Justia Constitutional Law Opinion Summaries

The case involves Maxim Levin and Vodka Properties LLC, who owned a residential building in Buffalo, New York, that was demolished by the City of Buffalo in 2019 under emergency procedures. The City justified the emergency demolition by citing illegal drug activity on the property, including a recent overdose death, and the building’s vacant and allegedly structurally compromised condition. Plaintiffs contested whether these circumstances actually warranted an immediate demolition without a pre-deprivation hearing and argued that their constitutional rights were violated.A magistrate judge in the United States District Court for the Western District of New York recommended denying summary judgment on some constitutional claims, finding disputed facts about the condition of the property and notice provided. The district court, however, dismissed certain claims, including procedural due process, based on its finding that adequate notice was given and that the individual City employees (except the City itself) were entitled to qualified immunity. The court also dismissed claims against the demolition company for lack of state action and dismissed claims against the City, concluding there was no municipal liability under Monell v. Department of Social Services.The United States Court of Appeals for the Second Circuit held that summary judgment was improper on the procedural due process, unlawful taking, and unreasonable seizure claims, because there were unresolved factual questions about whether the property’s condition justified emergency demolition. The appellate court further determined that Commissioner James Comerford, Jr. was the City’s final policymaker regarding demolition decisions, so Monell liability was improperly dismissed. The court reversed the grant of qualified immunity for the Commissioner due to factual disputes but affirmed summary judgment for the other individual employees and the demolition company. The court affirmed dismissal of the substantive due process and state law claims. The judgment was affirmed in part, vacated in part, and the case remanded for further proceedings. View "Levin v. City of Buffalo" on Justia Law

A group of Wisconsin taxpayers challenged a state program that provides need-based college grants to students belonging to specified racial, national origin, ancestry, or alienage groups attending private and technical colleges. The program, administered by the Higher Educational Aids Board (HEAB), was created to address disproportionate attrition rates among certain minority students by offering them financial support. Students who do not fall into the listed preferred groups are categorically ineligible for this aid.The Jefferson County Circuit Court ruled in favor of HEAB, holding that the taxpayers had standing and that the program was constitutional. The court relied on the U.S. Supreme Court’s decision in Grutter v. Bollinger, finding that fostering diversity in higher education is a compelling state interest and that the program was narrowly tailored to address high attrition rates among minority students. The taxpayers appealed this decision.While the case was on appeal, the United States Supreme Court decided Students for Fair Admissions, Inc. v. President & Fellows of Harvard College, which held that achieving diversity in higher education is no longer a compelling interest justifying race-based classifications. Applying this new precedent, the Wisconsin Court of Appeals reversed the circuit court, holding the program unconstitutional under the Equal Protection Clause and ordering HEAB to stop administering it.On further review, the Supreme Court of Wisconsin held that the taxpayers had standing because any illegal expenditure of public funds creates taxpayer injury. The court also held that the grant program violates the Equal Protection Clause of the Fourteenth Amendment. It found that neither promoting diversity nor equalizing educational opportunity for certain groups was a sufficiently compelling interest under current law, and that the means chosen were not narrowly tailored. The Supreme Court of Wisconsin affirmed the Court of Appeals and enjoined HEAB from operating the program. View "Rabiebna v. Higher Educational Aids Board" on Justia Law

