Justia Constitutional Law Opinion Summaries

Jason Starr, following a contentious divorce from his ex-wife Sara Starr, was required to pay substantial monthly support and other financial obligations. Evidence showed Jason was deeply frustrated by these requirements and expressed anger in personal writings. After Sara moved out, she confided to a friend that she feared Jason would kill her. Prior to the murder, Jason suggested to a friend that his brother Darin could “take care of” marital problems for a fee. Darin, living in Texas, purchased a motorcycle with Jason’s financial assistance and received additional payments from Jason through a third party. Cell-site data and witness testimony placed Darin near Sara’s Alabama residence in the days leading up to her murder. Sara was shot and killed outside her home, and surveillance footage showed a motorcycle leaving the scene shortly after. Darin returned to Texas the same day. Later, while in jail for an unrelated offense, Darin made statements implying Jason owed him a significant favor.A federal grand jury in the United States District Court for the Middle District of Alabama indicted Jason and Darin Starr for using interstate commerce facilities in the commission of a murder-for-hire, in violation of 18 U.S.C. § 1958. At trial, the government presented circumstantial evidence linking both brothers to the crime. The jury convicted both Jason and Darin, and the district court imposed mandatory life sentences.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed claims that the district court erred by excluding alternate perpetrator evidence, admitting certain hearsay and investigative testimony, and that the evidence was insufficient to support conviction. The Eleventh Circuit held that the district court properly excluded speculative alternate perpetrator evidence, correctly admitted the challenged statements under evidentiary rules, and found the evidence sufficient for conviction. The court affirmed both convictions and sentences. View "USA v. Starr" on Justia Law

During a protest in Omaha, Nebraska, following the death of George Floyd, law enforcement declared the gathering an unlawful assembly and ordered the crowd to disperse. Adam Keup, who was present with his partner and friends to document the protest, was standing on a sidewalk near a Walgreens with a backpack containing camera equipment. Unaware of the dispersal order, Keup was shot in the eye with a pepper ball by Deputy Nicholas Palmer, resulting in permanent vision loss. After being shot, Keup was taken behind police lines for medical attention but was not arrested.The United States District Court for the District of Nebraska granted summary judgment in favor of Deputy Palmer, finding that he was entitled to qualified immunity on both the First and Fourth Amendment claims. The district court determined that Keup had not shown he was engaged in protected First Amendment activity that was the but-for cause of the force used against him, and that the use of the pepper ball and subsequent actions did not constitute a clearly established Fourth Amendment seizure.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eighth Circuit held that Keup failed to establish a causal connection between any protected First Amendment activity and Deputy Palmer’s actions, as there was no evidence Keup was singled out for his expression. Regarding the Fourth Amendment claim, the court concluded that the use of the pepper ball was intended to disperse, not to apprehend, and that taking Keup for medical care did not amount to an unreasonable seizure. Therefore, Deputy Palmer was entitled to qualified immunity, and the district court’s decision was affirmed. View "Keup v. Palmer" on Justia Law

A group called Montanans for Nonpartisan Courts submitted a proposed constitutional amendment, Ballot Issue 6 (BI-6), which would require all judicial elections in Montana to remain nonpartisan and mandate that any new courts created after the amendment’s effective date have judges elected on a nonpartisan basis. The initiative was submitted to the Secretary of State, who forwarded it for review. The Legislative Services Division completed its review, and the Attorney General then conducted a legal sufficiency review.The Attorney General of Montana determined that BI-6 was not legally sufficient under Montana law, specifically citing a violation of the separate-vote requirement in Article XIV, Section 11, of the Montana Constitution. This provision requires that if more than one constitutional amendment is submitted at the same election, each must be prepared and distinguished so it can be voted on separately. The Attorney General concluded that BI-6 contained two distinct substantive changes: one regarding nonpartisan judicial elections and another regarding the method of selecting judges for newly created courts. Montanans for Nonpartisan Courts challenged this determination in the Supreme Court of the State of Montana, seeking a declaratory judgment that BI-6 was legally sufficient.The Supreme Court of the State of Montana reviewed whether BI-6 violated the separate-vote requirement. The Court held that BI-6 proposed two substantive changes that were not closely related: requiring all judicial elections to be nonpartisan and mandating that judges in new courts be elected rather than appointed. The Court found that combining these changes in a single measure would prevent voters from expressing separate preferences and could result in “logrolling.” Therefore, the Court affirmed the Attorney General’s determination and denied the petitioner’s request, holding that BI-6 was not legally sufficient. View "Montanans for Nonpartisan Courts v. Knudsen" on Justia Law

