Justia Constitutional Law Opinion Summaries

In this case, the appellant was convicted of malice murder and related offenses stemming from the shooting death of a victim in 2013. He, along with a co-defendant, was indicted and subsequently went to trial in early 2015. After being found guilty on all counts by a jury, he received multiple sentences, including life imprisonment. Following his conviction, he filed a timely motion for new trial, which remained unresolved for approximately ten years due to various delays in post-conviction proceedings, including changes in appointed counsel and a lack of substantive action on his case.Throughout this period, the Superior Court of Cobb County experienced significant delays in hearing and resolving the appellant’s motion for new trial. The motion was finally amended and heard in 2025. At the hearing, the appellant argued that the delay in his post-conviction proceedings violated his due process rights, particularly because his trial counsel no longer possessed the trial file, which he claimed hindered his ability to effectively pursue post-conviction relief. The trial court, applying the four-factor test from Barker v. Wingo and Chatman v. Mancill, found that the appellant failed to show actual prejudice resulting from the delay and denied the motion for new trial.Upon appeal, the Supreme Court of Georgia reviewed the Superior Court’s decision. The Supreme Court reiterated that, under Georgia law, actual (not presumed) prejudice must be shown for a due process violation based on appellate delay. The appellant did not provide specific evidence that the outcome of his appeal would have been different absent the delay. The Supreme Court of Georgia affirmed the trial court’s decision, holding that the appellant’s due process rights were not violated by the post-conviction delay because no actual prejudice was demonstrated. View "KELLY v. STATE" on Justia Law

Three men, including the appellant, were indicted in connection with the shooting death of an individual outside a local game room. The incident occurred after a fight broke out near the game room’s entrance, resulting in the victim being shot multiple times and dying at the scene. Witnesses saw the appellant and his co-defendants at or near the scene around the time of the shooting, and evidence linked the appellant to a firearm that matched shell casings found at the scene. The State also presented evidence that all three men were members of the same street gang and suggested a retaliatory motive based on the victim’s cooperation with police.The Superior Court of Emanuel County tried all three defendants together before a jury. The jury found the appellant guilty on all charges, including felony murder, armed robbery, aggravated assault, and possession of a firearm during the commission of a felony. The State conceded that the evidence was insufficient to support the gang-related charge against the appellant, and the trial court granted a new trial as to that count and later entered an order of nolle prosequi on it. The trial court denied the appellant’s motion for a new trial on the remaining convictions.On direct appeal to the Supreme Court of Georgia, the appellant challenged the sufficiency of the evidence, the admission of certain testimony, and a jury instruction. The Supreme Court of Georgia held that the evidence was sufficient to support the convictions under both federal due process and Georgia statutory law. The court found no plain error in the admission of testimony referencing statements by the appellant’s roommate, nor in a minor misstatement by the trial court during jury instructions, concluding that the written instructions properly informed the jury. The Supreme Court of Georgia affirmed the appellant’s convictions. View "SOMERVILLE v. STATE" on Justia Law

A man was shot and killed inside a DeKalb County restaurant. The shooter, described as wearing dark clothing, a hat, and glasses, fired multiple times and referenced “my nephew” before fleeing. Surveillance footage from the restaurant and a nearby drugstore captured individuals and vehicles at the scene. Investigators linked a black Dodge Charger, seen near the time of the shooting, to the defendant, whose driver’s license photo resembled the shooter in the footage. The defendant’s supervisor, familiar with him from daily work interactions, identified him in stills from the surveillance video. A search of the defendant’s car revealed glasses and ammunition similar to those associated with the shooting. Evidence also showed that, prior to the shooting, the defendant searched online for information about his nephew’s murder (in which the victim was a suspect) and about the victim himself.A DeKalb County grand jury indicted the defendant on multiple counts, including malice murder and firearm-related charges. At trial in the Superior Court of DeKalb County, a jury found him guilty on all counts. The court sentenced him to life without parole for malice murder and additional time for firearm possession. The defendant filed a motion for a new trial, later amended, which the court denied after an evidentiary hearing.On appeal, the Supreme Court of Georgia reviewed claims that the trial court erred by admitting lay identification testimony from the supervisor, allowing the defendant to be shackled at trial, and that counsel was ineffective. The Court held that the identification testimony was admissible under the rules for lay opinion based on familiarity. Although the trial court did not make specific findings justifying shackling, the error was harmless because the shackles were hidden from the jury. The Court also found no ineffective assistance of counsel. The Supreme Court of Georgia affirmed the convictions. View "MINOR v. STATE" on Justia Law

