Justia Constitutional Law Opinion Summaries

ICE officers entered the home Ramos shared with relatives with an administrative warrant for a sister, with no information about the identity or legal status of other occupants. During the next 15 hours, the agents detained and questioned the occupants, under circumstances that were allegedly extremely stressful. Ramos produced documents showing that he is a citizen of Guatemala; he did not produce any documentation that he was lawfully present in the U.S. The IJ denied a motion to suppress evidence found during the raid, although Ramos was detained without a warrant. Ramos asserted that the agents entered his home without valid consent and in violation of administrative regulations. He sought production of documents related to his search, seizure, and arrest, and ICE procedures. The IJ never ruled on that motion, but found Ramos removable. The BIA dismissed an appeal, declining to address a Fourth Amendment claim and finding that any regulatory violations did not alter the outcome. The Third Circuit vacated and remanded. The exclusionary rule may apply in cases where constitutional violations by immigration officers are widespread or evidence was obtained as a result of egregious violations of the Fourth Amendment or other liberties that might transgress notions of fundamental fairness and undermine the probative value of the evidence.

Newark detectives were watching a building in connection with a crime that occurred at another location, two months earlier. They did not have a description of anyone involved and had no information whatsoever about Navedo. After watching an interaction between Navedo and Pozo, the officers thought that Pozo had a gun. The officers approached and identified themselves and clearly saw that Pozo had a gun. Pozo threw it into his bag and ran. As one officer chased Pozo, Navedo ran up the stairs to his home with another officer pursuing him into the building. As Navedo opened the door to his apartment, he was tackled by the officer, who testified that he handcuffed Navedo, then observed a shotgun, rifles, and ammunition on the floor. The court denied a motion to suppress, holding that the officers had reasonable suspicion to stop and question Navedo and that Navedo’s flight elevated the reasonable suspicion to “probable cause for arrest and justified entry” under the theory of hot pursuit. The Third Circuit vacated. The police had no reason to suspect that Navedo was involved in criminal activity, and even if they had appropriately formed such suspicion, they would only have been entitled to detain and investigate, not arrest.

In 1986 Munchinski was convicted of two counts of first-degree homicide and two counts of second-degree homicide arising out of a pair of murders that occurred in 1977 in Bear Rocks, Pennsylvania. Munchinski later discovered that prosecutors had withheld from his counsel almost a dozen articles of exculpatory evidence. After unsuccessfully petitioning for post-conviction relief several times in state and federal court, Munchinski filed a second or successive habeas petition pursuant to 28 U.S.C. 2244 & 2254(d), arguing that the Pennsylvania Superior Court unreasonably applied Brady, when it declined to grant Munchinski post-conviction relief. The district court granted habeas relief. The court equitably tolled the statute of limitations for some untimely claims; excused certain procedural defaults, finding that applying the procedural default doctrine would effect a fundamental miscarriage of justice; and agreed that the state court had unreasonably applied Brady. The Third Circuit affirmed, noting that the scope of the Brady violations was “staggering.” Munchinski demonstrated actual innocence by clear and convincing evidence.

Philadelphia police officers entered a private residence without a warrant because they believed the house to be abandoned. Upon searching the house, they found Harrison sitting in a recliner with a gun, scales, pills, and cocaine base on the table next to him. The police took Harrison into custody, seized the gun, and obtained a warrant to seize the rest of the items. Harrison was charged with possession with intent to distribute five grams or more of cocaine base and moved to suppress the physical evidence. The district court denied the motion; although Harrison, a tenant, had a reasonable expectation of privacy in the house, the police officers were operating under the mistaken but reasonable belief that the house was abandoned. The Third Circuit affirmed. A house can be abandoned for Fourth Amendment purposes; the officers did not make a mistake of law. Their mistake of fact was reasonable, based on their observations over several months that the house appeared unfit for human habitation. There was trash strewn about, the lawn was overgrown with weeds, and windows on both levels were either boarded up or exposed. The front door was left open, and the lock may have been broken.

