Justia Constitutional Law Opinion Summaries

In the early morning of March 19, 2022, Quincy Bear Robe, his girlfriend, and her friends were in a hotel room when Myron Pourier and his friends entered uninvited. An altercation ensued, during which Bear Robe and Isaac Runningshield discharged their guns, resulting in Pourier's death from two gunshot wounds. Bear Robe was found nearby with a .40 caliber handgun and later bragged about the shooting to a friend. He was indicted on charges including second-degree murder and first-degree murder but accepted a plea agreement to plead guilty to first-degree manslaughter.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, accepted Bear Robe's guilty plea and ordered a presentence investigation report (PSI). The PSI noted Bear Robe's lack of prior criminal record, his young age, and several mitigating factors from his childhood, including mental health issues and a chaotic home environment. Despite these factors and letters of support from family and community members, the circuit court sentenced Bear Robe to 75 years in the penitentiary without any time suspended.The Supreme Court of the State of South Dakota reviewed the case. Bear Robe argued that the circuit court abused its discretion by focusing too heavily on general deterrence and not adequately considering mitigating evidence. He also contended that the sentence was cruel and unusual under the Eighth Amendment. The Supreme Court held that the circuit court did not abuse its discretion, as it had thoroughly considered Bear Robe's character and history, and the sentence was within the permissible range. The court also found that the 75-year sentence was not grossly disproportionate to the gravity of the offense of first-degree manslaughter. The Supreme Court affirmed the circuit court's decision. View "State v. Bear Robe" on Justia Law

Spring Siders, a Christian evangelist, sought to share her religious message outside a public amphitheater in Brandon, Mississippi. The City of Brandon had enacted an ordinance restricting protests and demonstrations near the amphitheater during events. Siders challenged the constitutionality of this ordinance after being directed by police to a designated protest area, which she found unsuitable for her activities. She argued that the ordinance infringed on her First Amendment rights.The United States District Court for the Southern District of Mississippi denied Siders' request for a preliminary injunction to prevent the enforcement of the ordinance. The court found that Siders had not demonstrated a likelihood of success on the merits of her claim, relying on a similar case, Herridge v. Montgomery County, which upheld restrictions on street preaching near a concert venue for public safety reasons.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the ordinance was content-neutral and subject to intermediate scrutiny. It found that the ordinance was narrowly tailored to serve the significant government interest of public safety and traffic control during events at the amphitheater. The court also determined that the ordinance left open ample alternative channels for communication, as Siders could still engage in her activities in the designated protest area and other locations outside the restricted area.The Fifth Circuit concluded that Siders had not demonstrated a likelihood of success on the merits of her First Amendment claim. Consequently, the court affirmed the district court's denial of the preliminary injunction. View "Siders v. City of Brandon" on Justia Law

The plaintiffs in this case are retail pet stores, a dog broker, and a dog breeder who want to sell dogs through physical retail stores in Maryland. However, a Maryland law restricts their ability to do so. The plaintiffs sued, alleging that the Maryland statute is preempted by the federal Animal Welfare Act (AWA) and violates the Commerce Clause of the United States Constitution.The United States District Court for the District of Maryland dismissed the plaintiffs' complaint, concluding that they failed to state plausible claims. The plaintiffs then appealed to the United States Court of Appeals for the Fourth Circuit.The Fourth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that the AWA does not preempt the Maryland statute because the AWA expressly contemplates state and local regulation on the same subject. The court also found that the Maryland statute does not pose an impermissible obstacle to achieving the purposes and objectives of the AWA.Regarding the Commerce Clause claims, the court held that the Maryland statute does not discriminate against interstate commerce in purpose or effect. The statute applies equally to in-state and out-of-state breeders and brokers, and it does not prohibit the flow of interstate goods or place added costs upon them. The court also found that the statute does not violate the Pike balancing test because the plaintiffs failed to plausibly allege that the statute imposes a substantial burden on interstate commerce that is clearly excessive in relation to its putative local benefits.In conclusion, the Fourth Circuit affirmed the district court's dismissal of the plaintiffs' complaint, holding that the Maryland statute is not preempted by the AWA and does not violate the Commerce Clause. View "Just Puppies, Inc. v. Brown" on Justia Law