Two men were convicted of malice murder and related crimes following the shooting death of an individual who attempted to break up a fight outside an apartment complex in May 2015. The incident arose after a series of confrontations triggered by suspicions that a resident’s acquaintance was falsely claiming membership in a street gang. During the final altercation, eyewitnesses reported that one defendant instructed the other to retrieve a firearm, after which shots were fired and the victim was killed. Both defendants fled the scene. Forensic evidence indicated multiple firearms were used. At trial, one defendant admitted to firing a gun but claimed it was only into the air.The Superior Court of Fulton County conducted a joint trial, where a jury found both men guilty on all counts. The court imposed life sentences and additional concurrent and consecutive terms. Both defendants filed motions for new trial, raising issues including sufficiency of the evidence, juror misconduct, trial errors, and ineffective assistance of counsel. After an evidentiary hearing, the Superior Court denied their motions.On appeal, the Supreme Court of Georgia reviewed the convictions. The Court held that the evidence was constitutionally sufficient for the malice murder conviction, including as a party to the crime. The Court found no abuse of discretion in the trial court’s rejection of juror misconduct claims and determined that issues with jury instructions and evidentiary rulings did not warrant reversal. Claims of Brady violations and ineffective assistance of counsel were also rejected because the alleged errors did not prejudice the defense or would not have succeeded if raised. Although one jury instruction regarding the gang activity charge was erroneous, the Court found the error harmless. The Supreme Court of Georgia affirmed all convictions and sentences. View "CLIFTON v. STATE" on Justia Law

The case concerns the conviction of a defendant for malice murder and related crimes stemming from the shooting death of a man during a robbery. The defendant, along with several co-defendants, planned to rob the victim, a known drug dealer, because the defendant needed money. The group lured the victim to a meeting, forced him into a car at gunpoint, and then drove to his home, where they took money, drugs, and other items. The victim, his girlfriend, and their child were tied up, and the group left with the victim, who was later shot and killed by the defendant. The co-defendants testified against the defendant, and physical evidence supported their accounts.Following indictment in the Superior Court of Troup County, the co-defendants pleaded guilty to lesser charges, and the defendant was tried alone and found guilty on all counts. He was sentenced to life without parole for malice murder and a consecutive life term for kidnapping with bodily injury. His timely motion for new trial was amended several times and ultimately denied by the trial court without a hearing, resulting in a significant delay before appeal.The Supreme Court of Georgia reviewed the case on appeal. The court held that evidence of the defendant’s prior drug use was properly admitted under the old Evidence Code to show motive. Any error in admitting evidence of his arrest in New York was harmless in light of strong evidence of guilt. The court also found no violation of the defendant’s Sixth Amendment right to counsel when the trial court required him to proceed with second-chair counsel after his lead counsel became ill, as he was still represented by competent counsel. The court affirmed the convictions. View "ALLEN v. STATE" on Justia Law

In the early morning hours, police received a 911 call from an individual identifying himself as “Dwayne Green,” reporting a nude woman lying in the grass at an apartment complex. Officers responded and found Latasha Smith’s body near the mailboxes; she was mostly unclothed, cold to the touch, and had visible injuries. An autopsy determined the cause of death was strangulation and blunt force trauma. Diandre Dryden, a resident of the complex, approached police on the scene and provided a false name. Upon learning his real identity and an outstanding warrant, police arrested Dryden. A search of his apartment uncovered bloody clothing with Smith’s DNA. Dryden’s DNA was also found under Smith’s fingernails, and Smith’s cell phone, used to place the 911 call, was found on Dryden when he was arrested.A Hall County grand jury indicted Dryden for malice murder, felony murder, and aggravated assault. In March 2024, a jury found him guilty of all charges, and the Superior Court of Hall County sentenced him to life without parole for malice murder, with the other convictions merging or being vacated. Dryden’s motion for a new trial was denied by the trial court, and he appealed.The Supreme Court of Georgia reviewed Dryden’s sole claim that his Sixth Amendment Confrontation Clause rights were violated by the admission of the 911 call, as the caller did not testify. Applying plain error review, the court found that the 911 call was not offered for the truth of its content but rather to demonstrate Dryden’s alleged effort to conceal his crime by alerting police and misrepresenting facts. Because the call was not admitted for its truth, it was not hearsay, and the Confrontation Clause did not apply. The court affirmed Dryden’s conviction. View "DRYDEN v. STATE" on Justia Law

The case involves a criminal defendant who was convicted on federal charges after law enforcement conducted a search of his home. The search was carried out pursuant to a warrant, and evidence seized during the search was used to support the prosecution’s case. The defendant challenged the lawfulness of the search, arguing that the affidavit supporting the warrant application contained misrepresentations or omissions that were material to the finding of probable cause.At trial in the United States District Court for the Northern District of Illinois, the defendant sought to suppress the evidence obtained during the search, contending that the warrant was not supported by probable cause due to false or misleading statements in the supporting affidavit. The district court denied the motion to suppress, finding that the affidavit provided a sufficient basis for probable cause and that any alleged inaccuracies were not material. The defendant was subsequently convicted, and he appealed, renewing his arguments regarding the validity of the search warrant.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the suppression motion. The appellate court held that in order to invalidate a search warrant under Franks v. Delaware, 438 U.S. 154 (1978), a defendant must show that the affidavit included deliberately or recklessly false statements, and that those statements were necessary to a finding of probable cause. The Seventh Circuit found that the defendant failed to make this showing. The court concluded that, even excising the challenged statements, the remaining contents of the affidavit were sufficient to establish probable cause. Therefore, the court affirmed the judgment of the district court, upholding the defendant’s conviction. View "Sunco International Inc. v Jiangsu Sunco Boiler Co., Ltd." on Justia Law

