Justia Constitutional Law Opinion Summaries

After an agent with the Tri-Agency Safe Trails Task Force purchased quantities of marijuana from Defendants in excess of what was legal under the Medical Marijuana Act, law enforcement arrested Defendants. Officers executed search warrants for Defendants' vehicles, their residence, and the garage Defendants frequented, retrieving four times the amount of marijuana Defendants were allowed to possess as caregivers and patients under the Act. Defendants were charged with several drug-related counts. Defendants filed a joint motion to suppress and dismiss, arguing that the state engaged in "outrageous government conduct" by obtaining evidence against them in violation of their federal due process rights. The district court granted the motion because the agent broke numerous laws under the banner of law enforcement. The Supreme Court reversed, holding that because the agent's conduct stopped short of violating the fundamental fairness shocking to the universal sense of justice mandated by the due process clause, the district court erred in dismissing Defendants' charges based on the outrageous government conduct defense. View "State v. Fitzpatrick" on Justia Law

Mike Alexander was one of two former employees of Bozeman Motors who filed suit against Bozeman Motors and its president and managers, alleging negligence, battery, and negligent or intentional infliction of emotional distress. Plaintiffs claimed long-term physical and emotional injuries resulting from exposure to carbon monoxide and propane. Alexander died after filing suit. Bozeman Motors moved for summary judgment on the basis that the claims against it were barred by the exclusive remedy provision of Montana's Workers' Compensation Act. The district court granted Bozeman Motors' motion, holding that the conduct of Defendants did not rise to the level of deliberate intent to cause specific harm, and that Mont. Code Ann. 39-71-413, which provides an exception to the exclusive remedy provision of the Act, was constitutional. The Supreme Court reversed and remanded with respect to Alexander's claims. On remand, the jury returned a verdict for Defendants on all claims. The Supreme Court affirmed, holding (1) section 39-71-413(2) does not create an impermissible class of employees in violation of equal protection; (2) the district court did not err in instructing the jury; and (3) the court did not err in denying Plaintiffs' motion to exclude Alexander's cause of death. View "Alexander v. Bozeman Motors, Inc." on Justia Law

Petitioner, a Mexican immigrant who did not speak or comprehend English, was convicted of first degree murder and related offenses. Before trial, Petitioner sought suppression of a statement he made connecting him to the murder. On appeal, Petitioner argued that the State failed to prove that he was properly advised of, and validly waived, his Miranda rights. The court of special appeals concluded that the record developed at the suppression hearing sufficed to permit the court to rule that the Miranda warnings and Petitioner's waiver complied with constitutional dictates. The Supreme Court affirmed, holding that the suppression court reasonably could find, from the totality of the evidence offered by the State, that the State proved both that proper Miranda warnings were adequately conveyed to Petitioner and that he knowingly and voluntarily waived those rights before he was interrogated and made the statement he sought to suppress. View "Gonzalez v. State" on Justia Law

Appellant, an adult citizen, filed a petition for a declaration of rights seeking a declaration that the statutory and regulatory provisions associated with the Cabinet for Health and Family Services and its sub-unit the Department of Community Based Services' (DCBS) process for investigating allegations of child abuse were unconstitutional. Appellant also challenged the constitutionality of the Cabinet's administrative process. The underlying administrative action was held in abeyance pending the conclusion of the present proceeding. The circuit court denied the petition, finding the challenged processes to be constitutional, and the court of appeals affirmed. The Supreme Court vacated the court of appeals, holding that the declaratory action was not ripe for review, as the administrative proceedings being held in abeyance were not available to contextualize the operations of the statutory and regulatory process as it functions in day-to-day practice. Remanded with directions that the court hold this action in abeyance until the conclusion of the underlying administrative proceedings. View "W.B. v. Commonwealth" on Justia Law

