Justia Constitutional Law Opinion Summaries

On the afternoon of July 31, 2022, a shooting occurred at a BP gas station in Overland Park, Kansas. Surveillance video captured Zarrell Semaj Finley retrieving an AK-47 from a backpack and shooting Shaquille Jackson multiple times following a brief physical struggle over the backpack. Finley then fled the scene with others, leaving Jackson, who later died from his wounds. During a subsequent police interview, Finley admitted to drinking heavily before the incident and claimed he acted in self-defense, believing Jackson was armed and posed a threat. Finley's sister testified that the firearm belonged to her, and Finley had been drinking on the day of the shooting.In Johnson District Court, Finley was charged with first-degree premeditated murder and criminal possession of a weapon by a convicted felon, to which he pleaded guilty to the weapons charge. The murder charge proceeded to trial, where the jury found Finley guilty, and the court imposed a life sentence. At trial, the court denied Finley’s requests for jury instructions on voluntary intoxication and heat of passion voluntary manslaughter. The court also declined to instruct on voluntary manslaughter based on defense of an occupied vehicle, but did instruct on imperfect self-defense voluntary manslaughter and other lesser included offenses.The Supreme Court of the State of Kansas reviewed Finley’s direct appeal. The court held that the district court properly refused Finley’s requested jury instructions because the evidence did not support a finding of impairment sufficient for voluntary intoxication, nor was there legally sufficient provocation for heat of passion manslaughter or factual basis for a defense of an occupied vehicle instruction. The court found that any prosecutorial errors during closing argument were harmless beyond a reasonable doubt. Finally, it concluded that sufficient evidence supported the jury’s finding of premeditation. The court affirmed Finley’s conviction. View "State v. Finley " on Justia Law

The petitioner was convicted of continuous sexual abuse of a child, involving at least twenty acts against a minor between November 2019 and August 2020. Sentenced in March 2022, he appealed his conviction, which was affirmed by the North Dakota Supreme Court in November 2022. In March 2023, he filed his first postconviction relief petition, which was denied by the District Court of Ward County and affirmed on appeal in March 2024. On April 29, 2025, the petitioner filed a second postconviction relief petition, alleging constitutional violations based on alleged withholding of evidence and false testimony by the State, citing Glossip v. Oklahoma, 604 U.S. 226 (2025).After the State answered the petition—raising the statute of limitations, res judicata, and misuse of process as affirmative defenses—it moved for summary disposition on the basis of misuse of process but omitted the statute of limitations in its motion. The district court, however, ordered briefing on the statute of limitations and the impact of Glossip. Neither party scheduled a hearing, and the court ultimately granted summary disposition and dismissed the petition as untimely.The Supreme Court of North Dakota reviewed the appeal. It held that the State preserved the statute of limitations defense by raising it in its answer, and the district court could properly consider that defense even though it was not included in the State’s summary disposition motion. The Court determined that the petitioner forfeited his hearing request by failing to schedule it, and that the district court provided adequate notice and opportunity to respond regarding the statute of limitations issue. The Court found the petitioner failed to show that his claim fell within an exception to the statute of limitations for a new interpretation of law. The Supreme Court of North Dakota affirmed the district court’s dismissal of the petition. View "Archambault v. State" on Justia Law

The case concerns James Guzman, who was convicted of the murder of David Colvin. Guzman has been tried three times for Colvin's murder, with the most recent conviction occurring in 2016. Following this conviction, Guzman has undergone four penalty-phase proceedings, each resulting in a death sentence. The current appeal focuses on the fourth penalty phase and the resulting death sentence, which followed a unanimous jury recommendation. During that penalty phase, Guzman moved to disqualify the judge based on her prior employment at the law firm (Rice and Rose) that represented him in his first appeal, though she did not work on his case or any criminal matters at the firm.Previously, the Circuit Court for the Seventh Judicial Circuit conducted the penalty phase, presided over jury selection, and ruled on Guzman's motion to disqualify the judge, finding it legally insufficient. The jury found four aggravating factors and recommended death, and the judge imposed the sentence after considering both aggravating and mitigating circumstances. Guzman appealed, raising issues regarding the judge’s disqualification, the jury instructions on victim impact testimony, and the constitutionality of the death penalty.The Supreme Court of Florida reviewed the case and affirmed the lower court’s decisions. The Court held that Guzman’s motion to disqualify the judge was legally insufficient, as the allegations did not establish an objectively reasonable fear of bias or prejudice. The Court also found Guzman’s challenge to the jury instructions regarding victim impact testimony was unpreserved and, even if preserved, meritless, since the instructions given were adequate. Finally, the Court rejected Guzman’s argument that the death penalty is inherently cruel and unusual, citing longstanding precedent. The disposition by the Supreme Court of Florida was to affirm Guzman’s sentence of death. View "Guzman v. State of Florida" on Justia Law

