Justia Constitutional Law Opinion Summaries

Appellant was convicted of first degree murder and sentenced to death. The Supreme Court affirmed. Appellant subsequently filed two postconviction motions, both of which were denied. Appellant also filed for federal habeas relief, which the federal courts denied. This appeal concerned Appellant’s latest motion for postconviction relief, which contained five claims dealing with the method of inflicting the death penalty and the State’s authority to put Appellant to death at all, no matter the method. The district court dismissed the petition without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant’s motion failed to state a claim for postconviction relief, either because his claims were without legal basis or because they were not cognizable in postconviction. View "State v. Ryan" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and use of a deadly weapon to commit a felony stemming from Defendant’s involvement in a fatal shooting that occurred during a home invasion robbery. On appeal, Defendant argued that the trial court erred when it restricted his cross-examination of three key prosecution witnesses and otherwise violated his constitutional rights of confrontation and due process by impeding his efforts to impeach the witnesses. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by limiting the cross examination of the witnesses; (2) Defendant’s argument that the State violated his rights by failing to disclose tacit plea agreements between the State and the witnesses was without merit; and (3) evidence of prior home invasion robberies committed by two of the witnesses was not admissible in this case because it was not relevant for any legitimate purpose, including impeachment. View "State v. Patton" on Justia Law

After a jury trial, Defendant was convicted of first degree murder and use of a deadly weapon to commit a felony for the death of her husband. On appeal, Defendant argued that the trial court abused its discretion by admitting certain statements Defendant made while in police custody as volunteered statements. Specifically, Defendant argued that the trial court erred in denying her motion to suppress the statements because Defendant had invoked her constitutional right to end the interrogation. The Supreme Court affirmed, holding (1) statements Defendant made from 3:43 to 4 a.m. should have been suppressed because Defendant had invoked her right to remain silent, but the district court’s error was harmless; and (2) statements Defendant made after 4:18 a.m. were not required to be suppressed as involuntary due to Defendant’s earlier invocation of her right to end questioning, as the statements Defendant made after 4:18 a.m. were initiated by Defendant and were not the product of interrogation. View "State v. DeJong" on Justia Law

Defendant was charged with first degree murder and use of a deadly weapon to commit a felony. Defendant moved to suppress the statements he made to police during the murder investigation. The district court overruled Defendant’s motion, and, at a bench trial, the State received evidence of the statements challenged in Defendant’s motion to suppress. The district court found Defendant guilty of both charges and sentenced him to life imprisonment for the murder conviction. The Supreme Court affirmed, holding (1) the district court erred in admitting evidence of Defendant’s confession during a pre-Miranda interrogation, but this evidence was cumulative to other admissible evidence, and its admission was harmless error; and (2) the evidence was sufficient to support Defendant’s convictions. View "State v. Juranek" on Justia Law

Defendant was convicted of knowing or intentional child abuse resulting in death and was sentenced to life in prison. The Supreme Court affirmed on appeal. Defendant subsequently filed a petition for postconviction relief, alleging errors on the part of the trial court and errors relating to the ineffectiveness of trial counsel and appellate counsel. Following an evidentiary hearing, the district court dismissed the petition. The Supreme Court affirmed, holding that the district court did not err in dismissing Defendant’s petition for postconviction relief on the basis of ineffective assistance of counsel. View "State v. Robinson" on Justia Law

After a jury trial, Defendant was found guilty of first degree sexual assault. Defendant appealed, arguing that he received ineffective assistance of counsel at trial in several respects and that his conviction was not supported by sufficient evidence. The court of appeals affirmed, concluding, as to three of Defendant’s ineffective assistance of counsel claims, they were without merit because Defendant failed to allege how he was prejudiced by his counsel’s performance. The Supreme Court affirmed as modified, holding (1) the court of appeals applied the wrong reasoning in finding that three of Defendant’s ineffective assistance claims lacked merit for failure to allege prejudice, as resolution of ineffective assistance of trial counsel claims requires specific allegations of the deficient conduct, but allegations of prejudice are not necessary on direct appeal; and (2) in these three instances, the record was not sufficient to review Defendant’s claim. View "State v. Filholm" on Justia Law

Appellant was a temporary employee at the University of Nebraska. After the University considering terminating Appellant’s employment, human resources completed a “threat assessment” in relation to the termination, which noted Appellant’s criminal record and history of becoming upset over discussion of work performance. When the University decided to terminate Appellant, an e-mail was circulated warning coworkers to alert campus police and lock their doors if they saw Appellant. Appellant filed this action under 42 U.S.C. 1983 against the University Board of Regents and two of its managers, making a “stigma plus” claim that he was deprived of a liberty interest in his good name without due process of law. The district court granted summary judgment in favor of Defendants, concluding (1) there was no genuine issue of material fact that Appellant had not sufficiently suffered a constitutional violation; (2) the Board of Regents was shielded by sovereign immunity; and (3) the individual defendants were protected by qualified sovereign immunity because the alleged violation was not clearly established. The Supreme Court affirmed, holding that the district court did not err in its judgment. View "Potter v. Bd. of Regents of Univ. of Neb." on Justia Law

After a jury trial, Appellant was convicted of first degree murder, use of a deadly weapon to commit a felony, and possession of a deadly weapon by a felon. The Supreme Court affirmed the convictions and sentences on appeal. Appellant subsequently filed a motion for postconviction relief, making numerous claims of ineffective assistance of trial counsel. After an evidentiary hearing, the district court denied the motion. The Supreme Court affirmed, holding that the district court did not err when it concluded that Appellant’s claims were without merit and denied his motion for postconviction relief. View "State v. Robinson" on Justia Law

The lead investigator for a law enforcement agency applied for and received a search warrant to search three computers Defendant owned for child pornography. Defendant admitted to the investigator to downloading and viewing child pornography and subsequently deleting the child pornography computer files. However, a forensic examination revealed remnants on Defendant’s hard drive. After a bench trial, Defendant was found guilty of knowingly possessing child pornography. Defendant appealed the denial of his motion to suppress the evidence resulting from the earlier search and seizure. The Supreme Court affirmed the conviction, holding (1) the investigator’s failure to explain in his affidavit that dynamic Internet Protocol (IP) addresses can change did not affect the probable cause determination; and (2) the evidence was sufficient to support the conviction. View "State v. Schuller" on Justia Law

In 2006, Appellant pled guilty to second degree murder. The district court sentenced Appellant to a term of imprisonment of fifty years to life. In 2012, Appellant filed a pro se petition for postconviction relief, alleging that his sentence was excessive and that he was denied the effective assistance of counsel in connection with his sentencing. The district court dismissed the motion without an evidentiary hearing. The Supreme Court affirmed, holding that the district court did not err when it determined that Appellant’s motion for postconviction relief did not allege facts which constituted a denial of his constitutional rights, and that as to certain matters, the record refuted Appellant’s claims. View "State v. Dragon" on Justia Law