The Montana State Legislature passed Senate Bill 99 (SB 99) in 2023, which prohibits the use of medications and surgeries to treat gender dysphoria in minors. The bill aims to protect minors from receiving harmful, experimental treatments and imposes professional consequences on healthcare providers who violate its provisions. Plaintiffs, including a transgender minor receiving treatment banned by SB 99, their parents, and healthcare providers, filed a lawsuit seeking declaratory and injunctive relief, arguing that SB 99 violates their constitutional rights to privacy and equal protection.The District Court of the Fourth Judicial District granted a preliminary injunction, temporarily enjoining SB 99. The court found that the plaintiffs had standing to challenge the bill and demonstrated a likelihood of success on the merits of their privacy claim. The court applied the Armstrong standard, which protects an individual's right to obtain lawful medical procedures from licensed healthcare providers unless the state can demonstrate a bona fide health risk. The court concluded that the state did not clearly and convincingly show that the treatments proscribed by SB 99 posed such a risk.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The court held that the plaintiffs had established a prima facie case of a violation of their right to privacy and demonstrated a likelihood of irreparable harm if the injunction were not granted. The court also found that the balance of equities and public interest favored the plaintiffs, as the potential harm to minors with gender dysphoria outweighed the state's interests. The preliminary injunction was upheld, allowing the case to proceed to trial for a final determination on the constitutional issues. View "Cross v. State" on Justia Law

In March 2011, Prentice Robinson was indicted by a grand jury for multiple criminal counts, including attempted murder, and admitted to using a firearm during the crime. He pleaded no contest to the charges and received a 22-year prison sentence. In January 2022, Robinson filed a petition for resentencing, arguing that the trial court erred in considering grand jury testimony. The People agreed that the grand jury testimony was inadmissible hearsay but disagreed on the proper remedy. The San Joaquin County District Attorney, as amicus curiae, argued that the grand jury transcripts were part of Robinson’s record of conviction and admissible under section 1172.6.The Superior Court of San Joaquin County denied Robinson’s petition for resentencing, finding that the grand jury transcripts were admissible and that Robinson was the direct perpetrator of the attempted murder. Robinson appealed, arguing that the trial court erred in admitting the grand jury testimony and that it violated his Sixth Amendment right to confrontation.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court’s decision. The court held that section 1172.6, subdivision (d)(3) created a hearsay exception for evidence previously admitted at any prior hearing or trial, including grand jury testimony. The court found that the grand jury proceedings were analogous to preliminary hearings and that the procedural safeguards in place ensured the reliability of the testimony. The court also held that the Sixth Amendment right to confrontation did not apply to section 1172.6 hearings, as they are postconviction collateral proceedings. The court concluded that Robinson’s due process rights were not violated, as he had the opportunity to present new evidence and challenge the grand jury testimony at the evidentiary hearing. View "People v. Robinson" on Justia Law

Jose Nunez-Dosangos filed a petition for a writ of habeas corpus challenging his ongoing detention in county jail pending trial on a charge of assault with a semiautomatic firearm. He was later released on his own recognizance after pleading guilty to a new charge of accessory after the fact, rendering his petition moot. However, the court decided to address the case due to its broad public interest and likelihood of recurrence. The petitioner had accrued presentence time-served and conduct credits exceeding the maximum potential sentence for the charged offense, and a probation report assessed him with a low risk of recidivism.The Superior Court of the City and County of San Francisco initially denied bail and set the case for a preliminary hearing. The magistrate judge found insufficient evidence to show the petitioner knew of his co-defendant's intent to use the firearm, leading to the dismissal of the murder charge against him. The People refiled the murder charge, which was again dismissed by the trial court. The petitioner filed multiple motions for release, arguing his prolonged detention violated due process, but the trial court denied these motions, citing public safety concerns and the possibility of refiling the murder charge.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and concluded that the petitioner's pretrial detention was excessive in relation to the government's public safety goals, constituting impermissible punishment in violation of due process principles. The court noted that the length of detention exceeded the maximum potential sentence and that the trial court erred in relying on the possibility of refiling the murder charge. The petition was ultimately dismissed as moot due to the petitioner's release. View "Nunez-Dosangos v. Superior Ct." on Justia Law

The State of Oklahoma sought to terminate the parental rights of Albert Parker, the natural father of J.O., a child who is a member of the Choctaw Nation. Parker was unaware of his paternity until genetic testing confirmed it in June 2022. The State filed a petition alleging that J.O. was deprived while in the mother's care, and the child was adjudicated deprived. Parker, who was incarcerated, had limited contact with J.O. and had not established a relationship with the child. The trial court terminated Parker's parental rights after a jury trial.The Court of Civil Appeals (COCA) reversed the trial court's decision and remanded the case for a new trial, finding that Parker's due process rights were violated and that the State was not required to comply with the Indian Child Welfare Act (ICWA) requirements. Both Parker and the State petitioned for certiorari review, which was granted.The Supreme Court of the State of Oklahoma reviewed the case and found that Parker's due process rights were indeed violated when the trial continued without his presence after his video feed was disconnected. The court also determined that the ICWA requirements apply in this case, regardless of whether Parker had a prior relationship with J.O. The court vacated the opinion of the Court of Civil Appeals, reversed the trial court's decision, and remanded the case for a new trial, ensuring compliance with ICWA and OICWA provisions. View "In re J.O." on Justia Law

