Justia Constitutional Law Opinion Summaries

Alexander William Santiago was convicted of production and possession of child pornography and sentenced to 240 months and 120 months imprisonment, respectively, to run consecutively. Santiago appealed, arguing that the district court erred in denying his motion to suppress evidence obtained from his iPhone. The iPhone was initially searched under a state search warrant, which Santiago claimed was impermissibly broad, and later under a federal search warrant that relied on the results of the state search.The United States District Court for the Western District of Oklahoma denied Santiago's motion to suppress, finding that the state search warrant failed the Fourth Amendment’s particularity requirement but applied the good faith exception to the exclusionary rule. The court did not address whether there was probable cause for the federal search warrant absent the state search results. Santiago was subsequently found guilty by a jury and sentenced.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court agreed with Santiago that the state search warrant was overbroad and violated the Fourth Amendment’s particularity requirement. The court held that the good faith exception did not apply because no reasonable officer could rely on such a warrant. Consequently, the evidence obtained from the state search should be suppressed.The court also examined the federal search warrant, determining that without the tainted evidence from the state search, the affidavit did not establish probable cause to search Santiago’s iPhone for child pornography. Therefore, the evidence from the federal search was also suppressed.The Tenth Circuit reversed the district court’s denial of Santiago’s motion to suppress, vacated his conviction and sentence, and remanded the case for further proceedings consistent with its opinion. View "United States v. Santiago" on Justia Law

In 1982, William Clark was convicted of eight counts of sexual intercourse without consent and was designated a dangerous offender, receiving a 30-year prison sentence for each count, to run concurrently. After being paroled, Clark sought relief from the sex offender registration requirement in 2005, which was denied by the district court. The court found that Clark was not eligible for relief under the 2005 Sexual and Violent Offender Registration Act (SVORA) because the victim was compelled to submit by force. This decision was affirmed on appeal.Clark again petitioned for relief in 2024, citing the Montana Supreme Court's decision in State v. Hinman, which held that the 2007 SVORA amendments were punitive and could not be applied retroactively. The State opposed, arguing that Clark remained subject to the 2005 SVORA requirements, which mandated lifetime registration. The Ninth Judicial District Court denied Clark's petition, maintaining that he must continue to register for life under the 2005 SVORA.The Montana Supreme Court reviewed the case and agreed with the lower court's decision. The Court held that the 2005 SVORA, which was determined to be a civil regulatory scheme and not punitive, could be applied retroactively. Since Clark's offenses occurred before the 2007 amendments, he remained subject to the 2005 SVORA, which required lifetime registration due to the nature of his offense involving force. The Court affirmed the district court's decision, concluding that there was no violation of the prohibition against ex post facto laws. View "Clark v. State" on Justia Law

Leslie Dean Ernst pleaded guilty to five felony counts of Privacy in Communications in violation of Montana law. He later sought to withdraw his guilty pleas and reduce two of the felony convictions to misdemeanors, which the District Court denied. Ernst appealed the decision.The Thirteenth Judicial District Court initially sentenced Ernst to 25 years in prison with a 15-year parole restriction. Ernst appealed, and the case was remanded for resentencing due to a missing transcript. Before resentencing, Ernst moved to withdraw his guilty pleas, arguing that the statute under which he was convicted was unconstitutional based on a prior court decision. The District Court denied his motion, finding that Ernst had not shown his prior convictions were unconstitutional. Ernst was resentenced to the same 25-year term with a 15-year parole restriction.The Supreme Court of the State of Montana reviewed the case. The court held that Ernst was charged, convicted, and sentenced under the constitutional portion of the Privacy in Communications statute. The court found that the charging documents, plea agreement, and sentencing did not rely on the unconstitutional prima facie provision. The court also determined that Ernst's guilty plea colloquy was sufficient to establish his intent to harass, annoy, or offend his victims, as required by the statute.Additionally, the court held that Ernst failed to provide direct evidence that his prior convictions were unconstitutional. The presumption of regularity attached to his prior convictions, and Ernst did not meet his burden to show they were invalid. Consequently, the court affirmed the District Court's denial of Ernst's motions and upheld his sentence. View "State v. Ernst" on Justia Law

