Justia Constitutional Law Opinion Summaries

Renton police and SWAT officers executed a search warrant at the apartment where Cristian Magaña Arévalo was staying with his family, seeking evidence related to the murder of Jason Hobbs. Officers ordered everyone out using a bullhorn, separated Magaña Arévalo from his family, restrained him with zip ties, and placed him in a patrol car before transporting him to a nearby parking lot. There, he was transferred to an officer’s work truck and questioned about Hobbs’s murder without receiving Miranda warnings. The officer told him he was “not under arrest” and asked if he would talk, which Magaña Arévalo agreed to. Two days later, he was interviewed again in a noncustodial setting, also without Miranda warnings.In King County Superior Court, Magaña Arévalo moved to suppress both statements, arguing the first was obtained during a custodial interrogation without Miranda warnings and the second was tainted by the initial violation. The court held a CrR 3.5 hearing and ruled both statements admissible, finding neither interrogation custodial or coerced. The jury convicted Magaña Arévalo of first degree murder, and the court sentenced him to prison. On appeal, the Washington Court of Appeals found the December 1 interrogation was custodial and that admitting the statement was error, but held the error was harmless beyond a reasonable doubt because of other strong evidence, including the December 3 statement and physical evidence.The Supreme Court of the State of Washington reviewed both parties’ petitions. It held that considering the totality of the circumstances—including restraints, isolation, police presence, and ethnicity—Magaña Arévalo was in custody during the December 1 interrogation, and admitting his statement without Miranda warnings violated his constitutional rights. However, the court found the December 3 statement was voluntary, noncustodial, and not tainted by the earlier violation. Applying a clarified harmless error standard, the court affirmed the Court of Appeals, holding the constitutional error was harmless beyond a reasonable doubt. View "State v. Magana-Arevalo" on Justia Law

Ajay, a recent immigrant from India with limited English proficiency, was investigated for alleged sexual assault and attempted sexual assault against a child under 14 in Reno, Nevada. The accusations stemmed from an incident involving a 13-year-old boy, A.P., whom Ajay met at his workplace and with whom he allegedly engaged in sexual acts. During a custodial police interrogation, Detective DeSantis read Ajay his Miranda rights in English. Ajay repeatedly expressed confusion, stated he was not good in English, and requested to speak in Hindi or have an interpreter. Despite this, DeSantis continued explaining the rights in English, using props and hypotheticals, until Ajay acquiesced and the interrogation proceeded, resulting in a confession.Ajay moved to suppress his statements before the Second Judicial District Court, Washoe County, arguing he had not knowingly and intelligently waived his Miranda rights due to his limited English proficiency. At a pretrial hearing, Ajay testified through an interpreter, detailing his lack of formal English education and unfamiliarity with the American legal system. The district court denied his motion, finding the waiver valid and voluntary, citing DeSantis’s efforts to clarify the warnings and Ajay’s apparent understanding.On appeal, the Supreme Court of Nevada reviewed whether Ajay’s Miranda waiver was knowing and intelligent. The court found that Ajay's limited English skills and explicit requests for an interpreter demonstrated he did not understand his rights. The court held that law enforcement must recognize when a language barrier prevents meaningful waiver and provide an interpreter as necessary. The district court’s admission of Ajay’s confession was not harmless beyond a reasonable doubt given its significance at trial. Therefore, the Supreme Court of Nevada reversed the conviction and remanded for further proceedings. View "Ajay v. State" on Justia Law

