, was ordered to undergo inpatient treatment at a sex offender residential treatment facility. Appellant remained in treatment when he turned 20 in February 2017 and he was assessed pursuant to Section 6352, the results of which found that involuntary treatment at a sex offender residential treatment facility pursuant to the Court-Ordered Involuntary Treatment of Certain Sexually Violent Persons Statute (Act 21) was still necessary. On January 4, 2018, following a hearing, a trial court denied appellant's motion to dismiss and granted the petition for involuntary treatment, determining appellant was an sexually violent delinquent child (SVDC) and committing him to one year of mental health treatment. On appeal, appeal, appellant argued: (1) Act 21 was punitive in nature, and this its procedure for determining whether an individual was an SVDC was unconstitutional; and (2) retroactive application of amendments to Act 21 made effective in 2011, was also unconstitutional. The Pennsylvania Supreme Court determined the superior court correctly determined the relevant provisions of Act 21 were not punitive, were constitutional, thus, affirming the trial court's order. View "In re: H.R." on Justia Law

Audrie, the Potts’ daughter, was sexually assaulted while unconscious from intoxication. Her assailants distributed intimate photographs of her. Audrie committed suicide. The Potts, as the registered successors-in-interest to “deceased personality” rights for Audrie under Civil Code 3344.1, authorized the use of Audrie’s name and likeness in a documentary. The Potts sued Lazarin under section 3344.1, claiming that Lazarin (who claims to be Audrie’s biological father) had used Audrie’s name and likeness "for the purpose of advertising services” without their consent. Lazarin admitted that he had displayed Audrie’s photograph “to change the law regarding parental rights” but argued that he had not acted to promote “goods or services.” The Potts submitted evidence that Lazarin solicited donations for a suicide prevention group, using Audrie’s name and photograph. Lazarin brought an unsuccessful special motion to strike the complaint under Code of Civil Procedure 425.16. The court of appeal reversed. Lazarin made a prima facie showing that the Potts’ suit was based on his “written or oral statement or writing made in a place open to the public or a public forum in connection with an issue of public interest.” The Potts failed to establish that there was a “probability” that they would “prevail” on their Civil Code section 3344.1 suit; they did not show that Lazarin “misappropriate[ed] the economic value generated by [Audrie’s] fame through the merchandising” of her name or likeness. View "Pott v. Lazarin" on Justia Law