Justia Constitutional Law Opinion Summaries

Duane Gary Underwood, II was convicted of possession with intent to distribute methamphetamine, possession of a stolen firearm, and possession of a firearm in furtherance of a drug trafficking crime. Underwood appealed his conviction on ten grounds, including the constitutionality of 18 U.S.C. § 924(c)(1)(A), the legality of his detention and search, the validity of a search warrant for his phone, the admissibility of certain evidence, voir dire procedures, the sufficiency of the evidence, jury instructions, and the licensure status of the prosecuting Assistant U.S. Attorney (AUSA).The United States District Court for the Western District of Michigan denied Underwood's pretrial motions to suppress evidence and dismiss charges. The court admitted evidence from Underwood's phone and grand jury testimony under Rule 803(5). The jury convicted Underwood on all counts, and he was sentenced to 180 months' imprisonment. Post-trial, Underwood moved to dismiss his conviction, arguing that the AUSA's administrative suspension for nonpayment of bar dues constituted prosecutorial misconduct and a jurisdictional defect. The district court denied this motion.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's judgment. The court held that 18 U.S.C. § 924(c)(1)(A) is constitutional, the officers had reasonable suspicion to detain and search Underwood, and the search warrant for Underwood's phone was valid. The court found no abuse of discretion in admitting the contested evidence or in the voir dire procedures. The evidence was deemed sufficient to support the convictions, and the jury instructions were appropriate. The court also ruled that the AUSA's administrative suspension did not constitute prosecutorial misconduct or create a jurisdictional defect, and there was no Brady violation. View "United States v. Underwood" on Justia Law

Raymon Risner was charged with several drug trafficking and firearms offenses. He moved to dismiss the firearm-related counts, arguing that the statutes violated the Second Amendment. The district court denied his motion, and Risner pleaded guilty to conspiracy to distribute methamphetamine and possessing a firearm in furtherance of a drug trafficking offense. He retained the right to appeal the denial of his motion to dismiss and filed a timely appeal.The United States District Court for the Eastern District of Kentucky denied Risner’s motion to dismiss the firearm-related counts. Risner then pleaded guilty to conspiracy to distribute methamphetamine and possessing a firearm in furtherance of a drug trafficking offense. The district court dismissed the felon-in-possession charge pursuant to the plea agreement.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Risner lacked standing to challenge the constitutionality of 18 U.S.C. § 922(g)(1) because the charge was dismissed and there were no collateral consequences. The court also held that 18 U.S.C. § 924(c)(1)(A) did not violate the Second Amendment, as the statute’s restriction on using a firearm in furtherance of a drug trafficking crime was consistent with the Nation’s historical tradition of firearm regulation. The court concluded that the Second Amendment does not protect the possession of weapons for unlawful purposes, and Risner’s challenge failed. View "United States v. Risner" on Justia Law

Victor Silvers was convicted of the premeditated murder of his estranged wife, Brittney Silvers, who was an active member of the United States Army, and was shot and killed at Fort Campbell, Kentucky. Silvers was also found guilty of attempted murder, domestic violence, violation of a protection order, possession of a firearm by a prohibited person, and the use of a firearm during a crime of violence. He was sentenced to life in prison.The United States District Court for the Western District of Kentucky took judicial notice that Fort Campbell was within the United States' special maritime and territorial jurisdiction. Silvers challenged this, arguing that the jury should have determined the jurisdictional status. He also moved to exclude a juror who wore a shirt supporting military veterans and had served in the Navy, claiming potential bias. Additionally, Silvers argued that his mandatory life sentence was unconstitutional under the Eighth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not err in taking judicial notice of the jurisdictional status of Fort Campbell, as it was a legal question rather than a factual one for the jury. The court also found no abuse of discretion in the district court's decision to deny Silvers's motion to exclude the juror, as the juror assured impartiality and the voir dire process was deemed adequate. Finally, the court upheld Silvers's mandatory life sentence, citing binding Supreme Court precedent and the Sixth Circuit's own precedent, which did not find such sentences to be cruel and unusual punishment.The Sixth Circuit affirmed both Silvers's conviction and his sentence. View "United States v. Silvers" on Justia Law

