Justia Constitutional Law Opinion Summaries

In July 2023, law enforcement responded to an incident in which James Jacobs allegedly discharged a firearm during a dispute with his girlfriend at his home. During a subsequent search, officers discovered two firearms. Jacobs, who has a prior felony conviction and a previous misdemeanor conviction for domestic battery in West Virginia, admitted to knowing he was prohibited from possessing firearms. As a result, a grand jury in the Northern District of West Virginia indicted him for possessing firearms after a felony conviction under 18 U.S.C. § 922(g)(1) and after a misdemeanor crime of domestic violence under § 922(g)(9).The United States District Court for the Northern District of West Virginia granted Jacobs’ motion to dismiss both counts of the indictment. The district court, employing the framework from New York State Rifle & Pistol Association v. Bruen, found that the government failed to demonstrate a historical tradition of disarming individuals like Jacobs—nonviolent felons and domestic violence offenders. The court concluded that both statutes were unconstitutional as applied to Jacobs and dismissed the charges without reaching the facial challenges.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s rulings de novo. The Fourth Circuit held that recent decisions—including United States v. Rahimi, United States v. Canada, United States v. Hunt, and United States v. Nutter—foreclose Jacobs’ facial and as-applied challenges to § 922(g)(1) and his facial challenge to § 922(g)(9). Accordingly, the court reversed the district court’s dismissal of the § 922(g)(1) charge and barred Jacobs from reviving those challenges. However, the Fourth Circuit determined that further proceedings were necessary regarding Jacobs’ as-applied challenge to § 922(g)(9), vacated the district court’s ruling on that count, and remanded for additional factfinding and analysis. View "United States v. Jacobs" on Justia Law

A telehealth company developed software that enables individuals to determine their refractive eye error using a computer or smartphone without an in-person visit to an optometrist or ophthalmologist. This technology, approved by the FDA and available in many states, was offered in South Carolina until the enactment of the Eye Care Consumer Protection Law in 2016. The law prohibits eye doctors from prescribing spectacles or contact lenses based solely on information from automated equipment, including kiosks or online applications, and requires a valid prescription from a provider following an in-person examination.After the law was enacted, the company ceased providing its service in South Carolina, as local eye doctors were no longer willing to issue prescriptions based solely on remote test results. The company challenged the constitutionality of the law, arguing it violated equal protection and due process guarantees under the South Carolina Constitution. The Circuit Court for Richland County initially granted summary judgment for the defendants, finding the law’s purpose was to protect public health and that its provisions were reasonably related to maintaining the standard of care for medical professionals.Upon direct appeal, the Supreme Court of South Carolina reviewed the case. The Court applied the rational basis test and held that the legislature’s decision to require in-person examinations before prescribing corrective lenses was rationally related to the legitimate government interest of protecting public health. The Court found the classification created by the Act was reasonable and did not violate equal protection, as it treated similarly situated eye doctors alike and addressed unique risks in eye care. The Supreme Court of South Carolina affirmed the circuit court’s grant of summary judgment, upholding the constitutionality of the law. View "Opternative v. South Carolina Optometric Physicians Association" on Justia Law

In this case, the defendant was convicted of felony murder and other offenses stemming from the shooting death of an individual in a parking garage following a dice game. The prosecution’s evidence indicated that the victim and another person were targeted for robbery by a group, including the defendant, after a dispute over gambling losses. Testimony from a co-defendant described the planning and execution of the crime, corroborated by cell phone records, surveillance footage, and forensic evidence. The defendant admitted to being present at the scene but denied active participation in the robbery.The case was initially indicted by a Fulton County grand jury, charging the defendant and four co-defendants with multiple counts. Two co-defendants pleaded guilty, while the defendant and two others were tried jointly before a jury in the Superior Court of Fulton County. The defendant was acquitted of malice murder but convicted on the remaining counts. He was sentenced to life in prison for felony murder, plus additional concurrent and consecutive terms for other offenses. The defendant filed a motion for a new trial, which was denied after an evidentiary hearing.On appeal, the Supreme Court of Georgia reviewed several claims, including sufficiency of the evidence, alleged due process violations regarding co-defendants’ plea deals, the accuracy of jury instructions, and the denial of severance. The Court held that the evidence was sufficient to support the convictions, found no due process violations in the prosecution’s handling of co-defendants’ plea deals, concluded that the jury instructions were proper when viewed in totality, and determined that severance was not required. The Supreme Court of Georgia affirmed the defendant’s convictions. View "WELLS v. THE STATE" on Justia Law

