Justia Constitutional Law Opinion Summaries

The case concerns the conviction of an individual for malice murder and related offenses following the shooting death of a man whose truck and credit card were later used by the defendant. After the victim was reported missing, police observed the defendant driving the victim’s truck and, following a high-speed chase, arrested him. During the investigation, incriminating evidence was discovered, including bloodstains and a shell casing in the truck, digital evidence of the defendant in possession of the truck, and eyewitness testimony. The defendant ultimately confessed to holding the victim at gunpoint, shooting him, and hiding the body.Following his arrest, the defendant was indicted by a Fulton County grand jury on multiple charges, including murder, armed robbery, and related firearm offenses. At trial in the Superior Court of Fulton County, the jury found him guilty on all counts. After sentencing, the defendant moved for a new trial, claiming violations of his rights during police interrogation and improper admission of only portions of his custodial interview. The trial court denied the motion, finding that the defendant had not unequivocally invoked his right to counsel and had knowingly waived his Miranda rights. The defendant appealed, and the Court of Appeals transferred the case to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed whether the defendant’s Miranda rights were violated and whether the trial court erred under the rule of completeness. The Court held that the defendant’s statements during the custodial interview did not constitute an unequivocal invocation of the right to remain silent or to counsel, and that he knowingly and intelligently waived his Miranda rights before making incriminating statements. The Court also found no plain error in the trial court’s handling of the interview recording. The convictions were affirmed. View "MCDANIEL v. THE STATE" on Justia Law

A 20-year-old college student, E.F., became extremely intoxicated while out with friends, leading to her being put in a Lyft to return home. The driver, Jerome Antonio Booze, picked her up and attempted to help her access her gated apartment complex. During this process, E.F. displayed clear signs of extreme intoxication: slurred speech, incoherence, inability to walk unaided, vomiting, and periods of unconsciousness. Booze eventually moved his car to a parking area, got in the back seat with E.F., and had sex with her. E.F. later reported the incident as rape, and Booze, after initially denying remembering E.F., admitted to having sex but claimed it was consensual. The evidence at trial included video footage, witness testimony, and Booze’s own statements.The Superior Court of Cobb County convicted Booze of rape and denied his motion for a new trial. Prior to trial, Booze filed a motion to quash the indictment, arguing that Georgia’s rape statute (OCGA § 16-6-1(a)(1)) was unconstitutionally vague as applied, specifically regarding the level of intoxication required to negate consent. The trial court denied the motion. Booze also challenged the constitutionality of the statute, the sufficiency of the evidence, and raised issues regarding jury instructions on mistake of fact and constructive force.The Supreme Court of Georgia reviewed the appeal. It held that OCGA § 16-6-1(a)(1) is not unconstitutionally vague as applied to Booze, given well-established Georgia case law that intercourse with a woman whose will is lost from intoxication is rape, and the evidence here unmistakably showed extreme intoxication. The Court further held the evidence was constitutionally sufficient to sustain the conviction, and that the jury instructions on mistake of fact and constructive force were proper. The Court affirmed Booze’s conviction. View "BOOZE v. THE STATE" on Justia Law

In April 2012, Ronald Lange Buchalla assaulted Jean Marie Morgan by strangling her and striking her in the head with a pool cue. In 2013, Buchalla pleaded guilty to attempted murder and aggravated assault for these actions and received consecutive sentences totaling 30 years, with 20 years in prison and 10 years on probation. In 2015, Morgan died, allegedly as a result of the injuries from Buchalla’s assault. Nearly a decade later, in October 2024, a grand jury indicted Buchalla for malice murder and felony murder, predicated on aggravated assault, based on Morgan’s death.The Superior Court of Camden County reviewed Buchalla’s plea in bar, through which he sought to dismiss the murder indictment before trial, arguing that the prosecution was barred under statutory and constitutional double jeopardy protections. The trial court denied the plea, reasoning that the murder charge was based on an essential fact—Morgan’s death—that had not occurred at the time of Buchalla’s original conviction.On appeal, the Supreme Court of Georgia examined whether double jeopardy principles barred the murder prosecution. The Court applied the clear error standard to factual findings and reviewed legal conclusions de novo. It held that neither constitutional nor statutory double jeopardy protections prevent the State from prosecuting a defendant for murder after conviction for a lesser-included offense, such as aggravated assault, when the victim’s death occurred after the original conviction. The Court found that the element of murder—the victim’s death—had not been completed or known to the prosecutor at the time of the first prosecution. Accordingly, the Supreme Court of Georgia affirmed the trial court’s denial of Buchalla’s plea in bar. View "BUCHALLA v. THE STATE" on Justia Law

