Justia Constitutional Law Opinion Summaries

K.W. agreed to buy a MacBook Pro laptop from a seller on the Letgo app, who was later identified as Mamadou Diaw. When K.W. met Diaw to complete the transaction, Diaw and an accomplice stole K.W.'s iPhone and money, assaulted him, and threatened him with a gun. Detective Michael Sturgill subpoenaed Letgo for information about the seller, obtaining an IP address, an email address, and a single location data point.The trial court granted Diaw's motion to suppress the information obtained from Letgo, finding that the police acquired it in violation of the Fourth Amendment. The Tenth District Court of Appeals reversed, holding that Diaw did not have a reasonable expectation of privacy in the location data because it was a single, voluntarily communicated data point that was historical in nature.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's judgment. The court held that a person generally has no expectation of privacy in information voluntarily shared with third parties. Therefore, the Fourth Amendment does not require law enforcement to obtain a search warrant before securing a single historical location data point from a third-party online-marketplace app. The case was remanded to the trial court for further proceedings consistent with this opinion. View "State v. Diaw" on Justia Law

The City of Dallas amended an ordinance regulating the short-term lending industry, which TitleMax of Texas, Inc. claimed severely harmed its business. TitleMax sought declaratory and injunctive relief, arguing the amendment was preempted by state law and violated its due course of law guarantee under the Texas Constitution. TitleMax requested a preliminary injunction to halt enforcement of the amendment until a trial on the merits, but the district court denied this request.The United States District Court for the Northern District of Texas reviewed the case and denied TitleMax’s motion for a preliminary injunction. The magistrate judge found that while TitleMax demonstrated potential irreparable harm, it did not show a substantial likelihood of success on the merits of its claims. The district court accepted this recommendation, leading TitleMax to appeal the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court’s decision. The appellate court concluded that TitleMax did not demonstrate a likelihood of success on its preemption and due course of law claims. The court found that the amended ordinance did not prohibit all Credit Services Organizations (CSOs) or Credit Access Businesses (CABs) from operating, but rather regulated their business models. Additionally, the court determined that TitleMax did not have a constitutionally protected interest in operating its business profitably under the due course of law guarantee. The court held that the ordinance was rationally related to a legitimate governmental interest in protecting low-income borrowers. Consequently, the appellate court affirmed the district court’s denial of the preliminary injunction. View "TitleMax of Texas v. City of Dallas" on Justia Law

Damon Victor Crist was convicted of first-degree kidnapping in Utah in 2006 and was required to register as a sex offender in Utah. In 2022, Crist began working in Idaho but did not register as a sex offender there. An informant tipped off the Idaho State Police (ISP), leading to Crist's arrest for failing to register. Crist argued that Idaho law did not permit the magistrate court to determine that his Utah conviction was substantially equivalent to Idaho’s second-degree kidnapping law, which would require him to register. He also claimed that the statutory scheme was void for vagueness.The magistrate court found probable cause to bind Crist over for trial, determining that his Utah conviction was substantially equivalent to an Idaho registrable offense. Crist filed a motion to dismiss in the district court, arguing that only the ISP’s Bureau of Criminal Identification could make the substantial equivalency determination and that he lacked proper notice of his duty to register. The district court denied his motion, concluding that the magistrate court had the authority to make the determination and that Crist had sufficient notice of his registration requirements.The Supreme Court of Idaho affirmed the district court's decision. The court held that a nonresident’s duty to register as a sex offender in Idaho is triggered by the fact of an out-of-state conviction that is substantially equivalent to an Idaho registrable offense and entry into Idaho for employment purposes. The court also concluded that the statutory and regulatory scheme provided fair notice to Crist and did not grant law enforcement unbridled discretion. Therefore, Crist's arguments were rejected, and the decision of the district court was affirmed. View "State v. Crist" on Justia Law

