Justia Constitutional Law Opinion Summaries

David Knellinger and Robert Storey discovered that the state of Colorado had taken possession of their property under the Revised Uniform Unclaimed Property Act (RUUPA). They filed a lawsuit under 42 U.S.C. § 1983, claiming that Colorado's unclaimed property scheme violated the Takings Clause of the Fifth Amendment. The plaintiffs alleged that Colorado took their property for public use without just compensation and did not provide them with notice or compensation.The United States District Court for the District of Colorado dismissed the plaintiffs' claims for lack of standing. The court found that Knellinger and Storey failed to sufficiently allege ownership of the property at issue, partly because they did not file an administrative claim to establish ownership as required by RUUPA. The district court also dismissed the plaintiffs' equitable claims, concluding that § 1983 provided an adequate basis for obtaining just compensation.The United States Court of Appeals for the Tenth Circuit reviewed the case and determined that the district court erred in dismissing the plaintiffs' claims for monetary relief. The appellate court held that Knellinger and Storey had plausibly alleged that Colorado took their property for public use without just compensation, which is sufficient to confer standing. The court emphasized that property owners need not file administrative claims with Colorado before suing for just compensation under the Takings Clause. However, the appellate court affirmed the district court's dismissal of the plaintiffs' equitable claims, as § 1983 provides an adequate remedy for obtaining just compensation.The Tenth Circuit reversed the district court's dismissal of the plaintiffs' damages claims and remanded the case for further proceedings consistent with its opinion. View "Knellinger v. Young" on Justia Law

Luis Gutierrez was arrested in May 2020 after New Mexico state officers found a loaded, stolen pistol in his motel room. He was charged with both federal and state crimes. In October 2021, he pleaded guilty to two counts of aggravated assault with a deadly weapon against a household member in state court and was sentenced to two years of imprisonment. He was released on May 5, 2022. Gutierrez was indicted for being a felon in possession of a firearm on August 11, 2020, while in state custody. However, he was not notified of the federal charge until his release from state custody.The United States District Court for the District of New Mexico denied Gutierrez’s motion to dismiss the indictment for violation of his Sixth Amendment right to a speedy trial. The court found that the delay in the federal case was justified due to complications caused by the COVID-19 pandemic and that Gutierrez failed to show any prejudice caused by the delay. Gutierrez then pleaded guilty to the federal charge, reserving the right to appeal the denial of his Sixth Amendment claim.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court applied the multi-factor test from Barker v. Wingo and found that while the length of the delay and Gutierrez’s assertion of his right favored him, the reason for the delay was neutral, and he failed to show any prejudice. The court held that the Speedy Trial clause does not apply to postconviction sentencing and that Gutierrez’s alleged harm at sentencing was not cognizable under the Sixth Amendment. The court affirmed the district court’s decision and found that Gutierrez’s appellate waiver was enforceable, barring his challenge to the application of U.S.S.G. § 5K2.6 to enhance his sentence. View "United States v. Gutierrez" on Justia Law

Gary Jordan, the defendant, pled guilty to armed bank robbery and other crimes, receiving a thirty-year prison sentence. After his plea, he discovered that prosecutors had recorded his attorney-client meetings before he entered his plea. Although the prosecutors claimed they did not watch the recordings, Jordan moved to vacate his guilty plea, arguing that the prosecutors' actions rendered his plea unconstitutionally unknowing and involuntary.The United States District Court for the District of Kansas denied Jordan's motion, stating that he could only challenge his guilty plea through an ineffective assistance of counsel claim, as the alleged unconstitutional conduct occurred before the plea. Jordan did not raise a claim of prejudice or ineffective assistance of counsel, relying solely on the structural-error theory from Shillinger v. Haworth. The district court concluded that Jordan could not prevail on this basis.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, holding that under Tollett v. Henderson, a defendant who has pled guilty cannot raise independent claims of constitutional violations that occurred before the plea. Instead, the defendant must show that the plea was not knowing and voluntary due to ineffective assistance of counsel, unless the plea was induced by threats, misrepresentations, or improper prosecutorial promises. The court found that Jordan's challenge failed because he did not pursue an ineffective assistance of counsel claim and relied solely on the now-overruled structural-error rule from Shillinger. The Tenth Circuit affirmed the district court's denial of Jordan's motion to vacate his guilty plea. View "United States v. Jordan" on Justia Law

