Justia Constitutional Law Opinion Summaries

The plaintiffs, Glenn Bowles, Kenneth Franks, and Robert Gardner, challenged the constitutionality of Michigan's Court of Claims Act. Bowles and Franks, former police academy instructors, faced employment actions after allegations of misconduct, while Gardner, a former doctoral student, faced expulsion and subsequent employment issues due to his advocacy for migrant workers. They argued that the Act violated their Fourteenth Amendment rights by requiring Court of Appeals judges to serve on the Court of Claims, thus creating potential bias in appellate reviews and denying them jury trials.The United States District Court for the Eastern District of Michigan dismissed their complaint. The court found that the plaintiffs lacked standing as they did not demonstrate how the Court of Claims Act directly caused their injuries. Additionally, the court held that Bowles's claims were precluded due to a prior federal lawsuit and concluded that the plaintiffs' constitutional claims lacked merit.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit agreed that the plaintiffs lacked Article III standing. The court noted that the plaintiffs' injuries were not fairly traceable to the actions of Michigan's Governor and Attorney General, who were named as defendants. The court also found that the requested relief, an injunction against the enforcement of the Court of Claims Act, would not redress the plaintiffs' employment-related injuries. Consequently, the Sixth Circuit affirmed the district court's dismissal of the case on jurisdictional grounds, modifying the judgment to a dismissal without prejudice. View "Bowles v. Whitmer" on Justia Law

In September 2020, Child Protective Services removed twelve-year-old Z.S. and her siblings from their home due to domestic violence allegations against their stepfather, Michael J. In May 2021, Z.S. disclosed to her aunt and therapist that Michael J. had sexually abused her. Subsequently, Michael J. was indicted on multiple sexual offense charges, including second-degree sexual assault and incest. During the trial, the prosecution relied heavily on Z.S.'s testimony, as there was no physical evidence. Michael J. denied the allegations and testified in his defense, supported by his wife, who claimed he was never alone with Z.S. However, Z.S.'s sister contradicted this, stating they were often left alone with him.The Circuit Court of Fayette County allowed the prosecution to ask potential jurors during voir dire if they would convict Michael J. based solely on Z.S.'s testimony if they found it believable. All potential jurors agreed. Michael J. objected, but the court overruled the objection. The jury found Michael J. guilty on all charges, and he was sentenced to 61 to 145 years in prison. Michael J. appealed, arguing that the voir dire question was improper and prejudiced the jury.The Supreme Court of Appeals of West Virginia reviewed the case and concluded that the prosecution's voir dire question was an improper commitment question. It violated Michael J.'s constitutional right to an impartial jury by asking jurors to pledge to convict based on the victim's testimony alone, without considering the burden of proof beyond a reasonable doubt. The court found that this likely prejudiced the jury and reversed the lower court's decision, remanding the case for a new trial. View "State of West Virginia v Michael J." on Justia Law

The case involves a challenge to Texas House Bill 20 (H.B. 20) by NetChoice, L.L.C. and the Computer & Communications Industry Association (CCIA). The plaintiffs argue that H.B. 20, which regulates content moderation by social media platforms, violates the First Amendment. The Supreme Court previously emphasized that facial challenges to state laws, especially under the First Amendment, require a thorough exploration of both the law's unconstitutional and constitutional applications. The Supreme Court found the record in this case to be underdeveloped, necessitating further factual discovery to determine who and what activities are covered by H.B. 20 and how these activities burden expression.The United States District Court for the Western District of Texas initially reviewed the case. The district court largely agreed with the plaintiffs that the issues were purely legal questions and required the State of Texas to complete discovery in a short period to avoid burdening the plaintiffs. The district court blocked extensive discovery, which the Supreme Court later indicated was necessary for a proper evaluation of the case.The United States Court of Appeals for the Fifth Circuit is currently reviewing the case. The court remanded the case to the district court for further proceedings consistent with the Supreme Court's instructions. The district court must now determine the full range of activities covered by H.B. 20, identify the actors involved, and assess how content moderation decisions burden expression. The district court must also separately consider the individualized-explanation provisions of H.B. 20 and evaluate whether these provisions unduly burden expressive activity. The Fifth Circuit emphasized that plaintiffs bear the burden of developing a factual record to support their facial challenge to H.B. 20. The case is remanded for further factual development and analysis. View "NetChoice v. Paxton" on Justia Law

