Justia Constitutional Law Opinion Summaries

The defendant was charged with reckless discharge of a firearm, unlawful possession of a weapon by a felon (UPWF), and misdemeanor domestic battery after an incident in his Chicago apartment. He had a prior felony conviction for aggravated unlawful use of a weapon, specifically for possessing a firearm without a valid Firearm Owners Identification (FOID) card. Evidence at trial showed he possessed and fired a handgun during a domestic dispute. The circuit court of Cook County, after a bench trial, found him guilty on all counts.On direct appeal to the Illinois Appellate Court, the defendant challenged the constitutionality of the UPWF statute under the Second Amendment, arguing both facially and as applied to him in light of New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The appellate court rejected both challenges, holding that Bruen’s standards did not apply to felons and that sufficient historical precedent supported felon firearm bans. The appellate court also considered and rejected the defendant’s as-applied challenge, despite the State’s argument that the issue was forfeited because it was not raised before the circuit court.The Supreme Court of the State of Illinois reviewed the appellate court’s judgment regarding the as-applied constitutional challenge. The court held that an as-applied challenge requires a developed factual record, which was lacking because the defendant did not raise the issue in the circuit court for an evidentiary hearing. The court vacated the part of the appellate court judgment that considered the merits of the as-applied challenge, affirmed the remainder of the appellate court’s judgment, and affirmed the defendant’s UPWF conviction. The main holding is that an as-applied constitutional challenge to the UPWF statute cannot be decided without a factual record developed in the trial court. View "People v. Benson" on Justia Law

A two-year-old child was discovered deceased in the home of the appellant, who had been dating the child’s mother. Police, suspecting foul play based on blood found at the scene, obtained a search warrant for electronic devices in the home. The search revealed videos of the appellant abusing the child, disturbing text messages, and evidence of file deletion software use. At trial, extensive forensic and medical evidence indicated the child was smothered, not killed by a fall, and DNA linked the appellant to a bloody pillow found in the crib. The appellant was convicted of capital murder and sentenced to life without parole.The Second Court of Appeals reviewed the case, focusing on the appellant’s claim that the search of electronic devices violated the Fourth Amendment because the warrant’s supporting affidavit lacked sufficient facts to establish probable cause. The court found the search unconstitutional and conducted a constitutional harm analysis, concluding that admission of the incriminating evidence from the devices was harmful. The court reversed the conviction, finding the GoPro video particularly prejudicial and determining that the other evidence was not overwhelming.The Court of Criminal Appeals of Texas reviewed the case on the State’s petition for discretionary review. The court assumed error in admitting the evidence and addressed only harm, holding that the court of appeals applied the wrong harm standard. Because the police acted in good faith reliance on the warrant, exclusion was required only under Texas’s statutory rule, so the nonconstitutional harm standard applied. The court found that, given the overwhelming medical, forensic, and DNA evidence, any error in admitting the videos and file deletion evidence was harmless. The judgment of the court of appeals was reversed and the trial court’s conviction was affirmed. View "STALEY v. STATE OF TEXAS" on Justia Law

A financial trustee acting on behalf of bondholders filed a proof of claim for $8.5 billion in the Commonwealth of Puerto Rico’s bankruptcy-like restructuring proceedings. The claim was based on allegations that the Commonwealth had impaired statutory and constitutional rights that were intended to protect bondholders in connection with revenue bonds issued by the Puerto Rico Electric Power Authority (PREPA), a public utility corporation. The Commonwealth had enacted laws that, according to the trustee, limited PREPA’s ability to set rates and satisfy its bond obligations, thereby breaching a statutory covenant not to impair PREPA’s ability to repay the bonds. The trustee characterized these statutory protections as a material inducement for investors to purchase the bonds.The United States District Court for the District of Puerto Rico, acting as the Title III court under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), had previously confirmed the Commonwealth’s Plan of Adjustment. This Plan created separate classes of claims, including one (Class 64) for claims subordinated under 11 U.S.C. § 510(b), which covers damages “arising from the purchase or sale” of a debtor’s security. The trustee’s claim was classified in Class 64, which receives no distribution, rather than as a general unsecured claim (Class 58), which would have allowed a partial recovery. The district court held that the trustee’s claim was properly subordinated under § 510(b).The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court’s judgment, holding that § 510(b) applies to the trustee’s claim because the damages sought arose from the purchase of PREPA’s revenue bonds, induced by the alleged statutory protections. The court also rejected procedural and constitutional avoidance arguments, and found that any challenge to the level of subordination was waived. View "FOMB v. SIG Structured Products, LLC" on Justia Law

