Justia Constitutional Law Opinion Summaries

James Conn murdered Savannah Puckett, and his parents, Mollie and Michael Slaybaugh, suffered property damage when police arrested Conn at their home. The Slaybaughs filed a lawsuit under 42 U.S.C. § 1983, seeking compensation for the damage under the Takings Clause of the Fifth Amendment and its Tennessee Constitution counterpart.The United States District Court for the Middle District of Tennessee dismissed the Slaybaughs' claims. The court ruled that the police actions did not constitute a taking for public use under the Fifth Amendment because the damage occurred while enforcing criminal laws. The court also dismissed the state-law claim, stating that the Tennessee Constitution offers protections co-extensive with the Fifth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the Slaybaughs did not state a valid takings claim because the police actions were privileged under the search-and-arrest privilege. This privilege allows law enforcement to use reasonable force to enter property and make an arrest without being liable for resulting property damage, provided the actions are lawful and reasonable. The court found no evidence suggesting the police acted unlawfully or unreasonably. Consequently, the court affirmed the district court's dismissal of both the federal and state constitutional claims. View "Slaybaugh v. Rutherford County" on Justia Law

Preston Strong was convicted of six counts of first-degree murder and sentenced to death. Strong had a history of financial troubles and was friends with one of the victims, Luis Rios, who often loaned him money. An argument between Strong and Luis occurred about a month before the murders, with Luis refusing to loan Strong more money. On the day of the murders, Luis and Adrienne Heredia, along with her four children, were found dead in their home. Evidence included Strong’s fingerprints on plastic bags found at the scene and his DNA on the steering wheel of Luis’s vehicle.The Superior Court in Yuma County denied Strong’s motions to change the venue, suppress evidence, and dismiss the case due to preindictment delay. The jury found Strong guilty and determined that the State had proved the alleged aggravating circumstances. The trial court later instructed the jury to disregard one of the aggravating factors during the penalty phase. Strong’s motions for a new trial and to vacate the judgment, based on alleged juror misconduct and other grounds, were denied.The Arizona Supreme Court reviewed the case and affirmed Strong’s convictions and sentences. The court found no abuse of discretion in the trial court’s rulings on preindictment delay, change of venue, and the admission of evidence. The court also concluded that the trial court did not err in its handling of juror misconduct allegations, the admission of DNA evidence, and the consideration of victim impact statements. The court held that the erroneous instruction regarding the cold-and-calculating aggravating factor did not constitute fundamental error, as the jury was instructed to disregard it. The court also found that the jury’s findings of aggravating circumstances and the imposition of the death penalty were supported by reasonable evidence and did not violate constitutional standards. View "STATE OF ARIZONA v STRONG" on Justia Law

Sutter’s Place, Inc., which operates Bay 101 Casino, challenged the City of San Jose's annual cardroom regulation fee, arguing it was an unconstitutional tax imposed without voter approval and violated due process. The fee was equally divided between Bay 101 and Casino M8trix, the only two cardrooms in the city. The plaintiff contended that the fee included costs outside the constitutional exception for regulatory charges and that the equal allocation was unfair.The Santa Clara County Superior Court held a bench trial and found the fee valid, covering reasonable regulatory costs and fairly allocated between the cardrooms. The court determined the fee was for regulatory functions, the amount was necessary to cover costs, and the equal allocation was reasonable given the equal number of tables and benefits to both cardrooms. The court also excluded certain expert testimony from the plaintiff and denied a separate due process trial.The California Court of Appeal, Sixth Appellate District, reviewed the case. It upheld the trial court's finding that the equal allocation of the fee was reasonable but reversed the judgment on other grounds. The appellate court found the trial court erred by not specifically determining whether all costs included in the fee fell within the constitutional exception for regulatory charges. The case was remanded for the trial court to identify and exclude any non-permissible costs from the fee and to conduct further proceedings on the due process claim if necessary. The appellate court also reversed the award of costs to the city and directed the trial court to reassess costs after applying the correct legal standards. View "Sutter's Place, Inc. v. City of San Jose" on Justia Law

Nathaniel DiMaggio filed a petition for writ of mandate to challenge the denial of his motion to suppress evidence obtained from his cellphone and tablet. DiMaggio argued that the Monterey County Sheriff’s Office exceeded the scope of the search warrant and that the trial court erred in finding the sheriff’s office acted in good faith. The Monterey County District Attorney contended that the sheriff’s office properly executed the search warrant and acted in good faith.The Monterey County Superior Court issued a search warrant authorizing the search of DiMaggio’s cellphone and tablet for evidence related to a sexual assault within a specific date range. During the search, the sheriff’s office found images of suspected child pornography, which were outside the specified date range. DiMaggio filed a motion to suppress this evidence, arguing it was obtained in violation of the Fourth Amendment. The trial court found that the sheriff’s office exceeded the scope of the warrant but denied the motion to suppress, applying the good faith exception to the exclusionary rule.The California Court of Appeal, Sixth Appellate District, reviewed the case and agreed with DiMaggio. The court found that the sheriff’s office knowingly exceeded the scope of the search warrant by including items without timestamps, which were not authorized by the warrant. The court held that the good faith exception did not apply because the actions of the sheriff’s office were not objectively reasonable and were part of a standard protocol that disregarded the warrant’s limitations. The court issued a peremptory writ of mandate directing the trial court to vacate its order denying the motion to suppress and to enter a new order suppressing any evidence obtained outside the date and time limitations set forth in the search warrant. View "DiMaggio v. Superior Court" on Justia Law

