Justia Constitutional Law Opinion Summaries

The petitioner was convicted of the rape and murder of a 15-year-old girl. After initially being sentenced to death, the Texas Court of Criminal Appeals (CCA) granted him a new sentencing trial. At the resentencing, the state introduced evidence of his affiliation with Satanism, including personal writings and expert testimony, to argue he posed a future danger. The petitioner claimed this violated his First Amendment rights. He was again sentenced to death.Following the resentencing, the petitioner’s First Amendment claim was rejected on direct appeal by the CCA, and his ineffective assistance of counsel (IAC) claims were denied by the state habeas court. The CCA adopted the habeas court’s findings. The petitioner then pursued federal habeas relief, but the United States District Court for the Western District of Texas found his claims were either procedurally defaulted or reasonably rejected by the state courts, and denied relief. The petitioner was granted a certificate of appealability on his First Amendment and IAC claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. Applying the highly deferential standard mandated by the Antiterrorism and Effective Death Penalty Act (AEDPA), the court concluded that the CCA’s rejection of the First Amendment claim was not contrary to or an unreasonable application of clearly established Supreme Court precedent. The court distinguished the evidence admitted in this case from the Supreme Court’s decision in Dawson v. Delaware and found it was relevant to the question of future dangerousness, not just to abstract beliefs. The court further held that no relief was warranted on the IAC claims because counsel’s performance was not objectively unreasonable and the state habeas court’s findings were not clearly erroneous. The Fifth Circuit affirmed the district court’s denial of habeas relief. View "Davis v. Guerrero" on Justia Law

Two North Dakota residents, who were involved in sponsoring a 2022 ballot initiative that established legislative term limits in the North Dakota Constitution, challenged a subsequent action by the Legislative Assembly. In 2025, the Assembly adopted Senate Concurrent Resolution 4008 to propose a constitutional amendment that would alter those term limits and repeal the provision prohibiting the Assembly from making such proposals. The Secretary of State accepted the resolution and planned to place the measure on the November 2026 general election ballot. The petitioners argued that the Assembly’s action exceeded its constitutional authority and sought a writ to prevent the measure from appearing on the ballot.Prior to this proceeding, the North Dakota Supreme Court had granted a writ of mandamus in Hendrix v. Jaeger, requiring the Term Limits Initiative to be placed on the 2022 ballot, resulting in voter approval and the addition of term limits to the constitution. After the Assembly adopted S.C.R. 4008, the petitioners filed directly in the North Dakota Supreme Court for declaratory and injunctive relief. The Secretary of State took no position on the constitutionality of the resolution but argued he lacked authority to withhold it from the ballot. The Legislative Assembly opposed the petition, disputing the petitioners’ standing and the ripeness of the issue.The Supreme Court of North Dakota exercised its discretionary original jurisdiction, finding that the petitioners had standing and that the matter was ripe for review because it concerned compliance with mandatory constitutional procedures. The court held that the Assembly’s adoption of S.C.R. 4008 violated Article XV, Section 4 of the North Dakota Constitution, which expressly prohibits the legislature from proposing amendments that alter or repeal legislative term limits, reserving that power to the people by initiative. The court declared S.C.R. 4008 and the proposed measure void ab initio, enjoined the Secretary of State from placing it on the ballot, and denied attorney’s fees. View "Bjerke v. North Dakota Legislative Assembly" on Justia Law