A masked individual entered Plato’s Closet in Jonesboro, Arkansas, threatened employees with what appeared to be a handgun, and stole $598 before fleeing in a gray Mercury sedan. Shortly after, law enforcement stopped Pierre Wright, who was driving a vehicle matching the description. Officers found clothing matching the suspect’s, an imitation firearm, and a Plato’s Closet bag containing $598 in the car. Additional evidence, including GPS and cell-phone data, further linked Wright to the crime.The State charged Wright with aggravated robbery and theft of property and sought to classify him as a habitual offender based on prior Tennessee convictions. At trial in the Craighead County Circuit Court, Wright moved for directed verdicts, arguing insufficient evidence of his identity as the robber. The circuit court denied these motions, and the jury found Wright guilty. During sentencing, the State introduced certified records of Wright’s prior Tennessee convictions—one for aggravated robbery and two for aggravated burglary—and argued that the Tennessee aggravated-burglary offenses were comparable to Arkansas’s aggravated residential burglary, making Wright eligible for a mandatory life sentence under Arkansas Code Annotated section 5-4-501(d). The circuit court agreed and imposed the life sentence.On appeal to the Supreme Court of Arkansas, Wright raised three arguments: the sufficiency of the evidence, the comparability of his Tennessee convictions to Arkansas offenses for sentencing enhancement, and the propriety of his mandatory life sentence. The Supreme Court of Arkansas held that the evidence was sufficient to support the convictions, that the circuit court did not abuse its discretion in finding the Tennessee aggravated-burglary convictions comparable to the Arkansas statute, and that the mandatory life sentence was proper. The Court affirmed the judgment and sentence. View "WRIGHT v. STATE OF ARKANSAS" on Justia Law

On October 18, 2022, a fatal shooting occurred in the parking lot of The Ridge apartment complex in Little Rock, Arkansas. The evidence at trial established that Ferrad McCoy traveled with Mason Abraham from Memphis to Little Rock, where Abraham, as the passenger in a white Infiniti, shot and killed Broderick Blueford. Law enforcement later pursued the same vehicle on Interstate 40, resulting in a high-speed chase and crash. Both McCoy and Abraham fled on foot but were apprehended nearby. Physical evidence, including firearms, shell casings, a cell phone, and a hoodie matching McCoy’s attire, as well as video footage and cell phone records, linked both men to the crime and location.The Pulaski County Circuit Court presided over a jury trial in which McCoy was convicted of capital murder, first-degree unlawful discharge of a firearm from a vehicle, and firearm enhancements. He received life imprisonment plus additional years for the enhancements. McCoy challenged the sufficiency of the evidence and objected to the admission of several items, including photographs, firearms, video footage, and a “BOLO” flyer. He also raised issues regarding jury instructions and the Confrontation Clause.The Supreme Court of Arkansas reviewed the case, applying the substantial evidence standard and broad discretion for evidentiary rulings. The Court held that there was substantial evidence to support the convictions, properly admitted the contested evidence, and found no reversible error in the circuit court’s rulings. The Court also determined that McCoy’s jury instruction and Confrontation Clause arguments were either waived or without merit. The convictions and sentences imposed by the Pulaski County Circuit Court were affirmed. View "MCCOY v. STATE OF ARKANSAS" on Justia Law

