Justia Constitutional Law Opinion Summaries

On December 21, 2022, Oklahoma City Police officers received a tip that Karen Gonzalez, who had an outstanding arrest warrant, was at a Days Inn. Officers surveilled the area and followed a car they believed she entered to a gas station. They confirmed her identity and arrested her. Jonas Tyler, who was near the car, was detained, handcuffed, and placed in a police car. Despite his compliance and lack of suspicion, officers detained him further while waiting for a K-9 unit, which eventually led to the discovery of a firearm and drugs in his car.The United States District Court for the Western District of Oklahoma denied Mr. Tyler's motion to suppress the evidence found in his car, ruling that his continued detention was reasonable. Mr. Tyler then entered a conditional guilty plea to possession of a firearm by a previously convicted felon, reserving his right to appeal the suppression ruling. He was sentenced to 84 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case and found that Mr. Tyler's continued detention after the arrest of Ms. Gonzalez was unreasonable and violated his Fourth Amendment rights. The court held that the government did not have a sufficient justification for detaining Mr. Tyler beyond the initial arrest of Ms. Gonzalez, as there was no reasonable suspicion of wrongdoing or dangerousness on his part. Consequently, the court vacated Mr. Tyler's conviction and sentence and remanded the case for further proceedings consistent with their opinion. View "United States v. Tyler" on Justia Law

The petitioner, a 67-year-old native and citizen of Guatemala, entered the United States in 1985 without admission or parole. In removal proceedings, he conceded removability but sought several forms of relief, including asylum, withholding of removal, relief under the Convention Against Torture (CAT), cancellation of removal under 8 U.S.C. § 1229b(b)(1), and relief pursuant to the Nicaraguan Adjustment and Central American Relief Act (NACARA). An immigration judge (IJ) denied all forms of relief, and the Board of Immigration Appeals (BIA) upheld the removal order in 2018. The petitioner then filed a motion to reopen proceedings, which the BIA denied in 2019.The BIA upheld the IJ's decision, concluding that the petitioner had withdrawn his asylum application, was ineligible for cancellation of removal due to a conviction for a crime involving moral turpitude, and did not merit NACARA relief. The BIA also found no sufficient indicia of incompetency to mandate remand for a competency evaluation. The petitioner then sought review of both the 2018 and 2019 BIA decisions.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court clarified its jurisdictional rules in light of recent Supreme Court decisions, concluding that it has jurisdiction over constitutional claims and questions of law, including fact-intensive mixed questions of law. The court lacks jurisdiction over purely factual findings and discretionary determinations.The Ninth Circuit held that the BIA abused its discretion by not remanding the case to the IJ for a competency determination, given the extensive evidence of the petitioner's potential incompetence. The court also found that the BIA erred in its assessment of the petitioner's fear of harm due to his mental illness, concluding that the petitioner established a reasonable likelihood of future harm if institutionalized in Guatemala. The court denied the petitioner's other claims and dismissed parts of the petition for lack of jurisdiction. The case was remanded for further proceedings consistent with the court's opinion. View "LEMUS-ESCOBAR V. BONDI" on Justia Law

This case involves a property on Maui in which Wade Brady owned a 50% interest. Beverly and James Spence obtained a default judgment against Wade and Katherine Brady in 2010, which they recorded as a lien against Wade Brady’s interest in the property. After the Bradys failed to satisfy their debt, the Spences obtained a writ of execution to sell the property. The sale was advertised by publication, and Wade Brady’s interest was sold to the Spences. At the time of the sale, Peter J. Winn and Westminster Realty, Inc. (the Winn parties) also had a recorded junior judgment lien on the property but did not receive personal notice of the sale.The Circuit Court of the Second Circuit confirmed the sale, stating it was free of all junior liens. The Winn parties later sought to execute their judgment on the property, but the circuit court denied their motion, stating they were not entitled to personal notice. The Intermediate Court of Appeals (ICA) vacated the circuit court’s order, holding that the Winn parties had a constitutionally protected property interest and were entitled to personal notice of the sale.The Supreme Court of the State of Hawai‘i reviewed the case. The court held that a recorded judgment lien under HRS § 636-3 creates a constitutionally protected property interest. The court further held that due process requires personal notice to junior judgment lienholders when the executing party knows or should know of their interest. However, the court decided that this ruling would apply prospectively only, due to the potential impact on prior and pending execution sales and the substantial prejudice to the intervenors. The court reversed the ICA’s decision to reinstate the Winn parties’ lien on the property. View "Winn v. Brady" on Justia Law

