Justia Constitutional Law Opinion Summaries

A woman reported being sexually assaulted by a man with whom she had socialized during an evening out. She alleged that the man engaged in acts that constituted sexual assault and attempted sexual assault in the second degree, including penetration, and later reported significant emotional distress and physical harm. The man was indicted on several felony charges, but through plea negotiations, he agreed to plead no contest to a misdemeanor charge of sexual assault in the fourth degree, specifically for exposing his genitals in a manner likely to alarm or cause fear, in exchange for dismissal of the more serious charges.The Circuit Court of the Third Circuit accepted the no contest plea but denied the defendant’s motion to defer acceptance of the plea (DANC), which would have allowed him to avoid a criminal conviction if he complied with certain conditions. The court sentenced him to probation, emphasizing the impact on the victim rather than considering allegations of penetration or lack of remorse. The defendant appealed, arguing that the court improperly considered dismissed charges and his alleged lack of remorse. The Intermediate Court of Appeals affirmed, finding the trial court acted within its discretion and did not improperly rely on the dismissed charges or lack of remorse.The Supreme Court of the State of Hawai‘i affirmed both the circuit court’s judgment and the Intermediate Court of Appeals’ judgment. The court held that trial courts may not consider dismissed charges at sentencing, even if a plea agreement purports to allow it, as this violates constitutional rights. The court also prospectively held that lack of remorse cannot be used against defendants who plead no contest, due to their limited right against self-incrimination, establishing a new rule applicable to future cases. View "State v. Gaeta" on Justia Law

A Florida Highway Patrol officer stopped Richard Rhodes in March 1984 while he was driving a car registered to Karen Nieradka. Rhodes was arrested for driving without a valid license and held in the Citrus County Jail. Weeks later, Nieradka’s decomposed body was discovered in construction debris in St. Petersburg, with the medical examiner determining manual strangulation as the cause of death. Detectives interviewed Rhodes, who gave inconsistent statements but always denied killing Nieradka. After further investigation, Rhodes was arrested for her murder. At trial, several jailhouse informants testified that Rhodes confessed to the killing; Rhodes was convicted of first-degree murder and sentenced to death.On direct appeal, the Supreme Court of Florida affirmed the conviction but remanded for resentencing, which again resulted in a death sentence and was affirmed. Rhodes later filed multiple postconviction motions. In the most recent proceeding, he filed a successive motion under Florida Rule of Criminal Procedure 3.851, submitting affidavits from jailhouse witnesses who recanted or claimed their trial testimony had been elicited or coached by the State in exchange for leniency or other benefits. At an evidentiary hearing, these witnesses testified, but their accounts were contradicted by State witnesses and records. The postconviction court found Rhodes’s witnesses not credible and denied all relief.The Supreme Court of Florida reviewed the denial of postconviction relief, applying deference to the lower court’s credibility findings and reviewing legal conclusions de novo. The court held that the postconviction court’s findings regarding witness credibility were supported by competent, substantial evidence. Rhodes failed to establish a violation under Brady v. Maryland, Giglio v. United States, or Massiah v. United States, and the affidavits did not constitute newly discovered evidence warranting a new trial. The Supreme Court of Florida affirmed the denial of Rhodes’s successive motion for postconviction relief. View "Rhodes v. State of Florida" on Justia Law

