Justia Constitutional Law Opinion Summaries

Alma Vidauri was convicted of one count of theft and three counts of forgery in connection with filings she made with the Garfield County, Colorado Department of Human Services (“Department”) between 2009 and 2016 for medical assistance benefits. A division of the court of appeals concluded that the evidence was insufficient because the prosecution had not shown the difference in value between the total amount of certain public benefits Vidauri received and the amount for which she might have been eligible had she accurately reported her household income. Therefore, the division reversed the trial court and entered judgment for the lowest level of theft, a class 1 petty offense. The Colorado Supreme Court reversed the division, finding the applicable theft statute placed no burden on the prosecution to establish that Vidauri would have been ineligible for any of the benefits she received. "Because an applicant is not entitled to, and so has no legally cognizable interest in, any benefits until she has submitted accurate information demonstrating as much, we conclude that all the benefits Vidauri received by submitting false information were obtained by deception. Therefore, the original judgment of conviction for a class 4 felony must be reinstated." View "Colorado v. Vidauri" on Justia Law

Delano Medina sought review of the dismissal of his habeas corpus petition by a district court magistrate. Because a district court magistrate was authorized to rule on a habeas corpus petition only when the parties consent to proceeding before the magistrate and Medina did not so consent here, the Colorado Supreme Court concluded the dismissal order was entered without authority. Accordingly, the Court reversed that order, and remanded the case to the district court with instructions to assign the petition to a district court judge for further proceedings. View "Medina v. Williams" on Justia Law

In 2008, Murray was sentenced to life in prison without the possibility of parole (LWOP) for a first-degree special circumstance murder he committed when he was 22 years old. In 2020, Murray unsuccessfully sought a Franklin hearing, contending he was eligible for a youth offender parole hearing under Penal Code section 3051. The court cited section 3051(h), “people sentenced to life without the possibility of parole for crimes committed when they were at least 18 years of age but no more than ‘25 years of age or younger are not eligible for youth offender parole hearings.” The court of appeal affirmed.Meanwhile, Murray sought habeas corpus relief, asserting an equal protection violation, arguing that section 3051(h) violates his right to equal protection by affording juvenile LWOP offenders (those under 18 at the time of their offense) a youth offender parole hearing while denying youthful LWOP offenders (those 18-25 years old at the time of their offense) a hearing. The court of appeal denied relief. There is a rational basis for distinguishing between juvenile and youthful LWOP offenders; children are constitutionally different from adults for purposes of sentencing. The court joined “others in encouraging the Legislature to revisit where it has drawn the line.” View "In re Murray" on Justia Law

When the state called Blackwell to testify at Miller's trial for the 1995 murder of Rice, she claimed that she could not remember anything about the day in question. Out of the jury’s presence, the judge sent Blackwell to jail to read statements that she had given to police shortly after the murder and notes that Miller’s investigator took when speaking with her. Blackwell returned to court and testified, consistently with her police statement, that the morning after the murder, she saw Miller in a car that looked like Rice’s and that Miller told her that Rice was dead before anyone else could have known. During cross-examination, Miller’s attorney asked Blackwell how she had regained her memory. Blackwell replied: “I don’t want to go to jail.”The Tennessee Court of Criminal Appeals ordered a new trial. Blackwell was unavailable. Rather than allow all of Blackwell’s testimony to be read to the jury, the court carved “any reference of incarceration or intimidation.” The jury never heard Blackwell’s statement that she did not want to go to jail. The rest of the prosecution’s case relied heavily on the testimony of a single eyewitness, who had credibility problems. Convicted, Miller received a life sentence. The Tennessee Court of Criminal Appeals rejected Miller’s claim that the court erred in admitting Blackwell’s redacted testimony.The Sixth Circuit reversed a denial of habeas corpus relief. Confrontation of an adverse witness necessarily entails that the trier of fact be allowed to learn the material results of that confrontation. The Tennessee Court of Criminal Appeals' application of Supreme Court Confrontation Clause jurisprudence was objectively unreasonable. View "Miller v. Genovese" on Justia Law

Nian worked as a home healthcare mentor for a family with a special-needs child, “SG.” After one visit, SG’s sister, JCG, claimed that Nian entered her room, tried to kiss her, put his hands on her private areas, and then pulled down her leggings and tried to perform oral sex on her. Her mother called the police and took JCG to the hospital. Nian was found guilty of rape by cunnilingus. Nian later sought a new trial, based on an affidavit from a juror, Cox, stating that another juror had introduced into deliberations facts about Nian being from Sierra Leone and having a prior criminal record, which she felt influenced the verdict. After holding an evidentiary hearing, the court excluded Cox’s testimony under Ohio Rule of Evidence 606(B) (aliunde rule) and denied Nian’s request for a new trial. The court stated that it questioned the credibility of the proffered testimony. The Ohio Court of Appeals affirmed.The Sixth Circuit reversed the denial of Nian’s petition for habeas relief. it is a constitutional error for a state court to use Ohio’s aliunde rule to exclude evidence of a jury’s consideration of extraneous information. This is not the rare case where the introduction of extraneous information was harmless. View "Nian v. Warden, North Central Correctional Institution" on Justia Law