Mitchell was convicted on charges related to his possession of a firearm with an obliterated serial number. The Third Circuit affirmed the district court’s denial of Mitchell’s motion to strike Juror 97, a police department employee, because the law does not categorically impute bias to coworkers of key witnesses in a trial. Under the circumstances, Mitchell’s right to trial by an impartial jury was protected adequately by inquiry for actual bias, and that inquiry yielded no evidence of actual bias. The court remanded for additional fact-finding with respect to Juror 28, a “close cousin” of the prosecutor. The law presumes bias in jurors who are close relatives of the parties in a case and the court did not elicit sufficient information on the nature of the relationship between the prosecutor and Juror 28.

Based on DNA evidence found on furniture, McBride was charged with the murder of his wife 16 years after her disappearance. He was convicted and exhausted Pennsylvania state court appeals. The district court denied his habeas corpus petition. The Third Circuit affirmed, rejecting McBride’s claim that his trial counsel was ineffective by failing to object to certain references to his silence, in violation of his constitutional right to remain silent. There was at least a reasonable argument that trial counsel’s actions were within the “wide range of professionally competent assistance.”

Booker participated in a bank robbery with co-conspirators. After being arrested on unrelated charges, he provided incriminating statements to the police. Booker moved to suppress these statements as violations of his Miranda rights. The district court denied his motion. Before trial, Booker requested that he be allowed to proceed pro se. The court conducted a hearing and warned him of the consequences of self-representation. While articulating the potential sentences facing him, the district court erred and misstated one of the relevant mandatory minimums (stating it was five years and not 25 years). Booker was convicted of all charges. The Third Circuit vacated and remanded for a new trial. In light of the court’s error, Booker’s waiver of counsel was not voluntary and knowing.

The Church of the Lord Jesus Christ of the Apostolic Faith was founded by Johnson in 1919. In 1947, Johnson established a non-profit corporation to hold and manage the assets of the Church. Following a 1992 schism, two factions claimed authority over the Church and ownership of church assets. In 2000 Pennsylvania courts concluded that Kenneth Shelton was the rightful General Overseer of the Church. Askew was a member of the faction loyal to Roddy Shelton. He does not accept Bishop Kenneth Shelton as the General Overseer of the Church. On multiple occasions since the schism, Bishop Shelton declared all followers of Roddy Shelton nonmembers of the Church. Asserting claims on behalf of himself as a church member and derivatively on behalf of the Church, Askew sued, alleging that Bishop Shelton and officers of the affiliated Board of Trustees misappropriated church assets and breached their fiduciary duties to the Church. The district court dismissed. The Third Circuit affirmed, holding that as a nonmember, Askew lacked standing and that First Amendment non-entanglement principles shields membership decisions from civil court review.

Seven states sought to recover proceeds of matured but unredeemed U.S. savings bonds from the Treasury, asserting that Treasury has possession of approximately $16 billion worth of matured but unredeemed savings bonds, of which persons whose last known addresses were within the plaintiff states own $1.6 billion. The states contended that their respective unclaimed property acts obliged Treasury to account for and deliver the proceeds of these bonds to the states for reunification with their owners. The district court dismissed, reasoning that sovereign immunity and intergovernmental immunity barred the action and that federal law and regulations preempted the states’ statutory authority to obtain the proceeds of the savings bonds. The Third Circuit affirmed. Although the federal government has waived sovereign immunity (5 U.S.C. 702), states may not directly regulate the federal government’s operations or property and federal law is sufficiently pervasive so as not to leave room for the enforcement of the unclaimed property acts to achieve the result that the states seek.

Figueroa admits that he sold heroin to an undercover officer, who returned later and purchased cocaine and heroin. During the second purchase, the officer saw what appeared to be a gun tucked into Figueroa’s waistband. It was dark and he only saw a few inches of the object. Officers then stopped the car driven, and owned, by Figueroa’s girlfriend. Figueroa was in the front passenger seat. Officers removed both from the car, opened the glove compartment, and recovered a handgun. Both occupants denied knowledge of the firearm. No forensic evidence connected either to the firearm. The jury convicted on the drug counts, but was split on the charge of carrying a firearm during a drug trafficking offense, 18 U.S.C. 924(c)(1). After releasing the jury, the judge changed courses, asked that the jury be held, and had them deliberate a charge of possession of a firearm by a felon, 18 U.S.C. 922(g)(1) and 924(e). The jury convicted and Figueroa was sentenced to 180 months, the statutory minimum for possession by a felon. The Third Circuit affirmed. Reconvening after declaring a mistrial on Count III did not violate Double Jeopardy or subject the jury to outside influences.