Three defendants, including the appellant, were implicated in the shooting death of a woman during a burglary of her home in Fulton County, Georgia. On the evening of the incident, the defendants were seen near the victim’s residence, and the victim herself called 911 to report suspicious activity. During the burglary, the appellant discovered the victim hiding in her closet and fatally shot her. The evidence included testimony from neighbors, a subdivision security officer, and individuals to whom the appellant confessed. Items linked to the burglary were found along the suspects’ escape route. The appellant also made incriminating statements to family members after the crime.A Fulton County grand jury indicted the appellant for malice murder, felony murder, burglary, and related firearm offenses. Following a joint jury trial in the Superior Court of Fulton County, the appellant was convicted on all counts against him and sentenced to life without parole for malice murder, with additional consecutive sentences for the other crimes. The trial court vacated or merged the remaining counts for sentencing. The appellant’s initial motion for a new trial was denied after a substantial delay, prompting a timely appeal.The Supreme Court of Georgia reviewed the appellant’s arguments, including the sufficiency of the evidence, alleged evidentiary errors, motions for mistrial, jury selection issues, denial of severance, sentencing challenges, and claims of ineffective assistance of counsel. The Court held that the evidence was constitutionally sufficient to support the convictions. Alleged errors in evidentiary rulings and trial management did not amount to reversible error, and most claims regarding mistrials and ineffective assistance were either waived or not preserved for review. The Court also held that the sentence of life without parole was not grossly disproportionate nor did it violate the Eighth Amendment. The convictions and sentences were affirmed. View "BANKS v. THE STATE" on Justia Law

Deanthony Cullins was indicted on charges including malice murder and aggravated assault after allegedly shooting at a vehicle, resulting in one fatality. Cullins claimed he acted in self-defense. As the trial approached, the State sought a continuance to review newly obtained deposition transcripts from a related civil case, but the motion was denied. The State also filed an untimely motion to admit other acts evidence, which the court denied. During trial, the prosecution questioned a detective in a manner that highlighted Cullins’s post-arrest silence, prompting the defense to object and move for a mistrial on the grounds that the questioning improperly commented on the defendant’s right to remain silent. The trial court granted the mistrial.Following the mistrial, Cullins filed a plea in bar, arguing that double jeopardy barred retrial because the State intentionally provoked the mistrial to gain a tactical advantage. The Superior Court of DeKalb County held a hearing and found that the State’s conduct—particularly the improper questioning and the context of late filings, requests for delay, and witness preparedness—indicated that the prosecution was not ready for trial and sought to abort the proceedings for a fresh start. The trial court granted the plea in bar, finding that the State’s objective was to intentionally end the trial to secure a more favorable opportunity at retrial.The Supreme Court of Georgia reviewed whether the trial court clearly erred in finding that the State intended to goad Cullins into moving for a mistrial. Applying a deferential standard of review to the trial court’s factual findings, the Supreme Court held that there was evidence supporting the trial court’s determination and that its findings were not clearly erroneous. The Supreme Court affirmed the trial court’s judgment, barring the State from retrying Cullins. View "THE STATE v. CULLINS" on Justia Law

A 16-year-old defendant shot and killed a 17-year-old in what appeared to be a gang-related incident. The defendant, riding in the backseat of a car, observed the victim wearing a rival gang’s T-shirt, exited the vehicle, and shot the victim five times. Charged with first-degree murder and felony-firearm, the jury convicted him of the lesser included offense of second-degree murder and felony-firearm. The trial court sentenced him as an adult to 50 to 75 years’ imprisonment for second-degree murder, consecutive to two years for felony-firearm, exceeding the advisory sentencing guidelines recommending 12 to 25 years or parolable life.On direct appeal, the Michigan Court of Appeals affirmed the conviction and sentence, finding no disproportionality under People v Milbourn. The Michigan Supreme Court denied leave to appeal. Decades later, the defendant filed a motion for relief from judgment, arguing his sentence was unconstitutional and disproportionate in light of Miller v Alabama and related cases. The Wayne Circuit Court denied the motion, as did the Court of Appeals. The Supreme Court remanded for reconsideration in light of People v Stovall and People v Boykin, which addressed youth sentencing.The Michigan Supreme Court held that a sentence of 50 to 75 years’ imprisonment for second-degree murder committed by a youthful offender violates the prohibition on cruel or unusual punishment under the state constitution and applies retroactively to cases on collateral review. The Court found that all Bullock factors supported this conclusion, noting that such a sentence is harsher than those imposed for first-degree murder on youths and fails to advance rehabilitation. The Court affirmed the Court of Appeals’ reversal of the trial court’s denial of relief, vacated the sentence, and remanded for resentencing, while vacating portions of the Court of Appeals’ opinion addressing Milbourn and Boykin. View "People Of Michigan v. Eads" on Justia Law

A man was arrested without a warrant after taking his three-month-old daughter to the hospital, where doctors suspected abuse. He denied harming the child during initial police questioning. The child died that evening, and an autopsy the next day concluded her death was a homicide due to traumatic brain injury. Two days after his arrest, and at least 64 hours into his warrantless detention, the man waived his Miranda rights and made statements to a detective that included several explanations for his daughter’s injuries, including that he shook her. A magistrate later found probable cause and authorized a criminal complaint.The man was convicted by a jury in the Ingham Circuit Court of felony murder and first-degree child abuse. The Michigan Court of Appeals affirmed his conviction, and the Michigan Supreme Court denied leave to appeal. Years later, the trial court granted the man’s motion for relief from judgment due to ineffective assistance of counsel, leading to a new trial. Before the retrial, the prosecution sought to admit his statements from the prolonged detention. The trial court, following a hearing, ruled the statements were voluntary under the factors from People v Cipriano and thus admissible, despite acknowledging that the man had been detained in violation of the Fourth Amendment under Riverside Co v McLaughlin. The Michigan Court of Appeals denied leave to appeal this ruling.The Michigan Supreme Court held that when an arrestee is detained in violation of the Fourth Amendment’s requirement for a prompt judicial determination of probable cause, any statements made must be excluded unless the prosecution proves the statements were sufficiently attenuated from the unconstitutional detention. Voluntariness under Cipriano is a separate inquiry. The Supreme Court vacated the trial court’s order admitting the statements and remanded for determination under the proper standard. View "People v. Sanders" on Justia Law

