Justia Constitutional Law Opinion Summaries

Defendant-appellant Kelvin Hill boarded an east-bound Amtrak train in Los Angeles, California. The train stopped in Albuquerque, New Mexico, and was boarded by Agent Kevin Small of the Drug Enforcement Agency (“DEA”) to conduct drug-interdiction activities. Small proceeded to a common luggage area, noticing a black and white “Coogi” brand suitcase with no name tag. He removed the Coogi suitcase from the common luggage area; carried it to the passenger area; and rolled it down the center aisle of the coach, asking each passenger if the bag belonged to him. All passengers present in the coach, including defendant, denied ownership of the bag. Deeming it abandoned, Small searched the bag, finding a large quantity of cocaine and items of clothing linking the bag to defendant. A grand jury charged defendant with possessing with intent to distribute at least 500 grams of cocaine. Defendant moved to suppress, arguing that Small’s taking the Coogi bag from the common storage area and moving it about the coach amounted to an illegal seizure, rendering defendant’s subsequent abandonment of the bag legally invalid. The district court denied the motion. Defendant’s appeal of the denial of his suppression motion framed a particularly narrow legal question for the Tenth Circuit’s review: did Small’s actions in removing defendant’s bag from the train’s common luggage area and carrying it through the coach as he questioned passengers constitute a seizure of the bag? The Tenth Circuit answered in the affirmative: Small’s actions amounted to a “meaningful interference with [Hill’s] possessory interests in” the Coogi bag. View "United States v. Hill" on Justia Law

Defendant Thomas Rodella, the former sheriff of Rio Arriba County, New Mexico, was convicted by a jury of one count of depriving a person of his constitutional right to be free of unreasonable force and seizure, resulting in bodily injury and including the use of a dangerous weapon. The conviction stems from a “road rage” incident in 2014 in which Michael Tafoya, outraged he was being tailgated by a Jeep containing Rodella, “flipped off” the driver, Rodella’s son Thomas Junior. According to Tafoya, both men started walking towards his Mazda in an aggressive fashion while simultaneously telling Tafoya to “come on.” At no point, according to Tafoya, did Rodella flash a badge or otherwise identify himself as a law enforcement officer. Tafoya, unaware of either man’s identity and believing that the two men wanted to fight him, sped off in his vehicle. Rodella and his son got back in their Jeep and, with Rodella Jr. again driving, began to follow Tafoya. In an attempt to elude the Jeep, Tafoya’s vehicle got stuck on a metal pole. The Jeep caught up with Tafoya. Rodella and Tafoya struggled before additional deputies arrived on the scene. Tafoya was arrested and jailed before being bailed out by his grandfather. The criminal charges were ultimately dismissed. Tafoya recounted this experience to the FBI. For violating Tafoya’s Constitutional rights, Rodella was sentenced to a total term of 121 months. On appeal, Rodella challenged his convictions on several grounds. But finding no error, the Tenth Circuit affirmed the convictions. View "United States v. Rodella" on Justia Law

The issue on appeal before the Tenth Circuit in this matter was whether appellant Jonathan Madrid’s prior conviction for statutory rape in Texas qualified as a “crime of violence” under the United States Sentencing Guidelines. In light of “Johnson v. United States,” (135 S. Ct. 2551 (2015), the Tenth Circuit held that it did not. Accordingly, the Court vacated Madrid’s sentences as a career offender under the U.S. Sentencing Guidelines, and remanded for resentencing. View "United States v. Madrid" on Justia Law