Justia Constitutional Law Opinion Summaries

In 1996, Daniel Whalen was convicted of first-degree murder during a robbery and received a death sentence. His conviction and sentence were affirmed by the California Supreme Court in 2013, and his first state habeas corpus petition was denied in 2014. Whalen filed a second habeas corpus petition in 2016, raising claims of prosecutorial misconduct, ineffective assistance of counsel, and constitutional challenges to the death penalty. This petition was transferred to the Stanislaus Superior Court, which denied it in 2022, finding the claims were successive and could have been raised earlier.Whalen appealed the denial and requested a certificate of appealability from the California Court of Appeal, Fifth Appellate District. The appellate court initially denied the request, but the California Supreme Court directed it to reconsider whether the superior court had properly ruled the petition as successive under Proposition 66 and its implementing statutes. Upon remand, the superior court reaffirmed its decision that the claims were successive and granted a certificate of appealability without specifying the claims.The California Court of Appeal, Fifth Appellate District, reviewed the case and found the certificate of appealability fatally defective because it did not indicate which claims were substantial, as required by law. The court dismissed the appeal and remanded the case to the superior court to either deny the certificate of appealability or issue a new one that complies with the statutory requirements. The appellate court also upheld the constitutionality of section 1509, subdivision (d), which limits successive habeas corpus petitions to claims of actual innocence or ineligibility for the death sentence. View "In re Whalen" on Justia Law

In 1996, Jesse Banda Ortega, then 17 years old, was involved in a gang-related shooting in Santa Ana, California, resulting in one death and one injury. Ortega was convicted of one count of murder and three counts of attempted murder, with firearm enhancements. He was sentenced to 25 years to life, plus 17 years, making him eligible for parole after 42 years.Ortega filed a petition for recall and resentencing under California Penal Code section 1170(d)(1) in 2023, arguing that his sentence was the functional equivalent of life without parole (LWOP) and that he should be eligible for relief under equal protection principles. The Superior Court of Orange County denied his petition, stating that Ortega's sentence included a meaningful opportunity for release during his 25th year of incarceration, thus it was neither LWOP nor its functional equivalent.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that Ortega's sentence, modified by legislative changes requiring youth offender parole hearings, provided a meaningful opportunity for release after 25 years. Therefore, Ortega was not serving a sentence equivalent to LWOP. The court affirmed the trial court's denial of Ortega's petition, concluding that his constitutional claim was moot due to the legislative changes ensuring parole eligibility. The court also found that Ortega's equal protection argument was moot, as his current sentence did not violate constitutional principles. View "P. v. Ortega" on Justia Law

The Association for Accessible Medicines (AAM), representing generic drug manufacturers, challenged a Minnesota law regulating drug prices, Minn. Stat. § 62J.842, arguing it violated the dormant Commerce Clause. The law prohibits manufacturers from imposing excessive price increases on generic or off-patent drugs sold in Minnesota. The district court granted AAM's motion for a preliminary injunction, finding the law likely violated the dormant Commerce Clause.The United States District Court for the District of Minnesota concluded that AAM was likely to succeed on the merits of its claim, faced a threat of irreparable harm, and that the balance of harms and public interest factors were neutral. Minnesota appealed, contesting the likelihood of success on the merits and the balance of harms/public interest.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s ruling for abuse of discretion and its legal conclusions de novo. The court found that the Minnesota law had the impermissible extraterritorial effect of controlling prices outside the state, similar to laws previously struck down by the Supreme Court. The court rejected Minnesota's argument that the law did not control out-of-state prices, noting that it effectively regulated out-of-state transactions if the drugs ended up in Minnesota.The Eighth Circuit affirmed the district court’s decision, agreeing that AAM was likely to succeed on the merits of its dormant Commerce Clause claim. The court also found no abuse of discretion in the district court’s assessment of the balance of harms and public interest, noting that protecting constitutional rights is always in the public interest. The preliminary injunction against the Minnesota law was upheld. View "Ass'n for Accessible Medicines v. Ellison" on Justia Law

