Justia Constitutional Law Opinion Summaries

A registered nurse working in a hospital’s Mother Baby Unit requested a religious exemption from her employer’s mandatory COVID-19 vaccination policy. Her request, which cited Christian beliefs regarding the sanctity of life and objections to the use of abortion-derived cell lines in vaccine development and testing, was denied. The hospital had followed an executive order issued by the Oregon governor, requiring all healthcare workers to be vaccinated unless granted a medical or religious exemption. The nurse was subsequently terminated for failure to comply with the vaccination mandate.The nurse filed suit in the United States District Court for the District of Oregon. She alleged a Free Exercise claim under 42 U.S.C. § 1983 against individual members of the hospital’s Board of Directors and Vaccine Exception Review Committee, and a Title VII claim against the hospital for failure to accommodate her religious beliefs. The district court granted the individual defendants’ motion to dismiss the Free Exercise claim on qualified immunity grounds, finding that the right to refuse a state-mandated vaccine on religious grounds was not clearly established in 2021. The court denied the hospital’s motion to dismiss the Title VII claim but later granted summary judgment for the hospital, holding that accommodating the nurse’s request would have imposed undue hardship due to health, safety, operational, and financial risks.The United States Court of Appeals for the Ninth Circuit reviewed the case. It affirmed the district court’s dismissal of the Free Exercise claim, holding that the individual defendants were entitled to qualified immunity because no clearly established law in 2021 recognized a healthcare worker’s religious right to a vaccine exemption under those circumstances. The court also affirmed summary judgment for the hospital on the Title VII claim, concluding that the hospital demonstrated undue hardship in accommodating the nurse without substantial risk to patients and operations. View "MACDONALD V. OREGON HEALTH AND SCIENCE UNIVERSITY" on Justia Law

The case involves William Castillo, who was convicted and sentenced to death for the murder of Isabelle Berndt in Las Vegas, Nevada. Castillo used a key he found while working as a roofer at Berndt’s home to later enter her residence with an accomplice, steal items, and fatally attack Berndt with a tire iron. Subsequently, he returned to the home to set it on fire. Evidence recovered from Castillo’s apartment linked him to the crime. He confessed to the robbery, murder, and arson during police interrogation and was convicted by a jury on multiple counts, including first-degree murder. The penalty phase included testimony regarding his abusive childhood and mental health, but the jury imposed a death sentence.After his conviction, Castillo appealed to the Nevada Supreme Court, which affirmed both the conviction and sentence. His state post-conviction relief (PCR) petition was denied by the trial court and affirmed by the Nevada Supreme Court. Castillo then filed a federal habeas corpus petition in the United States District Court for the District of Nevada. He voluntarily dismissed the petition, but later moved to reopen it. His subsequent amended petitions were dismissed by the district court as untimely or procedurally defaulted. The district court granted a certificate of appealability for four claims and denied it for two others.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that Castillo’s first and second amended habeas petitions were untimely and equitable tolling was not warranted. The court affirmed denial of relief on most claims, including ineffective assistance of trial counsel and the as-applied Eighth Amendment challenge to Nevada’s lethal injection protocol. However, the court reversed the district court’s ruling on two claims, finding that attorney error in state PCR proceedings could excuse procedural default under Martinez v. Ryan and Hogan v. Bean. Those claims were remanded for further proceedings. The court affirmed denial of certificates of appealability for the remaining claims. View "CASTILLO V. BEAN" on Justia Law