The defendant was charged with multiple counts of sexual assault in the first degree and risk of injury to a child, stemming from multiple incidents of sexual abuse against two minor victims who attended an in-home day care operated by the defendant’s wife in New Haven. The alleged abuse occurred between 2007 and 2012, when the victims were approximately three to eight years old. Each count of sexual assault was predicated on multiple, separate instances of specific sexual acts committed by the defendant. Following police investigations in 2019 and subsequent arrest in 2020, the defendant was tried on these charges.At trial in the Superior Court for the judicial district of New Haven, the prosecution presented evidence of several distinct incidents of sexual abuse. The trial judge provided the jury with a specific unanimity instruction for each count, requiring jurors to unanimously agree that the defendant committed at least one specific instance of the charged conduct in order to find him guilty on any particular count. The jury found the defendant guilty on all counts of sexual assault and risk of injury to a child, and the court sentenced him to a total effective sentence of twenty-five years, with execution suspended after twenty-one years and ten years of probation.On direct appeal to the Connecticut Supreme Court, the defendant argued that his federal constitutional right to a unanimous jury verdict was violated because the trial court did not require the jury to answer special interrogatories regarding unanimity on each alleged incident, despite providing proper unanimity instructions. The Connecticut Supreme Court held that the constitution does not require special interrogatories in addition to specific unanimity instructions for counts charging multiple instances of conduct. The court affirmed the judgments of conviction. View "State v. Carlos G." on Justia Law

A police officer in Peoria, Illinois, encountered a parked vehicle in a closed, dark parking lot at around 2:45 a.m. Inside the vehicle were Dazmine Erving and a female companion. The officer observed Erving make a sudden movement that appeared to be an attempt to hide something, smelled burnt cannabis, and noticed the woman provided false identification information. The officer determined that Erving was on federal supervised release for a weapons offense, only twelve days into his release. After allowing both individuals to retrieve their belongings, the officer conducted a limited search under the driver’s seat, where he discovered a handgun. Erving admitted ownership of the firearm.The United States District Court for the Central District of Illinois reviewed Erving’s motion to suppress the firearm, arguing the search was not justified under the Fourth Amendment. The district court found the officer’s testimony credible and held that, considering the totality of circumstances—furtive movement, odor of cannabis, Erving’s criminal history, and his companion’s false statements—a protective search was warranted. Erving’s motion to suppress was denied. He then pleaded guilty to unlawful possession of a firearm as a felon and admitted to violating supervised release; the court sentenced him to the upper range of the advisory Guidelines and imposed a consecutive sentence for the supervised release violation.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed. The court found the protective search justified under the Fourth Amendment, as the officer had reasonable suspicion that Erving was dangerous and could gain immediate access to a weapon. The appellate court also rejected Erving’s arguments regarding procedural and constitutional errors at sentencing, concluding the district court did not rely on impermissible factors or speculation in imposing sentence. The denial of the suppression motion and the sentencing decision were affirmed. View "United States v. Erving" on Justia Law

