Justia Constitutional Law Opinion Summaries

The plaintiffs in this case are trustees who own a property in Kīhei, Maui, which they use as a vacation home for personal use. In 2021, Maui County reclassified their property as a “short-term rental” based solely on zoning, not actual use, resulting in a higher property tax rate. The plaintiffs paid the assessed taxes but did not utilize the administrative appeals process available through the Maui County Board of Review. Instead, they filed a class action in the Circuit Court of the Second Circuit, seeking a refund and alleging that the County’s collection of the higher taxes was unconstitutional, violated due process, and resulted in unjust enrichment.The Circuit Court of the Second Circuit granted the County’s motion to dismiss, finding it lacked subject matter jurisdiction. The court determined that under Hawai‘i Revised Statutes chapter 232 and Maui County Code chapter 3.48, the proper procedure for contesting real property tax assessments—including constitutional challenges—requires first appealing to the County Board of Review and, if necessary, then to the Tax Appeal Court. Because the plaintiffs bypassed these required steps and missed the statutory deadline to appeal, the court dismissed the case with prejudice.On appeal, the Supreme Court of the State of Hawai‘i affirmed the circuit court’s dismissal. The Supreme Court held that the Tax Appeal Court has exclusive jurisdiction over appeals regarding real property tax assessments, including those raising constitutional issues, and found that the plaintiffs’ claims were time-barred due to their failure to timely pursue the established administrative remedies. As a result, the Supreme Court affirmed the circuit court’s judgment dismissing the plaintiffs’ claims for lack of subject matter jurisdiction. View "Piezko v. County of Maui" on Justia Law

Police officers stopped a motorist for driving without a front license plate and failing to use a turn signal in a high-crime area of Denver known for gang activity. The driver, Antoan Raban, was identified as a member of the Tre Tre Crips gang and was driving in rival Bloods gang territory. During the stop, a known Crips gang member, Deshay Armstrong, parked nearby, watched the officers, and called Raban’s phone. Raban did not have identification, and a records check revealed violent and weapons-related convictions. Officers called for backup, removed Raban from his car to fingerprint him, frisked him, and found no weapons. While preparing to take fingerprints, an officer conducted a protective sweep of Raban’s car and discovered a loaded pistol and ammunition.The United States District Court for the District of Colorado denied Raban’s motion to suppress, finding that under the totality of the circumstances—including the high-crime area, Raban’s gang affiliation, Armstrong’s presence, and Raban’s ankle monitor—the officers had reasonable suspicion that Raban was dangerous. Initially, the district court questioned whether the officers genuinely intended to return Raban to his car but later reconsidered and found it was objectively reasonable for the officers to believe Raban might be released with a citation and allowed to reenter his vehicle.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s decision de novo. It held that the officers had reasonable suspicion that Raban was presently dangerous and that he might regain access to a weapon in his car if released. The appellate court affirmed the district court’s denial of the suppression motion and upheld Raban’s conviction, holding that the protective sweep was lawful under the Fourth Amendment given the circumstances. View "United States v. Raban" on Justia Law

A former assistant principal at a middle school in the Central Valley School District posted a Facebook comment about the Democratic National Convention that included epithets, slurs, and violent language. The post, though made on his private account and shared with Facebook friends, was seen by other school district employees and quickly forwarded to administrators. Within days, the assistant principal was placed on paid administrative leave, prohibited from contacting district staff or students, and ultimately transferred to a non-administrative teaching position. The school district’s investigation revealed additional concerns about derogatory comments he had made at work. The district offered him a voluntary transfer if he signed a release of claims, which he rejected, leading to further administrative proceedings and the final transfer decision.Previously, the United States District Court for the Eastern District of Washington reviewed the case. The court initially denied summary judgment to individual administrators on qualified immunity, a decision affirmed by the Ninth Circuit on interlocutory appeal. After further discovery and cross-motions for summary judgment, the district court granted summary judgment to the school district and the individual administrators. The court found the plaintiff had established a prima facie First Amendment retaliation claim but held that the district’s interests outweighed the plaintiff’s under the Pickering balancing test. Qualified immunity was also found to apply to the individual defendants.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s rulings. It held that while the plaintiff’s Facebook post was private speech on a matter of public concern and he made a prima facie case for retaliation, the school district showed a reasonable prediction of disruption and its interest in maintaining a safe and inclusive environment outweighed the plaintiff’s First Amendment interests. The court also affirmed qualified immunity for the individual administrators. View "Thompson v. Central Valley School District No 365" on Justia Law