Wes Lee Whitaker was convicted by a jury of sexual intercourse without consent (SIWC), incest, and sexual assault. The case involved allegations that Whitaker sexually abused his stepdaughter, L.M., who was a young child at the time. The abuse was reported by L.M.'s mother, Jessica, after she observed suspicious behavior and L.M. disclosed inappropriate touching by Whitaker. L.M. provided detailed accounts of the abuse during a forensic interview and a medical examination, although she could not recall many details during the trial.The District Court of the Fourth Judicial District, Missoula County, presided over the trial. Whitaker raised several issues on appeal, including the admission of testimony via video from a federal prisoner, the admission of L.M.'s prior statements, and a claim of double jeopardy regarding his convictions for SIWC and sexual assault. The District Court allowed the video testimony due to COVID-19 concerns and admitted L.M.'s prior statements as inconsistent with her trial testimony.The Supreme Court of the State of Montana reviewed the case. The court held that the District Court did not violate Whitaker's confrontation rights by allowing the video testimony, as the decision was justified by the pandemic and the witness's incarceration status. The court also found no abuse of discretion in admitting L.M.'s prior statements, as her inability to recall details at trial constituted a material inconsistency. However, the court agreed with Whitaker and the State that his convictions for SIWC and sexual assault violated double jeopardy, as they were based on the same act. Consequently, the court reversed the sexual assault conviction and remanded for entry of an amended judgment, while affirming the other convictions. View "State v. Whitaker" on Justia Law

Thomas Eugene Creech, sentenced to death in 1995, faced a failed execution attempt in early 2024 due to the inability to establish reliable intravenous access. Following this, Creech filed a petition for post-conviction relief, arguing that any further attempt to execute him would violate his constitutional rights under the Fifth Amendment’s Double Jeopardy Clause and the Eighth Amendment’s prohibition against cruel and unusual punishment.The District Court of the Fourth Judicial District of Idaho dismissed Creech’s petition, construing his Eighth Amendment argument as a challenge to the method of execution, which it determined could not be litigated in a post-conviction action. The court suggested that Creech could pursue his Eighth Amendment challenge through other legal avenues, such as a 42 U.S.C. § 1983 action. The court also addressed the merits, finding that a second execution attempt did not violate the Fifth Amendment as it did not impose more punishment than authorized, nor did it violate the Eighth Amendment as the failed attempt did not involve intentional or malicious infliction of unnecessary pain.The Supreme Court of Idaho affirmed the district court’s dismissal. It held that Creech’s claims were properly raised under Idaho Code section 19-2719 but found no genuine issue of material fact warranting an evidentiary hearing. The court determined that the failed execution did not constitute cruel and unusual punishment under the Eighth Amendment, as the psychological strain and pain experienced were inherent in any execution method. Additionally, the court ruled that a second execution attempt did not violate the Double Jeopardy Clause, as the initial attempt did not complete the punishment authorized by the legislature. Creech’s state constitutional claims were not considered as they were not adequately preserved for appeal. View "Creech v. State" on Justia Law

In the early morning, a police officer stopped Chad Thomas for driving with a broken headlight. During the stop, Thomas exhibited unusual behavior, such as rolling down the rear window instead of the front, being unable to find his driver’s license, and acting nervously. The officer conducted a pat-down search, during which Thomas mentioned he might have a "sharp," a term the officer associated with drug use. Thomas's behavior, including blocking the officer's view and lying about having his license, led the officer to call for a canine unit, which eventually alerted to the presence of drugs.The Circuit Court of Saline County overruled Thomas's motion to suppress the evidence found during the search, concluding that the officer had reasonable suspicion to extend the stop based on Thomas's behavior. The court found that the extension of the stop was justified by Thomas's actions and the need to verify his identity and the outstanding warrant. The court admitted the evidence, and the jury found Thomas guilty of possession of a controlled substance and unlawful possession of drug paraphernalia. Thomas was sentenced to 10 years in prison.The Supreme Court of Missouri reviewed the case and affirmed the circuit court’s judgment. The court held that the officer had reasonable suspicion to extend the traffic stop based on the totality of Thomas's behavior, which included nervousness, evasive actions, and inconsistent statements. The court found that the detention and subsequent search were lawful under the Fourth Amendment, as the officer's actions were justified by reasonable suspicion of criminal activity. View "State vs. Thomas" on Justia Law

In April 2023, Colorado Governor Jared Polis signed a law raising the minimum age for purchasing firearms in Colorado from 18 to 21. The law was set to take effect on August 7, 2023. Plaintiffs, including two individuals and a firearms advocacy group, filed a lawsuit in federal court seeking a preliminary injunction to prevent the law from taking effect. The district court granted the injunction on the day the law was to take effect, halting its enforcement. Governor Polis appealed the decision.The United States District Court for the District of Colorado initially found that the plaintiffs had standing, except for the advocacy group, and determined that the plaintiffs were likely to succeed on the merits of their Second Amendment challenge. The court concluded that the law was not consistent with the nation's historical tradition of firearms regulation and that the plaintiffs would suffer irreparable harm without the injunction. Governor Polis appealed the district court's decision, arguing that the plaintiffs lacked standing and that the law was consistent with historical firearm regulations.The United States Court of Appeals for the Tenth Circuit reviewed the case and reversed the district court's decision. The Tenth Circuit held that the plaintiffs did not demonstrate a substantial likelihood of success on the merits of their Second Amendment claim. The court found that the law was a presumptively lawful regulation imposing conditions on the commercial sale of firearms, which did not fall within the scope of the Second Amendment's protections. The court also determined that the plaintiffs did not establish irreparable harm and that the balance of harms and public interest favored the enforcement of the law. Consequently, the Tenth Circuit remanded the case with instructions to dissolve the preliminary injunction. View "Rocky Mountain Gun Owners v. Polis" on Justia Law

