Justia Constitutional Law Opinion Summaries

The defendant was previously convicted of murder and criminal possession of a firearm. This court reversed the murder conviction due to the prosecutor's improper comments on the defendant's post-Miranda silence, violating Doyle v. Ohio. The defendant then moved to dismiss the murder charge, arguing that double jeopardy protections barred a retrial because the prosecutor intended to prevent an acquittal that was imminent without the impropriety.The trial court denied the motion to dismiss, finding that the defendant did not establish that the prosecutor intended to prevent an acquittal. The court based its decision on the trial transcripts and this court's previous decision, which concluded that the evidence was sufficient to support the conviction. The defendant appealed, renewing his argument that the double jeopardy clause barred a retrial and asserting that the Connecticut constitution provided broader protections.The Supreme Court of Connecticut affirmed the trial court's decision. The court held that the defendant failed to demonstrate that the prosecutor engaged in impropriety with the intent to prevent an acquittal that the prosecutor believed was imminent. The court noted that the evidence at trial, although not overwhelming, was sufficient to support a conviction, and the prosecutor's actions did not indicate an intent to provoke a mistrial or prevent an acquittal. The court also declined to overrule its previous decisions in State v. Colton and State v. Michael J., maintaining that the Connecticut constitution does not provide broader double jeopardy protections than the federal constitution. View "State v. Patrick M." on Justia Law

In 1992, the defendant was sentenced to 100 years in prison for deliberate homicide, with an additional 10-year enhancement for weapon use. In 2008, he became parole eligible but was consistently denied parole. In 2018, he planned an escape from prison, involving two former prisoners. He used a cellphone to coordinate the escape, but prison staff discovered his plan and transferred him to more secure housing. Despite this, he continued to communicate with one of the former prisoners to delete incriminating evidence.The Third Judicial District Court in Powell County found the defendant guilty of Conspiracy to Commit Escape and Conspiracy to Commit Tampering With or Fabricating Physical Evidence. He was sentenced to 8 years for each count, to run concurrently but consecutively to his prior sentence. The court dismissed charges of Transferring of Illegal Articles and Solicitation to Commit Unlawful Possession of a Firearm by a Convicted Person. The defendant appealed, arguing his sentence violated his First Amendment rights and that there was insufficient evidence for the tampering conviction. He also sought pretrial credit for time served.The Supreme Court of the State of Montana reviewed the case. The court held that the defendant did not properly object to his sentence on First Amendment grounds during the trial, and thus did not preserve the issue for appeal. The court also found sufficient evidence to support the tampering conviction, as the defendant's actions demonstrated an intent to delete incriminating evidence. Lastly, the court ruled that the defendant was not entitled to pretrial credit for time served, as he was already serving a sentence for a prior conviction and was not detained specifically for the new charges. The court affirmed the lower court's decision. View "State v. Demarie" on Justia Law

In October 2022, NCIS investigators obtained a military warrant to seize but not search Joshua Lee Ray's cell phone. Despite this, they searched the phone and found evidence of child sexual abuse material. Ray moved to suppress the evidence, arguing the search violated the Fourth Amendment as the warrant did not authorize it. The district court granted the motion.The Government appealed, conceding the warrant did not authorize the search, there was no verbal authorization, and the warrant did not incorporate an affidavit requesting authorization. The Government argued the search was justified under the good faith exception.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the Government could not rely on the good faith exception because the warrant was not deficient; it simply did not authorize the search. The court emphasized that the NCIS exceeded the scope of the valid warrant, and the good faith exception did not apply to such conduct. The court affirmed the district court's decision to suppress the evidence. View "US v. Ray" on Justia Law

The National Association of Immigration Judges (NAIJ) challenged an Executive Office for Immigration Review (EOIR) policy requiring immigration judges to obtain prior approval before speaking publicly on immigration-related issues. NAIJ argued that this policy violated the First and Fifth Amendment rights of its members. The district court dismissed the case for lack of subject matter jurisdiction, concluding that the Civil Service Reform Act (CSRA) provided the exclusive remedy for such claims, requiring them to be brought through the administrative procedures established by the CSRA.The United States District Court for the Eastern District of Virginia dismissed the case, determining that the CSRA's comprehensive scheme for reviewing personnel actions against federal employees precluded the district court from exercising jurisdiction. The district court held that NAIJ's members must pursue their claims through the CSRA's administrative process, which includes review by the Merit Systems Protection Board (MSPB) and potential judicial review by the Federal Circuit.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court's decision. The Fourth Circuit held that while the CSRA generally precludes district court jurisdiction over such claims, the current functionality and independence of the MSPB and the Office of Special Counsel (OSC) were in question. The court noted that recent events, including the removal of the Special Counsel and the lack of a quorum in the MSPB, raised concerns about whether the CSRA's adjudicatory scheme was functioning as Congress intended. The Fourth Circuit remanded the case to the district court to conduct a factual inquiry into whether the CSRA continues to provide a functional and independent review process, as required for the jurisdiction-stripping scheme to apply. View "Natl Assn of Immigration Judges v. Owen" on Justia Law