Anthony Lee was accused of assaulting Amy Groff at his home near Sequim, Washington. After an evening spent together, Lee became angry with Groff, allegedly due to her drug use, theft, and verbal abuse. When they returned home, Lee reportedly fired a gun in the air, struck Groff in the head with the gun, pushed her out of his truck, kicked and hit her, and then shot at her as she ran away. Groff was later found by police with visible injuries and recounted the assault to officers.Lee was charged in the Clallam County Superior Court with two counts of second degree assault with a deadly weapon, each based on separate alleged acts: one for beating Groff with the gun and another for shooting at her. At trial, the judge admitted Groff’s statements to police under the excited utterance exception to hearsay, and instructed the jury not to consider any judicial comments as opinions on the evidence. The jury found Lee guilty on both counts, and the trial court determined the assaults were distinct acts, rejecting Lee’s double jeopardy argument. Lee appealed, raising the double jeopardy issue and, for the first time, challenging the trial judge’s comment on the evidence. The Washington Court of Appeals affirmed both convictions, finding no double jeopardy violation and no manifest constitutional error regarding the judicial comment.The Supreme Court of the State of Washington reviewed the case and held that, under the unit of prosecution analysis and considering all relevant factors, Lee’s assaultive acts constituted a single course of conduct. Therefore, two convictions for second degree assault violated double jeopardy principles. The court reversed on that issue, ordering one conviction and its firearm enhancement to be vacated. On the comment on the evidence issue, the court affirmed, finding no manifest constitutional error that would permit review for the first time on appeal. View "State v. Lee" on Justia Law

On the evening of April 12, 2022, Ralph Kinerson was stabbed following a physical altercation at his home. Both Kinerson and Barclay Dylan Bennett testified that they fought that night, but their accounts differed regarding the circumstances and who initiated the violence. Kinerson claimed Bennett attacked him at his home, while Bennett asserted that Kinerson assaulted him in the street, aided by others, and denied stabbing Kinerson. The police interviewed witnesses, including Kinerson’s neighbor and Kinerson’s daughter, Malea, whose statements became central to the subsequent trial.During trial in the Spokane County Superior Court, Bennett was charged with first degree assault. Bennett’s defense focused on alleged deficiencies in the police investigation, suggesting that officers failed to consider other suspects. On cross-examination, Bennett introduced portions of Malea’s interview with a detective to support this theory, referencing statements about another woman, Abbey Pearson, possibly stealing from Kinerson. In response, the State introduced another part of Malea’s interview, which suggested Bennett had a motive to attack Kinerson due to his relationship with Kinerson’s friend, Roberts. Bennett objected on hearsay and Sixth Amendment grounds, arguing he could not confront Malea, who was unavailable to testify. The trial court overruled the objection, finding Bennett had “opened the door” to the evidence.The Washington Court of Appeals affirmed Bennett’s conviction, concluding that any error in admitting the hearsay was invited by Bennett’s own actions and precluded review, even for constitutional claims. The Supreme Court of the State of Washington affirmed the appellate decision, holding that the statement’s admission was justified under the rule of completeness (ER 106). The Court found the statement was not offered for its truth but to contextualize the investigation, so it did not trigger the confrontation clause. Bennett’s conviction was upheld. View "State v. Bennett" on Justia Law

After filing a federal discrimination lawsuit against her former employer, which was dismissed, the petitioner sent emails to the employer’s counsel that led to state criminal charges for terrorizing in Cass County, North Dakota. At trial in state district court, the petitioner was convicted by a jury and sentenced to jail time with probation. During her probation, she was found to possess a firearm, resulting in revocation of probation and a new sentence.The petitioner appealed her criminal conviction to the North Dakota Supreme Court, arguing, among other things, that the State’s failure to preserve and disclose evidence constituted a Brady violation and that the evidence was insufficient to sustain her conviction. The Supreme Court affirmed her conviction. Subsequently, in the district court, the petitioner sought postconviction relief, alleging constitutional violations, lack of subject matter jurisdiction, unlawful withholding of evidence, and ineffective assistance of counsel. She also moved to disqualify the presiding judge. The district court summarily dismissed her application, finding most claims barred by res judicata or misuse of process, and denied the motion for disqualification after a hearing.On appeal, the Supreme Court of North Dakota reviewed the district court’s rulings. It held that the district court erred by summarily dismissing the ineffective assistance of counsel claim without an evidentiary hearing, as the State had not moved for summary disposition on those claims. The court reversed and remanded for an evidentiary hearing on that issue. It affirmed the dismissal of the other claims, finding the district court had subject matter jurisdiction, correctly denied the motion to disqualify the judge, and properly dismissed other claims as procedurally barred or lacking merit. The court affirmed in part, reversed in part, and remanded for further proceedings on the ineffective assistance claim. View "Pederson v. State" on Justia Law