A deputy sheriff sergeant was terminated from his employment after an incident where he encountered two individuals with active “time pay” warrants for failure to pay fines. Despite confirming the existence and validity of the warrants, which were issued by a county court and directed to any law enforcement officer, he told the individuals that he would not arrest them because he believed doing so would be pointless. The interaction was recorded on his body camera. After the sheriff’s office conducted an internal investigation, the sergeant was found to have violated standard operating procedures by neglecting his duty.The sergeant appealed the termination to the county sheriff’s merit commission, which upheld the decision after a hearing. He then filed a petition in error with the District Court for Lancaster County, arguing that the evidence did not support his termination, that due process was denied because he was not given notice regarding issues of credibility or prior investigations, that the commission’s decision was void for untimely delivery, and that he had not waived any objections by failing to object during the administrative hearing. The district court found sufficient evidence supported the commission’s decision, determined the procedures were constitutionally adequate, rejected the argument about untimely delivery because no specific deadline for notification was violated, and concluded there was no prejudice regarding any waiver issue.The Nebraska Supreme Court reviewed the case. It held that sufficient evidence supported the finding that the sergeant neglected his statutory duty to execute the warrants, which justified termination under the governing procedures. The court also held that due process requirements were satisfied, as the sergeant received notice of the charges, an explanation of the evidence, and an opportunity to be heard. The court affirmed the district court’s judgment, finding no prejudicial error in the proceedings. View "Schmuecker v. Lancaster County" on Justia Law

A police officer stopped a motorist who was driving a light blue Chrysler minivan with dark tinted windows. The officer had knowledge of an armed robbery that had occurred two days earlier, where the suspect’s vehicle was described as a gold or tan Dodge or Chrysler minivan with a license plate possibly beginning with “TWL.” As the officer approached the vehicle, he realized its color and license plate did not exactly match the suspect description but continued the stop, noticing illegal window tint and the smell of burnt marijuana. A search revealed the motorist possessed a loaded firearm despite being a convicted felon.The Cuyahoga County Court of Common Pleas held a suppression hearing and granted the defendant’s motion to suppress the evidence, concluding that the officer should have ended the stop once he determined the vehicle did not match the robbery suspect’s description. The Eighth District Court of Appeals remanded for findings of fact, after which the trial court stated the stop was initiated to investigate the robbery, not the window tint. The trial court again ruled for suppression, and the Eighth District affirmed, finding the police improperly extended the stop after losing reasonable suspicion related to the robbery.The Supreme Court of Ohio reviewed the case and applied Fourth Amendment standards, emphasizing that reasonable suspicion to justify a traffic stop is an objective inquiry and does not depend on an officer’s subjective intent. The court held that when an officer initiates a traffic stop with multiple independent reasonable suspicion bases, the stop remains lawful as long as at least one basis persists, even if others are extinguished. The judgment of the Eighth District was reversed, and the case was remanded to the trial court for further proceedings. View "State v. Mathis" on Justia Law

The case arose when a property owner initiated an eviction action against a tenant. The parties resolved the matter through a court-approved settlement, under which the tenant agreed to vacate the apartment by a specified date. The tenant complied with the settlement terms. Several months later, the tenant moved for expungement of the eviction record, relying on a recently amended Minnesota statute providing that courts must expunge eviction files if the case is settled and the defendant fulfills the terms of the settlement.A housing court referee recommended expungement pursuant to that statute, and the district court signed the expungement order. The property owner, Sela Investments, appealed to the Minnesota Court of Appeals, arguing that the statutory expungement provision was unconstitutional. The Court of Appeals agreed, holding that the statute was a facial violation of the separation of powers because it infringed on the judiciary’s inherent authority to manage its own records. The appellate court reversed the expungement and remanded for the district court to apply a discretionary balancing test instead.On review, the Supreme Court of Minnesota first considered whether Sela Investments had standing to challenge the constitutionality of the statute. The court held that to have standing for a constitutional challenge, a party must show the statute has disadvantaged or is about to disadvantage its legal interest or right. The Supreme Court found that Sela Investments had not been harmed by the expungement statute, as it retained its own knowledge of the tenant and did not lose any legal right or interest.Because Sela Investments lacked standing, the Supreme Court held that neither it nor the Court of Appeals had jurisdiction to adjudicate the constitutional claim. The Supreme Court therefore vacated the decision of the Court of Appeals. View "Sela Investments, Ltd LLP vs. J.H." on Justia Law

