Justia Constitutional Law Opinion Summaries

Nathan Rinne sued Camden County and two of its commissioners, Greg Hasty and Donald Williams, Jr., alleging violations of his First and Fourteenth Amendment rights after Hasty and Williams voted to ban him from all County property for one year. The defendants sought summary judgment on the defenses of qualified and legislative immunity and on the merits of the issue of punitive damages. The district court denied these motions in full.The United States District Court for the Western District of Missouri denied the defendants' motions for summary judgment. The defendants then appealed the denial of legislative immunity, qualified immunity, and the issue of punitive damages.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the denial of legislative immunity, holding that the commissioners' decision to ban Rinne from county property was administrative, not legislative, in nature. The court found that the act of banning Rinne did not concern the enactment or promulgation of public policy but was an effort to monitor and discipline his presence and conduct at future commission meetings. Consequently, the commissioners were not entitled to legislative immunity. The court dismissed the remainder of the appeal, including the issues of qualified immunity and punitive damages, for lack of jurisdiction, as these involved genuine disputes of fact that could not be resolved at the appellate level. View "Rinne v. Hasty" on Justia Law

Selim Zherka, a convicted felon, challenged the constitutionality of 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms. Zherka argued that because his felony was nonviolent, Congress could not deprive him of his Second Amendment right to bear arms. He also claimed a due process right to an individualized assessment of dangerousness before being deprived of this right. Zherka sought a declaration that the statute was unconstitutional as applied to him and an injunction preventing the government from enforcing it against him.The United States District Court for the Southern District of New York dismissed Zherka’s claims. The court held that § 922(g)(1) was constitutional as applied to him and that he had no right to a hearing before the application of a categorical prohibition. The court relied on the Supreme Court’s assurance in District of Columbia v. Heller that longstanding prohibitions on the possession of firearms by felons are presumptively lawful. The court also rejected Zherka’s due process claim, citing Connecticut Department of Public Safety v. Doe, which held that procedural due process does not require a hearing to prove or disprove facts irrelevant under the challenged statute.The United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The court held that the Second Amendment does not prohibit Congress from disarming convicted felons, including those convicted of nonviolent felonies. The court found that there is a historical tradition of legislative disarmament of classes of people perceived as dangerous, which supports the constitutionality of § 922(g)(1). The court also concluded that Zherka had no procedural due process right to an individualized assessment of dangerousness before being disarmed under the statute. View "Zherka v. Bondi" on Justia Law

DeShawn Gervin was on probation in Georgia with the sole condition that he not return to the South Georgia Judicial Circuit. He moved to North Carolina but was later imprisoned there for various crimes. A Georgia probation officer, Pamela Florence, learned of his North Carolina offenses and sought a warrant for his arrest in Georgia, falsely claiming he had violated probation by failing to report. Gervin was arrested in North Carolina and extradited to Georgia, where he spent 104 days in jail before a court found he had not violated his probation and ordered his release.Gervin sued Florence and another probation officer, Tandria Milton, under 42 U.S.C. § 1983, alleging violations of his Fourth, Eighth, and Fourteenth Amendment rights. The United States District Court for the Middle District of Georgia granted summary judgment for the defendants on the Eighth and Fourteenth Amendment claims but denied it on the Fourth Amendment claim, characterizing it as a malicious-prosecution claim.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's ruling. The court held that Gervin presented enough evidence to support his Fourth Amendment malicious-prosecution claim. The court found that Florence and Milton recklessly made false statements and omissions that led to Gervin's arrest and prolonged detention, violating his Fourth and Fourteenth Amendment rights. The court also concluded that the probation officers were not entitled to qualified immunity because the constitutional violations were clearly established at the time of their actions. View "Gervin v. Florence" on Justia Law

Three-month-old La’Mello Parker died during a confrontation between his father, Eric Smith, and law enforcement. Smith, a fugitive wanted for double homicide, used La’Mello as a human shield and fired at officers, who returned fire, killing La’Mello. La’Mello’s grandfather and brother sued various law enforcement entities and officers, alleging constitutional violations under 42 U.S.C. § 1983 and state law claims.The United States District Court for the Southern District of Mississippi dismissed the case, finding that the officers’ actions did not constitute constitutional violations and that they were protected by qualified immunity. The court also dismissed the Fourteenth Amendment claims, stating that the conduct did not shock the conscience, and declined to exercise jurisdiction over the state-law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s dismissal, holding that the officers did not violate La’Mello’s Fourth Amendment rights as their use of force was reasonable under the circumstances. The court noted that Smith posed a grave and immediate threat, and the officers’ decision to return fire was justified. The court also found that the officers were entitled to qualified immunity because the law was not clearly established that their conduct was unconstitutional. Additionally, the court held that the Fourteenth Amendment claims failed as the officers’ actions did not shock the conscience. The court concluded that without an underlying constitutional violation, the bystander liability and municipal liability claims also failed. View "Estate of Parker v. Mississippi Department of Public Safety" on Justia Law