The case concerns a defendant who was charged and convicted of felony lewd and lascivious conduct after an incident involving an eighteen-year-old victim who was staying overnight at a friend’s house, where the defendant was also present. During the night, the defendant engaged in sexual contact with the sleeping victim, including touching her breast and genitals, and masturbating over her. The victim disclosed the incident days later, and the defendant subsequently admitted his actions. The jury found the defendant guilty of the felony offense and not guilty of the lesser-included misdemeanor. The court sentenced him to two-to-four years, with all but ninety days suspended, and imposed probation.After sentencing, the defendant appealed, raising a constitutional challenge to the proportionality of his sentence and arguing it was disproportionate to his conduct, which he characterized as “misdemeanor-level.” The Vermont Supreme Court, in an earlier direct appeal, reviewed the proportionality argument for plain error due to lack of preservation and did not find plain error. Following that decision, the defendant filed a motion for sentence reconsideration under Vermont Rule of Criminal Procedure 35 in the Superior Court, Windham Unit, Criminal Division, arguing his sentence violated the Vermont Constitution and seeking a reduction based on mitigating factors.The Superior Court denied the motion, concluding it lacked authority under Rule 35(a) to address constitutional challenges to the underlying conviction and that the arguments presented had already been considered at sentencing. On further appeal, the Vermont Supreme Court affirmed, holding that Rule 35(a) cannot be used to collaterally attack a conviction or to challenge the constitutionality of the statute of conviction, and that the defendant’s sentence was within the statutory limits. The Court also held that the trial court did not abuse its discretion in denying sentence reduction under Rule 35(b). View "State v. Smith" on Justia Law

A man was stopped by South Dakota wildlife conservation officers while boating on the Missouri River between South Dakota and Nebraska in July 2024. The officers noticed possible impairment and, after a field sobriety test, arrested him for boating under the influence and other offenses. The events in question took place near the Nebraska shoreline, beyond the centerline of the river’s designed channel.The defendant moved to dismiss the charges in the Magistrate Court of the First Judicial Circuit, Union County, South Dakota, arguing the state lacked jurisdiction because the incident happened on the Nebraska side of the river. After an evidentiary hearing, the magistrate court found that the arrest occurred on the Nebraska side, and concluded that South Dakota’s statutes giving conservation officers jurisdiction to the furthermost shoreline were preempted by the federally approved 1989 South Dakota-Nebraska Boundary Compact, which fixes the state boundary at the centerline of the Missouri River. The magistrate court dismissed the case for lack of jurisdiction.The State of South Dakota sought appellate review. The Supreme Court of the State of South Dakota first determined that the State’s petition for intermediate appeal was timely and that it had appellate jurisdiction. The Supreme Court held that the magistrate court did not abuse its discretion by receiving testimony and evidence to resolve the jurisdictional issue. The Supreme Court further held that, based on federal law and the 1989 Compact, South Dakota does not have concurrent jurisdiction over the Missouri River beyond the centerline of the designed channel unless there is an agreement or reciprocal legislation with Nebraska, which does not exist. As a result, the Supreme Court affirmed the magistrate court’s order dismissing the charges for lack of jurisdiction. View "State v. Ogden" on Justia Law

The case involved a mother whose parental rights to her youngest child were terminated by the Maine District Court. The Department of Health and Human Services initiated a child protection proceeding in June 2023, citing concerns about the mother's mental health, substance abuse, and neglect. The mother missed the preliminary hearing, and the child remained in the Department’s custody. Shortly before a scheduled jeopardy hearing, the mother’s attorney, without prior motion or notice to the mother, orally requested the appointment of a guardian ad litem (GAL) for the mother. The court, relying solely on representations of counsel and without a hearing or evidence, appointed a GAL with broad authority to make binding decisions on the mother’s behalf.Following this, several hearings took place, including a jeopardy hearing and judicial review hearings. There was ongoing confusion among the court and the mother’s attorneys regarding whether direction should be taken from the mother or the GAL, especially when their positions diverged. In August 2025, at the termination hearing, the mother’s GAL consented to termination of parental rights on the mother’s behalf, over the mother’s absence and without her knowledge of the GAL’s intent to consent. The District Court entered the termination order based on the GAL’s consent, and the mother appealed.The Maine Supreme Judicial Court reviewed the case. It held that the process used to appoint the GAL violated the mother’s due process rights because she was not afforded notice or an opportunity to be heard before the GAL’s appointment and before her decision-making authority was delegated. The Court further concluded that this error was prejudicial and required the judgment to be vacated. The case was remanded for a proper competency hearing and new proceedings beginning with the jeopardy phase, ensuring the mother’s due process rights are protected moving forward. View "In re Child of Mindy P." on Justia Law

