Justia Constitutional Law Opinion Summaries

The defendant was involved in a fatal altercation at Terry’s Café, where surveillance footage showed he shot and killed an acquaintance, Jeremy Peters, after Peters retrieved and concealed a knife. The defendant was indicted for first-degree murder and three counts of wanton endangerment with a firearm. During his January 2023 trial, several key participants, including the defendant, counsel for both sides, court staff, and at least one juror, contracted COVID-19, leading the Circuit Court of Boone County to declare a mistrial due to health concerns and potential prejudice to both parties.Following the mistrial, the defendant moved to dismiss the charges on double jeopardy grounds, arguing that the retrial was barred because the court failed to consider a brief continuance, which both parties had suggested as an alternative. The Circuit Court denied the motion, finding that the COVID-19 outbreak constituted a manifest necessity for the mistrial and was outside the State’s control. The defendant was retried, found guilty of voluntary manslaughter, acquitted of the wanton endangerment charges, and sentenced to fifteen years of incarceration. He appealed the sentencing order, challenging the mistrial ruling.The Supreme Court of Appeals of West Virginia reviewed the case and held that the circuit court acted within its discretion in determining that a manifest necessity existed for declaring a mistrial due to the widespread COVID-19 outbreak among trial participants. The court concluded that the retrial was not barred by double jeopardy because the mistrial was justified by manifest necessity, even though the procedure for considering alternatives was imperfect. The court affirmed the circuit court’s sentencing order. View "State v. Dickens" on Justia Law

Kelly was suspected of illegal drug activity after Detective Jonathan Smith observed a drug sale involving a black male who left the scene in a red vehicle with a white female passenger. Shortly after, Deputy Cody Jett received an anonymous tip indicating Heather McDonald would arrive in a red Hyundai at a McDonald’s restaurant, accompanied by a black male driver, and that both individuals possessed heroin and were dealing drugs. Deputy Jett verified an arrest warrant for McDonald. At the restaurant, Jett observed a vehicle matching the tip, McDonald, and a black male later identified as Kelly. After Kelly and McDonald responded to Jett’s instructions, McDonald attempted to flee and was apprehended, while Kelly was detained and eventually admitted there were drugs in the vehicle. Officers subsequently obtained a search warrant, found additional evidence, and arrested Kelly for driving with a suspended license and several drug offenses.The United States District Court for the Middle District of Florida initially denied the officers’ motion to dismiss under Heck v. Humphrey, finding it could not conclude at that stage that Kelly’s Fourth Amendment claims were barred. Later, upon motions for summary judgment, the district court granted summary judgment in favor of the officers, holding that Heck barred Kelly’s suit because success would imply the invalidity of his convictions. The district court did not address qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and declined to base its decision on Heck. Instead, the appellate court found that both Deputy Jett and Detective Smith were entitled to qualified immunity because there was probable cause to detain Kelly, given the corroborated anonymous tip and observed circumstances. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Kelly v. Jett" on Justia Law

The case concerns a shooting in a Los Angeles park involving rival gangs. Jesus Guzman, associated with Lawndale 13, was accused of killing David Najera, a member of Muertos 13, after an altercation between the gangs the previous night at a hookah bar. The prosecution argued that Guzman and his gang sought revenge for the prior incident, resulting in Najera’s death and the attempted murder of another Muertos member, Portillo. Evidence against Guzman included eyewitness descriptions, video footage, and information from a confidential reliable informant who identified Guzman by his gang moniker and linked his social media account to the crime.The Superior Court of Los Angeles County presided over Guzman’s trial. The jury convicted Guzman of second-degree murder and premeditated attempted murder, finding that a principal—but not Guzman himself—personally and intentionally discharged a firearm causing death. Guzman was sentenced to 22 years to life. The central issue on appeal was Guzman’s challenge to the police search of his social media account, arguing that the affidavit supporting the search warrant lacked sufficient probable cause and did not establish a link between his account and the crime.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that the evidence obtained from Guzman’s social media account was properly admitted because, at a minimum, the good-faith exception to the exclusionary rule applied. The affidavit supporting the search warrant provided a reasonable basis for police to believe the warrant was valid, and it was reasonable to infer that the social media account would contain relevant evidence. The judgment of the trial court was affirmed. View "People v. Guzman" on Justia Law

A Sedona resident, who has obsessive-compulsive disorder, often sleeps in her car because her disability prevents her from entering her apartment. The City of Sedona has a criminal ordinance prohibiting sleeping in a vehicle on public or private property. The resident was twice warned by police for sleeping in her car and requested reasonable accommodation under the Americans with Disabilities Act (ADA) to exempt her from enforcement of this ordinance. The city denied her requests, and her landlord threatened not to renew her lease if she continued sleeping in her car. She alleges that the city’s actions caused her emotional distress and loss of income, and she continues to sleep in her car several times a week.The United States District Court for the District of Arizona dismissed her claims for lack of standing, finding that the prior police warnings were insufficient to support a specific threat of prosecution and that she failed to allege a history of enforcement against similarly situated individuals. The district court addressed only her standing to seek injunctive relief, despite her claims for damages as well. Her requests to amend her complaint were denied, and she appealed.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s dismissal. The Ninth Circuit held that she had Article III standing to bring an ADA claim for both damages and injunctive relief, based on the city’s denial of her request for accommodation and a credible threat of future enforcement. The court further held that Title II of the ADA applies to requests for reasonable accommodation to comply with municipal criminal ordinances. The ADA claim was remanded for further proceedings, allowing her to amend her complaint, while the dismissal of her Eighth Amendment claim was affirmed. View "BERAM V. CITY OF SEDONA" on Justia Law

