Justia Constitutional Law Opinion Summaries

Clyde James Barnes Jr. was convicted by a jury of first-degree premeditated murder, aggravated burglary, tampering with electronic monitoring equipment, criminal threat, and violation of a protective order. The case arose after Barnes, who was on house arrest, tampered with his GPS ankle bracelet and traveled to the residence of his ex-partner, Jessica Leigh Smith. Barnes broke into Smith's home and brutally murdered her with a mattock. The crime was captured on surveillance cameras, and forensic evidence linked Barnes to the scene.The Johnson County District Court found Barnes guilty on all counts and sentenced him to life imprisonment with a mandatory minimum of 620 months for the murder, plus additional consecutive sentences for the other charges. Barnes appealed, raising several issues, including the constitutionality of the territorial jurisdiction statute under which he was prosecuted for tampering with electronic monitoring equipment, claims of prosecutorial error, the admission of graphic photographs, the jury instructions on premeditation, and the sufficiency of the evidence for the tampering conviction.The Kansas Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the district court had subject matter jurisdiction over the tampering charge under K.S.A. 21-5106(b)(3), as the proximate result of Barnes' tampering occurred in Kansas. The court also found no prosecutorial error in the closing arguments, determining that the prosecutor's statements were fair comments on the evidence. The court ruled that the admission of the photographs was not an abuse of discretion, as they were relevant and not unduly prejudicial. The court upheld the premeditation jury instruction, finding it accurately stated the law. Finally, the court concluded that sufficient evidence supported Barnes' conviction for tampering with electronic monitoring equipment and that cumulative error did not deny him a fair trial. View "State v. Barnes " on Justia Law

In 2016, a fourteen-year-old boy was involuntarily committed, disqualifying him from possessing firearms. Eight years later, he petitioned the district court to restore his firearm rights under Iowa Code section 724.31. The district court found that the statutory requirements were met and restored his firearm rights. The State appealed the decision.The Iowa District Court for Monona County initially reviewed the case and granted the petition to restore the petitioner’s firearm rights. The State then appealed the district court’s decision, arguing that the restoration requirements were not met and questioning the State’s right to appeal the decision.The Iowa Supreme Court reviewed the case and first addressed whether the State had the right to appeal the restoration order. The court concluded that the State did have the right to appeal under Iowa Rule of Appellate Procedure 6.103(1). The court then reviewed the merits of the case de novo and found that the petitioner had met the burden of proving by a preponderance of the evidence that he would not likely act in a manner dangerous to public safety and that granting the relief would not be contrary to the public interest. The court affirmed the district court’s order restoring the petitioner’s firearm rights. View "In re N.F." on Justia Law

Ezekiel Kieffer was convicted of domestic abuse assault impeding the flow of air or blood and domestic abuse assault causing injury after an altercation with his girlfriend, Daphne. The incident occurred after they returned intoxicated from a community event, leading to a physical confrontation where Kieffer strangled Daphne. Law enforcement was called, and Kieffer was charged and later convicted by a jury. He was sentenced to 180 days (with 93 days suspended) on each count, to be served concurrently, and was also subject to a firearm prohibition.In the Iowa District Court for Black Hawk County, Kieffer was found guilty on both charges. He appealed, arguing insufficient evidence of cohabitation with Daphne, a violation of the district court’s order in limine, and that the firearm prohibition violated his constitutional rights. The district court had denied his motion for a mistrial based on the State’s alleged violations of the order in limine and included a firearm prohibition in his sentencing order.The Iowa Supreme Court reviewed the case and affirmed the convictions and sentence. The court held that there was sufficient evidence to support the jury’s finding that Kieffer and Daphne were cohabiting, as they were in a serious relationship, and Daphne had moved in with Kieffer. The court also found that the district court did not abuse its discretion in denying Kieffer’s motion for a mistrial, as the alleged violations of the order in limine were promptly addressed and cured. Lastly, the court rejected Kieffer’s constitutional challenge to the firearm prohibition under the Second Amendment, citing recent federal jurisprudence upholding similar prohibitions. The court did not address the state constitutional challenge under article I, section 1A, as it was not necessary for the disposition of the case. View "State of Iowa v. Kieffer" on Justia Law