After a welfare check was requested by his fiancée, Joseph Maser was involved in a standoff with police at his suburban Iowa home. Maser had threatened suicide, fired a gun inside his house, and was reportedly intoxicated with access to firearms. Officers attempted to negotiate with Maser for nearly an hour, during which Maser became increasingly agitated and made threats. Maser exited his garage holding a rifle, ignored commands to drop the weapon, and raised the rifle outward from his body. Officer Joshua Van Brocklin, perceiving a threat, shot Maser twice in the chest. Maser survived and subsequently brought a claim under 42 U.S.C. § 1983, alleging that Officer Van Brocklin used excessive force in violation of the Fourth Amendment.Initially, Maser filed suit in state court against Officer Van Brocklin, the City of Coralville, and other officers, asserting both state and federal claims. The case was removed to the United States District Court for the Southern District of Iowa. Following a decision by the Iowa Supreme Court in Burnett v. Smith, which foreclosed excessive force claims under the Iowa Constitution, the district court granted summary judgment on those claims. The district court also granted summary judgment for Officer Van Brocklin on the federal excessive force claim, finding no constitutional violation and awarding qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of the circumstances, Officer Van Brocklin’s use of deadly force was objectively reasonable because Maser’s actions—raising a rifle outward after repeated noncompliance and threats—created an imminent threat of serious harm. The court found no genuine dispute of material fact and affirmed the district court’s grant of summary judgment, holding that Maser’s Fourth Amendment rights were not violated. View "Maser v. City of Coralville, IA" on Justia Law

Sandra Malone (Grandmother) filed a lawsuit against Salvador Galvan (Father) seeking visitation rights with ALG, the child of her deceased daughter. Father and Mother had a child, ALG, in July 2022. They regularly attended family dinners with Mother’s family, including Grandmother. After Mother’s death in an ATV accident caused by Father, Grandmother accused Father of killing Mother and supported his criminal prosecution. Father, concerned about Grandmother’s negative impact on ALG, stopped attending family dinners and discontinued visits between ALG and Grandmother, although he maintained relationships with other family members.The District Court of Albany County held a trial and granted Grandmother visitation rights. The court found that Grandmother had a significant preexisting relationship with ALG and concluded that Father’s decision to discontinue visits with Grandmother was harmful to ALG. The court awarded Grandmother visitation despite acknowledging concerns about her animosity towards Father and the potential negative impact on ALG.The Supreme Court of Wyoming reviewed the case. The court held that the district court erred in its findings. It emphasized that Grandmother needed to prove by clear and convincing evidence that Father’s decision to restrict visitation was harmful to ALG. The court found that Grandmother did not present any evidence of harm, while Father’s expert testified that visitation with Grandmother could harm ALG due to the hostile relationship between Father and Grandmother. The Supreme Court concluded that the district court violated Father’s constitutional rights as a parent by granting Grandmother visitation without sufficient evidence of harm to ALG.The Supreme Court of Wyoming reversed the district court’s decision, holding that the lower court clearly erred in finding that Grandmother established harm by clear and convincing evidence. View "Galvan v. Malone" on Justia Law

Gary Perez and Matilde Torres, members of the Lipan-Apache Native American Church, believe that certain religious services must be conducted at a specific site within Brackenridge Park in San Antonio, Texas. The City of San Antonio planned improvements to the park, including tree removal and bird deterrence, which Perez and Torres argued would destroy their sacred worship space. They sued the City, claiming violations of their religious rights under the First Amendment, the Texas Constitution, the Texas Religious Freedom Restoration Act (RFRA), and a new clause in the Texas Constitution that prohibits limiting religious services.The federal district court granted limited relief, allowing the Church access for certain ceremonies but did not enjoin the City's improvement plans. Perez appealed, and the Fifth Circuit initially affirmed the district court's decision but later withdrew its opinion and certified a question to the Supreme Court of Texas regarding the scope and force of the new Texas Religious Services Clause.The Supreme Court of Texas held that the Texas Religious Services Clause imposes a categorical bar on governmental limitations of religious services, regardless of the government's interest in the limitation. However, the Court also concluded that the scope of the clause is not unlimited and does not extend to the government's preservation and management of publicly owned lands. The Court emphasized that the clause does not require the government to provide or maintain natural elements necessary for religious services on public property. The case was remanded to the federal courts for further proceedings consistent with this interpretation. View "PEREZ v. CITY OF SAN ANTONIO" on Justia Law