Several individuals living within a five-mile radius of the Seattle-Tacoma Airport sued two major airlines and the Port of Seattle. They alleged that pollution from aircraft takeoffs and landings caused harm to their health and property, particularly from particulate matter and other pollutants released by aircraft engines and fuselages. Plaintiffs claimed the defendants had knowledge of studies linking these pollutants to negative health outcomes and property devaluation but failed to remediate or prevent further pollution. The affected community was described as disproportionately composed of minority, immigrant, and low-income residents.The plaintiffs initially brought their case in King County Superior Court, but the defendants removed it to the United States District Court for the Western District of Washington. The plaintiffs advanced state tort and constitutional claims, seeking various remedies including damages, injunctive relief, and remediation. The defendants moved to dismiss, arguing that the claims were a collateral attack on federal agency actions, were expressly and impliedly preempted by federal law, and failed to state a claim. The district court denied the motions, finding that the complaint did not directly challenge any specific agency order and that preemption was not clearly established at this stage. The district court certified its order for interlocutory appeal.Reviewing the case on interlocutory appeal, the United States Court of Appeals for the Ninth Circuit held that the district court properly exercised jurisdiction because the collateral attack doctrine did not apply; defendants could not identify any specific agency orders inescapably implicated by the plaintiffs’ claims. However, the court held that the claims were expressly preempted by Section 233 of the Clean Air Act, which bars states from enforcing any emission standards for aircraft pollutants unless identical to federal standards. The court reversed the district court’s order denying the motion to dismiss and remanded the case. View "CODONI V. PORT OF SEATTLE" on Justia Law

In this case, the petitioner was convicted of capital murder and sentenced to death following a 2003 armed robbery in Houston, Texas, during which a restaurant employee was killed. Key evidence included eyewitness testimony, statements from co-defendants and jailhouse informants, and information about the petitioner’s criminal history and conduct in prison. The prosecution’s case centered on the petitioner being the sole gunman, though there was conflicting testimony about whether a second person entered the restaurant.The Texas Court of Criminal Appeals affirmed the conviction and sentence on direct appeal and denied state habeas relief, finding the petitioner’s subsequent and additional habeas claims to be procedurally barred as an abuse of the writ. The petitioner then sought federal habeas relief in the United States District Court for the Southern District of Texas, raising thirteen claims, including allegations of false evidence, inconsistent prosecutorial theories, Brady violations, ineffective assistance of counsel, and racial bias. The district court denied relief on the merits where permitted and found the remaining claims procedurally barred due to default under Texas law, ruling that the petitioner had not shown cause, actual prejudice, or a fundamental miscarriage of justice to excuse the default.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether a certificate of appealability (COA) should issue for the claims dismissed as procedurally barred. The court held that the petitioner failed to show that jurists of reason could debate the district court’s procedural rulings. The court concluded that the claims were subject to an adequate and independent state procedural bar, and the petitioner had not demonstrated cause and prejudice or actual innocence to overcome that bar. The Fifth Circuit therefore denied the application for a certificate of appealability. View "Marshall v. Guerrero" on Justia Law