A defendant, who was 15 years old at the time of the offense, was convicted in 1988 of first-degree felony murder, armed robbery, and felony-firearm following a bench trial. He received a sentence of life without parole for the murder conviction. After the United States Supreme Court decided in *Miller v. Alabama* that mandatory life without parole sentences for juveniles are unconstitutional, and in *Montgomery v. Louisiana* that this rule applies retroactively, the prosecution moved to reimpose the defendant’s life without parole sentence under Michigan law. At his resentencing hearing, the defendant presented expert psychological evidence suggesting his capacity for rehabilitation, while the prosecution presented no witnesses. The trial court reimposed the life without parole sentence, stating the prosecution did not bear the burden of proof.The Michigan Court of Appeals later vacated the amended sentence after the Michigan Supreme Court held in *People v. Taylor* that the prosecution bears the burden of proof at such hearings. On remand, the prosecution requested that the defendant be compelled to undergo a psychological evaluation by its expert or, alternatively, that the defense’s psychological evidence be excluded. The trial court granted this request, and the Court of Appeals affirmed that decision.The Michigan Supreme Court held that if a defendant intends to introduce expert psychological evidence at a Miller resentencing hearing, the trial court may require the defendant to submit to a psychological examination by a prosecution expert, consistent with the constitutional right against self-incrimination. However, evidence from this compelled examination is admissible only as rebuttal and not during the prosecution's case-in-chief. The court also clarified that the second Miller hearing is a new proceeding and vacated any order incorporating the record from the prior hearing. The case was remanded to the trial court for proceedings consistent with these rulings. View "People v. Black" on Justia Law

Two long-term employees of a township senior center lost their jobs when a newly elected board, led by a candidate from the opposing political party, reorganized the center's leadership structure. The plaintiffs, both Republicans, had campaigned for the losing Republican candidate in the local election. After the incoming Democratic supervisor and board took office, they voted to eliminate the plaintiffs' positions as part of a broader reorganization, creating new roles and appointing others, including one individual who had also supported the Republican candidate.After their terminations, the plaintiffs filed suit in Illinois state court, naming the township and certain officials as defendants. They alleged, among other claims, that their First Amendment rights had been violated because their political activity was a motivating factor in their dismissals. The defendants removed the case to the United States District Court for the Northern District of Illinois. Following partial dismissal of claims, only the First Amendment retaliation and breach of implied contract claims against the township remained. After discovery, the district court granted summary judgment for the township, finding plaintiffs had not shown that their political activity was a motivating factor in the terminations, nor had they rebutted the township's evidence of legitimate reasons for the reorganization.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit held that the plaintiffs had not produced sufficient evidence that their political activity motivated their terminations. The court found that the undisputed evidence showed neither the new supervisor nor the trustees knew of the plaintiffs' political involvement, and there were valid, non-retaliatory reasons for the personnel changes. The court affirmed the district court’s grant of summary judgment for the township. View "Fox v DuPage Township" on Justia Law

A man’s wife called 911 to request a welfare check after her husband threatened to harm himself. The dispatcher relayed to law enforcement that the man had made similar threats in the past, was not acting like himself, and was last known to be at a riverfront house. When the responding officer arrived, he found the man’s vehicle at the property but received no response to repeated knocks and announcements at multiple doors. The officer entered the house several times after announcing himself, ultimately discovering a suicide note and pill bottle. Upon further entry, the officer encountered the man in his bedroom. After a brief exchange in which the man repeatedly ordered the officer to leave, the man retrieved a rifle and advanced toward the officer, ignoring commands to stop. The officer fired, fatally wounding the man.The personal representative of the man’s estate filed suit in South Carolina state court against the responding officer, the county sheriff, and the sheriff’s office, alleging violations of the Fourth Amendment for unlawful entry and excessive force, as well as a claim for failure to train. The case was removed to the United States District Court for the District of South Carolina. The district court granted summary judgment to the defendants on all federal claims, holding that the officer’s entries and use of force were objectively reasonable and that he was entitled to qualified immunity. The court also found no basis for municipal liability and remanded the state-law claims to state court.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the officer’s warrantless entries were justified under the emergency aid exception, given the objectively reasonable belief that the man was at risk of serious harm. The court also concluded that the use of deadly force was objectively reasonable under the circumstances. Accordingly, all federal claims were properly dismissed. View "Crosby v. Colleton County Sheriff's Office" on Justia Law