The case involves a post-dismissal challenge to a trial court’s order that permanently sealed the petitioners’ actual names and allowed them to be identified by pseudonyms in court records. The petitioners, identified as John Does P, Q, R, and S, sought to prevent Thurston County from releasing unredacted sex offender records in response to a Public Records Act (PRA) request by Donna Zink. The trial court granted the Does’ motion for voluntary dismissal and entered a permanent order to maintain the use of pseudonyms and seal a court record listing their actual names.The trial court initially allowed the Does to proceed in pseudonym to preserve their ability to seek relief in their PRA injunction action. However, over the course of the litigation, nearly all of the Does’ PRA exemption claims were rejected, and Zink received most of the records she requested. The trial court’s preliminary orders allowing pseudonyms were based on the potential harm of being identified as sex offenders. On remand, the trial court granted the Does’ motion for voluntary dismissal and permanently sealed their names, citing compelling privacy and safety concerns.The Washington Supreme Court reviewed the case and held that the trial court abused its discretion in permanently sealing the Disclosure Document and allowing the Does to remain in pseudonym. The court found that the trial court’s findings were insufficient to satisfy GR 15 or the Ishikawa factors, which require specific and compelling reasons to restrict public access to court records. The court noted that the Does’ identities as sex offenders were already publicly available, and the trial court’s order did not articulate new compelling privacy or safety concerns. The Supreme Court remanded the case with instructions to unseal the Disclosure Document, use the Does’ actual names in future proceedings, and replace the pseudonyms in court records with their actual names. View "Doe P v. Thurston County" on Justia Law

Nathan Parris was taken into protective custody by law enforcement after making suicidal statements and exhibiting concerning behavior. Officers searched him before transporting him to the hospital for a mental health evaluation and found a small, closed container in his pocket, which contained methamphetamine. Parris was charged with possession of a controlled substance and moved to suppress the drug evidence, arguing that the search of the container was impermissible.The Circuit Court of the Seventh Judicial Circuit in Pennington County, South Dakota, denied Parris's motion to suppress, finding that the officers had probable cause to take him into protective custody and that the search of the container was permissible. Parris was found guilty of possession of a controlled substance in a court trial based on stipulated facts.The Supreme Court of the State of South Dakota reviewed the case. The court held that the officers had probable cause to believe that Parris required emergency intervention due to his suicidal statements, emotional distress, and possession of a loaded handgun. The court also held that the search of the closed container was a reasonable administrative step to ensure the safety of Parris, the officers, and the facility, and was not conducted as part of a criminal investigation. Therefore, the search did not violate the Fourth Amendment.The Supreme Court affirmed the circuit court's decision, upholding Parris's conviction for possession of a controlled substance. View "State v. Parris" on Justia Law

Defendant Ronald Deshunn Lewis was charged with two counts of assault and alleged probation violations. He was found mentally incompetent to stand trial and committed to the California Department of State Hospitals (Department), which was authorized to administer antipsychotic medication involuntarily. Lewis appealed, arguing that his due process and equal protection rights were violated because the trial court issued the involuntary medication order without an evidentiary hearing.The Contra Costa County District Attorney initially charged Lewis with assault by means likely to produce great bodily injury. The trial court suspended criminal proceedings due to doubts about his mental competence and appointed psychologists to evaluate him. Based on their reports, the court found him incompetent and committed him to the Department. After a month, the Department certified that Lewis had regained competence, and he pled no contest to the assault charge, receiving probation. However, a subsequent probation violation led to new charges and another suspension of proceedings due to doubts about his competence. A psychologist's report again found him incompetent, and the court committed him to the Department, authorizing involuntary medication.The California Court of Appeal, First Appellate District, reviewed the case. The court held that section 1370(a)(2)(B) of the Penal Code does not require an evidentiary hearing before authorizing involuntary medication. The court found that the trial court's procedures, which included considering written reports from mental health experts and allowing for argument by counsel, provided sufficient due process. The court also held that the different procedural requirements for inmates and other civil committees did not violate equal protection, as there were rational bases for the distinctions. The court affirmed the trial court's order authorizing involuntary medication. View "P. v. Lewis" on Justia Law

