Justia Constitutional Law Opinion Summaries

A technology company, along with its U.S. subsidiary, was designated by the Secretary of Defense as a “Chinese military company” under Section 1260H of the National Defense Authorization Act. This listing, published annually in the Federal Register, leads to significant legal consequences, including prohibitions on entering into certain federal contracts and receiving federal funds or support. The designation also carries reputational harm, as it publicly identifies the company as having ties to the Chinese military. The company develops and sells LiDAR products primarily used in advanced driver-assistance and autonomous vehicle systems.After being listed in January 2024, the company sued the Department of Defense in the United States District Court for the District of Columbia, challenging both the original and an October 2024 redesignation under the Administrative Procedure Act and the Fifth Amendment’s Due Process Clause. The company argued that it was not provided notice of the unclassified evidence relied upon or a meaningful chance to respond before the designation was finalized. The district court granted summary judgment to the government, upholding the designation and concluding that any due process violation was harmless because the company did not show prejudice.On appeal, the United States Court of Appeals for the District of Columbia Circuit held that the company had a protected liberty interest under the “stigma-plus” doctrine, as the designation combined reputational harm with formal exclusion from government contracting opportunities. The Court ruled that the Constitution required the Secretary to provide notice of the unclassified evidence and a meaningful pre-deprivation opportunity to respond. The Secretary’s failure to do so was not harmless error. The appellate court reversed the district court’s judgment and remanded with instructions to remand to the Secretary for further proceedings, but did not vacate the designation pending remedial process. View "Hesai Technology Co., Ltd v. DOD" on Justia Law

In June 2017, the defendant drove his truck into an alley and ran over two individuals sleeping under a blanket, resulting in one fatality and one serious injury. After being told by a witness that he had run over people, he denied it and drove away from the scene. Law enforcement, acting on witness information, located the defendant at his home, where he exhibited signs of alcohol use. Subsequently, the defendant was charged with leaving the scene of an accident resulting in death and with leaving the scene of an accident resulting in serious bodily injury. The prosecution later added habitual criminal counts based on prior felony convictions.At trial in the district court, the jury was instructed on the elements of the leaving-the-scene offenses without any requirement that the defendant acted with a culpable mental state, such as “knowingly.” The jury convicted the defendant on both charges. The judge, not a jury, adjudicated the defendant as a habitual offender and imposed a sixty-year sentence. The defendant appealed, arguing the trial court erred by not requiring proof of a mental state for the leaving-the-scene offenses and challenging the constitutionality of the habitual offender statute for permitting a judge, rather than a jury, to make factual findings that increased his sentence.The Colorado Court of Appeals affirmed both the convictions and the habitual offender adjudication, finding itself bound by existing precedent and concluding any error was harmless beyond a reasonable doubt. On review, the Supreme Court of Colorado held that its prior decision in People v. Manzo remains controlling, so the trial court did not err in omitting a culpable mental state from the jury instructions for the leaving-the-scene convictions. The court further held that the habitual offender statute was not unconstitutional and that any error in the judge’s factual findings, rather than a jury’s, was harmless beyond a reasonable doubt. The court affirmed the lower court’s judgment. View "Brown v. People" on Justia Law

A priest formerly affiliated with the Russian Orthodox Church Outside of Russia (ROCOR) brought suit against various church leaders and entities, alleging defamation. He claimed that leaders within ROCOR falsely accused him of forging letters from church officials that purportedly announced his election as a bishop. The priest maintained that he had been chosen for elevation, and that the accusations of forgery, which circulated within the church and were subsequently posted online, damaged his reputation and led to his suspension and eventual removal from clerical office.The United States District Court for the Southern District of New York, upon reassignment to a new judge, granted summary judgment to the defendants. The court found that the plaintiff failed to present sufficient evidence under New York defamation law linking the defendants to the public dissemination of the allegedly defamatory statements. Additionally, the court held in the alternative that the lawsuit was barred by the First Amendment’s church autonomy doctrine, as adjudicating the claims would require the court to intrude upon religious questions regarding ROCOR’s selection, supervision, and discipline of clergy, as well as its internal governance protocols.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s decision, focusing on the constitutional ground. The Second Circuit held that the First Amendment’s church autonomy doctrine prevents civil courts from adjudicating claims that would interfere with a religious organization’s management of its ministers or require secular courts to resolve disputes over church protocols and internal governance. The court concluded that the plaintiff’s claims, whether based on internal or public statements, were barred because their resolution would necessitate unconstitutional entanglement in matters of church governance and doctrine. View "Belya v. Kapral" on Justia Law

