Justia Constitutional Law Opinion Summaries

In petitions for a writ of mandamus, two juvenile offenders sought dismissal of capital-murder indictments based on "Roper v. Simmons," (543 U.S. 551 (2005)), and "Miller v. Alabama," (132 S.Ct. 2455 (2012)). Both juveniles argued that Alabama's capital-murder statute was unconstitutional as applied to them because the mandatory sentencing structure provides that all defendants charged with a capital offense, including juveniles, must receive either a sentence of death or a mandatory sentence of life imprisonment without parole. Upon review, the Supreme Court concluded the juveniles failed to show that the holding in Miller required it to dismiss the capital-murder indictments against them. Accordingly, their petitions for a writ of mandamus were denied. View "Alabama vs. Henderson " on Justia Law

The State sought certiorari for review of a decision of the Court of Criminal Appeals that reversed the Juvenile Court's decision to deny G.M.'s motion to suppress evidence that G.M. argued was obtained pursuant to an illegal search. The matter was one of first impression for the Supreme Court: whether evidence of a public-school student's association with an individual known to be involved in criminal activity and suspected of being affiliated with a gang, without more, constituted reasonable grounds for a search of the student by a school official under the Fourth Amendment. The Supreme Court concluded that it did not. Therefore, the Court affirmed the Court of Criminal Appeals' judgment. View "G. M. v. Alabama " on Justia Law

Frank Moultrie appealed a circuit court judgment that assessed attorney fees and costs to Moultrie after finding him in contempt for violating the terms of a temporary restraining order. Upon review, the Supreme Court dismissed the appeal in part and affirmed the judgment. Based on the arguments presented by Moultrie in this appeal, the Court could not conclude that Moultrie had affirmatively demonstrated that the circuit court exceeded its discretion by assessing the attorney fees and costs against Moultrie. View "Moultrie v. Wall, II" on Justia Law

Toma E. Smith, as personal representative of the estate of Tiffani P. Smith, appeals the grant of a summary judgment in favor of Dr. James Fleming, and a judgment entered in favor of Dr. Winfield S. Fisher III and the University of Alabama Foundation on her wrongful death claims. Dr. Fisher and the Foundation cross-appealed, arguing that the action should have been dismissed as being void ab initio. Based on the trial court record, the Supreme Court concluded the trial court did not err in entering a summary judgment in favor of Dr. Fleming. The Court concluded the trial court did not err in its judgment in favor of Dr. Fisher and the Foundation. View "Smith v. Winfield" on Justia Law

The Board of Equalization and Adjustment of Shelby County appealed a consent judgment reflecting an agreement between the Board and Shelby 39, LLC. The Board argued the circuit court lacked subject-matter jurisdiction over certain matters decided by the consent judgment. Upon review, the Supreme Court affirmed. View "Board of Equalization and Adjustment of Shelby County v. Shelby 39, LLC " on Justia Law

Joseph Lester Pate petitioned the Supreme Court Court for a writ of certiorari to review the Court of Criminal Appeals' affirmance by unpublished memorandum of the circuit court's denial of his motion for reconsideration of his sentence imposed pursuant the Habitual Felony Offender Act ("the HFOA"). The trial court dismissed Pate's "Kirby" motion because it erroneously believed that it lacked jurisdiction to consider it. The Court of Criminal Appeals, on remand from the Supreme Court's decision in "Ex parte Pate," affirmed the trial court's order because it determined that Pate was not entitled to review (on the merits) of a second "Kirby" motion because, it said, there was no indication that Pate's first "Kirby" motion had not properly been considered. The Supreme Court concluded that there was indeed no indication in the record that Pate's first "Kirby" motion was considered on the merits. The judgment of the Court of Criminal Appeals was reversed and the case remanded for further proceedings. View "Pate v. Alabama" on Justia Law

Jessica Eastman, as the dependent widow of David Bentley, and on behalf of Bentley's three minor children, appealed a judgment entered in favor of R. Warehousing and Port Services Inc. On appeal to the Supreme Court, she argued: (1) that she was entitled to a judgment as a matter of law on R. Warehousing's affirmative defense based on the "loaned-servant" doctrine; and (2) she was entitled to a new trial because counsel for R. Warehousing implied during opening statements that she had recovered workers' compensation benefits from Richway Transportation Services,Inc. in violation of the collateral-source rule. Finding no error, the Supreme Court affirmed. View "Eastman v. R Warehousing & Port Services, Inc. " on Justia Law

South Alabama Gas District (SAG) appealed a circuit court order enjoining it from selling liquified petroleum ("LP") gas and related appliances outside its member cities. Four individual taxpayers and Fletcher Smith Butane Co., Inc., sued SAG seeking both an injunction and damages for SAG's alleged violation of 11-50-266, as made applicable to gas districts by 11-50-399. The trial court bifurcated the claim for injunctive relief and the damages claim, and held a bench trial on the claim for injunctive relief. SAG argued that the notice and buy-out provisions did not apply to it because LP gas is not a "manufactured gas" within the terms of the statute. The trial court found otherwise and enjoined SAG from selling LP gas if it did not comply with 11-50-266. The circuit court found that the taxpayers lacked standing to challenge SAG's appliance sales. With regard to Fletcher Smith, SAG argued (among other things), that Fletcher Smith lacked standing because it sold its assets and was no longer engaging in the LP gas business. As proof, SAG cited Fletcher Smith's to "Requests for Admissions of Fact." After review of the circuit court record and the admissions cited by SAG in its appeal brief, the Supreme Court found that Fletcher Smith's claims for prospective relief became moot. "Because mootness goes to justiciability, this Court will not consider the merits of a claim that is moot." View "South Alabama Gas District v. Knight" on Justia Law

Defendant Reginald Tyrone Lightfoot challenged his conviction for trafficking in cocaine and his sentence of 15 years' imprisonment. The Supreme Court granted certiorari review to determine, as a matter of first impression, whether an Apprendi error in applying a sentence enhancement was automatically harmless when the erroneous application of the enhancement did not increase the sentence beyond the statutory maximum for the underlying offense. The Court held that it was not, and reversed the Court of Criminal Appeals. View "Lightfoot v. Alabama " on Justia Law

The Supreme Court held that Defendant's Rule 32 petition should not have been dismissed on the grounds that his claim for relief under Rule 32.1 lacked allegations to negate the preclusive bars of Rule 32.1(a)(3) and (5). Defendant was convicted of capital murder and sentenced to death. He filed a Rule 32 petition for post-conviction relief, alleging in part that the State failed to disclose exculpatory evidence. The State asserted in response that defendant's claims were procedurally barred by Rule 32.2(a)(3) and (5) because defendant could have, but did not, raise the issue at trial. The trial court dismissed defendant's application and the Court of Criminal Appeals affirmed. The case was remanded for further proceedings. View "Beckworth v. Alabama" on Justia Law