Victor Silvers was convicted of the premeditated murder of his estranged wife, Brittney Silvers, who was an active member of the United States Army, and was shot and killed at Fort Campbell, Kentucky. Silvers was also found guilty of attempted murder, domestic violence, violation of a protection order, possession of a firearm by a prohibited person, and the use of a firearm during a crime of violence. He was sentenced to life in prison.The United States District Court for the Western District of Kentucky took judicial notice that Fort Campbell was within the United States' special maritime and territorial jurisdiction. Silvers challenged this, arguing that the jury should have determined the jurisdictional status. He also moved to exclude a juror who wore a shirt supporting military veterans and had served in the Navy, claiming potential bias. Additionally, Silvers argued that his mandatory life sentence was unconstitutional under the Eighth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not err in taking judicial notice of the jurisdictional status of Fort Campbell, as it was a legal question rather than a factual one for the jury. The court also found no abuse of discretion in the district court's decision to deny Silvers's motion to exclude the juror, as the juror assured impartiality and the voir dire process was deemed adequate. Finally, the court upheld Silvers's mandatory life sentence, citing binding Supreme Court precedent and the Sixth Circuit's own precedent, which did not find such sentences to be cruel and unusual punishment.The Sixth Circuit affirmed both Silvers's conviction and his sentence. View "United States v. Silvers" on Justia Law

Brandon Wade Kurns, a convicted felon, began working at Modern Pawn & Consignment in Helena, Montana, in June 2021, where he sold firearms and ammunition. In July 2021, after an investigation linked stolen gunpowder to the shop, ATF agents searched Modern Pawn and found evidence that Kurns had possessed several firearms. Kurns was indicted and pleaded guilty to being a felon in possession of a firearm.The United States District Court for the District of Montana sentenced Kurns to 36 months in prison, applying a base offense level of 20 under U.S.S.G. § 2K2.1(a)(4)(B)(i)(I) for possessing a semiautomatic firearm capable of accepting a large capacity magazine, and a four-level enhancement under § 2K2.1(b)(1)(B) for possessing eight or more firearms. Kurns objected, arguing that the evidence was insufficient to support these enhancements and that the court violated his Fifth Amendment rights by drawing an adverse inference from his silence during sentencing.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The court held that the evidence, including surveillance footage and ATF transfer forms, supported the finding by a preponderance of the evidence that Kurns possessed a semiautomatic firearm with a large capacity magazine and at least eight firearms. The court also found no Fifth Amendment violation, as there was no indication that the district court drew an adverse inference from Kurns' silence. Additionally, the court declined to consider Kurns' Second Amendment challenge based on New York State Rifle & Pistol Ass’n v. Bruen, as it was raised for the first time after the completion of appellate briefing. View "USA V. KURNS" on Justia Law

Tennessee and sixteen other states challenged a regulation by the Equal Employment Opportunity Commission (EEOC) under the Pregnant Workers Fairness Act, which mandates reasonable accommodations for pregnancy-related conditions, including abortion. The states argued that the regulation unlawfully required them to accommodate employees seeking abortions, conflicting with their policies. They sought an injunction and a declaratory judgment against the rule, claiming it was arbitrary, exceeded EEOC's authority, violated the First Amendment and federalism principles, and was unconstitutional under Article II.The United States District Court for the Eastern District of Arkansas dismissed the case, ruling that the states lacked standing as they did not demonstrate an imminent injury or that the alleged injuries were redressable. The court found the risk of enforcement speculative and compliance costs not directly traceable to the rule. The court also dismissed the states' motion for a preliminary injunction as moot and for failing to show irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that the states had standing as they were the direct objects of the EEOC's regulation, which imposed new obligations on them. The court found that the states were injured by the regulatory burden itself and that setting aside the rule would remedy this injury. The court concluded that the states' need to comply with the rule constituted an injury in fact, caused by the EEOC's action, and redressable by a favorable judicial decision. The case was remanded for further proceedings without addressing the merits of the claims. View "State of Tennessee v. EEOC" on Justia Law

