Justia Constitutional Law Opinion Summaries

Aaron Spencer was charged with second-degree murder and a firearm enhancement for the shooting death of Michael Fosler. Fosler had been charged with sexual offenses against Spencer’s daughter and was out on bond. On the night of the incident, Spencer found his daughter in Fosler’s truck and forced it off the road, resulting in an altercation where Spencer shot Fosler, who died at the scene. The case garnered significant media attention, leading the State to request a gag order to preserve the integrity of the jury pool and ensure a fair trial.The Lonoke County Circuit Court granted the State’s motion for a gag order without holding a hearing. The order restricted various parties, including attorneys, public officials, and Spencer’s family, from making public statements about the case. Spencer opposed the gag order, arguing it violated his constitutional rights to a fair and public trial and free speech. He filed a petition for writ of certiorari with the Arkansas Supreme Court, seeking to vacate the gag order.The Arkansas Supreme Court reviewed the case and found that the gag order was overly broad, vague, and lacked a factual basis. The court held that the order constituted a plain, manifest, clear, and gross abuse of discretion. The court emphasized that gag orders should be a last resort and must be narrowly tailored based on specific factual findings. The court granted Spencer’s petition for writ of certiorari, issued the writ, and vacated the circuit court’s gag order. The court did not preclude the possibility of a subsequent, more narrowly tailored gag order after an evidentiary hearing. View "SPENCER v. STATE OF ARKANSAS" on Justia Law

A juvenile court in a dependency proceeding granted a restraining order requested by a mother, K.B., against her 17-year-old dependent child, D.B. The Santa Clara County Department of Family and Children’s Services had received multiple referrals over the years concerning D.B.'s well-being due to alleged abuse and neglect by the mother. D.B. had a history of physical altercations with her mother and was placed in protective custody after her mother refused to allow her back home following an arrest for assault.The Santa Clara County Superior Court assumed jurisdiction over D.B. and declared her a dependent child. The court adopted a case plan that included supervised visitation with the mother. However, D.B. struggled in her placement and exhibited behavioral issues. The mother later requested termination of reunification services, which the court granted with D.B.'s agreement.Subsequently, the mother filed for a restraining order against D.B., citing threats and harassment. The court issued a temporary restraining order and later a one-year restraining order after a hearing. The court found that section 213.5 of the Welfare and Institutions Code authorized it to issue restraining orders against a dependent child and determined that it was in D.B.'s best interest to do so.The California Court of Appeal, Sixth Appellate District, reviewed the case and affirmed the juvenile court's decision. The appellate court held that section 213.5, subdivision (a), grants the juvenile dependency court authority to issue restraining orders against a dependent child, provided the child's best interest is considered. The court found substantial evidence supporting the restraining order and concluded that it did not violate D.B.'s constitutional rights, as reunification services had already been terminated with D.B.'s consent. View "In re D.B." on Justia Law

The Heidi Group, Inc. alleged that several Texas officials violated the Fourth Amendment and Texas law by conspiring with a private citizen to steal documents from a cloud-based file storage system. The officials moved for judgment on the pleadings and asserted various immunity defenses. The district court denied the motions in relevant part.The United States District Court for the Western District of Texas reviewed the case and denied the defendants' motions for judgment on the pleadings. The defendants then appealed to the United States Court of Appeals for the Fifth Circuit. The appeal involved four distinct groups of orders: the denial of qualified immunity for individual capacity defendants on the Fourth Amendment claim, the denial of judgment on the pleadings for the official capacity Fourth Amendment claim, the denial of state law immunity for the individual capacity defendants on the unlawful-access claim, and the denial of judgment on the pleadings for the state law religious-discrimination claim.The United States Court of Appeals for the Fifth Circuit dismissed the appeal regarding the religious-discrimination claim and declined to exercise pendent appellate jurisdiction over the official capacity Fourth Amendment claim. The court held that only Gaylon Dacus engaged in state action and was not entitled to qualified immunity for the Fourth Amendment claim. The court found that Dacus used a former employee to access Heidi's documents without proper authorization, violating clearly established Fourth Amendment rights. The court also affirmed the denial of state law immunity for the individual capacity defendants on the unlawful-access claim, as their actions were not in good faith. The court reversed the denial of judgment on the pleadings for Johnson and Kaufman on the individual capacity Fourth Amendment claim and remanded for further proceedings. View "Heidi Group v. Texas Health and Human Services Commission" on Justia Law