The appellant was arrested in Mississippi, extradited to Georgia, and released on bond. He was charged with theft by conversion stemming from a dispute involving the sale of a tractor-trailer. While on bond, he filed a pretrial habeas corpus petition, arguing that he continued to be unconstitutionally restrained due to ongoing bond conditions and pending prosecution. He requested the court to order the State to justify the restraint and sought a prompt hearing on probable cause. He also objected to the assignment of his habeas case to the same judge presiding over his criminal case, repeatedly seeking that judge’s recusal.The Superior Court of Gwinnett County assigned his habeas petition to Judge Tracey Mason, who denied multiple motions for her own recusal, explaining that adverse rulings are not grounds for disqualification. When the habeas petition came for hearing, a different judge, Judge Kylene Armond, presided by designation. The appellant refused to participate in the hearing, insisting that a new judge should be assigned before he would proceed. Judge Armond noted the appellant offered no evidence and warned that the petition could be dismissed for failure to prosecute. The appellant maintained his refusal, and Judge Armond dismissed the petition due to his failure to present evidence or pursue the claim.On appeal, the Supreme Court of Georgia considered only the dismissal order. The Court held that because the appellant failed to challenge the dismissal on the ground that he presented no evidence, that ground was presumed correct and binding. The Court further found that the recusal issue was irrelevant, since the judge whose recusal was sought did not dismiss the petition. The judgment of dismissal was affirmed. View "TWUM-BAAH v. THE STATE" on Justia Law

Rodney Greene was convicted for the felony murder of Tyjerus White following a shooting incident. On the night of the incident, White drove with three companions to visit a friend. While they were parked outside, Greene approached the car, acted aggressively, and initiated a confrontation with White and his companions. Witnesses testified that Greene appeared intoxicated and escalated the situation by threatening White with a lighter and later brandishing a handgun. After a heated argument, White attempted to leave but was confronted again by Greene, resulting in gunfire. White was fatally wounded and later found in his crashed vehicle. A .22 caliber bullet was recovered from White’s body, and shell casings at the scene matched a .22 caliber firearm, which was never found. Greene was arrested weeks later and admitted to the shooting.The Superior Court of Sumter County conducted a jury trial, which found Greene guilty of felony murder and aggravated assault. Greene was sentenced to life imprisonment with the possibility of parole. He filed a motion for a new trial, which the trial court denied after a hearing. Greene then appealed to the Supreme Court of Georgia, arguing that the evidence was insufficient to disprove his claim of self-defense and raising two claims of ineffective assistance of counsel.The Supreme Court of Georgia reviewed the case and held that the evidence was constitutionally sufficient for a rational jury to find Greene guilty beyond a reasonable doubt and to reject his justification defense. The Court also concluded that Greene’s trial counsel was not constitutionally ineffective either for failing to seek a mistrial due to alleged juror misconduct or for not calling a GBI agent whose testimony would have been inadmissible hearsay. The Supreme Court of Georgia affirmed Greene’s conviction. View "GREENE v. THE STATE" on Justia Law

The case concerns Andre Richardson, who was convicted of malice murder and possession of a firearm during a felony after the fatal shooting of Xavier Cato. The incident arose after Richardson, having separated from his wife, Shicana Brown, encountered her and Cato together in a parking lot. Richardson confronted them, displayed a firearm, and, after an exchange, shot Cato twice. Cato died from his injuries. Surveillance footage and Richardson’s own statements were presented at trial, with Richardson claiming he acted reflexively out of fear, and his defense centered on the argument that the killing constituted voluntary manslaughter rather than murder.The Superior Court of Fulton County presided over Richardson’s trial. The jury found him guilty of malice murder, aggravated assault with a deadly weapon, and possession of a firearm during the commission of a felony, while acquitting him of computer invasion of privacy. The felony murder conviction was vacated by operation of law, and the aggravated assault conviction merged with the malice murder conviction. Richardson was sentenced to life in prison plus five years. After trial, Richardson, with new counsel, filed a motion for a new trial, alleging ineffective assistance of counsel. The trial court denied this motion, finding that Richardson’s trial attorney was not deficient.The Supreme Court of Georgia reviewed Richardson’s claim that his trial counsel had been constitutionally ineffective for eliciting an investigator’s opinion about the decision to charge murder rather than voluntary manslaughter. The Court held that Richardson failed to show his counsel’s performance was objectively unreasonable, noting that the line of questioning was a legitimate trial strategy aimed at supporting the voluntary manslaughter theory. The Court affirmed the denial of the motion for a new trial and Richardson’s convictions. View "RICHARDSON v. THE STATE" on Justia Law

After being involved in an eviction proceeding in Hillsborough County, Florida, an individual deposited funds into the court registry, as required by state law. Over time, he changed addresses and updated his contact information in the state’s e-filing system, but did not always update his address with the county court. The county clerk attempted to notify him of unclaimed funds by mailing letters to an outdated address (despite repeated returned mailings) and by publishing notice in a local Spanish-language newspaper with very limited circulation in the county. The funds were eventually declared abandoned and forfeited to the county under a Florida statute.The United States District Court for the Middle District of Florida granted summary judgment in favor of the county clerk. The district court found that publication in the local newspaper constituted constitutionally sufficient notice and that the forfeiture did not amount to an unconstitutional taking because statutory schemes for escheatment of abandoned property are generally permissible.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The appellate court held that the statute’s notice procedure is not facially unconstitutional because there are situations where publication alone may suffice—for instance, when the property owner is unknown. However, the court found the clerk’s application of the statute to this individual was unconstitutional. The clerk had access to alternative means of contact (including email and a valid mailing address in the state’s e-file system) but failed to use them, relying instead on methods not reasonably calculated to provide notice. The court also determined that the individual had not abandoned the funds, since he never received constitutionally adequate notice, and thus the county’s appropriation of the funds constituted an unconstitutional taking. The Eleventh Circuit affirmed in part, reversed in part, and remanded for further proceedings. View "Warner v. Hillsborough County Clerk of Courts" on Justia Law

