Justia Constitutional Law Opinion Summaries

The issue before the Supreme Court in this case was whether defendant was properly convicted of first degree criminal sexual assault under MCL 750.520b(1)(b)(ii), which requires that a defendant be related to the victim "by blood." It was undisputed that defendant Jason Zajaczkowski was not related to the victim, but the prosecution asserted that a civil presumption of legitimacy had been met, thereby establishing the relationship "by blood" for the purposes of the conviction. Upon review of the civil presumption of legitimacy implicated by Michigan statutory and caselaw, the Supreme Court concluded that the prosecution could not establish that a blood relationship between the defendant in this case and his victim. "Moreover, the presumption of legitimacy cannot be substituted for a blood relationship in order to fulfill this element of the crime charged." Accordingly, the vacated defendant's conviction for first-degree criminal sexual conduct, and remanded the case for entry of a conviction of third-degree criminal sexual conduct in accordance with defendant's plea agreement, and for resentencing. View "Michigan v. Zajaczkowski" on Justia Law

Defendant Ryan Bylsma, a registered primary caregiver under the Michigan Medical Marijuana Act (MMMA), was charged with manufacturing marijuana in violation of state law. Defendant moved to dismiss the charge, asserting that he was the registered primary caregiver of two registered, qualifying patients, and was allowed to possess the numerous plants ultimately seized by police from a building that belonged to other registered primary caregivers and registered patients whom defendant offered help in growing and cultivating the plants. The trial court denied defendant's motion, holding that the statute has a strict limit of how many plants a registered caregiver may possess, and allows only one person to have access to the facility in which the plants were grown. The issue before the Supreme Court was whether the MMMA provides a registered primary caregiver immunity when growing plants collectively with other registered primary caregivers and their qualifying patients. The Court held that a portion of the MMMA did not contemplate collective action, and as such, defendant was not entitled to its grant of immunity from arrest, prosecution or penalty. Though defendant's argument failed with regard to immunity, the Court determined that the appellate court erred in not considering defendant's affirmative defense argument under a separate section of the MMMA. The Court reversed that portion of the appellate court's decision and remanded the case to the trial court for further proceedings. View "Michigan v. Bylsma" on Justia Law

The issue before the Supreme Court in this case was whether a traffic stop motivated by an uncorroborated tip (but also independently motivated by a reasonable, articulable suspicion) was unconstitutionally pretextual under the Washington Constitution. Upon review, the Court concluded that a "mixed motive" traffic stop is not pretextual "so long as the desire to address a suspected traffic infraction (or criminal activity) for which the officer has a reasonable, articulable suspicion is an actual, conscious and independent cause" of the stop. View "Washington v. Arreola" on Justia Law

After a jury trial, Appellant was convicted of murder and sentenced to forty years in prison. On appeal, the Supreme Court affirmed, holding (1) the trial court erred when it allowed into evidence the fact that Appellant owned two guns with the same model number as the weapon used in the murder crime, though neither weapon was used to commit the crime, but the error was harmless; (2) the trial court erred when it admitted hearsay testimony regarding the victim's request to borrow money from his wife, but the error was harmless in the context of this case; and (3) the trial court properly refused to allow Appellant to inform the jury he had already been tried twice for these charges and the prior two juries deadlocked. View "Harris v. Commonwealth" on Justia Law

Appellee was charged with assault in the fourth degree. Before Appellee was arrested but after an arrest warrant was issued, Appellee's attorney made an ex parte request to a different district court judge from the one who issued the arrest warrant, seeking to set the warrant aside and issue a summons. The warrant was withdrawn and a summons issued instead. The Commonwealth's request for the reinstatement of the arrest warrant was denied. Appellee later pled guilty to the charge. The Supreme Court granted the certification request of the Commonwealth to answer a question of law and answered that Kentucky law does not authorize an ex parte motion by a criminal defendant to vacate or set aside a warrant for his or her arrest with no notice or opportunity for the Commonwealth to be heard. View "Commonwealth v. Minton" on Justia Law