Several individuals who were employed by the City and County of San Francisco and were at least 40 years old when hired brought a class action lawsuit alleging that the City’s method for calculating disability retirement benefits under its retirement system discriminated against employees based on age. The system employs two formulas; Formula 1 is used if it yields a benefit exceeding a percentage threshold, while Formula 2 is used if the threshold is not met. Plaintiffs argued that Formula 2, which imputes years of service until age 60, resulted in lower benefits for those who entered the retirement system at age 40 or older, in violation of the California Fair Employment and Housing Act (FEHA).After initial proceedings in the San Francisco City and County Superior Court—including a demurrer sustained on statute of limitations grounds and subsequent reversal by the Court of Appeal—the plaintiffs filed an amended complaint asserting FEHA claims for disparate treatment and disparate impact, as well as claims for declaratory relief, breach of contract, and equal protection violations. The trial court certified a class and denied summary judgment due to triable issues of fact. A bench trial followed, where both parties presented expert testimony on whether Formula 2 disparately impacted older employees.The Court of Appeal of the State of California, First Appellate District, Division Four, reviewed the trial court’s findings. It affirmed the judgment, holding that plaintiffs failed to prove intentional age discrimination or disparate impact under FEHA. The court found that Formula 2 was motivated by pension status and credited years of service, not by age, and that plaintiffs’ evidence was insufficient as it was based on hypothetical calculations rather than actual data. The trial court’s denial of plaintiffs’ request to amend their complaint after trial was also upheld, as any alleged error was not reversible on the record. The judgment in favor of the City was affirmed. View "Carroll v. City and County of San Francisco" on Justia Law

A law enforcement agency served an electronic service provider with a search warrant for data associated with an email account belonging to a university graduate student under investigation for rape. The warrant was accompanied by a nondisclosure order (NDO) prohibiting the provider from notifying the student or anyone at the university about the warrant for 90 days. The provider did not contest the restriction against notifying the account holder but sought permission to inform a trusted contact at the university about the warrant's existence, citing concerns under the California Electronic Communications Privacy Act (CalECPA) and the First Amendment.The Superior Court of Los Angeles County reviewed a sealed affidavit and found that several statutory criteria for “adverse results” under CalECPA were present, justifying the NDO. When the provider requested to modify the order to allow notification of a university contact, the court considered the proposal but ultimately declined after law enforcement objected, noting the court lacked jurisdiction over the university and could not ensure compliance with the NDO. The order was extended once and later lifted after the target was arrested. The provider’s initial petition for writ of mandate was summarily denied by the California Court of Appeal. The California Supreme Court then granted review and transferred the matter back to the appellate court for further consideration.The California Court of Appeal, Second Appellate District, reviewed the case de novo and held that the trial court made the required findings under CalECPA before issuing the NDO and that the NDO did not violate the provider’s First Amendment rights. The court found the NDO served a compelling government interest and was narrowly tailored to protect the integrity of an ongoing investigation. The petition for writ of mandate was denied. View "Microsoft Corp. v. Superior Ct." on Justia Law

