Justia Constitutional Law Opinion Summaries

A woman was convicted of possessing methamphetamine and drug paraphernalia after police discovered these items during a search of a residence she shared with another individual who was on probation. The search was initiated when a probation officer visited to verify the housemate's residence. The woman answered the door, attempted to refuse entry by shutting the door, but the officer entered regardless and proceeded to search the shared bedroom after both occupants indicated there might be contraband present. The officer found drugs and paraphernalia in the room, and both individuals were charged.Previously, the District Court of the Fourth Judicial District, Ada County, denied the woman's motion to suppress the evidence, rejecting her argument that the search was unlawful under Georgia v. Randolph because she had expressly objected to the entry. The district court also admitted a police body camera video at trial, which included statements from her housemate that allegedly violated her Sixth Amendment confrontation rights under Bruton v. United States. The case proceeded to a joint jury trial, resulting in guilty verdicts for both defendants.The Supreme Court of the State of Idaho reviewed the case. It held that the search was lawful because the probationer's waiver of Fourth Amendment rights as a condition of probation allowed officers to enter and search shared areas, even over the objection of a co-occupant. The Court declined to extend the Randolph rule to probation searches, reasoning that co-tenants of probationers have a reduced expectation of privacy. Regarding the confrontation issue, the Court found that admitting the body camera footage was error under Bruton, but determined the error was harmless due to overwhelming independent evidence of guilt. The Court affirmed the district court’s judgment of conviction. View "State v. Horn" on Justia Law

Venticinque and Lair, long-term romantic partners living in Savannah, decided to start a family together in 2018. They selected a sperm donor resembling Lair, with Venticinque to be the biological mother. Lair contributed to fertility treatment costs, participated in events marking the pregnancy, and was involved in the child’s birth and early care. Both women were publicly identified as parents of the child, L.V., in birth announcements and social media posts. However, after L.V.’s birth in July 2021, Venticinque’s behavior changed, and in November 2022, she left Savannah with L.V., ceased contact between Lair and the child, and alleged abuse by Lair.Following this, Lair filed a petition in the Superior Court seeking equitable caregiver status under OCGA § 19-7-3.1. Venticinque opposed the petition and challenged the statute’s constitutionality. The trial court denied Venticinque’s motion to dismiss and held that the statute was constitutional, relying on precedent from Clark v. Wade, 273 Ga. 587 (2001). The trial court found that Lair met the statutory requirements for equitable caregiver status and awarded her joint legal custody, visitation, and ultimately primary physical custody of L.V. after a subsequent bench trial. Venticinque appealed the final order, and the Court of Appeals transferred the case to the Supreme Court of Georgia due to the constitutional questions involved.The Supreme Court of Georgia determined that the trial court had applied the wrong legal standard under OCGA § 19-7-3.1 by placing the burden of proving harm to the child on Venticinque, rather than on Lair, the petitioner. The Supreme Court vacated both the equitable caregiver and custody orders and remanded the case for the trial court to apply the correct statutory standard. The constitutional issues were not addressed, as resolution of the statutory issue was dispositive. View "VENTICINQUE v. LAIR" on Justia Law

The case involved the disappearance of Ann Berry in 1991, whose remains were not discovered until 2011 near the home she shared with her husband, Kevin James Lee. On the night she vanished, Berry was attempting to leave Lee with their children, as heard during a worried phone call to her sister. Lee later moved with the children to Kansas and gave inconsistent explanations for Berry’s absence. Berry was not officially listed as missing until 1997. In 2011, her remains were found and identified, with the cause of death ruled a homicide. Lee was indicted in 2012 for malice murder and concealing a death, with the case placed on the dead docket until his 2018 arrest in California.After his arrest, the case was returned to active status in the Coweta County Superior Court. A jury trial in 2022 resulted in Lee’s conviction for malice murder and concealing the death of another. The trial court sentenced him to life plus twelve months. Following a motion for new trial, the court set aside the conviction for concealing a death due to a statute of limitations issue but denied other grounds for a new trial.On appeal to the Supreme Court of Georgia, Lee challenged the sufficiency of the evidence for malice murder, the admission of certain hearsay evidence, the excusal of a juror, and the effectiveness of his counsel regarding speedy trial claims and plea negotiations. The Supreme Court of Georgia held that the evidence was sufficient for the malice murder conviction, the trial court did not abuse its discretion in evidentiary and juror decisions, and Lee’s counsel was not constitutionally ineffective. The judgment of conviction for malice murder was affirmed. View "LEE v. THE STATE" on Justia Law

