Justia Constitutional Law Opinion Summaries

The appellant was convicted of first-degree murder, robbery, and grand theft after brutally beating and killing a woman with whom he was temporarily staying. Evidence at trial established the appellant stole cash and the victim’s car, fled the state, and used an alias before being apprehended in Alabama and returned to Florida for prosecution. The jury convicted him and recommended the death penalty by a 10-2 vote. The trial court found aggravating factors including murder during a robbery and that the crime was especially heinous, atrocious, or cruel, outweighing mitigating circumstances, and imposed a sentence of death.The Supreme Court of Florida previously affirmed the convictions and sentence on direct appeal. The appellant later filed multiple unsuccessful postconviction motions in state and federal courts, including a motion based on the Florida Supreme Court’s decision in Hurst v. State, which was denied due to lack of retroactivity. After the Governor signed a death warrant, the appellant filed a successive motion for postconviction relief and a stay of execution in the Circuit Court for Polk County, raising claims regarding his age and cognitive decline, warrant timing, the warrant process, and the nonunanimous jury recommendation.The Supreme Court of Florida reviewed the circuit court’s summary denial of postconviction relief de novo. The Court affirmed the summary denial, holding the appellant’s claims were either procedurally barred or meritless. Specifically, it ruled there is no constitutional prohibition against executing elderly prisoners experiencing cognitive decline, the expedited warrant period does not violate due process or equal protection, the Governor’s discretion in signing death warrants is not unconstitutional, and a nonunanimous jury recommendation of death does not violate the Fifth, Sixth, or Eighth Amendments. The Court also denied the appellant’s request for a stay of execution. View "Beasley v. State" on Justia Law

In 2003, Samuel Anthony Cruz and several other members of the 7th Street gang were involved in two separate shooting incidents that resulted in the deaths of rival gang members. Cruz was charged with two counts of murder but entered a plea agreement in which he pleaded guilty to two counts of voluntary manslaughter, along with enhancements and gang participation. He was sentenced to a negotiated term of 21 years and eight months.Many years later, Cruz filed a petition under California Penal Code section 1172.6, seeking to vacate his manslaughter convictions and be resentenced on the grounds that legal standards for murder liability had changed. The Superior Court of Orange County issued an order to show cause and held an evidentiary hearing. At this hearing, the prosecution introduced transcripts from the 2007 trial of Cruz’s codefendant, Juan Becerra. Cruz objected to the use of these transcripts on due process grounds but did not challenge the factual findings or dispute this court’s prior opinions allowing such evidence. The trial court denied Cruz’s petition, finding he was an actual shooter in one killing and a direct aider and abettor in the other.Upon appeal, the California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the trial court’s consideration of a codefendant’s trial testimony violated Cruz’s right to due process. The court held that admission of this testimony did not violate procedural due process because Cruz had a full and fair opportunity to contest the evidence: he could have subpoenaed witnesses, testified on his own behalf, or introduced new evidence. The court affirmed the trial court’s order denying Cruz’s petition for vacatur and resentencing. View "P. v. Cruz" on Justia Law

Two Hawaii residents challenged two aspects of the state's “shall-issue” firearm licensing regime. The first challenged provision required that a handgun acquisition permit be used within thirty days of issuance or else the applicant must restart the process. The second provision required that, after purchasing a firearm, certain owners must bring it to a police station for inspection and registration in specific circumstances. Plaintiffs alleged that these requirements imposed undue burdens on their ability to acquire firearms, in violation of the Second Amendment.The United States District Court for the District of Hawaii granted summary judgment to the plaintiffs. The district court found both requirements facially unconstitutional under the Second Amendment, applying intermediate scrutiny as was then the circuit precedent. The court permanently enjoined the state from enforcing the challenged provisions. After this ruling, the Supreme Court decided New York State Rifle & Pistol Ass’n v. Bruen, which changed the standard for Second Amendment claims to a “text, history, and tradition” test.On appeal, the United States Court of Appeals for the Ninth Circuit, sitting en banc, considered the impact of Bruen and subsequent Supreme Court cases. The Ninth Circuit noted that Bruen distinguished between “may-issue” and “shall-issue” licensing regimes and, in footnote 9, characterized objective, non-abusive “shall-issue” regimes as presumptively constitutional. The court concluded that the two challenged Hawaii requirements were objective, non-discretionary, and did not amount to abusive practices that would deny ordinary citizens their Second Amendment rights. At most, the provisions imposed only modest, procedural burdens and did not materially impede firearm acquisition.The Ninth Circuit therefore reversed the district court’s injunction and remanded for further proceedings, holding that Hawaii’s “shall-issue” regime, as applied here, comports with the Second Amendment. View "YUKUTAKE V. LOPEZ" on Justia Law