Quincy Taylor was convicted by a jury of possession of a controlled substance with intent to distribute, possession of a firearm in furtherance of drug trafficking, and being a felon in possession of a firearm. The charges stemmed from an incident where Taylor was involved in a car accident, and a witness, William Howell, testified that Taylor had a bag containing drugs and a firearm. Howell's testimony was the only evidence linking Taylor to the contraband.The United States District Court for the Eastern District of Kentucky limited Taylor's ability to cross-examine Howell about his criminal history and potential bias. Specifically, the court allowed Taylor to ask if Howell had any felony convictions but prohibited questions about the nature of the conviction, Howell's pending felon-in-possession charge, and any benefits Howell might receive for his cooperation. Taylor argued that these limitations violated his Confrontation Clause rights under the Sixth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court's limitations on cross-examination violated Taylor's constitutional right to confront witnesses. The court determined that the jury did not have sufficient information to assess Howell's potential bias and motive for testifying. The court also found that the error was not harmless, as Howell's testimony was crucial to the prosecution's case, and there was no other evidence linking Taylor to the contraband.As a result, the Sixth Circuit reversed Taylor's convictions and remanded the case for a new trial, holding that the district court's limitations on cross-examination violated Taylor's Confrontation Clause rights and that the error was not harmless. View "United States v. Taylor" on Justia Law

In March 2020, Andrew Cooperrider, owner of Brewed, a coffee shop and bar in Lexington, Kentucky, criticized Governor Beshear’s COVID-19 policies on social media. In November 2020, the Kentucky Department of Alcoholic Beverage Control (DABC) suspended Brewed’s alcohol license, and officially revoked it in March 2022. Cooperrider filed a lawsuit against Governor Beshear, DABC officials, and other state officials, alleging First Amendment retaliation and due-process violations, claiming the license revocation was in retaliation for his critical speech.The United States District Court for the Eastern District of Kentucky dismissed the case, granting the defendants' motions to dismiss. The court found that most of Cooperrider’s claims were barred by absolute, qualified, and sovereign immunity. It also determined that Cooperrider’s remaining substantive-due-process claim did not meet the Rule 12(b)(6) pleading standard.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of most claims, agreeing that the defendants were protected by absolute, qualified, and sovereign immunity. However, the appellate court found that the district court improperly granted qualified immunity to Governor Beshear, Ray Perry, and Wesley Duke regarding Cooperrider’s First Amendment retaliation claim. The appellate court held that Cooperrider had plausibly alleged that the enforcement action against Brewed was motivated by his protected speech. Consequently, the court reversed the district court’s decision on this point and remanded the case for further proceedings on the First Amendment retaliation claim. View "Cooperrider v. Woods" on Justia Law

Louis Chandler, a Michigan prisoner, was convicted of two counts of first-degree criminal sexual conduct and sentenced to concurrent terms of twenty-five to seventy-five years in prison. Chandler filed a habeas corpus petition, claiming that the trial court infringed his right to present a complete defense. The district court denied the petition, and Chandler appealed.The United States District Court for the Western District of Michigan initially reviewed the case and denied Chandler's habeas corpus petition. Chandler argued that the trial court's refusal to delay the trial, exclusion of key witnesses, and prevention of presenting critical evidence violated his constitutional rights. The Michigan Court of Appeals found that the trial court had abused its discretion by denying Chandler's requests for an adjournment, barring his witnesses, and excluding evidence of the victim's prior false allegations. However, the appellate court affirmed Chandler's conviction, concluding that the errors were not outcome determinative under the state's non-constitutional error standard.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the trial court's actions significantly undermined Chandler's ability to present a complete defense. The court held that the exclusion of evidence and witnesses critical to Chandler's defense violated his constitutional rights. The court concluded that the errors had a substantial and injurious effect on the jury's verdict, creating grave doubt about the trial's fairness.The Sixth Circuit reversed the district court's decision, conditionally granted Chandler's habeas corpus petition, and remanded the case with instructions to order Chandler's release unless the State of Michigan grants him a new trial within ninety days. View "Chandler v. Brown" on Justia Law

The case involves Michigan's electricity market regulations, specifically the Individual Local Clearing Requirement (ILCR), which mandates that electricity retailers in Michigan's lower peninsula procure a certain percentage of their capacity from within that region. Plaintiffs, including Energy Michigan and the Association of Businesses Advocating Tariff Equity (ABATE), challenged the ILCR on the grounds that it violates the dormant Commerce Clause by discriminating against interstate commerce.The United States District Court for the Eastern District of Michigan initially dismissed the Michigan Public Service Commission (MPSC) on Eleventh Amendment grounds but allowed the case to proceed against individual commissioners. The court denied summary judgment motions from both sides, finding that there were factual disputes regarding whether the ILCR discriminated against interstate commerce. After a three-day bench trial, the district court concluded that the ILCR did not violate the Commerce Clause.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the ILCR is facially discriminatory because it requires electricity to be generated within a specific geographic region, effectively favoring in-state over out-of-state electricity. The court held that this discrimination necessitates strict scrutiny, which the district court did not properly apply. The Sixth Circuit reversed the district court's judgment and remanded the case for further proceedings to determine if the ILCR can survive strict scrutiny by proving it is the only means to achieve the state's goal of ensuring a reliable energy supply. View "Energy Michigan, Inc. v. Public Service Commission" on Justia Law