A group called Montanans for Nonpartisan Courts (MNC) submitted a proposed constitutional initiative, CI-132, which would add a section to the Montana Constitution stating that judicial elections shall remain nonpartisan. MNC also submitted a proposed ballot statement: “CI-132 amends the Montana Constitution to require that judicial elections remain nonpartisan.” After the initiative and statement were submitted to the Secretary of State and reviewed by the Legislative Services Division, the Montana Attorney General conducted a legal sufficiency review. The Attorney General found the initiative legally sufficient but rejected MNC’s proposed statement, arguing it did not accurately reflect the current constitutional text and failed to define “nonpartisan.” The Attorney General then issued a revised statement, which MNC challenged as misleading and prejudicial.MNC filed an original proceeding in the Supreme Court of the State of Montana, seeking a declaratory judgment that the Attorney General’s revised statement violated statutory requirements and asking the Court to certify its own proposed statement. The Attorney General responded, defending his revised statement and criticizing MNC’s version for not reflecting the constitutional status quo and lacking a definition of “nonpartisan.”The Supreme Court of the State of Montana held that the Attorney General’s revised statement was misleading because it implied CI-132 would change the status quo, when in fact judicial elections in Montana are already nonpartisan by statute. The Court also found that a definition of “nonpartisan” was unnecessary, given voters’ familiarity with the term and the absence of a statutory definition. The Court concluded that MNC’s proposed statement was a true and impartial explanation of the initiative in plain language, meeting statutory requirements. The Court certified MNC’s statement to the Secretary of State and granted the petition for declaratory judgment. View "Montanans for Nonpartisan Courts v. Knudsen" on Justia Law

A group of Maine lobstermen challenged a state rule requiring all federally permitted lobster fishers to install electronic tracking devices on their vessels, which transmit GPS location data whenever the vessels are in the water. This rule was adopted by the Maine Department of Marine Resources (MDMR) to comply with an addendum to the Atlantic States Marine Fisheries Commission’s American Lobster Fishery Management Plan. The addendum aimed to reduce risks to North Atlantic right whales, improve fishery data, and support regulatory enforcement. The tracking devices must remain powered and transmit data at all times, including when vessels are docked or used for personal purposes.The plaintiffs filed suit in the United States District Court for the District of Maine, arguing that the MDMR Rule violated their rights under the Fourth Amendment, as well as equal protection and state administrative law. The district court granted the state’s motion to dismiss, holding that the plaintiffs failed to state a claim under the Fourth Amendment because the lobster fishery is a closely regulated industry and the rule was not unreasonably invasive. The court noted several concessions by the parties, including that the GPS tracking constituted a search, that the lobster industry is closely regulated, and that the search was administrative in nature.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court held that the lobster industry is a closely regulated industry and that the administrative search exception, as articulated in New York v. Burger, 482 U.S. 691 (1987), applied. The court found that the MDMR Rule satisfied the Burger test: it served a substantial government interest, warrantless searches were necessary to the regulatory scheme, and the rule provided a constitutionally adequate substitute for a warrant. The First Circuit affirmed the district court’s dismissal. View "Thompson v. Wilson" on Justia Law

In this case, the defendant applied for U.S. citizenship in 2011 and, on his application and during an interview, denied ever having committed a crime for which he was not arrested. However, in 2013, he pleaded guilty in North Carolina state court to attempted statutory rape for conduct that occurred in 2008, admitting to engaging in a sexual act with a minor. He did not disclose this conduct on his naturalization application. Years later, a federal grand jury indicted him for naturalization fraud, alleging he knowingly concealed his criminal history to obtain citizenship.The United States District Court for the Western District of North Carolina denied the defendant’s motion to dismiss the indictment for unconstitutional preindictment delay, finding he had not shown actual prejudice from the delay. The court also denied his motion to suppress evidence of his state guilty plea, ruling that he could not collaterally attack the validity of his state conviction in federal court except for a deprivation of counsel, which did not apply here. At trial, the court limited the testimony of the defendant’s expert witness regarding his cognitive abilities, excluding certain opinions about his capacity to understand the application question. The jury convicted the defendant, finding he knowingly made a false statement, and the court sentenced him to six months in prison and revoked his citizenship.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the defendant failed to demonstrate substantial actual prejudice from the preindictment delay, that the district court properly refused to suppress the state guilty plea, and that while the limitation of the expert’s testimony was error under recent Supreme Court guidance, the error was harmless given the other evidence presented. The conviction and sentence were therefore affirmed. View "US v. Palmer" on Justia Law

Drexel Starks was arrested for possession of a controlled substance and taken to the St. Louis County Justice Center, where he reported heroin withdrawal symptoms. Jail medical staff placed him on a withdrawal protocol, which included comfort medication and regular nurse assessments. Over the next day, nurses noted some improvement in his symptoms. However, there is no evidence of further assessments as required by protocol. On August 6, a correctional officer found Drexel on the floor with withdrawal symptoms; he was transferred to the infirmary and then to a hospital, where he died. The medical examiner attributed his death to withdrawal from heroin and cocaine, dehydration, and cardiac dysrhythmia.Margaret Starks, Drexel’s mother, filed suit in the United States District Court for the Eastern District of Missouri under 42 U.S.C. § 1983, alleging that jail nurses and a correctional officer were deliberately indifferent to Drexel’s serious medical needs, and that nurse supervisors and St. Louis County failed to train or supervise staff and maintained an unlawful policy of denying medical care. The district court granted summary judgment for the defendants, finding that Margaret failed to establish a violation of Drexel’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that no reasonable jury could find Drexel had an objectively serious medical need that was obvious to a layperson or supported by medical evidence, nor that the defendants acted with deliberate indifference akin to criminal recklessness. The court also held that, absent an underlying constitutional violation, claims against the nurse supervisors and the County for failure to train or supervise, or for unlawful policy, could not succeed. The judgment of the district court was affirmed. View "Starks v. St. Louis County" on Justia Law

