Justia Constitutional Law Opinion Summaries

Chadlen Dewayne Smith was convicted of sexual exploitation of a child by possession of sexually exploitative material. The case began when Smith was arrested for stalking a police dispatcher. Following his arrest, law enforcement impounded his vehicle and conducted an inventory search, during which they seized electronic devices containing sexually exploitative materials. Smith challenged the district court's denial of his motion to suppress the evidence found on these devices.The District Court of the First Judicial District, Kootenai County, denied Smith's motion to suppress, concluding that there was probable cause for his arrest for stalking and that the impoundment and inventory search of his vehicle were reasonable and conducted according to police procedures. Smith was subsequently convicted by a jury of sexual exploitation of a child but acquitted of distributing obscene material. He appealed the conviction, arguing that the evidence obtained from the inventory search should have been suppressed.The Supreme Court of the State of Idaho reviewed the case and reversed the district court's decision. The court held that the State did not meet its burden to show that the police officer's decision to impound Smith's vehicle served a community caretaking purpose. The impoundment was deemed unreasonable under the Fourth Amendment, making the subsequent inventory search unconstitutional. As a result, the evidence obtained from the search was inadmissible, leading to the vacating of Smith's conviction. View "State v. Smith" on Justia Law

Christopher Hamilton was convicted of federal felony possession of child pornography. After a federal district court terminated his federal sex offender registration requirement, the California Attorney General notified him of his lifetime obligation to register under California law, pursuant to Penal Code section 290.005(a). The Attorney General determined that the state law equivalent of Hamilton’s federal offense required lifetime registration, placing him in the highest tier of California’s three-tier scheme.Hamilton petitioned the Superior Court of Los Angeles County to terminate his state registration requirement. The Superior Court denied his petition and a subsequent amended motion. Hamilton appealed the denials, arguing violations of equal protection and due process.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the Attorney General’s classification of Hamilton’s offense as a felony with a lifetime registration requirement did not violate equal protection. The court reasoned that the federal offense’s classification as a felony, based on custodial exposure, justified the equivalent state offense’s classification as a felony. Additionally, the court found that the federal offense’s requirement of interstate or foreign commerce provided a rational basis for the different treatment.The court also rejected Hamilton’s due process challenge, concluding that he received notice and had opportunities to contest his tier designation through his petition and amended motion. Lastly, the court dismissed Hamilton’s vagueness challenge, finding that the term “equivalent” in section 290.005(a) was sufficiently clear when considered in context with other statutory provisions.The Court of Appeal affirmed the Superior Court’s orders denying Hamilton’s petition and amended motion. View "People v. Hamilton" on Justia Law

Rashawn Vertez Carter was involved in a violent home invasion and robbery in Aiken, South Carolina, on May 9, 2015. After the crime, law enforcement officers used Carter's real-time cell-site location information from his cell-service provider, T-Mobile, to track him down without obtaining a search warrant. Carter was subsequently arrested and made incriminating statements during interviews with the police.At trial, Carter moved to suppress the evidence obtained from his real-time cell-site location information, arguing that it was obtained in violation of his Fourth Amendment rights and the South Carolina Constitution. The trial court denied the motion, ruling that the information gathered did not constitute a search under either constitution. The jury convicted Carter of burglary, armed robbery, kidnapping, and illegal possession of a weapon, but acquitted him of the alleged sexual assault. Carter appealed to the South Carolina Court of Appeals, which affirmed the trial court's decision, holding that the exigent circumstances exception to the warrant requirement applied and that the good-faith exception to the exclusionary rule also justified the officers' actions.The South Carolina Supreme Court reviewed the case and affirmed Carter's convictions. The court did not address whether a search occurred or if the exigent circumstances exception applied. Instead, it focused on the good-faith exception to the exclusionary rule, concluding that the officers acted in good faith reliance on the federal Stored Communications Act, which allowed the disclosure of customer records in emergencies. The court held that the good-faith exception precluded the suppression of evidence obtained through Carter's real-time cell-site location information, as the officers reasonably believed their actions were lawful under the statute. View "State v. Carter" on Justia Law