Andy Nahkai was charged with two counts of abusive sexual contact with a child and one count of abusive sexual contact with a child aged 12-16, all occurring within Indian country. During the investigation, Nahkai made incriminating statements to law enforcement officers while being interviewed in an unlocked police vehicle parked outside his home. The officers did not administer Miranda warnings before the interview.The United States District Court for the District of Utah granted Nahkai’s motion to suppress the statements he made during the interview. The court concluded that the interrogation was custodial, and the statements were not voluntary under the Fifth Amendment. The court based its decision on the officers' failure to inform Nahkai that he was free to leave, the accusatory nature of the questioning, and the police-dominated atmosphere of the encounter.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that Nahkai was not in custody for purposes of Miranda v. Arizona. The court found that the totality of the circumstances did not support the conclusion that Nahkai’s freedom of action was curtailed to a degree associated with formal arrest. The court noted that Nahkai was not physically restrained, the vehicle doors were unlocked, and the questioning, although accusatory, was not unusually confrontational. The court reversed the district court’s order suppressing Nahkai’s statements and remanded the case for further proceedings. View "United States v. Nahkai" on Justia Law

Leslie Torgerson filed a lawsuit in federal district court against Roberts County, South Dakota, and several individuals, including County Sheriff Tyler Appel, County Deputies Zachary Angerhofer and Wesley Bowsher, his adopted son Ross Torgerson, and his ex-wife Terri Torgerson. Torgerson alleged violations of his substantive and procedural due process rights under the Fourteenth Amendment and civil conspiracy. He also asserted a Monell claim against the County, a state-law claim for common law battery against Ross, and a state-law intentional-infliction-of-emotional distress claim against Deputy Angerhofer, Deputy Bowsher, Ross, and Terri. These claims stemmed from a domestic dispute involving Torgerson, Ross, and Terri.The defendants moved for summary judgment on Torgerson’s claims. The United States District Court for the District of South Dakota granted the defendants' motions for summary judgment and declined to exercise jurisdiction over the remaining state-law claims. The court concluded that Torgerson failed to state a claim for a Fourteenth Amendment violation, as he did not plead that he possessed a constitutional interest that had been violated. The court also determined that Torgerson’s civil conspiracy claim failed due to the lack of a stated constitutional interest and insufficient facts showing a conspiracy. Consequently, Torgerson’s Monell claim against the County also failed. The court declined to exercise supplemental jurisdiction over the state-law claims, considering them to be purely state-related issues.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Torgerson did not suffer a deprivation of liberty as he was not charged or prosecuted for any crime, thus failing to establish a Fourteenth Amendment violation. The court also upheld the summary judgment on the civil conspiracy and Monell claims, as there was no underlying constitutional violation. Finally, the court found no abuse of discretion in the district court’s decision to decline supplemental jurisdiction over the state-law claims. View "Torgerson v. Roberts County of South Dakota" on Justia Law

Mary Doe, a social worker proceeding under a pseudonym, challenged New York’s Reproductive Health Act (RHA), arguing it violated constitutional rights. Doe sought to represent a class of viable fetuses, claiming the RHA’s decriminalization of abortion and elimination of fetal homicide laws harmed them. She also sought to amend her complaint post-judgment to include a specific fetus, "Baby Nicholas," alleging he faced harm due to the RHA.The United States District Court for the Northern District of New York dismissed Doe’s claims for lack of standing, denying her motion to be appointed as "next friend" to the fetuses, citing her lack of a significant relationship with them. The court also denied her post-judgment motion to amend the complaint, finding it futile as Baby Nicholas lacked standing.The United States Court of Appeals for the Second Circuit reviewed the case. The court agreed that the district court erred in requiring a significant relationship for next friend appointments under Federal Rule of Civil Procedure 17(c). However, it affirmed the dismissal of Doe’s claims on the grounds that she failed to identify or describe any specific member of the viable fetus class, thus failing to establish a live case or controversy under Article III.Regarding the post-judgment motion, the Second Circuit affirmed the district court’s denial, concluding that Baby Nicholas lacked standing. The court found that the alleged risks to Baby Nicholas were not imminent and traceable to the RHA, as required for standing. The potential harm from a third party was not sufficiently connected to the RHA’s provisions.The Second Circuit affirmed the district court’s judgment, maintaining the dismissal of Doe’s claims and denying the motion to amend the complaint. View "Doe v. Hochul" on Justia Law