Defendant was indicted for being a persistent felony offender (PFO) 2. The PFO 2 count was based on an earlier conviction for which Defendant was granted diversion. Defendant was still on diversion when the grand jury indicted him for the later offenses. Upon Defendant's motion, the trial court dismissed the PFO 2 count because Defendant had not been finally sentenced on the previously diverted felony. The Supreme Court affirmed, holding (1) a conviction for which a defendant is currently on diversion cannot be used to indict that defendant as a PFO 2 when he commits a subsequent felony offense; and (2) the sentence on the prior felony must be imposed at the time the defendant commits the subsequent crime in order for the conviction to support a PFO 2 charge. View "Commonwealth v. Derringer" on Justia Law

Defendant was originally convicted in 1981 for murder and sentenced to death. After a series of appeals and postconviction motions, Defendant filed a successive motion to vacate his sentence. Specifically, Defendant asserted that he was mentally retarded pursuant to Atkins v. Virginia. The trial court held an evidentiary hearing on Defendant's motion in 2009. The court denied relief, determining that Defendant could not meet the first prong of the mental retardation standard to establish his mental retardation. The Supreme Court affirmed, holding that there was competent, substantial evidence to support the court's finding that Defendant was not mentally retarded. View "Hall v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of first-degree murder, one count of burglary with assault or battery while armed, and one count of criminal mischief. The trial court imposed death sentences for both murders. The trial court subsequently denied Defendant's motion for postconviction relief. Defendant appealed the trial court's denial of his motion and petitioned the Supreme Court for a writ of habeas corpus. The Court affirmed the denial of Defendant's postconviction motion and denied his habeas petition, holding, among other things, that (1) Defendant's trial counsel did not provide ineffective assistance during the guilt phase or the penalty phase; (2) the State did not violate Brady v. Maryland by withholding evidence; (3) trial counsel was not operating under an actual conflict of interest due to counsel's workload; (4) the trial court did not err in denying several of Defendant's requests for additional public records; and (5) Defendant was not entitled to relief on any of the claims he raised in his habeas petition. View "Dennis v. State" on Justia Law

Plaintiff brought suit against her former employer under the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq., after she was terminated. The district court granted summary judgment in favor of the employer because plaintiff did not present sufficient evidence from which a jury could conclude that the employer's proffered nondiscriminatory reason for the termination - that plaintiff violated (or appeared to violate) the company's conduct policies - was pretextual. In this case, the corporate executive who terminated plaintiff later said that she was an exceptional employee who had done nothing wrong, had done everything right, and should not have been fired. The court held that such evidence, when combined with a prima facie case, created a jury question as to discrimination. Accordingly, the court reversed and remanded. View "Kragor v. Takeda Pharmaceuticals America" on Justia Law

On Halloween 1996, Parish, age 20, was arrested by Elkhart police as he prepared to take his three children trick-or-treating, and charged with attempted murder and armed robbery. No physical evidence tied Parish to the crime. Based mainly on eyewitness testimony, the jury convicted Parish. For eight years, Parish pursued appeals. In 2005, the appellate court ordered a new trial based on his attorney’s failure to properly investigate and introduction of an improper jury instruction. Parish was then 30 years old. The government offered a plea that involved no additional jail time, but Parish refused. The government then dismissed the case. Parish sued under 42 U.S.C. 1983. The jury found in favor of Parish, but awarded only $73,125 in compensatory damages and $5,000 in punitive damages. In his unsuccessful motion for a new trial, Parish presented evidence that the average jury award was nearly $950,000 per year of wrongful imprisonment. The Seventh Circuit reversed, noting that the court admitted testimony of eyewitnesses identifying Parish, but refused to allow Parish to present significant evidence that he was not guilty, including identification of other individuals as possible perpetrators, and recantations by the eyewitnesses. View "Parish v. City of Elkhart, IN" on Justia Law