Justia Constitutional Law Opinion Summaries

Trenton Jefferson was tried for first degree murder in the circuit court of St. Clair County. The jury found him guilty but answered negatively to a special interrogatory asking if the State had proven beyond a reasonable doubt that Jefferson personally discharged a firearm causing the victim’s death. The appellate court reversed Jefferson’s conviction for unrelated reasons and ordered a new trial. Jefferson then argued that the jury’s answer to the special interrogatory, under the doctrine of issue preclusion as embodied in the double jeopardy clause of the federal constitution, barred the State from arguing or presenting evidence in his retrial that he personally discharged a firearm causing the victim’s death. The trial court granted the motion, but the appellate court reversed the judgment, holding that the jury’s answer to the special interrogatory did not bar the State from arguing or presenting evidence that Jefferson discharged the firearm.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court concluded that the jury’s answer to the special interrogatory and general verdict could be understood as an indication that the jury was unable to determine whether Jefferson or another individual shot the victim, but that it had determined, beyond a reasonable doubt, that either one or the other did. Because a rational jury could have grounded its verdict upon an issue other than that which Jefferson sought to foreclose from consideration, Jefferson failed to establish that the doctrine of issue preclusion applied. Therefore, the trial court erred in granting Jefferson’s motion to suppress evidence. The State, on retrial, is not barred from again arguing that either Jefferson or the other individual shot the victim. However, the State is barred from seeking a sentence enhancement on remand, as the State conceded that Jefferson cannot get the enhancement ever again. View "People v. Jefferson" on Justia Law

The case revolves around Monique H. Worrell, who was suspended from her position as State Attorney for the Ninth Judicial Circuit by Governor Ron DeSantis through Executive Order 23-160. The order alleged that during Worrell's tenure, the administration of criminal justice in the Ninth Circuit was fundamentally derelict, constituting both neglect of duty and incompetence. The order detailed that Worrell authorized or allowed charging practices that permitted violent offenders, drug traffickers, serious juvenile offenders, and pedophiles to evade incarceration when otherwise warranted under Florida law. It also alleged that Worrell authorized or allowed practices that prevented assistant state attorneys from seeking certain sentencing enhancements and limited charges for possession of child pornography.The Florida Constitution allows the governor to suspend any state officer not subject to impeachment for neglect of duty or incompetence. Worrell, not being subject to impeachment, was constitutionally subject to suspension. The Florida Senate has the power to remove from office or reinstate the suspended official.The Supreme Court of Florida's role was to determine whether the governor had met the constitutional mandate to state the grounds of the officer's suspension. The court's review was deferential, confirming that the governor had specified the applicable grounds for suspension and that the allegations in the suspension order bore a reasonable relation to the asserted basis for the suspension.The Supreme Court of Florida found that the Executive Order passed this test. It named the grounds for Worrell's suspension—neglect of duty and incompetence—and provided various factual allegations that reasonably related to those grounds of suspension. The court disagreed with Worrell's claim that the allegations in the Executive Order were impermissibly vague or that they addressed conduct that fell within the lawful exercise of prosecutorial discretion. Therefore, the court denied Worrell's petition for a writ of quo warranto. View "Worrell v. DeSantis" on Justia Law

The defendant, Britian Lee Barr, was charged with eleven counts of sexual exploitation of a child for possessing child pornography. Barr had previously been convicted of felony possession of sexually exploitative material in 2011. On the second day of trial, Barr pleaded guilty to five counts of sexual exploitation of a child for possessing child pornography and admitted to being a repeat offender. In exchange for his guilty pleas, the other counts were dismissed. Barr was sentenced to five, fifteen-year fixed sentences to run consecutively, resulting in an aggregate seventy-five-year fixed sentence. The consecutive nature of the sentences was mandated by Idaho Code section 19-2520G(3).Barr appealed the sentence, arguing that the district court abused its discretion by failing to perceive that it had discretion to designate indeterminate portions for the mandatory fifteen-year sentences and that it had discretion to order the sentences be served concurrently. The Supreme Court of the State of Idaho affirmed the decision of the district court because Barr had not preserved his arguments for appeal. Barr returned to the district court and filed a Rule 35(a) motion to correct an illegal sentence. Barr argued that the consecutive sentence requirement in Idaho Code section 19-2520G(3) is unconstitutional because it violates the doctrine of separation of powers by usurping the judiciary’s inherent power to determine whether a sentence runs consecutively or concurrently. The district court denied the motion, concluding that the legislature is empowered to designate mandatory consecutive sentences under the plain language of Article V, section 13 of the Idaho Constitution. Barr timely appealed.The Supreme Court of the State of Idaho held that determining whether a sentence is to be served consecutively or concurrently is not a power reserved exclusively to the judiciary. As a result, section 19-2520G(3) does not violate the separation of powers provision of the Idaho Constitution. The court affirmed the district court's decision denying Barr's Rule 35(a) motion. View "State v. Barr" on Justia Law