Federal agents suspected that an individual was using his auto garage as a front for narcotics distribution. After two controlled purchases of cocaine and ongoing surveillance, agents obtained a warrant to search his house and the surrounding grounds for evidence of drug crimes. The warrant did not specifically list vehicles among the items to be seized. Upon executing the warrant, agents found a blue minivan and a red truck parked in the driveway. Although a search of the vehicles initially revealed no contraband, the agents seized them for civil asset forfeiture, believing the minivan was used to facilitate drug sales and the truck was purchased with drug proceeds. Later, after receiving a tip, agents obtained a separate warrant to search the minivan and discovered cocaine and a firearm hidden in a secret compartment.The United States District Court for the District of Connecticut denied the defendant’s motion to suppress the evidence found in the minivan. The court reasoned that, under Florida v. White, law enforcement does not need a warrant to seize forfeitable vehicles from places where officers are lawfully present, even private driveways. The defendant subsequently pleaded guilty while preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Second Circuit reviewed the case. The Court held that the warrantless seizure of the minivan from the private driveway was reasonable under the Fourth Amendment since the agents had a warrant authorizing them to be present on the property and search its grounds. The Court explained that such a seizure did not constitute an invasion of privacy. The Court distinguished this case from United States v. Lasanta, finding Lasanta inapposite because the agents here had a search warrant for the property, unlike in Lasanta. The judgment of the district court was affirmed. View "United States v. Acevedo" on Justia Law

The case involves a defendant convicted of first degree murder and use of a deadly weapon to commit a felony. The defendant was part of a group that planned to purchase marijuana but instead decided to rob the victim, resulting in the victim’s death. At trial, the prosecution’s key witness testified that the defendant was the shooter. Another witness identified the perpetrators as three black males, while the defendant is white. The defendant was sentenced to life imprisonment and 25 to 30 years for the respective convictions. His direct appeal, handled by the same attorney as at trial, was unsuccessful.Subsequently, the defendant filed a motion for postconviction relief in the District Court for Douglas County, asserting ineffective assistance of counsel relating to a juror who allegedly exhibited bias during voir dire and was not removed by peremptory challenge or on appeal. He also claimed that the State failed to disclose implied plea agreements with two witnesses, violating his constitutional rights. The district court denied all claims without an evidentiary hearing, finding the juror claims were refuted by the record and the plea agreement claims were either procedurally barred, unsupported by facts, or harmless error.The Nebraska Supreme Court reviewed the case. It affirmed the district court’s denial of an evidentiary hearing regarding all claims about the juror and the claim concerning an implied plea agreement with one witness, finding the record did not support allegations of juror bias, ineffective assistance, or an undisclosed agreement. However, the court reversed in part, holding that the defendant was entitled to an evidentiary hearing on the claim that the State failed to disclose an implied plea agreement with another witness. The court directed that the case be remanded for this limited evidentiary hearing. Thus, the judgment was affirmed in part and in part reversed and remanded with directions. View "State v. Elseman" on Justia Law

A politically active resident of East Cleveland, Ohio, who had long used a sound truck to broadcast political messages, supported a challenger in a mayoral primary. After this involvement, city officials began enforcing rarely used parking and noise ordinances against him. The plaintiff was warned, cited, had his truck impounded, and was prosecuted for a noise violation. He alleged that these actions were motivated by his support for the challenger and criticism of the administration. The plaintiff, along with his company, brought claims under 42 U.S.C. § 1983 against the city, the mayor, the mayor’s chief of staff, and the police chief, asserting First Amendment retaliation and prior-restraint violations, as well as Fourth and Fourteenth Amendment claims.The United States District Court for the Northern District of Ohio resolved all claims in favor of the defendants. Some claims—including First Amendment retaliation claims against the mayor and chief of staff—were dismissed at the pleading stage, while others were resolved at summary judgment. The court found that the ordinances were facially valid and that the plaintiff had either failed to establish the required elements for his claims or had forfeited certain arguments on appeal.On appeal, the United States Court of Appeals for the Sixth Circuit revived certain First Amendment retaliation claims. It held that the district court erred in applying the probable cause requirement to the retaliation claims against the mayor and chief of staff, reversing their dismissal. The court affirmed summary judgment for the police chief on qualified immunity grounds, finding no clearly established law that would make him liable as a conduit for another’s retaliatory motive. As to the city, the court vacated summary judgment on retaliation, remanding for further proceedings on whether municipal policy directly caused a constitutional violation. The court affirmed the district court on all other claims, including the prior-restraint and Fourth Amendment seizure claims, and noted that the plaintiff had forfeited his selective enforcement arguments on appeal. View "Fambrough v. City of E. Cleveland" on Justia Law