Zillow, Inc., a for-profit corporation, requested property tax data from several Kentucky property valuation administrators (PVAs) under Kentucky’s Open Records Act (KORA). The PVAs classified Zillow’s requests as having a commercial purpose and quoted fees amounting to thousands of dollars. Zillow sued, arguing that KORA’s fee structure, which distinguishes between commercial and non-commercial purposes and includes exceptions for newspapers, radio, and television stations, violated the First and Fourteenth Amendments.The United States District Court for the Eastern District of Kentucky held that the commercial/non-commercial distinction did not violate the First or Fourteenth Amendments but found the newspaper exception unconstitutional. The court severed the newspaper exception from the statute, resulting in both Zillow and newspapers being subject to enhanced fees. The Kentucky Press Association and American City Business Journals intervened and, along with Zillow, appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the commercial-fee statute did not violate the First Amendment as applied to Zillow. It determined that the distinction between commercial and non-commercial purposes was content-neutral and did not impermissibly discriminate based on the content of Zillow’s speech. The court reversed the district court’s order declaring the newspaper exception unconstitutional, vacated the permanent injunction, and remanded with instructions to grant summary judgment to the PVAs. View "Zillow, Inc. v. Miller" on Justia Law

Harkness was commissioned as a Navy Chaplain Corps officer in 1987, endorsed by a non-liturgical Christian church. Harkness left active duty in 1995 and took reserve status. In 2000, Harkness and other non-liturgical chaplains sued the Navy, alleging systemic denominational prejudice in its promotion procedures. That suit is still pending. In 2007, Harkness was denied promotion by a reserve officer promotion board. Harkness requested a special selection board (SSB). The petition was denied. Harkness filed suit in 2010, challenging (10 U.S.C. 14502(h)(1)) the SSB denial and the promotion procedures. The Sixth Circuit affirmed dismissal of the constitutional claim for failure to exhaust administrative remedies. In 2012, the Secretary convened an SSB to reconsider the 2007 decision. It did not select Harkness for promotion; Harkness unsuccessfully requested a second SSB. In 2013, Harkness was again denied promotion and unsuccessfully requested an SSB, alleging that procedures employed by promotion boards produced denominational preferences and challenging the delegation of governmental authority to chaplains serving on promotion boards without effective guarantees that the power would be exercised in a neutral, secular manner. In filing suit, Harkness added a First Amendment retaliation claim. The Sixth Circuit affirmed dismissal of all claims. the 2013 promotion board was not constitutionally infirm; the denial of Harkness’s 2013 SSB request was not arbitrary, capricious, or otherwise contrary to law under section 14502(h)(1). View "Harkness v. Secretary of Navy" on Justia Law

Anita drove her son, Omar, to Lowe’s, to pick up his last paycheck. When the assistant manager approached, Omar “started talking a lot of gibberish” and eventually began throwing paint cans. Officers, responding to a 911 call, stopped Anita’s car. Omar was evasive but compliant. During the pat-down, officers discovered pills in a container, which they returned to Omar’s pocket after handcuffing him. Omar stated that he had not taken his medication, for a psychiatric condition, for weeks. Anita stated that Omar, who began ranting incoherently, was bipolar, that the pills were Seroquel, and that he had not taken his medication. At the jail, Omar would calm down periodically, then return to rambling, talking to himself, and engaging in strange behavior. Released without handcuffs to make a phone call, Omar threw an officer to the floor and began choking him. Officers rushed into the jail and pulled Omar into the restraint chair and noticed something wrong. Omar’s pulse was weak. They tried to resuscitate him and called the rescue squad. At the hospital, Omar was pronounced dead “as a result of a sudden cardiac event during a physical altercation in association with bipolar disease.” In Anita’s suit, alleging deliberate indifference, the court denied the officers qualified immunity. The Sixth Circuit reversed. There was no violation of a clearly established constitutional right. The officers did not act with recklessness that would permit them to be liable under Ohio law. View "Arrington-Bey v. City of Bedford Heights" on Justia Law