A Michigan resident who owned a smoke shop that offered a promotion—purchasing a pipe and receiving marijuana as a gift—became the subject of a multi-year investigation by state police officers. Undercover officers repeatedly visited the shop, purchased pipes, and received marijuana, gathering evidence that the business was operating without a state dispensary license. Officers also examined the business’s financial records and concluded that income was underreported. Based on these findings, an officer submitted an affidavit to obtain a search warrant for the owner’s home. During the search, the owner was handcuffed, detained outside, and denied use of his restroom, ultimately being forced to urinate in his yard. The search led to criminal charges, to which the owner later pled guilty to one count in exchange for dismissal of another.The United States District Court for the Western District of Michigan reviewed the owner’s civil suit brought under 42 U.S.C. § 1983, which alleged that the officers violated his Fourth Amendment rights by executing an invalid search warrant and by refusing to allow him to use his restroom while detained. He also brought a Fourteenth Amendment substantive due process claim. The district court granted the officers qualified immunity and dismissed all claims, finding the warrant supported by probable cause and the alleged constitutional violations not clearly established.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the dismissal of the Fourth Amendment unlawful search claim, finding the warrant was supported by probable cause even after removing the alleged false statements from the affidavit. The court also affirmed dismissal of the Fourteenth Amendment claim as duplicative of the Fourth Amendment unreasonable seizure claim. However, the appeals court reversed the dismissal of the unreasonable seizure claim against the officer who denied restroom access, holding that, under the totality of the circumstances, the plaintiff plausibly alleged a violation of a clearly established Fourth Amendment right. The case was remanded for further proceedings on this claim. View "Antol v. English" on Justia Law

A former Fire Chief of the Cincinnati Fire Department, who had worked for the department since 1993 and was promoted to Fire Chief in 2021, was terminated by the City Manager in 2023 without being given a pre-termination hearing. The City Charter provided that, after serving six months as Fire Chief, the individual could only be removed for cause. When promoted, the Fire Chief signed a memorandum stating the position was “unclassified” and subject to dismissal without cause, but the Charter’s language provided for-cause protection after the first six months. The City Manager provided the Fire Chief with a termination letter listing reasons for the firing and publicized the termination, including to the media, citing the reasons as “for cause.” The Fire Chief did not receive a pre-termination or post-termination hearing before a neutral decisionmaker.The United States District Court for the Southern District of Ohio denied summary judgment to the City Manager and the City, holding that the City Manager was not entitled to qualified immunity regarding pre-termination due process violations. The court found that, under the Charter, the Fire Chief had a property interest in continued employment after six months and that there were unresolved factual disputes regarding waiver of those rights. The district court also denied statutory immunity to the City Manager on the Fire Chief’s state law defamation claim, finding triable issues regarding whether her statements were knowingly false or made with malice.On interlocutory appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that the City Charter unambiguously gave the Fire Chief for-cause removal protection after six months, creating a property interest protected by procedural due process. It found that no “clear and unmistakable” waiver of those rights was effected by the memorandum. The court also held that sufficient evidence existed for a jury to decide whether the City Manager acted with malice or bad faith in making allegedly defamatory statements. The matter was remanded for further proceedings. View "Washington v. City of Cincinnati" on Justia Law

A group of former employees of a public university in Washington State were terminated after failing to comply with a COVID-19 vaccine mandate issued by the state’s governor. These employees had requested, and in some cases received, religious or medical exemptions from the vaccine requirement. However, the university determined that accommodating these exemptions would impose undue hardship and, as a result, denied many accommodation requests. None of the employees received the vaccine or could be accommodated, so they lost their jobs.The former employees filed a lawsuit in the United States District Court for the Western District of Washington against the university and certain human resources officers, alleging that their terminations violated their constitutional rights under the First and Fourteenth Amendments, and brought claims under 42 U.S.C. § 1983. Both parties moved for summary judgment on these claims. The district court ruled in favor of the university, finding that it is an “arm of the state” under the test articulated in Kohn v. State Bar of California and thus is not a “person” subject to suit under § 1983. The employees appealed this ruling.The United States Court of Appeals for the Ninth Circuit reviewed the case. While the appeal was pending, the Supreme Court decided Galette v. New Jersey Transit Corp., clarifying the “arm of the state” analysis. The Ninth Circuit held that its prior three-factor test remains valid but must be applied in accordance with the Supreme Court’s guidance, giving the greatest weight to whether the state intended to create a legally independent entity, less weight to formal liability for debts, and the least weight to state control. Applying the refined test, the Ninth Circuit concluded that the university is an arm of the state under the Eleventh Amendment and not a “person” under § 1983, affirming summary judgment for the university and dismissing the § 1983 claims. View "NILSEN V. UNIVERSITY OF WASHINGTON" on Justia Law