The defendant was charged with deliberate homicide following an arrest in March 2021. Initially released on bond, he was later taken into custody after missing a required hearing. At a pretrial release revocation hearing, the State was represented by then-Deputy County Attorney Brett Linneweber. Over time, the defendant changed attorneys multiple times, displaying distrust toward counsel and initially refusing to accept any plea agreement. Ultimately, after negotiations, he agreed to plead guilty to mitigated deliberate homicide in exchange for a binding sentencing recommendation and dismissal of other charges. Before the plea hearing, Judge Linneweber, who had since been appointed to the bench, was assigned to the case. Although he had previously appeared for the State in a related proceeding, he determined his involvement was minimal and did not recuse himself, accepting the defendant’s guilty plea.After his plea, the defendant filed a motion for Judge Linneweber’s disqualification, which was referred to the Montana Supreme Court. Judge Linneweber then recused himself, and the motion was denied as moot. The defendant later sought to withdraw his guilty plea, citing involuntariness, ineffective assistance of counsel, newly discovered evidence, and pressure to accept the plea, but did not explicitly raise the disqualification issue as a basis for withdrawal. The Thirteenth Judicial District Court denied the motion, finding no evidence that the plea was not knowing or voluntary and that the new evidence could have been discovered earlier.The Supreme Court of the State of Montana reviewed whether the failure to recuse constituted good cause for plea withdrawal. The Court held that Judge Linneweber’s prior involvement as counsel required disqualification by statute and rule. The failure to recuse was a due process violation and constituted good cause to withdraw the guilty plea. The Court reversed the District Court’s order and remanded for further proceedings. View "State v. Notafraid" on Justia Law

A group of local United Methodist churches, through their trustees, sought to disaffiliate from the United Methodist Church while retaining ownership of their church property. This dispute arose amid a broader doctrinal disagreement within the denomination, particularly regarding the ordination of homosexual clergy and performance of same-sex weddings. The Conference, representing the denomination’s regional authority, asserted that church property was held in trust for the benefit of the entire denomination and could not be retained by a local church upon disaffiliation except as authorized by church law. The local churches alleged that the Conference engaged in fraudulent and collusive conduct, including misrepresentations about the procedures and timing for lawful disaffiliation, which caused them to miss the window for disaffiliation with property under denominational rules.The Circuit Court of Mercer County initially dismissed the complaint, holding that it lacked subject matter jurisdiction under the ecclesiastical abstention doctrine since the dispute required interpretation of church doctrine and governance—a matter reserved for the church’s highest tribunals. The court found that the allegations of fraud and collusion did not pertain to the procurement of a final ecclesiastical adjudication. However, following a Rule 59(e) motion by the local churches, a different judge vacated the prior dismissal, determining that the allegations of fraud and collusion raised factual questions for a jury and reopened the case.The Supreme Court of Appeals of West Virginia reviewed the matter on a petition for a writ of prohibition. The court held that constitutional limitations under the First Amendment and the West Virginia Constitution prevented civil courts from adjudicating disputes involving church doctrine, discipline, or governance. The court further clarified that the fraud or collusion exception only applies if such conduct procured a final ecclesiastical adjudication, which was not alleged here. The writ of prohibition was granted, barring enforcement of the order reopening the case, and reaffirming the circuit court’s lack of jurisdiction. View "State ex rel. Trustees of the West Virginia Conference of the United Methodist Church v. Wills" on Justia Law

