Justia Constitutional Law Opinion Summaries

A man named Douglas Bradford was convicted of first-degree murder in a "cold case" that was solved 35 years after the crime occurred. The case was based entirely on circumstantial evidence. The trial judge excluded exculpatory evidence of another viable suspect, Joseph Giarrusso, who had dinner with the victim on the evening of the murder and was the last known person to see her alive.The California Court of Appeal upheld the conviction, ruling that the exclusion of the evidence was consistent with the rules of evidence and therefore did not violate the Constitution. The court also found that the evidence related to Giarrusso was not sufficient to raise a reasonable doubt about Bradford's guilt.Bradford appealed to the United States Court of Appeals for the Ninth Circuit, arguing that the exclusion of the evidence violated his constitutional right to present a defense. The Ninth Circuit reversed the lower court's decision, finding that the exclusion of the evidence was both contrary to and an unreasonable application of clearly established Supreme Court law. The court also found that the decision was based on an unreasonable determination of facts. The court remanded the case with instructions to grant a conditional writ of habeas corpus, ordering Bradford's release unless the state of California notifies the district court within thirty days of the issuance of the court’s mandate that it intends to retry Bradford without excluding the evidence pertaining to Giarrusso, and commences Bradford’s retrial within seventy days of issuance of the mandate. View "BRADFORD V. PARAMO" on Justia Law

Jeremy Travis Payne, a California parolee, was arrested and charged with possession with intent to distribute fentanyl, fluorofentanyl, and cocaine. The charges stemmed from evidence obtained from a house in Palm Desert, California, and from Payne's cell phone, which was unlocked by police using Payne's thumbprint during a traffic stop. Payne moved to suppress the evidence, arguing that the search of his phone and the house violated his Fourth and Fifth Amendment rights.The district court denied Payne's motion. It found that the search of Payne's phone was reasonable under the Fourth Amendment given Payne's parole status and the conditions of his parole, which allowed for suspicionless searches of his property. The court also determined that the use of Payne's thumbprint to unlock his phone was not testimonial and therefore did not violate his Fifth Amendment privilege against self-incrimination.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the search of Payne's phone did not violate the Fourth Amendment. It found that the search was authorized under a general search condition of Payne's parole, which allowed for the suspicionless search of any property under Payne's control. The court also held that the search of Payne's phone was not unreasonable under California law, which prohibits arbitrary, capricious, or harassing searches.Regarding the Fifth Amendment claim, the court held that the use of Payne's thumbprint to unlock his phone was not testimonial because it required no cognitive exertion. Therefore, the Fifth Amendment did not apply.Finally, the court held that there was sufficient probable cause to support the issuance of a search warrant for the house in Palm Desert, California, without regard to observations made during a challenged protective sweep of the house. View "USA V. PAYNE" on Justia Law

In this case, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision to deny absolute and qualified immunity to two social workers, Gloria Vazquez and Mirta Johnson, in a case brought against them by Sydney Rieman and her child, K.B. The plaintiffs alleged that the defendants violated their Fourth and Fourteenth Amendment rights by (1) failing to provide them with notice of a juvenile detention hearing where the County’s Child and Family Services sought custody of K.B., and (2) providing false information to the Juvenile Court about why Ms. Rieman was not noticed for the hearing.The court rejected the defendants' claim that they were entitled to absolute immunity for actions taken in their quasi-prosecutorial role as social workers. The court determined that the failure to provide notice of the hearing and the provision of false information to the Juvenile Court were not similar to discretionary decisions about whether to prosecute. Therefore, absolute immunity did not apply.The court also held that the defendants were not entitled to qualified immunity from suit for failing to provide notice of the hearing and for providing false information to the Juvenile Court. The court affirmed that Ms. Rieman had a due process right to such notice and that this right was clearly established. It was also clear that providing false information to the court constituted judicial deception. The court concluded that a reasonable social worker in the defendants' position would have understood that their actions were violating the plaintiffs' constitutional rights. View "RIEMAN V. VAZQUEZ" on Justia Law

