Justia Constitutional Law Opinion Summaries

A prisoner serving life imprisonment following a death sentence challenged the conditions of his long-term solitary confinement in a high-security Connecticut facility. After the death penalty was abolished in Connecticut, the inmate’s sentence was changed to life without parole, but he remained in solitary confinement under conditions mandated by a state statute (section 18-10b). He argued that these conditions violated his rights under the Eighth Amendment and the Due Process Clause of the Fourteenth Amendment.Previously, the United States District Court for the District of Connecticut denied the prison officials’ motion for judgment as a matter of law based on qualified immunity and granted the prisoner’s motion for a new trial. The District Court had also divided the due process claim into two periods: before and after 2017, and a jury found the officials liable only for the period after 2017. The court ordered a new trial on the Eighth Amendment claim, ruling that the jury’s verdict was against the weight of the evidence, and denied judgment as a matter of law for the officials on both the Eighth Amendment and due process claims.The United States Court of Appeals for the Second Circuit reviewed the case. It determined it lacked jurisdiction to review the denial of qualified immunity for the Eighth Amendment claim, as unresolved factual disputes remained. However, the court found it had jurisdiction over the denial of qualified immunity on the post-2017 due process claim because the relevant facts were undisputed. The court held that the prison officials did not violate clearly established law regarding the due process claim and were therefore entitled to qualified immunity for that period. The appeal was dismissed in part, the district court’s order was reversed in part, and the case was remanded for further proceedings. View "Reynolds v. Quiros" on Justia Law

A high school student, JR, reported to law enforcement that her stepfather, Charles Merrell, had engaged in a pattern of inappropriate sexual conduct over several years. JR described repeated incidents, including touching, massaging, and pinching her bare buttocks, forced intimate dancing and hugging in which she felt his genitals against her, and other behaviors such as rubbing her bare stomach and kissing her neck. She also recounted that Merrell initiated conversations about masturbation, encouraged her to “explore” her body, and tried to justify his actions as helping her. Merrell admitted most of the physical contact but claimed his motives were innocent.Following a police investigation, Merrell was charged in the District Court of Lincoln County, Wyoming, with two counts of third-degree sexual abuse of a minor under Wyoming Statute § 6-2-316(a)(iv). The prosecution amended the charges for clarity after Merrell requested a bill of particulars. At trial, JR testified in detail about the conduct. The jury found Merrell guilty on both counts. The district court denied Merrell’s motions for acquittal and for a new trial, sentencing him to concurrent prison terms.On appeal to the Supreme Court of the State of Wyoming, Merrell challenged the statute as unconstitutionally vague, the sufficiency of the evidence, the unanimity of the jury verdict, the admission of expert testimony on “grooming,” alleged prosecutorial misconduct, and cumulative error. The Supreme Court held that the statute was neither vague on its face nor as applied; that sufficient evidence supported the convictions; that no unanimity violation or instructional error occurred; that the expert testimony and prosecution’s arguments were properly admitted or not prejudicial; and that cumulative error analysis was unwarranted. The Court affirmed the convictions and sentences. View "Merrell v. State" on Justia Law

A fatal shooting occurred at a bar in Des Moines, Iowa, where the defendant and two associates confronted the victim, Tyrone Hutchins. Surveillance footage showed the defendant entering the bar with his hand on a pistol and shooting Hutchins at close range as Hutchins attempted to leave, resulting in Hutchins’ death. The defendant claimed he acted in self-defense, but forensic evidence indicated only the defendant fired shots. He voluntarily went to the police after the incident, claimed justification, but later left the city and was arrested months later.The Iowa District Court for Polk County conducted a jury trial, during which the defendant objected to a courthouse policy requiring a uniformed deputy to sit behind him while he testified, arguing it prejudiced the jury. The district court overruled the objection, reasoning the deputy’s presence was unobtrusive and not prejudicial. The jury convicted the defendant of second-degree murder. The defendant appealed, raising several issues, including the deputy’s courtroom positioning and a sentencing order requiring victim-offender dialogue. The Iowa Court of Appeals reversed the conviction, finding the deputy’s presence inherently prejudicial and lacking case-specific justification, and remanded for a new trial.The Iowa Supreme Court granted further review. It held that the presence of a deputy near a testifying defendant is not inherently prejudicial under federal constitutional standards unless there is a showing of actual prejudice, which was not demonstrated in this case. The court vacated the Court of Appeals’ decision, affirmed the conviction and most of the sentence, but vacated the requirement for victim-offender dialogue, remanding for its removal from the sentencing order. View "State v. Wiggins" on Justia Law