A criminal defendant was charged with assault after a neighbor identified him as the perpetrator of an attack on a sixty-nine-year-old woman at her home. The woman, whose primary language was Chuukese, provided a brief description of her attacker to the police. Her identification occurred during a field show-up at a nearby bus stop, where she was transported in an ambulance without a Chuukese interpreter. The defendant was the only person presented during the show-up, and he was handcuffed and accompanied by a uniformed police officer. The police were unable to instruct the woman that the perpetrator might not be present, due to a language barrier.The Circuit Court of the First Circuit held a hearing and denied the defendant’s motion to suppress the identification, relying exclusively on the factors listed in Hawai‘i Pattern Jury Instructions--Criminal (HAWJIC) 3.19. The jury subsequently found the defendant guilty. On appeal, the Intermediate Court of Appeals vacated the conviction and remanded the case for a new trial, finding that the circuit court failed to consider additional relevant factors listed in HAWJIC 3.19A and did not evaluate the effect of the suggestiveness of the show-up procedure on the reliability of the identification.The Supreme Court of the State of Hawai‘i reviewed the case and clarified the standards for suppression of identification evidence in inherently suggestive show-ups. The court held that trial courts must, at minimum, consider relevant factors in both HAWJIC 3.19 and 3.19A, as well as the effect of suggestiveness on reliability. Applying these standards to the record, the court concluded that the identification was not sufficiently reliable and ordered that it be suppressed on remand. The court affirmed the ICA’s judgment vacating the conviction and remanded the case for further proceedings, holding the error was not harmless beyond a reasonable doubt. View "State v. Jercy" on Justia Law

Two individuals were prosecuted for their roles in a violent drug-trafficking organization in the U.S. Virgin Islands. One defendant was identified as the leader, convicted by a jury of 22 counts including drug, firearm, and racketeering charges; the other, an armorer, was convicted of seven counts relating to racketeering and firearms. Their trial occurred in March 2022, shortly after the District Court resumed in-person proceedings following COVID-19 restrictions. Initially, all public spectators were required to observe the proceedings from an overflow room via audiovisual feed, rather than in the courtroom itself. After the first day, some spectators, including family members, were permitted into the courtroom, but for several days, court security personnel prevented the defendants’ mothers from entering, even when seats were available.Following their convictions, the defendants moved for a new trial in the District Court of the Virgin Islands, arguing that their Sixth Amendment right to a public trial was violated by these restrictions. After an evidentiary hearing, the court found that some seating was always available on a first-come basis and that any interruptions in the audiovisual feed were brief. The District Court denied the motions, concluding that the public was not excluded from the trial.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s factual findings for clear error and legal conclusions de novo, but applied plain error review due to the defendants’ failure to make timely objections. The Third Circuit held that there were errors: the initial exclusion of all public spectators and the subsequent exclusion of the defendants’ mothers were unjustified. However, the court also held that these errors did not seriously affect the fairness, integrity, or public reputation of judicial proceedings and therefore did not warrant reversal. The judgments of conviction were affirmed. View "USA v. Harry" on Justia Law

