Justia Constitutional Law Opinion Summaries

The defendant faced serious felony charges and underwent two trials, both ending in mistrials. The second mistrial occurred because a courtroom clerk mistakenly gave the jury an exhibit revealing the defendant's prior felony conviction, which had been excluded from the jury's consideration. The defendant moved to dismiss the charges with prejudice, arguing that a retrial was barred by the former jeopardy provision in the Oregon Constitution, as interpreted in State v. Kennedy. The trial court denied the motion, concluding it could not find "indifference" under the Kennedy test.The Multnomah County Circuit Court initially declared a mistrial due to a deadlocked jury. Months later, a juror contacted the defendant's counsel, revealing that the jury had seen an exhibit disclosing the defendant's prior conviction. The trial court then changed the basis for the mistrial to include the erroneous submission of the exhibit. After further hearings and testimony from jurors and the clerk's supervisor, the trial court found that the clerk had made an error but did not intentionally give the jury the exhibit knowing it disclosed the prior conviction. The court could not determine whether the clerk was indifferent or simply lacked the capacity to do her job.The Oregon Supreme Court reviewed the case and denied the petition for a writ of mandamus. The court held that the record did not compel findings that the clerk knowingly engaged in improper and prejudicial conduct or acted with indifference to the consequences. The court emphasized that the Kennedy test requires a conscious choice of prejudicial action, which was not evident in this case. Therefore, the trial court was not compelled to dismiss the charges with prejudice, and a retrial was not barred under the Oregon Constitution. View "State v. Blackmon" on Justia Law

The petitioner was arrested under a warrant for allegedly violating Maryland's juror intimidation statute. After a bench trial, the circuit court acquitted her based on its interpretation of the statute. Subsequently, the petitioner filed a civil suit against a sheriff’s deputy, claiming false arrest, false imprisonment, malicious prosecution, and violations of her rights under the Maryland Declaration of Rights. The deputy had filed the application for charges after consulting with the State’s Attorney’s Office, which determined that the petitioner’s conduct violated the statute.The Circuit Court for Wicomico County granted summary judgment in favor of the State, ruling that the deputy could not be held civilly liable for the petitioner’s arrest pursuant to a warrant issued by a judicial officer. The Appellate Court of Maryland affirmed this decision, concluding that the warrant provided legal justification for the arrest and that the officers’ interpretation of the statute was objectively reasonable.The Supreme Court of Maryland reviewed the case and upheld the lower courts' decisions. The Court held that the circuit court did not err in granting summary judgment in favor of the State on the common law claims of malicious prosecution, false arrest, and false imprisonment, as well as on the constitutional claims under Articles 24 and 26 of the Maryland Declaration of Rights. The Court emphasized that when an arrest is made pursuant to a warrant, probable cause is predetermined by a judicial officer, creating a strong presumption of objective reasonableness. The petitioner failed to overcome this presumption.Additionally, the Court held that the circuit court did not err in granting summary judgment on the petitioner’s claim that her arrest and imprisonment violated her free speech rights under Article 40. The Court found that the judicial officer had probable cause to believe that the petitioner’s speech constituted a “true threat” and thus fell outside the protections of Article 40. Finally, the Court upheld the circuit court’s ruling that the juror intimidation statute was not unconstitutionally vague. View "Rovin v. State" on Justia Law

Mark Rath and Heather Zins share a child, A.J.O., born in 2004. Zins was awarded primary residential responsibility, and Rath was ordered to pay child support. A.J.O. turned 18 in November 2022, ending Rath's ongoing support obligation, but he had accrued arrears. Rath was served with an order to show cause for civil contempt due to non-payment. After an evidentiary hearing, a judicial referee found Rath in contempt and ordered him to make monthly payments towards his arrears, with a suspended 20-day jail sentence contingent on a future hearing.Rath sought review by the District Court of Burleigh County, which adopted the judicial referee's findings. Rath appealed, arguing violations of his right to counsel, errors in child support calculations, and that the Federal Consumer Credit Protection Act limits the State's ability to collect more than fifty percent of his income. He also claimed the defense of laches and third-party standing should prevent enforcement of his obligations.The North Dakota Supreme Court reviewed the case under a clearly erroneous standard. The court held that Rath's Sixth Amendment right to counsel was not violated because the contempt hearing did not result in immediate incarceration, and procedural safeguards were followed. The court also found that Rath's child support obligation continued despite temporary custody by the division of juvenile services and that the doctrine of laches does not apply to child support arrearages. Additionally, the court ruled that the State and Zins have standing to collect arrears even after the child reached the age of majority, and the Federal Consumer Credit Protection Act does not limit the State's collection efforts in this context. The Supreme Court affirmed the district court's decision. View "Burleigh County Social Service Board v. Rath" on Justia Law