Andrew Miller was convicted by a jury in the Circuit Court of Raleigh County, West Virginia, of wanton endangerment, malicious wounding, and felony possession of a firearm by a prohibited person. The jury also found him to be a recidivist felon, leading to a life sentence with the possibility of parole. The case arose from an incident where Miller allegedly shot Anthony Goard during a dispute over drugs at Niesha Dotson’s apartment. Miller claimed that another individual, J.T., was the actual shooter.At trial, the State presented testimony from Dotson and Goard, both of whom had used drugs at the time of the incident. Dotson testified about a disagreement over drugs between her and Miller, while Goard identified Miller as the shooter but initially told hospital staff he did not know who shot him. The State also introduced a 9 millimeter firearm with Miller’s DNA, although Goard identified a different firearm as the one used in the shooting. Miller testified in his defense, asserting that J.T. shot Goard and that he left the scene to avoid being implicated due to his parole status.The Supreme Court of Appeals of West Virginia reviewed the case, focusing on Miller’s claim that his constitutional right to silence was violated. The court found that the circuit court erred by allowing the State to cross-examine Miller about his post-arrest silence, which was not harmless beyond a reasonable doubt. The court noted that this improper questioning directly prejudiced Miller’s defense, as it suggested to the jury that Miller fabricated his story about J.T. being the shooter.The Supreme Court of Appeals of West Virginia vacated Miller’s convictions and remanded the case for a new trial, concluding that the constitutional error was not harmless and affected the jury’s verdict. View "State of West Virginia v. Miller" on Justia Law

Samuel Joseph was convicted of drug and firearm offenses. He appealed the district court's denial of his motion to suppress evidence seized during two encounters with law enforcement. The first encounter occurred in Charleston, West Virginia, where an officer, after receiving a tip about possible drug activity, observed Joseph's suspicious behavior and items consistent with drug distribution in a motel room. Joseph was apprehended after fleeing from officers, and a search of his duffel bag, which he abandoned during the chase, revealed drugs and firearms.The United States District Court for the Southern District of West Virginia denied Joseph's motion to suppress the evidence obtained during the encounters. Joseph argued that the officers lacked reasonable suspicion to stop him and that the search and seizure violated his Fourth Amendment rights. The district court found that the officers had reasonable suspicion based on their observations and Joseph's behavior, and that the subsequent search and seizure were lawful.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that the officers had reasonable suspicion to stop Joseph based on their observations and his unprovoked flight. The court also found that the officers' actions following the stop, including the use of a drug-detection dog and obtaining a search warrant for the duffel bag, were permissible and did not violate the Fourth Amendment. Additionally, the court rejected Joseph's arguments regarding the lack of bodycam footage and the reliability of the initial tip, as well as his claim that the traffic stop in Parkersburg was impermissibly prolonged. The court concluded that the district court's factual findings were not clearly erroneous and upheld the denial of the motion to suppress. View "United States v. Joseph" on Justia Law

Barry Jackson was convicted of illegally possessing two firearms as a domestic violence misdemeanant. After his conviction, but before pleading guilty, he was found with three additional firearms, one of which had a large-capacity magazine. Jackson challenged the constitutionality of 18 U.S.C. § 922(g)(9) and the reasonableness of his sentence.The United States District Court for the Western District of Oklahoma denied Jackson's motion to declare § 922(g)(9) unconstitutional. Jackson then pleaded guilty without a plea agreement. At sentencing, the court determined that Jackson's possession of firearms on two separate occasions constituted relevant conduct, leading to a higher advisory Sentencing Guidelines range. Jackson was sentenced to 72 months in prison.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that § 922(g)(9) is constitutional as applied to Jackson, consistent with the principles established in United States v. Rahimi and United States v. Rogers. The court found that Jackson's prior domestic violence convictions demonstrated a propensity for violence, justifying his disarmament under § 922(g)(9). The court also upheld the district court's determination that Jackson's possession of additional firearms was relevant conduct, supporting the sentence imposed.The Tenth Circuit affirmed the district court's judgment of conviction and sentence, concluding that the sentence was both procedurally and substantively reasonable. View "United States v. Jackson" on Justia Law

A vehicle was stopped by Trooper Ryan Wilkinson in Smith County for speeding, having an expired temporary tag, and an inoperative brake light. The driver, Bridgett Tobler, did not have a valid driver’s license, and the passenger, Justin Heath Pettit, was on probation. After confirming there were no warrants for either individual, Trooper Wilkinson prolonged the stop to wait for a K-9 unit, which arrived nearly an hour later. The K-9 alerted to the presence of drugs, leading to a search that uncovered prescription medication, syringes, and a sawed-off shotgun. Pettit was charged with possession of a prohibited weapon.The trial court granted Pettit’s motion to suppress the evidence, concluding that the detention was unreasonably prolonged without reasonable suspicion, violating the Fourth Amendment. The State appealed, arguing that Pettit, as a passenger, lacked standing to challenge the search. The Twelfth Court of Appeals agreed with the State, reversing the trial court’s decision and holding that Pettit did not have standing to contest the search.The Court of Criminal Appeals of Texas reviewed the case and held that Pettit had standing to challenge the search of the vehicle. The court reasoned that both drivers and passengers have a reasonable expectation of privacy in not being detained longer than necessary for a traffic stop. The search of the vehicle was deemed the fruit of the unreasonably prolonged detention. The court reversed the judgment of the court of appeals and remanded the case for further consideration of whether the prolonged detention was reasonable. View "State v. Pettit" on Justia Law