The plaintiff, John William Scharnhorst, III, was held as a pretrial detainee at the Washington County Detention Center (WCDC) for several months. During his detention, he experienced restrictions on access to books, newspapers, and religious materials. WCDC implemented these restrictions in response to issues with inmates using paper for illicit purposes, such as jamming locks, flooding cells, concealing contraband, and making weapons. The facility limited inmates to four books—three from a book cart and one religious text—and transitioned to providing electronic access to books and newspapers via kiosks and tablets, though access to these devices was time-limited. While religious materials and paper mail could be requested, Scharnhorst claimed that staff inconsistently delivered these materials.The United States District Court for the Western District of Arkansas, adopting a magistrate’s recommendation, granted summary judgment to some defendants and found moot the preliminary injunction requiring daily newspaper uploads. However, it denied summary judgment and qualified immunity to Sheriff Cantrell, Major Denzer, and Lieutenant Ake, finding material disputes about their enforcement of WCDC policies and concluding that, if enforced as alleged, the restrictions violated clearly established First Amendment rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of qualified immunity. Accepting the facts found or likely assumed by the district court, the appellate court held that Scharnhorst did not demonstrate a violation of clearly established law. The Eighth Circuit found that WCDC’s policies did not amount to a “de facto permanent ban” on communication or access to religious materials, as inmates retained access to mail, electronic newspapers, and religious texts. Consequently, the court reversed the district court’s denial of qualified immunity to the defendants and remanded for further proceedings. View "Scharnhorst v. Cantrell" on Justia Law

Several misdemeanor prosecutions were consolidated in a municipal court after the City Attorney for Henderson argued that Nevada Revised Statute 178.4849(1), which requires pretrial release hearings within 48 hours of arrest, impaired prosecutors’ ability to prepare adequately for those hearings. The City sought a declaration that the statute was unconstitutional under Marsy’s Law and the separation-of-powers doctrine. In each case, defendants were arrested on weekends and brought before the municipal court within 24 hours. The City asserted that the compressed timeline undermined its ability to protect victims’ rights and to present sufficient evidence for bail determinations.The Henderson Municipal Court consolidated the cases and found that the City had both direct standing and third-party standing to challenge the statute on behalf of victims. It declared NRS 178.4849 unconstitutional under Marsy’s Law and separation-of-powers principles, citing conflicts with statewide pretrial risk assessment requirements and judicial precedent. Respondents petitioned the Eighth Judicial District Court for a writ of mandamus or prohibition. The district court concluded the City lacked both direct and third-party standing, as it failed to demonstrate a concrete, traceable injury and victims were not hindered from asserting their own interests. The district court also found the statute constitutional and granted the petition.Reviewing the appeal, the Supreme Court of the State of Nevada determined that the City of Henderson had not established standing. It found no concrete injury to the City’s prosecutorial interests that was traceable to NRS 178.4849 or likely to be redressed by the requested relief. The court held that the City lacked both direct and third-party standing, and the public-importance exception did not apply. Without standing, the court declined to address the constitutional merits and affirmed the district court’s order granting the writ. View "CITY OF HENDERSON VS. ARMENDAREZ" on Justia Law

Stefanie Boone, a parent with children enrolled in Lowell Area Schools, publicly criticized the district’s curriculum and practices, particularly those she saw as promoting diversity, equity, inclusion, and social justice issues. She shared her views on a Facebook page, often referencing specific district employees. In response to one post, the high school principal sent Boone a letter requesting that she stop referencing district employees on social media and warning her that failure to comply could result in legal action. The letter also directed her not to contact staff without prior permission. Boone felt threatened and stopped making public comments or contacting teachers directly.Boone filed suit in the United States District Court for the Western District of Michigan, naming the district and several officials in their official capacities. She alleged violations of her First and Fourteenth Amendment rights under 42 U.S.C. § 1983, a Title IX violation, and state law claims. The district court granted the defendants’ motion to dismiss, concluding that neither the “Social Media Policy” nor the “Communication Policy” constituted unconstitutional restraints on speech—characterizing the request as non-binding and the communication restriction as merely channeling her speech. The court also rejected her Fourteenth Amendment and Title IX claims and declined to exercise supplemental jurisdiction over her state law claims.Reviewing the case de novo, the United States Court of Appeals for the Sixth Circuit held that Boone plausibly alleged a First Amendment violation regarding the Social Media Policy, as the district’s letter amounted to a coercive threat of legal action capable of chilling protected speech. However, the Communication Policy, which required Boone to channel communications through administrators, did not violate her speech rights. The court affirmed the dismissal of her Fourteenth Amendment and Title IX claims, reversed the dismissal of her First Amendment claim as to the Social Media Policy, and remanded for further proceedings, including consideration of her state law claims. View "Boone v. Lowell Area Schools" on Justia Law