Dr. John Doe, a federal public servant with a security clearance, was convicted of two felonies in Ohio in the early 1990s. He received a pardon from the Ohio governor in 2009, and his felony convictions were sealed by an Ohio court. In 2022, Dr. Doe applied for a position at the Federal Deposit Insurance Corporation (FDIC), but his application was denied due to a statutory bar against hiring individuals with felony convictions. Dr. Doe then filed a lawsuit challenging the constitutionality of this hiring prohibition and sought to proceed under a pseudonym to avoid public association with his sealed convictions.The United States District Court for the District of Columbia denied Dr. Doe's motion to proceed under a pseudonym. The court acknowledged Dr. Doe's privacy concerns and the lack of unfairness to the government but concluded that the privacy interest in felony convictions does not warrant pseudonymity. The court emphasized the importance of transparency in judicial proceedings, especially in cases involving constitutional challenges against the government.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Dr. Doe's privacy interest in his sealed felony convictions was insufficient to overcome the presumption against pseudonymous litigation. The court highlighted the public's significant interest in open judicial proceedings, particularly when the case involves a constitutional challenge to a federal statute. The court found that the district court did not abuse its discretion in applying the relevant factors and denying Dr. Doe's motion to proceed under a pseudonym. View "Doe v. McKernan" on Justia Law

The case involves a challenge to the constitutionality of the State of New Hampshire's funding for public education. The plaintiffs, which include several school districts and individuals, argue that the amount of base adequacy aid provided under RSA 198:40-a, II(a) is insufficient to cover the cost of providing a constitutionally adequate education as defined by RSA 193-E:2-a. They seek a declaratory judgment and injunctive relief to increase the funding.The Superior Court (Ruoff, J.) ruled in favor of the plaintiffs, declaring RSA 198:40-a, II(a) unconstitutional on its face. The court found that the current funding level of $4,100 per pupil was significantly below the amount necessary to provide an adequate education. The court determined a conservative minimum threshold of $7,356.01 per pupil, which it found to be the minimum amount that base adequacy aid must exceed. The court also directed the State to immediately increase base adequacy aid payments to this threshold amount pending further legislative action.The State appealed to the Supreme Court of New Hampshire, arguing that the trial court erred in its findings and that the immediate payment directive violated the separation of powers doctrine. The State contended that the trial court should have considered the total funding provided under RSA 198:40-a, including differentiated aid, rather than focusing solely on base adequacy aid.The Supreme Court of New Hampshire affirmed the trial court's rulings on the admissibility of expert testimony, the declaration that RSA 198:40-a, II(a) is facially unconstitutional, and the determination of a conservative minimum threshold for base adequacy aid. However, the court reversed the trial court's immediate payment directive, finding that it failed to properly weigh separation of powers concerns and the history of school funding litigation. The court emphasized the need for the legislative and executive branches to act expeditiously to remedy the constitutional deficiency in funding public education. View "Contoocook Valley Sch. Dist. v. State" on Justia Law

Deonte Kitchens was convicted of malice murder and other crimes related to the shooting death of Alveno Culver. Kitchens was indicted in November 2015 and tried alone in September 2016, where the jury found him guilty on all counts. He was sentenced to life in prison without parole for malice murder, along with additional consecutive and concurrent sentences for other charges. Kitchens filed a motion for a new trial, claiming, among other things, that his constitutional right to a speedy trial was violated.The trial court denied Kitchens's motion for a new trial, rejecting his speedy-trial claim. Kitchens appealed, arguing that the trial court made a clearly erroneous finding about a material fact and misapplied the law in several significant ways. The trial court found that the delay was due to the complexity of the case and the State's ongoing investigation, and it did not weigh this factor heavily against the State. The court also found that Kitchens never invoked his right to a speedy trial, which was a clearly erroneous finding since Kitchens had filed a constitutional speedy trial demand in August 2014.The Supreme Court of Georgia reviewed the case and found that the trial court made several errors in its analysis. The trial court failed to calculate the length of the delay correctly, conflated the analyses of presumptive prejudice and the length of the delay, and did not consider whether the delay was uncommonly long. The Supreme Court vacated the trial court's order denying Kitchens's motion for a new trial and remanded the case for the trial court to properly address the speedy-trial claim, considering the correct facts and legal analysis. View "KITCHENS v. THE STATE" on Justia Law

Steven Alford Jacobs was convicted of malice murder and other crimes related to the shooting death of Curtis Pitts. The incident occurred on September 21, 2018, and Jacobs was indicted on multiple charges, including malice murder, felony murder, aggravated assault, armed robbery, and possession of a firearm during the commission of a felony. The jury found Jacobs guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, among other sentences for the additional charges.Jacobs filed a motion for a new trial, which was denied by the trial court. He appealed, arguing that his constitutional right to be present during a critical phase of the trial was violated when the jury viewed a vehicle connected to the charges without him being present. During the trial, the jury was allowed to view the van involved in the case, and Jacobs's defense objected, questioning whether the van was in the same condition as it was in 2018. The trial court allowed the viewing, and Jacobs's attorneys testified that they had discussed the right to be present with Jacobs, who chose not to attend the viewing.The Supreme Court of Georgia reviewed the case and affirmed the trial court's decision. The court held that even if Jacobs had a right to be present during the jury's viewing of the van, the evidence supported the trial court's conclusion that Jacobs waived that right. The court found that Jacobs's attorneys had informed him of his right to be present, and Jacobs had explicitly declined to attend the viewing. Therefore, the trial court's finding that Jacobs waived his right to be present was not clearly erroneous, and Jacobs was not entitled to a new trial based on his absence during the jury's viewing of the van. View "JACOBS v. THE STATE" on Justia Law

