Justia Constitutional Law Opinion Summaries

A long-serving correctional officer at the District of Columbia Department of Corrections was terminated from her position after nearly three decades of service. During the COVID-19 pandemic, she became increasingly vocal about perceived failures in the Department’s response to the crisis. In her role as a union leader, she forwarded internal Department emails to union attorneys and participated in a local television interview criticizing the Department’s pandemic management. The Department launched an investigation, ultimately determining that she violated confidentiality policies and terminated her employment, despite a hearing officer’s recommendation for a lesser penalty.After her termination, she filed suit in D.C. Superior Court against the Department’s leadership, alleging that her firing violated her First Amendment rights. The defendants removed the case to the United States District Court for the District of Columbia, where both sides moved for summary judgment. The district court found triable issues of fact regarding whether her termination was motivated by protected speech and denied qualified immunity to the individual defendants. The defendants sought reconsideration, which was denied, and then appealed to the United States Court of Appeals for the District of Columbia Circuit.The United States Court of Appeals for the District of Columbia Circuit held that the officials were entitled to qualified immunity with respect to her claim that she was fired for forwarding confidential emails, finding no violation of a clearly established First Amendment right in those circumstances. However, the court affirmed the denial of qualified immunity for the claim that she was fired for giving a media interview, concluding that if her termination was motivated by the interview, it would violate clearly established First Amendment law. The case was remanded for further proceedings. View "Johnson v. DC" on Justia Law

The case concerns a defendant who was arrested after his girlfriend reported to police that he had struck her, taken her handgun, chambered a round, and threatened her with it. Forensic evidence later confirmed his DNA on the weapon. The defendant gave conflicting accounts, initially denying knowledge of the gun, then claiming he took it from his girlfriend to protect himself. Officers arrested him, and he was charged in state court with domestic violence and illegal firearm possession. While out on bond, federal prosecutors indicted him for being a felon in possession of a firearm after an earlier felony conviction. During execution of a federal arrest warrant, officers found a stolen rifle in the home. The government offered a plea deal involving a single count, which the defendant declined, resulting in a superseding indictment on two counts.The United States District Court for the Northern District of Ohio denied the defendant’s motion to suppress the rifle and his motion to dismiss on Second Amendment grounds. The defendant ultimately pleaded guilty to both counts without a written plea agreement. At sentencing, the district court applied an enhancement for possessing a firearm in connection with a felony offense, based on evidence that he had threatened his girlfriend with the handgun, and imposed a 100-month prison sentence. The defendant appealed, raising constitutional arguments and challenging the sentencing enhancement.The United States Court of Appeals for the Sixth Circuit held that, because the defendant pleaded guilty unconditionally and did not comply with Federal Rule of Criminal Procedure 11(a)(2), he waived his right to appeal pre-plea constitutional issues. The court declined to address his ineffective assistance of counsel claim on direct appeal, finding the record undeveloped. Reviewing the sentencing enhancement for clear error, the court found ample evidence to support the district court’s application of the enhancement and affirmed the sentence. View "United States v. Williams" on Justia Law

In 2019, a man was indicted in Coahoma County, Mississippi, on three charges: sexual battery of a child under fourteen, felonious child abuse, and exposing another to HIV. The case involved his eight-year-old daughter, who moved to live with him that year. After the child disclosed abuse to her older sister, she was taken to the hospital, where injuries consistent with sexual abuse were observed. Medical professionals and law enforcement became involved, and the child underwent further examinations and interviews. During the investigation, the defendant admitted to law enforcement that he was HIV positive.A jury in the Coahoma County Circuit Court found the defendant guilty on all three counts. The trial court sentenced him to twenty years for sexual battery, and five years each for child abuse and exposing another to HIV, all to be served concurrently. The defendant’s motion for a new trial was denied. On appeal to the Supreme Court of Mississippi, the defendant challenged only his conviction for exposing another to HIV, arguing the trial court violated his Confrontation Clause rights by admitting Mississippi Department of Health records without the opportunity to cross-examine their custodian and that the State presented insufficient evidence of knowing exposure.The Supreme Court of Mississippi held that the Confrontation Clause argument was procedurally barred because it was not raised at trial and, alternatively, the admitted records were non-testimonial business records not subject to the Confrontation Clause. The court also determined that the State had presented sufficient evidence for a rational juror to convict under the plain language of the statute, which required proof that the defendant was HIV positive and knowingly exposed the child. The conviction and sentence were affirmed. View "Sims v. State of Mississippi" on Justia Law