Landowners in Florida who own property adjacent to a former rail corridor challenged the federal government’s issuance of a Notice of Interim Trail Use (“NITU”) under the National Trails System Act Amendments of 1983. This NITU allowed the rail corridor to be converted to a recreational trail rather than being abandoned completely. The landowners asserted that when the NITU was issued, it blocked their reversionary interests from taking effect, amounting to an uncompensated taking under the Fifth Amendment. The crux of the dispute centered on whether the railroad’s original property interests, acquired through various deeds and a condemnation judgment, were fee simple estates or merely easements.The United States Court of Federal Claims reviewed the evidence, including the deeds and the condemnation judgment, and determined that the language of each deed unambiguously conveyed a fee simple interest to the railroad. For the condemnation judgment, the court found the language ambiguous but, after consulting extrinsic evidence from the condemnation proceeding, also concluded it conveyed fee simple title. On this basis, the Claims Court held that no reversionary interest remained with the landowners, and thus no taking had occurred. The court granted summary judgment for the government.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the Claims Court’s summary judgment de novo. It agreed with the lower court’s interpretation of Florida law, finding that the relevant deeds and condemnation judgment conveyed fee simple title to the railroad. The court explained that, where the language of a deed is unambiguous, it must be enforced as written, and extrinsic evidence is only considered if ambiguity exists. The Federal Circuit affirmed the Claims Court’s judgment, holding that the landowners did not retain a reversionary interest and that the issuance of the NITU did not constitute a compensable taking. View "BARRON v. US " on Justia Law

Police in Seabrook, New Hampshire, were investigating reports of drug sales at a particular apartment complex. They received multiple tips, including one specifically naming a red Chevrolet Cruze and a silver Honda Civic, with license plate numbers, as being involved in these activities. The Cruze was registered to a woman living in the investigated complex, and she had previously been identified in reports as a suspected drug dealer. On June 2, 2023, an officer observed the Cruze with two occupants—a woman presumed to be the registered owner and a male passenger. The officer followed the vehicle from Seabrook to an apartment complex in Methuen, Massachusetts, known to be connected to drug activity. After about ten minutes at that location, the Cruze left, made a brief stop at a store parking lot, and then returned to Seabrook. The officer observed no traffic violations but did note "excessive blinker usage" and requested another officer to conduct a stop based on reasonable suspicion of drug possession.The defendant, identified as the male driver after a seat change, was found to be a certified habitual offender and admitted to having purchased fentanyl, which was located on the female passenger. He was charged with operating after certification as a habitual offender. He moved to suppress evidence from the stop, arguing lack of reasonable suspicion. The Rockingham County Superior Court concluded the officer’s observations and prior tips did not establish reasonable suspicion and granted the motion to suppress.The Supreme Court of New Hampshire reviewed the case de novo. It held that, viewing the totality of the circumstances—including prior reliable tips, the known drug-related activity at both apartment complexes, and the officer’s observations—the officer had reasonable suspicion to justify the investigatory stop. The court reversed the suppression order and remanded the case for further proceedings. View "State v. Hefferon" on Justia Law

A group of individuals, businesses, and an advocacy organization challenged the constitutionality of two provisions of the Federal Switchblade Act (FSA), which restricts the introduction, manufacture, transportation, distribution, sale, and possession of switchblade knives. The plaintiffs argued that these restrictions violate their rights under the Second Amendment. Some plaintiffs are individuals who wish to purchase, carry, or sell switchblade knives, while others are businesses that would sell such knives but refrain from doing so due to the FSA’s provisions.The United States District Court for the Northern District of Texas dismissed the plaintiffs’ challenge to the provision regulating possession, sale, and manufacture of switchblades in certain federal jurisdictions (15 U.S.C. § 1243) for lack of standing, finding no substantial threat of enforcement. It allowed standing for the challenge to the provision targeting interstate commerce in switchblades (15 U.S.C. § 1242) but ruled that this section did not violate the Second Amendment, reasoning that it was not a de facto ban on possession since switchblades remained available through intrastate commerce. The plaintiffs appealed the dismissal of their claims.The United States Court of Appeals for the Fifth Circuit held that plaintiffs had standing to challenge both provisions. Applying the framework from New York State Rifle & Pistol Association, Inc. v. Bruen, the Fifth Circuit determined that switchblades are “arms” under the Second Amendment and that § 1242 burdens constitutionally protected conduct. The court found the government failed to show that the regulation was consistent with the historical tradition of arms regulation, particularly regarding the manner in which it restricted switchblade knives. Therefore, the Fifth Circuit reversed the district court’s dismissal of the § 1242 claim. However, it affirmed dismissal of the § 1243 claim, concluding that the plaintiffs had not met the demanding standard required for a facial challenge to that provision. The case was remanded for further proceedings. View "Knife Rights v. Blanche" on Justia Law