Robert E. Dupuis and twelve other plaintiffs filed lawsuits against the Roman Catholic Bishop of Portland, seeking damages for sexual abuse allegedly perpetrated by the Bishop’s clergy when the plaintiffs were minor children. Their claims were previously barred by the statute of limitations. The Bishop moved for judgment on the pleadings, arguing that 14 M.R.S. § 752-C(3) (2022), which purports to revive the plaintiffs’ claims, deprives the Bishop of a constitutionally protected vested right.The Business and Consumer Docket (McKeon, J.) denied the Bishop’s motions but reported its orders to the Maine Supreme Judicial Court under Maine Rule of Appellate Procedure 24(c). The court accepted the report to determine whether the retroactive application of section 752-C(3) is constitutional.The Maine Supreme Judicial Court held that the retroactive application of section 752-C(3) contravenes centuries of precedent and multiple provisions of the Maine Declaration of Rights, as well as the Constitution’s provisions regarding separation of powers. The court concluded that once a statute of limitations has expired for a claim, a right to be free of that claim has vested, and the claim cannot be revived. Therefore, section 752-C(3) is unconstitutional as applied to expired claims. The court remanded the case for further proceedings consistent with this opinion. View "Dupuis v. Roman Catholic Bishop of Portland" on Justia Law

Dontarious Burke was convicted of malice murder and armed robbery for the shooting death of Kentrell Jones. The incident occurred on November 27, 2019, and Burke was indicted on March 1, 2021. His trial was severed from his brother DeMarcus Burke's trial. Burke was tried by a jury from October 19 to 20, 2021, and found guilty on all counts. He was sentenced to life in prison for malice murder and an additional 20 years for armed robbery. Burke filed a motion for a new trial, which was denied by the trial court on May 6, 2024. He then filed a timely notice of appeal.The trial court denied Burke's motion for a new trial, and he appealed to the Supreme Court of Georgia. Burke raised several claims, including a violation of his Sixth Amendment rights under the Confrontation Clause, ineffective assistance of counsel, and the cumulative effect of errors requiring a new trial. The trial court had admitted testimony from police officers about information obtained from non-testifying witnesses, which Burke argued violated his Confrontation Clause rights. However, because Burke did not raise this objection at trial, the Supreme Court reviewed it for plain error and found none.The Supreme Court of Georgia reviewed Burke's claims and found that none of them warranted a reversal of his convictions. The court held that Burke's Confrontation Clause rights were not violated, as the testimony in question did not clearly and obviously violate established law. Additionally, the court found that Burke's trial counsel did not render ineffective assistance, as the decisions made by counsel were within the bounds of reasonable trial strategy. Finally, the court determined that there was no cumulative error that would require a new trial. Consequently, the Supreme Court of Georgia affirmed Burke's convictions. View "BURKE v. THE STATE" on Justia Law

In 2022, the Georgia General Assembly enacted House Bill 839 (HB 839), which incorporated the City of Mableton within unincorporated Cobb County and provided for the creation of one or more community improvement districts (CIDs) within Mableton. Deidre White and other residents of Cobb County challenged the constitutionality of HB 839, arguing that it violated the "Single Subject Rule" of the Georgia Constitution by creating more than one unit of government, specifically Mableton and the CIDs.The trial court dismissed the complaint for failure to state a claim upon which relief could be granted. The court found that HB 839 did not violate the Single Subject Rule, as the creation of CIDs within Mableton was germane to the overall objective of incorporating the city. The Appellants then appealed this decision.The Supreme Court of Georgia reviewed the case and affirmed the trial court's dismissal. The court held that HB 839 did not violate the Single Subject Rule because the creation of CIDs within Mableton had a logical and natural connection to the incorporation of the city. The court also rejected the argument that the ballot question for HB 839 contravened the precedent set in Rea v. City of LaFayette, as the creation of CIDs was related to the single objective of establishing Mableton. Thus, the court concluded that HB 839 was constitutional and upheld the trial court's decision. View "WHITE v. CITY OF MABLETON" on Justia Law

Tico Holloway was convicted of malice murder and related crimes in connection with the shooting death of Mercedes Dejesus Antunez-Flores and violent crimes against N.H. and M.H. The crimes occurred on August 17, 2019. Holloway was indicted on multiple counts, including malice murder, felony murder, criminal attempt to commit armed robbery, aggravated assault, aggravated battery, armed robbery, and possession of a firearm by a convicted felon. A jury found Holloway guilty of all counts except armed robbery. He was sentenced to life in prison without parole for malice murder, with additional concurrent sentences for other charges. Holloway's motion for a new trial was denied, and he appealed.The trial court, Cobb County, denied Holloway's motion for a new trial. Holloway argued that the evidence was insufficient to support his malice murder conviction and that the trial court made errors. He claimed the evidence did not disprove his self-defense argument beyond a reasonable doubt. Holloway also contended that the trial court erred by allowing the medical examiner to testify remotely via videoconference, which he argued violated his Sixth Amendment right to confrontation. Additionally, he claimed that errors in the Spanish-to-English interpretation of M.H.'s testimony violated his right to a fair trial.The Supreme Court of Georgia reviewed the case and affirmed the lower court's decision. The court held that the evidence was sufficient to support Holloway's malice murder conviction, as the jury was entitled to reject his self-defense claim. The court also found no plain error in allowing the medical examiner to testify remotely, noting that Holloway had consented to this procedure. Finally, the court concluded that Holloway waived his claim regarding the interpretation errors by agreeing to the procedure used during the trial. View "HOLLOWAY v. THE STATE" on Justia Law