Plaintiff-Appellant Mansoor Hamoud Hadwan, a natural-born U.S. citizen, has been stranded in Yemen for twelve years. In 2013, he visited the U.S. Embassy in Sana’a, Yemen, to apply for immigration paperwork for his children. During this visit, embassy staff retained his Consular Report of Birth Abroad (CRBA) and U.S. passport. Nine months later, the U.S. Department of State formally revoked both documents, alleging they were fraudulently obtained. Hadwan was unable to attend his hearing challenging the revocation.The United States District Court for the Southern District of New York upheld the State Department's decision to revoke Hadwan's documents. The court found that Hadwan had waived most of his arguments by not presenting them at the agency hearing, which he was not permitted to attend. The court also found that the State Department's hearing process did not violate due process requirements.The United States Court of Appeals for the Second Circuit reviewed the case and found that the State Department erred in two ways. First, the decision to uphold the revocation was arbitrary and capricious, violating the Administrative Procedure Act, because it failed to consider material, undisputed facts about Hadwan’s English literacy, which raised doubts about the reliability of his alleged confession statement. Second, the State Department violated Hadwan’s constitutional due process rights by revoking his documents without providing him an opportunity to be heard in a meaningful manner. The court reversed the district court's judgment and the State Department's decision, ordering the State Department to return Hadwan’s CRBA and expired passport so he may reapply for a new passport if he chooses. View "Hadwan v. US Dep't of State" on Justia Law

H.C. appealed an order terminating her parental rights, arguing that the Due Process Clause of the Fourteenth Amendment and public policy require the State to prove by clear and convincing evidence, or at least a preponderance of the evidence, that termination is in the best interests of the child. H.C.'s son, John, has significant medical and developmental needs, which H.C. failed to address. John was taken into custody at age two after numerous incidents of abuse and neglect. H.C. struggled with addiction, mental health issues, and was often absent from her group home. The State filed a petition to terminate H.C.'s parental rights, citing continuing CHIPS and failure to assume parental responsibility.The Milwaukee County Circuit Court found H.C. unfit and determined that terminating her parental rights was in John's best interests. The court of appeals affirmed, stating that the circuit court did not err in its discretion. However, the court of appeals also asserted that due process requires the child's best interests to be proven by a preponderance of the evidence, with the burden of proof shared by all parties.The Wisconsin Supreme Court reviewed the case and held that the best interests of the child during the dispositional phase of a TPR proceeding constitute a discretionary determination by the circuit court, with no burden of proof placed on any party. The court concluded that neither the Due Process Clause nor applicable statutory law imposes a burden of proof during the dispositional phase. The court affirmed the decision of the court of appeals, agreeing that the circuit court committed no error in terminating H.C.'s parental rights but rejected the court of appeals' due process analysis. View "State v. H. C." on Justia Law

A group of landlords and property owners in New York's Hudson Valley region challenged the constitutionality of the 2023 amendments to New York's rent stabilization law. These amendments, known as the Vacancy Provisions, allow municipalities to impose civil penalties on landlords who do not cooperate with vacancy surveys and to presume zero vacancies for nonresponsive landlords. The landlords argued that these provisions authorize warrantless searches of their records without an opportunity to challenge the searches' scope, violating the Fourth Amendment, and that they prevent landlords from contesting vacancy calculations, violating procedural due process under the Fourteenth Amendment.The United States District Court for the Northern District of New York denied the landlords' motion for a preliminary injunction and dismissed their complaint for failure to state a claim. The landlords appealed the decision.The United States Court of Appeals for the Second Circuit affirmed the district court's judgment. The court held that the Vacancy Provisions are facially valid under the Fourth Amendment because landlords have adequate pre-compliance review available under Article 78 of the New York Civil Practice Law and Rules. The court also found that the searches authorized by the Vacancy Provisions are not unreasonable in every situation, given the ample notice and minimal penalties involved. Additionally, the court held that the Vacancy Provisions do not violate procedural due process because landlords can contest vacancy calculations at public hearings before rent stabilization is adopted and through Article 78 after adoption. View "Hudson Shore v. State of New York" on Justia Law