In December 2017, William Roberts had an argument with his girlfriend, Elizabeth Hellstrom, after which she became unresponsive but was later revived. The next day, Roberts informed a friend that Elizabeth was dead and placed in the trunk of her car, also expressing an intent to commit suicide using a propane tank. Law enforcement was alerted and found Elizabeth’s body in her vehicle and evidence of violence in the camper she shared with Roberts. Roberts was indicted for first-degree murder, and the State sought the death penalty based on his prior violent felony conviction and the especially heinous nature of the crime.Following indictment, Roberts was represented by court-appointed counsel but expressed dissatisfaction and chose to waive his right to a jury trial and his presence at trial, both of which the trial court found to be knowing and voluntary. The case proceeded as a bench trial in the Circuit Court in and for Lake County, which found Roberts guilty of first-degree premeditated murder. During the penalty phase, Roberts waived the presentation of mitigating evidence, and the court eventually sentenced him to death, giving great weight to the statutory aggravators and only slight weight to limited mitigating factors.Roberts appealed to the Supreme Court of Florida, raising multiple claims including the admission of collateral crime evidence, the trial court’s rejection of a statutory mitigator, the use of certain penalty phase evidence, constitutional challenges to the death penalty and Florida’s sentencing scheme, and the lack of a contemporaneous competency hearing. The Supreme Court of Florida held that the trial court did not abuse its discretion in admitting evidence or in its mitigator findings, found no constitutional violation, and affirmed the sufficiency of the nunc pro tunc competency determination. The conviction and death sentence were affirmed. View "Roberts v. State of Florida" on Justia Law

Several Syrian and Haitian nationals challenged the United States Secretary of Homeland Security’s decision to terminate Temporary Protected Status (TPS) designations for Syria and Haiti. TPS provides humanitarian relief for foreign nationals who cannot safely return to their countries. Syria’s TPS status, granted in 2012 due to civil war, was set for termination in 2025 following changes in the country’s government and improved conditions. Haiti’s TPS status, in place since a 2010 earthquake, was also scheduled for termination in 2026, with the government citing improved conditions and foreign policy considerations.In the United States District Court for the Southern District of New York, Syrian plaintiffs sued under the Administrative Procedure Act (APA), and the court granted interim relief, postponing termination. The United States Court of Appeals for the Second Circuit denied the government’s request for a stay. Separately, Haitian plaintiffs in the United States District Court for the District of Columbia brought APA and constitutional equal protection claims, alleging racial motivation behind the termination. That court also granted interim relief, and the United States Court of Appeals for the District of Columbia Circuit declined to issue a stay. The government petitioned for a stay and certiorari before judgment, after which the Supreme Court consolidated the cases for review.The Supreme Court of the United States held that the TPS statute bars judicial review of any non-constitutional claims related to the designation, extension, or termination of TPS for a foreign state. The Court also concluded that the equal protection claim brought by the Haitian plaintiffs was unlikely to succeed, finding insufficient evidence that race was a motivating factor in the termination decision. As a result, the Supreme Court reversed the interim relief granted by both district courts and remanded the cases for further proceedings. View "Mullin v. Doe" on Justia Law

