Justia Constitutional Law Opinion Summaries

Orthodox Jewish families and schools challenged California's requirement that private schools be nonsectarian to provide special education under the IDEA. The families argued this requirement violated their Free Exercise and Equal Protection rights by preventing them from advocating for religious school placements for their children with disabilities. The schools claimed the requirement barred them from certification solely due to their religious affiliation.The U.S. District Court for the Central District of California dismissed the case, ruling the schools and one family lacked standing and denying the families' motion for a preliminary injunction. The court found the schools did not demonstrate they were "able and ready" to apply for certification and that the nonsectarian requirement did not affect the educational placement of one family's child. However, it held that another family had standing to challenge the requirement.The U.S. Court of Appeals for the Ninth Circuit affirmed the dismissal of the schools' and one family's claims for lack of standing but reversed the dismissal of the other families' claims. The court held that the nonsectarian requirement burdened the families' free exercise rights by preventing them from advocating for religious school placements. It found the requirement was not neutral to religion and applied strict scrutiny, concluding the State failed to show the requirement was narrowly tailored to serve a compelling interest. The court vacated the denial of the preliminary injunction and remanded for further consideration of the injunction factors. View "LOFFMAN V. CALIFORNIA DEPARTMENT OF EDUCATION" on Justia Law

Michael Benson was civilly committed to the Minnesota Sex Offender Program in 1993. In 2020, he petitioned for a reduction in custody, which the Special Review Board recommended denying. Benson then sought a rehearing and reconsideration from the Commitment Appeal Panel (CAP). He filed a motion to cross-examine witnesses and participate in his defense, expressing a preference to proceed pro se. The CAP allowed limited cross-examination by Benson but required his appointed counsel to be present and conduct initial questioning. Benson refused to participate under these conditions, leading the CAP to dismiss his petition.Benson appealed to the Minnesota Court of Appeals, arguing that the right to counsel under Minnesota Statutes section 253D.20 is waivable. The court of appeals affirmed the CAP's decision, holding that the right to counsel in section 253D.20 is not waivable, based on its precedent. The court also noted that Benson forfeited his constitutional arguments by not raising them at the CAP hearing.The Minnesota Supreme Court reviewed the case to determine whether a civilly committed person can waive the right to counsel under section 253D.20. The court concluded that the right to counsel is waivable, provided the waiver is knowing and intelligent. The court found the statutory language ambiguous but interpreted it in light of legislative intent, common law, and constitutional considerations. The court reversed the court of appeals' decision and remanded the case to the CAP to determine if Benson's waiver of counsel was knowing and intelligent. If so, the CAP must allow him to represent himself. View "In re Matter of the Civil Commitment of Benson" on Justia Law

A man was unable to purchase a firearm because a background check revealed he was subject to a long-term domestic violence protective order (DVPO). He sued the State, claiming he was no longer subject to a protective order as defined by federal statute and sought a permanent injunction and declaratory judgment to have the Department of Public Safety (DPS) notify a national database that he was no longer subject to a protective order under 18 U.S.C. § 922(g)(8). He filed a motion for summary judgment, which the State opposed, filing a cross-motion for summary judgment. The superior court granted the State’s cross-motion, and the man appealed.The superior court found that the DVPO had not expired and remained a qualifying order under Section 922(g)(8). It also concluded that the man’s constitutional claims were not ripe because he had not initiated modification or dissolution of the order. The court entered a final judgment in favor of the State.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court’s decision. The court held that the DVPO remained in effect and was a qualifying order under 18 U.S.C. § 922(g)(8). The court found that the legislative history supported the interpretation that DVPOs issued under AS 18.66.100(c)(1) are effective until further order of the court. The court also concluded that the man’s remaining claims were not ripe for adjudication because he had not attempted to dissolve or modify the DVPO. View "Eng v. State" on Justia Law

The case involves an automobile accident that occurred on June 2, 2018, where Theresa Fisher's vehicle was rear-ended by a vehicle driven by Steven Harter, Jr., causing a chain reaction. Steven Harter, Sr., was also named as a defendant because his son was a minor at the time. The plaintiff sought a declaratory judgment challenging the constitutionality of La. R.S. 13:4163, which allows legislators and legislative employees to obtain continuances or extensions of court dates.The 1st Judicial District Court upheld the constitutionality of La. R.S. 13:4163, and the appellate court declined the plaintiff’s application for supervisory review. The district court had previously granted a partial summary judgment in favor of the plaintiff, finding Steven Harter, Jr. negligent and his father vicariously liable. The court also dismissed the defendants' affirmative defenses of comparative and third-party fault. However, the district court denied the plaintiff's motion for declaratory judgment on the constitutionality of La. R.S. 13:4163, stating that the statute did not violate the separation of powers or any constitutional rights.The Supreme Court of Louisiana reviewed the case and reversed the district court's decision. The court held that La. R.S. 13:4163 is unconstitutional on its face because it usurps the judiciary's power to grant or deny continuances, violating the separation of powers doctrine. The court emphasized that the statute mandates courts to grant continuances ex parte, without a hearing, which undermines the courts' inherent authority to manage their dockets and ensure the fair administration of justice. The case was remanded to the district court with instructions to conduct a contradictory hearing for all contested motions for continuance. View "FISHER VS. HARTER" on Justia Law