Police officers stopped a driver late at night after observing her vehicle traveling above normal speed, lacking visible license plates, and making unusual movements when pulling over. The driver admitted she did not have a license and appeared confused, struggling to answer questions. The passenger was reportedly highly intoxicated. The officers suspected impairment and decided to conduct field sobriety tests. Due to snow and cold weather, they transported the driver a few blocks to a nearby parking garage attached to police headquarters, where they administered sobriety tests and a preliminary breath test. After completing the tests, the officers arrested the driver and took her inside the headquarters for a breath alcohol analysis.The District Court for Douglas County reviewed the defendant’s motion to suppress evidence, which argued that the transport to the parking garage constituted an unlawful arrest lacking probable cause. The court held a hearing, reviewed testimony and video evidence, and found that the officers made a lawful traffic stop supported by reasonable suspicion. The court concluded that the transport to the parking garage for field sobriety tests, motivated by safety and weather concerns, did not convert the investigative detention into an arrest. After a bench trial on stipulated facts and evidence, the court found the defendant guilty of driving under the influence, fourth offense, and imposed sentence.The Nebraska Supreme Court applied a two-part review: clear error for factual findings, and independent review for legal conclusions regarding Fourth Amendment protections. The court held that the officers’ transport of the defendant to a parking garage for field sobriety testing, under these circumstances, did not elevate the detention to an arrest requiring probable cause. The investigatory detention remained lawful, and the district court’s decision overruling the motion to suppress was affirmed. View "State v. Saunsoci" on Justia Law

The defendant was involved in a fatal altercation at Terry’s Café, where surveillance footage showed he shot and killed an acquaintance, Jeremy Peters, after Peters retrieved and concealed a knife. The defendant was indicted for first-degree murder and three counts of wanton endangerment with a firearm. During his January 2023 trial, several key participants, including the defendant, counsel for both sides, court staff, and at least one juror, contracted COVID-19, leading the Circuit Court of Boone County to declare a mistrial due to health concerns and potential prejudice to both parties.Following the mistrial, the defendant moved to dismiss the charges on double jeopardy grounds, arguing that the retrial was barred because the court failed to consider a brief continuance, which both parties had suggested as an alternative. The Circuit Court denied the motion, finding that the COVID-19 outbreak constituted a manifest necessity for the mistrial and was outside the State’s control. The defendant was retried, found guilty of voluntary manslaughter, acquitted of the wanton endangerment charges, and sentenced to fifteen years of incarceration. He appealed the sentencing order, challenging the mistrial ruling.The Supreme Court of Appeals of West Virginia reviewed the case and held that the circuit court acted within its discretion in determining that a manifest necessity existed for declaring a mistrial due to the widespread COVID-19 outbreak among trial participants. The court concluded that the retrial was not barred by double jeopardy because the mistrial was justified by manifest necessity, even though the procedure for considering alternatives was imperfect. The court affirmed the circuit court’s sentencing order. View "State v. Dickens" on Justia Law

Kelly was suspected of illegal drug activity after Detective Jonathan Smith observed a drug sale involving a black male who left the scene in a red vehicle with a white female passenger. Shortly after, Deputy Cody Jett received an anonymous tip indicating Heather McDonald would arrive in a red Hyundai at a McDonald’s restaurant, accompanied by a black male driver, and that both individuals possessed heroin and were dealing drugs. Deputy Jett verified an arrest warrant for McDonald. At the restaurant, Jett observed a vehicle matching the tip, McDonald, and a black male later identified as Kelly. After Kelly and McDonald responded to Jett’s instructions, McDonald attempted to flee and was apprehended, while Kelly was detained and eventually admitted there were drugs in the vehicle. Officers subsequently obtained a search warrant, found additional evidence, and arrested Kelly for driving with a suspended license and several drug offenses.The United States District Court for the Middle District of Florida initially denied the officers’ motion to dismiss under Heck v. Humphrey, finding it could not conclude at that stage that Kelly’s Fourth Amendment claims were barred. Later, upon motions for summary judgment, the district court granted summary judgment in favor of the officers, holding that Heck barred Kelly’s suit because success would imply the invalidity of his convictions. The district court did not address qualified immunity.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and declined to base its decision on Heck. Instead, the appellate court found that both Deputy Jett and Detective Smith were entitled to qualified immunity because there was probable cause to detain Kelly, given the corroborated anonymous tip and observed circumstances. The Eleventh Circuit affirmed the summary judgment in favor of the officers. View "Kelly v. Jett" on Justia Law

The case concerns a shooting in a Los Angeles park involving rival gangs. Jesus Guzman, associated with Lawndale 13, was accused of killing David Najera, a member of Muertos 13, after an altercation between the gangs the previous night at a hookah bar. The prosecution argued that Guzman and his gang sought revenge for the prior incident, resulting in Najera’s death and the attempted murder of another Muertos member, Portillo. Evidence against Guzman included eyewitness descriptions, video footage, and information from a confidential reliable informant who identified Guzman by his gang moniker and linked his social media account to the crime.The Superior Court of Los Angeles County presided over Guzman’s trial. The jury convicted Guzman of second-degree murder and premeditated attempted murder, finding that a principal—but not Guzman himself—personally and intentionally discharged a firearm causing death. Guzman was sentenced to 22 years to life. The central issue on appeal was Guzman’s challenge to the police search of his social media account, arguing that the affidavit supporting the search warrant lacked sufficient probable cause and did not establish a link between his account and the crime.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that the evidence obtained from Guzman’s social media account was properly admitted because, at a minimum, the good-faith exception to the exclusionary rule applied. The affidavit supporting the search warrant provided a reasonable basis for police to believe the warrant was valid, and it was reasonable to infer that the social media account would contain relevant evidence. The judgment of the trial court was affirmed. View "People v. Guzman" on Justia Law

