Justia Constitutional Law Opinion Summaries

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

Susan Embert was arrested in February 2015 for charges related to the shooting death of her husband, William “Jake” Embert. She was indicted on June 24, 2015, on five counts, including malice murder and aggravated assault. Her trial took place in December 2019, nearly five years after her arrest, and she was found guilty on all counts. However, over three years later, it was discovered that one of the jurors was a convicted felon, making him ineligible for jury service. Embert raised this issue in her third amended motion for a new trial, which the trial court granted based on the juror’s ineligibility.The trial court then dismissed the case on constitutional speedy trial grounds, determining that the December 2019 trial was void due to the ineligible juror, and thus did not count for the speedy trial calculation. The court found that the delay from Embert’s arrest to the present exceeded nine years, violating her constitutional right to a speedy trial. The trial court attributed most of the delay to Embert but concluded that the presumptive prejudice from the nine-year delay warranted dismissal.The Supreme Court of Georgia reviewed the case and held that the trial court erred in finding the December 2019 trial void for speedy trial purposes. The court clarified that a trial with an ineligible juror results in a voidable verdict, not a void trial. Consequently, the December 2019 trial should be considered for the speedy trial analysis. The Supreme Court vacated the trial court’s dismissal order and remanded the case for reconsideration of the speedy trial analysis, instructing the trial court to reweigh the factors using the correct factual and legal analysis. View "THE STATE v. EMBERT" on Justia Law

Plaintiffs, Carvin Thomas and Terrell Lawrence, filed a class-action lawsuit against members of the Tennessee Board of Parole, alleging that the use of a computer test, STRONG-R, to determine parole eligibility violated their constitutional right to due process. They claimed that the test produced inaccurate results due to inadequate training of correctional employees and that the results were kept secret, preventing inmates from challenging them effectively. Both plaintiffs experienced changes in their STRONG-R scores without any new negative behavior, leading to parole denials based on these scores.The United States District Court for the Middle District of Tennessee dismissed the complaint, concluding that the plaintiffs failed to state a plausible claim for relief. The court found that Tennessee’s parole statutes do not confer a protected liberty interest in parole, as they do not create a legitimate expectation of parole.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that Tennessee’s parole statutes do not sufficiently constrain the Board’s discretion to deny parole, thus not creating a constitutionally recognized entitlement to parole. The court noted that while the plaintiffs identified serious issues with the STRONG-R test, the lack of a protected liberty interest in parole precluded their due process claims. Consequently, the court affirmed the dismissal of the plaintiffs' complaint. View "Thomas v. Montgomery" on Justia Law

Lavonce Makiri Smith was stopped by police in Grand Rapids, Michigan, and a gun was found in his pocket. Smith moved to suppress the evidence, arguing that the police lacked reasonable suspicion to stop and frisk him. The incident began when Detective Garza was involved in a car accident, and Lt. Jonathan Wu, who was also at the scene, noticed a silver Chrysler that matched a stolen vehicle report. The Chrysler circled the area multiple times, and Wu observed three young Black men, including Smith, walking towards his car from the direction of the Chrysler. Wu suspected they were associated with the stolen car and might be planning a carjacking or robbery.The United States District Court for the Western District of Michigan held an evidentiary hearing where Wu testified. The court found Wu's testimony credible and concluded that the officers had reasonable suspicion to stop and frisk Smith. The court ruled that the stop was lawful due to the reasonable suspicion of criminal activity, and the frisk was justified based on the totality of the circumstances suggesting Smith was armed and dangerous. Smith entered a conditional guilty plea, preserving his right to appeal the suppression decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that the stop was supported by reasonable suspicion. The court found that Wu's observations and the behavior of Smith and his companions, combined with the context of the stolen vehicle and the high-crime area, provided a particularized and objective basis for suspecting criminal activity. The court also rejected Smith's arguments challenging the district court's factual findings and application of the law, concluding that the totality of the circumstances justified the stop and frisk. View "United States v. Smith" on Justia Law

Planned Parenthood of Montana and Dr. Samuel Dickman challenged three laws passed by the 2021 Montana Legislature regulating abortion care. The laws included a 20-week ban on abortions (HB 136), restrictions on medication abortions and requirements for informed consent (HB 171), and a mandate for providers to offer patients the opportunity to view an ultrasound and listen to a fetal heart tone before an abortion (HB 140).The Thirteenth Judicial District Court granted a preliminary injunction against the enforcement of these laws, which was affirmed by the Montana Supreme Court. Following discovery, the District Court granted summary judgment to the plaintiffs, concluding that the laws violated the Montana Constitution's guarantees of individual privacy, equal protection, and free speech. The court permanently enjoined the enforcement of all three laws.The Montana Supreme Court reviewed the case and affirmed the District Court's decision. The Court held that the 20-week ban on abortions (HB 136) violated the right to privacy because it prohibited pre-viability abortions and was not justified by a compelling state interest. The Court also found that the restrictions on medication abortions and the informed consent requirements (HB 171) infringed on the right to privacy and free speech, as they imposed unnecessary burdens on patients and providers without addressing a bona fide health risk. Lastly, the Court held that the mandate to offer patients the opportunity to view an ultrasound and listen to a fetal heart tone (HB 140) violated the right to privacy by interfering with the patient-provider relationship without a compelling state interest.The Montana Supreme Court affirmed the District Court's judgment, permanently enjoining the enforcement of the challenged laws. View "Planned Parenthood v. State" on Justia Law