Raymond Richardson was indicted for first-degree robbery under West Virginia law, specifically charged with using the threat of deadly force against Denise Cool to steal money. However, at trial, the prosecution presented evidence that Richardson accomplished the robbery by physically assaulting Cool rather than by threatening her with a deadly weapon. Richardson admitted to hitting Cool but denied taking her money. The jury found him guilty of first-degree robbery, assault during the commission of a felony, and possession with intent to deliver cocaine. The central issue on appeal concerned the alleged variance between the indictment and the State’s theory at trial.Following his conviction, Richardson sought post-conviction relief in state court, arguing that his trial counsel was ineffective for failing to object to the variance between the indictment and the evidence presented at trial. At an evidentiary hearing, Richardson and his trial counsel testified. Counsel acknowledged missing the indictment’s specific language but stated that the variance did not affect the defense strategy, which was focused on denying any theft rather than disputing the manner in which the robbery was committed. The state court denied habeas relief, finding Richardson had sufficient notice of the charges and was not prejudiced by the variance. The West Virginia Supreme Court of Appeals affirmed, concluding the difference between the indictment and trial evidence did not mislead Richardson or prejudice his defense.On federal habeas review, the United States District Court for the Southern District of West Virginia denied Richardson’s petition, finding he received adequate notice under the Fourteenth Amendment. The United States Court of Appeals for the Fourth Circuit affirmed, holding that the variance did not violate due process because Richardson was convicted of the offense charged, had actual notice of the evidence to be presented, and failed to show that the variance hindered his defense. The court found no ineffective assistance of counsel or prejudice and affirmed the district court’s denial of habeas relief. View "Richardson v. Frame" on Justia Law

Plaintiffs, consisting of individuals and gun rights organizations, challenged multiple Maryland statutes and regulations that prohibit the carrying of firearms in a range of locations, including government buildings, mass transit, school grounds, public demonstrations, state parks and forests, healthcare facilities, places of amusement, locations selling alcohol, and private property. The plaintiffs claimed these laws violated their Second Amendment rights, arguing that the restrictions could not be justified under the Supreme Court’s “sensitive places” exception to the right to bear arms.The United States District Court for the District of Maryland consolidated the cases and ruled on cross-motions for preliminary injunction and summary judgment. It denied injunctive relief for most challenges, including those relating to museums, healthcare facilities, mass transit, state parks and forests, places of amusement, school grounds, and government buildings. However, it granted injunctive relief to plaintiffs for the restrictions on carrying guns on private property held open to the public, at public demonstrations, and at locations selling alcohol for on-site consumption. All summary judgment motions were initially denied without prejudice; on renewal, the district court granted summary judgment in part and denied it in part. Both sides appealed.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo and issued a comprehensive decision applying Supreme Court precedent, particularly District of Columbia v. Heller and New York State Rifle & Pistol Association, Inc. v. Bruen. The Fourth Circuit affirmed the constitutionality of Maryland’s restrictions on carrying firearms in government buildings, mass transit, school grounds, state parks and forests, museums, healthcare facilities, stadiums, racetracks, amusement parks, and casinos. It also reversed the district court and upheld Maryland’s restrictions at public demonstrations and locations selling alcohol. However, the Fourth Circuit affirmed the district court’s ruling that Maryland’s ban on carrying firearms on private property held open to the public without express permission is unconstitutional, and found plaintiffs lacked standing to challenge the restriction on property not held open to the public. The judgment was affirmed in part and reversed in part. View "Kipke v. Moore" on Justia Law