The defendant was convicted in 2003 of voluntary manslaughter, robbery, possession of a firearm, and received various sentence enhancements, including a prior strike, a firearm enhancement, and seven prior prison term enhancements, resulting in a sentence of 42 years and four months. Two restitution fines of $5,000 each were also imposed. In 2023, following legislative changes, the Department of Corrections and Rehabilitation identified the defendant as eligible for resentencing under Penal Code section 1172.75, which invalidated certain prior prison term enhancements. The defendant sought to have those enhancements stricken and also requested further modifications, including striking the prior strike and firearm enhancement, and imposing a lesser term for the manslaughter conviction.At the Superior Court of Sacramento County, during the resentencing hearing held in October 2024, the court struck the seven prior prison term enhancements, reducing the sentence to 35 years and four months. However, the court declined to strike the prior strike and firearm enhancement, and reimposed the original restitution fines and victim restitution. The updated abstract of judgment noted the restitution fines were “stayed.” The defendant appealed, raising constitutional and statutory challenges to the reimposition of the upper term, the denial of his request to strike the firearm enhancement under section 1385, and the continued imposition of the restitution fine.The California Court of Appeal, Third Appellate District, held that the trial court did not err by reimposing the upper term for voluntary manslaughter without requiring new findings of aggravating circumstances under amended section 1170, subdivision (b), because section 1172.75, subdivision (d)(4) exempts previously imposed upper terms from these requirements. The court also found no abuse of discretion or statutory error in declining to dismiss the firearm enhancement, as no applicable mitigating factors were established. However, the court concluded that the restitution fine originally imposed in 2003 must be vacated under section 1465.9, as more than ten years had elapsed. The judgment was affirmed as modified to vacate the restitution fine. View "P. v. Salstrom" on Justia Law

One defendant in this case was a high-ranking member of the Varrio Fallbrook Locos gang and the Mexican Mafia, while a codefendant acted as a secretary within the gang structure. In December 2013, the defendant participated in a meeting regarding methamphetamine sales, which resulted in the violent assault of another gang member, A.C., after accusations of unpaid debts. Following the assault, the defendant attempted to prevent A.C. from testifying and conspired to arrange the murder of another gang affiliate. The defendant was convicted by a jury of multiple offenses, including assault with a deadly weapon, conspiracy to commit murder, and conspiracy to dissuade a witness, among others. The trial court imposed a lengthy prison sentence and ordered the defendant to pay various fines and ancillary costs, despite defense counsel’s request to consider the defendant’s inability to pay.The Court of Appeal for the Fourth Appellate District, Division One, reviewed the monetary orders. It held that the trial court should have considered the defendant’s ability to pay before imposing ancillary costs but rejected the argument that an ability-to-pay finding was required for punitive fines. The appellate court clarified that fines could still be challenged under the excessive fines clauses of the federal and state constitutions and remanded the case for resentencing and further proceedings regarding the fines and costs.The Supreme Court of California reviewed the case to resolve inconsistent approaches among lower courts concerning court-ordered financial obligations. The Court held that challenges to the amount of criminal fines must be reviewed under the excessive fines clauses of the United States and California Constitutions. Separately, the Court held that, upon request, a sentencing court must consider a defendant’s inability to pay before imposing court operations and facilities assessments, as failing to do so violates equal protection. The judgment was reversed in part and remanded for further proceedings consistent with these holdings. View "P. v. Kopp" on Justia Law

