Justia Constitutional Law Opinion Summaries

In November 2004, a sixteen-year-old juvenile stalked and robbed a victim at gunpoint, repeatedly raped her in her home, and then bound, gagged, and robbed her roommate when she arrived. He was sentenced to state prison for aggravated rape and other offenses, with a period of parole ineligibility compliant with constitutional requirements. After serving his prison term, he was placed on probation for the remaining nonhomicide offenses.In March 2007, the juvenile was adjudicated as a youthful offender and sentenced to sixteen to twenty years in state prison for aggravated rape, with additional concurrent and consecutive sentences for other offenses. In 2021, following a court decision, his sentence was restructured to comply with constitutional requirements, reducing his parole ineligibility to fifteen years. He was released from prison in January 2022 and began a five-year probation term. In August 2022, he was arrested for new offenses, leading to a probation violation notice and detention.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the restructured sentence, including the probation term, did not violate constitutional protections against cruel or unusual punishment. The court emphasized that the probation term provided the juvenile with an opportunity for rehabilitation and reintegration into the community. The court also noted that any potential further incarceration resulting from a probation violation would be subject to constitutional constraints, ensuring that the juvenile would not be treated more harshly than a juvenile convicted of murder for parole eligibility purposes. The court affirmed the order denying the juvenile's motion for relief from unlawful restraint. View "Commonwealth v. Sajid S." on Justia Law

The case revolves around Candice Lea Davis, who was arrested for driving under the influence (DUI) after her vehicle was found high-centered on a rock berm. Davis had red and watery eyes, and the officer detected the smell of alcohol from her vehicle. She admitted to having a drink after her shift at work. Due to adverse weather conditions, the officer decided to conduct standardized field sobriety tests (SFSTs) at the Sheriff’s Office. Davis was handcuffed for transportation but was informed that she was not under arrest. After performing poorly on the SFSTs and a breath test at the Sheriff’s Office, Davis was arrested for DUI.Davis was convicted on all counts in Justice Court and appealed to the District Court for a trial de novo. She filed a motion to suppress, arguing that she was subjected to a custodial interrogation without being advised of her Miranda rights and that all evidence obtained after she was handcuffed should be suppressed. The State argued that the officer had particularized suspicion that Davis was driving under the influence. The District Court denied Davis's motion to suppress, reasoning that the officer had particularized suspicion to extend the stop at each step of his investigation.The Supreme Court of the State of Montana affirmed the District Court's decision. The court concluded that there was probable cause to believe Davis had committed the offense of DUI when she was placed in handcuffs and taken to the Sheriff’s Office for testing. The court also found that Davis's Miranda rights were not violated as she was not subjected to a custodial interrogation. The court held that the results of the SFSTs and breath test did not require a Miranda warning as they were not self-incriminating statements that must be suppressed in the absence of a Miranda waiver. View "State v. Davis" on Justia Law

The case involves Zackary Sanders, who was convicted for violating federal child pornography laws. Sanders had engaged in communications with underage boys, some as young as 13 years old, through various social media and communication applications. He had the minors send him explicit videos and pictures of themselves, some of which he later used as blackmail. Sanders stored these videos and photos, as well as other depictions of child pornography downloaded from the Internet, on the same electronic devices that he used to communicate with the minors. Sanders was indicted in 12 counts for the production, receipt, and possession of child pornography.The district court ordered the forfeiture of nine electronic devices on which Sanders stored child pornography and with which he committed the crimes. Sanders objected to the forfeiture, contending that the forfeiture statute did not reach so broadly as to require the forfeiture of non-contraband items that were also stored on the electronic devices. He requested that the district court order the government to allow his forensic expert to segregate and make digital copies of non-contraband items. The district court refused his request.On appeal, Sanders challenged the district court’s reading of the forfeiture statute. He also claimed, for the first time on appeal, that the forfeiture order’s inclusion of his non-contraband items was “plainly excessive under the Eighth Amendment.” The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the forfeiture statute required the forfeiture of electronic devices that contain visual depictions of child pornography. The court also concluded that the forfeiture of the nine electronic devices, with the data contained on them at the time of forfeiture, was not grossly disproportional to the gravity of the offenses for which Sanders was convicted. View "U.S. v. Sanders" on Justia Law