James R. Kalita was convicted in county court of second-degree criminal trespass and refusal to obey a lawful order after he brought a flagpole into the Nebraska State Capitol Building, which was against the building's regulations. Despite being informed by Capitol security and Nebraska State Patrol officers that poles were not permitted, Kalita refused to remove the flagpole or leave the premises, leading to his arrest.Kalita appealed to the District Court for Lancaster County, arguing that the statutes and regulations under which he was convicted were unconstitutional as applied to him and that the evidence was insufficient to support his convictions. The district court affirmed the county court's judgment, finding the evidence sufficient and rejecting the constitutional challenge.The Nebraska Supreme Court reviewed the case and concluded that Kalita forfeited his constitutional challenge by failing to raise it in the county court. The court emphasized that constitutional issues must be specifically raised at the trial court level to be considered on appeal. The court also found that the evidence was sufficient to support Kalita's convictions, as he had clearly refused to obey a lawful order from the Nebraska State Patrol and remained in the Capitol building despite being informed that he was trespassing.The Nebraska Supreme Court affirmed the district court's judgment, upholding Kalita's convictions for second-degree criminal trespass and refusal to obey a lawful order. View "State v. Kalita" on Justia Law

Alex Francois, a Haitian national, left Haiti in 1979 to reunite with his U.S. citizen father. He has lived in New York City, raised six U.S. citizen children, and suffers from severe mental illnesses, including schizophrenia and bipolar disorder. Francois has been hospitalized multiple times for his mental health and has had several encounters with law enforcement, often related to his mental illness. In 2017, he was arrested for trespassing in Texas, found incompetent to stand trial, and subsequently transferred to U.S. Immigration and Customs Enforcement custody. The Department of Homeland Security charged him with removability under 8 U.S.C. § 1182(a)(6)(A)(i).The Immigration Judge (IJ) initially granted Francois withholding of removal, finding that he would likely be persecuted in Haiti due to his mental illness. The IJ based this decision on expert testimony and country conditions evidence, which highlighted the dire conditions and violent treatment of mentally ill individuals in Haitian prisons. The government appealed, and the Board of Immigration Appeals (BIA) remanded the case for further factfinding, questioning whether Francois would be singled out for persecution and whether there was a pattern of persecution against similarly situated individuals.The IJ, on remand, reversed the initial decision, denying Francois's claims for withholding of removal and protection under the Convention Against Torture (CAT). The IJ found that Francois had not proven he would be targeted for persecution in Haiti based on his mental illness. The BIA affirmed this decision, finding no clear error in the IJ's findings. Francois then filed a petition for review with the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit held that the BIA deprived Francois of due process by violating its own regulations, specifically by remanding for further factfinding instead of reviewing the IJ's initial findings for clear error. The court granted Francois's petitions for review, vacated the BIA's orders, and remanded the case for the BIA to review the IJ's initial order under the proper standards of review. View "Francois v. Garland" on Justia Law

The case involves the interpretation of Oregon Revised Statutes (ORS) 166.255, which makes it unlawful for a person to possess a firearm or ammunition if they have been convicted of a "qualifying misdemeanor" involving the use or attempted use of physical force against a family or household member. The defendant, Richard Darrel Eggers, was convicted of harassment under ORS 166.065(1)(a)(A) for subjecting his brother to offensive physical contact during a domestic altercation.The Lane County Circuit Court concluded that the harassment conviction constituted a "qualifying misdemeanor" under ORS 166.255, thereby prohibiting Eggers from possessing firearms. The Court of Appeals reversed this decision, holding that the "offensive physical contact" element of harassment did not meet the "physical force" requirement of ORS 166.255(3)(e).The Oregon Supreme Court reviewed the case to determine whether the "offensive physical contact" element of harassment qualifies as "physical force" under ORS 166.255(3)(e). The court concluded that the Oregon legislature intended to align ORS 166.255 with the federal firearms prohibition under the Violence Against Women Act (VAWA), which the U.S. Supreme Court had interpreted to include even minimal offensive touching as "physical force" in United States v. Castleman.The Oregon Supreme Court held that the "physical force" requirement in ORS 166.255(3)(e) includes the degree of force necessary to complete a common-law battery, which encompasses offensive physical contact. Therefore, harassment under ORS 166.065(1)(a)(A) is a "qualifying misdemeanor" for the purposes of ORS 166.255. The court reversed the decision of the Court of Appeals and affirmed the judgment of the circuit court, upholding the firearms prohibition against Eggers. View "State v. Eggers" on Justia Law