Desroisiers was stopped by police while driving a Chevrolet Trailblazer with her mother as a passenger. The vehicle lacked an inspection sticker, prompting a police sergeant to initiate a traffic stop. The vehicle was registered but not to Desroisiers, who was on pre-conviction bail requiring her to commit no criminal act. During the encounter, Desroisiers resisted requests for documentation, accused the officer of harassment, and refused to comply with commands to be handcuffed. She crossed her arms, attempted to pull away, dropped to the ground after being handcuffed, and later stuck her foot outside the cruiser door, requiring officers to push it in. Footage showed her thrashing inside the cruiser.The Aroostook County Superior Court held a jury trial and admitted relevant evidence, including body camera footage. Desroisiers moved for judgments of acquittal on the charge of refusing to submit to arrest or detention, arguing the evidence showed only passive resistance, not physical force. The court denied the motions. The jury convicted her of refusing to submit to arrest or detention by using physical force against a law enforcement officer, operating an unregistered vehicle, and violating a condition of release. Desroisiers subsequently renewed her acquittal motions, which were again denied, and she timely appealed.The Maine Supreme Judicial Court reviewed the case. It interpreted the statutory phrase “uses physical force against a law enforcement officer” to include any muscular effort directed toward an officer’s attempt to detain, not just violent or injurious acts. The court held that Desroisiers’s crossing her arms, pulling away, and obstructing the cruiser door constituted physical force under the statute, affirming her convictions for refusing to submit to arrest and violating a condition of release. However, the court found insufficient evidence that Desroisiers was the current owner required to register the vehicle, vacating her conviction for operating an unregistered vehicle. View "State of Maine v. Desrosiers" on Justia Law

A minister sought to hold a small prayer event on the lower section of the Eastern Steps of the United States Capitol, advocating for various causes including opposition to federal funding of abortion. Under federal regulations, public demonstrations on these Steps are generally prohibited unless sponsored by a member of Congress, with violations carrying criminal penalties. The minister, unable to secure sponsorship, faced the threat of arrest and had previously been arrested for similar conduct.After protracted litigation and partial settlement, the parties stipulated to key facts and proceeded to cross-motions for summary judgment in the United States District Court for the District of Columbia. That court ruled in favor of the minister on his First Amendment claim, holding that the lower section of the Eastern Steps was a traditional public forum and that the regulations at issue suppressed more speech than necessary. The district court entered a permanent universal injunction, barring enforcement of the regulations against anyone wishing to demonstrate on the lower Steps. The Capitol Police Board appealed, and the district court later limited the injunction to the minister and up to 14 others pending appeal.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo regarding summary judgment and for abuse of discretion as to the injunction. The appellate court disagreed with the district court’s forum classification, holding that the Eastern Steps constitute a nonpublic forum because of their specialized function and physical integration with the Capitol. Nevertheless, the court held that the regulation’s requirement of congressional sponsorship for demonstrations was unreasonable, as it granted unbridled discretion to members of Congress, violating First Amendment protections. The court affirmed summary judgment for the minister but vacated the universal injunction, remanding for the district court to determine the proper scope of injunctive relief in light of recent Supreme Court guidance limiting universal injunctions. View "Mahoney v. United States Capitol Police Board" on Justia Law

