Justia Constitutional Law Opinion Summaries

The Supreme Court of Wisconsin ruled that certain legislative review provisions governing the Knowles-Nelson Stewardship Program, a land conservation initiative, were unconstitutional. The provisions in question allowed the Joint Committee on Finance (JFC), a legislative committee, to review and potentially block expenditures exceeding $250,000 or for land acquisitions outside of a project boundary, even after the legislature had already appropriated the funds.The case was brought by Governor Tony Evers and several state departments, who argued that these provisions violated the separation of powers by allowing the legislature to intrude on the executive branch's power to execute the law. The legislative respondents defended the statutes, arguing that they were necessary for overseeing the executive branch's expenditure of state funds.The Supreme Court of Wisconsin disagreed with the legislative respondents, ruling that the provisions unconstitutionally authorized the legislative branch to impede the executive's core power to execute the law. The court held that once the legislature appropriates funds for a particular purpose, the executive branch possesses the power to distribute those funds in accordance with the purposes outlined by the legislature. The court concluded that the legislative review provisions violated the separation of powers structurally enshrined in the Wisconsin Constitution. View "Evers v. Marklein" on Justia Law

The case involves Napoleao Pires, who was convicted for carrying a firearm without a license and possession of a controlled substance. The conviction was based on evidence obtained when a police officer, responding to a dispatch, stopped and searched Pires. The dispatch reported a man matching Pires' description walking around with a gun. Upon arrival, the officer did not observe any criminal activity or see a gun, but stopped Pires based on the dispatch information. Pires challenged the trial justice’s decision to deny his motion to suppress the evidence, arguing that the seizure violated his constitutional rights under the Fourth Amendment.The Superior Court held a hearing on the motion to suppress and concluded that the gun and cocaine had been lawfully seized. The court found that the officer's thirty years of experience, the dispatch sending him to a high-crime area, Pires' match to the dispatch description, Pires' noncompliance to the officer’s commands, and Pires' pivot to reach for his waistband amounted to the level of reasonable suspicion required to justify the warrantless stop.The Supreme Court of Rhode Island reversed the decision on the motion to suppress and vacated the judgment of conviction. The court held that Pires was seized the moment he complied with the officer’s order to raise his hands. The court found that the state failed to submit adequate evidence to show that reasonable suspicion existed at the inception of Pires' encounter with the officer. The court concluded that Pires' Fourth Amendment rights were violated because the state failed to submit adequate evidence to show that reasonable suspicion existed at the inception of his encounter with the officer. View "State v. Pires" on Justia Law

The case involves Keith Atherton, who pleaded guilty to one count of using or attempting to use a minor to produce a visual depiction of sexually explicit conduct. His plea agreement contained an appeal waiver with certain exceptions. Atherton was sentenced to the statutory maximum of 30 years. He appealed, arguing that the district court violated his due process rights during sentencing by relying on false or unreliable information.The United States Court of Appeals for the Ninth Circuit affirmed the sentence. The court held that a due process challenge to sentencing, like Atherton’s, falls within the appeal waiver limitation set forth in United States v. Wells, for “a challenge that the sentence violates the Constitution.” The court rejected the government’s contention that the Wells exception is limited to constitutional claims targeting the substantive terms of the sentence.Reviewing for plain error, the court held that Atherton’s due process rights were not violated. The court concluded that Atherton did not demonstrate that it is clear or obvious that the challenged information was patently false or unreliable or that the court relied upon the information in imposing sentence. View "United States v. Atherton" on Justia Law

The case revolves around Larry Sapp, an Army veteran with a history of felony drug convictions, who was elected to the Sauk Village Board of Trustees in Illinois. However, his felony convictions came to the attention of the Cook County State’s Attorney’s Office, which used two Illinois statutes to remove him from his position. These statutes bar certain felons from holding public office. Sapp challenged the constitutionality of these statutes, arguing that they violated the Eighth Amendment's clauses on Cruel and Unusual Punishment and Excessive Fines by barring him from public service and depriving him of the income a career in public service would generate.The Cook County Circuit Court rejected Sapp's arguments, ruling that the statutes' enforcement did not violate the Eighth Amendment. The court held that Sapp was ineligible to serve as a Board Trustee and removed him from his position. Sapp then filed a federal lawsuit against Illinois Governor J.B. Pritzker and State’s Attorney Kimberly Foxx, seeking to bar the Cook County State’s Attorney from enforcing either statute against him in future elections. He reiterated his Eighth Amendment arguments and added a new one, claiming that enforcing the statutes against him would violate the Cruel and Unusual Punishment Clause.The United States Court of Appeals for the Seventh Circuit affirmed the dismissal of Sapp’s complaint. The court did not reach the merits of Sapp's constitutional arguments, instead ruling that they were foreclosed by Illinois principles of collateral estoppel and res judicata. The court held that Sapp's federal lawsuit arose from the same group of operative facts as the State’s Attorney’s quo warranto action in Cook County Court, and thus constituted the same "cause of action" under Illinois law. As a result, Sapp was barred from raising arguments in the federal suit that were available to him in the quo warranto action. View "Sapp v. Foxx" on Justia Law