Robert L. Fooks was convicted by the Circuit Court for Wicomico County for violating Section 5-133(b)(2) of the Public Safety Article, which prohibits firearm possession by individuals convicted of a common law crime and sentenced to more than two years in prison. Fooks, who had a prior conviction for constructive criminal contempt and a sentence exceeding four years, argued that this statute violated his Second Amendment rights.The Circuit Court denied Fooks's motion to dismiss the firearms-related counts, and he entered a conditional guilty plea to two counts, reserving his right to appeal the Second Amendment issue. The Appellate Court of Maryland upheld the statute's constitutionality, affirming Fooks's convictions. Fooks then sought review from the Supreme Court of Maryland.The Supreme Court of Maryland affirmed the lower court's decision, holding that Section 5-133(b)(2) is consistent with the Second Amendment. The court noted that the statute is effectively a prohibition on firearm possession by felons, which the U.S. Supreme Court has repeatedly identified as presumptively lawful. The court also found that such prohibitions are consistent with the nation's historical tradition of firearm regulation, which has long included disarming individuals deemed to present a special danger, including those who have committed serious crimes. The court concluded that the statute is constitutional both on its face and as applied to Fooks. View "Fooks v. State" on Justia Law

The case involves Deliezha Davonte Gravely, who was pulled over by a police officer for speeding. During the stop, the officer discovered that Gravely was driving with a revoked license due to a DUI and found a loaded firearm in his pocket. Gravely was subsequently indicted on multiple charges, including unlawful possession of a firearm by a prohibited person and carrying a concealed firearm by a prohibited person, based on his prior conviction for conspiracy to commit first-degree robbery.The Circuit Court of Mercer County ruled that Gravely's prior conviction for conspiracy to commit first-degree robbery qualified as a "felony crime of violence against the person of another" under West Virginia Code § 61-7-7(b). Gravely was convicted by a jury on all counts and sentenced to imprisonment. He appealed, arguing that the circuit court erred in classifying his conspiracy conviction as a crime of violence.The Supreme Court of Appeals of West Virginia reviewed the case de novo, focusing on whether the elements of conspiracy under West Virginia Code § 61-10-31 include a violent act against a person. The court applied the elements test from State v. Mills, which requires examining the statutory elements of the predicate offense rather than the specific conduct of the defendant. The court found that the elements of conspiracy—an agreement to commit an offense and an overt act to effect the conspiracy—do not require a violent act against a person.The Supreme Court of Appeals of West Virginia held that conspiracy to commit first-degree robbery is not a "felony crime of violence against the person of another" for the purposes of West Virginia Code § 61-7-7(b). Consequently, the court reversed Gravely's convictions for unlawful possession of a firearm by a prohibited person and carrying a concealed firearm by a prohibited person, and remanded the case for resentencing on his remaining convictions. View "State v. Gravely" on Justia Law

In the early morning of June 28, 2014, Ms. Taylor Hawkridge was shot and killed in the parking lot of her apartment complex. Eyewitnesses reported seeing a man in a hooded sweatshirt fleeing the scene and entering a dark Dodge Charger. Ms. Hawkridge had a verbal altercation with Nasstashia Van Camp Powell at Vixens Gentlemen’s Club, where she worked. Ms. Powell, after being convicted of second-degree murder, implicated Richard Small and Joseph Mason in the murder, stating they were paid to kill Ms. Hawkridge because she was a police informant. Mr. Small was interviewed by law enforcement multiple times, including a June 2018 interview where he ambiguously mentioned needing a lawyer.The Circuit Court of Berkeley County held a joint trial for Mr. Small and Mr. Mason. Mr. Small filed motions to exclude evidence of Mr. Mason’s gang affiliation and to suppress his June 2018 statement, arguing he had invoked his right to counsel. The court denied these motions, finding the gang affiliation evidence intrinsic to the crimes and Mr. Small’s statement ambiguous. The jury convicted Mr. Small of conspiracy to commit murder and first-degree murder, and he was sentenced to life without parole.On appeal to the Supreme Court of Appeals of West Virginia, Mr. Small argued his constitutional rights were violated by his and his counsel’s absence from critical-stage hearings, the admission of prejudicial evidence, the failure to sever his trial from Mr. Mason’s, the denial of his motion to suppress, and improper comments by the State during the mercy phase. The court found no error, holding that the hearings were not critical stages for Mr. Small, the evidence was intrinsic and relevant, Mr. Small did not properly move to sever, his statement was not an unequivocal request for counsel, and the State’s comments did not constitute plain error. The court affirmed Mr. Small’s convictions and sentence. View "State v. Small" on Justia Law

