Justia Constitutional Law Opinion Summaries

The defendant was charged with continuous sexual abuse of his stepdaughter, following her disclosure of alleged abuse. He sought to introduce evidence that the accuser had engaged in an inappropriate online relationship with an adult male, including sexually explicit exchanges, arguing that she fabricated the allegations against him in retaliation for being disciplined after her mother discovered the relationship and terminated it. The defendant believed this evidence would support his theory that the accuser had a motive to lie.The District Court of Cass County, East Central Judicial District, held an in camera hearing under North Dakota Rule of Evidence 412 to consider the admissibility of the proposed evidence. The court conditionally denied the defendant’s motion, finding the evidence inadmissible under Rule 412(a) and determining that the defendant had not provided a sufficient offer of proof to invoke the constitutional exception under Rule 412(b)(1)(C). The court identified foundational deficiencies in the proffered evidence and allowed limited questioning about the fact and emotional impact of discipline, but not the explicit sexual content. The jury subsequently convicted the defendant of continuous sexual abuse, and the court entered judgment.On appeal to the Supreme Court of the State of North Dakota, the defendant argued that the exclusion of evidence violated his Sixth Amendment right to confrontation and constituted an abuse of discretion. The Supreme Court reviewed the constitutional claim de novo and the evidentiary ruling for abuse of discretion. It concluded that the District Court’s exclusion of the explicit evidence was neither arbitrary nor disproportionate, given the marginal probative value and the temporal gap between the events. The defendant’s confrontation rights were not violated because he was permitted to question the victim about discipline and emotional impact. The Supreme Court affirmed the criminal judgment. View "State v. Fox" on Justia Law

A Michigan State Police trooper stopped a vehicle for speeding, driven by the defendant, with a passenger under the age of 21. The trooper smelled marijuana but did not see any in plain view, nor did the occupants appear intoxicated or in possession. After both initially denied possessing marijuana, the passenger admitted to having a small amount (“shake”), which under Michigan law is a civil infraction for those under 21. The trooper then searched the vehicle and found a concealed firearm, which the defendant admitted was his.At the preliminary examination, the defendant argued that the vehicle search violated the Fourth Amendment. The 63rd District Court bound him over on the concealed weapon charge. In Kent Circuit Court, the defendant moved to suppress the firearm, but the motion was denied. The Michigan Court of Appeals, after remand from the Michigan Supreme Court, affirmed the circuit court’s denial, holding the search did not violate the Fourth Amendment.The Supreme Court of Michigan reviewed the case and held that the warrantless search was unlawful under the automobile exception to the Fourth Amendment’s warrant requirement. The Court found that the trooper had probable cause only to believe a civil infraction (possession of a small amount of marijuana by a minor) had occurred, not a crime. The Court clarified that probable cause to believe only a civil infraction has been committed does not justify a warrantless search under the automobile exception. The presence of marijuana odor, without more, does not establish probable cause to believe a criminal amount is present. The judgment of the Court of Appeals was reversed, and the case was remanded to the circuit court for further proceedings. View "People of Michigan v. Wilkins" on Justia Law

The defendant pleaded guilty to attempted unarmed robbery in Michigan in 2021, following a prior conviction for attempted rape in Illinois in 1983. As part of the 2022 sentence, the Berrien Circuit Court imposed lifetime registration as a Tier III sex offender under Michigan’s Sex Offenders Registration Act (SORA), based on the statute’s “recapture” provision. This provision requires individuals with pre-SORA sexual offense convictions to register if they are later convicted of any felony after July 1, 2011. The defendant had not committed another sexual offense in the intervening decades, and his recent conviction involved theft and a disputed assault in a Walmart store.After sentencing, the defendant challenged the registration requirement, arguing it was unconstitutional and not applicable because he was an out-of-state resident. The Berrien Circuit Court denied his motion to correct an invalid sentence. The Michigan Court of Appeals affirmed, finding the registration requirement constitutional but held that the defendant, as a nonresident, did not have to register unless he moved to or worked in Michigan.The Michigan Supreme Court reviewed the case, focusing on whether SORA’s recapture provision constituted cruel or unusual punishment when imposed for nonsexual offenses. The Court held that imposing SORA registration on individuals convicted of nonsexual offenses who had a pre-SORA sexual offense conviction was unconstitutional under the Michigan Constitution. The Court found the registration requirement grossly disproportionate, ineffective for rehabilitation, and harsher than penalties imposed for similar offenses elsewhere. The judgment of the Court of Appeals was reversed, and the case was remanded to the trial court to remove the registration requirement from the defendant’s sentence. View "People of Michigan v. Ellis" on Justia Law

