Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed Defendant's convictions of attempted first-degree murder, aggravated assault on a law enforcement officer, and other offenses, holding that the circuit court did not err by denying Defendant's motions to suppress and did not abuse its discretion by denying Defendant's proposed jury instructions on lesser-included offenses.Prior to trial, Defendant filed three motions to suppress his statements to law enforcement and also moved to suppress evidence derivative of his arrest on the basis that the officer engaged in racial profiling as the basis for the traffic stop. The circuit court denied the motions to suppress. Defendant was subsequently convicted. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Defendant's motions to suppress; and (2) did not err in refusing to give Defendant's proposed lesser included offense instructions. View "State v. Willingham" on Justia Law

The Supreme Court reversed the order of the magistrate court that Defendant's motion to suppress should be granted in accordance with an earlier order of the circuit court, holding that Defendant's constitutional rights were not violated, and therefore, Defendant's motion to suppress should have been denied.Defendant was charged with driving under the influence of alcohol. Defendant filed a motion to suppress evidence as a result of his encounter with a police officer, arguing that he was not detained based on reasonable suspicion, and therefore, the stop of his vehicle violated the Fourth Amendment of the federal constitution and Article VI of the state constitution. The magistrate court denied the motion to suppress and entered a judgment of conviction. The circuit court reversed and ordered that Defendant's motion to suppress should be granted. The magistrate court then entered its order acting in accordance with the circuit court's order and granted Defendant's motion to suppress. The Supreme Court reversed, holding (1) this Court had jurisdiction to hear the State's appeal; and (2) the officer developed a reasonable suspicion of criminal activity before seizing Defendant, and therefore the evidence from the stop should not have been suppressed. View "State v. Sharpfish" on Justia Law

The Supreme Court affirmed Defendant's conviction for theft by exploitation in an amount exceeding $5,000, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Court held that the circuit court (1) did not violate Defendant's rights under the Sixth Amendment by finding Defendant's waiver of his right to counsel was knowing, voluntary, and intelligent; (2) did not err by denying Defendant's motion for a judgment of acquittal; (3) did not err in ordering Defendant to pay $31,743.82 in restitution; and (4) did not impose a sentence that violated the Eighth Amendment's prohibition against cruel and unusual punishment. View "State v. Hauge" on Justia Law

The Supreme Court affirmed Defendant's conviction of four counts of rape in the fourth degree, one count of sexual exploitation of a minor, one count of solicitation of a minor, and a misdemeanor count of enticing a child away, holding that Defendant's sentences did not violate double jeopardy protections and that the State did not commit prosecutorial misconduct.On appeal, Defendant argued (1) his sentences for sexual exploitation of a minor and solicitation of a minor violated the Double Jeopardy Clause of the Fifth Amendment because those convictions arose from the same conduct as the rape convictions; and (2) in asking about similarities between Defendant's step-daughter and the victim during cross-examination the State engaged in prosecutorial misconduct. The Supreme Court affirmed, holding (1) any error in conviction and sentence for solicitation and sexual exploitation of a minor was not plain; and (2) Defendant did not show that the State's improper cross-examination affected his substantial rights. View "State v. McMillen" on Justia Law

The Supreme Court affirmed Defendant's conviction of simple assault and kidnapping, holding that the trial court did not err in the proceedings below and that Defendant's sentence was not unconstitutional under the Eighth Amendment.Specifically, the Court held (1) the circuit court did not err when it denied Defendant's motion for a mistrial for an alleged Brady violation; (2) the circuit court did not abuse its discretion when it denied Defendant's motion for a mistrial; (3) Defendant was not denied a fair trial due to cumulative errors; and (4) Defendant's sentence was not grossly disproportionate or excessive. View "State v. Delehoy" on Justia Law

The Supreme Court affirmed the decision of the circuit court affirming the magistrate judge's denial of Defendant's motion to suppress evidence obtained during a vehicle stop, holding the magistrate judge did not err by concluding that the stop was justified under the community caretaker exception.Defendant was convicted in magistrate court of driving under the influence. Defendant appealed the denial of his motion to suppress all evidence and statements obtained during the traffic stop, arguing that the police officer lacked reasonable suspicion of criminal activity. The Supreme Court affirmed, holding that the officer was acting in his community caretaking role when he stopped Defendant's vehicle in the parking lot, and the officer provided specific and articulable facts supporting his decision to stop Defendant's vehicle. View "State v. Short Bull" on Justia Law

The Supreme Court affirmed Defendant’s convictions for first-degree robbery and aiding, abetting, or advising first-degree robbery stemming from two separate cases, holding that any error in the proceedings below was harmless.Specifically, the Court held (1) the circuit court did not by denying Defendant’s motion to dismiss the indictments for violation of his statutory and constitutional rights to a speedy trial; (2) Defendant’s waiver of Miranda rights and subsequent statements were voluntary, knowing, and intelligent; and (3) although Defendant invoked his right to an attorney, his unambiguous request occurred after he had confessed to the crimes, and therefore, the detectives’ error in continuing the interview after that point was harmless, and the circuit court’s failure to exclude Defendant’s post-invocation statements was also harmless. View "State v. Two Hearts" on Justia Law

The Supreme Court affirmed Defendant’s sentence, imposing in connection with his conviction of second-degree rape, of forty years in the state penitentiary, with five years suspended, to run consecutive to the prison term Defendant was currently serving in Iowa for offenses involving the same victim, holding that the sentence was not cruel and unusual in violation of the Eighth Amendment.Specifically, the Supreme Court held (1) after weighing the gravity of the offense against the sentence Defendant received, the circuit court did not violate Defendant’s constitutional rights by imposing a sentence within the authorized fifty-year maximum; and (2) the circuit court did not abuse its discretion in sentencing Defendant. View "State v. Yeager" on Justia Law

The Supreme Court affirmed the circuit court’s judgment convicting Defendant of first-degree rape, multiple counts of sexual contact with a child, and possessing, manufacturing, or distributing child pornography, holding that the circuit court did not violate Defendant’s right to a public trial when it ordered the partial closure of the courtroom during the minor victim’s testimony.On appeal, Defendant argued that the circuit court erred in partially closing the courtroom in violation of his Sixth Amendment right to a public trial and that the court erred in denying his motion to suppress his non-custodial statement to a law enforcement officer. The Supreme Court affirmed, holding (1) there was no violation of Defendant’s Sixth Amendment right to a public trial; and (2) the absence of any custodial interrogation rendered Defendant’s second argument unsustainable under Miranda v. Arizona, 384 U.S. 436 (1996), and Edwards v. Arizona, 451 U.S. at 485-85 (1990). View "State v. Uhre" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree felony murder, commission of a felony while armed with a firearm, and burglary in the first degree, holding that the circuit court properly denied Defendant’s motion to suppress and did not err by refusing to compel specific performance of a plea agreement.On appeal, Defendant argued that his statements to law enforcement during a custodial interrogation should have bene suppressed because they were obtained in violation of his right to counsel and right against self-incrimination. Defendant further claimed that the circuit court erred in denying his motion for specific performance of the plea agreement that he alleged would have allowed him to plead guilty to manslaughter. The Supreme Court affirmed, holding (1) the admission of the evidence that was the subject of the motion to suppress was harmless error even if the statements had been unlawfully obtained; and (2) Defendant failed to show an enforceable plea agreement existed, and therefore, the circuit court properly denied Defendant’s motion for specific performance of the plea agreement. View "State v. Lewandowski" on Justia Law