Samuel Alejondro Torrez was arrested for driving while impaired and driving after license cancellation. Law enforcement obtained a search warrant to test Torrez’s blood or urine, which he refused. Torrez was charged with first-degree test refusal and driving after license cancellation. Before trial, Torrez requested the district court to instruct the jury that the State must prove the arresting officer had probable cause to believe he was driving while impaired. The district court denied this request, and the jury found Torrez guilty on both counts.The Minnesota Court of Appeals affirmed Torrez’s conviction, concluding that the district court did not abuse its discretion by not including a probable cause element in the jury instructions. The court reasoned that the issuance of the search warrant already established probable cause.The Minnesota Supreme Court reviewed whether Minnesota Statutes section 169A.20, subdivision 2(2), requires the State to prove that the arresting officer had probable cause to believe the defendant was driving while impaired. The court held that the plain language of the statute does not require the State to prove probable cause for the refusal of a blood or urine test when a search warrant is involved. The court affirmed the decision of the court of appeals, concluding that the district court did not err in its jury instructions. View "State v. Torrez" on Justia Law

The defendant was convicted of threatening a police officer via social media while on mandatory supervision. As a condition of his postrelease community supervision, the trial court prohibited him from creating or using social media accounts and from accessing social media websites. The defendant challenged this condition as unconstitutionally vague and overbroad.The Superior Court of Sacramento County initially sentenced the defendant to a split sentence for various offenses, including carrying a concealed weapon and perjury. While on mandatory supervision, the defendant was convicted of making a criminal threat using his Facebook account. The trial court executed the previously imposed sentence and added a consecutive sentence for the new conviction. On appeal, the Court of Appeal vacated the sentence and remanded for resentencing. The trial court then imposed a revised sentence, and the defendant was released on postrelease supervision with the challenged social media condition.The California Court of Appeal, Third Appellate District, reviewed the case. The court held that the social media prohibition was not unconstitutionally vague, as it clearly defined the prohibited conduct. The court also found that the condition was not overbroad, as it was closely related to the defendant's use of social media to commit the crime. The court concluded that the prohibition was a reasonable measure to protect the state's interest in the defendant's reformation and rehabilitation. The judgment of the lower court was affirmed. View "People v. Nixon" on Justia Law

Martin Misjuns, a Fire Captain and paramedic with the Lynchburg Fire Department, was terminated after posting offensive social media content targeting transgender individuals. Misjuns alleged that his termination was due to his political and religious views, which he expressed on his Facebook pages. He claimed that the City of Lynchburg and its officials conspired to violate his constitutional rights, leading to his firing.The United States District Court for the Western District of Virginia dismissed all of Misjuns' claims. The court found that the claims against the individual defendants in their official capacities were duplicative and dismissed them. The court also dismissed Misjuns' breach of contract, equal protection, conspiracy, and wrongful termination claims. The court partially dismissed his First Amendment claims but later dismissed them entirely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Misjuns' claims. The court held that Misjuns failed to establish Monell liability against the City of Lynchburg, as he did not adequately plead that a policy or custom caused the alleged constitutional violations. The court also found that the City's Employment Policies & Procedures handbook did not constitute a binding contract, thus dismissing the breach of contract claim. Additionally, the court upheld the dismissal of the conspiracy and wrongful termination claims against the individual defendants, as those claims were not asserted against the City and had been dismissed by agreement.The Fourth Circuit concluded that Misjuns did not sufficiently plead facts to state a claim for relief on any of his six claims, affirming the district court's decision. View "Misjuns v. City of Lynchburg" on Justia Law