Dr. Anthony Tufaro, a former Chief of Plastic & Reconstructive Surgery and Professor of Medicine at the University of Oklahoma (OU), filed a lawsuit against OU and three of its doctors after his contract was not renewed. Tufaro alleged that his contract was not renewed because he had exposed various discrepancies and misconduct within OU’s Medical and Dental Colleges. His claims included wrongful termination, First Amendment retaliation, Fourteenth Amendment deprivation of property and liberty, breach of contract, and violation of the Oklahoma Constitution.The case was initially filed in state court but was later removed to federal court. In the federal court, the defendants filed a motion to dismiss, which the court granted in part and denied in part. The court dismissed all the § 1983 claims against OU and the individual defendants in their official capacities, as they were not considered "persons" under § 1983. The court also dismissed the breach of contract claim against OU, as it found that OU had followed the procedures outlined in the Faculty Handbook. However, Tufaro's Burk tort claim against OU survived the motion to dismiss.After discovery, the defendants filed a motion for summary judgment, which the court granted. The court ruled that Tufaro's complaints fell outside the scope of the First Amendment because they were made during his employment as part of his official duties. The court also held that Tufaro failed to demonstrate he was an "at-will" employee, an essential element of the Burk tort claim. Following the entry of summary judgment on all remaining claims, the district court entered final judgment, ending Tufaro’s case. Tufaro appealed several of the district court's rulings. View "Tufaro v. Board of Regents of the University of Oklahoma" on Justia Law

The defendant, Jason Ortiz, was charged with several criminal counts, including carrying a pistol without a license, domestic assault, resisting arrest, and disorderly conduct. The charges stemmed from an incident in which Ortiz was apprehended by police after a domestic dispute. The police found a pistol in the vicinity of Ortiz's arrest, and DNA evidence linked Ortiz to the weapon. Ortiz was nineteen years old and a resident of Massachusetts at the time of his arrest.In the Superior Court for Providence County, Ortiz filed a motion to dismiss the charge of carrying a pistol without a license, arguing that the Rhode Island statute requiring a license to carry a pistol violated his Second Amendment rights. The state objected, arguing that Ortiz lacked standing to challenge the statute because he had never applied for a license and therefore had not been denied one. The trial justice denied Ortiz's motion to dismiss, finding that Ortiz lacked standing to challenge the statute and that the statute was reasonably adopted to address the government's interest in reducing gun violence. After a bench trial, Ortiz was found guilty of carrying a pistol without a license and sentenced to five years imprisonment, with eighteen months to serve and the balance of the sentence suspended, with probation.On appeal to the Supreme Court of Rhode Island, Ortiz argued that the trial justice erred in denying his motion to dismiss. He contended that the licensing statute violated his Second Amendment rights and that he had standing to challenge the statute because he was being punished for violating it. The state argued that Ortiz lacked standing to challenge the statute because he had not applied for a license. The Supreme Court affirmed the judgment of the Superior Court, holding that Ortiz lacked standing to challenge the licensing statute because he had not applied for a license and would not have qualified for one had he applied due to his age and residency. The court declined to reach Ortiz's arguments regarding the constitutionality of the licensing statute. View "State v. Ortiz" on Justia Law

In 1993, William E. Neilly was convicted of first-degree felony murder, felon in possession of a firearm during the commission of a felony, and conspiracy to commit armed robbery. He was sentenced to life imprisonment without parole. However, subsequent rulings by the United States Supreme Court deemed mandatory life without parole sentences for defendants who committed crimes when under the age of 18 years old as unconstitutional. As a result, Neilly was resentenced to 35 to 60 years in prison. The trial court also ordered Neilly to pay $14,895.78 in restitution to the victim’s family for funeral expenses.Neilly appealed the restitution order, arguing that it violated the Ex Post Facto Clauses of the United States and Michigan Constitutions. He contended that the trial court ordered restitution under the current restitution statutes rather than the former restitution statutes in effect when he was originally sentenced in 1993. The Court of Appeals rejected Neilly’s argument, reasoning that restitution is a civil remedy and not punishment, and its imposition did not result in an increase in punishment in violation of the Ex Post Facto Clauses.The Michigan Supreme Court affirmed the lower court's decision. The court held that restitution imposed under the current statutes is a civil remedy, not a criminal punishment. Therefore, applying the restitution statutes to defendants whose criminal acts predate the enactment of the restitution statutes does not violate the Ex Post Facto Clauses of the United States and Michigan Constitutions. The court concluded that the trial court’s restitution order was affirmed. View "People v. Neilly" on Justia Law

