Justia Constitutional Law Opinion Summaries

In 2001, a 17-year-old Morris Mullins killed a 78-year-old widow, Amy Davis, and was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At the sentencing, the court considered evidence of Mullins’s dysfunctional upbringing and psychological evaluation but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama. The district court denied his motion in 2016, and Mullins’s appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether the sentencing court properly considered Mullins’s youth and potential for change as required by Miller and subsequent cases. The court found that the sentencing judge’s comments suggested ambiguity about Mullins’s capacity for change, undermining confidence in the constitutionality of the JLWOP sentence. The court vacated Mullins’s sentence and remanded the case for resentencing, emphasizing the need to consider the constitutional implications of Mullins’s youth and potential for rehabilitation. View "Galassi v. Lowe's Home Centers, LLC" on Justia Law

Paul Porter applied twice to register a firearm, but the District of Columbia Metropolitan Police Department (MPD) denied his applications, citing a previous weapons offense conviction in Maryland. The Maryland records were expunged in 2020, so the full details of the case are not available. However, it is known that Porter pleaded guilty in 2009 to transporting a handgun on a highway, was initially sentenced to three years of incarceration (suspended for probation), and later had his sentence reconsidered to probation before judgment in 2015.Porter sought review of MPD's denial from the Office of Administrative Hearings (OAH). The Administrative Law Judge (ALJ) at OAH overturned MPD's decision, reasoning that under Maryland law, a discharged sentence of probation before judgment is not considered a conviction and that failing to recognize this would deny Maryland law full faith and credit.The District of Columbia Court of Appeals reviewed the case. The court held that the Full Faith and Credit Clause does not compel the District to adopt Maryland's interpretation of "conviction" for firearm registration purposes. The court concluded that under District law, a sentence of probation before judgment constitutes a conviction for the purposes of firearm registration. The court emphasized that the legislative intent of the Firearms Control Regulations Act of 1975 was to restrict firearm possession to individuals without disqualifying offenses, and allowing those with probation before judgment to register firearms would undermine this purpose.The court reversed OAH's order and upheld MPD's denial of Porter's application for a firearm registration certificate, holding that Porter "has been convicted" of a disqualifying offense under D.C. Code § 7-2502.03(a)(2), and that subsequent discharge of probation and expungement do not alter this conclusion. View "District of Columbia Metropolitan Police Department v. Porter" on Justia Law

In 2016, Chad Hintze, a registered sex offender, visited a public park, violating his sex offender registry conditions. He was charged with a class A misdemeanor in 2018 while serving a prison sentence for a separate offense. However, the State did not notify Hintze of the charge until March 2020, when he was being considered for parole on the separate offense. The State began prosecuting the misdemeanor in June 2020 after Hintze requested a hearing.Hintze moved to dismiss the charge, claiming his Sixth Amendment right to a speedy trial was violated due to the State's two-year delay, which he argued prejudiced his parole chances. The Third District Court, Salt Lake County, disagreed, finding Hintze's prejudice claim speculative and determining that his speedy trial right was not violated based on the Barker v. Wingo framework. Hintze entered a conditional guilty plea and appealed.The Utah Court of Appeals, in a divided decision, reversed the district court's ruling, concluding that the Barker factors favored Hintze and required dismissal of the case on Sixth Amendment grounds. The State then petitioned the Utah Supreme Court for certiorari review.The Utah Supreme Court reviewed the case and concluded that although the two-year delay was significant, the Barker factors, when appropriately weighed, did not establish a violation of Hintze’s speedy trial right. The court found that the delay, caused by the State's negligence, was not extraordinary, and Hintze's claim of prejudice was speculative. Consequently, the court reversed the court of appeals' decision, reinstated Hintze’s conviction, and remanded the case to the court of appeals for further proceedings on Hintze’s motion to suppress. View "State v. Hintze" on Justia Law

