Justia Constitutional Law Opinion Summaries

Arthur Lee Henderson appealed the judgment entered after the Superior Court of Los Angeles County granted his petition for resentencing under Penal Code section 1170.95 (now section 1172.6) concerning his attempted murder conviction. The court resentenced him on his remaining convictions for murder (with a felony-murder special-circumstance finding) and attempted robbery, imposing a life without the possibility of parole (LWOP) sentence. Henderson argued that the application of section 1385.1, which restricted the court's discretion to strike the felony-murder special circumstance, violated the ex post facto clauses of the California and United States Constitutions.The Superior Court of Los Angeles County initially sentenced Henderson in 1988 to LWOP for first-degree murder, plus additional terms for attempted murder and attempted robbery. Henderson's petition for resentencing was partially granted, leading to the dismissal of his attempted murder conviction. However, the court maintained the LWOP sentence for the murder conviction, citing section 1385.1, which prohibits striking special circumstances in first-degree murder cases.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court held that the application of section 1385.1 at Henderson's 2023 resentencing did not violate ex post facto principles. The court reasoned that the resentencing under section 1172.6 was an act of legislative lenity, not a new criminal prosecution, and Henderson's new sentence was no more severe than the punishment prescribed at the time of his crimes. The court also found that the law of the case doctrine barred reconsideration of Henderson's petition for resentencing as to his murder conviction, as the Supreme Court's decision in People v. Curiel did not constitute a significant change in the law regarding direct aider and abettor liability.The Court of Appeal affirmed the judgment, directing the Superior Court to correct the abstract of judgment to reflect the oral pronouncement of judgment accurately. View "People v. Henderson" on Justia Law

A Massachusetts law prohibits the sale, transfer, or possession of assault weapons and large capacity feeding devices. Joseph R. Capen, a Massachusetts resident, and the National Association for Gun Rights challenged the law, claiming it violates the Second Amendment. They sought a declaratory judgment and preliminary and permanent injunctions against the law's enforcement.The U.S. District Court for the District of Massachusetts denied the motion for a preliminary injunction, concluding that the plaintiffs could not demonstrate a likelihood of success on the merits of their claims. The court found that the law is consistent with the nation's historical tradition of regulating dangerous and unusual weapons, which are not typically used for self-defense. The court also found that the law's restrictions on large capacity magazines are supported by historical precedents of regulating items that pose a significant public safety threat.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the Massachusetts law's restrictions on assault weapons, specifically the AR-15, are consistent with historical regulations that aimed to protect public safety by restricting particularly dangerous weapons. The court also found that the law's restrictions on large capacity magazines are supported by historical analogues and do not impose a significant burden on the right to self-defense. Therefore, the plaintiffs are unlikely to succeed on the merits of their claims, and the district court did not abuse its discretion in denying the preliminary injunction. View "Capen v. Campbell" on Justia Law

Jewels Helping Hands and Ben Stuckart challenged a proposed initiative by Spokane resident Brian Hansen, which aimed to expand the criminalization of camping within 1,000 feet of schools, parks, and childcare facilities. The initiative was a response to increased crime rates near a homeless encampment called Camp Hope. Spokane had previously adopted a comprehensive ordinance regulating public camping, which included provisions to comply with the Ninth Circuit's Martin v. City of Boise decision, barring criminalization of camping when no shelter space was available.The trial court ruled that the plaintiffs had standing but found their claims without merit, allowing the initiative to proceed to the ballot. The Court of Appeals affirmed, holding that the initiative was within the scope of the local initiative power, not a zoning ordinance, did not conflict with state law, and was legislative rather than administrative.The Washington Supreme Court reviewed the case and disagreed with the lower courts. It held that the initiative was impermissibly administrative because it modified the details of Spokane's preexisting comprehensive policy on public camping. The court emphasized that local initiatives must be legislative in nature, creating new policies rather than administering existing ones. The court reversed the lower courts' decisions, ruling that the initiative exceeded the scope of the local initiative power. View "Jewels Helping Hands v. Hansen" on Justia Law