The case concerns Del Orrin Crawford, who was involved in a deadly altercation outside the South Fork Saloon in Martin City, Montana, on August 26, 2022. After a dispute regarding a golf cart escalated, Crawford fired a handgun, resulting in the death of Whisper Sellers and serious injury to Douglass Crosswhite. Crawford fled the scene, called 911 multiple times claiming self-defense, and was later apprehended by law enforcement. Upon arrest, Crawford surrendered unarmed, and the firearm he used was not immediately recovered. Law enforcement questioned Crawford about the firearm’s location and conducted further interrogation after transporting him to the sheriff’s office.The Eleventh Judicial District Court in Flathead County presided over Crawford’s jury trial. Crawford moved to suppress two sets of statements made to law enforcement after he invoked his right to counsel. The court denied most of his motion, suppressing only statements related to his alcohol consumption before his second Miranda advisement. Crawford was subsequently convicted by the jury of Deliberate Homicide, Attempted Deliberate Homicide, Assault with a Weapon, and Tampering with Physical Evidence, and sentenced to 100 years in prison.On appeal, the Supreme Court of the State of Montana reviewed whether the district court erred in admitting Crawford’s statements regarding the firearm’s location after he requested counsel and whether it was correct in finding that Crawford reinitiated conversation and knowingly waived his right to counsel before making further statements. The Supreme Court held that even if admitting the statements about the firearm’s location was erroneous, any error was harmless beyond a reasonable doubt due to cumulative admissible evidence. The Court further held that Crawford voluntarily reinitiated conversation and validly waived his right to counsel before providing additional statements. The judgment of conviction was affirmed. View "State v. Crawford" on Justia Law

The case concerns a defendant who was charged with abusing his elderly stepfather, resulting in both mental injury and physical harm. The elderly victim, who had declining health and required assistance, was subjected to several years of verbal threats, intimidation, and, on at least one occasion, physical assault when the defendant struck him in the face. The victim’s daughter and other family members observed concerning behavior, including an incident where the defendant shook the victim in a manner described as threatening. The victim, before passing away, gave a recorded deposition detailing the abuse, his fear, and its emotional toll. The charges included abuse of an elderly person and first-offense partner or family member assault.Prior to trial, the defendant sought to enforce an alleged plea agreement, but the District Court found no such agreement had been accepted, following a hearing. Although a jury trial was scheduled, the defendant requested a bench trial, and the Tenth Judicial District Court, Fergus County, confirmed that he knowingly and voluntarily waived his right to a jury trial, albeit orally rather than in writing. After a two-day bench trial, the court found the defendant guilty on both counts and imposed a prison sentence. The defendant appealed, arguing insufficient evidence due to a lack of expert testimony on mental injury, an improper waiver of jury trial, and that the elder abuse statute was unconstitutionally vague and overbroad.The Supreme Court of the State of Montana held that expert testimony is not required to establish “mental injury” under the relevant statute, as a reasonable person standard applies and lay testimony was sufficient. The court found no manifest miscarriage of justice in accepting the oral waiver of a jury trial. The court also rejected the facial constitutional challenges, as the defendant’s conduct was clearly proscribed by statute. The judgment of the District Court was affirmed. View "State v. Pein" on Justia Law