In 2023, police in Des Moines, Iowa, received a tip about suspected narcotics trafficking at a residence. Acting under Iowa Code section 808.16, officers conducted warrantless searches of garbage bags placed curbside for collection. The searches revealed evidence of drug dealing, which was used to obtain a warrant to search the home, leading to further evidence and charges against two occupants, Charles Amble and John Mandracchia. The defendants moved to suppress the evidence, arguing that section 808.16 was unconstitutional.The Iowa District Court for Polk County ruled in favor of the defendants, declaring Iowa Code section 808.16 facially unconstitutional under article I, section 8 of the Iowa Constitution, as interpreted in State v. Wright. The court suppressed the evidence obtained from the garbage searches and the subsequent home search. The State appealed the decision.The Iowa Supreme Court reviewed the case and concluded that the district court erred in its ruling. The court held that the specific provision in Iowa Code section 808.16(3), which deems garbage placed outside for collection in a publicly accessible area as abandoned property, is constitutional both facially and as applied in this case. This provision preempts conflicting local ordinances and negates any reasonable expectation of privacy in such garbage. Consequently, the warrantless trash pulls conducted by the police were lawful, and the evidence obtained was admissible.The Iowa Supreme Court reversed the district court's suppression ruling and remanded the case for further proceedings consistent with its opinion. View "State of Iowa v. Amble" on Justia Law

Aldrick Scott was convicted of first-degree murder, use of a deadly weapon to commit a felony, and tampering with physical evidence after he shot and killed his former girlfriend, Cari Allen, in her home, buried her body, and disposed of other evidence. Scott claimed self-defense, stating that Allen had pulled a gun on him during an argument. However, evidence showed Scott had driven from Topeka to Omaha, where Allen lived, and waited outside her house before the incident. Scott's actions after the shooting, including disposing of Allen's body and other evidence, and fleeing to Belize, were also presented at trial.The District Court for Douglas County denied Scott's motion to suppress evidence obtained from his arrest and search by Belizean police, which included his cell phone. Scott argued that his arrest and search violated Belizean law and the extradition treaty between the United States and Belize, and that the evidence should be excluded under the Fourth Amendment. The court found that U.S. law enforcement did not substantially participate in Scott's arrest and search, and thus, the exclusionary rule did not apply.The Nebraska Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the involvement of U.S. law enforcement did not amount to a joint venture with Belizean police, and thus, the Fourth Amendment's exclusionary rule did not apply. The court also found that any error in admitting the cell phone evidence was harmless, as it was cumulative of Scott's own testimony. Additionally, the court concluded that there was sufficient evidence for a rational trier of fact to find Scott guilty of all charges beyond a reasonable doubt. The court affirmed Scott's convictions and sentences. View "State v. Scott" on Justia Law

Following a high-speed chase, Kordell L. Grady was charged with multiple criminal offenses. He accepted a plea deal, pleading no contest to three charges. The dispute arose over whether Grady's due process rights were violated during a restitution hearing, where he was ordered to pay for damages caused to a law enforcement vehicle during the chase. Grady's counsel argued he lacked the ability to pay, and Grady, attending via Zoom, interrupted the proceedings. The court allowed him to speak with his attorney but warned that the conversation could be heard by everyone in the courtroom. Grady's statements undermined his counsel's argument, and the court ordered him to pay the full restitution amount.Grady filed a motion for postconviction relief, arguing that his due process rights were violated because he could not consult confidentially with his counsel, and that the Assistant District Attorney improperly used his statements. The circuit court rejected these arguments, finding that Grady did not intend for his conversation to be confidential. The court of appeals summarily affirmed the circuit court's decision.The Wisconsin Supreme Court reviewed the case and deferred to the circuit court's factual finding that Grady did not intend for his conversation with his counsel to be confidential. The Supreme Court held that Grady's due process rights were not violated, as he did not seek a confidential conversation. Consequently, his conversation was not privileged under Wisconsin Statute § 905.03(2). The decision of the court of appeals was affirmed. View "State v. Grady" on Justia Law

Promenade D’Iberville, LLC, the owner and developer of a large retail shopping center in D’Iberville, Mississippi, discovered soil issues during construction in 2009. The problems were linked to the use of OPF42, a soil stabilizer containing bed ash from Jacksonville Electric Authority (JEA), a Florida public utility. Promenade filed a lawsuit in 2010 in the Harrison County Circuit Court against several parties, including JEA, alleging damages from the defective product.The Harrison County Circuit Court granted JEA’s motion to dismiss for lack of subject-matter jurisdiction, citing sovereign immunity based on California Franchise Tax Board v. Hyatt (Hyatt III). The court also held that the Full Faith and Credit Clause and comity principles required dismissal due to Florida’s presuit notice and venue requirements. Promenade appealed the decision.The Supreme Court of Mississippi reviewed the case and found that Hyatt III does not apply to JEA, as it is not an arm of the State of Florida but an instrumentality of the City of Jacksonville. The court also determined that neither the Full Faith and Credit Clause nor comity principles mandated dismissal. The court held that Promenade should be allowed to proceed with its claims against JEA in Mississippi, seeking damages similar to those allowed under Mississippi’s constitution for property damage.The Supreme Court of Mississippi reversed the trial court’s judgment of dismissal and remanded the case for further proceedings consistent with its opinion. View "The Promenade D'Iberville, LLC v. Jacksonville Electric Authority" on Justia Law