Justia Constitutional Law Opinion Summaries

Martin’s state conviction became “final” in April 2002, triggering the one-year limitations period on state prisoners seeking federal habeas corpus relief, 28 U.S.C. 2244(d)(1). The clock ran for 193 days, until October 21, 2002, when Martin filed a petition for state post-conviction relief (PCR). The clock was paused until June 14, 2004, the last day on which Martin could have appealed (but did not) the trial court’s denial of his petition—and expired 172 days later, on December 3, 2004. In June 2015, Martin filed a petition seeking federal habeas relief. The state appellate court had accepted Martin’s April 2012 motion for leave to appeal “as within time” the denial of his 2002 PCR petition; he argued that the ruling retroactively tolled the limitations period. Martin essentially argued that a “properly filed” PCR petition is “pending” under section 2244(d)(2) for the period between the expiration of time under state law in which a prisoner could have timely appealed the denial of a PCR petition, and the prisoner’s submission of a motion for leave to file a PCR appeal “as within time.”.The Third Circuit affirmed the dismissal of his petition as untimely. Section 4 2244(d)(2)’s tolling mechanism looks forward, not backward, and a state court’s acceptance of an appeal “as within time” does not rewind the one-year clock. View "Martin v. Administrator New Jersey State Prison" on Justia Law

The Halls sued Millersville University under Title IX, 20 U.S.C. 1681, after their daughter, Karlie, was murdered in her dorm room by her boyfriend, Orrostieta. Orrostieta had previously been removed from campus at Karlie’s request and, on the night of the murder, a resident assistant heard Karlie scream but did not follow up. Despite finding genuine issues of material fact, the district court granted Millersville summary judgment, holding that Millersville lacked notice it could face liability under Title IX for the actions of a non-student guest.The Third Circuit reversed. Millersville had adequate notice it could be liable under Title IX for its deliberate indifference to known sexual harassment perpetrated by a non-student guest. Title IX’s plain terms notify federal funding recipients that they may face monetary liability for intentional violations of the statute; it is an intentional violation of Title IX’s terms for a funding recipient to act with deliberate indifference to known sexual harassment where the recipient exercises substantial control over the context in which the harassment occurs and the harasser, even if they are a third party. Millersville’s own Title IX policy thus contemplated Title IX liability could result from the actions of third parties such as “visitors” like Orrostieta. The court agreed that factual disputes preclude summary judgment. View "Hall v. Millersville University" on Justia Law

Taylor, on probation, was found to be in possession of drugs, a firearm, and cash, and moved to suppress the evidence. Before the scheduled hearing, his court-appointed lawyer (Carey) moved to withdraw because Taylor would not permit him to withdraw pro se motions in which Taylor refused to “accept that the laws of the United States govern him.” Taylor contended that “the United States is not a country. It is a corporation.” The court denied Carey’s motion Taylor filed more documents. Carey again moved to withdraw, explaining that Taylor “desires to proceed pro se.” Carey acknowledged substantial concerns about Taylor’s legal competency.” Taylor acknowledged that he “d[id not] understand law” and requested that the court “deal with [him] commonly.” The court stated that his pro se filings were rambling and not founded on any legal principles. Taylor repeatedly attempted to challenge the jurisdiction of the court.The court denied his request to represent himself, denied his motion to suppress, and, later (twice) appointed new counsel. Taylor was convicted and sentenced to 264 months’ imprisonment. The Third Circuit vacated. The Sixth Amendment guarantees a criminal defendant the right to self-representation if he “knowingly and intelligently” waives his right to counsel. When Taylor invoked that right, the district court bore “the weighty responsibility of conducting a sufficiently penetrating inquiry to satisfy itself that” Taylor could make such a waiver. The court did not complete the requisite inquiry. View "United States v. Taylor" on Justia Law