A man was stopped by law enforcement while riding as a passenger in a car due to a traffic infraction. During the stop, officers identified him and found that he was on felony probation. The officers searched a backpack at his feet, which contained a significant quantity and variety of illegal narcotics, as well as items suggestive of drug distribution. The man denied ownership of the backpack, claiming it belonged to his girlfriend. Subsequent investigation revealed that he was subject to a probation agreement that included both waiver of his Fourth Amendment rights and consent to searches by law enforcement.He was charged in two separate cases with various drug-related offenses, including possession with intent to deliver and possession of drug paraphernalia. The cases were consolidated in the District Court of the Fourth Judicial District, Ada County. He moved to suppress the evidence found in the backpack, arguing that the search was unconstitutional. The district court denied his motion, finding that he lacked standing to challenge the search due to the express waiver of his Fourth Amendment rights in his probation agreement.After trial, a jury found him guilty on multiple counts, and he was sentenced to a unified fifteen-year term, with five years fixed. On appeal to the Supreme Court of the State of Idaho, he argued that the district court erred in treating his waiver as a categorical bar to standing, particularly since officers did not know of the waiver at the time of the search.The Supreme Court of the State of Idaho affirmed the district court’s denial of the motion to suppress. The Court held that an express waiver of Fourth Amendment rights in a probation agreement extinguishes any legitimate expectation of privacy and therefore precludes standing to challenge the search, overruling its prior decision in State v. Maxim, 165 Idaho 901, 454 P.3d 543 (2019), to the extent it held otherwise. View "State v. Al-Mafrachi" on Justia Law

Two candidates for public office in the November 2026 Delaware general election challenged the constitutionality of the state’s permanent absentee voting statute. They argued that the statute unlawfully expanded absentee voting beyond the categories permitted by the Delaware Constitution and that the Department of Elections failed to adequately verify the continued eligibility of permanent absentee voters, thereby enabling ineligible individuals to vote by absentee ballot.Previously, the Court of Chancery of the State of Delaware considered cross-motions for summary judgment. The plaintiffs sought declaratory and injunctive relief to prevent use of the permanent absentee voting process for the 2026 election. The Court of Chancery found that the statute did not expand the constitutionally enumerated categories of absentee voters but rather limited permanent absentee status to a subset of those groups. The court further held that the statute did not permit voting by those ineligible to vote absentee and that the Department’s procedures for maintaining the permanent absentee list, though not perfect, did not render every application of the statute unconstitutional. The Court of Chancery thus granted summary judgment to the defendants.On appeal, the Supreme Court of the State of Delaware reviewed the case de novo and affirmed the decision of the Court of Chancery. The Supreme Court held that the permanent absentee voting statute neither expanded absentee voting eligibility beyond the categories set by the Delaware Constitution nor permitted ineligible individuals to vote by absentee ballot. The Court also held that the plaintiffs failed to meet the high burden required for a facial constitutional challenge, as the statute could be applied constitutionally. Therefore, the Supreme Court affirmed the judgment upholding the statute. View "Hocker v. Albence" on Justia Law

The case involves a defendant who was convicted of first degree murder and other crimes in 1996, with the jury finding special circumstances and imposing a death sentence. During jury selection at trial, the prosecutor used peremptory challenges to strike several Black and Latino jurors. The defendant’s counsel objected to these strikes, raising claims of racial discrimination under Batson v. Kentucky and People v. Wheeler. The trial court found a prima facie case of discrimination for most challenges, required race-neutral justifications from the prosecutor, and ultimately denied the motions. On direct appeal, the California Supreme Court affirmed the trial court’s rulings.Years later, the defendant sought postconviction discovery under Penal Code section 1054.9, including the prosecution’s jury selection notes. The Superior Court for the County of Riverside denied production of these notes, citing prior case law that required a prima facie showing of a Batson/Wheeler violation for postconviction access to jury selection notes. Shortly after this ruling, Assembly Bill No. 1036 was enacted, amending section 1054.9 to expressly include jury selection notes as discoverable material and shifting the burden to the prosecution to show good cause for withholding or redacting these notes.The California Court of Appeal, Fourth Appellate District, Division Two, held that the recent legislative amendments eliminate the requirement for a defendant to make a prima facie case of racial bias to obtain jury selection notes postconviction. Instead, a request for these notes now shifts the burden to the prosecution to demonstrate good cause for shielding or redacting the notes. The appellate court granted the petition for writ of mandate, directing the trial court to adjudicate the defendant’s request in accordance with the current law. View "Montes v. Superior Court" on Justia Law