Dustin Booth, who had a history of stable employment and no prior mental health issues, began exhibiting signs of severe mental illness in early 2022 after changes in his substance use. His erratic behavior escalated over several days, culminating in a violent incident at home and a lengthy standoff with police after he barricaded himself inside his house. Booth’s wife repeatedly sought police intervention, expressing concerns that he was a danger to himself and others, and noted his access to firearms. After attempts to calm Booth and persuade him to leave his house, he eventually left with a friend, taking a gun with him. Police stopped the vehicle, leading to a confrontation in which Booth brandished the firearm and was fatally shot by officers.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants on all federal claims. The district court held that the proposed accommodation under the Americans with Disabilities Act (ADA)—that officers should have used de-escalation techniques—was unreasonable due to the safety risks posed by Booth. The court further found that the officers’ actions during the traffic stop and subsequent use of force, including the deployment of a police dog and takedown maneuver, were reasonable under the Fourth Amendment. It also declined to exercise supplemental jurisdiction over the state-law claims.Upon review by the United States Court of Appeals for the Sixth Circuit, the appellate court affirmed the district court’s decision. The Sixth Circuit held that, as a matter of law, the ADA did not require officers to accommodate Booth’s disability in the face of objective safety risks. Additionally, the court found the officers had probable cause for a mental-health seizure and acted reasonably under the Fourth Amendment in both the stop and use of force. The judgment in favor of the defendants was affirmed. View "Booth v. Lazzara" on Justia Law

After receiving a report from his ex-girlfriend that he was threatening suicide and may have shot himself, law enforcement officers in Montana responded to William Case’s home. The officers were aware of Case’s mental health and substance abuse history, as well as prior threats of suicide and confrontations with police. Upon arrival, they received further details about the phone call from Case’s ex-girlfriend, observed an empty handgun holster, a notepad resembling a suicide note, and noted Case’s lack of response to their attempts at contact. Believing Case might be injured or at risk of imminent harm, the officers entered the home without a warrant to render emergency aid. During their search, Case emerged from a closet holding an object that appeared to be a gun, prompting an officer to shoot and injure him. A handgun was found near where Case had been standing.Case was charged with assaulting a police officer and moved to suppress the evidence obtained from the warrantless entry, arguing a Fourth Amendment violation. The trial court denied the motion, finding the entry justified by emergency circumstances. A Montana jury convicted Case. On appeal, the Montana Supreme Court upheld the conviction, applying its “community caretaker doctrine” and concluding that police may enter a home for a welfare check if “objective, specific and articulable facts” lead an experienced officer to suspect peril. The court rejected the argument that probable cause was required for such an entry, distinguishing emergency aid situations from criminal investigations.The Supreme Court of the United States reviewed the case to clarify the legal standard for warrantless home entry to render emergency aid. The Court held that officers may enter a home without a warrant if they have an “objectively reasonable basis for believing” that an occupant is seriously injured or imminently threatened with such injury. It declined to require probable cause in this context and affirmed the judgment of the Montana Supreme Court, finding the officers’ entry reasonable under the Fourth Amendment. View "Case v. Montana" on Justia Law

Illinois law provides that election officials must count mail-in ballots postmarked or certified no later than election day, as long as those ballots are received within two weeks after election day. Congressman Michael Bost and two other political candidates filed suit against the Illinois State Board of Elections and its executive director, asserting that counting ballots received after election day violates federal statutes that set a single election day for federal offices. The plaintiffs alleged that the challenged law would require them to expend additional campaign resources, potentially harm their reputations, and deprive them of a fair electoral process. Congressman Bost, in particular, claimed he would need to extend campaign activities and monitoring efforts for two additional weeks, incurring costs and risking a reduction in his margin of victory.The United States District Court for the Northern District of Illinois dismissed the case, concluding that the plaintiffs lacked standing. The United States Court of Appeals for the Seventh Circuit affirmed, reasoning that the injuries alleged—such as increased campaign costs and potential reputational harm—were speculative or voluntarily incurred. The Seventh Circuit emphasized that Congressman Bost had won his prior election with a significant margin and found the plaintiffs’ injuries to be neither concrete nor particularized enough to support standing.The Supreme Court of the United States reviewed the case and held that Congressman Bost, as a candidate for office, does have standing to challenge the rules governing vote counting in his election. The Court reasoned that candidates possess a concrete and particularized interest in the integrity and legality of the electoral process, which is distinct from the generalized interest of voters. The judgment of the Seventh Circuit was reversed and the case remanded for further proceedings. View "Bost v. Illinois Bd. of Elections" on Justia Law