Christopher Thigpen applied for and received unemployment benefits from the Minnesota Department of Employment and Economic Development (DEED) for 104 weeks spanning March 2020 to March 2022. During this period, Thigpen was employed as a personal care assistant, earning weekly wages, but reported to DEED each week that he had not worked or received other income. This misrepresentation led to Thigpen receiving overpayments totaling $39,605 in standard and pandemic unemployment benefits. In April 2022, DEED reviewed his account, confirmed his employment during the relevant period, and determined that he had obtained the overpayments due to misrepresentation. As a result, DEED assessed a penalty of 40 percent of the overpaid amount, imposed 1 percent monthly interest, and barred Thigpen from receiving any future unemployment benefits until repayment, subject to a statutory ten-year cancellation period.Thigpen appealed the determination before an unemployment law judge, arguing that he did not intend to defraud DEED and misunderstood the forms. After multiple evidentiary hearings, the unemployment law judge found Thigpen’s explanations not credible, upheld the finding of misrepresentation, and applied the statutory penalty, interest, and benefit ineligibility.Thigpen requested certiorari review from the Minnesota Court of Appeals, challenging the sufficiency of evidence, burden of proof, denial of due process, and constitutionality of the penalties under the Excessive Fines Clauses of the U.S. and Minnesota Constitutions. The Court of Appeals rejected all arguments, specifically finding the penalties proportionate and comparable to those for similar offenses in Minnesota and other states.On further appeal, the Minnesota Supreme Court affirmed the Court of Appeals, holding that the penalty, interest, and benefit ineligibility for unemployment benefit misrepresentation do not violate the Excessive Fines Clauses, as they are not grossly disproportionate to the gravity of the offense and are consistent with penalties in Minnesota and other jurisdictions. View "Thigpen vs. Best Home Care LLC" on Justia Law

A police officer stopped a vehicle driven by the appellant for traffic violations and discovered that his driver’s license had been canceled. During the stop, the officer smelled a strong odor of marijuana coming from the vehicle. Citing only the odor as justification, the officer conducted a warrantless search of the car. During the search, the officer found ammunition in a locked safe in the backseat. The appellant was prohibited by law from possessing ammunition and was subsequently charged with that offense, as well as with driving after cancellation.The trial court, the Scott County District Court, granted the appellant’s motion to suppress the ammunition, ruling that the search violated his constitutional rights. This ruling came after the Minnesota Supreme Court’s decision in State v. Torgerson, which held that the smell of marijuana alone is not sufficient to establish probable cause for a warrantless vehicle search. The State appealed. The Minnesota Court of Appeals reversed the district court’s decision, holding that the good-faith exception to the exclusionary rule applied because, at the time of the search, officers could reasonably have relied on existing appellate precedent that arguably permitted such searches.The Supreme Court of Minnesota, reviewing the case, rejected the application of the good-faith exception. The court held that there was no binding appellate precedent specifically authorizing warrantless vehicle searches based solely on the smell of marijuana at the time of the search, and previous Minnesota Supreme Court decisions had emphasized the need to evaluate the totality of the circumstances. The court concluded that the good-faith exception did not apply, reversed the decision of the Court of Appeals, and remanded the case to the district court for further proceedings. View "State of Minnesota vs. Douglas" on Justia Law