A group of asylum seekers who entered the United States without admission or parole were apprehended, screened for expedited removal, and found to have a credible fear of persecution or torture. As a result, they were transferred from expedited to regular removal proceedings to have their asylum claims adjudicated. However, due to their initial placement in expedited removal, they were subject to mandatory detention under 8 U.S.C. § 1225(b)(1)(B)(ii), which, as interpreted in Jennings v. Rodriguez, does not permit bond hearings or individualized determinations regarding detention. The plaintiffs, forming a certified class, argued that the lack of such hearings violated their rights under the Fifth Amendment’s Due Process Clause.Initially, the United States District Court for the Western District of Washington granted class certification and issued a preliminary injunction requiring bond hearings. After the Attorney General issued a decision, Matter of M-S-, which aligned with Jennings and eliminated the statutory right to bond hearings, the plaintiffs amended their complaint to challenge the constitutionality of mandatory detention. The district court again granted relief, but the government appealed. The United States Court of Appeals for the Ninth Circuit initially affirmed, but the Supreme Court vacated and remanded for reconsideration in light of Department of Homeland Security v. Thuraissigiam. Upon remand, the district court, after further proceedings, denied the government’s motion to dismiss, holding that it had jurisdiction and that the due process claim was not foreclosed by Thuraissigiam.On interlocutory appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of the government’s motion to dismiss. The court held that none of the jurisdiction-stripping provisions of 8 U.S.C. § 1252(a)(2)(A) or § 1252(e)(3) barred judicial review of the class’s due process claim. The court also held that Thuraissigiam did not eliminate the due process rights of noncitizens apprehended well within the United States, distinguishing the case from those at the “threshold of initial entry.” The Ninth Circuit affirmed that these individuals may pursue constitutional due process claims regarding their detention. View "PADILLA V. UNITED STATES IMMIGRATION AND CUSTOMS ENFORCEMENT" on Justia Law

A town and its select board challenged a state law enacted to address the Massachusetts housing crisis. The law requires municipalities served by the Massachusetts Bay Transportation Authority to have at least one district where multifamily housing is permitted as of right. The town attempted to adopt compliant zoning amendments, but town meeting voters rejected these proposals. The select board subsequently decided not to pursue further compliance steps. After being notified by the state agency responsible that it was noncompliant and at risk of losing state grant funding, the town and board filed a lawsuit seeking declaratory and injunctive relief.The action was filed in the Superior Court Department. The Commonwealth and the Executive Office of Housing and Livable Communities moved to dismiss for lack of subject matter jurisdiction and failure to state a claim. The Superior Court judge granted the motion, finding the plaintiffs failed to plausibly allege that the law imposed an unfunded local mandate or unlawfully interfered with the town’s zoning authority. The plaintiffs appealed, and the Supreme Judicial Court of Massachusetts allowed direct appellate review.The Supreme Judicial Court of Massachusetts affirmed the dismissal. It held that the complaint did not sufficiently allege that the law imposed an unfunded local mandate because the costs described were either incidental local administration expenses or voluntarily incurred. The Court also held that the town and board lacked standing to assert constitutional voting rights claims on behalf of town meeting voters. Addressing the public importance of the issue, the Court concluded that the law is a valid general law and does not violate the Home Rule Amendment or conflict with the Zoning Act. The judgment dismissing the complaint was affirmed. View "Marshfield v. Commonwealth" on Justia Law