A student, C.S., transferred from one high school to another within the Fort Smith School District and was rendered ineligible to participate in sports for one year due to the district's policy on intradistrict transfers. This policy contrasts with the immediate eligibility granted to students transferring from outside the district. Vincent Standridge, C.S.'s father, challenged this policy, arguing it violated state law, equal protection, parental rights, and constituted an abuse of power.The Sebastian County Circuit Court dismissed Standridge's complaint, holding that the policy did not violate Arkansas Code subsection 6-18-1904(f), which the court interpreted as applying only to interdistrict transfers. The court also found no constitutional violations or abuse of power.The Supreme Court of Arkansas reviewed the case and reversed the circuit court's decision in part. The Supreme Court held that Arkansas Code subsection 6-18-1904(f) applies to both intra- and interdistrict transfers, thus prohibiting the district's policy of excluding intradistrict transfer students from sports based solely on their transfer status. The court remanded the case for entry of judgment in Standridge's favor on this statutory claim.However, the Supreme Court affirmed the circuit court's dismissal of Standridge's equal protection, parental rights, and abuse of power claims. The court found that the district's policy had a rational basis and did not violate equal protection. It also held that there is no constitutional right to participate in sports and that the policy did not interfere with parental rights. The court concluded that there is no recognized claim for "abuse of power" in this context.The Supreme Court directed the clerk to issue the mandate immediately to allow C.S. to participate in extracurricular activities before the end of the spring semester. View "STANDRIDGE V. FORT SMITH PUBLIC SCHOOLS" on Justia Law

A juvenile was found delinquent on firearm charges and guilty on a youthful offender indictment for one of the offenses. At the trial, the juvenile was nineteen years old, and the Commonwealth called his mother to testify about events that occurred when he was seventeen. The juvenile argued that the parent-child witness disqualification statute, which prohibits testimony by a parent against their minor child, should have precluded his mother's testimony even though he was no longer a minor at the time of trial. He also claimed that the trial judge made several errors in admitting other evidence and that his sentence was unlawful and unconstitutional.The juvenile was charged in a delinquency complaint with possession of a firearm without a firearm identification card, unlawful possession of a large capacity feeding device, and improper storage of a firearm. He was subsequently indicted as a youthful offender for the large capacity feeding device charge. The juvenile filed a motion to prevent the Commonwealth from calling his mother as a witness, invoking the parent-child witness disqualification statute. The motion judge denied the motion, reasoning that the statute applied only to testimony against a minor child, and the juvenile was no longer a minor.The Supreme Judicial Court of Massachusetts reviewed the case and agreed with the trial judge's interpretation that the statutory prohibition of testimony by a parent against their minor child does not apply once the child has reached the age of eighteen. The court found no prejudicial error in the admission of other evidence, although it concluded that the judge should not have admitted a detective's testimony that a firearm depicted in still images was "identical" to the firearm admitted in evidence, nor two hearsay statements. Regarding the juvenile's sentence, the court agreed that the judge erred in not issuing written findings explaining the sentence but concluded that this error did not prejudice the juvenile. The court affirmed the juvenile's delinquency and youthful offender adjudications and declined to vacate his sentence. View "Commonwealth v. Rajiv R." on Justia Law

Carlos and Ana Carachure filed a lawsuit against the City of Azusa, claiming the City violated article XIII D of the California Constitution by charging sewer and trash franchise fees that exceeded the cost of providing those services and using the fees to fund general city services. The City argued that the Carachures failed to exhaust their administrative remedies because they did not follow the statutory procedures for a refund, which require paying the fees under protest and filing a claim for a refund. The trial court agreed with the City and entered judgment in its favor.The Superior Court of Los Angeles County ruled that the Carachures were required to file a claim for a refund with the City before seeking judicial relief, as they claimed the fees were illegally collected or assessed. The court denied the Carachures' petition for a writ of mandate and entered judgment for the City. The Carachures filed a motion for a new trial and to vacate the judgment, arguing the trial court relied on inapplicable property tax cases and the current version of the Revenue and Taxation Code. The trial court denied the motion.The Court of Appeal of the State of California, Second Appellate District, Division Seven, reviewed the case and reversed the trial court's judgment. The appellate court held that the Carachures' constitutional challenge to the City's collection and use of franchise fees seeks relief outside the scope of the statutory claims procedure for refunds. The court concluded that the Carachures did not have to file a claim for a refund before bringing this action, as their challenge was not an action for a refund governed by section 5472 and Article 2 of the Revenue and Taxation Code. The judgment was reversed, allowing the Carachures to proceed with their constitutional claims. View "Carachure v. City of Azusa" on Justia Law