In April 2019, a man and his girlfriend, along with her children, were living in an apartment in DeKalb County, Georgia. After being told to move out by the apartment’s primary resident, the man became angry and assaulted his girlfriend in the presence of her child, inflicting multiple injuries including choking, hitting, and stomping. He later transported her, with the help of his daughter, to another apartment in Fulton County, where further violence occurred. The girlfriend was eventually taken to a hospital and pronounced dead. Medical evidence showed she suffered extensive internal and external injuries, including blunt force trauma and strangulation, which were determined to be the cause of death.A DeKalb County grand jury indicted the man for malice murder and related offenses. At trial in the Superior Court of DeKalb County, the jury found him guilty on all counts. He was sentenced to life imprisonment without parole for malice murder, with the other counts vacated or merged. The defendant filed a motion for a new trial, which was denied, and then appealed.The Supreme Court of Georgia reviewed the case. The court held that the evidence was sufficient to support the conviction for malice murder and to establish venue in DeKalb County, as the fatal injuries were inflicted there. The court also rejected the defendant’s challenges to the constitutionality of the venue statute and related jury instruction, finding no conflict with state or federal constitutional requirements. Finally, the court found the defendant’s arguments regarding the proportionality and constitutionality of his sentence to be factually unsupported or abandoned. The Supreme Court of Georgia affirmed the conviction and sentence. View "TAYLOR v. THE STATE" on Justia Law

Residents of Jackson, Mississippi, brought a class action lawsuit alleging that the city knowingly contaminated their drinking water with lead, failed to treat the water to prevent lead leaching, and misled the public about the water’s safety. The complaint details how city officials ignored warnings about the water system’s vulnerabilities, failed to repair critical treatment equipment, switched water sources in a way that worsened contamination, and delayed notifying residents of dangerous lead levels. Plaintiffs claim they and their families suffered significant health effects, including lead poisoning and related medical and developmental issues, as a result of consuming the contaminated water.The United States District Court for the Southern District of Mississippi granted the defendants’ motion for judgment on the pleadings. The court found that the plaintiffs failed to state a substantive due process claim against the city and that the individual city officials were entitled to qualified immunity. The district court also declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the plaintiffs plausibly alleged a violation of their Fourteenth Amendment right to bodily integrity by claiming the city affirmatively introduced toxins into the water supply, misrepresented the water’s safety, and thereby deprived residents of the ability to make informed decisions about their health. The court also formally adopted the state-created danger doctrine as a viable theory in the circuit. The court reversed the dismissal of the due process claims against the city and vacated the dismissal of the state-law claims, remanding for further proceedings. However, the court affirmed the dismissal of claims against the individual city officials on qualified immunity grounds, finding the relevant rights were not clearly established at the time. View "Sterling v. City of Jackson" on Justia Law

The case concerns a man who, along with his wife, adopted two young girls through the foster care system. Years later, when one of the girls was nearly 17, she disclosed to a friend’s mother that she had been sexually abused by her adoptive father over several years. This disclosure led to a law enforcement investigation, during which the defendant voluntarily went to the sheriff’s department to “turn himself in.” He was subsequently interrogated by two officers in a closed interview room at the station. During the third segment of questioning, after persistent and increasingly accusatory interrogation techniques, the defendant confessed to engaging in sexual acts with one of the victims.The Superior Court of San Bernardino County heard pretrial motions regarding the admissibility of the defendant’s statements to law enforcement. The prosecution sought to admit the statements, while the defense moved to suppress them, arguing they were obtained in violation of the defendant’s constitutional rights. The trial court ruled the interrogation was not custodial and admitted the statements. At trial, the prosecution presented testimony from the victims and law enforcement, while the defense highlighted inconsistencies and lack of physical evidence. The jury found the defendant guilty on all counts, and he was sentenced to over 120 years to life in prison.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the defendant’s confession should have been suppressed under Miranda v. Arizona. The appellate court held that while the initial questioning was noncustodial, the interrogation became custodial during the third segment, at which point Miranda warnings were required but not given. The court found the admission of the confession was prejudicial and not harmless beyond a reasonable doubt. Accordingly, the judgment was reversed and the case remanded for further proceedings. View "People v. NavaAdame" on Justia Law