Officer Staffer saw Jefferson traveling at high speed with his car alarm blaring. Staffer, suspecting the vehicle was stolen, attempted a traffic stop. Jefferson was driving with an open container of alcohol. Fearing a probation violation, Jefferson did not stop. Officer Lias joined the pursuit after hearing radio dispatches, only aware that Jefferson was driving a possibly stolen vehicle. Although other officers observed Jefferson traveling at high speeds, running red lights, ignoring police signals to pull over, and driving close to other vehicles, Lias did not personally witness Jefferson doing so. Jefferson hit a fire hydrant. Officers surrounded Jefferson’s vehicle. Jefferson reversed, striking a police vehicle before backing into an intersection. Lias arrived as Jefferson was driving away. Lias claims that he discharged his firearm because he feared for his own safety and others around him. Jefferson was struck in his forearm, fracturing his bones, but drove away. Jefferson later pled guilty to second-degree eluding.The district court rejected Jefferson’s 42 U.S.C. 1983 suit, finding Lias entitled to qualified immunity. The Third Circuit reversed. A jury should make factual determinations regarding Lias’s decision to employ deadly force against Jefferson. Video footage makes clear that neither Lias nor anyone else was in danger of being struck by Jefferson. It is clearly established that an otherwise non-threatening individual engaged in vehicular flight is entitled to be free from being subjected to deadly force if it is unreasonable for an officer to believe his or others’ lives are in immediate jeopardy. Jefferson’s second-degree eluding conviction does not preclude his excessive force claim. View "Jefferson v. Lias" on Justia Law

Maple’s girlfriend, Vinsek, told him that Teck had tried to rape her. Later, they found her apartment ransacked and blamed Teck and his friend, Altman. Maple tracked them down at a bar, where he brawled with them. Vinsek called the police to report the burglary. Maple stated, “maybe I’ll just handle it my way.” Hours later, Maple found Teck and Altman and shot at them, killing Teck. Detectives went to talk to Maple and Vinsek, identified themselves as police, and stated that Maple was not under arrest but asked to talk with him about the murder. Maple agreed. Officers failed to read his Miranda rights. After about an hour, Maple confessed. He was then arrested and read Miranda warnings. He waived those rights and confessed again, on tape. At trial, Maple confessed again, claiming he was drunk at the time. The prosecution produced a “mountain of evidence” that proved his intent. Altman and three witnesses testified to the shooting. Maple was convicted of first-degree murder and attempted murder.The Third Circuit reversed the district court’s grant of habeas relief. E Even if the trial court should have suppressed his confession before Miranda warnings, any error was harmless; other evidence overwhelmingly incriminated him. Maple doubtless would have been convicted of first-degree murder of Teck and trying to murder Altman. View "Maple v. Superintendent Albion SCI" on Justia Law

Dennis was convicted of a 1991 robbery and first-degree murder and was sentenced to death. In 2013, the district court granted Dennis’s habeas petition, vacated his conviction, and ordered a new trial on all charges, finding that Dennis’s prosecutors withheld material impeachment evidence. The Third Circuit, en banc, affirmed. On remand, Dennis accepted a deal. In exchange for a time-served sentence, he pleaded nolo contendere to reduced charges. Dennis then filed suit under 42 U.S.C. 1983, alleging fabrication of evidence and deliberate deception, civil rights conspiracy, failure to intervene, supervisory liability, and municipal liability.The Third Circuit affirmed the denial of a motion to dismiss based on qualified immunity. Dennis has alleged the violation of his due process rights clearly established at the time of the detective’s conduct on which the claims are based. Dennis’s deliberate deception claim not only alleges that the detectives withheld exculpatory and impeachment evidence that would have supported his alibi and defense, but that they also failed to correct testimony they knew was false and concealed from the defense the evidence that revealed that trial testimony as false. The court dismissed, for lack of jurisdiction on interlocutory appeal, consideration of a ruling that the Heck bar does not apply. View "Dennis v. City of Philadelphia" on Justia Law

Garrett, a New Jersey prisoner, has commenced at least 10 civil actions against prison officials, state officials, and the United States, avoiding paying filing fees for these lawsuits by proceeding in forma pauperis. All his lawsuits have been unsuccessful. Garrett appealed the dismissal of his latest lawsuit, which concerns his risk of contracting COVID-19 and speedy trial issues.The Third Circuit affirmed, citing the three-strikes rule, 28 U.S.C. 1915(g). Noting the division among circuit courts, the court stated that a suit dismissed under “Heck” is dismissed for failure to state a claim and counts as a strike. In Heck, the Supreme Court held that a prisoner lacks a “cause of action” under section 1983 if the prisoner is challenging an “allegedly unconstitutional conviction or imprisonment” before having the conviction or sentence overturned (the favorable-termination requirement). Garrett has three prior suits dismissed for failure to meet Heck’s “favorable-termination” requirement. Garrett has not shown that he is “under imminent danger of serious physical injury,” 28 U.S.C. 1915(g). View "Garrett v. Murphy" on Justia Law