A New Jersey physician wished to provide medical aid in dying to terminally ill patients, including nonresidents seeking this service under New Jersey’s law that permits doctor-assisted suicide. The relevant statute allows only New Jersey residents, with a prognosis of six months or fewer to live, to request and obtain a prescription for life-ending medication. Patients must demonstrate residency through various documents and satisfy several procedural safeguards. The plaintiff, a physician, challenged the law’s residency requirement after two terminally ill nonresidents who had joined the suit died during the course of litigation.The United States District Court for the District of New Jersey dismissed the complaint. The court reasoned that the right to receive medical aid in dying was neither a fundamental privilege nor a fundamental right requiring extension to nonresidents under the Privileges and Immunities Clause or the Equal Protection Clause. It further found the law was not economic protectionism and survived rational-basis review. The plaintiff appealed this decision.The United States Court of Appeals for the Third Circuit affirmed the District Court’s dismissal. It held that New Jersey’s restriction of doctor-assisted suicide to its own residents does not violate the Privileges and Immunities Clause because there is no longstanding tradition making such access a fundamental privilege, nor does it violate the Equal Protection Clause, as there is no fundamental right to assisted suicide or to interstate travel for this purpose. The Third Circuit also determined that the law does not offend the dormant Commerce Clause since it is a moral rather than commercial regulation and does not discriminate against out-of-state economic interests. The court concluded that New Jersey’s residency requirement is constitutionally permissible, justified by the state’s interests in protecting doctors, avoiding interstate friction, and safeguarding patients. View "Bryman v. Murphy" on Justia Law

These consolidated cases concern the constitutionality of statutory limits on the President’s authority to remove members of the National Labor Relations Board (NLRB) and the Merit Systems Protection Board (MSPB). Both agencies are composed of members appointed by the President with Senate confirmation, and statutes prohibit the President from removing members except for cause. The NLRB oversees labor relations and union elections, with powers including rulemaking, adjudication, and the issuance of affirmative remedies. The MSPB administers federal employment disputes and can issue final orders, award a range of remedies, and promulgate certain regulations.After the President removed Gwynne Wilcox from the NLRB and Cathy Harris from the MSPB—without alleging the statutory grounds for removal—Wilcox and Harris challenged their removals in the United States District Court for the District of Columbia. The District Court held that the statutory protections against removal were constitutional under the precedent of Humphrey’s Executor v. United States, declared Wilcox and Harris remained in office, and enjoined the government from interfering with their roles. The government appealed, and the Supreme Court stayed the district court’s orders pending appeal, signaling skepticism about the constitutionality of the removal restrictions.The United States Court of Appeals for the District of Columbia Circuit reversed the district courts’ judgments. The court held that, under Seila Law LLC v. Consumer Financial Protection Bureau, Congress may not restrict the President’s ability to remove principal officers who wield substantial executive power. The court found that both the NLRB and MSPB exercise powers that are executive in nature and go beyond the quasi-legislative or quasi-judicial functions contemplated in Humphrey’s Executor. Consequently, statutory restrictions on the President’s removal authority for members of these boards are unconstitutional. The court ordered that the removal protections for NLRB and MSPB members be disregarded. View "Harris v. Bessent" on Justia Law