In this case, Markanthony Sapalasan was arrested and his backpack was searched. After the arrest, his backpack was taken into police custody, and Sapalasan was taken to the police station for questioning regarding a potential murder. After questioning, Sapalasan was released, but his backpack remained in police custody. Approximately six hours later, Officer Tae Yoon conducted an inventory search of the backpack and discovered methamphetamine. Sapalasan was subsequently convicted of two drug felonies and appealed the conviction, claiming that the search of his backpack violated his Fourth Amendment rights.The United States Court of Appeals for the Ninth Circuit held that the police may constitutionally conduct an inventory search of belongings when the property is lawfully retained and the search is done in compliance with police regulations, even after the individual has been released. The court found that the lawfulness of the initial separation of Sapalasan from his backpack was unchallenged, so the justification of an inventory search did not depend on whether he was headed to jail. The court also determined that Officer Yoon's inventory search substantially complied with the police department's policy. Therefore, the court affirmed the lower court's denial of Sapalasan's motion to suppress the methamphetamine found during the search. View "USA V. SAPALASAN" on Justia Law

In a case before the United States Court of Appeals for the Ninth Circuit, the petitioner, Terry Eugene Iversen, appealed the district court’s denial of his 28 U.S.C. § 2254 petition for a writ of habeas corpus. Iversen had been sentenced to life without parole (LWOP) for the crime of public indecency under Oregon’s sex offender recidivism statute due to his extensive criminal history, which included prior convictions for public indecency, rape, and sodomy. Iversen argued that the LWOP sentence was grossly disproportionate to his offense, in violation of the Eighth Amendment’s prohibition against cruel and unusual punishment.The court, applying the demanding standard required by the Antiterrorism and Effective Death Penalty Act, upheld the district court’s decision. The court found that the Oregon state court’s decision concerning Iversen’s sentence was not contrary to Supreme Court’s Eighth Amendment jurisprudence. The court considered Iversen’s extensive history of adult felony recidivism, his mental health record, his failed opportunities to reform, and the fact that he remained dangerous to others. The court also noted Oregon’s public-safety interest in incapacitating and deterring recidivist felons like Iversen.The court concluded that Iversen’s sentence did not raise an inference of gross disproportionality given the gravity of his offense and criminal history. Therefore, the court affirmed the district court’s denial of Iversen’s habeas petition. View "Iversen v. Pedro" on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the constitutionality of a pretrial release condition that temporarily barred two defendants from possessing firearms pending trial. The defendants, Jesus Perez-Garcia and John Thomas Fencl, were charged with various felony offenses. The district courts imposed a condition barring them from possessing firearms as part of their pretrial release, arguing that the restriction was necessary for public safety. The defendants appealed, arguing that this condition infringed on their Second Amendment rights.The Ninth Circuit disagreed, finding that the firearm condition was constitutional. The court reasoned that the Bail Reform Act of 1984's firearm condition on pretrial release is consistent with how courts have historically balanced the constitutional rights of pretrial detainees with public safety considerations. The court also pointed out that the nation has a long history of temporarily disarming criminal defendants facing serious charges and those deemed dangerous or unwilling to follow the law. Therefore, the court held that the temporary disarmament of the defendants was justified by this historical tradition. View "United States v. Garcia" on Justia Law