The Shelby County Sheriff’s Department dispatcher alerted three deputies that a 911 caller, Nancy Lewellyn, had told the dispatcher that she was suicidal, that she had a gun (possibly a .45 caliber pistol), and that she would kill anyone who came to her residence. Each squad car was equipped with a dashboard camera, which recorded video, sound, and the time of day. At 12:14 p.m., Lewellyn walked outside and turned toward her driveway, carrying in her right hand a BB handgun that resembled a .45 caliber pistol. She began to raise that handgun. The deputies yelled to her then fired shots. Lewellyn continued walking with her right arm extended and the pistol pointing toward her car, Lewellyn leaned on its hood briefly, then turned back toward the house. The shooting continued. Llewellyn collapsed; 11 seconds had elapsed since she exited her house. Ten shots were fired. Lewellyn had deposited the handgun on the sedan’s hood before turning back. The deputies approached and discovered that she was unarmed. Lewellyn died at the scene.In a suit under 42 U.S.C. 1983, the district court rejected the deputies’ claims of qualified immunity. The Sixth Circuit vacated. The reasonableness of a particular use of force must be judged from the perspective of a reasonable officer on the scene, rather than in hindsight. The “facts and circumstances” support the deputies’ contention that reasonable officers would perceive that Lewellyn posed an immediate threat to their safety. View "Cunningham v. Shelby County" on Justia Law

Plaintiff filed suit against Ford under the Family and Medical Leave Act (FMLA), the Americans with Disabilities Act (ADA), and the Missouri Human Rights Act (MHRA), claiming that Ford terminated him twice and took other adverse employment action against him based on his asthma and scoliosis. The district court dismissed the FMLA claim as time-barred, and dismissed his ADA and MHRA claims on the ground that he exhausted his administrative remedies.The Eighth Circuit concluded that FMLA claims were sufficient to survive a Federal Rule of Civil Procedure 12(b)(6) motion. The court also concluded that plaintiff has cleared the exhaustion hurdle on his MHRA claim but has pulled up short on his three ADA claims. Accordingly, the court affirmed in part and reversed in part. View "Weatherly v. Ford Motor Co." on Justia Law

The United States Court of Appeals for the Eleventh Circuit certified to three questions of law to the Georgia Supreme Court relating to a lawsuit brought in federal district court by Fife Whiteside, the trustee of the bankruptcy estate of Bonnie Winslett. Whiteside sued GEICO to recover the value of Winslett’s failure-to-settle tort claim against GEICO so that the bankruptcy estate could pay creditor Terry Guthrie, who was injured in an accident caused by Winslett. The certified questions certified asked the Supreme Court to analyze how Georgia law applied to an unusual set of circumstances that implicated both Winslett’s duty to give GEICO notice of suit and GEICO’s duty to settle the claim brought against Winslett. The Supreme Court was unable to give unqualified “yes” or “no” answers to two of the certified questions as they were posed; rather, the Court answered the questions only in the context of the circumstances of this particular case. "Winslett remains liable to Guthrie, even if her bankruptcy trustee succeeds on the failure-to-settle claim against GEICO; therefore, if the bankruptcy estate does not recover enough from GEICO to satisfy Guthrie’s judgment, the estate would not be fully compensated for Winslett’s damages, and GEICO would escape responsibility for breaching its settlement duty to Winslett. Such an outcome would deny Winslett the full measure of compensatory damages allowed under Georgia law." View "GEICO Indemnity Co. v. Whiteside" on Justia Law

Million Bedford and Yaheed Brooks were tried together and convicted of malice murder and other crimes in connection with the 2017 shooting death of Johnny Jackson. Each contended on appeal that there was insufficient evidence to sustain their convictions and that the trial court erred in denying a mistrial due to the State’s improper comment about courtroom spectators during its closing argument. Separately, Bedford claimed the trial court erred by denying his motion for directed verdict of acquittal and by admitting his pretrial statements. Brooks argued that a detective witness improperly bolstered other witnesses’ testimony and that the trial court abused its discretion by failing to allow him to supplement his motion for new trial with new claims and by not setting an evidentiary hearing on the supplemental motion. Finding no reversible error, the Georgia Supreme Court affirmed. View "Bedford v. Georgia" on Justia Law

Appellant Derrick Agee was found guilty at a bench trial of malice murder and other crimes in connection with the shooting death of Steven Lowe and assault of Monitaaz Simmons. On appeal, Agee contended the evidence was insufficient to support his convictions because the two witnesses who identified him as the shooter later recanted their statements. Additionally, Agee challenged the validity of his waiver of his right to a jury trial. Concluding these claims lacked merit, the Georgia Supreme Court affirmed Agee's convictions. View "Agee v. Georgia" on Justia Law