After stealing a pickup truck and a gun from a ranch in Odessa, the appellant was stranded at a convenience store in McCamey. His suspicious behavior drew the attention of Upton County sheriff’s deputies Thomas Stiles and Billy Kennedy. When the deputies began investigating, the appellant instigated a shootout, resulting in the death of Deputy Kennedy.A Nueces County jury convicted the appellant of capital murder for killing Deputy Kennedy. Based on the jury’s answers to special issues during the punishment phase, the trial court sentenced him to death. The appellant raised two points of error challenging his conviction and seven points challenging his sentence.The Court of Criminal Appeals of Texas reviewed the case. The appellant argued that the trial court erred by not instructing the jury on the lesser-included offense of murder, claiming a juror could have doubted whether he knew Kennedy was a peace officer. The court rejected this argument, stating the appellant did not preserve the issue and that no evidence supported the need for such an instruction. The appellant also claimed that the trial court’s refusal to submit the murder instruction violated his constitutional rights, but the court found no evidence to support this claim.The appellant challenged the sufficiency of the evidence regarding his future dangerousness, arguing his injuries and inevitable incarceration mitigated this risk. The court found the evidence legally sufficient, citing the circumstances of the offense, the appellant’s history of violence, lack of remorse, and misbehavior in custody.The appellant also contested the admission of hearsay evidence and the denial of a mistrial due to the State’s failure to provide notice of extraneous misconduct evidence. The court found no abuse of discretion in these rulings. Additionally, the court deemed the prosecutor’s improper argument referencing facts outside the record as harmless beyond a reasonable doubt. Finally, the appellant’s constitutional challenge to the future dangerousness special issue was not preserved for review. The court affirmed the trial court’s judgment and sentence. View "GREEN v. THE STATE OF TEXAS" on Justia Law

Thomas Stephens, a 20-year-old, sought to carry a handgun in public beyond the limited ways allowed under Georgia law. Georgia law permits individuals aged 18 to 21 to possess long guns and carry them in public, and to possess handguns in specific locations such as their home, car, or place of business. However, carrying a handgun in public generally requires the individual to be 21 or older unless they have received military weapons training. Stephens challenged the statute that restricts public carry of handguns to those over 21, arguing it violates the Georgia Constitution.Stephens initially filed the lawsuit along with Georgia Second Amendment, Inc., which later withdrew its appeal, leaving Stephens as the sole appellant. The trial court dismissed Stephens's complaint, upholding the statute. The court reasoned that the statute was a reasonable safety measure and did not constitute a complete prohibition on the right to bear arms, citing longstanding precedent that allows the General Assembly to regulate the manner of bearing arms.The Supreme Court of Georgia reviewed the case and affirmed the lower court's decision. The court held that the statutory scheme did not violate the Georgia Constitution. The court emphasized that state statutes are presumed constitutional and that Stephens failed to meet the heavy burden of proving otherwise. The court also noted that the consistent construction of the right to bear arms under Georgia law, which allows the General Assembly to regulate the manner of bearing arms, has been upheld for over a century. Stephens's argument to reconsider and overrule this precedent was not compelling, and his constitutional challenge to the statute failed. View "STEPHENS v. STATE OF GEORGIA" on Justia Law

Four businesses involved in the cultivation, manufacture, possession, and distribution of marijuana within Massachusetts, in compliance with state laws, sued the Attorney General of the United States in 2023. They claimed that the Controlled Substances Act (CSA) exceeded Congress's powers under Article I of the U.S. Constitution and violated the Due Process Clause of the Fifth Amendment. They sought a declaratory judgment and an injunction to prevent the enforcement of the CSA against their intrastate activities.The United States District Court for the District of Massachusetts dismissed the plaintiffs' claims for failing to state a claim upon which relief could be granted. The court reasoned that the Supreme Court's decision in Gonzales v. Raich, which upheld the CSA's application to intrastate marijuana activities under the Commerce Clause, was controlling. The District Court also found no precedent for recognizing a fundamental right to cultivate, process, and distribute marijuana, thus rejecting the plaintiffs' substantive due process claim.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's dismissal. The First Circuit held that the CSA's regulation of intrastate commercial marijuana activities was within Congress's power under the Commerce Clause and the Necessary and Proper Clause. The court found that Congress had a rational basis for concluding that intrastate marijuana activities substantially affect interstate commerce. Additionally, the court rejected the plaintiffs' substantive due process claim, holding that there is no fundamental right to cultivate, manufacture, possess, and distribute marijuana. The court emphasized that historical practices and recent state legislative trends do not establish such a fundamental right. View "Canna Provisions, Inc. v. Bondi" on Justia Law