A Malaysian national who worked as a managing director for Goldman Sachs in Malaysia was prosecuted for his role in a large-scale financial scheme involving 1Malaysia Development Berhad (1MDB), a Malaysian state-owned investment fund. The government presented evidence showing that, along with other conspirators, he participated in three major bond offerings raising $6.5 billion, from which more than $2.5 billion was diverted for bribes and kickbacks to officials and participants, including himself. The funds were laundered through shell companies, and the defendant received $35.1 million that was deposited in an account controlled by his family members. The defendant’s wife asserted at trial that these funds were legitimate investment returns, not criminal proceeds.Prior to this appeal, the United States District Court for the Eastern District of New York denied several motions by the defendant. The court rejected his arguments that the indictment should be dismissed for lack of venue, concluding that acts in furtherance of the conspiracy passed through the Eastern District of New York. The court also found that the government did not breach an agreement regarding his extradition from Malaysia, since the superseding indictments did not charge new offenses. The district court excluded a video recording offered by the defense as inadmissible hearsay, and ultimately, a jury found him guilty on all counts. He was sentenced to 120 months’ imprisonment and ordered to forfeit $35.1 million.On appeal to the United States Court of Appeals for the Second Circuit, the defendant argued improper venue, breach of extradition agreement, erroneous exclusion of evidence, and that the forfeiture was an excessive fine under the Eighth Amendment. The Second Circuit held that the district court had not erred in any respect. Venue was proper, the extradition agreement was not breached, the evidentiary ruling was not an abuse of discretion, and the forfeiture was not grossly disproportionate to the offense. Accordingly, the judgment of conviction and forfeiture order were affirmed. View "USA v. NG CHONG HWA" on Justia Law

In November 2018, police and firefighters responded to a fire at the defendant’s home. About forty minutes after their arrival, while the main section of the house remained ablaze, officers seized a digital video recorder (DVR) from the garage attached to the house without first obtaining a warrant. The State alleged that the DVR contained footage relevant to a broader investigation, including suspicion of arson and multiple related homicides. The defendant moved before trial to suppress the DVR, arguing that its warrantless seizure was unconstitutional.The Superior Court, Law Division held a multi-day suppression hearing, heard testimony from several first responders, and reviewed video and photographic evidence. The trial judge found the officers credible but determined that exigent circumstances did not justify the warrantless seizure because the garage fire had been extinguished for about thirty minutes and the garage was physically distant from the still-burning portion of the house. The Appellate Division affirmed, agreeing that the officers had time to secure a warrant and that the facts did not support an objectively reasonable belief that immediate seizure was necessary.The Supreme Court of New Jersey reviewed the case and, applying a de novo standard to the legal conclusions, found that under the totality of the circumstances, the police acted reasonably and that exigent circumstances justified the warrantless seizure of the DVR. The Court explained that no bright-line rule governs exigency, and its determination requires a fact-sensitive analysis. Here, the seriousness of the crime, the urgency of the situation, the difficulty of obtaining a warrant at that hour, and the risk of evidence destruction supported the officers’ actions. The Court reversed the suppression order and remanded for further proceedings. View "State v. Caneiro" on Justia Law

A city in Florida established a "vehicular safety zone" outside a medical clinic that performs abortions, which prohibited most pedestrians, including sidewalk counselors, from entering a 38-foot section of public sidewalk that included the clinic's driveway during business hours. The city justified this restriction by citing repeated incidents involving protestors allegedly impeding vehicles and intimidating occupants, and asserted that existing measures like targeted trespass warnings or arrests were insufficient due to the location being public property and violations being misdemeanors not committed in officers’ presence. Four individuals who regularly engaged in sidewalk counseling—offering literature and conversation to those entering the clinic—along with a nonprofit organization, challenged the ordinance, arguing it violated their First Amendment rights by significantly restricting their ability to communicate with clinic patients, particularly by preventing them from handing leaflets to occupants of vehicles entering or exiting the clinic.The United States District Court for the Middle District of Florida denied the plaintiffs’ motion for a preliminary injunction, finding that they were unlikely to succeed on the merits of their First Amendment claim. The court concluded that the ordinance was narrowly tailored to serve the city's significant interest in vehicular safety and that it left open alternative channels for communication.Upon review, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs were likely to succeed on the merits of their facial First Amendment challenge. Applying the standard from McCullen v. Coakley, the appellate court found that the ordinance was not narrowly tailored because the city had not seriously considered less restrictive alternatives that would further vehicular safety without burdening substantially more speech than necessary. The Eleventh Circuit vacated the district court’s judgment and remanded with instructions to grant the preliminary injunction, finding also that the remaining factors for injunctive relief favored the plaintiffs. View "Florida Preborn Rescue, Inc. v. City of Clearwater" on Justia Law