Appellants Marcus Swan and D'Andre Owens were convicted of multiple crimes related to a violent home invasion they carried out. The Supreme Court affirmed Swan's judgment of conviction and sentence in its entirety, and affirmed in part and reversed in part Owens's judgment, although his overall sentence was unaffected, holding that the trial court (1) correctly admitted into evidence the guns used in the crime; (2) properly failed to dismiss the indictment because of the destruction of other guns found in the victim's house; (3) did not err in failing to hold a hearing on Swan's right to proceed pro se or with hybrid counsel; (4) properly allowed a witness to testify in the penalty phase after having been present in the courtroom during guilt-phase testimony; (5) did not commit reversible error by evaluating the competency of a child witness in a short fashion and in the presence of the jury; (6) erred in failing to give an instruction on second-degree assault as a lesser-included offense; and (7) erred in failing to grant a directed verdict on the charge of first-degree wanton endangerment relating to Latonia Lumpkins. Accordingly, Owens's convictions for first-degree assault and first-degree wanton endangerment of Lumpkins were reversed. Remanded. View "Swan v. Commonwealth" on Justia Law

After a jury trial, Appellant was convicted of wanton murder and initially sentenced to forty years' imprisonment. The Supreme Court vacated Appellant's sentence and remanded for a new sentencing phase. At Appellant's second sentencing phase trial, Appellant was represented by a public advocacy attorney that had represented Chris Eapmon, who had been jointly indicted with Appellant during his negotiations for a plea deal. Eapmon eventually pled guilty in exchange for his testimony against Appellant. The Supreme Court affirmed Appellant's twenty-eight year prison sentence, holding (1) Appellant did not suffer any identifiable prejudice arising out of counsel's representation; (2) the successive representation here did not violate Ky. R. Crim. P. 8.30; and (3) Appellant's confrontation rights were not violated at his second sentencing phase due to the use of videotaped testimony from the guilt phase of his trial. View "Steward v. Commonwealth" on Justia Law

Defendant pled guilty to armed robbery and murder and was sentenced to life in prison without the possibility of parole for twenty-five years. After Defendant's conviction was affirmed, Defendant filed a pro se motion seeking relief from the circuit court's judgment. The matter was allowed to lie dormant for four years until counsel filed an amendment to Defendant's original motion. The trial court denied the motion, finding that counsel's amendment was untimely and that on the merits the claims in Defendant's original motion were refuted by the record. The court of appeals affirmed. The Supreme Court affirmed, although its reasoning differed from the lower court's, holding that to the extent the amended motion sought to raise a new, factually independent claim, it was subject to dismissal as untimely, and Defendant's timely claims were facially without merit. View "Roach v. Commonwealth" on Justia Law

The issue before the Supreme Court in this case came from the court of appeals' unpublished decision in "Bacheller v. General Steel Domestic Sales, LLC," and centered on the determination of the applicability of "Protect Our Mountain Environment, Inc. v. District Court," (677 P.2d 1361 (Colo. 1984) ("POME")) to this case and the propriety of the trial court's decision to a treble and exemplary damages award. Bacheller sued General Steel, Discount Steel, and those companies' presidents for abuse of process, malicious prosecution, and civil conspiracy, based on their filing an arbitration complaint against him. The court of appeals held that the trial court did not abuse its discretion by refusing to include additional elements reflecting POME's heightened standard in the jury instruction for Bacheller's malicious prosecution claims. The court of appeals also held that the trial court did not abuse its discretion by trebling an exemplary damages award against General Steel and Discount Steel. Upon review, the Supreme Court affirmed the appellate court: "POME does not apply where, as here, the underlying alleged petitioning activity was the filing of an arbitration complaint that led to a purely private dispute." View "General Steel Domestic Sales, LLC v. Bacheller" on Justia Law

Robert Lee Jenkins was convicted for possession of a controlled substance. He was sentenced to life imprisonment under the habitual-offender statute. The Supreme Court granted Jenkins's petition for writ of certiorari to examine whether the trial court erred by allowing a laboratory supervisor to testify regarding the results of substance testing, where the supervisor reviewed and verified the results, but another analyst actually performed the tests. Finding no error, the Court affirmed. View "Jenkins v. Mississippi" on Justia Law

Frederick Denell Grim was convicted by jury for the sale of cocaine. The circuit court adjudicated Grim a habitual offender and sentenced him to life imprisonment without the possibility of parole. The Court of Appeals affirmed the trial court's judgment of conviction and sentence. The Supreme Court granted Grim's petition for writ of certiorari to examine whether the trial court erred by allowing a laboratory supervisor, who neither observed nor participated in the testing of the substance, to testify in place of the analyst who had performed the testing. Finding no error, the Court affirmed. View "Grim v. Mississippi" on Justia Law