The defendant, after previously pleading guilty to aggravated criminal damage to property under Louisiana law, was found in possession of a firearm. His earlier offense involved intentionally damaging vehicles during a police traffic stop, endangering human life, which led to a three-year sentence. After serving his sentence, he was again found with a firearm, resulting in an indictment for possession of a firearm by a convicted felon under 18 U.S.C. § 922(g)(1).The United States District Court for the Western District of Louisiana reviewed the defendant’s motion to dismiss the indictment, in which he argued that § 922(g)(1) was unconstitutional as applied to him. The district court denied the motion. The defendant then entered a conditional guilty plea, reserving the right to appeal the denial, and was sentenced to 56 months’ imprisonment.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the constitutionality of § 922(g)(1) as applied to the defendant, considering whether the government's justification for permanent disarmament was supported by a historical tradition consistent with the Second Amendment, as outlined in New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The Fifth Circuit found that the government had not met its burden to demonstrate a relevant historical analogue for disarming individuals with a property crime predicate like the defendant’s. The court declined to expand precedent by treating aggravated property damage as sufficiently violent for permanent disarmament under historical going-armed laws.The Fifth Circuit vacated the district court’s order denying the motion to dismiss and remanded the case for reconsideration. The main holding was that, absent sufficient evidence of a historical tradition supporting disarmament for this type of predicate felony, the government had not justified the application of § 922(g)(1) to the defendant. View "USA v. Debrow" on Justia Law

Raymond Carrin was a federal detainee diagnosed with Hepatitis C who sought medical treatment while in custody at the Federal Detention Center in Tallahassee, Florida. Despite Carrin’s repeated requests and visible deterioration over more than a year—including emergency hospitalizations and symptoms consistent with advanced liver disease—medical staff did not provide him with the direct-acting antiviral treatment prescribed for his condition. The facility’s staff indicated that treatment would only begin once Carrin was transferred to his designated institution, a transfer that was delayed for various reasons. Carrin eventually died from hepatic cirrhosis without receiving the necessary medication. He did not file a formal grievance or seek relief under the prison’s Administrative Remedy Program (ARP) before his death.Carrin’s estate brought suit in the United States District Court for the Northern District of Florida against two federal prison officials, alleging violations of Carrin’s Fifth and Eighth Amendment rights and seeking damages under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). The district court initially denied the defendants’ motions to dismiss and for summary judgment. However, after the Eleventh Circuit’s decision in Johnson v. Terry, 119 F.4th 840 (11th Cir. 2024), the court granted judgment on the pleadings for the defendants, holding that the presence of the ARP constituted a special factor counseling against extending Bivens to these claims, and that Carrin’s case differed meaningfully from prior Supreme Court Bivens precedents.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that both the Eighth and Fifth Amendment claims arose in a new context distinct from Carlson v. Green, 446 U.S. 14 (1980), and that the existence of the ARP—regardless of its adequacy or accessibility to the estate—was a special factor precluding the extension of Bivens remedies. View "Carrin v. Smiledge" on Justia Law

Stanford Williams was tried three times for the 1993 murder of Omar Massey. The first trial ended in a hung jury, and the second trial was interrupted when a key witness, John Faingnaert, changed his expected testimony regarding Williams’s exposure to gun residue. Williams’s attorney, John Elash, contemplated becoming a witness to rebut Faingnaert but acknowledged he could not continue representing Williams if he did so. The trial court concluded that Elash could not waive a potential ineffective assistance claim and, after discussion, granted a mistrial. Williams was convicted at his third trial and sentenced to life in prison.Following his conviction, Williams argued that the third trial violated his protection against double jeopardy, asserting that he had not requested or consented to the mistrial in the second trial. The Allegheny County Court of Common Pleas rejected this claim, finding that Williams had moved for a mistrial. The Pennsylvania Superior Court affirmed, holding that Williams waived his double jeopardy claim by not raising it before the third trial and that the claim lacked merit because he had requested the mistrial. Williams sought post-conviction relief, and the same trial judge found again that Williams requested the mistrial; the Superior Court affirmed this finding.Williams then filed for habeas corpus relief in the United States District Court for the Western District of Pennsylvania. The District Court granted his petition, holding that the third trial violated double jeopardy and that his counsel was ineffective for failing to raise the claim. On appeal, the United States Court of Appeals for the Third Circuit applied AEDPA deference to the state court’s findings and concluded that Williams did not provide clear and convincing evidence that the state court erred in finding he requested a mistrial. The Third Circuit held that the third trial did not violate the Double Jeopardy Clause and that Williams’s counsel was not ineffective for failing to raise a meritless double jeopardy claim. The District Court’s order was reversed. View "Williams v. Superintendent Fayette SCI" on Justia Law

The defendant was charged with continuous sexual abuse of his stepdaughter, following her disclosure of alleged abuse. He sought to introduce evidence that the accuser had engaged in an inappropriate online relationship with an adult male, including sexually explicit exchanges, arguing that she fabricated the allegations against him in retaliation for being disciplined after her mother discovered the relationship and terminated it. The defendant believed this evidence would support his theory that the accuser had a motive to lie.The District Court of Cass County, East Central Judicial District, held an in camera hearing under North Dakota Rule of Evidence 412 to consider the admissibility of the proposed evidence. The court conditionally denied the defendant’s motion, finding the evidence inadmissible under Rule 412(a) and determining that the defendant had not provided a sufficient offer of proof to invoke the constitutional exception under Rule 412(b)(1)(C). The court identified foundational deficiencies in the proffered evidence and allowed limited questioning about the fact and emotional impact of discipline, but not the explicit sexual content. The jury subsequently convicted the defendant of continuous sexual abuse, and the court entered judgment.On appeal to the Supreme Court of the State of North Dakota, the defendant argued that the exclusion of evidence violated his Sixth Amendment right to confrontation and constituted an abuse of discretion. The Supreme Court reviewed the constitutional claim de novo and the evidentiary ruling for abuse of discretion. It concluded that the District Court’s exclusion of the explicit evidence was neither arbitrary nor disproportionate, given the marginal probative value and the temporal gap between the events. The defendant’s confrontation rights were not violated because he was permitted to question the victim about discipline and emotional impact. The Supreme Court affirmed the criminal judgment. View "State v. Fox" on Justia Law