A group of plaintiffs, including Vicente Topasna Borja, challenged the federal Uniformed and Overseas Citizens Absentee Voting Act (UOCAVA) and Hawaii’s Uniform Military and Overseas Voters Act (UMOVA). Borja, a former Hawaii resident now living in Guam, argued that these laws violate equal protection by allowing former Hawaii residents who move abroad or to the Commonwealth of the Northern Mariana Islands (CNMI) to vote absentee in Hawaii’s federal elections, while those who move to other U.S. Territories cannot.The United States District Court for the District of Hawaii found that the plaintiffs had standing to challenge the enforcement of UOCAVA but granted summary judgment in favor of the defendants. The court held that the plaintiffs did not have a fundamental right to vote in Hawaii’s federal elections and that those who move from a state to a territory are not a suspect or quasi-suspect class. Therefore, the court applied rational basis review and concluded that UOCAVA and UMOVA satisfied this standard.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The Ninth Circuit held that rational basis review, not strict scrutiny, applies to UOCAVA and UMOVA’s overseas voting provisions. The court reasoned that these laws do not deprive residents within a geographically defined governmental unit from voting in a unit-wide election nor dilute the voting power of qualified voters within Hawaii. The court found that the differential treatment of former Hawaii residents who move to other U.S. Territories versus those who move abroad or to the CNMI is rationally related to legitimate governmental interests. The court also rejected the argument that individuals who move from Hawaii to other U.S. Territories constitute a suspect or quasi-suspect class warranting heightened scrutiny.The Ninth Circuit concluded that UOCAVA and UMOVA’s classifications satisfy rational basis review and affirmed the district court’s judgment in favor of the defendants. View "BORJA V. NAGO" on Justia Law

A group of LGBTQ+ students sued the U.S. Department of Education, alleging that they experienced discrimination at religious colleges and universities that receive federal funding. They challenged the religious exemption to Title IX, which allows religious institutions to discriminate based on gender if it conflicts with their religious tenets. The plaintiffs claimed this exemption violated the First Amendment's Establishment Clause and the Fifth Amendment's equal protection guarantee. They also argued that the Department's 2020 amendment to Title IX regulations, which clarified that institutions do not need to submit a written statement to claim the exemption, was arbitrary and capricious under the Administrative Procedure Act (APA).The United States District Court for the District of Oregon dismissed the plaintiffs' claims. It ruled that the plaintiffs failed to state a claim that the religious exemption violated the First and Fifth Amendments. The court also found that the plaintiffs lacked standing to challenge the 2020 amendment under the APA. The court denied the plaintiffs' motion to amend their complaint, concluding that any amendment would be futile.The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal. The Ninth Circuit held that the Title IX religious exemption does not violate the Establishment Clause under the historical practices and understanding test set forth in Kennedy v. Bremerton School District. The court found that the exemption is consistent with a long history of religious accommodations in U.S. law. The court also held that the exemption does not violate the Fifth Amendment's equal protection guarantee, as it is substantially related to the important governmental objective of accommodating religious exercise. Finally, the court agreed that the plaintiffs lacked standing to challenge the 2020 amendment, as they did not show that the rule caused them harm. The court also upheld the denial of leave to amend the complaint. View "HUNTER V. USEDU" on Justia Law

Williams Nunez was charged with rape for engaging in sexual intercourse with a person unable to consent due to intoxication. He admitted to the act but claimed the victim was not too intoxicated to consent. A jury convicted him, and the district court sentenced him to 155 months in prison with lifetime postrelease supervision, based on the finding that he was 18 years or older at the time of the crime.Nunez appealed, arguing that his Sixth Amendment rights under Apprendi v. New Jersey were violated because his age was not determined by the jury. The Kansas Court of Appeals affirmed his conviction and sentence, concluding that Nunez had sufficiently admitted his age through various documents and statements, and any Apprendi error was harmless.The Kansas Supreme Court reviewed the case to determine if Nunez's rights under Apprendi were violated. The court held that for a sentencing court to rely on a defendant's admission to increase a sentence, the admission must follow a knowing and voluntary waiver of the jury trial right. Since Nunez did not waive his jury trial rights regarding his age, the court found an Apprendi violation. The court also determined that the error was not harmless because the jury was not presented with evidence of Nunez's age.The Kansas Supreme Court reversed the Court of Appeals' decision, vacated the district court's sentence, and remanded the case for resentencing. The court directed that Nunez be sentenced to 60 months of postrelease supervision under K.S.A. 22-3717(d)(1)(G)(ii), as this was the appropriate term given the lack of a jury finding on his age. View "State v. Nunez" on Justia Law