VVF Intervest, L.L.C., a contract manufacturer based in Kansas, produced bar soap for High Ridge Brands (HRB), the brand owner. HRB, an "asset light" entity, directed VVF to ship the soap from Kansas to a third-party distribution center in Columbus, Ohio. Subsequently, HRB resold most of the product to national retailers, and the soap was shipped out of Ohio to various locations. Between 2010 and 2014, VVF paid Ohio’s commercial-activity tax (CAT) on its gross receipts from these sales to HRB.After making these payments, VVF sought a refund from the Ohio tax commissioner, arguing that its gross receipts should not be sitused to Ohio since the products left the state soon after arrival. The tax commissioner denied the refund, emphasizing that the relevant sale for tax purposes was VVF’s sale to HRB, not HRB’s subsequent sales to retailers. VVF appealed to the Ohio Board of Tax Appeals, which held that the Columbus distribution center was merely an interim stop and that the gross receipts should not be sitused to Ohio. The board also found that VVF had not adequately preserved an alternative statutory argument regarding services and declined to rule on constitutional claims.The Supreme Court of Ohio reviewed the appeal and reversed the Board of Tax Appeals’ decision. The court held that under R.C. 5751.033(E), VVF’s gross receipts from sales to HRB are properly sitused to Ohio because HRB, as the purchaser, received the goods in Ohio. The court dismissed VVF’s alternative statutory argument for lack of jurisdiction and rejected VVF’s constitutional challenges under the Due Process, Commerce, and Equal Protection Clauses. Thus, VVF is not entitled to a refund of the CAT paid on these transactions. View "VVF Intervest, L.L.C. v. Harris" on Justia Law

The defendant was involved in a fatal shooting during a drug transaction in Hartford, Connecticut. He testified at trial that he acted in self-defense, claiming the victim drew a gun on him during a dispute. However, other witnesses contradicted this account, and no gun was found on or near the victim. After the shooting, the defendant fled the scene and did not report the incident to the police. He was later arrested and charged with murder.The case was tried before the Superior Court in the judicial district of Hartford. At trial, the defendant testified in his own defense. The prosecutor, with approval from the trial court, cross-examined the defendant regarding his failure to report to police that he had acted in self-defense prior to his arrest. The defense objected, arguing that the questioning infringed upon the defendant’s right to remain silent, but the trial court overruled the objection, reasoning that, by testifying, the defendant waived his Fifth Amendment right regarding silence and that his failure to report was inconsistent with a claim of self-defense. The jury found the defendant guilty of murder, and he was sentenced to fifty years in prison.On direct appeal to the Supreme Court of Connecticut, the defendant argued that the trial court committed plain error by allowing the prosecutor to cross-examine him about his prearrest silence. The Supreme Court of Connecticut held that the trial court did not commit plain error because established case law allows impeachment using a defendant’s prearrest, pre-Miranda silence, particularly when the defendant testifies and claims self-defense. The Court concluded that the circumstances did not present an obvious or egregious error requiring reversal. The judgment of conviction was affirmed. View "State v. Thorpe" on Justia Law

Parker Noland operated a construction debris removal business in Flathead County, Montana, but was ordered by the Montana Public Service Commission to cease operations due to lacking a required Class D motor carrier certificate. Noland formed PBN LLC and applied for the certificate, but withdrew his application after finding the administrative process—including requests for sensitive financial information by competitors—too burdensome. He then limited his business to activities not requiring the certificate. Subsequently, Noland filed suit in the Eleventh Judicial District Court of Flathead County, seeking a declaratory judgment that two provisions of the Montana Motor Carrier law, known as the public convenience and necessity (PCN) provisions, were unconstitutional under both the Montana and United States Constitutions.The District Court granted summary judgment in favor of the State of Montana and Evergreen Disposal, Inc., which had intervened. The court held that Noland lacked standing to bring an as-applied constitutional challenge, reasoning he sought to vindicate only a future injury and had not shown how the statutes would be unconstitutionally applied to him. However, the court found Noland had standing to bring a facial challenge, but ruled against him, concluding the provisions were not facially unconstitutional because some applicants had previously received Class D certificates.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s rulings de novo. The Montana Supreme Court affirmed the District Court’s decision that Noland lacked standing for an as-applied challenge, holding that he failed to demonstrate a concrete injury or how the statutes were applied to him. The Court reversed the District Court’s denial of Noland’s facial challenge, holding that he had standing to challenge the statute’s constitutionality on its face, since the procedural requirements themselves could constitute injury regardless of outcome. The case was remanded for further consideration of the facial constitutional challenges. View "Noland v. State" on Justia Law