Sherran Wasserman agreed to sell land in Franklin County to Anthony Pham, contingent on the approval of a conditional use permit by the Franklin County Board of Commissioners. Pham applied for the permit to build and operate chicken houses, but the Board denied the application. Wasserman then sued the Board and the County, initially bringing multiple claims under state and federal law. She dismissed some claims, conceded others, and the trial court dismissed her remaining state-law claims due to sovereign immunity. This left two federal claims: one alleging the County violated Pham’s equal protection rights based on race, and another alleging a violation of Wasserman’s equal protection rights as a “class of one.”The trial court denied the County’s motion for summary judgment, applying the federal doctrine of third-party standing, which allows a plaintiff to assert the rights of third parties. The court found genuine issues of material fact precluded summary judgment on standing and the merits of Wasserman’s equal protection claims. The Court of Appeals reversed, concluding Wasserman lacked third-party standing and that her “class of one” claim failed as a matter of law.The Supreme Court of Georgia reviewed whether a plaintiff may rely on the federal doctrine of third-party standing to establish constitutional standing in Georgia courts. The court held that Georgia’s constitutional standing requirements, rooted in the common law and consistent precedent, do not allow a plaintiff to maintain an action by asserting only the rights of a nonparty. The court overruled its previous adoption of the federal doctrine of third-party standing, concluding that a plaintiff must assert her own legal rights to invoke the judicial power of Georgia courts. The judgment was vacated and remanded for further proceedings consistent with this opinion. View "WASSERMAN v. FRANKLIN COUNTY" on Justia Law

Stephen Bryant was sentenced to death by a South Carolina state court. During postconviction proceedings, Bryant filed a new application for relief, claiming his execution would violate the Eighth Amendment due to his intellectual disabilities, as defined in Atkins v. Virginia and Hall v. Florida. Later, Bryant sought to amend his application to include a claim that he suffers from fetal alcohol spectrum disorder (FASD) and that executing individuals with FASD should also be prohibited under the Eighth Amendment. The state postconviction court denied this request, ruling it was both impermissibly successive and filed too late.Bryant's initial appeal to the South Carolina Supreme Court, which focused on a single claim of evidentiary error, was denied. He then sought post-conviction relief on several grounds, none of which included the Eighth Amendment claim. The state trial court denied these claims, and the South Carolina Supreme Court denied discretionary review. Bryant subsequently filed for federal habeas corpus relief, which was stayed to allow him to exhaust state remedies. He filed two new applications in state court, one of which was allowed to proceed on the intellectual disability claim but not on the FASD claim. The state trial court ultimately denied the intellectual disability claim on its merits.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the state trial court's refusal to permit Bryant to amend his application to add the FASD claim rested on state procedural grounds that were independent of federal law and adequate to bar federal habeas review. The Fourth Circuit affirmed the district court's denial of habeas relief, concluding that Bryant's FASD claim was procedurally defaulted and could not be considered on its merits. View "Bryant v. Stirling" on Justia Law

The case involves Access Independent Health Services, Inc., doing business as Red River Women’s Clinic, and several physicians who challenged the constitutionality of North Dakota’s abortion regulation statutes, N.D.C.C. ch. 12.1-19.1. The plaintiffs argued that the law was unconstitutionally vague and violated pregnant women’s rights to life and health-preserving care under the North Dakota Constitution.The District Court of Burleigh County granted summary judgment in favor of the plaintiffs, declaring the law unconstitutionally vague and recognizing a fundamental right for pregnant women to choose abortion before viability under the North Dakota Constitution. The court found that the law’s language was ambiguous and did not provide clear guidelines for physicians, thus violating due process. The court also held that the law infringed on the fundamental rights of pregnant women.The State of North Dakota appealed to the Supreme Court of North Dakota, seeking a stay of the district court’s judgment pending appeal. The Supreme Court of North Dakota denied the motion for a stay. The court applied a four-factor test to determine whether to grant a stay: likelihood of success on appeal, irreparable injury to the appellant, substantial harm to any party, and harm to the public interest. The court found that the State was unlikely to succeed on the merits of the appeal, as the law was likely unconstitutionally vague and did not meet the strict scrutiny standard required for laws infringing on fundamental rights. The court also determined that the balance of harms and public interest did not favor granting a stay, noting that the law had never been enforced and that the state’s attorneys had agreed not to enforce it pending the outcome of the appeal. View "Access Independent Health Services, Inc. v. Wrigley" on Justia Law