The case revolves around Jack Potter, a man who lived in a 23-foot travel trailer hitched to his truck, which he parked on public lots and streets in the city of Lacey, Washington. In 2019, the city passed an ordinance barring people from parking such large vehicles and trailers on public lots and streets for more than four hours per day. The city then ordered Potter to move his trailer and truck off the city hall parking lot and off Lacey streets. Potter sued the city, claiming that its new ordinance violated his state constitutional “right to reside,” which he argued was inherent in the state constitutional right to intrastate travel.The case was initially filed in Thurston County Superior Court but was later moved to the federal district court for the Western District of Washington. The district court granted summary judgment to the city on nearly all of its claims, including Potter’s state right to intrastate travel claim. The court explained that the ordinance did not fundamentally impede the right to exist or reside in a given area. It was a parking ordinance applicable to all people in Lacey, and only by extension did it restrict the manner in which a person could live in Lacey. The right to travel did not include a right to live in a certain manner.The case was then appealed to the Ninth Circuit Court of Appeals, which certified questions of state law to the Supreme Court of the State of Washington. The Supreme Court held that the RV parking ordinance did not violate Potter’s claimed Washington State constitutional right to intrastate travel. Potter had not established that his claimed right to reside was inherent in a Washington state constitutional right to intrastate travel or that it protected his preferred method of residing in Lacey: by siting his 23-foot trailer on a public street in violation of generally applicable parking ordinances. View "Potter v. City of Lacey" on Justia Law

The case involves James Herard, a member of the "BACC Street Crips," a branch of the national Crips gang. Herard was found guilty of 18 gang-related felonies, including the first-degree murders of Eric Jean-Pierre and Kiem Huynh. The crimes were committed as part of a body-count competition within the gang. Herard was sentenced to death for the murder of Jean-Pierre and life without parole for the murder of Huynh. He appealed his convictions and death sentence.Herard's trial was held in May 2014, where the prosecution presented evidence of incriminating statements made by Herard to law enforcement following his arrest for stealing a pit bull. The defense argued that Herard's statements were inconsistent, unreliable, and involuntary. The jury found Herard guilty on 18 counts and not guilty on a robbery count.In the penalty phase, the jury recommended a death sentence for the murder of Jean-Pierre by a vote of 8 to 4. The trial court found that the State had proven three aggravating circumstances beyond a reasonable doubt and sentenced Herard to death for the Jean-Pierre murder and to life without the possibility of parole for the Huynh murder.The Supreme Court of Florida affirmed the lower court's decision. The court rejected Herard's arguments that the trial court erred in denying his due process-based motion to dismiss, denying his motions to suppress incriminating statements, admitting physical evidence he claimed was unrelated to the crimes charged, excluding his expert witness testimony about false confessions, and sentencing him in a manner that violated the Sixth and Eighth Amendments. The court also found that there was sufficient evidence to sustain Herard’s conviction for the murder of Eric Jean-Pierre. View "Herard v. State of Florida" on Justia Law

In February 2021, Salvador Salas, Jr. was accused of giving methamphetamine to a 13-year-old girl, sexually abusing her, and photographing the incident. The police obtained a warrant to search Salas's home and vehicle for drugs and related evidence. During the search, they seized Salas's iPhone and a hard drive. Suspecting Salas of producing or possessing child pornography, the officers obtained a second warrant to search for such evidence. They seized a laptop and another hard drive from Salas's residence. A digital forensic analyst found child pornography on Salas's iPhone and on the laptop and hard drive. Salas was charged with six federal counts of possessing and producing child pornography.Salas argued that the second warrant lacked probable cause and violated his Fourth Amendment rights. He also argued that the child pornography on his iPhone, seized under the first warrant, would not have been inevitably discovered because the first warrant only authorized the seizure, not the search, of his iPhone. The district court agreed that the second warrant lacked probable cause but declined to suppress the child pornography evidence. It found that the first warrant allowed for both the seizure and search of Salas's iPhone and therefore child pornography would have been inevitably discovered by the officers as part of their investigation into Salas's drug activities. Salas was convicted on all counts and appealed.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court held that the first warrant was sufficiently particular to justify a search of Salas's iPhone and the search would have been conducted reasonably. The court also held that the child pornography on Salas's iPhone would have been inevitably discovered because the first warrant allowed for both the seizure and search of Salas's iPhone. The court concluded that Salas's child pornography would not have indefinitely stayed hidden behind his iPhone's locked passcode. It would have inevitably been discovered. View "U.S. v. Salas" on Justia Law