The plaintiff, Jane Doe, challenged the Manchester School District's policy regarding transgender and gender non-conforming students. The policy allowed students to keep their transgender status private and required school personnel to use a student's preferred name and pronouns, without disclosing this information to parents unless legally required or authorized by the student. Jane Doe, the parent of a minor child (M.C.) in the district, discovered that M.C. had asked to be called by a different name and pronouns. She requested the school to use M.C.'s birth name and pronouns, but the school adhered to the district policy.The Superior Court dismissed Jane Doe's claims, finding that the policy did not infringe upon a fundamental right and thus did not warrant strict scrutiny. The court applied the rational basis test and concluded that the policy was constitutional. The court also found that the policy was not ultra vires and did not violate federal laws such as the Family Educational Rights and Privacy Act (FERPA) or the Protection of Pupil Rights Act (PPRA).The Supreme Court of New Hampshire reviewed the case and affirmed the lower court's decision. The court held that the policy did not directly interfere with the fundamental right to parent, as it did not prevent parents from obtaining information from other sources or restrict their ability to parent their child. The court agreed that the policy did not infringe on a fundamental right and thus was subject to rational basis review, which it survived. The court did not find it necessary to address the plaintiff's facial and as-applied challenges separately, as the policy was found to be constitutional under the rational basis test. View "Doe v. Manchester School District" on Justia Law

In 1987, Michael Hill was convicted of two murders and sentenced to death. Hill maintained that the murders were committed by Michael McCray, whose statements to the police incriminated both himself and Hill. McCray did not testify at trial, invoking his privilege against self-incrimination, but his statements were admitted under the hearsay rule. Decades later, Hill discovered that the prosecution had failed to disclose a promise not to prosecute McCray for his involvement in the case. Hill filed a habeas corpus petition alleging violations of Brady v. Maryland and Napue v. Illinois.The trial court dismissed Hill’s claims, finding he failed to establish a prima facie case. The court concluded that the evidence against Hill was overwhelming and that the failure to disclose the non-prosecution agreement did not undermine confidence in the verdict. The court also found that Hill did not plead that false evidence was presented to the jury, as required under Napue.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court found that Hill established a prima facie case for both Brady and Napue violations. The court noted that McCray’s testimony at the preliminary hearing was misleading and that the prosecution’s suppression of the non-prosecution agreement allowed McCray to assert his privilege against self-incrimination, leading to the admission of his statements without cross-examination. The court concluded that the suppressed evidence was material and could have affected the jury’s verdict. The court reversed the trial court’s order and remanded the case for further proceedings, directing the trial court to issue an order to show cause. View "In re Hill" on Justia Law

The case involves Jeremiah Ira Williams, who was sentenced to an indeterminate prison term of 100 years to life plus 86 years and two months for committing multiple forcible sexual offenses under California's One Strike law when he was 24 years old. Williams argued that the exclusion of One Strike offenders from early parole eligibility under California’s youth offender parole statute (Pen. Code, § 3051) violated his equal protection rights under the Fourteenth Amendment. He contended that it was irrational to exclude young adults convicted of One Strike offenses from early parole while not excluding young adults convicted of murder without special circumstances.The San Diego County Superior Court convicted Williams on multiple counts, including robbery, forcible rape, and sodomy by use of force, among others. The jury found him guilty on most counts and found true several aggravating factors, including personal use of a firearm and infliction of great bodily injury. The trial court imposed the lengthy sentence based on these findings. Williams appealed to the Fourth Appellate District, Division One, arguing that the exclusion of One Strike offenders from early parole eligibility violated equal protection. The Court of Appeal rejected his claim, finding a rational basis for the differential treatment based on the threat of recidivism by violent sexual offenders.The Supreme Court of California reviewed the case and affirmed the Court of Appeal’s judgment. The court held that the Legislature could rationally exclude One Strike offenders from early parole eligibility under section 3051 based on concerns about the high risk of recidivism and the aggravated nature of their offenses. The court concluded that these concerns provided a rational basis for the differential treatment, thus rejecting Williams' equal protection challenge. The court remanded the matter to the Court of Appeal to consider any briefing on Williams' entitlement to the benefit of any ameliorative legislation enacted during the pendency of his appeal. View "People v. Williams" on Justia Law