Three defendants, who held leadership positions in a nationwide gang operating in Michigan and Chicago, were charged after a lengthy federal investigation uncovered extensive drug distribution, violent acts, and strict internal codes of silence within the organization. Law enforcement used confidential informants, monitored communications, conducted controlled purchases, and executed search warrants on social media and personal devices to gather evidence. The defendants were indicted for racketeering conspiracy, drug conspiracies, and related offenses. While many co-defendants pled guilty, these three proceeded to trial.The United States District Court for the Eastern District of Michigan conducted a month-long trial, after which a jury convicted all three defendants on most counts. One defendant was acquitted of certain drug trafficking and firearm possession charges but convicted on racketeering, drug conspiracy, and possession with intent to distribute marijuana. At sentencing, the district court imposed lengthy prison terms for each defendant. The defendants appealed, raising suppression issues concerning wiretap evidence, social media searches, and cell phone searches; Sixth Amendment claims regarding prison mail policies and cross-examination limitations; sufficiency-of-the-evidence challenges; and a sentencing dispute.The United States Court of Appeals for the Sixth Circuit reviewed the case. It rejected all suppression arguments except for a procedural sentencing challenge raised by one defendant, finding that the district court failed to adequately address his objection to a sentencing enhancement based on acquitted conduct. The Court affirmed the convictions for all three defendants and rejected their constitutional and evidentiary claims, holding that the evidence and trial procedures met legal standards. However, it vacated the sentence for the one defendant on procedural grounds and remanded for resentencing, while affirming all other aspects of the district court’s judgment. View "United States v. Fordham" on Justia Law

A man was convicted of first-degree murder in 2001 after fatally shooting another individual during a confrontation at a woman’s apartment. At trial, a paramedic testified that the victim suffered two gunshot wounds—one to the chest and another to the head with brain matter visible—supporting the prosecution’s theory of premeditation. However, the pathologist’s autopsy report, which was not introduced at trial, indicated there was only one gunshot wound, entering through the upper chest or neck and exiting from the upper back, with the victim’s head found intact.After his conviction was affirmed on direct appeal by the California Court of Appeal, Fourth Appellate District, the defendant unsuccessfully sought relief in the San Bernardino County Superior Court and then again in the Court of Appeal, arguing that his conviction rested on false evidence. He filed a similar petition in the California Supreme Court, which issued an order to show cause, directing the Court of Appeal to consider whether the prosecution had violated due process by allowing false testimony about the number and nature of gunshot wounds.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the pleadings and determined that the paramedic’s testimony was materially false and had been relied upon by the prosecution to argue for premeditation. The court found no procedural bar to the petition and concluded that the discrepancy between the trial testimony and the autopsy report required further factual development. The court granted the habeas corpus petition and remanded the matter to the superior court for an evidentiary hearing to determine the origins and impact of the false testimony, the prosecution’s knowledge of the autopsy report, and whether a new trial should be ordered. View "In re McCowen" on Justia Law

A property owner acquired a Chicago apartment building through foreclosure in February 2024, after the city’s ordinance requiring new owners of foreclosed rental properties to negotiate new 12-month leases with existing tenants and provide a $10,600 relocation fee to those who decline new leases went into effect. Upon acquisition, the owner notified more than 220 tenants of their rights, and at least five tenants declined to sign new leases, requesting the relocation assistance. The property owner filed suit against the City of Chicago, claiming that the ordinance’s relocation fee requirement constituted an unconstitutional taking under the Fifth Amendment.The United States District Court for the Northern District of Illinois reviewed the owner’s complaint, which sought to enjoin enforcement of the ordinance. The court dismissed the complaint, concluding that the ordinance did not violate the Constitution, and the owner declined to amend its pleading before appealing.The United States Court of Appeals for the Seventh Circuit considered whether the ordinance’s relocation assistance requirement amounted to a physical or regulatory taking, or imposed an unconstitutional condition. The court held that the ordinance, which regulates the landlord-tenant relationship and imposes financial obligations similar to permissible rent control schemes, is not a per se physical taking. Applying the Penn Central factors, the court found no regulatory taking, noting the property owner’s lack of allegations regarding economic infeasibility and that the acquisition occurred after the ordinance’s enactment. The court also determined that the unconstitutional conditions doctrine did not apply, as the ordinance directly mandates a fee rather than leveraging a permitting process. The Seventh Circuit affirmed the district court’s dismissal, holding that the ordinance does not violate the Takings Clause. View "BBLI Edison, LLC v. City of Chicago" on Justia Law

The case involved charges against a defendant for first-degree murder, second-degree murder, voluntary manslaughter, robbery with a dangerous weapon, and related firearms offenses after the shooting deaths of two individuals during a drug transaction. The defendant, who admitted to the shootings but claimed self-defense, was impeached at trial with a prior custodial statement in which he denied any involvement. The statement was made during a late-night, uncounseled custodial interrogation after the defendant was advised of his Miranda rights.At trial in the Circuit Court for Baltimore City, the defendant requested a jury instruction directing the jury to consider the voluntariness of his custodial statement before using it for impeachment. The trial court declined to give this instruction, finding there was no evidence suggesting the statement was involuntary. The jury acquitted the defendant of first- and second-degree murder but found him guilty of voluntary manslaughter, robbery, and several firearms offenses. He was sentenced to 70 years' imprisonment.The defendant appealed to the Appellate Court of Maryland, arguing he was entitled to the voluntariness instruction. The Appellate Court affirmed the conviction, holding that the instruction was not required since the statement was introduced only for impeachment, was exculpatory, and there was no “some evidence” of involuntariness.Upon further review, the Supreme Court of Maryland disagreed with the Appellate Court’s reasoning that the instruction was unnecessary because the statement was used for impeachment or was exculpatory. However, the Supreme Court determined the defendant failed to present “some evidence” that his statement was involuntary, as required to trigger the instruction. The Court also concluded that, even if it was error to deny the instruction, the error was harmless beyond a reasonable doubt given the nature of the evidence and the jury’s verdict. The Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Shuler v. State" on Justia Law