The case involves Mid Valley Pipeline Company, an interstate pipeline company, and the Board of Mississippi Levee Commissioners. In 1949, the Levee Board granted Mid Valley a permit to construct and maintain two pipelines across a levee in Mississippi. The permit was not limited to a term of years and could be revoked by the Levee Board if Mid Valley failed to comply with any of the permit's conditions. In 2005, Mid Valley was instructed to relocate its pipelines, which it did at a cost of over $700,000. In 2020, the Levee Board informed Mid Valley that it would be charging an annual pipeline crossing fee and would revoke all existing permits for pipelines not currently paying the fee. Mid Valley did not respond to these notices.The United States District Court for the Northern District of Mississippi granted summary judgment in favor of the Levee Board, dismissing Mid Valley's claim that the imposition of the annual fee and the revocation of the permit violated the Contract Clause of the United States Constitution. The court reasoned that the 1949 permit was not a contract.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The appellate court agreed with the district court that the 1949 permit was not a contract. The court noted that under Mississippi law, a contract requires mutual assent, among other elements. The court found that the permit was a unilateral grant of permission by the Levee Board, and there was no evidence of mutual assent to form a contract. Therefore, the Levee Board's actions did not violate the Contract Clause. View "Mid Valley Pipeline v. Rodgers" on Justia Law

The case involves Patrick Hancock, who pleaded guilty to unlawful possession of a firearm as a convicted felon. His federal sentence was enhanced on the grounds that he also violated Indiana Code § 35-44.1-2-6, which makes it a felony for a civilian to impersonate a law enforcement officer. Hancock appealed his sentence, challenging the Sentencing Guidelines enhancement. The evidence supported the district court’s findings that Hancock represented himself as a police officer by wearing various law enforcement paraphernalia.The district court applied a four-level sentencing enhancement, finding that Hancock's attire was sufficient to prove by a preponderance of the evidence that § 2K2.1(b)(6)(B) applied. The court sentenced Hancock to 48 months in prison to be followed by three years of supervised release. The district court varied upward from the Sentencing Guidelines range because it found that Hancock’s crime involved “extreme conduct” and that greater punishment was needed to deter future criminal conduct.In the United States Court of Appeals For the Seventh Circuit, the court affirmed the district court’s decision. The court rejected Hancock’s argument that he did not intend to deceive anyone at Costco into thinking he was a law enforcement officer. The court also rejected Hancock’s argument that Indiana’s false impersonation statute violates the First Amendment. The court held that the statute was narrowly tailored to serve the government’s compelling public interest in preserving public safety and protecting the reputation of law enforcement. View "USA v. Hancock" on Justia Law

Eric English was convicted of first-degree criminal sexual conduct with a minor, his biological daughter. The victim, who was six or seven years old at the time of the abuse, tested positive for gonorrhea. English and Jamie Stroman, the victim's mother's boyfriend, also underwent STD testing. English tested positive for gonorrhea, while Stroman tested negative. The trial court admitted the STD test reports as evidence under the business records exception to the rule against hearsay, despite English's objections.The court of appeals affirmed the trial court's decision, arguing that the test reports were admissible under the business records exception and were not testimonial under the United States Supreme Court's holding in Davis v. Washington. English appealed, arguing that the test reports were inadmissible without the testimony of the individuals who performed the tests, citing State v. James.The Supreme Court of South Carolina affirmed the lower courts' decisions in part and vacated in part. The court overruled James, stating that it had been abrogated by subsequent decisions interpreting the Sixth Amendment's Confrontation Clause. The court held that the STD test reports were nontestimonial and did not implicate English's Sixth Amendment right of confrontation. Therefore, the trial court did not err in admitting the reports without requiring the testimony of the individuals who authored the reports. However, the court vacated the court of appeals' holding that the requirements of Rule 803(6) were satisfied, as English did not argue that the reports did not meet these requirements. View "The State v. English" on Justia Law

This case involves a challenge to a statute and a constitutional provision in Hawaii that relate to the prosecution of continuous sexual assault of a minor under the age of fourteen. The defendant, Alvin Tran, was charged with violating this statute. After a trial, a jury found him guilty. Tran then filed a motion for a new trial, arguing that the statute and the constitutional provision violated the U.S. Constitution because they did not require the jury to unanimously agree on the specific acts that constituted the continuous sexual assault. The trial court denied this motion. Tran also filed a motion to dismiss the indictment against him, arguing that it was not specific enough. The trial court granted this motion in part and denied it in part, dismissing the case but allowing the state to refile the charges.The Supreme Court of the State of Hawaii held that the statute and the constitutional provision did not violate the U.S. Constitution. The court reasoned that these provisions did not authorize non-unanimous jury verdicts, which would be unconstitutional. Instead, they allowed a unanimous jury to find a defendant guilty even if the jurors did not agree on which specific acts constituted the continuous sexual assault. The court also held that the indictment against Tran was sufficient. Therefore, the court vacated the trial court's order dismissing the case and remanded the case for further proceedings. View "State v. Tran" on Justia Law