Three residents of Maui County, Hawaii, each possessing a concealed-carry firearm permit, along with an organizational plaintiff, challenged a Hawaii statute that prohibits carrying firearms on private property open to the public unless the owner gives express, affirmative consent. This law, enacted after a Supreme Court decision recognized a constitutional right to carry handguns outside the home for self-defense, significantly limited the places where permit holders could lawfully carry. The statute imposed new burdens: permit holders had to obtain explicit permission before entering everyday establishments like stores and restaurants, reversing the traditional rule where entry was presumed permissible unless expressly forbidden.At the trial level, the United States District Court for the District of Hawaii enjoined enforcement of the law as applied to private property open to the public, finding it unconstitutional. The United States Court of Appeals for the Ninth Circuit reversed this injunction, allowing Hawaii’s law to remain in effect. The full Ninth Circuit denied a request for rehearing en banc, with several judges dissenting.The Supreme Court of the United States reviewed the case and held that Hawaii’s law violates the Second and Fourteenth Amendments. The Court found that the restriction fell within the plain text of the Second Amendment, creating a significant burden on the right to carry firearms for self-defense. The Court determined that Hawaii’s historical analogues—laws from the colonial and early state periods—were not sufficiently similar, as they primarily targeted unauthorized hunting, not self-defense in public establishments. The Supreme Court reversed the Ninth Circuit’s decision and remanded for further proceedings, holding that states cannot adopt default property rules that broadly prohibit carrying firearms on public-facing private property without individualized, express consent. View "Wolford v. Lopez" on Justia Law

In 2020, a home was broken into and the resident, Z.H., was assaulted by an unknown individual. Z.H. later suggested to police that the perpetrator might be a classmate she had seen on the bus, eventually identifying the respondent as that classmate. A detective sought and obtained a Colorado Rule 41.1 order, supported by reasonable suspicion, to collect DNA evidence from the respondent. The detective contacted the respondent and instructed him to come to the police station, but when that did not occur, detectives went to his home the next morning. There, they questioned the respondent about the assault, obtained inculpatory statements, and subsequently transported him to collect the DNA sample as authorized.The respondent was charged with several offenses related to the assault. He moved to suppress the statements made during the home encounter, arguing a violation of his Fourth Amendment rights and Colorado’s Rule 41.1, as interpreted in People v. Harris. The trial court denied the suppression motion, and the respondent was convicted by a jury. On appeal, the Colorado Court of Appeals reversed, holding that the execution of the Rule 41.1 order—and thus the protections against interrogation—began when the respondent was seized at his home, making his statements inadmissible.The Supreme Court of Colorado reviewed the case and affirmed the appellate court’s decision. The court held that execution of a Rule 41.1 order begins when a reasonable person in the suspect’s position would not feel free to leave, marking the point at which interrogation is prohibited without probable cause. Because the detectives interrogated the respondent after he was seized for the purpose of collecting nontestimonial identification evidence, the court concluded that his statements must be suppressed. The judgment of the Colorado Court of Appeals was therefore affirmed. View "People v. Castro-Velasquez" on Justia Law

A man was convicted of capital murder after killing his former partner and her ten-year-old daughter in their shared apartment, while her twin four-year-old sons were present but unharmed. The killings occurred shortly before a court hearing at which the man was facing charges for previous assaults against the same woman. After committing the murders, he attempted to clean the crime scene, fled to Tennessee, confessed to his uncle, and was arrested as he tried to escape police. During the trial’s punishment phase, evidence of the sexual assault of the child victim, the defendant’s disruptive behavior in jail, and threats to his attorneys was presented.The trial originated in the Criminal District Court No. 1 in Tarrant County, Texas, where a jury convicted the defendant of capital murder and sentenced him to death based on their answers to special punishment issues. The defendant raised multiple claims on appeal, including challenges to the sufficiency and form of the indictment, denial of a motion to suppress evidence related to a search warrant, alleged Confrontation Clause violations tied to expert testimony and hearsay statements admitted during the punishment phase, the admission of expert testimony about prison violence, and the constitutionality of the statute governing jury instructions in capital cases.The Texas Court of Criminal Appeals reviewed the case on automatic direct appeal. The court held that the defendant waived his challenge to the indictment by failing to object before trial, and that the omission in the search warrant affidavit was not material. The court found no Confrontation Clause violation regarding the expert’s testimony, and any error in admitting certain hearsay during punishment was harmless beyond a reasonable doubt. The court also determined that the prison violence testimony was admissible, and that the constitutional challenge to the jury instruction statute was not preserved for appeal. The court affirmed the conviction and sentence of death. View "LAWYER v. STATE OF TEXAS" on Justia Law