Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was found guilty of incest and attempted incest involving his daughter, incest and sexual intercourse without consent involving his step-daughter, and sexual intercourse without consent involving his sister-in-law. The Supreme Court affirmed Defendant's convictions and sentences, holding (1) the district court did not abuse its discretion when it did not conduct a hearing on Defendant's posttrial allegation that some jurors slept through critical portions of the trial testimony; (2) Defendant was not subjected to double jeopardy when he was convicted of both incest and attempted incest, as the State charged and proved two separate and distinct transactions between Defendant and his daughter; and (3) the district court did not commit structural error when it failed to arraign Defendant on the amended charge of attempted sexual intercourse without consent. View "State v. Geren" on Justia Law

Defendant was charged with home invasion and other offenses. Defendant filed a motion to suppress an audio recording allegedly made by a key witness in violation of state and federal wiretap laws. The witness was receiving witness protection services from the Commonwealth. Defendant then moved for issuance of a summons to secure the witness's attendance at the suppression hearing. A superior court judge ordered that the Commonwealth file the witness's address with the court under seal so that a summons could be served in time for the suppression hearing. The Commonwealth sought relief from this order. The Supreme Court affirmed, holding that, under these circumstances, the judge was within his discretion to order this limited disclosure. View "Commonwealth v. Platt" on Justia Law

Defendant was indicted for armed assault with intent to murder and other offenses. Defendant filed a motion seeking information as to the alleged victim's status as a police informant. Defendant argued that this information was relevant to his state of mind as to the time of the incident. The judge ordered the prosecutor to inquire of the alleged victim whether he was an informant for any law enforcement agency and to report the result to defense counsel. The Commonwealth sought relief from this order. The Supreme Court reversed, holding that there was no basis for the judge to order the Commonwealth to ask the alleged victim whether he was a confidential informant, as this information, obtained by counsel after the alleged incident, logically could not demonstrate Defendant's state of mind at the time of the incident. View "Commonwealth v. Jordan" on Justia Law

Respondent sued the City of Houston. After an attempted settlement, Respondent asserted that the City breached the settlement agreement. The City filed a plea to the jurisdiction, which the trial court denied. The court of appeals affirmed, but the Supreme Court reversed. On remand, the City filed another plea to the jurisdiction (2006 plea), arguing that it was immune from suit. The trial court implicitly denied the City's plea and set the case for trial. The City did not appeal. After Respondent died, the case was transferred to probate court. There the City filed a motion for summary judgment and an amended plea to the jurisdiction. The probate court denied the City's motion for summary judgment and, construing the City's amended plea as a motion to reconsider the 2006 plea, denied it. The City filed an interlocutory appeal. The court of appeals dismissed part of the appeal but considered the merits of part of it. The Supreme Court reversed in part, holding the court of appeals erred by failing to dismiss the entire appeal for lack of jurisdiction because the amended plea was a motion to reconsider the 2006 plea, and time had expired for interlocutory appeal from it. View "City of Houston v. Estate of Jones" on Justia Law

Plaintiff Pamela Mattison, gave birth to twins who were conceived by artificial insemination after their father, Jeffery Mattison, had died. She sought social security survivors' benefits for the children based on Jeffery's earnings. The Social Security Administration denied her application, and an administrative law judge affirmed that decision. Plaintiff then filed an action in the United States District Court for the Western District of Michigan challenging the decision. That court has asked the Michigan Supreme Court to rule on whether the children could inherit from Jeffery under Michigan intestacy law. Having heard oral argument, the Supreme Court granted the district court's request to answer the question and held that under Michigan intestacy law, plaintiff's children could not inherit from Jeffery. The matter was returned to the district court for further proceedings. View "In re Mattison v. Social Security Comm." on Justia Law

