Justia Constitutional Law Opinion Summaries

Plaintiff, a California resident and leading owner of thoroughbred race horses, claimed a bay filly in a claiming race at Churchill Downs in Louisville, Kentucky. Plaintiff filed a complaint seeking a declaration that certain Kentucky thoroughbred racing regulations that restrict the transfer and racing of claimed thoroughbreds (Article 6 restrictions) violate the Commerce Clause of the United States Constitution. The trial court entered summary judgment in favor of the Kentucky Horse Racing Commission. The Supreme Court affirmed, holding (1) Plaintiff had a sufficient case or controversy to sustain this action; but (2) Article 6 restrictions survive the strict scrutiny applicable to laws that appear facially discriminatory. View "Jamogotchian v. Ky. Horse Racing Comm’n" on Justia Law

After a jury trial, Defendant was found guilty of murder, first-degree burglary, and defacing a firearm. Defendant was sentenced to life imprisonment. The Supreme Court affirmed the conviction and sentence on appeal. Defendant subsequently filed a Ky. R. Crim. P. (RCr) 11.42 motion and a Ky. R. Civ. P. (CR) 60.02 motion as an alternative to his RCr 11.42 motion. Both motions were joined into a single action. The circuit court denied Defendant’s post-conviction motions. The court of appeals reversed and remanded for a new trial, concluding that Defendant was denied effective assistance of counsel. The Supreme Court reversed in part and affirmed in part, holding (1) there was no error based on trial counsel’s failure to request a renewed competency motion during trial or in trial counsel’s waiving Defendant’s presence during trial; (2) the trial court correctly denied Defendant’s claims that were conclusively disproved through an examination of the record; (3) there was no error in pre-trial counsel’s strategy to permit Defendant to be interviewed by law enforcement; and (4) the circuit court should have conducted an evidentiary hearing concerning Defendant’s claim of error based on pre-trial counsel’s failure to convey a twenty-year plea offer to him. Remanded. View "Commonwealth v. McGorman" on Justia Law

Appellant was charged with seven counts of first-degree sodomy. All seven counts of the indictment read identically. Appellant was acquitted on two counts and convicted of the other five. Later, the court of appeals vacated Appellant’s convictions and remanded for a new trial, concluding that Appellant’s counsel had been ineffective. On remand, Appellant moved to dismiss the indictment, claiming his re-prosecution was barred by double jeopardy. The trial court denied the motion. Appellant then filed a petition for a writ of prohibition in the court of appeals claiming again that the prohibition on double jeopardy would be violated by retrial. The court of appeals denied the writ. The Supreme Court reversed, holding that a new trial in this case raised a substantial risk that Appellant will be tried for crimes for which he has already been acquitted in violation of his double-jeopardy right against successive prosecution. Remanded. View "Dunn v. Hon. Beth Maze" on Justia Law

Appellant entered a conditional guilty plea to charges of first-degree trafficking in a controlled substance, first-degree possession of drug paraphernalia, and being a first-degree persistent felony offender. Appellant was sentenced to twenty years’ imprisonment. Appellant appealed the denial of his motion to suppress evidence that was found on his person and in his car following a sniff search by a narcotics-detection dog that was conducted after a routine traffic stop. The Supreme Court reversed, holding (1) the arresting officer prolonged the seizure and conducted the search in violation of Rodrigues and Appellant’s Fourth Amendment rights; and (2) therefore, the fruits of that search must be suppressed. View "Davis v. Commonwealth" on Justia Law

Appellant was indicted for being a convicted felon in possession of a handgun, carrying a concealed deadly weapon, and alcohol intoxication in a public place. Appellant filed a motion to suppress the weapon seized at his arrest, arguing that the arresting officer lacked sufficient cause to arrest Appellant for alcohol intoxication and that the ensuing search of his person incident to the improper arrest violated his Fourth Amendment rights. The trial court denied the motion. The court of appeals upheld the validity of the arrest. The Supreme Court reversed, holding (1) Appellant’s arrest for alcohol intoxication in a public place was unlawful because the offense was not committed in the presence of the arresting officer; and (2) therefore, the search conducted incident to that arrest was not valid, and the evidence obtained during the search should have been suppressed. View "Maloney v. Commonwealth" on Justia Law