In this case, a group of individual donors and two independent-expenditure organizations challenged certain campaign finance regulations enacted in Alaska after voters passed Ballot Measure 2, aimed at shedding light on "dark money" in the state's elections. The plaintiffs argued that these regulations violated their First Amendment rights. The two regulations at issue were: (1) a requirement for individual donors to report contributions exceeding an annual aggregate of $2,000 to an entity making expenditures for a candidate in prior or current election cycles, and (2) a requirement for political advertisements to disclose certain identifying information about donors in any communications intended to influence the election of a candidate.Applying exacting scrutiny, the United States Court of Appeals for the Ninth Circuit held that both regulations were substantially related and narrowly tailored to the government's interest in providing the electorate with accurate, real-time information. This interest was deemed sufficiently important in the campaign finance context. The court dismissed the plaintiffs' arguments that the reporting requirement was duplicative of existing criminal laws and overly burdensome. It also rejected their contention that the disclaimer requirement for political advertisements was unconstitutionally discriminatory against out-of-state speakers.The court concluded that the plaintiffs had not shown that the district court abused its discretion in denying their motion for a preliminary injunction. Therefore, the district court's denial of the preliminary injunction was affirmed. The court, however, did not consider the remaining factors for a preliminary injunction as they were unnecessary for this holding. View "SMITH V. HELZER" on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the district court's denial of a federal habeas corpus petition by Raymond Anthony Lewis, who was sentenced to death in 1991 after a California jury convicted him of the first-degree murder of Sandra Simms. Lewis argued that the state trial court's admission of his juvenile confession to a prior murder was unconstitutional and that his trial counsel was ineffective in failing to present evidence of his innocence of the prior murder. The court concluded that the California Supreme Court's affirmance of the trial court's admission of Lewis's juvenile confession was not contrary to or an unreasonable application of federal law and that Lewis's trial counsel’s litigation of the evidence of the prior murder did not fall below an objective standard of reasonableness.Lewis also contended that his trial counsel was constitutionally ineffective by failing to investigate, develop, and present certain mitigating evidence during the penalty phase of the trial. The court found that Lewis failed to show that his trial counsel’s performance fell below an objectively reasonable standard. His counsel made reasonable strategic decisions to ask for the jury’s mercy and to appeal to any lingering doubt the jurors may have had about Lewis’s guilt. The court also concluded that much of the evidence Lewis argued his trial counsel was ineffective in not introducing would have been cumulative of evidence his counsel did introduce.Lewis also raised uncertified claims on appeal, but the court denied a certificate of appealability on these claims. View "LEWIS V. ANDES" on Justia Law

The case involves Peridot Tree, Inc. and Kenneth Gay, who filed suit against the City of Sacramento and Davina Smith, alleging that the city's requirement for individuals applying for permits to operate storefront marijuana dispensaries to be Sacramento residents violated the dormant Commerce Clause of the federal Constitution. The clause prevents states from discriminating against interstate commerce.The District Court abstained from exercising jurisdiction over the claim due to the conflict between state and federal law regulating marijuana use and distribution, and directed the plaintiffs to seek relief in California state court. The plaintiffs appealed this decision.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision to abstain from exercising jurisdiction. The court found that abstention was not warranted under any of the established abstention doctrines, including the Pullman, Burford, Thibodaux, and Colorado River doctrines. The court reasoned that the case did not present "exceptional circumstances" warranting abstention, and that the district court effectively imposed an exhaustion requirement on the plaintiffs by requiring them to first identify and litigate potential state-law claims before raising their federal constitutional concerns.The case was remanded back to the lower court for further proceedings on the dormant Commerce Clause claim. View "PERIDOT TREE, INC. V. CITY OF SACRAMENTO" on Justia Law

The United States Court of Appeals for the Ninth Circuit ruled in favor of the United States in a dispute over the planned transfer of a site, Oak Flat, of spiritual importance to the Apache tribe to a mining company, Resolution Copper. The nonprofit Apache Stronghold had sought to block the transfer, arguing that it would infrely violate its members’ rights under the First Amendment, the Religious Freedom Restoration Act ("RFRA"), and an 1852 treaty between the U.S. and the Apaches. The court, however, disagreed.Applying the precedent set in Lyng v. Northwest Indian Cemetery Protective Association, the court held that while the transfer of Oak Flat would significantly interfere with the Apache tribe's religious practices, it would not coerce them into acting contrary to their religious beliefs, and therefore did not violate the Free Exercise Clause of the First Amendment.Further, the court held that RFRA did not abrogate the holding in Lyng, and thus the planned land transfer did not "substantially burden" the Apache tribe's exercise of religion under RFRA.Finally, the court rejected the argument that an 1852 treaty created a trust obligation that would be violated by the transfer of Oak Flat. It interpreted the Land Transfer Act as abrogating any contrary treaty obligation. Consequently, the court held that Apache Stronghold was unlikely to succeed on the merits of any of its claims and therefore was not entitled to a preliminary injunction blocking the land transfer. View "Apache Stronghold v. United States" on Justia Law