Justia Constitutional Law Opinion Summaries

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

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