A Michigan state prisoner filed a lawsuit against various defendants, alleging constitutional violations and seeking to proceed in forma pauperis, which would allow him to pay filing fees over time or not at all. The key dispute concerned whether the prisoner had accumulated three “strikes” under 28 U.S.C. § 1915(g), which would bar him from proceeding in forma pauperis unless he was in imminent danger of serious physical injury. Two of the actions identified as strikes by the district court involved claims dismissed on Eleventh Amendment immunity grounds.The United States District Court for the Western District of Michigan denied the prisoner’s request to proceed in forma pauperis, finding that he had three strikes under § 1915(g) and that the imminent-danger exception did not apply. Because he had not paid the filing fee, the court dismissed his action without prejudice. The prisoner appealed, specifically challenging the district court’s determination that two actions dismissed on Eleventh Amendment immunity grounds counted as strikes.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that dismissals based solely on Eleventh Amendment immunity grounds do not count as strikes under § 1915(g), unless the dismissing court explicitly labels the claims as frivolous or malicious, which was not done in the actions at issue. The appellate court also determined that issue preclusion did not bar the prisoner from contesting the strike status because the relevant issue was not actually litigated in prior proceedings. Additionally, the court found that the timing of another proposed strike did not meet the statutory requirements. As a result, the Sixth Circuit vacated the district court’s order and remanded for further proceedings, concluding that the prisoner is not barred from proceeding in forma pauperis in this action. View "Henderson v. Kent County" on Justia Law

A motorist was stopped by a police officer after turning right from a gas station parking lot onto a city street without using a turn signal. The officer, parked nearby, followed and initiated the stop, which led to the discovery of drugs and a handgun in the vehicle. The State charged the motorist with felony and misdemeanor offenses related to the handgun and drugs. Prior to trial, the motorist moved to suppress the evidence, arguing that no traffic law required signaling for this type of turn, so the stop violated his rights under both the federal and Indiana constitutions.The Marion Superior Court denied the suppression motion. The court relied on a previous appellate decision, Datzek v. State, and found that the officer’s interpretation of Indiana Code section 9-21-8-24, which requires signaling when turning “from a direct course upon a highway” or changing lanes, was not mistaken. The Court of Appeals affirmed, holding that the officer’s interpretation of the statute was objectively reasonable, and thus the stop complied with the Fourth Amendment. The appellate panel similarly upheld the stop under the Indiana Constitution.The Indiana Supreme Court reviewed the case and vacated the Court of Appeals’ opinion. The Court held that the statute in question is unambiguous and does not require a turn signal when exiting a private parking lot onto a city street. The officer’s contrary interpretation was not objectively reasonable, meaning the stop violated the Fourth Amendment. Because the State did not argue for any exception to the exclusionary rule, the evidence must be suppressed. The Indiana Supreme Court reversed the trial court’s suppression ruling and remanded with instructions to grant the motion; it did not reach the Indiana constitutional issue. View "Lanier v. State" on Justia Law

The case centers on a government investigation into a leak of highly classified information regarding a military operation. After a news article revealed details previously unreported, authorities suspected that journalists associated with the news outlet might have communicated with confidential sources via LinkedIn. The government obtained two orders under the Stored Communications Act: one requiring LinkedIn to disclose metadata records for the journalists over an eighteen-month period, and another barring LinkedIn from informing anyone, including the journalists and their employer, about the existence of the orders for one year. LinkedIn challenged both orders, arguing that they were substantially overbroad and threatened First Amendment protections by sweeping in unrelated confidential sources.A magistrate judge for the United States District Court for the Eastern District of Virginia found LinkedIn had standing but sided with the government on the merits, holding that LinkedIn could only challenge the orders based on logistical or practical burdens, not on overbreadth or constitutional grounds. The district court adopted this recommendation, rejecting LinkedIn’s arguments regarding overbreadth and First Amendment protections, and upholding both the Disclosure and Secrecy Orders. LinkedIn’s motion for access to ex parte materials and for reconsideration following new information about the government’s disclosure to the news outlet was also denied.Upon appeal, the United States Court of Appeals for the Fourth Circuit found LinkedIn had standing to challenge both orders. The court held that the Disclosure Order was substantially overbroad, violating statutory and constitutional norms, and required the district court to narrow its scope. The court also held that the Secrecy Order was overly broad as a prior restraint and must be modified to allow LinkedIn to disclose the existence of the orders to a single vetted attorney for the news outlet. However, the court affirmed the district court’s denial of LinkedIn’s request for access to ex parte materials, citing national security concerns. The case was affirmed in part, reversed in part, and remanded. View "In re: Application" on Justia Law