A tenured professor at the University of Illinois Chicago School of Law, Jason Kilborn, included an expurgated racial slur in a law school exam question. This led to an investigation by university officials, who found that Kilborn had created a racially hostile environment and violated the university's nondiscrimination policy. Consequently, Kilborn was suspended from teaching until he completed a diversity training program and was denied a two percent raise. Kilborn sued several university officials, alleging violations of his constitutional rights to free speech and due process.The United States District Court for the Northern District of Illinois dismissed Kilborn's federal claims with prejudice, finding that his speech was not constitutionally protected. The court also declined to exercise supplemental jurisdiction over his state law claims, dismissing them without prejudice. Kilborn appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and reversed the dismissal of Kilborn's First Amendment retaliation claim, concluding that his speech was constitutionally protected under the Supreme Court's decisions in Connick v. Myers and Pickering v. Board of Education. The court found that Kilborn's speech addressed matters of public concern and that the university's actions could be seen as pretextual. However, the court affirmed the dismissal of Kilborn's remaining federal claims, including his compelled speech and procedural due process claims. The court also vacated the dismissal of Kilborn's state law claims for further consideration by the district court. View "Kilborn v. Amiridis" on Justia Law

Steven D’Braunstein was involved in a serious single-vehicle accident, resulting in his car being totaled. California Highway Patrol Officer Samantha Diaz-Durazo arrived at the scene and found D’Braunstein disoriented and in physical distress. Despite his evident symptoms, she did not call for medical assistance. Instead, she arrested him for driving under the influence of drugs and took him to jail. A nurse at the jail refused to admit D’Braunstein due to his medical condition, prompting Durazo to finally take him to the hospital, where he was diagnosed with a stroke. The delay in receiving medical treatment allegedly led to permanent injuries for D’Braunstein.The United States District Court for the Central District of California granted summary judgment in favor of Officer Durazo, holding that although she violated D’Braunstein’s Fourth Amendment rights by failing to provide reasonable medical care, she was entitled to qualified immunity. The court reasoned that the constitutional violation was not clearly established, as D’Braunstein’s injury was sustained prior to his arrest and not during the arrest process.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s summary judgment. The Ninth Circuit held that a reasonable jury could find that Durazo violated D’Braunstein’s constitutional rights by failing to summon prompt medical care, given the serious nature of the collision and his symptoms. The court further held that Durazo’s failure to provide medical care was a violation of clearly established law, which requires officers to seek medical assistance for an injured detainee or arrestee facing a substantial and obvious risk of serious harm. The case was remanded for further proceedings. View "D’Braunstein v. California Highway Patrol" on Justia Law

Two professors of Indian descent and adherents to the Hindu religion challenged California State University's (CSU) anti-discrimination and harassment policy, which included "caste" as a protected class. They argued that this inclusion stigmatized their religion and caused them to self-censor certain religious practices. They filed a lawsuit alleging violations of the Due Process Clause, Free Exercise Clause, and Establishment Clause of the U.S. Constitution, as well as equivalent claims under the California Constitution.The United States District Court for the Central District of California dismissed the professors' Equal Protection claim and the equivalent state law claim for lack of standing. The court also dismissed the Free Exercise claim for failing to state a claim without deciding on standing. The Due Process and Establishment Clause claims proceeded to a bench trial, where the court ultimately dismissed these claims as well, finding that the professors lacked sufficient injury for a pre-enforcement challenge and that the policy did not express government disapproval of Hinduism.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the professors lacked Article III standing for their Due Process claim because they failed to show that they intended to engage in any religious practice that could reasonably constitute caste discrimination or harassment. The court also found that the professors lacked standing for their Free Exercise claim, as they did not demonstrate any injury to their ability to exercise their religion. Finally, the court held that the professors lacked standing for their Establishment Clause claim, as the district court's factual finding that the policy had no hostility toward religion was not clearly erroneous. The court affirmed the judgment for the defendants and remanded for entry of judgment of dismissal without prejudice. View "Kumar v. Koester" on Justia Law

Dontavius R. Sharkey was convicted by a jury of two counts of felon in possession of a firearm and two counts of a straw-purchasing conspiracy. The district court sentenced him to 360 months in prison. Sharkey appealed his conviction and sentence, arguing that the statutes under which he was convicted were unconstitutional and that the district court improperly used acquitted conduct to enhance his sentence.The United States District Court for the Southern District of Iowa found Sharkey's acquitted conduct proven by a preponderance of the evidence and used it to increase his Guidelines range. Sharkey's arguments against the constitutionality of 18 U.S.C. § 922(g)(1) and the use of acquitted conduct were rejected based on existing precedent. The district court also applied enhancements for using a firearm in connection with another felony and for his role as an organizer in the criminal activity.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The court held that Sharkey's constitutional challenges were foreclosed by precedent, specifically citing United States v. Jackson. The court also upheld the use of acquitted conduct in sentencing, referencing United States v. Watts and United States v. Bullock. Additionally, the court found no procedural error in the application of the Guidelines enhancements and determined that the district court did not abuse its discretion in imposing an above-Guidelines sentence. The court concluded that the district court properly considered the relevant factors and did not give undue weight to any improper or irrelevant factors. View "United States v. Sharkey" on Justia Law