The case involves Plaintiff Tyler Luethje, who filed a § 1983 complaint against Defendants Travis Kyle and Scott Kelly, both employed by the Douglas County Sheriff’s Office. On February 11, 2022, the deputies responded to a 911 call about a broken window at Luethje’s residence. Upon arrival, they sent a police canine, Sig, into the house without announcing themselves. Sig bit Luethje, who was in bed, and continued to bite him while the deputies questioned him. Luethje was then handcuffed and taken to the hospital. He was not charged with any crime.The United States District Court for the District of Colorado reviewed the case and denied the deputies' motion to dismiss based on qualified immunity. The court held that the deputies violated Luethje’s Fourth Amendment rights regarding unlawful entry and search, unlawful arrest, and excessive force. The court found that the law clearly established these rights.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that the deputies were not entitled to qualified immunity. The court held that the deputies’ actions violated Luethje’s constitutional rights and that these rights were clearly established. The court found that the deputies lacked an objectively reasonable belief in an ongoing emergency to justify the warrantless entry, did not have probable cause for the arrest, and used excessive force by allowing the canine to continue biting Luethje after he was subdued. View "Luethje v. Kyle" on Justia Law

The case involves the Consumer Product Safety Commission's (CPSC) second attempt to regulate small, high-powered magnets that pose serious health risks to children when ingested. These magnets, used in various consumer products like jewelry and puzzles, can cause severe internal injuries or death if swallowed. The CPSC's first attempt to regulate these magnets was struck down by the Tenth Circuit in 2016 due to inadequate data supporting the rule. The CPSC then revised its approach and issued a new rule, which is now being challenged by industry groups.The industry groups petitioned for review of the CPSC's new rule, arguing that the CPSC's cost-benefit analysis was flawed and that the rule was promulgated by an unconstitutionally structured agency. They contended that the CPSC's data on magnet ingestions was unreliable, that the CPSC failed to consider the impact of its own enforcement efforts, and that the rule was underinclusive and arbitrary. They also argued that existing voluntary standards were sufficient to address the risks posed by the magnets.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the CPSC's rule was supported by substantial evidence, noting that the CPSC had adequately addressed the shortcomings identified in the previous case and had conducted a thorough cost-benefit analysis. The court also held that the CPSC's structure, which includes removal protections for its commissioners, was constitutional, reaffirming its previous decision in Leachco, Inc. v. Consumer Product Safety Commission.The Tenth Circuit denied the petition for review, upholding the CPSC's rule regulating small, high-powered magnets. The court concluded that the rule was necessary to address the significant health risks posed by these magnets and that the CPSC had acted within its authority in promulgating the rule. View "Magnetsafety.org v. Consumer Product Safety Commission" on Justia Law

Amelia Baca, a 75-year-old woman with dementia, was fatally shot by Officer Jared Cosper in Las Cruces, New Mexico. On April 16, 2022, Baca's daughter called 911, reporting that Baca had become aggressive and threatened to kill her and her daughter. Officer Cosper, who was nearby, responded to the call. Upon arrival, he saw Baca holding knives and ordered her to drop them. Baca did not comply and took two slow steps towards Cosper, who then shot her twice, resulting in her death.The Estate of Amelia Baca filed a complaint in the United States District Court for the District of New Mexico, alleging that Officer Cosper used excessive force in violation of the Fourth Amendment. The district court granted summary judgment in favor of Cosper on qualified immunity grounds, concluding that the Estate had not raised a genuine dispute of material fact regarding Cosper's perception of an immediate threat.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court concluded that the district court erred in granting summary judgment. Viewing the evidence in the light most favorable to the Estate, the Tenth Circuit determined that a reasonable jury could find a Fourth Amendment excessive-force violation. The court also held that such a violation was clearly established under controlling law at the time of the shooting. Consequently, the Tenth Circuit reversed the district court's grant of summary judgment and remanded the case for further proceedings. View "Baca v. Cosper" on Justia Law