The defendants in this case challenged the constitutionality of 8 U.S.C. § 1326, which criminalizes unlawfully reentering the United States after a prior removal. They argued that the statute violates the equal protection component of the Fifth Amendment’s Due Process Clause by discriminating against Mexican and other Latin American immigrants. Their theory was that the statute’s predecessor, the Undesirable Aliens Act of 1929, was enacted with discriminatory intent, and that § 1326, first codified in 1952 and amended several times thereafter, perpetuates that taint.The United States District Court for the Middle District of Florida denied the defendants’ motions to dismiss their indictments. The court assumed without deciding that the Arlington Heights framework applied but concluded that the defendants had failed to establish a discriminatory purpose behind § 1326’s enactment. The court also concluded that the statute easily satisfied rational-basis review. The defendants then entered conditional guilty pleas or proceeded to a stipulated bench trial, reserving their rights to appeal the constitutional issue. The District Court sentenced the defendants to varying terms of imprisonment and supervised release.The United States Court of Appeals for the Eleventh Circuit reviewed the case and upheld the District Court’s decision. The court found no clear error in the District Court’s conclusion that the defendants had not shown that § 1326 was enacted or maintained for a discriminatory purpose. The court noted that the defendants’ evidence, including historical context, statements by public officials, and statistical disparities, was insufficient to establish that the 1952 Congress acted with discriminatory intent. The court also emphasized that laws do not carry forward “taint” through reenactment unless the later legislature acted with the same constitutionally impermissible purpose. The judgments of the District Court were affirmed. View "USA v. Ferretiz-Hernandez" on Justia Law

William Hines was convicted in the United States District Court for the Northern District of New York for receipt and possession of child pornography found on his cellphone and laptop. Hines had pleaded guilty but reserved the right to appeal the denial of his motion to suppress evidence obtained from the search of his cellphone. Hines argued that his girlfriend, K.S., acted as an agent of the police when she used his password to unlock his cellphone, observed child pornography, and showed the images to a police officer, thus violating his Fourth Amendment rights.The district court held an evidentiary hearing and found that K.S. acted independently and not as a government agent when she unlocked the phone and showed the images to the police officer. The court concluded that the private search did not implicate the Fourth Amendment and denied the motion to suppress the evidence obtained from the subsequent search warrant.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the burden lies with the defendant to show that a private search constituted governmental action implicating the Fourth Amendment. The court found no error in the district court's determination that Hines failed to meet this burden. The court concluded that K.S. acted independently and not as a government agent, and thus, the private search did not violate the Fourth Amendment. Consequently, the evidence obtained from the search warrant was admissible. The Second Circuit affirmed the judgment of the district court. View "United States v. Hines" on Justia Law

The plaintiffs, property owners in New Hampshire, challenged the administration of the Statewide Education Property Tax (SWEPT), arguing that it violated the state constitution by allowing property-wealthy towns to retain excess funds and by setting negative local education tax rates in certain unincorporated places. They sought a permanent injunction to discontinue this funding scheme, claiming it resulted in disproportionate tax rates.The Superior Court granted the plaintiffs' motion for partial summary judgment, finding that allowing communities to retain excess SWEPT funds and setting negative local education tax rates violated Part II, Article 5 of the New Hampshire Constitution. The court enjoined the state from permitting these practices and treated its order as a final decision.The Supreme Court of New Hampshire reviewed the case. It concluded that the legislature's decision to allow communities to retain excess SWEPT funds was an exercise of its spending power and did not violate the constitution. Therefore, the court reversed the trial court's ruling on this issue. However, the Supreme Court agreed with the trial court that setting negative local education tax rates in certain unincorporated places violated Part II, Article 5, and affirmed this part of the trial court's decision.The Supreme Court vacated the trial court's injunction remedy, stating that resolving the constitutional issue of setting negative local tax rates is the responsibility of the other branches of government. The case was remanded for further proceedings consistent with the Supreme Court's decision. View "Rand v. State" on Justia Law

Law enforcement officers approached David Mickel without a warrant, detained him with guns drawn, handcuffed him, searched him, and transported him to the police station for an interview. Mickel was assured he was only being detained and not charged with any crime. During the interview, Mickel waived his Miranda rights and made statements that the State sought to use against him in a trial for malice murder related to the shooting death of Michael Anthony Thomas.The trial court held a pretrial evidentiary hearing where officers testified they did not have probable cause to arrest Mickel at the time of his seizure. The trial court agreed, concluding that the warrantless encounter amounted to a "full-blown custodial arrest" without probable cause, thus violating Mickel's Fourth Amendment rights. Consequently, the court suppressed Mickel's statements as "fruit of the poisonous tree."The Supreme Court of Georgia reviewed the case. The State argued that Mickel's arrest was supported by probable cause. However, the Supreme Court found that the trial court's orders did not allow for meaningful appellate review due to limited factual findings and lack of detailed analysis. The Supreme Court vacated the portions of the trial court's orders concerning the probable cause determination and the suppression of Mickel's statements. The case was remanded for further proceedings to provide additional fact-finding and analysis, particularly regarding the credibility of the officers' testimony and the potential impact of a self-defense claim on the probable cause determination. View "THE STATE v. MICKEL" on Justia Law