Registered Missouri voters Raymond McCarty, Daniel Shaul, Russell Lahl, and Michael Hastings, along with several nonprofit organizations, contested the results of the November 2024 election approving Proposition A. They argued that the summary statement and fiscal note summary for Proposition A were misleading, casting doubt on the election's fairness and validity. Proposition A proposed increasing the minimum wage, adjusting it based on the Consumer Price Index, requiring paid sick leave, and exempting certain entities.The Missouri Supreme Court reviewed the case. The lower courts had not previously reviewed this specific election contest. The plaintiffs brought the case directly to the Missouri Supreme Court, which has original jurisdiction over election contests under chapter 115 of the Missouri statutes.The Missouri Supreme Court held that the summary statement and fiscal note summary for Proposition A were not misleading or materially inaccurate. The court found that the summary statement fairly and impartially summarized the central features of Proposition A, and the fiscal note summary adhered to statutory requirements by focusing on governmental costs. The court concluded that there was no election irregularity of sufficient magnitude to cast doubt on the election's validity. Additionally, the court dismissed the plaintiffs' claims that Proposition A violated the "single subject" and "clear title" requirements of the Missouri Constitution, citing a lack of original jurisdiction over these claims. The court upheld the election results, affirming the validity of Proposition A. View "McCarty v. Secretary of State" on Justia Law

Sonya Kenette Brown, a City Council member in Albion, Michigan, was prosecuted for allegedly violating a City Charter provision that prohibits council members from directing the appointment or removal of city employees. Brown claimed that her political opponents on the City Council engaged in retaliatory prosecution and arrest, malicious prosecution, and conspiracy to violate her civil rights. She also challenged the constitutionality of the City Charter provision.The United States District Court for the Western District of Michigan dismissed Brown's claims of retaliatory prosecution and arrest, malicious prosecution, and conspiracy, finding that there was probable cause for her prosecution based on her Facebook messages. The court also granted summary judgment to the defendants on Brown's claim that the City Charter provision was unconstitutional.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of Brown's claims, agreeing that there was probable cause for her prosecution. The court found that Brown's Facebook messages provided sufficient evidence to believe she had violated the City Charter by directing the removal of a city employee. The court also held that the City Charter provision was not unconstitutionally vague or overbroad, as it provided clear standards and did not prohibit a substantial amount of protected speech.The Sixth Circuit concluded that Brown's claims failed because she could not demonstrate an absence of probable cause, and the City Charter provision was constitutionally valid. The court affirmed the district court's judgment in favor of the defendants. View "Brown v. City of Albion, Mich." on Justia Law

Adolfo Acevedo Ibarra, a Mexican citizen, entered the United States illegally and used the identity of a U.S. citizen, Raul Cabrera, to obtain various documents and benefits fraudulently. He was detained in 2014 for using a fraudulent Social Security number and later pleaded guilty to illegal entry. The Department of Homeland Security initiated removal proceedings against him, and Ibarra admitted to the allegations and agreed he was removable. He sought cancellation of removal, arguing that his removal would cause hardship to his four U.S.-citizen children. However, the immigration judge denied his application, citing his lack of good moral character due to his fraudulent activities.The Board of Immigration Appeals (BIA) affirmed the immigration judge's decision, agreeing that Ibarra's significant negative criminal history, including fraud, outweighed any evidence of good character. Ibarra then petitioned for review, claiming that his Fifth Amendment rights were violated during the removal hearing when his attorney's attempts to assert the privilege against self-incrimination were overruled.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that substantial evidence supported the immigration judge's finding that Ibarra lacked good moral character. The court noted that Ibarra's fraudulent activities, even without a conviction, justified the finding under the catchall provision of 8 U.S.C. § 1101(f). The court also rejected Ibarra's Fifth Amendment claim, stating that the privilege against self-incrimination must be asserted by the individual, not their attorney, and that Ibarra continued to testify without asserting the privilege himself.The Fourth Circuit denied Ibarra's petition for review, upholding the BIA's decision to deny cancellation of removal based on the substantial evidence of his lack of good moral character and rejecting his Fifth Amendment claims. View "Ibarra v. Bondi" on Justia Law

Anthony Unocic, while incarcerated in a Nebraska detention center, told two fellow inmates that he wanted to kill a federal agent named Tubbs who had investigated him. Unocic's threats were taken seriously by the inmates because he bragged about a previous violent standoff with police, demonstrated stabbing techniques, and mentioned using explosives. The inmates reported the threats to federal agents, leading to Unocic being charged with one count of threatening to assault a federal officer under 18 U.S.C. § 115(a)(1)(B) and (c)(1).Unocic pleaded not guilty, and the case went to trial in the United States District Court for the District of Nebraska. The district court instructed the jury on the elements required to convict Unocic, including that he either knew or intended that others would regard his communication as threatening violence, or recklessly disregarded a substantial risk that others could regard his communication as threatening violence. The jury found Unocic guilty, and he was sentenced to thirty-three months' imprisonment.On appeal to the United States Court of Appeals for the Eighth Circuit, Unocic argued that the district court erred by including the term "carelessly" in the definition of "recklessly disregards" in the jury instructions. He claimed this allowed the jury to convict him for speech protected by the First Amendment. The Eighth Circuit reviewed for plain error and concluded that, taken as a whole, the jury instructions did not mislead the jury to convict Unocic based on an incorrect standard. The court found no obvious error and affirmed the district court's judgment. View "United States v. Unocic" on Justia Law