Calixte Fleury was convicted of aggravated trafficking, unlawful trafficking, unlawful possession of scheduled drugs, and operating under the influence. On September 18, 2020, Fleury was driving on I-95 when he crashed his vehicle. A responding sergeant found Fleury with a bag of pills containing fentanyl and tramadol, and later discovered more fentanyl and cash on Fleury. Fleury's blood alcohol content was 0.093 grams per 100 milliliters. He was indicted and later charged with multiple counts, including aggravated trafficking and unlawful trafficking of scheduled drugs.The trial court (York County, Martemucci, J.) held a jury trial, resulting in guilty verdicts on all four criminal counts. The court found in favor of Fleury on the criminal forfeiture count. Fleury was sentenced to seven years with all but four years suspended for aggravated trafficking, three years for unlawful trafficking, and 30 days for operating under the influence, with some sentences running concurrently. The court merged the unlawful possession count with the unlawful trafficking count.The Maine Supreme Judicial Court reviewed the case. Fleury argued that the application of a repealed definition of "traffick" was unconstitutional. The court disagreed, stating that the repealed statute was rationally related to controlling opioids and its application was not unconstitutional. The court also noted that the amended statute did not apply retroactively to Fleury's case.However, the court found that the trial court should have merged the aggravated trafficking count with the unlawful trafficking and possession counts for sentencing. The Maine Supreme Judicial Court vacated the sentence and remanded for resentencing, affirming the convictions in all other respects. View "State of Maine v. Fleury" on Justia Law

The case involves Christopher Poller, who was convicted by the United States District Court for the District of Connecticut for possession with intent to distribute fentanyl and cocaine base, and possession of a firearm in furtherance of a drug trafficking crime. Poller pleaded guilty but reserved the right to appeal the denial of his motion to suppress evidence seized from his vehicle, which included the drugs and firearms forming the basis of his charges.The District Court denied Poller's motion to suppress, concluding that the officers' use of iPhone cameras to see through the tinted windows of Poller's car did not violate his reasonable expectation of privacy. The court also found that even if the officers' physical touching of the car constituted a trespassory search, suppression was unwarranted because the trespass was not the but-for cause of obtaining the evidence.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that Poller's expectation of privacy from all observation of the interior of his car was unreasonable. The use of iPhone cameras to view the car's interior did not transform those visual observations into "searches" under the Fourth Amendment. Additionally, assuming the officers' physical touching of the car constituted a trespassory search, suppression was unwarranted because the trespass was not the but-for cause of obtaining the evidence. Therefore, the Second Circuit affirmed the judgment of the district court. View "United States v. Poller" on Justia Law

In September 2022, Antoine Leon Richardson had an altercation with Mckyla Middleton at a liquor store in Lancaster, California. Richardson accused Middleton of cutting him off, threatened her, and flashed a gun at her from a satchel. In November 2022, police searched Richardson’s home and found ammunition but no firearms. Richardson admitted to brandishing the gun during the altercation and owning the ammunition.The Los Angeles County Superior Court charged Richardson with being a felon in possession of a firearm, being a felon in possession of ammunition, and misdemeanor exhibiting a concealable firearm in public. The jury found Richardson guilty on all counts and confirmed his prior felony convictions. The court sentenced him to three years and eight months in prison for the firearm and ammunition charges, with a concurrent 364-day term for the misdemeanor.The California Court of Appeal, Second Appellate District, reviewed the case. Richardson argued that his convictions for firearm and ammunition possession violated the Second Amendment, citing New York State Rifle & Pistol Association, Inc. v. Bruen. The court disagreed, stating that the Second Amendment protects law-abiding citizens, not felons. The court also found that substantial evidence supported the trial court’s finding that Richardson had separate objectives for possessing and exhibiting the firearm, thus allowing multiple sentences under Penal Code section 654.The Court of Appeal affirmed the trial court’s judgment, upholding Richardson’s convictions and sentences. View "People v. Richardson" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law