In this case, the defendant allowed two sixteen-year-old girls who had run away from a treatment facility to stay in his home for ten days. During that period, he provided them with drugs and made repeated sexual advances, subjecting one girl to sexual contact. He later pleaded guilty to attempted sexual assault and distributing a controlled substance to a minor. A Sex Offender Management Board evaluator determined, using the Sexually Violent Predator Assessment Screening Instrument, that the defendant met the criteria of a sexually violent predator (SVP), largely based on his risk assessment score. The district court designated him as an SVP and sentenced him to fifteen years in prison, finding that the SVP designation was not punishment but rather intended to protect the community.The Colorado Court of Appeals affirmed the district court’s decision. The appellate division held that the SVP designation was not “punishment” under the Eighth Amendment, relying on prior precedent and distinguishing a recent case involving juvenile sex offender registration. The division noted some tension between the precedents, but concluded that the previous holding that SVP designation was not punishment remained controlling, as the juvenile case did not expressly overrule it.The Supreme Court of Colorado reviewed whether the SVP designation constitutes criminal punishment under the Eighth Amendment and, if so, whether it is cruel and unusual as applied. The court held that the Colorado General Assembly did not intend the SVP designation to be punitive, and that its effects do not, by the “clearest proof,” outweigh this nonpunitive intent. After analyzing statutory intent and applying the Mendoza-Martinez factors, the court concluded that the SVP designation and its accompanying requirements do not amount to punishment under the Eighth Amendment. Accordingly, the Supreme Court of Colorado affirmed the judgment of the court of appeals. View "Beagle v. People" on Justia Law

The defendant was charged with three counts of sexual assault and pleaded not guilty. During the jury trial, the prosecution submitted instructions for lesser-included attempt offenses, and the court accepted them over the defense’s objection. The jury received verdict forms allowing them to find the defendant not guilty of both the completed and attempted offenses, or guilty of one or the other, but could not indicate acquittal on the main charge while deadlocked on the lesser charge. After several days of deliberation, the jury notified the court in writing that it had reached a unanimous verdict on the main charges but was deadlocked on the lesser-included attempt offenses. The court confirmed the jury’s meaning through clarifying questions.Defense counsel requested revised verdict forms to allow the jury to separately indicate its decisions on the completed and attempted offenses, and also asked to poll the jury. The Larimer County District Court denied both requests and declared a mistrial on all charges. The defendant sought review under Colorado Appellate Rule 21, arguing that an ordinary appellate remedy was inadequate and he would otherwise suffer irreparable harm.The Supreme Court of Colorado, En Banc, reviewed the trial court’s decision for abuse of discretion. It found that the jury’s communication constituted a spontaneous and unequivocal partial verdict—namely, acquittal on the charged offenses. The trial court’s order for a complete mistrial violated the defendant’s right against double jeopardy under the Colorado Constitution. The Supreme Court held that the trial court abused its discretion by failing to accept the partial verdict and instead declared a mistrial as to all offenses. On remand, the defendant may be retried only for the attempt offenses, not for the completed sexual assault charges. View "People v. Mena" on Justia Law

The case arose after the Wyoming Legislature amended the election code to require voters who wished to change their party affiliation before a primary election to do so at least 96 days prior to the primary. Several individuals were affected by this new deadline: some were unable to vote for their preferred candidates in the 2024 primary because they could not change party affiliation after the cutoff, while others, who ran for office, were unsuccessful in their respective primaries. The plaintiffs challenged the constitutionality of the 96-day party affiliation deadline, arguing it violated their rights under the Wyoming Constitution to open, free, and equal elections, untrammeled exercise of suffrage, and equal political rights.The District Court of Laramie County granted summary judgment in favor of the Secretary of State, holding that the statutes establishing the 96-day party affiliation deadline were a valid exercise of legislative authority to regulate elections and did not violate constitutional voting rights or equal protection. The plaintiffs appealed only the district court’s ruling on the party affiliation deadline.The Supreme Court of Wyoming reviewed the case de novo, considering only legal questions as the facts were stipulated. The Court held that the right to vote in Wyoming, including in primary elections, is fundamental, but that the legislature is also constitutionally charged with securing the purity of elections. Employing a balancing approach informed by the Anderson-Burdick standard, the Court found the 96-day deadline imposed only a slight burden on voting rights, justified by the state’s legitimate interest in preventing party raiding and ensuring orderly elections. The Court further held that the deadline did not violate equal protection, as all electors had an equal opportunity to affiliate before the cutoff, and distinctions drawn between new registrants and previously registered voters were not constitutionally impermissible. The Supreme Court of Wyoming affirmed the district court’s judgment. View "Malcom v. Gray" on Justia Law