A noncitizen from Iran, who was granted asylum in the United States as a child, faced removal proceedings after a drug conviction. In 2002, an immigration judge deferred his removal under the Convention Against Torture, and he was released on supervision, consistently complying with all terms for over 20 years. After relocating from California to Kansas with approval from immigration authorities, he was unexpectedly detained by ICE officers in June 2025, despite no alleged violations of his release terms. He was subsequently notified that his release was revoked due to a supposed new possibility of removal to a third country, yet was not given the required informal interview to contest this revocation.The United States District Court for the District of Kansas denied his initial habeas petition challenging the legality of his detention, as well as his request for a preliminary injunction to stop his transfer out of Kansas. The court suggested he could file a new habeas petition if detained for more than six months. After over eight months in detention, the petitioner filed a second habeas petition, which the district court granted, leading to his release. The government then moved to dismiss his appeal as moot.The United States Court of Appeals for the Tenth Circuit determined the appeal was not moot, applying the exception for wrongs capable of repetition yet evading review. On the merits, the court held that the district court misapplied the applicable legal standards. It concluded that the government violated its own regulations by failing to promptly provide the petitioner with an informal interview upon revocation of his release, a due process violation that was per se prejudicial. The court also found error in the district court's application of the six-month presumptive reasonableness standard for detention under Zadvydas v. Davis, ruling it did not reset with each re-detention. The Tenth Circuit reversed and remanded for further proceedings. View "Abedi v. Carter" on Justia Law

A police officer stopped a car after it ran a red light and found three occupants, all under the age of twenty-one. There was marijuana in the car, and none of the occupants was wearing a seat belt. When asked if anyone had a weapon, the defendant, seated in the front passenger seat, did not respond. The officer asked him to exit the car, at which point the defendant pushed the officer and fled, discarding a loaded handgun during the pursuit. The defendant was charged with assault and battery on a police officer and unlawful possession of a firearm without a license.The charges were brought in the Dorchester Division of the Boston Municipal Court Department. A jury found the defendant guilty on both counts. The defendant appealed his convictions, raising no challenge to the assault and battery conviction. The Supreme Judicial Court of Massachusetts transferred the appeal from the Appeals Court on its own initiative to address the defendant's challenge to his conviction for unlawful possession of a firearm without a license. Specifically, the defendant argued that the statutory minimum age requirement of twenty-one for obtaining a license to carry a firearm violated his Second Amendment rights, both facially and as applied to him, even though he had never applied for a license and was only twenty years old at the time of the offense.The Supreme Judicial Court of Massachusetts held that while the defendant lacked standing to bring an as-applied challenge because he had not applied for a license, he did have standing to bring a facial challenge. The court found that the Commonwealth’s licensing age restriction—requiring individuals to be at least twenty-one years old to obtain a license to carry a firearm—was consistent with the nation’s historical tradition of firearm regulation and did not violate the Second Amendment. The court affirmed the defendant’s convictions. View "Commonwealth v. Thomson" on Justia Law

