Justia Constitutional Law Opinion Summaries

In 2015, the defendant drove his vehicle on a freeway while speeding and under the influence of alcohol and controlled substances. He struck the back of another vehicle, resulting in the deaths of two individuals and serious injuries to three others. The defendant was convicted by a jury in the Genesee Circuit Court of multiple charges, including two counts of involuntary manslaughter and two counts of reckless driving causing death.On direct appeal, the defendant argued for the first time that his convictions violated the multiple-punishments strand of double jeopardy, specifically challenging the convictions for both involuntary manslaughter and reckless driving causing death. The Michigan Court of Appeals affirmed the defendant’s convictions.The Michigan Supreme Court reviewed the case and held that under Michigan common law, the mens rea requirement for reckless driving causing death (willful or wanton disregard) is the same as the mens rea requirement for involuntary manslaughter (criminal gross negligence). Therefore, when an involuntary manslaughter charge is based on a theory of gross negligence, the offense does not have an element that reckless driving causing death does not have. Consequently, the Double Jeopardy Clauses of the United States and Michigan Constitutions prohibit convicting a defendant of both offenses. The Court reversed the judgment of the Court of Appeals and remanded the case to the trial court to determine the appropriate remedy for the double-jeopardy violation. View "People of Michigan v. Fredell" on Justia Law

The case involves 11 public charter schools (the Schools) seeking to overturn a decision by the Public Employment Relations Board (PERB). PERB found that the Schools violated section 3550 of the Prohibition on Public Employers Deterring or Discouraging Union Membership by sending e-mails that tended to influence employees' decisions regarding union representation by United Teachers Los Angeles (UTLA). The Schools argued that PERB's interpretation of section 3550 was erroneous and that the statute was unconstitutional as it violated free speech protections.The administrative law judge (ALJ) initially dismissed the allegations, finding that the e-mails did not contain threats or promises and thus did not violate the Educational Employment Relations Act (EERA). However, PERB, applying its new interpretation from Regents I and Regents II decisions, found that the e-mails violated section 3550 because they tended to influence employee choice regarding union membership. PERB rejected the Schools' defenses, including claims of business necessity and constitutional free speech rights.The California Court of Appeal, Second Appellate District, reviewed the case. The court upheld PERB's interpretation of section 3550, finding it not clearly erroneous. The court also rejected the Schools' constitutional claims, determining that section 3550 regulates only government speech, which is not protected by the First Amendment or the California Constitution. The court found that the Schools, as public employers, and their administrators and Alliance CMO, as agents, were engaged in government speech when communicating about union matters.The court concluded that substantial evidence supported PERB's findings that the Schools could be held responsible for the e-mails sent by Alliance CMO and the School administrators under theories of actual and apparent authority. The court affirmed PERB's decision and order. View "Alliance Marce & Eva Stern Math & Sci. High Sch. v. PERB" on Justia Law

A Black man, known for his career in the NFL, was accused by an intellectually disabled woman of raping her at gunpoint during a babysitting job interview at his home. The jury found him guilty of forcible rape, forcible oral copulation, and false imprisonment, with firearm use in the first two offenses. He was sentenced to 15 years to life in prison. The prosecution argued that the police did not search his house due to his fame and race, suggesting a search would have caused controversy.The trial began in March 2020 but was paused due to the COVID-19 pandemic, resuming three months later. The jury acquitted him on two counts related to the victim's incapacity to consent. The trial court sentenced him in October 2020. The defendant appealed, arguing that the prosecution's statements violated the California Racial Justice Act of 2020 by appealing to racial bias.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found that the prosecution violated the Racial Justice Act by explicitly asserting that the defendant's race influenced the police's decision not to search his house, implying he gained an undeserved advantage at trial because he was Black. The court concluded that the prosecution's statements constituted racially discriminatory language under Penal Code section 745, subdivision (a)(2). The court held that Penal Code section 745, subdivision (e)(2)(A) precludes harmless error analysis and mandates vacating the conviction and sentence. Consequently, the court reversed the judgment, vacated the conviction and sentence, and remanded for new proceedings consistent with the Racial Justice Act. View "P. v. Stubblefield" on Justia Law