After a jury trial, Appellant was convicted of murder and four counts of first-degree criminal abuse. Appellant was sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the trial court’s admission of evidence of Appellant’s prior bad acts - namely, his history of domestic violence against his spouse - was not in error; (2) the admission of hearsay statements made to an examining pediatrician was not in error, and the admission of a detective’s hearsay testimony in violation of Appellant’s confrontation rights was harmless beyond a reasonable doubt; and (3) improper closing statements made during the Commonwealth’s closing argument did not rise to the level of misconduct requiring reversal. View "Dickerson v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of one count of intentional murder and one count of being a first-degree persistent felony offender. Defendant was sentenced to twenty years’ imprisonment. Defendant appealed, arguing (1) the trial court’s power to establish the number of peremptory challenges awarded to the Commonwealth is an impermissible delegation of legislative authority under Kentucky’s separation of governmental powers principle, and (2) he was entitled to a directed verdict on the intentional-homicide charge. The Supreme Court affirmed, holding (1) because Defendant did not notify the Attorney General of his intent to challenge the constitutionality of Ky. Rev. Stat. 29A.290(2)(b), Defendant failed to comply with Ky. Rev. Stat. 418.075, and therefore, the Court must decline to address the merits of his argument; and (2) Defendant was not entitled to a directed verdict. View "Craft v. Commonwealth" on Justia Law

Defendant was charged with multiple drug-related criminal offenses. Defendant filed a motion to suppress all the evidence collected from his trailer, arguing that law enforcement officers unlawfully exceeded the scope of a warrantless knock and talk by entering the protected curtilage of his residence. The trial court denied the suppression motion. Defendant subsequently entered a conditional guilty plea to complicity to manufacture methamphetamine, complicity to possess marijuana, and complicity to possess drug paraphernalia. The court of appeals reversed, concluding that the officers did not have the right to venture away from the front of Defendant’s house pursuant to a knock and talk and to invade the curtilage of Defendant’s residence. The Supreme Court reversed, holding that, based on the totality of the factors set forth in United States v. Dunn, as well as the officers’ uncontroverted testimony, neither officer unlawfully encroached on the trailer’s curtilage. View "Commonwealth v. Dixon" on Justia Law

Laul Deng (“Aker”) sued his former employer, Norton Healthcare, Inc., for racial discrimination in terminating his employment. Specifically, Aker alleged that Norton’s failure to reinstate him after termination of his employment was retaliation for filing a pro se discrimination complaint. The trial court granted Norton summary judgment on all of Aker’s claims. Despite acknowledging that Aker never applied for any position with Norton, the court of appeals reversed, concluding that the futile-gesture doctrine excused the requirement that Aker show that he applied for a position in order to establish a prima facie claim for employment discrimination. The Supreme Court reversed, holding (1) the court of appeals erred in invoking the futile-doctrine theory sua sponte; and (2) the trial court did not err in granting summary judgment to Norton as a matter of law. View "Norton Healthcare, Inc. v. Deng" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder for intentionally killing his parents and one count of tampering with physical evidence. Defendant was sentenced to a total of forty-five years’ imprisonment. At issue on appeal was whether the trial court erred in failing to suppress Defendant’s confession made during protracted interrogation by sheriff’s detectives. The Supreme Court reversed Defendant’s convictions, holding (1) Defendant’s confession was involuntarily extracted through interrogation techniques employed by law enforcement that were constitutionally unjustifiable; and (2) the trial court improperly excluded Defendant’s alternate perpetrator evidence at trial. View "Gray v. Commonwealth" on Justia Law