Sidney Kimble was convicted of two drug-trafficking felonies. After serving his sentences, he was found in possession of a handgun and charged under 18 U.S.C. § 922(g)(1), which prohibits felons from possessing firearms. Kimble argued that this lifelong prohibition violated his Second Amendment rights.The United States District Court for the Western District of Texas denied Kimble's motion to dismiss the indictment, stating that the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen did not overrule Fifth Circuit precedent upholding the constitutionality of § 922(g)(1). Kimble then pleaded guilty but retained the right to appeal the constitutionality of the statute.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that § 922(g)(1) is constitutional as applied to Kimble. The court reasoned that the Second Amendment allows Congress to disarm individuals deemed dangerous, and drug trafficking is inherently dangerous. The court found that historical and legal precedents support the disarmament of individuals involved in drug trafficking due to the intrinsic violence associated with the drug trade. Therefore, the court affirmed Kimble's conviction under § 922(g)(1). View "USA v. Kimble" on Justia Law

Dimaryn Ware was indicted on multiple firearms-related charges. He moved to dismiss the indictment, arguing that the statutes violated the Second Amendment both on their face and as applied to him. The district court denied his motion, and Ware pled guilty while preserving his right to appeal the denial. He now appeals the denial and several sentencing decisions.The district court, the United States District Court for the Southern District of Iowa, denied Ware's motion to dismiss the indictment. Ware pled guilty to two counts, and the remaining counts were dismissed on the government's motion. At sentencing, the court applied the Base Offense Level from the United States Sentencing Guideline (USSG) § 2K2.1(a)(3), concluding that the offense involved a firearm capable of accepting a large capacity magazine. The court calculated a Guidelines range of 84 to 105 months but varied upward to 144 months' imprisonment, ordering the sentence to run concurrently with a state sentence for a related shooting but consecutively to other state sentences for unrelated offenses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Ware's arguments against the constitutionality of 18 U.S.C. § 922(g)(1) and § 932(b)(1) were foreclosed by precedent, specifically citing United States v. Jackson and United States v. Sharkey. The court also held that the district court did not err in considering conduct underlying an acquitted charge when determining Ware's sentence, as permitted by precedent. Additionally, the court found no clear error in the district court's application of USSG § 2K2.1(a)(3) based on the evidence of the firearm's capability to accept a large capacity magazine. Finally, the court upheld the district court's decision to impose Ware's federal sentence consecutively to his unrelated state sentences and to not reduce his federal sentence based on time served for those unrelated state sentences.The judgment of the district court was affirmed. View "United States v. Ware" on Justia Law

Officer Alexandra Weaver took a fourteen-year-old child, J.M., from her home during a child welfare investigation. The child and her parents sued, claiming Weaver searched the apartment and seized the child in violation of their Fourth and Fourteenth Amendment rights. Weaver appealed the district court’s order denying her motion for summary judgment on the basis of qualified immunity.The United States District Court for the Western District of Texas found that Weaver was not entitled to qualified immunity and denied summary judgment on three claims: the Fourth Amendment claim for unreasonable search of the apartment, J.M.’s Fourth Amendment claim for unreasonable seizure, and the Fourteenth Amendment claim for procedural due process. Weaver then appealed to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit reviewed the case and affirmed the district court’s decision. The court held that the warrantless search of the apartment was not justified by exigent circumstances, and no other exception applied. The court also found that J.M. was seized without a court order, parental consent, or exigent circumstances, violating her Fourth Amendment rights. Additionally, the court held that the procedural due process claim was valid because J.M. was seized without a court order or exigent circumstances, and this violation was clearly established by precedent.The Fifth Circuit concluded that Weaver was not entitled to qualified immunity on any of the claims and affirmed the district court’s denial of summary judgment. View "McMurry v. Weaver" on Justia Law