Leachco, Inc., an Oklahoma corporation that manufactures and markets various products, appealed the denial of its request for a preliminary injunction to halt administrative enforcement proceedings by the Consumer Product Safety Commission (CPSC). Leachco argued that the statutory removal protections for CPSC commissioners and administrative law judges (ALJs) violated Article II of the Constitution and the separation of powers. The district court denied Leachco's motion for a preliminary injunction, stating that even if Leachco's constitutional arguments were valid, the alleged constitutional violations were insufficient to establish that Leachco would suffer "irreparable harm" if the injunction was denied.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that under current Supreme Court and Tenth Circuit precedent, Leachco's subjection to proceedings before an agency whose officials allegedly have unconstitutional protection against removal is insufficient, by itself, to establish irreparable harm. The court also found that Leachco failed to show that the removal protections for CPSC commissioners and its administrative law judge were unconstitutional. Therefore, Leachco failed to satisfy the irreparable harm requirement necessary to obtain a preliminary injunction. View "Leachco v. Consumer Product Safety Commission" on Justia Law

Maria Elvia Smith, a Mexican citizen, was denied legal status in the U.S. by immigration authorities. Smith had been married to a U.S. citizen, Arlo Henry Smith, Sr., who filed a Form I-130 petition to classify her as his immediate-relative spouse. However, Arlo died while the petition was pending, and it automatically converted to an I-360, Widow(er) Petition. The U.S. Citizenship and Immigration Services (USCIS) and the Board of Immigration Appeals denied Smith's I-360 petition, concluding that she failed to prove by a preponderance of the evidence that her marriage to Arlo was bona fide for immigration purposes. This conclusion was based on evidence of Smith's continued relationship with her ex-husband and her inconsistent statements to immigration officials.Smith sued the United States Attorney General, USCIS, and the Board, alleging that they improperly denied her I-360 petition and violated her Fifth Amendment right to due process. The United States District Court for the Eastern District of Wisconsin dismissed her complaint, finding that she did not plausibly allege that USCIS and the Board acted improperly in denying her petition, acted without observance of the procedure required by law, or substantively violated the Fifth Amendment’s Due Process Clause.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that the agencies had considered the evidence, applied the proper standards and burden of proof, and validly elected not to credit Smith’s statements in light of her past untruthfulness. The court also found that the agencies had complied with the procedures required by law and that Smith had received all the process due to her. Finally, the court rejected Smith's claim that the agencies violated her procedural and substantive due process rights under the Fifth Amendment. View "Smith v. Garland" on Justia Law

David Lewicki was part of a group that attempted to rob Humberto Pelayo, resulting in Pelayo suffering permanent injuries. Lewicki claimed he did not inflict the injuries and had tried to protect Pelayo. However, the jury found him guilty of attempted robbery causing serious bodily injury, and he was sentenced to 65 years in prison as a habitual offender. Lewicki's conviction and sentence were affirmed by the state courts.Lewicki then sought federal relief, arguing that his appellate lawyer had been ineffective for not arguing that his Sixth Amendment right to a speedy trial had been violated. The district court agreed, issuing a conditional writ of habeas corpus. The court found that Lewicki's lawyer's failure to raise the speedy trial argument amounted to ineffective assistance of counsel. However, the court did not find that Indiana had violated the Speedy Trial Clause. Instead, it ordered Indiana to release Lewicki unless it provided him with a new appeal.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court found that the district court had erred in granting relief based on ineffective assistance of counsel without finding that Lewicki had been prejudiced by his lawyer's failure to raise the speedy trial argument. The court explained that ineffective assistance of counsel requires both deficient performance and prejudice. The court also found that Lewicki did not have a strong speedy-trial claim. Despite a nearly three-year delay between his charge and trial, the court found that Lewicki had not shown prejudice from the delay. The court noted that Lewicki's own lawyer had proposed multiple continuances, and Lewicki had not shown that evidence was lost or memories faded due to the delay. The court also noted that little of Lewicki's time in custody could be attributed to the delayed trial of the attempted-robbery charge. Therefore, the court reversed the district court's decision and upheld Lewicki's conviction and sentence. View "Lewicki v. Emerson" on Justia Law