Thomas Zundel attempted to purchase a firearm but was denied due to a 1990 simple assault charge in Jamestown Municipal Court, which was flagged in the National Instant Criminal Background Check System (NICS). The charge was noted as continued for a year pending counseling, with no conviction confirmed. Zundel's voluntary appeal to the FBI was denied because the final disposition of the case was missing. Zundel sought records from various agencies, but none had documentation beyond the initial arrest. He then petitioned the North Dakota Supreme Court for a writ of mandamus to close the case and restore his constitutional rights.The Jamestown Municipal Court and other respondents argued that Zundel had an adequate remedy in federal court, referencing Ross v. Fed. Bureau of Alcohol, Tobacco, Firearms, and Explosives. However, the North Dakota Supreme Court found that a federal suit would not adequately address the state court records issue. The court emphasized the municipal court's duty to maintain accurate records and noted that the missing record should have been retained permanently according to administrative rules.The North Dakota Supreme Court granted the petition in part, ordering the Jamestown Municipal Court to conduct a diligent inquiry to locate or reconstruct the missing record and document the results. The court denied Zundel's requests for declaratory relief regarding the nature of the 1990 charge and his right to possess a firearm, citing a lack of evidence in the record to make such determinations. The court's decision underscores the importance of accurate court records for due process and public accountability. View "Zundel v. City of Jamestown" on Justia Law

The case involves a challenge to the Parental Consent for Abortion Act of 2013 (Consent Act) in Montana, which requires minors to obtain parental consent or a judicial waiver to have an abortion. The plaintiffs, Planned Parenthood of Montana and Dr. Samuel Dickman, argue that the Act violates the Montana Constitution by infringing on minors' fundamental rights to privacy and equal protection.The First Judicial District Court in Lewis and Clark County initially issued a preliminary injunction against the Consent Act, keeping the Parental Notice of Abortion Act of 2011 (Notice Act) in effect. The District Court later granted summary judgment in favor of Planned Parenthood, ruling that the Consent Act violated the Montana Constitution. The court found that the Act was not narrowly tailored to achieve the State's compelling interests, such as protecting minors from sexual offenses, ensuring informed decision-making, and promoting parental rights. The court did not address the equal protection challenge but noted that the Notice Act, while serving similar ends, was less onerous.The Montana Supreme Court reviewed the case de novo. The Court held that the Consent Act violates minors' fundamental rights to privacy and equal protection under the Montana Constitution. The Court found that the Act's classification between minors seeking abortions and those carrying pregnancies to term was unjustified. The State failed to demonstrate that the Act was narrowly tailored to serve compelling state interests, such as protecting minors from sexual victimization, psychological and physical harm, and immaturity, or promoting parental rights. The Court also found that the judicial waiver provision did not save the Act, as it introduced unnecessary delays and burdens on minors seeking abortions.The Montana Supreme Court concluded that the Consent Act infringes on minors' fundamental rights without adequate justification and does not enhance their protection. Therefore, the Court held that the Consent Act is unconstitutional. View "Planned Parenthood v. State" on Justia Law

Four female hockey players filed a lawsuit against the University of North Dakota, alleging that the university violated Title IX by eliminating the women’s ice hockey program after the 2016-17 season. None of the plaintiffs were enrolled at the university at the time of the program's termination. They sought to represent a class of current, prospective, and future female students and requested a declaratory judgment and an injunction to reinstate the women’s hockey program.The United States District Court for the District of North Dakota dismissed the case for lack of jurisdiction, finding that the plaintiffs did not demonstrate a "concrete" injury as required for standing under Article III.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that two plaintiffs, Calli Forsberg and Maya Tellmann, had standing. Forsberg was recruited to play for the university’s hockey team but chose another school after the program was cut. Tellmann, a two-time state hockey champion, was accepted as a student but had no opportunity to play due to the program's elimination. Both plaintiffs demonstrated a concrete injury by being denied the opportunity to compete for the team of their choice, and they expressed a definite intent to attend the university if the program were reinstated.The court found that the other two plaintiffs, Emily Becker and Morgan Stenseth, did not allege sufficient facts to establish standing. Becker did not provide details about her qualifications or acceptance to the university, and Stenseth did not express an intent to attend the university in the future.The Eighth Circuit reversed and remanded the case in part, allowing Forsberg and Tellmann’s claims to proceed, but affirmed the dismissal of Becker and Stenseth’s claims. View "Becker v. North Dakota University System" on Justia Law

Two non-domiciliary companies, S&H Independent Premium Brands East, LLC, and S&H Independent Premium Brands West, LLC, import and distribute European alcoholic beverages in the United States. They hold certificates of compliance under Massachusetts General Laws Chapter 138, Section 18B, allowing them to sell alcoholic beverages to licensed wholesalers in Massachusetts. In 2019, an Austrian malt beverage producer, Stiegl Getränke & Service GmbH & Co. KG, terminated its distribution agreement with S&H without prior notice and entered into a new agreement with another distributor, Win-It-Too, Inc.S&H filed a petition with the Alcoholic Beverages Control Commission (ABCC), alleging that Stiegl violated Massachusetts General Laws Chapter 138, Section 25E, which prohibits suppliers from refusing to sell to any licensed wholesaler without good cause. The ABCC dismissed the petition, stating that Section 25E protections apply only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. S&H then sought judicial review in the Superior Court, which upheld the ABCC's decision, agreeing that Section 25E protections do not extend to Section 18B certificate holders.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the lower court's decision. The Court held that the term "any licensed wholesaler" in Section 25E refers only to wholesalers licensed under Section 18, not to certificate holders under Section 18B. The Court also concluded that this interpretation does not violate the dormant commerce clause of the United States Constitution, as Section 18B certificate holders and Section 18 licensed wholesalers serve different roles in the regulatory framework. Therefore, the ABCC's decision to dismiss S&H's petition was upheld. View "S&H Independent Premium Brands East, LLC v. Alcoholic Beverages Control Commission" on Justia Law