An activist who sought to distribute leaflets at two adjoining privately owned shopping centers in California was denied permission by the centers' owners, who maintained a policy prohibiting expressive activity, including leafletting, on their property. The activist’s leaflets promoted his views on men’s reproductive rights and invited the public to attend related meetings. After his requests to leaflet were repeatedly denied, he brought suit, arguing that the centers' blanket ban on expressive activity violated the California Constitution’s liberty of speech provision. He also challenged a section of the centers’ code of conduct that required prior written permission for noncommercial expressive activity, asserting that it granted management unfettered discretion.The Superior Court of Los Angeles County found that a blanket ban on leafletting was unconstitutional and that the balance of harms favored the plaintiff. However, the court denied the activist’s motion for a preliminary injunction, concluding he was unlikely to prevail on the merits. The court reasoned that his deposition testimony limited his challenge to leafletting near store entrances—areas not considered public fora under California precedent—and further found that his leaflets constituted unlicensed legal advice, which it deemed unprotected speech.The California Court of Appeal, Second Appellate District, Division One, reversed. The appellate court held that the plaintiff had standing to bring a facial challenge to the centers' expressive activity ban, regardless of whether his own speech was constitutionally protected, and that his challenge was not limited to store entrances. The court determined that the centers' total ban on expressive activity in common areas was unconstitutional under Robins v. Pruneyard Shopping Center and subsequent California Supreme Court authority. It also found the centers’ permitting requirement invalid for lacking objective criteria. The appellate court directed the trial court to grant a preliminary injunction, allowing the centers to impose reasonable time, place, and manner restrictions but not to prohibit expressive activity entirely. View "Salazar v. Majestic Realty Co." on Justia Law

Four Arizona voters, each residing in a different geographic voting district, challenged the constitutionality of the statute governing the retention election process for Arizona Court of Appeals judges. The statute, A.R.S. § 12-120.02, divides the state into four geographic voting districts, limiting which voters may participate in the retention elections for particular appellate judges. The plaintiffs argued that, because Court of Appeals judges have statewide precedential authority, all Arizona voters should be permitted to participate in their retention elections. They alleged that the district-based system violated both the Free and Equal Elections Clause and the Equal Privileges and Immunities Clause of the Arizona Constitution.In the Superior Court in Maricopa County, the State moved to dismiss the complaint, raising arguments including lack of standing and the constitutionality of the statute. The superior court granted the motion to dismiss. It found that § 12-120.02 did not violate the Free and Equal Elections Clause because there was no complete denial of the right to vote, and that the Constitution’s design did not require statewide participation in all judicial retention elections. The court also rejected the Equal Privileges and Immunities Clause claim, holding that the statute treated all similarly situated voters within each district equally, and no class was treated differently from another similarly situated class.On direct review, the Supreme Court of the State of Arizona affirmed the superior court’s dismissal. The court held that the Free and Equal Elections Clause is only implicated where there is a complete denial of the right to vote or unequal weighting of votes, neither of which were present here. It also held that the one-person, one-vote principle does not apply to judicial retention elections. Regarding the Equal Privileges and Immunities Clause, the court found that all voters within each geographic district are treated equally, so the statute did not violate the state constitution. View "KNIGHT v FONTES" on Justia Law