The defendant, a New Hampshire resident, was arrested in Massachusetts on November 8, 2021, for operating a motor vehicle under the influence of alcohol following a collision. During a search of his vehicle, a handgun and ammunition were found. The defendant did not have a Massachusetts nonresident firearm license and was charged with unlawful possession of a firearm under G. L. c. 269, § 10 (a). He moved to dismiss the charge, arguing that the nonresident licensing scheme violated his Second Amendment rights, relying on the U.S. Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen.The District Court judge allowed the motion to dismiss, concluding that the nonresident licensing scheme was unconstitutional as applied to the defendant. The judge found that the scheme violated the Second Amendment by imposing discretionary licensing requirements on nonresidents. The Commonwealth appealed, and the Supreme Judicial Court of Massachusetts granted direct appellate review.The Supreme Judicial Court of Massachusetts held that the Commonwealth's prior nonresident firearm licensing scheme, which allowed the State police colonel discretion to issue or deny licenses, violated the Second Amendment under the Bruen decision. The court noted that such discretionary "may issue" regimes are presumptively invalid and not supported by historical tradition. The court also found that the impermissible portions of the statute could not be severed from the remainder, rendering the entire scheme unconstitutional. Consequently, the court affirmed the dismissal of the charge against the defendant. View "Commonwealth v. Donnell" on Justia Law

The defendant, a New Hampshire resident, was involved in a vehicle accident in Massachusetts and was found in possession of an unlicensed firearm. He was charged with unlawful possession of a firearm and ammunition. The defendant filed a motion to dismiss, arguing that the Commonwealth's nonresident firearm licensing scheme violated his Second Amendment rights in light of the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen. The motion judge allowed the motion to dismiss, and the Commonwealth appealed.The Supreme Judicial Court of Massachusetts reviewed the case. The court first determined that the defendant lacked standing to bring an as-applied challenge to the Commonwealth's nonresident firearm licensing scheme because he had not applied for and been denied a license under that scheme. The court then considered the merits of a facial challenge to the scheme.The court held that the Commonwealth's nonresident firearm licensing scheme is consistent with the Second Amendment. The scheme's purpose is to restrict access to firearms by demonstrably dangerous persons, which is consistent with the nation's historical tradition of firearm regulation. The court also found that the scheme's "shall issue" licensing regime, which requires nonresidents to meet specific criteria to obtain a license, is analogous to historical regulations such as surety and going armed laws.Additionally, the court held that the scheme does not violate the Fourteenth Amendment rights to travel and to equal protection. The differences in the treatment of resident and nonresident license applicants, such as license duration and processing times, are rationally related to the legitimate state interest of ensuring public safety.The Supreme Judicial Court reversed the motion judge's order allowing the defendant's motion to dismiss, upholding the constitutionality of the Commonwealth's nonresident firearm licensing scheme. View "Commonwealth v. Marquis" on Justia Law

A city ordinance criminalizes broadcasting obscene, profane, or vulgar language from commercial properties above certain volumes at specific times. A bar owner challenged the ordinance, claiming it violated the First Amendment. This appeal focuses on the restriction of "vulgar" language.The United States District Court for the District of South Carolina declined to enjoin the vulgar-language provision, interpreting it as only restricting speech that is obscene under constitutional standards, which can be entirely prohibited. The court upheld the obscene-language and vulgar-language provisions but enjoined the profane-language provision. The bar owner appealed, arguing that the vulgar-language provision, properly construed, is unconstitutional.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court disagreed with the district court's interpretation, concluding that the vulgar-language provision reaches some constitutionally protected speech and is not limited to obscene speech. The court held that the vulgar-language provision is content-based and fails strict scrutiny because it is not narrowly tailored to serve compelling state interests. The court found that the provision is both overinclusive and underinclusive, affecting protected speech and not effectively serving the city's stated interests.The Fourth Circuit reversed the district court's judgment in part and remanded the case for further proceedings, holding that the vulgar-language provision is unconstitutional. View "Moshoures v. City of North Myrtle Beach" on Justia Law