Petitioners Jason Fabrizius and Fabrizius Livestock LLC sought review of a USDA Judicial Officer's order that denied their appeal of two USDA ALJ orders. The ALJ found Fabrizius Livestock responsible for ensuring animals transported interstate had required documentation and issued a $210,000 fine against the company. Fabrizius Livestock, a Colorado corporation dealing in horses, often sold horses intended for slaughter and kept them in conditions that made them vulnerable to disease. The company sold horses across state lines without the necessary documentation, including ICVIs and EIA test results.The ALJ found Fabrizius liable for violations of the CTESA and AHPA regulations, including transporting horses without owner/shipper certificates and selling horses without ICVIs. The ALJ imposed a $210,000 fine, which included penalties for each violation. Fabrizius appealed to a USDA Judicial Officer, arguing that the regulation was unconstitutionally vague, they were not among the "persons responsible," they lacked adequate notice, the fine was arbitrary and capricious, and the fine was excessive under the Eighth Amendment. The Judicial Officer rejected these arguments and affirmed the ALJ's orders.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that the regulation was not unconstitutionally vague and provided adequate notice. The court found that the term "persons responsible" reasonably included sellers like Fabrizius. The court also held that the $200,000 fine for the AHPA violations was not arbitrary or capricious, as the Judicial Officer had considered all relevant factors. Finally, the court found that the fine was not excessive under the Eighth Amendment, given the gravity of the violations and the potential harm to the equine industry. The court denied the petition for review. View "Fabrizius v. United States Department of Agriculture" on Justia Law

A transgender woman, Darlene Griffith, filed a civil rights lawsuit regarding her pretrial confinement at the El Paso County Jail in Colorado. She alleged that the jail's policies, which assigned housing based on genitalia and denied her access to female clothing and products, violated her constitutional rights and the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The district court dismissed her complaint under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), leading to this appeal.The United States District Court for the District of Colorado dismissed Ms. Griffith’s complaint, concluding that she failed to state a plausible claim for relief. The court applied rational-basis review to her Equal Protection claim, finding that transgender individuals are not a protected class under existing precedent. The court also dismissed her ADA and Rehabilitation Act claims for lack of subject matter jurisdiction, as she did not properly name the county as a defendant according to state law requirements.The United States Court of Appeals for the Tenth Circuit reviewed the case and concluded that remand was required for some of Ms. Griffith’s claims. The court reversed and remanded for further proceedings on her Fourteenth Amendment Equal Protection claim against Sheriff Elder in his official capacity, her Fourth and Fourteenth Amendment cross-gender search claims against Sheriff Elder in his official capacity, and her Fourth Amendment abusive search claim against Deputy Mustapick. The court vacated the district court’s order dismissing Ms. Griffith’s ADA and Rehabilitation Act claims under Rule 12(b)(6) because those claims were dismissed without prejudice for lack of subject matter jurisdiction under Rule 12(b)(1), and that ruling was unchallenged on appeal. The court otherwise affirmed the district court’s dismissal of the remaining claims. View "Griffith v. El Paso County, Colorado" on Justia Law

Defendant Alexander Pauler was convicted of possessing a firearm after having previously been convicted of a misdemeanor crime of domestic violence. The district court denied Defendant’s motion to dismiss the indictment for failure to state an offense, holding that Defendant violated the applicable statute because he possessed a firearm in 2014 after having been convicted in 2009 of violating a Wichita, Kansas municipal domestic battery ordinance by punching his girlfriend. The sole issue for the Tenth Circuit's review was whether a misdemeanor violation of a municipal ordinance qualified as a “misdemeanor under . . . State . . . law” when viewed in the context of a statutory scheme that clearly and consistently differentiated between state and local governments and between state statutes and municipal ordinances. Applying well-established principles of statutory interpretation, the Tenth Circuit held that it did not, and the Court accordingly reversed and remanded for the district court to vacate Defendant’s federal conviction. View "United States v. Pauler" on Justia Law

The test applied in evaluating the constitutionality of a reasonable doubt jury instruction instruction is not whether a court finds it exemplary. Rather, the proper inquiry requires a court to consider the instructions in their entirety and ask whether a “reasonable likelihood” exists that the jury “understood the instructions to allow conviction based on proof insufficient to meet the [reasonable doubt] standard.” The Government charged Defendant Ishmael Petty with assaulting three employees at the federal correctional facility in Florence, Colorado. At Defendant’s trial, the district court tendered the jury a reasonable doubt instruction that tracked verbatim the Tenth Circuit’s Pattern Jury Instruction on reasonable doubt. The district court overruled Defendant’s objections to the instruction, and a jury found Defendant guilty. Defendant contended the district court’s instruction diluted the Government’s burden of proof contrary to his Fifth Amendment right to due process and his Sixth Amendment right to a fair trial. After review, the Tenth Circuit rejected Defendant’s argument that the reasonable doubt instruction as tendered was unconstitutional, and affirmed. View "United States v. Petty" on Justia Law