The case involves two Georgia non-profit organizations, New Georgia Project and New Georgia Project Action Fund (collectively referred to as "New Georgia"), and the Georgia Government Transparency and Campaign Finance Commission. New Georgia was accused of violating the Georgia Government Transparency and Campaign Finance Act by failing to register with the Commission and disclose their campaign expenditures and sources. The Commission initiated an investigation and found "reasonable grounds" to conclude that New Georgia had violated the Act.New Georgia then filed a federal lawsuit claiming that the Act violated the First and Fourteenth Amendments. The district court granted a preliminary injunction preventing the state from enforcing the Act against New Georgia. The state appealed, arguing that the district court should have abstained from exercising its jurisdiction under the doctrine established in Younger v. Harris.The United States Court of Appeals for the Eleventh Circuit held that the district court should have abstained under the Younger doctrine. The court found that the state's enforcement action against New Georgia was ongoing and implicated important state interests, and that New Georgia had an adequate opportunity in the state proceeding to raise constitutional challenges. The court vacated the district court's decision and remanded with instructions to dismiss New Georgia's action. View "New Georgia Project, Inc. v. Attorney General" on Justia Law

The case involves a constitutional challenge to the Horseracing Integrity and Safety Act of 2020 (“HISA”). The Act empowers a private corporation, the Horseracing Integrity and Safety Authority (“Authority”), to create and enforce nationwide rules for thoroughbred horseracing. The plaintiffs, a group of horsemen's associations and other stakeholders in the horseracing industry, argued that the Act violated the private nondelegation doctrine, the Due Process Clause, the Appointments Clause, and the Tenth Amendment.The district court had previously held that an amendment to the Act, which gave the Federal Trade Commission (FTC) the power to abrogate, add to, or modify the Authority’s rules, cured the Act’s constitutional deficiencies. The district court also rejected claims that the Act violated the Constitution’s Appointments Clause and the Tenth Amendment.On appeal, the United States Court of Appeals for the Fifth Circuit agreed with the district court that the FTC’s new rulemaking oversight meant the agency was no longer bound by the Authority’s policy choices, thereby resolving the nondelegation problem with the Authority’s rulemaking power. The court also agreed that the Act did not violate the Due Process Clause or the Appointments Clause.However, the court disagreed with the district court regarding the Act’s enforcement provisions. The court held that the Act’s enforcement provisions, which empowered the Authority to investigate, issue subpoenas, conduct searches, levy fines, and seek injunctions without the FTC’s approval, violated the private nondelegation doctrine. The court declared these enforcement provisions facially unconstitutional. The court also affirmed the district court’s finding that one of the plaintiffs lacked standing to bring a Tenth Amendment challenge. View "National Horsemen’s Benevolent and Protective Association v. Black" on Justia Law

The case involves a challenge to a series of statutes and implementing regulations ("Challenged Laws") relating to the licensure of abortion provider facilities in Kansas. The plaintiffs, an abortion care facility and its doctors, argued that the Challenged Laws infringed on a woman's fundamental right to personal autonomy, which includes the right to abortion, as protected under section 1 of the Kansas Constitution Bill of Rights. The district court agreed and issued a permanent injunction restraining the State from enforcing the Challenged Laws.The State appealed the decision, arguing that the Challenged Laws did not infringe on the right to abortion and that they survived strict scrutiny because they furthered the State's compelling interest in protecting maternal health and regulating the medical profession. The State also argued that the district court erred in striking down the Challenged Laws in their entirety, ignoring the statute's severability clause.The Supreme Court of the State of Kansas affirmed the district court's decision. The court held that the Challenged Laws did infringe on a woman's right to abortion and that the State failed to meet its burden to show that the laws furthered its stated compelling interests. The court also found it improper to sever the unconstitutional substantive licensure requirements from the statute. The court declined to address the equal protection issues raised by the State. View "Hodes v. Stanek" on Justia Law

The case involves a Kansas law, S.B. 95, which effectively bans a common method of second-trimester abortion known as Dilation and Evacuation (D & E), except when necessary to preserve the life of the pregnant woman or to prevent substantial and irreversible physical impairment of a major bodily function. The law was challenged by doctors who perform D & E abortions in Kansas, arguing that it violates the Kansas Constitution Bill of Rights.The district court granted a temporary injunction, concluding that the Kansas Constitution protects a right to abortion. The Court of Appeals affirmed the district court's decision, and the case was appealed to the Supreme Court of Kansas. The Supreme Court affirmed the temporary injunction, ruling that the Kansas Constitution Bill of Rights protects a right to choose whether to continue a pregnancy and that any government infringement of that right must withstand strict scrutiny. The case was remanded to the district court to apply this standard.On remand, the district court granted summary judgment for the doctors, holding that the law does not withstand strict scrutiny and consequently violated the Kansas Constitution Bill of Rights. The State appealed to the Supreme Court of Kansas.The Supreme Court of Kansas affirmed the district court's decision. The court held that the State failed to show that the law is narrowly tailored to further any compelling interest. The court struck down the law as an unconstitutional violation of section 1 of the Kansas Constitution Bill of Rights. View "Hodes v. Kobach" on Justia Law