Justia Constitutional Law Opinion Summaries

This case stems from the corrupt purchase of land, the Pensacola Soccer Complex, by the County Commission of Escambia County, Florida, in 2001. At the time of the purchase, petitioner was serving as a county commissioner for Escambia County, the equivalent of a county legislator. Petitioner appealed the district court's order denying his petition for a writ of habeas corpus and the court was called on to define what it meant to render an "adjudication on the merits." After examining Supreme Court precedents, the court affirmed the district court's denial of the petition for a writ of habeas corpus and held that the Florida District Court of Appeal's adjudication was on the merits of petitioner's claim and that the decision on the merits was neither contrary to, nor an unreasonable application of, Supreme Court Confrontation Clause precedents.

Appellant, a death row inmate, filed a motion for stay of execution in the Alabama Supreme Court after the Alabama Department of Corrections ("ADOC") announced plans to alter its lethal injection protocol for his execution by replacing the first drug in its lethal injection protocol with another. At issue was whether the ADOC's protocol change would result in violation of appellant's Eighth Amendment right to be free from cruel and unusual punishment. The court held that appellant had not demonstrated a substantial likelihood of success on the merits of his Eighth Amendment claim where the evidence presented did not demonstrate that the ADOC's use of the new drug created substantial risk of harm to him and where appellant was adequately informed of the process that would be used. Accordingly, the district court did not abuse its discretion in denying the motion to stay execution and the court affirmed.

Petitioner filed a petition for writ of habeas corpus relief pursuant to 18 U.S.S.C. 2254 after he was convicted of capital murder and sentenced to death for the murders of his father and three other persons. At issue was whether the Alabama Court of Criminal Appeals unreasonably applied clearly established federal law by concluding that the prosecutor did not comment on petitioner's silence at trial. The court denied the petition for habeas relief and held that the state court's adjudication of petitioner's claim did not violate clearly established federal law where the prosecutor's statement at issue was not the kind of compelled self-incrimination barred by clearly established federal law and where, without a more descriptive statement in the record of the supposed gesture at issue, multiple interpretations of the trial record were possible.

Petitioner, a federal prisoner, petitioned to have an error of law in the calculation of his sentence corrected based upon a Supreme Court decision interpreting the sentencing guidelines, even though that decision was issued eleven years after he was sentenced. At issue was whether the savings clause contained in 28 U.S.C. 2255(e) permitted a federal prisoner to challenge his sentence in a habeas corpus petition when he could not raise that challenge in a section 2255 motion because of the section 2255(h) bar against second and successive motions. The court held that the savings clause did not authorize a federal prisoner to bring a habeas corpus petition, which would otherwise be barred by section 2255(h), and that the sentencing guidelines were misapplied in a way that resulted in a longer sentence not exceeding the statutory minimum. The court also held that the reasoning, standards, and tests announced by the Supreme Court in Gonzalez v. Crosby, which involved a state prisoner case, also applied to federal prisoner cases. Therefore, petitioner must serve the sentence that was imposed on him fourteen years ago.

Defendant appealed his conviction for attempting to obstruct an official proceeding by attempting to dispose of and hide assets involved in a forfeiture proceeding. At issue was whether the district court erred in denying defendant's motion for judgment of acquittal. The court held that, because the government offered no evidence that defendant knew that his actions were likely to affect a forfeiture proceeding, the court concluded that a jury could not find beyond a reasonable doubt that he had the requisite intent to obstruct. Therefore, the district court erred in denying defendant's motion where the evidence was insufficient to support defendant's conviction.

Plaintiff filed a lawsuit against defendant alleging that defendant had discriminated against him because of his bankruptcy, in violation of 11 U.S.C. 525(b), by refusing to hire him and alternatively, by terminating him from the job after it had hired him. The primary issue was whether section 525(b) prohibited a private employer from denying employment to an individual on the ground that he was or has been in bankruptcy. The court applied elementary principles of statutory construction and common sense, holding that section 525(b) did not prohibit private employers from denying employment to persons because of their status as a bankruptcy debtor. The court also held that the evidence was more than enough for the jury to discredit appellant's contrary testimony and found that no employment relationship was formed. Accordingly, the court held that the district court did not err in denying plaintiff's renewed motion for judgment as a matter of law and in denying plaintiff's motion for a new trial where the jury's verdict was not against the great weight of the evidence.