In this case, Charles House was involved in drug trafficking activities, traveling to California to obtain large quantities of marijuana and methamphetamine, which he then shipped to addresses in Indiana. In October 2018, FedEx personnel alerted law enforcement to suspicious packages addressed to various locations in Anderson, Indiana. A drug-sniffing dog indicated that five of the twelve packages contained drugs, leading to a state warrant and the discovery of methamphetamine and marijuana. Subsequently, law enforcement installed a pole camera to surveil House’s residence for thirteen months, capturing his activities and patterns related to drug distribution.The United States District Court for the Southern District of Indiana denied House’s motion to suppress the pole camera evidence, relying on the precedent set in United States v. Tuggle, which held that the warrantless use of pole cameras does not constitute a search under the Fourth Amendment. House was found guilty on all counts, including drug distribution and possession of a firearm by a convicted felon, and was sentenced to 360 months’ imprisonment.The United States Court of Appeals for the Seventh Circuit reviewed the case and reaffirmed the Tuggle decision. The court held that the warrantless use of pole cameras to observe a home does not amount to a search under the Fourth Amendment, as it is consistent with Supreme Court precedent and the rulings of other federal courts. The court emphasized that House did not have a reasonable expectation of privacy in the activities observable from public thoroughfares. The court affirmed the district court’s denial of House’s motion to suppress the pole camera evidence. View "United States v. House" on Justia Law

Cedric Allen Ricks was convicted of capital murder in Texas state court for killing his girlfriend and her eight-year-old son and was sentenced to death. After his direct appeal and state habeas petition were denied, Ricks filed a federal habeas petition, which the district court also denied, including a certificate of appealability (COA).Ricks sought a COA from the United States Court of Appeals for the Fifth Circuit on several claims. The district court had denied his Batson claim, which alleged racial discrimination in jury selection, finding no prima facie case of discrimination and accepting the prosecution's race-neutral justifications. The district court also found no pattern of racially disparate questioning. The Fifth Circuit agreed, noting that reasonable jurists would not find the district court's assessment debatable or wrong, and thus denied the COA on this claim.Ricks also claimed ineffective assistance of appellate counsel for not raising the Batson claim on appeal. The state court had denied this claim on the merits. The Fifth Circuit found that since the Batson claim was meritless, the appellate counsel's failure to raise it was neither unreasonable nor prejudicial, and denied the COA on this claim as well.Ricks argued that his due process rights were violated when the jury saw him in shackles. The district court rejected this claim, noting that Ricks exposed his shackles himself and failed to show any substantial influence on the jury's verdict. The Fifth Circuit found this claim procedurally defaulted because it was not raised on direct appeal and was barred by the Texas Court of Criminal Appeals. Consequently, no COA was issued for this claim.Lastly, Ricks claimed ineffective assistance of trial counsel for not objecting to the shackling and for not challenging the State's peremptory strikes against female venire members. The Fifth Circuit found the trial counsel's decisions reasonable and strategic, and thus denied the COA on these claims.The Fifth Circuit denied the motion for a COA on all claims. View "Ricks v. Lumpkin" on Justia Law

In November 2021, Brendan Krepchin reported an armed robbery at his apartment. Upon investigation, the Mountain View Police Department found no evidence of a robbery but discovered a note suggesting potential violence, law enforcement equipment, and firearms. The police department sought and obtained an emergency gun violence restraining order (GVRO) from the Santa Clara County Superior Court, which was later extended to a three-year order after a hearing in January 2023.The trial court found clear and convincing evidence that Krepchin posed a significant danger of causing personal injury by possessing firearms. The court emphasized the note found in his apartment and his inability to explain it. Krepchin appealed, arguing that the GVRO violated his Second Amendment rights, was procedurally defective, and that the trial court erred in qualifying an officer as a threat assessment expert and admitting hearsay evidence.The California Court of Appeal, Sixth Appellate District, affirmed the trial court's decision. The appellate court held that the GVRO did not violate the Second Amendment, referencing the U.S. Supreme Court's decision in United States v. Rahimi, which upheld firearm restrictions for individuals posing a threat. The court also found no procedural defects in the GVRO's issuance and ruled that the trial court did not abuse its discretion in qualifying the officer as an expert or in admitting hearsay evidence. The court concluded that substantial evidence supported the trial court's findings, including the note and other evidence indicating Krepchin's potential for violence. View "Mountain View Police Dept. v. Krepchin" on Justia Law