Two victims were robbed at gunpoint and had their personal items and vehicle stolen by two suspects, one of whom drove away in the victims’ car while the other fled in a different vehicle. Police responded shortly after, locating the victim’s vehicle and monitoring the suspect’s vehicle at an address associated with one of the suspects, Marcos Andres Andrade. During the investigation, officers obtained cell site location information (CSLI) from Andrade’s phone carrier without a warrant by submitting an emergency disclosure request. This data assisted in acquiring search and arrest warrants, leading to Andrade’s arrest and recovery of some stolen items.The Santa Clara County Superior Court reviewed Andrade’s motion to suppress evidence derived from the warrantless CSLI request. The trial court denied the motion, finding exigent circumstances justified the search because the suspects were outstanding, armed, and there was potential for destruction of evidence or public danger. Andrade subsequently entered a no contest plea to second degree robbery and admitted a prior strike, receiving a four-year sentence. He appealed, arguing the exigent circumstances exception did not apply.The California Court of Appeal, Sixth Appellate District, considered whether the warrantless acquisition of both historical and real-time CSLI was a Fourth Amendment search, and if exigent circumstances justified the search. The court held that law enforcement’s request for historical and real-time CSLI constituted a Fourth Amendment search, requiring a warrant unless a valid exception applied. The court found that no exigent circumstances justified the warrantless search in this case and directed suppression of the CSLI data. The judgment was reversed and remanded for further proceedings, with instructions for the trial court to permit Andrade to withdraw his plea and to determine whether other evidence should be suppressed as fruits of the illegally obtained CSLI. View "People v. Andrade" on Justia Law

A man was killed in a motor vehicle accident while working for Rent-A-Center. His widow and the mother of his minor child sued the driver responsible for the accident and other related parties in the District Court of Bryan County, Oklahoma. The employer and its insurance carrier, having paid statutory workers' compensation death benefits to the widow and child, were allowed to intervene, seeking reimbursement for the death benefits from any recovery against the tortfeasor, as authorized by 85A O.S.2014, § 43.Plaintiffs moved for summary judgment, arguing that Section 43 was unconstitutional under Article 23, section 7 of the Oklahoma Constitution. The District Court granted summary judgment in favor of the plaintiffs, finding the statute unconstitutional as applied to death benefits. The employer and insurer appealed, and the Court of Civil Appeals, Division I, reversed the trial court’s order, holding Section 43 constitutional based on precedent and persuasive authority from other jurisdictions. Plaintiffs then petitioned for certiorari review by the Oklahoma Supreme Court, which was granted.The Supreme Court of the State of Oklahoma conducted a de novo review and held that 85A O.S.2014, § 43 is constitutional and does not violate Article 23, section 7 of the Oklahoma Constitution. The court clarified that Section 43 does not abrogate the right of action for wrongful death but rather apportions recovery between dependents and the employer or insurer who paid benefits. The opinion of the Court of Civil Appeals and the trial court’s order were both vacated, and the case was remanded for further proceedings consistent with the Supreme Court’s decision. View "ALEXANDER v. DUONG" on Justia Law

James Seabrook was arrested in May 2016 and spent more than seven and a half years in pre-trial detention. In April 2019, he was convicted of criminal possession of a weapon, but juries hung on more serious charges during subsequent retrials, and Seabrook was ultimately acquitted of those charges in December 2023. On January 31, 2024, Seabrook was sentenced to an indeterminate term of three and a half to seven years for the 2019 conviction. All parties recognized at sentencing that he had already served more time than the maximum sentence, yet he was remanded to Rikers Island, where he remained for seventeen days pending transfer from the New York City Department of Correction to the New York State Department of Corrections and Community Supervision, before his release.Seabrook filed suit in the United States District Court for the Southern District of New York, alleging violations of the Eighth and Fourteenth Amendments under 42 U.S.C. § 1983, naming the City of New York and various DOC officials. The district court dismissed his claims, holding that the complaint did not adequately allege deliberate indifference by any individual defendant, nor the existence of a City policy or practice causing his over-detention. The court also found no deprivation of a cognizable liberty interest or lack of procedural protections sufficient to sustain the due process claim.The United States Court of Appeals for the Second Circuit reviewed the case and held that Seabrook had plausibly alleged both an unconstitutional City policy or practice causing his excessive detention and deliberate indifference by DOC Captain Monastero. The Court further determined that Seabrook's procedural due process claim was sufficiently pleaded, given the absence of adequate processes to prevent over-detention. The Second Circuit vacated the district court's dismissal and remanded for further proceedings. View "Seabrook v. City of New York" on Justia Law