Delaware’s Unclaimed Property Law (UPL), Del. Code tit. 12 section 1101, allows the state to escheat certain types of unclaimed property held by businesses chartered in the state, if the particular business holding the property is not the owner of it, and if there has been no contact with the owner for a specified period of time. Delaware initiated an audit of Siemens, which is incorporated under Delaware law. After a near-decade-long audit process, Siemens sued the state, challenging the constitutionality of the audit and arguing that Delaware’s actions conflict with federal common law limiting the scope of any state’s escheatment authority.The district court dismissed most of Siemens’s claims and denied its motion for a preliminary injunction on the sole surviving claim, which alleged a violation of procedural due process. The Third Circuit vacated. The district court erred in concluding that Siemens failed to show irreparable harm based on its procedural due process claim, and in dismissing Siemens’s federal preemption claim as unripe. In considering the audit, the district court paid insufficient heed to a holder’s payment obligations with respect to interest and penalties under the statute and the consequences of not meeting those obligations. The court affirmed the dismissal of Siemens’s expedited-audit procedural due process claim. View "Siemens USA Holdings Inc. v. Geisenberger" on Justia Law

Argueta, a 20-year-old citizen of Honduras, entered the U.S. in 1998. In 2007, Argueta had an altercation with a former employer over the late payment of wages. Convicted of aggravated assault, he was sentenced to 96 months’ imprisonment. In removal proceedings, he sought asylum, withholding of removal, and protection under the Convention Against Torture. Argueta has been in ICE custody since December 2014 and has been transferred at least 15 times. His removal proceedings remain pending, Argueta unsuccessfully requested bond.In 2019, Argueta sought habeas corpus relief, 28 U.S.C. 2241. The district court denied Argueta’s petition without prejudice, reasoning that the statutory scheme under which Argueta was detained rendered him ineligible for immediate release. In April 2020, Argueta, who by then had been transferred to a detention facility outside of New Jersey, moved to reopen. The district court denied Argueta’s motion, finding that the motion raised new claims and constituted a new habeas petition over which it lacked jurisdiction because of ICE’s transfer of Argueta.The Third Circuit reversed. In referring to Covid-19 and to a change in the governing statutory scheme, Argueta did not raise new claims; his motion is a Rule 60(b)(6) motion. After a district court acquires jurisdiction over an ICE detainee’s section 2241 petition for relief from continued detention, the transfer of the detainee outside of the court’s territorial jurisdiction does not strip that court of jurisdiction to entertain a Rule 60(b) motion. View "Anariba v. Director Hudson County Correctional Center" on Justia Law

Since his 2012 federal conviction, Garrett has brought at least 10 federal civil suits. In this suit, Garrett sued New Jersey's Governor and another official under 42 U.S.C. 1983, alleging due process and “speedy trial” violations. The district court granted Garrett in forma pauperis status. The court screened Garrett’s complaint under the Prison Litigation Reform Act (PLRA), 28 U.S.C. 1915(e)(2)(B)(i)–(iii), concluded that Garrett’s due process claim “is a string of nonsequiturs" with no facts to support any claim, and dismissed Garrett’s speedy trial claim as properly raised only in a habeas action. The Third Circuit advised Garrett to seek a final judgment to perfect his right to appeal. The district court obliged, dismissing Garrett’s complaint “with prejudice.” Garrett never filed a new or amended notice of appeal in the district court, and a notice of appeal must be filed within 30 days “after the entry” of judgment, 28 U.S.C. 2107(a).The Third Circuit then denied Garrett’s motion to proceed in forma pauperis; he must pay filing fees under the three-strikes rule. 28 U.S.C. 1915(g). A suit dismissed under “Heck” is dismissed for failure to state a claim and counts as a strike. In Heck, the Supreme Court held that a prisoner lacks a section 1983 “cause of action” if the prisoner is challenging an “allegedly unconstitutional conviction or imprisonment” before having the conviction or sentence overturned. Garrett has not shown imminent danger or serious physical injury. View "Garrett v. Murphy" on Justia Law