Danny Washington was convicted by a jury on multiple charges, including first-degree kidnapping, injury to personal property, and several counts of aggravated and simple assault. The charges stemmed from incidents involving his then-girlfriend, J.B., in October 2021. Washington allegedly assaulted J.B., damaged her vehicle, and forcibly confined her with a firearm, leading to his arrest and subsequent indictment on eight counts.The Circuit Court of the Second Judicial Circuit in Minnehaha County, South Dakota, presided over the trial. Washington filed several pretrial motions, including motions to exclude references to his parole status and to prevent the use of the term "victim" in court. The court granted these motions but denied his request for a personal copy of the discovery. During the trial, the jury found Washington guilty on all counts. Washington later filed a motion for a new trial, citing ineffective assistance of counsel and other trial errors, which the court denied. He was sentenced to 100 years for kidnapping, with additional concurrent and consecutive sentences for other charges.The Supreme Court of South Dakota reviewed the case. Washington argued ineffective assistance of counsel, insufficient evidence for the kidnapping conviction, cumulative trial errors, discrepancies between the oral and written sentences, and improper multiple convictions for aggravated assault. The court declined to address the ineffective assistance claim on direct appeal, noting the need for a more developed record. It found sufficient evidence to support the kidnapping conviction and determined that the alleged trial errors did not cumulatively deny Washington a fair trial. The court clarified that the written sentence, which suspended 60 years of the 100-year kidnapping sentence, controlled over any ambiguous oral pronouncements. Finally, the court held that entering multiple convictions for a single statutory offense arising from the same act violated double jeopardy principles, but found no plain error due to the lack of clear precedent. The court affirmed the lower court's decisions. View "State v. Washington" on Justia Law

Matthew Dettle was charged and convicted of three felonies in Florida: using a computer to solicit a child for unlawful sexual conduct, traveling to meet a minor after such solicitation, and using a two-way communications device to facilitate a felony. His conviction for the third offense was vacated. Dettle argued that his remaining two convictions violated the Double Jeopardy Clause of the U.S. Constitution, which prohibits multiple punishments for the same offense.The First District Court of Appeal found that Dettle's convictions for traveling to meet a minor and unlawful use of a two-way communications device violated double jeopardy and vacated the latter conviction. However, it affirmed his convictions for solicitation and traveling, as they were based on separate illegal acts. Dettle's convictions became final in 2017. After the Florida Supreme Court's decision in Lee v. State, which held that courts should only consider the charging document to determine double jeopardy violations, Dettle sought retroactive relief under this new rule.The Supreme Court of Florida reviewed whether the rule in Lee should apply retroactively. The court concluded that Lee does not apply retroactively to cases that were already final when it was decided. The court reasoned that the rule in Lee is procedural, not substantive, and does not meet the high bar for retroactive application under either the Witt or Teague standards. Consequently, the court affirmed the decision of the First District Court of Appeal, denying Dettle's request for postconviction relief. View "Dettle v. State of Florida" on Justia Law

Michael Jones was convicted of attempted murder and related charges after an incident where he and his codefendants, Syheed Wilson and Keirsten Carroll, were involved in a shooting of a cab driver, Alex Destin. Jones directed the cab driver and then shot him, while Wilson also shot the driver. The three were identified through surveillance footage and arrested. Wilson gave a statement to the police implicating Jones as the shooter.At trial, Jones objected to the admission of Wilson’s statement, arguing it violated the Sixth Amendment Confrontation Clause as established in Bruton v. United States. The trial court overruled the objection, and the jury was instructed to consider each defendant’s statement only against the one who made it. Jones was found guilty on all counts and sentenced to twenty to forty years in prison. The Superior Court affirmed the conviction, reasoning that the redacted statement, which referred to Jones as “my friend,” did not violate the Confrontation Clause because it did not explicitly name him and required linkage with other evidence to be incriminating.The Supreme Court of Pennsylvania reviewed the case, focusing on whether the admission of Wilson’s redacted statement violated Bruton. The court noted that the statement, though redacted to refer to Jones as “my friend,” still directly incriminated him by describing him in a way that the jury could easily identify him, especially since the jury was shown surveillance footage and still images identifying Jones. The court concluded that the statement violated Bruton’s prohibition against admitting a non-testifying codefendant’s confession that directly implicates the defendant.The Supreme Court of Pennsylvania vacated the Superior Court’s order and remanded the case for the Superior Court to determine whether the Bruton violation amounted to harmless error. View "Commonwealth v. Jones" on Justia Law