This case involves a dispute over the sale of surplus state property owned by the Idaho Transportation Department (ITD). The property, located at 3311 West State Street in Boise, was declared surplus after a flood rendered its largest building unusable. The Idaho Department of Administration (DOA) initiated a bidding process, and the petitioners, a group of business entities, submitted the highest bid. Despite negotiating a purchase and sale agreement, the DOA did not finalize the sale due to legislative actions that revoked its authority to dispose of the property and transferred control back to the ITD Board.The petitioners filed an original action in the Idaho Supreme Court seeking writs of prohibition and mandate. They argued that the legislative provisions revoking the DOA's authority were unconstitutional, violating the single-subject rule of the Idaho Constitution. They sought a declaratory judgment to invalidate these provisions and compel the DOA to complete the sale. The Idaho House of Representatives and its Speaker intervened, and the State Board of Examiners disclaimed further participation, having fulfilled its statutory duties.The Idaho Supreme Court held that the petitioners lacked standing to bring the action. The court found that while the petitioners demonstrated a distinct and palpable injury from the halted sale, they failed to show that a favorable decision would redress their injury. The court noted that the petitioners did not have a legally enforceable right to purchase the property, as the DOA had discretion in concluding the sale. Additionally, the court determined that the petitioners did not meet the criteria for relaxed standing, as other parties, such as the DOA and ITD, could potentially bring the constitutional claim. Consequently, the court dismissed the petition for writs of prohibition and mandate. View "Hawkins Companies, LLC v. State" on Justia Law

In 1997, John Doe pleaded guilty to two class C felonies: deviate sexual assault in the first degree and sexual assault in the first degree. He was placed on probation for five years and registered as a sex offender under the Missouri Sex Offender Registry Act (MO-SORA). After completing probation in 2002, his criminal records were sealed. Despite this, Doe remained on the sex offender registry. Over the years, MO-SORA was amended to include more stringent requirements, such as public disclosure of registrants' information, in-person reporting, and lifetime registration for certain offenses.Doe filed a petition for declaratory and injunctive relief in the Circuit Court of St. Louis County, arguing that the amendments to MO-SORA violated his substantive due process rights and constituted an ex post facto law. The circuit court ruled against Doe on all claims, leading to his appeal.The Supreme Court of Missouri reviewed the case and affirmed the lower court's judgment. The court held that Doe has no fundamental right to privacy in the information required by the registry, as the information was already public before his records were sealed. The court found that MO-SORA is rationally related to the legitimate state interest of protecting children and public safety. Additionally, the court determined that MO-SORA is civil in nature and does not constitute a punitive ex post facto law. The court concluded that the registration requirements, including lifetime registration and in-person reporting, are not excessive and serve the non-punitive purpose of public safety. Therefore, the court upheld the constitutionality of MO-SORA's registration requirements. View "Doe v. Olson" on Justia Law

In 2007, Luis Fernandez and others conspired to rob a fictional cocaine stash house set up by law enforcement. They were arrested en route to the stash house with loaded firearms. Fernandez was indicted on multiple charges, including conspiracy and attempt to possess cocaine, conspiracy and attempt to commit Hobbs Act robbery, and carrying a firearm in furtherance of a crime of violence or drug trafficking crime under 18 U.S.C. § 924(c). The jury found him guilty of the Hobbs Act charges and the § 924(c) charge but acquitted him of the drug-related charges. He was sentenced to 360 months in prison.Fernandez's direct appeal was unsuccessful. In 2016, he filed a motion under 28 U.S.C. § 2255 to vacate his sentence, arguing that his § 924(c) conviction was invalid under Johnson v. United States, which invalidated the residual clause of the Armed Career Criminal Act (ACCA). The district court denied the motion as untimely and procedurally defaulted. In 2020, Fernandez sought to file a second § 2255 motion based on United States v. Davis, which invalidated § 924(c)’s residual clause. The Eleventh Circuit granted his motion, acknowledging that his conviction might be unconstitutional under Davis.The United States Court of Appeals for the Eleventh Circuit reviewed Fernandez's appeal. The court held that Fernandez could not prove that his § 924(c) conviction rested solely on the residual clause, as required by Beeman v. United States. The court noted that the jury's general verdict did not specify which predicate offense supported the § 924(c) conviction. Additionally, the court found that the legal landscape at the time of Fernandez's conviction did not clearly establish that only the residual clause could support his conviction. Consequently, the court affirmed the district court's denial of Fernandez's § 2255 motion. View "Fernandez v. United States" on Justia Law