A Sedona resident, who has obsessive-compulsive disorder, often sleeps in her car because her disability prevents her from entering her apartment. The City of Sedona has a criminal ordinance prohibiting sleeping in a vehicle on public or private property. The resident was twice warned by police for sleeping in her car and requested reasonable accommodation under the Americans with Disabilities Act (ADA) to exempt her from enforcement of this ordinance. The city denied her requests, and her landlord threatened not to renew her lease if she continued sleeping in her car. She alleges that the city’s actions caused her emotional distress and loss of income, and she continues to sleep in her car several times a week.The United States District Court for the District of Arizona dismissed her claims for lack of standing, finding that the prior police warnings were insufficient to support a specific threat of prosecution and that she failed to allege a history of enforcement against similarly situated individuals. The district court addressed only her standing to seek injunctive relief, despite her claims for damages as well. Her requests to amend her complaint were denied, and she appealed.The United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part the district court’s dismissal. The Ninth Circuit held that she had Article III standing to bring an ADA claim for both damages and injunctive relief, based on the city’s denial of her request for accommodation and a credible threat of future enforcement. The court further held that Title II of the ADA applies to requests for reasonable accommodation to comply with municipal criminal ordinances. The ADA claim was remanded for further proceedings, allowing her to amend her complaint, while the dismissal of her Eighth Amendment claim was affirmed. View "BERAM V. CITY OF SEDONA" on Justia Law

The plaintiff, John William Scharnhorst, III, was held as a pretrial detainee at the Washington County Detention Center (WCDC) for several months. During his detention, he experienced restrictions on access to books, newspapers, and religious materials. WCDC implemented these restrictions in response to issues with inmates using paper for illicit purposes, such as jamming locks, flooding cells, concealing contraband, and making weapons. The facility limited inmates to four books—three from a book cart and one religious text—and transitioned to providing electronic access to books and newspapers via kiosks and tablets, though access to these devices was time-limited. While religious materials and paper mail could be requested, Scharnhorst claimed that staff inconsistently delivered these materials.The United States District Court for the Western District of Arkansas, adopting a magistrate’s recommendation, granted summary judgment to some defendants and found moot the preliminary injunction requiring daily newspaper uploads. However, it denied summary judgment and qualified immunity to Sheriff Cantrell, Major Denzer, and Lieutenant Ake, finding material disputes about their enforcement of WCDC policies and concluding that, if enforced as alleged, the restrictions violated clearly established First Amendment rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of qualified immunity. Accepting the facts found or likely assumed by the district court, the appellate court held that Scharnhorst did not demonstrate a violation of clearly established law. The Eighth Circuit found that WCDC’s policies did not amount to a “de facto permanent ban” on communication or access to religious materials, as inmates retained access to mail, electronic newspapers, and religious texts. Consequently, the court reversed the district court’s denial of qualified immunity to the defendants and remanded for further proceedings. View "Scharnhorst v. Cantrell" on Justia Law

Several misdemeanor prosecutions were consolidated in a municipal court after the City Attorney for Henderson argued that Nevada Revised Statute 178.4849(1), which requires pretrial release hearings within 48 hours of arrest, impaired prosecutors’ ability to prepare adequately for those hearings. The City sought a declaration that the statute was unconstitutional under Marsy’s Law and the separation-of-powers doctrine. In each case, defendants were arrested on weekends and brought before the municipal court within 24 hours. The City asserted that the compressed timeline undermined its ability to protect victims’ rights and to present sufficient evidence for bail determinations.The Henderson Municipal Court consolidated the cases and found that the City had both direct standing and third-party standing to challenge the statute on behalf of victims. It declared NRS 178.4849 unconstitutional under Marsy’s Law and separation-of-powers principles, citing conflicts with statewide pretrial risk assessment requirements and judicial precedent. Respondents petitioned the Eighth Judicial District Court for a writ of mandamus or prohibition. The district court concluded the City lacked both direct and third-party standing, as it failed to demonstrate a concrete, traceable injury and victims were not hindered from asserting their own interests. The district court also found the statute constitutional and granted the petition.Reviewing the appeal, the Supreme Court of the State of Nevada determined that the City of Henderson had not established standing. It found no concrete injury to the City’s prosecutorial interests that was traceable to NRS 178.4849 or likely to be redressed by the requested relief. The court held that the City lacked both direct and third-party standing, and the public-importance exception did not apply. Without standing, the court declined to address the constitutional merits and affirmed the district court’s order granting the writ. View "CITY OF HENDERSON VS. ARMENDAREZ" on Justia Law