A man was convicted of first-degree murder, kidnapping, and sexual abuse in connection with the 1989 killing of a woman. The prosecution relied heavily on testimony from a codefendant, who received a plea deal and testified that the defendant killed the victim after a dispute over drugs. Other witnesses, including the victim’s family and friends, corroborated aspects of the prosecution’s account. The defendant’s counsel presented a misidentification defense and a mere-presence defense, but the jury found him guilty and he was sentenced to death after the trial court determined the crime was especially cruel, heinous, or depraved.Following the initial conviction, the Arizona Supreme Court reversed some convictions and remanded for a retrial, after which the defendant was again convicted and sentenced to death. On direct appeal, the Arizona Supreme Court affirmed the conviction and sentence, finding both aggravating factors met and that mitigating evidence, including the defendant’s abusive childhood and substance abuse, did not outweigh aggravation. The defendant filed state postconviction petitions, arguing ineffective assistance of counsel at both the guilt and penalty phases, and raising issues about mitigation evidence. Both the trial court and Arizona Supreme Court denied relief, often finding the claims procedurally barred or unsupported.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of federal habeas relief. The court held that most guilt-phase ineffective assistance claims were procedurally defaulted and not excused under Martinez v. Ryan, as the defendant failed to show cause and prejudice. The court found one claim—failure to retain a forensic expert to challenge testimony about the victim’s gurgling—was not defaulted, but concluded the state court reasonably found no prejudice given overwhelming evidence of guilt. The court also found the Arizona Supreme Court reasonably rejected penalty-phase ineffective assistance claims and denied a certificate of appealability on the claim regarding mitigation evidence and the causal nexus test. The judgment of the district court was affirmed. View "DETRICH v. THORNELL" on Justia Law

Federal authorities investigated an individual in Massachusetts after monitoring his activity on Freenet, an internet-based peer-to-peer network known for anonymous file sharing. Law enforcement noted that a user at his IP address requested child pornography files. They obtained a search warrant and, upon execution, seized several electronic devices from the individual’s home. One device contained substantial evidence of child pornography, including images and videos of an identified minor in various states of undress, as well as internet activity linking the device to the individual.Following investigation, the United States filed criminal charges for possession, receipt, and production of child pornography. A grand jury returned indictments on all three counts. The individual moved to suppress evidence from the search, arguing the warrant lacked probable cause. The United States District Court for the District of Massachusetts denied this motion. At trial, a jury convicted the defendant on all charges. The district court then imposed sentencing enhancements for, among other things, a pattern of activity, use of a computer, vulnerable victim status, and obstruction of justice, resulting in a total sentence of 20 years for the production count and 14 years each for the receipt and possession counts, to be served concurrently.On appeal to the United States Court of Appeals for the First Circuit, the defendant challenged the denial of his suppression motion, the sufficiency and constitutionality of the production charge, certain evidentiary rulings, and the sentencing enhancements. The First Circuit reviewed each claim and rejected them, finding the search warrant was supported by probable cause, the evidence sufficient for conviction, § 2251(a) constitutional as applied, and no reversible error in evidentiary or sentencing rulings. The First Circuit affirmed both the conviction and sentence. View "US v. Baxter" on Justia Law

In this case, the defendant was involved in a car accident in the early morning hours, after which a witness observed him exiting the overturned vehicle with a bag containing drugs and a firearm. When the witness refused to take the bag, the defendant hid it by the roadside and left the scene in another vehicle. Police later recovered the bag, which contained cocaine, a loaded revolver, and ammunition. The vehicle was registered to the defendant. The government’s key witness at trial testified about the defendant’s actions, and his testimony was the only direct evidence linking the defendant to the bag.After the first trial, the defendant was convicted on all counts: possession with intent to distribute cocaine, possession of a firearm in furtherance of drug trafficking, and being a felon in possession of a firearm. However, the United States Court of Appeals for the Sixth Circuit reversed those convictions, finding that the United States District Court for the Eastern District of Kentucky had improperly limited the defendant’s ability to cross-examine the witness about matters relevant to his bias and motivation. A retrial followed, during which the defendant sought to obtain more information about the witness’s criminal history and potential benefits received for his testimony, but was unable to secure expunged records from state court officials.Upon appeal after the second trial, the United States Court of Appeals for the Sixth Circuit reviewed whether the District Court’s refusal to compel production of the witness’s criminal file and its limitations on cross-examination violated the defendant’s rights under the Confrontation Clause. The Sixth Circuit held that the Confrontation Clause does not grant a defendant a pretrial right to compelled discovery of documents for cross-examination purposes, and that the District Court allowed sufficient latitude for cross-examination to satisfy constitutional requirements. The judgment of conviction was affirmed. View "United States v. Taylor" on Justia Law