A man and a female companion were suspected of shoplifting at a Walmart in White Hall, West Virginia. After the store employee alerted law enforcement, officers stopped and searched the vehicle the pair had used. The man, sitting in the passenger seat, was arrested, and officers found a black fanny pack under his seat, which contained a loaded firearm, baggies of white powder suspected to be cocaine, and pills believed to be oxycontin. He was indicted on six counts, including possession with intent to deliver cocaine and fentanyl, use or presentation of a firearm during the commission of a felony, possession of a firearm by a prohibited person, and prohibited person carrying a concealed firearm.The Circuit Court of Marion County presided over a one-day jury trial, after which the jury found the man guilty of five counts and not guilty of conspiracy. He filed a post-trial motion for judgment of acquittal or, alternatively, a new trial, arguing that the evidence was insufficient for the firearm charge and that his Sixth Amendment right to confront the forensic analyst was violated when the analyst who performed drug testing was not called to testify. The circuit court denied the motion, ruling that the sufficiency of evidence was a question for the jury and that the testimony of a substitute expert satisfied the confrontation requirement.The Supreme Court of Appeals of West Virginia reviewed the case and applied a de novo standard to the sufficiency and confrontation issues. The court held that the evidence was insufficient to sustain a conviction for use or presentation of a firearm during a felony because there was no proof the defendant actively employed the firearm. The court further held that admitting the forensic laboratory report through a surrogate expert violated the Confrontation Clause. Accordingly, the court reversed the firearm conviction, vacated the drug convictions, and remanded for a new trial on the drug charges. View "State v. Crawford" on Justia Law

Three former employees of the Senate of the Commonwealth of Puerto Rico alleged they were terminated from their positions—Protocol Officer and Liaison Technician—because of their political affiliations, in violation of their First Amendment rights. The suit was brought against Senate officials in their personal capacities under 42 U.S.C. § 1983, seeking damages for alleged unconstitutional patronage dismissals.The U.S. District Court for the District of Puerto Rico initially heard the case, which involved numerous plaintiffs and claims, including due process, equal protection, and Puerto Rico law claims. Many claims were dismissed at earlier procedural stages. The claims relevant to this appeal survived summary judgment and concerned only the First Amendment-based damages actions brought by the three former employees. The District Court denied the defendants’ motion for summary judgment, which was based on qualified immunity, finding there were genuine disputes of material fact regarding the plaintiffs’ job duties and whether defendants had considered the nature of those duties before termination.The United States Court of Appeals for the First Circuit reviewed the interlocutory appeal, which focused on the denial of qualified immunity. The First Circuit affirmed the District Court’s order. The appellate court held that the District Court erred in considering whether the officials had subjectively inquired into the plaintiffs’ job duties, as qualified immunity is an objective standard. However, the First Circuit found no error in the District Court’s other reasoning, ruling that unresolved factual disputes about the nature of the plaintiffs’ job responsibilities precluded summary judgment on qualified immunity. The court also determined that claims against the officials in their personal capacities were not discharged by the Commonwealth’s bankruptcy proceedings under PROMESA. Thus, the District Court’s denial of summary judgment was affirmed. View "Ortiz-Resto v. Rivera-Schatz" on Justia Law

The defendant was convicted in 2011 of first degree murder, multiple sexual offenses, and related crimes stemming from incidents in July 2008. A jury found him guilty and determined that he personally and intentionally discharged a firearm causing great bodily injury or death. Additional findings included three prior prison terms. He was originally sentenced to 78 years to life in prison. Following a change in the law eliminating one-year sentence enhancements for prior prison terms, the defendant petitioned for resentencing. The trial court resentenced him to 77 years to life, removing the prior prison term enhancements but retaining all other aspects of the sentence, including the gun enhancement.After the resentencing, the defendant argued that the trial court should have dismissed the gun enhancement under Penal Code section 1385(c), specifically referencing the Racial Justice Act (RJA). He contended that applying the enhancement would result in a discriminatory racial impact. In the Alameda County Superior Court, the trial judge found that dismissing the enhancement would endanger public safety and that none of the mitigating factors, including those based on racial bias, were established. The defendant’s evidence of racial bias was based on a statistical report and a claim of bias by the original sentencing judge, but the trial court found these claims insufficient under the RJA.On appeal, the California Court of Appeal, First Appellate District, Division Three, held that the defendant failed to present evidence meeting the RJA’s requirements. Specifically, he did not show that he received a longer sentence than similarly situated individuals of other races in the same county, nor did he provide comparator cases or adequate statistical evidence. The appellate court affirmed that to trigger section 1385(c)(2)(A), a defendant must satisfy the RJA’s standard, which the defendant did not. Accordingly, the judgment was affirmed. View "People v. Savoy" on Justia Law