Jacob Trakhtenberg was convicted of three counts of second-degree criminal sexual conduct. The charges stemmed from allegations of sexual contact made by defendant's then 8-year-old daughter. The issue before the Supreme Court in this case was whether collateral estoppel could be applied to preclude review of defendant's claim of ineffective assistance of counsel when a prior civil judgment held that defense counsel's performance did not amount to malpractice. Upon review, the Supreme Court concluded that collateral estoppels may not be applied in these circumstances because defendant did not have a full and fair opportunity to litigate his ineffective-assistance-of-counsel claim. Given this conclusion, the Court concluded further that defense counsel's performance was constitutionally deficient because she failed to exercise reasonable professional judgment when she decided to forgo any investigation of the case before settling on a defense strategy. "That deficiency prejudiced defendant by undermining the reliability of the outcome of his trial, which rested solely on the credibility of the complainant and defendant." Accordingly, the Court reversed the judgment of the Court of Appeals and remanded this case to the trial court for a new trial. View "Michigan v. Trakhtenberg" on Justia Law

Defendant Kurtis Minch pled guilty to possessing a short-barreled shotgun and possessing a firearm during the commission of a felony. The issue before the Supreme Court in this case was whether Michigan's "felon in possession" statute prevents a police department from delivering lawfully seized noncontraband firearms to the designated agent of a convicted felon. The Court concluded that it does. "The statute does not, however, prevent a court from appointing a successor bailee to maintain possession of a defendant's weapons during his or her period of legal incapacity." View "Michigan v. Minch" on Justia Law

Defendant as convicted of aggravated murder and attempted aggravated murder. Defendant's conviction was affirmed on appeal, after which he filed a pro se petition seeking relief under the Post-Conviction Remedies act (PCRA) on the grounds that his trial counsel was ineffective for failing to raise a defense and that his appellate counsel was ineffective for failing to raise a claim of ineffective assistance of counsel on direct appeal. The court granted summary judgment for the State, concluding that Defendant's appellate counsel was not ineffective and that Defendant's ineffective assistance of trial counsel claim was procedurally barred. The Supreme Court reversed, holding (1) disputed issues of material fact precluded summary judgment on Defendant's claim that his appellate counsel was ineffective; and (2) because the Court could not determine whether appellate counsel was ineffective, it could not determine whether Defendant's claim regarding trial counsel was procedurally barred by the PRCA. Remanded for an evidentiary hearing. View "Ross v. State" on Justia Law

Plaintiff was a tenured teacher who worked for Defendant, the Memphis City Schools Board of Education. After Plaintiff requested and was granted a substantial amount of sick leave but failed to return from that sick leave, Defendant dismissed Plaintiff without providing her with written charges or an opportunity for a hearing. Plaintiff filed a complaint alleging that her dismissal violated the Tennessee Teacher Tenure Act and her constitutional due process rights. The trial court granted Plaintiff's motion for partial summary judgment and awarded Plaintiff's reinstatement, back pay, compensatory damages for the actual harm she suffered, and attorney's fees. The court of appeals vacated the grant of summary judgment. The Supreme Court reversed the judgment of the court of appeals and reinstated the judgment of the trial court, holding (1) although a tenured teacher's failure to return from sick leave may constitute cause for termination, there is no statute authorizing a board of education to deem it a constructive resignation or a forfeiture of tenure; and (2) accordingly, Defendant violated Plaintiff's rights under the Tenure Act and her constitutional due process rights. View "Thompson v. Memphis City Schs. Bd. of Educ." on Justia Law

Appellant pled guilty to one count of theft by deception in the amount of $500 to $1500 pursuant to a plea bargain. Appellant appealed, contending that the district court erred in failing to inform him that he had a right to a presentence investigation and that, therefore, his waiver of his statutory right to a presentence investigation was not made freely, voluntarily, knowingly, or intelligently. The Supreme Court affirmed, holding (1) under a review of the totality of the circumstances, Appellant was informed of his right to a presentence investigation, was questioned as to whether he had been threatened or promised anything for his decision to waive this right, and was expressly asked if his waiver was made freely and voluntarily; and (2) therefore, the district court did not clearly err in finding that Appellant's waiver was made voluntarily, knowingly, and intelligently. View "State v. Qualls" on Justia Law