Petitioner was sentenced to death following his convictions on two counts of malice murder for the fatal shootings of his grandmother and fifteen-year-old cousin. At issue was whether habeas relief was properly denied where trial and appellate counsel were ineffective in failing to conduct a reasonable investigation for mitigating evidence; where trial counsel's penalty-phase closing argument was ineffective; where petitioner's right to conflict-free counsel was wrongfully denied; and where petitioner was constructively absent from the penalty phase of trial. The court held that the state court's rejection of petitioner's ineffective-assistance claims was an unreasonable application of Strickland v. Washington where neither the jury nor the sentencing judge was ever told that petitioner suffered from extensive mental health problems and a history of abuse. Accordingly, the court granted habeas corpus relief and had no occasion to address petitioner's remaining penalty-phase claims. The court further held that it was unpersuaded by petitioner's claim that he was otherwise unconstitutionally encumbered by conflict-ridden counsel.

Defendant appealed his 30 month sentence for removing a child from the United States with intent to obstruct the lawful exercise of parental rights in violation of 18 U.S.C. 1204(a). At issue was whether the district court erred by applying the two-level enhancement under U.S.S.G. 3C1.2 for recklessly endangering another in the course of fleeing from a law enforcement officer. The court held that the district court erred in applying section 3C1.2 where defendant did not endanger his son while knowingly fleeing a law enforcement officer when defendant was unaware of the pursuit by the Coast Guard agents until the pursuit was over and defendant immediately cooperated with the first law enforcement officers he encountered. The court also held that the error was not harmless because the district court expressly stated that it was sentencing defendant in the middle of the guideline range and defendant's 30 month sentence exceeded the guideline range applicable without the section 3C1.2 enhancement. Accordingly, the court vacated the sentence and remanded for re-sentencing.

Defendants, Don Eugene Siegelman, the former Governor of Alabama and Richard Scrushy, the founder and former Chief Executive Officer of Health South Corporation ("HealthSouth"), were convicted of federal funds bribery and five counts of honest services mail fraud and conspiracy. Siegelman was also convicted of obstruction of justice. The Supreme Court of the United States remanded to the court for reconsideration in light of Skilling v. United States. Defendants raised numerous issues of error related to their convictions and sentences. The court affirmed Count 3 and 4 for Federal Funds Bribery and held that there was no reversible error in the bribery instructions given by the district court and that the evidence of a corrupt agreement between defendants was sufficient to permit a reasonable juror to find quid pro quo. The court affirmed Count 5, 6, and 7 for Honest Services Mail Fraud and Conspiracy and held that any error in the honest services instructions was harmless. The court reversed Count 8 and 9 for Self Dealing where there was lack of evidence from which the jury could infer that Siegelman knowingly agreed to or participated in a broader scheme that included Scrushy's alleged subsequent dealing and where, in light of Skilling, the evidence was insufficient to show self-dealing. The court affirmed Count 17 for Obstruction of Justice and held that the district court did not abuse its discretion in admitting evidence that a certain statement at issue met the United States v. Caraza standard. The court also held that the district court did not abuse its discretion in holding that there was no reasonable possibility of prejudice to defendants that arose out of the exposure of the jury to certain extrinsic evidence and denied the motion for new trial. The court held that exposure of the jurors to media reports about the trial was harmless in view of the limited and incidental nature of the exposure and the substantial evidence of defendants' guilt. The court also agreed with the district court that defendants were not entitled to a new trial where there was no possibility that defendants suffered prejudice from any premature deliberations, discussion of penalty, or deliberation with fewer than all the members of the jury present. The court further held that Scrushy's recusal motion was untimely and without merit; that defendants' claims regarding the Middle District of Alabama's jury selection procedures were without merit and did not entitle them to any relief; and that Siegelman's upward departure in sentencing was not an abuse of discretion.

Defendant appealed a conviction for attempting to persuade, entice, or coerce a minor to engage in sexual activity in violation of 18 U.S.C. 2422(b). At issue was whether there was sufficient evidence to support defendant's conviction; whether the court erred in denying defendant's motion to suppress evidence seized from his truck; and whether a detective failed to preserve computer evidence in bad faith and instant message transcripts should not have been admitted at trial. The court held that there was sufficient evidence to support defendant's convictions where defendant's actions strongly corroborated his culpability and supported the jury's verdict. The court also held that the district court did not err in denying the motion to suppress where defendant's truck was mobile and the officers had probable cause to search the truck pursuant to the automobile exception. The court further held that defendant failed to provide evidence of bad faith on the part of the detective and that the district court did not abuse its discretion by admitting the transcripts or clearly erred in accepting as fact the detective's authenticating testimony, by rejecting defendant's best evidence objection because there was no showing of bad faith, and by failing to admit the alleged additional parts of the instant message transcripts where there was no evidence of its existence. The court finally held that the district court did not abuse its discretion in denying defendant's proposed jury instructions where the spoliation doctrine had not been recognized in the criminal context.