The petitioner was convicted of a federal crime and, after the enactment of the Mandatory Victims Restitution Act of 1996 (MVRA), was sentenced to pay $7,567.25 in restitution to his victim, even though his criminal conduct occurred before the MVRA became law. Years later, the petitioner challenged the continued obligation to pay restitution, arguing that applying the MVRA retroactively to his conduct violated the Ex Post Facto Clause of the Constitution.The United States District Court initially sentenced the petitioner under the MVRA. When the petitioner challenged the restitution order, the United States Court of Appeals for the Eighth Circuit found against him, ruling that restitution under the MVRA is not criminal punishment and thus not subject to the Ex Post Facto Clause. The Eighth Circuit’s decision rested on its interpretation that MVRA restitution was a civil remedy rather than a criminal penalty.The Supreme Court of the United States reviewed the case and reversed the Eighth Circuit’s judgment. The Supreme Court held that restitution imposed under the MVRA constitutes criminal punishment for purposes of the Ex Post Facto Clause. The Court explained that the statutory text and structure, as well as its placement in the criminal code and its role as a penalty imposed at sentencing, demonstrate that restitution under the MVRA is penal in nature. The Court further noted that only criminal defendants can be ordered to pay restitution, it is imposed in criminal proceedings, and the government, not the victim, is the adverse party. The Supreme Court remanded the case for further proceedings consistent with its ruling, allowing the Eighth Circuit to consider other arguments raised by the government. View "Ellingburg v. United States" on Justia Law

The defendant was arrested on October 2, 2021, for misdemeanor driving under the influence and was released after signing a citation promising to appear in court on December 14, 2021. The Riverside County District Attorney filed a misdemeanor complaint on November 17, 2021. The defendant failed to appear on the scheduled date, resulting in a bench warrant for her arrest. After a subsequent stop and another citation, she failed to appear again, leading to another bench warrant. In March 2024, the defendant voluntarily contacted the court, had her matters calendared, and pled not guilty. She later filed a motion to dismiss, arguing her Sixth Amendment right to a speedy trial had been violated due to delays.The Riverside County Superior Court denied the motion, finding the defendant’s own failures to appear contributed to the delay. The defendant then sought review by petitioning the Appellate Division of the Riverside County Superior Court. The Appellate Division, in a divided opinion, held that the prosecution’s failure to file a formal complaint within 25 days as required by Penal Code section 853.6 deprived the trial court of personal jurisdiction and automatically relieved the defendant of any obligation to appear. Based on this, it ordered the trial court to vacate its order and reconsider the motion to dismiss.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the Appellate Division’s decision. It held the lower court had abused its discretion by misinterpreting Penal Code section 853.6. The Court of Appeal clarified that the failure to file charges within 25 days did not relieve a defendant of the obligation to appear or deprive the court of personal jurisdiction. The appellate court issued a writ directing the Appellate Division to vacate its opinion and reconsider the defendant’s writ petition consistent with this interpretation. View "People v. Superior Ct." on Justia Law

The plaintiffs in this case are the sons of Roberto Clemente, a renowned Puerto Rican baseball player, and two corporations they control. The dispute centers on the Commonwealth of Puerto Rico’s use of Clemente’s name and image on commemorative license plates and vehicle registration tags. Proceeds from these items were designated to fund a new “Roberto Clemente Sports District,” a public project that would replace an earlier initiative, Ciudad Deportiva, originally founded by Clemente. The plaintiffs allege that they hold trademark rights in Clemente’s name and that the Commonwealth’s actions were unauthorized and caused public confusion, with many mistakenly believing the Clemente family benefited financially from the program.The plaintiffs brought suit in the United States District Court for the District of Puerto Rico against the Commonwealth, several high-ranking officials, and the Puerto Rico Convention Center District Authority. Their claims included trademark infringement, false association, false advertising, and trademark dilution under the Lanham Act, as well as a takings claim under the Fifth and Fourteenth Amendments. The Commonwealth and the Authority moved to dismiss, arguing sovereign and qualified immunity and failure to state a claim. The district court granted both motions, dismissing all federal claims on immunity and merits grounds, and declined to exercise jurisdiction over non-federal claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court affirmed the dismissal of all claims against the Authority and all claims against the Commonwealth and its officials in their official capacities. It also affirmed dismissal of the false advertising and takings claims. However, the court vacated the dismissal of the Lanham Act claims for trademark infringement, false endorsement, and dilution against the Commonwealth officials in their personal capacities, holding those claims were plausibly alleged and not barred by qualified immunity at this stage, and remanded for further proceedings. View "Clemente Properties, Inc. v. Pierluisi-Urrutia" on Justia Law