Lloyd Gerald Napouk was fatally shot by two Las Vegas Metropolitan Police Department officers after they responded to reports of a man behaving suspiciously in a residential neighborhood with what appeared to be a long, bladed weapon. The officers attempted to engage Napouk, who refused to follow their commands and advanced towards them multiple times. When Napouk came within nine feet of one of the officers, both officers fired their weapons, killing him. The weapon turned out to be a plastic toy fashioned to look like a blade.Napouk’s parents and estate sued the officers and the Las Vegas Metropolitan Police Department, alleging excessive force in violation of the Fourth Amendment, deprivation of familial relations in violation of the Fourteenth Amendment, municipal liability based on Monell v. Department of Social Services, and Nevada state law claims. The United States District Court for the District of Nevada granted summary judgment for the defendants, determining that the officers’ use of force was reasonable as a matter of law.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s summary judgment. The court held that the officers were entitled to qualified immunity from the Fourth Amendment excessive force claim because Napouk posed an immediate threat to the officers, and no rational jury could find the officers’ mistake of fact regarding the weapon unreasonable. The court also held that the plaintiffs’ Fourteenth Amendment claim failed because there was no evidence that the officers acted with anything other than legitimate law enforcement objectives. Additionally, the plaintiffs’ Monell claims failed due to the absence of a constitutional violation, and the state law claims failed because the officers were entitled to discretionary-function immunity under Nevada law. View "Napouk v. Las Vegas Metropolitan Police Department" on Justia Law

Ammon Sumrall was convicted in October 1992 by a DeKalb County jury of felony murder, armed robbery, and other crimes related to the shooting death of Wade Barrett, Jr. on April 7, 1991. He was sentenced to two consecutive life sentences plus five additional years. Over 30 years later, Sumrall filed a pro se petition in the Superior Court of DeKalb County seeking retroactive first-offender treatment based on an amendment to OCGA § 42-8-66. He also filed a motion to declare the statute unconstitutional.The trial court initially dismissed Sumrall’s petition and motion, but later vacated this order and issued an amended order. The amended order dismissed the petition for failing to obtain the necessary consent from the prosecuting attorney and denied the motion to declare the statute unconstitutional, citing a lack of standing and insufficient supporting arguments.The Supreme Court of Georgia reviewed the case and affirmed the trial court’s decisions. The court held that Sumrall failed to meet the statutory requirement of obtaining the prosecuting attorney’s consent before filing his petition for retroactive first-offender treatment. The court also found no merit in Sumrall’s argument that the prosecuting attorney’s inaction constituted implied consent. Additionally, the court upheld the trial court’s denial of Sumrall’s motion to declare OCGA § 42-8-66 (a) (1) unconstitutional, concluding that Sumrall did not demonstrate a clear and palpable conflict with the Georgia or United States Constitutions. The court emphasized that the statute did not deprive Sumrall of his right to access the courts or to be heard. View "Sumrall v. State" on Justia Law

Tabitha Wood was convicted of malice murder and other crimes after killing her fiancé, Leroy Kramer. Wood claimed self-defense, citing a history of Kramer’s violence towards her and presented expert testimony that she suffered from battered person syndrome. Kramer’s body was found in their shared home two months after his death, and Wood was indicted on multiple charges, including malice murder and concealing the death of another. The jury found her guilty on all counts, and she was sentenced to life in prison for malice murder, with additional sentences for other charges.Wood appealed, arguing that the trial court erred by not allowing her to introduce testimony about Kramer’s violence towards other women under OCGA § 24-4-405 (b) and that this exclusion violated her constitutional right to a complete defense. The trial court had ruled that Wood could testify about her knowledge of Kramer’s violent acts to show her state of mind but could not introduce extrinsic evidence of specific acts through other witnesses. Wood’s motion for a new trial was denied, and she appealed to the Supreme Court of Georgia.The Supreme Court of Georgia held that the trial court did not abuse its discretion by excluding the testimony about Kramer’s prior acts of violence under Rule 405 (b), as a victim’s violent character is not an essential element of self-defense. The court also found no plain error in the trial court’s application of the evidentiary rules, concluding that Wood’s constitutional rights were not violated. The court affirmed Wood’s convictions. View "Wood v. State" on Justia Law