Brian Pyle sought a writ of mandamus to compel several South Dakota law enforcement agencies and officials to provide him with investigative records regarding the disappearance and death of his son, Ryan. Ryan was reported missing in August 2020, and his remains were found in November 2020 near the Snake Creek Recreation Area. Pyle alleged that he had made numerous requests for medical records and investigative reports, but had not received any documents. He cited Marsy’s Law in the South Dakota Constitution, asserting that as a victim or relative of a victim, he was entitled to these records.The Circuit Court of the First Judicial Circuit, Charles Mix County, initially issued a peremptory writ requiring the respondents to answer. The State, representing all respondents, moved to quash the writ, arguing that the requested records contained confidential criminal justice information exempt from disclosure by law, and that Pyle had not exhausted administrative remedies for accessing such records. The State also contended that, since law enforcement found no evidence of foul play and concluded no crime had occurred, Marsy’s Law did not apply. After a hearing, in which no testimony or evidence was presented, the circuit court granted the State's motion, quashed the writ, and denied Pyle's application, finding Pyle was not a victim under Marsy’s Law and that no mandatory duty existed to disclose the records.On appeal, the Supreme Court of the State of South Dakota reviewed the circuit court’s decision for abuse of discretion and questions of law de novo. The Supreme Court held that Marsy’s Law requires a crime to have occurred for someone to be considered a victim and to invoke its rights. Because law enforcement determined no crime had been committed, Pyle was not entitled to the records under Marsy’s Law. Further, the Supreme Court found that South Dakota statutes exempt criminal investigative records from mandatory disclosure. The circuit court’s decision was affirmed. View "Pyle v. S.D. Division Of Criminal Investigation" on Justia Law

The case concerns a fatal incident following an argument among Katrina Carvalho, her sister Regina, and Regina’s boyfriend, Vintell Johnson. After dinner, the three argued in Johnson’s apartment complex parking lot. Witnesses testified that Johnson shoved both sisters, and Carvalho was seen pointing a gun at Johnson and another bystander. Moments later, gunshots were heard, and Johnson was fatally wounded. The prosecution charged Carvalho with first-degree murder with the use of a deadly weapon. At trial, Carvalho’s defense was that another person, specifically Regina, may have fired the shots, and she highlighted weaknesses in the police investigation and the possibility of alternative suspects.The Second Judicial District Court, Washoe County, presided over the second trial after a mistrial was declared in the first due to late evidence disclosure. During closing arguments, the district court repeatedly interrupted, admonished, and ultimately sanctioned defense counsel for arguing that the evidence equally implicated Regina. The court instructed the jury not to consider Regina’s guilt or speculate about her involvement, effectively preventing the defense from fully presenting its alternative-suspect theory. The jury found Carvalho guilty, and she was sentenced to life in prison with the possibility of parole after 28 years.The Supreme Court of the State of Nevada reviewed the appeal. It held that the district court abused its discretion by foreclosing Carvalho’s opportunity to present an alternative-suspect defense, violating her due process right to a meaningful opportunity to present a complete defense. The court ruled that while a jury should not be asked to determine the guilt of someone other than the defendant, it is permissible for the defense to argue that reasonable doubt exists because the evidence supports an alternative suspect. The Supreme Court reversed the conviction and remanded the case for a new trial before a different department. View "CARVALHO VS. STATE" on Justia Law