Johnell Lavell Barber was convicted of felony possession of a firearm under 18 U.S.C. § 922(g)(1) after he opened fire on two passing vehicles, injuring Eric Escalara and his ten-year-old daughter. Police arrested Barber at his wife Shiffon Wilson’s home, where they found him hiding. After initially refusing, Wilson later consented to a search of her home, leading to the discovery of several firearms and ammunition. Barber challenged his conviction on three grounds: invalid consent to the search, the unconstitutionality of § 922(g)(1) under the Second Amendment, and insufficient evidence to support his conviction.The United States District Court for the Eastern District of Texas denied Barber’s motion to suppress the evidence obtained from the search, finding that Wilson had voluntarily consented. At trial, multiple witnesses testified against Barber, including eyewitnesses who saw him with the AR-15 and forensic experts who found his DNA on the weapon and gunshot residue on his hands. The jury found Barber guilty, and he was sentenced to 120 months imprisonment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Wilson’s consent to the search was voluntary, as the police did not use coercion and adequately informed her of her rights. The court also upheld the constitutionality of § 922(g)(1), referencing Supreme Court precedent that laws disarming felons are presumptively lawful. Finally, the court found sufficient evidence to support Barber’s conviction, noting the presence of his DNA on the firearm, eyewitness testimony, and the firearm’s interstate travel history.The Fifth Circuit affirmed Barber’s conviction on all grounds. View "United States v. Barber" on Justia Law

Chesla A. Scott challenged the Idaho Department of Labor's service of three determination notices, claiming she did not receive them while temporarily working out-of-state. The Department mailed the notices to her last known address, and Scott missed the fourteen-day appeal period. When she attempted to appeal, the Department's Appeals Examiner dismissed her appeal as untimely. Scott argued that the Department's service by mail did not meet constitutional due process requirements.The Appeals Examiner conducted a hearing and concluded that Scott's appeal was untimely under Idaho Code section 72-1368(3) and (5). The Idaho Industrial Commission affirmed this decision, denying Scott's request for a new hearing and conducting a de novo review of the record. The Commission also concluded that Scott had not timely filed her appeal.Scott appealed to the Idaho Supreme Court, arguing that the Department's service by mail was constitutionally inadequate. The Court reviewed whether Scott exhausted her administrative remedies and preserved her constitutional challenge. The Court held that Scott had exhausted her administrative remedies and preserved her due process claim, allowing it to be reviewed.The Idaho Supreme Court affirmed the Commission's decision, holding that the Department's mailing of the determination notices was reasonable under all the circumstances and did not violate due process. The Court found that the Department's method of service was reasonably calculated to provide notice, and Scott's failure to receive the notices was not due to any fault of the Department. The Court did not award attorney fees to either party but awarded costs to the Department. View "Scott v. Home Depot USA, Inc." on Justia Law

A mother and her fiancé filed a petition to terminate the biological father's parental rights and allow the fiancé to adopt the child. The mother did not serve the father with the petition, and he did not participate in the proceedings. The magistrate court terminated the father's parental rights and granted the adoption. The father later filed two motions to set aside the judgment, arguing that his due process rights were violated due to lack of notice. The magistrate court denied the second motion, citing res judicata. The district court reversed this decision, finding that the father's due process argument warranted consideration.The Idaho Supreme Court reviewed the case. The court held that the father's Rule 60(b)(4) motion, which alleged a fundamental error violating his constitutional right to due process, was not barred by res judicata. The court applied the fundamental error doctrine, which allows for exceptions to procedural bars when a fundamental constitutional right is at stake. The court also rejected the mother's arguments that the father's motion was barred by the doctrines of claim splitting, invited error, appellate waiver, and the law of the case.The Idaho Supreme Court affirmed the district court's decision to remand the case to the magistrate court for an evidentiary hearing to determine whether the father's Rule 60(b)(4) motion was timely and whether the termination and adoption judgment was void. The court also awarded the father partial attorney fees on appeal for defending against certain arguments made by the mother. View "Doe v. Doe" on Justia Law

In Michigan, citizens can amend the state constitution through ballot initiatives without legislative approval. Two state senators and nine state representatives challenged the use of such initiatives to regulate federal elections, arguing it violated the U.S. Constitution's Elections Clause. They sought to prevent Michigan officials from enforcing these amendments.The United States District Court for the Western District of Michigan dismissed the case, ruling that the legislators lacked standing to sue under Civil Rule 12(b)(1). The court found that the plaintiffs did not demonstrate a concrete injury necessary for standing.The United States Court of Appeals for the Sixth Circuit affirmed the district court's dismissal. The appellate court held that the legislators did not have standing because they did not represent the entire legislature or a controlling bloc within it. The court distinguished this case from precedents where entire legislatures or controlling blocs had standing to sue. The court emphasized that individual legislators generally lack standing to assert institutional injuries of the legislature. The court also noted that the legislators had not shown that their votes were nullified by the amendments, as required for standing under relevant Supreme Court precedents.The Sixth Circuit concluded that the legislators' claims did not meet the requirements for standing under Article III of the U.S. Constitution, as they did not suffer a concrete and particularized injury. The court affirmed the district court's dismissal of the case. View "Lindsey v. Whitmer" on Justia Law