A theft victim sought restitution from the person who broke into her office and stole property. The offender pleaded guilty to attempted breaking and entering and petty theft. At sentencing, the trial court did not award restitution, despite a request from the victim and supporting documentation. The victim initially filed a timely direct appeal, arguing for restitution under Marsy’s Law, which provides victims certain rights, including restitution. However, while her appeal was pending, she voluntarily dismissed it. Several years later, after related proceedings—including a writ of mandamus directing the trial court to determine restitution—the victim attempted to file a delayed appeal challenging the lack of restitution.After the victim’s direct appeal was dismissed, she sought mandamus relief in the Eighth District Court of Appeals, which partially granted her request by directing the trial court to consider restitution. The trial court scheduled a restitution hearing, but the offender appealed, and the Eighth District vacated the order for a hearing, holding the victim had forfeited the right to challenge restitution by dismissing her earlier appeal. The Supreme Court of Ohio declined jurisdiction over the victim’s appeal from that decision. The victim then moved for leave to file a delayed appeal of the original sentencing order, but the Eighth District denied her request, citing Appellate Rule 5(A), which allows delayed appeals only for defendants, not victims.The Supreme Court of Ohio held that victims seeking to appeal a trial court’s denial of restitution are subject to the procedural requirements of Appellate Rule 4(A) and Appellate Rule 5(A). The court concluded that neither the Ohio nor United States Constitutions require courts to allow victims to file delayed appeals, and that Appellate Rule 5(A)’s limitation to criminal defendants is valid. The judgment of the Eighth District was affirmed, and the victim’s motion for leave to file a delayed appeal was denied. View "State v. Barnes" on Justia Law

A woman in Great Falls, Montana, made a frantic 9-1-1 call pleading for help because her former partner had locked her out of their residence, and had “our” baby inside. The call abruptly ended, and police responding to the scene were unable to reestablish contact. Officers spoke to a neighbor who referenced a disturbance, and then encountered loud, indiscernible screaming from the involved apartment. Upon identifying themselves and requesting entry, the occupant, Phillip Friscia, responded angrily, repeatedly opening and closing the door, sometimes holding the child, and stated he had the right to defend himself from people in his house. Officers, concerned for the safety of those inside, forcibly entered the residence, apprehended Friscia, and found the woman and child unharmed.The State charged Friscia with felony threatening an officer and misdemeanor destruction of a communication device. Friscia moved to suppress evidence, arguing the entry was unlawful and not justified by exigent circumstances, and challenged the constitutionality of the statute under which he was charged. The Eighth Judicial District Court, Cascade County, denied both motions, finding the police entry justified by exigent circumstances based on the totality of evidence and the statute constitutionally valid. Friscia entered an Alford plea, reserving his right to appeal these decisions.The Supreme Court of the State of Montana reviewed the appeal. It held that the District Court’s factual findings regarding exigent circumstances and probable cause were not clearly erroneous and properly supported the denial of the suppression motion. The Supreme Court further held that Montana’s statute, requiring a subjective mental state, was not facially unconstitutional or overbroad, and did not violate the First Amendment under Counterman v. Colorado. The Supreme Court affirmed the District Court’s rulings and Friscia’s conviction. View "State v. Friscia" on Justia Law

In this case, the owner of a Massachusetts gun store and the store itself challenged recent amendments to state law that prohibit the sale, transfer, or possession of certain "assault-style firearms" and related magazines. The plaintiffs argued that these provisions, enacted in 2024, violated their rights under the Second Amendment, the dormant Commerce Clause, and the Equal Protection Clause of the Fourteenth Amendment. They asserted that the law infringed on their ability to keep and bear arms, imposed unconstitutional burdens on interstate commerce by affecting out-of-state manufacturers and their own business, and discriminated against them compared to individuals and businesses in other states.The United States District Court for the District of Massachusetts granted the state defendants’ motion to dismiss for failure to state a claim. The district court concluded that the plaintiffs’ Second Amendment claim was foreclosed by the First Circuit’s earlier decision in Capen v. Campbell, which upheld a similar Massachusetts firearms ban. The court also found the plaintiffs’ dormant Commerce Clause and Equal Protection Clause claims inadequately pleaded, noting that the complaint did not plausibly allege discrimination against interstate commerce or that similarly situated persons were treated differently.The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that its prior decision in Capen v. Campbell controlled and that the challenged restrictions on assault-style firearms were consistent with the Nation’s historical tradition of firearm regulation and thus did not violate the Second Amendment. The court further held that the law did not discriminate against or impose an undue burden on interstate commerce, nor did it violate equal protection, as the right to make a living is not a fundamental right and the law had a rational basis. The district court’s judgment was affirmed. View "Recchia v. Campbell" on Justia Law