The case involves the Upstate Jobs Party (UJP) and two of its leaders who sued the Commissioners of the New York State Board of Elections over campaign finance regulations. UJP, an independent body, argued that it is similarly situated to political parties because both nominate candidates that compete in the same elections. UJP claimed that New York's preferential treatment of parties violates the Fourteenth Amendment right to equal protection. UJP also asserted First Amendment violations, alleging that New York's campaign finance rules distinguishing between parties and independent bodies are not closely drawn to a sufficient state interest in preventing corruption or the appearance thereof.The United States District Court for the Northern District of New York determined that differences in contribution limits applicable to parties and independent bodies violate the Fourteenth and the First Amendments. However, it also determined that allowing parties but not independent bodies to maintain so-called “housekeeping accounts” did not violate either amendment. Both UJP and the State Board appealed.The United States Court of Appeals for the Second Circuit reversed in part and affirmed in part the district court’s judgment. The court held that parties and independent bodies are not similarly situated, and that the state’s contribution limits and housekeeping account exception are closely drawn to serve the state’s anticorruption interests. Therefore, the court concluded that the state’s campaign finance laws withstand all constitutional challenges raised. View "Upstate Jobs Party v. Kosinksi" on Justia Law

The defendant, Avram M. Niebling, was arrested for driving under the influence. During the arrest, the officer conducted a pat-down search and removed a wallet from the defendant's pocket. The wallet was not searched at the scene but was placed in an evidence bag and taken to the police station. At the station, during the booking process, the officers counted the cash in the wallet and looked inside for the defendant's driver's license. In doing so, they discovered two white pills identified as oxycodone. The defendant was subsequently charged with possession of a controlled drug.The defendant moved to suppress the evidence obtained from the wallet, arguing that there was no applicable exception to a warrantless search of the wallet during the booking process. The Superior Court denied the motion, finding that the search of the wallet constituted a search incident to arrest. The defendant appealed, arguing that the warrantless search of his wallet was neither conducted incident to arrest nor conducted pursuant to a neutral inventory policy, and was therefore unreasonable and unconstitutional.The Supreme Court of New Hampshire affirmed the lower court's decision. The court held that a search that may be made at the time and place of arrest also may be legally conducted when the arrested individual later arrives at a place of detention. The court found that because the defendant's wallet was seized during a lawful arrest, the officer was permitted to search it at the police station during the booking process without a warrant. The court distinguished this case from others where the property was searched at the officer's convenience after passage of appreciable time and was at all times under the exclusive control of the arresting officer. In this case, the arresting officer obtained possession of the defendant's wallet during a lawful arrest and looked inside it at the time of the defendant's booking at the police station while the defendant was present. Therefore, the court held that the trial court did not err in determining that the search of the wallet fell within the search incident to arrest exception to the warrant requirement. View "State v. Niebling" on Justia Law

The case revolves around a medical malpractice and hospital negligence claim filed by Jami Lynn Golden against Floyd Healthcare Management, Inc. Golden visited Floyd Emergency Care Center in July 2016, complaining of abdominal pain, fever, chills, and nausea. Despite a computer-generated sepsis alert, Golden was discharged with instructions to follow up in two to three days. Her condition worsened, and she was later admitted to Redmond Regional Medical Center Intensive Care Unit in septic shock. As a result, Golden suffered necrosis that required the amputation of parts of her fingers and toes.Floyd Healthcare Management moved to dismiss Golden's claim, arguing that the five-year medical malpractice statute of repose had expired. The trial court denied the motion, concluding that the repose statute was tolled by the "Order Declaring Statewide Judicial Emergency" issued in response to the COVID-19 pandemic. However, the Court of Appeals reversed this decision, holding that the repose statute was not tolled by the emergency order.The Supreme Court of Georgia reversed the Court of Appeals' decision. It held that the emergency order did indeed toll the repose statute, and that there was no impediment in the federal or Georgia Constitutions for the statute of repose to be tolled. The court concluded that Golden's claims were not time-barred, and that the application of the emergency order to toll the repose statute did not violate Floyd Healthcare Management's due process rights. View "GOLDEN v. FLOYD HEALTHCARE MANAGEMENT, INC." on Justia Law