A Michigan State Police trooper stopped a vehicle for speeding, driven by the defendant, with a passenger under the age of 21. The trooper smelled marijuana but did not see any in plain view, nor did the occupants appear intoxicated or in possession. After both initially denied possessing marijuana, the passenger admitted to having a small amount (“shake”), which under Michigan law is a civil infraction for those under 21. The trooper then searched the vehicle and found a concealed firearm, which the defendant admitted was his.At the preliminary examination, the defendant argued that the vehicle search violated the Fourth Amendment. The 63rd District Court bound him over on the concealed weapon charge. In Kent Circuit Court, the defendant moved to suppress the firearm, but the motion was denied. The Michigan Court of Appeals, after remand from the Michigan Supreme Court, affirmed the circuit court’s denial, holding the search did not violate the Fourth Amendment.The Supreme Court of Michigan reviewed the case and held that the warrantless search was unlawful under the automobile exception to the Fourth Amendment’s warrant requirement. The Court found that the trooper had probable cause only to believe a civil infraction (possession of a small amount of marijuana by a minor) had occurred, not a crime. The Court clarified that probable cause to believe only a civil infraction has been committed does not justify a warrantless search under the automobile exception. The presence of marijuana odor, without more, does not establish probable cause to believe a criminal amount is present. The judgment of the Court of Appeals was reversed, and the case was remanded to the circuit court for further proceedings. View "People of Michigan v. Wilkins" on Justia Law

The defendant pleaded guilty to attempted unarmed robbery in Michigan in 2021, following a prior conviction for attempted rape in Illinois in 1983. As part of the 2022 sentence, the Berrien Circuit Court imposed lifetime registration as a Tier III sex offender under Michigan’s Sex Offenders Registration Act (SORA), based on the statute’s “recapture” provision. This provision requires individuals with pre-SORA sexual offense convictions to register if they are later convicted of any felony after July 1, 2011. The defendant had not committed another sexual offense in the intervening decades, and his recent conviction involved theft and a disputed assault in a Walmart store.After sentencing, the defendant challenged the registration requirement, arguing it was unconstitutional and not applicable because he was an out-of-state resident. The Berrien Circuit Court denied his motion to correct an invalid sentence. The Michigan Court of Appeals affirmed, finding the registration requirement constitutional but held that the defendant, as a nonresident, did not have to register unless he moved to or worked in Michigan.The Michigan Supreme Court reviewed the case, focusing on whether SORA’s recapture provision constituted cruel or unusual punishment when imposed for nonsexual offenses. The Court held that imposing SORA registration on individuals convicted of nonsexual offenses who had a pre-SORA sexual offense conviction was unconstitutional under the Michigan Constitution. The Court found the registration requirement grossly disproportionate, ineffective for rehabilitation, and harsher than penalties imposed for similar offenses elsewhere. The judgment of the Court of Appeals was reversed, and the case was remanded to the trial court to remove the registration requirement from the defendant’s sentence. View "People of Michigan v. Ellis" on Justia Law

Three defendants, who held leadership positions in a nationwide gang operating in Michigan and Chicago, were charged after a lengthy federal investigation uncovered extensive drug distribution, violent acts, and strict internal codes of silence within the organization. Law enforcement used confidential informants, monitored communications, conducted controlled purchases, and executed search warrants on social media and personal devices to gather evidence. The defendants were indicted for racketeering conspiracy, drug conspiracies, and related offenses. While many co-defendants pled guilty, these three proceeded to trial.The United States District Court for the Eastern District of Michigan conducted a month-long trial, after which a jury convicted all three defendants on most counts. One defendant was acquitted of certain drug trafficking and firearm possession charges but convicted on racketeering, drug conspiracy, and possession with intent to distribute marijuana. At sentencing, the district court imposed lengthy prison terms for each defendant. The defendants appealed, raising suppression issues concerning wiretap evidence, social media searches, and cell phone searches; Sixth Amendment claims regarding prison mail policies and cross-examination limitations; sufficiency-of-the-evidence challenges; and a sentencing dispute.The United States Court of Appeals for the Sixth Circuit reviewed the case. It rejected all suppression arguments except for a procedural sentencing challenge raised by one defendant, finding that the district court failed to adequately address his objection to a sentencing enhancement based on acquitted conduct. The Court affirmed the convictions for all three defendants and rejected their constitutional and evidentiary claims, holding that the evidence and trial procedures met legal standards. However, it vacated the sentence for the one defendant on procedural grounds and remanded for resentencing, while affirming all other aspects of the district court’s judgment. View "United States v. Fordham" on Justia Law