Lathfield Investments, LLC, Lathfield Holdings, LLC, and Lathfield Partners, LLC (collectively, "Lathfield") own three commercial buildings in Lathrup Village, Michigan, rented to various commercial tenants. The City of Lathrup Village and its Downtown Development Authority (collectively, the "City") require landlords to obtain a rental license and list each tenant's name and principal business. Lathfield applied for a landlord rental license in July 2020 but did not list the required tenant information, leading to the denial of their application and their tenants' business license applications. Lathfield sued the City, alleging unlawful compulsion to apply for unnecessary licenses and make unnecessary property improvements, bringing eleven claims, nine against the City.The United States District Court for the Eastern District of Michigan granted summary judgment to the City on all nine claims. Lathfield appealed, arguing that the City improperly required site plan approval, violated due process and equal protection rights, and engaged in inverse condemnation, among other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Lathfield's request for declaratory relief regarding site plan approval was moot since the site plan process was already completed. The court also found that Lathfield was required to obtain a general business license under the City Code and that the City Code's tenant registration requirement applied to Lathfield. The court rejected Lathfield's due process claims, noting that the City’s adoption of the Michigan Building Code was a legislative act not subject to procedural due process requirements. The court also dismissed Lathfield's equal protection claim due to a lack of evidence of differential treatment and found no basis for the Contracts Clause claim under 42 U.S.C. § 1983. Lastly, the court concluded that Lathfield failed to establish an inverse condemnation claim or a civil conspiracy. View "Lathfield Investments, LLC v. City of Lathrup Village, Mich." on Justia Law

Two detectives from the Lowell police department, while investigating a home invasion in Lowell, Massachusetts, crossed into Nashua, New Hampshire, to speak with the defendant. During the conversation, one detective suspected the defendant was deleting data from his cell phone and seized it without a warrant. The detectives then brought the phone back to Massachusetts and obtained a warrant to search it.In the Superior Court, the defendant moved to suppress the evidence obtained from the cell phone, arguing that the seizure was unlawful. The motion judge allowed the motion, finding that the Lowell detectives had no authority to seize the phone in New Hampshire. The Commonwealth sought an interlocutory appeal, which was allowed by a single justice of the Supreme Judicial Court for the county of Suffolk. The case was then transferred to the Supreme Judicial Court on its own initiative.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the Lowell detective did not have extraterritorial authority to seize the cell phone in New Hampshire. The court found that no statutory or common law authority permitted the warrantless seizure in these circumstances. The court also rejected the Commonwealth's argument that the evidence would have been inevitably discovered, as this theory was not sufficiently supported by the record. The court held that suppression of the evidence was the appropriate remedy to deter police misconduct and preserve judicial integrity. The order allowing the motion to suppress was affirmed. View "Commonwealth v. McCarthy" on Justia Law

Davion Rivers was convicted of possessing a firearm as a convicted felon and sentenced to 188 months in prison. Rivers appealed, arguing that the district court erred in denying his motions to suppress evidence and in sentencing him under the Armed Career Criminal Act (ACCA) without a jury determining whether his prior offenses occurred on different occasions.The district court denied Rivers's motions to suppress the firearm found on his person and a spent shotgun shell from his residence. The court found that the officers' approach to Rivers's residence was lawful under the knock-and-talk exception and that the search warrant for the residence was supported by probable cause. Rivers was convicted by a jury, and the district court applied the ACCA enhancement based on Rivers's prior drug offenses, finding that they occurred on different occasions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed Rivers's conviction, finding no error in the denial of the suppression motions. The court held that the officers' approach to the residence was lawful and that the search warrant was supported by probable cause.However, the court vacated Rivers's sentence under the ACCA, citing the Supreme Court's decision in Erlinger v. United States, which requires that a jury, not a judge, must determine whether prior offenses occurred on different occasions. The court found that the district court's judicial fact-finding violated Rivers's constitutional rights and that the error was not harmless beyond a reasonable doubt. The case was remanded for resentencing consistent with the Supreme Court's ruling in Erlinger. View "United States v. Rivers" on Justia Law