The appellant was convicted of first-degree murder, robbery, and grand theft after brutally beating and killing a woman with whom he was temporarily staying. Evidence at trial established the appellant stole cash and the victim’s car, fled the state, and used an alias before being apprehended in Alabama and returned to Florida for prosecution. The jury convicted him and recommended the death penalty by a 10-2 vote. The trial court found aggravating factors including murder during a robbery and that the crime was especially heinous, atrocious, or cruel, outweighing mitigating circumstances, and imposed a sentence of death.The Supreme Court of Florida previously affirmed the convictions and sentence on direct appeal. The appellant later filed multiple unsuccessful postconviction motions in state and federal courts, including a motion based on the Florida Supreme Court’s decision in Hurst v. State, which was denied due to lack of retroactivity. After the Governor signed a death warrant, the appellant filed a successive motion for postconviction relief and a stay of execution in the Circuit Court for Polk County, raising claims regarding his age and cognitive decline, warrant timing, the warrant process, and the nonunanimous jury recommendation.The Supreme Court of Florida reviewed the circuit court’s summary denial of postconviction relief de novo. The Court affirmed the summary denial, holding the appellant’s claims were either procedurally barred or meritless. Specifically, it ruled there is no constitutional prohibition against executing elderly prisoners experiencing cognitive decline, the expedited warrant period does not violate due process or equal protection, the Governor’s discretion in signing death warrants is not unconstitutional, and a nonunanimous jury recommendation of death does not violate the Fifth, Sixth, or Eighth Amendments. The Court also denied the appellant’s request for a stay of execution. View "Beasley v. State" on Justia Law

In 2003, Samuel Anthony Cruz and several other members of the 7th Street gang were involved in two separate shooting incidents that resulted in the deaths of rival gang members. Cruz was charged with two counts of murder but entered a plea agreement in which he pleaded guilty to two counts of voluntary manslaughter, along with enhancements and gang participation. He was sentenced to a negotiated term of 21 years and eight months.Many years later, Cruz filed a petition under California Penal Code section 1172.6, seeking to vacate his manslaughter convictions and be resentenced on the grounds that legal standards for murder liability had changed. The Superior Court of Orange County issued an order to show cause and held an evidentiary hearing. At this hearing, the prosecution introduced transcripts from the 2007 trial of Cruz’s codefendant, Juan Becerra. Cruz objected to the use of these transcripts on due process grounds but did not challenge the factual findings or dispute this court’s prior opinions allowing such evidence. The trial court denied Cruz’s petition, finding he was an actual shooter in one killing and a direct aider and abettor in the other.Upon appeal, the California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the trial court’s consideration of a codefendant’s trial testimony violated Cruz’s right to due process. The court held that admission of this testimony did not violate procedural due process because Cruz had a full and fair opportunity to contest the evidence: he could have subpoenaed witnesses, testified on his own behalf, or introduced new evidence. The court affirmed the trial court’s order denying Cruz’s petition for vacatur and resentencing. View "P. v. Cruz" on Justia Law

Two Hawaii residents challenged two aspects of the state's “shall-issue” firearm licensing regime. The first challenged provision required that a handgun acquisition permit be used within thirty days of issuance or else the applicant must restart the process. The second provision required that, after purchasing a firearm, certain owners must bring it to a police station for inspection and registration in specific circumstances. Plaintiffs alleged that these requirements imposed undue burdens on their ability to acquire firearms, in violation of the Second Amendment.The United States District Court for the District of Hawaii granted summary judgment to the plaintiffs. The district court found both requirements facially unconstitutional under the Second Amendment, applying intermediate scrutiny as was then the circuit precedent. The court permanently enjoined the state from enforcing the challenged provisions. After this ruling, the Supreme Court decided New York State Rifle & Pistol Ass’n v. Bruen, which changed the standard for Second Amendment claims to a “text, history, and tradition” test.On appeal, the United States Court of Appeals for the Ninth Circuit, sitting en banc, considered the impact of Bruen and subsequent Supreme Court cases. The Ninth Circuit noted that Bruen distinguished between “may-issue” and “shall-issue” licensing regimes and, in footnote 9, characterized objective, non-abusive “shall-issue” regimes as presumptively constitutional. The court concluded that the two challenged Hawaii requirements were objective, non-discretionary, and did not amount to abusive practices that would deny ordinary citizens their Second Amendment rights. At most, the provisions imposed only modest, procedural burdens and did not materially impede firearm acquisition.The Ninth Circuit therefore reversed the district court’s injunction and remanded for further proceedings, holding that Hawaii’s “shall-issue” regime, as applied here, comports with the Second Amendment. View "YUKUTAKE V. LOPEZ" on Justia Law