Angela Reading, a mother and former school board member, alleged that federal and local government officials violated her First Amendment rights by censoring and retaliating against her after she posted comments on Facebook. The controversy began when Reading criticized a poster at her child's elementary school that featured various sexual identities. Her post drew significant attention and backlash from military personnel at a nearby base, leading to a series of communications and actions by local and federal officials, including heightened security at a school board meeting and referrals to counter-terrorism authorities.Reading sought a preliminary injunction to prevent further interference with her free speech rights. The United States District Court for the District of New Jersey denied her motion, concluding that she failed to demonstrate irreparable harm.The United States Court of Appeals for the Third Circuit reviewed the case and focused on whether Reading had standing to seek a preliminary injunction. The court found that the bulk of the alleged unlawful conduct occurred during a brief period and had significantly subsided by the time Reading filed her lawsuit. The court determined that Reading did not show a substantial risk of future harm or a likelihood of future injury traceable to the defendants. Consequently, the court held that Reading lacked standing to seek a preliminary injunction and affirmed the District Court's order denying her motion. The case was remanded for further proceedings consistent with this opinion. View "Reading v. North Hanover Township" on Justia Law

A nonprofit corporation, Moving Oxnard Forward (MOF), challenged campaign finance limitations in the Oxnard City Code, alleging they violated the First Amendment. The limitations, adopted by the City of Oxnard, California, primarily affected Aaron Starr, MOF's President, who had a history of receiving large contributions and challenging the City Council's policies. Starr had previously led recall efforts against the City Council and ran for Mayor, relying on larger-dollar contributions.The United States District Court for the Central District of California granted summary judgment in favor of the City, upholding the campaign finance limitations. MOF appealed the decision, arguing that the limitations were designed to target and suppress Starr's political activities rather than to prevent corruption.The United States Court of Appeals for the Ninth Circuit reviewed the case and found significant "danger signs" of invidious discrimination against Starr. The court noted that the legislative record and the practical impact of the limitations disproportionately affected Starr, who had been a vocal critic of the City Council. The court also found that the City's justification for the limitations, based on a 2010 corruption scandal, was tenuous and unrelated to campaign contributions.The Ninth Circuit concluded that the contribution limits were not narrowly tailored to the City's interest in preventing quid pro quo corruption. Instead, the limits appeared to be more closely drawn to suppress Starr's political activities. As a result, the court reversed the district court's decision and remanded with instructions to grant summary judgment in favor of MOF, holding that the per-candidate aggregate contribution limitations in the Oxnard City Code violated the First Amendment. View "MOVING OXNARD FORWARD, INC. V. ASCENSION" on Justia Law

The plaintiff filed a civil suit against the defendant, alleging defamation and intentional infliction of emotional distress (IIED) after the defendant reported to the police that the plaintiff had sexually and physically assaulted her. This report led to the plaintiff being criminally charged, arrested, and held without bail for almost two years before being acquitted. The plaintiff claimed that the defendant's report was false and made with malicious intent to harm him.The Superior Court, Windsor Unit, Civil Division, granted the defendant's motion for judgment on the pleadings, concluding that the defendant's statements to the police were absolutely privileged as communications preliminary to a judicial proceeding. The court also granted the defendant's special motion to strike under Vermont's anti-SLAPP statute, 12 V.S.A. § 1041, and awarded attorney’s fees to the defendant. The court reasoned that the defendant's statements were protected under the anti-SLAPP statute as an exercise of her right to petition the government.The Vermont Supreme Court affirmed the trial court's grant of judgment on the pleadings, agreeing that the defendant's statements to the police were absolutely privileged. The Court held that public policy supports extending absolute privilege to such statements to encourage free and full disclosure to law enforcement without fear of civil liability. The Court also affirmed the trial court's application of the anti-SLAPP statute, concluding that the defendant's statements were made in connection with a public issue and were an exercise of her constitutional rights. However, the Supreme Court remanded the case for the trial court to consider the plaintiff's constitutional challenges to the anti-SLAPP statute, which the trial court had not adequately addressed. View "Talandar v. Manchester-Murphy" on Justia Law