In 2015, the Missouri General Assembly enacted sections 67.287 and 479.359.2, which imposed certain standards and revenue caps on municipalities, specifically targeting St. Louis County. The City of Normandy and other municipalities challenged these statutes, claiming they violated the Missouri Constitution's prohibition against local or special laws. In 2016, the Circuit Court of Cole County declared these sections unconstitutional and issued a permanent injunction against their enforcement. The Missouri Supreme Court affirmed this decision in City of Normandy v. Greitens.Following a shift in legal analysis in City of Aurora v. Spectra Communications Group, LLC, the state sought relief from the 2016 injunction, arguing that the statutes would have survived under the new rational basis review. The circuit court initially granted this relief, but the Missouri Supreme Court vacated that judgment in City of Normandy v. Parson, remanding the case for further proceedings. On remand, the circuit court overruled the state's motion for partial relief from the judgment.The Missouri Supreme Court reviewed the case and affirmed the circuit court's decision. The court held that the change in legal analysis from City of Aurora did not automatically warrant relief from the permanent injunction under Rule 74.06(b)(5). The court emphasized the importance of finality in judgments and found that the state did not demonstrate sufficient inequity to justify lifting the injunction. The court also noted that the state had not sought relief from the declaratory judgment that the statutes were unconstitutional, which remained in effect. Therefore, the circuit court did not abuse its discretion in denying the state's motion for relief. View "City of Normandy v. Kehoe" on Justia Law

The State of Oklahoma moved to terminate a mother's parental rights due to her methamphetamine addiction and failure to provide a stable environment for her child. The child was placed in emergency custody in May 2022, and the mother entered and left multiple inpatient treatment programs without completing them. The State filed a motion to terminate her parental rights in April 2023, and a jury trial was set for August 2023. The mother failed to appear for the trial, and her attorney requested a continuance, which was denied. The trial court held a nonjury trial and terminated her parental rights.The mother appealed the decision, and the Court of Civil Appeals, Division III, affirmed the trial court's ruling. The mother argued that the statute allowing the trial court to deem her failure to appear as a waiver of her right to a jury trial was unconstitutional. The Court of Civil Appeals did not substantively address this constitutional claim.The Supreme Court of the State of Oklahoma reviewed the case and found that the statute in question is constitutional. However, the court emphasized that due process requires that the record must reflect that the parent received notice of the possible consequences of failing to appear for the jury trial. The court vacated the Court of Civil Appeals' opinion and remanded the case to the trial court for an evidentiary hearing to determine whether the mother had received sufficient notice. The trial court is to hold the hearing within 30 days and submit findings of fact and conclusions of law to the Supreme Court within 15 days after the hearing. View "IN THE MATTER OF FB v STATE OF OKLAHOMA" on Justia Law

A class of incarcerated juvenile offenders in Florida, all sentenced to life in prison with the possibility of parole under a now-defunct sentencing scheme, sued the Commissioners of the Florida Commission on Offender Review. They claimed that the parole system violated the Eighth Amendment's prohibition against cruel and unusual punishment and the Fourteenth Amendment's due process rights. The plaintiffs argued that the parole system did not provide a meaningful opportunity for release based on demonstrated maturity and rehabilitation.The United States District Court for the Middle District of Florida granted summary judgment to the Commissioners, dismissing the plaintiffs' claims. The court found that Florida's parole system did not violate the Eighth Amendment or the Fourteenth Amendment's Due Process Clause. The plaintiffs appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Florida's parole system does not violate the Eighth Amendment for either homicide or non-homicide juvenile offenders. For homicide offenders, the system is not a sham and provides a genuine possibility of parole, satisfying the requirements set forth in Miller v. Alabama. For non-homicide offenders, the system offers a meaningful opportunity for release based on demonstrated maturity and rehabilitation, as required by Graham v. Florida.Regarding the due process claim, the court concluded that the plaintiffs did not have a constitutionally protected liberty interest in parole under either state law or the Eighth Amendment. Therefore, their procedural due process claim failed. The Eleventh Circuit affirmed the district court's grant of summary judgment to the Commissioners. View "Howard v. Coonrod" on Justia Law

Matthew Morrison was convicted of a sexually violent offense and sentenced to prison. Before his release, the Santa Clara County District Attorney filed a petition to commit him as a sexually violent predator under the Sexually Violent Predator Act (SVPA). The trial court found the petition true, declared Morrison a sexually violent predator, and committed him to the State Department of State Hospitals for an indeterminate term.Morrison appealed, arguing that the trial court violated his constitutional rights by not personally advising him of his right to a jury trial and securing a personal waiver of that right. He claimed that the SVPA’s failure to require a personal jury trial advisement and waiver, unlike other civil commitment statutes, violated the constitutional equal protection guarantee.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court determined that Morrison’s equal protection challenge was subject to rational basis review. Since Morrison did not raise the issue in the trial court, the appellate court conditionally affirmed the commitment order and remanded the matter to allow Morrison to raise his equal protection claim before the trial court. The appellate court provided guidance on the principles the trial court should apply when resolving Morrison’s constitutional claim. View "P. v. Morrison" on Justia Law