The defendant was charged with capital murder and other offenses in 1993. Throughout the proceedings, concerns arose regarding his mental competency and his ability to represent himself. On two occasions, the trial court declared a doubt as to the defendant’s competency and held hearings, concluding both times that he was competent. During the second such hearing in July 1994, the defendant represented himself, which meant no counsel was appointed despite statutory requirements. The medical experts at the hearing offered differing views: one expert found the defendant competent to stand trial but not to represent himself, while the other found him unable to cooperate rationally with counsel. The defendant was ultimately convicted and sentenced to death.After direct appeal, the Supreme Court of California found reversible error in the trial court’s failure to appoint counsel during the 1994 competency proceedings and remanded the case, instructing the trial court to determine if a retrospective competency hearing was feasible. If feasible, a hearing would be held; if not, the reversal would stand.On remand, the Kern County Superior Court found that a retrospective hearing was feasible, conducted the hearing, and a jury found the defendant competent at the relevant time, leading to reinstatement of the judgment. The defendant appealed again, arguing that feasibility was not established.The Supreme Court of California held that the trial court erred in finding a retrospective competency hearing feasible. The court emphasized that such hearings are generally disfavored and that the prosecution had not met its burden to show sufficient and reliable evidence existed to determine the defendant’s competence nearly two decades later, especially given the unavailability of key witnesses and the compromised development of evidence due to the lack of appointed counsel in 1994. As a result, the Supreme Court reversed the reinstated judgment, subject to retrial if the defendant is then found competent. View "P. v. Lightsey" on Justia Law

Derek Fields was involved in a violent kidnapping in September 2015, during which he and his co-defendants abducted Adrian Harris, inflicted physical harm, and demanded ransom. Fields was arrested within days alongside his co-defendants and indicted on several charges, including kidnapping, making a ransom demand, and firearm offenses. The government extended multiple plea offers, each carrying substantial prison time, but Fields consistently rejected them, viewing sentences over twenty years as tantamount to a life sentence. After his motion to suppress evidence was denied, Fields proceeded to trial, was convicted on all counts, and originally sentenced to 53 years. On appeal, his conviction under one firearm statute was vacated pursuant to United States v. Davis, 588 U.S. 445 (2019), and he was resentenced to 43 years.After his conviction became final, Fields filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Northern District of Indiana, arguing that his last counsel was constitutionally ineffective for failing to adequately advise him about an alleged 37-year plea offer presented during jury selection. The district court denied the motion without an evidentiary hearing, focusing primarily on a different plea agreement attached to Fields’s reply brief, and concluded that Fields failed to show prejudice because he did not establish a reasonable probability he would have accepted the offer and received a lower sentence.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial de novo for legal questions and for abuse of discretion regarding the lack of an evidentiary hearing. The Seventh Circuit assumed, for argument’s sake, that the alleged 37-year plea offer existed and that counsel’s advice was inadequate, but found that Fields did not demonstrate a reasonable probability he would have accepted the plea or received a lower sentence. The court therefore affirmed the district court’s denial of Fields’s § 2255 motion without an evidentiary hearing. View "Fields v. USA" on Justia Law

Jessica McKee, a pretrial detainee at the Steele County Detention Center in Minnesota, suffered from Crohn’s disease. During her detention, she communicated with jail medical staff, including Nurse Jessica Brady, regarding various medical needs. McKee requested accommodations such as a lower bunk due to alleged seizures and pain, dietary changes to address her Crohn’s disease, and access to her prescription medication. Brady denied the bunk request due to lack of documentation, approved dietary changes as requested by McKee, and communicated with outside care providers to obtain medical records. When McKee reported worsening symptoms, Brady called her for an in-person evaluation and referred her to the emergency room, where McKee was hospitalized and suffered complications.McKee filed a lawsuit under 42 U.S.C. § 1983, asserting that Brady was deliberately indifferent to her serious medical needs in violation of her Fourteenth Amendment rights. Nurse Brady moved for summary judgment on the basis of qualified immunity. The United States District Court for the District of Minnesota denied Brady’s motion, finding that a reasonable jury could conclude that Brady was deliberately indifferent to McKee’s medical needs.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment de novo. The Eighth Circuit concluded that McKee failed to show that Brady’s actions violated a clearly established constitutional right. The court found that Brady responded to each of McKee’s requests, followed appropriate procedures within her authority, and was not deliberately indifferent as defined by precedent. The court further determined that any negligence did not rise to the level of a constitutional violation. Accordingly, the Eighth Circuit held that Brady was entitled to qualified immunity and reversed the district court’s order denying summary judgment. View "McKee v. Brady" on Justia Law