Justia Constitutional Law Opinion Summaries

The defendant, Ronald Yoel Marte Carmona, was convicted on charges related to multiple fentanyl sales. He appealed, challenging the district court's denial of his motions to suppress the fruits of a Terry stop and arguing that the evidence supporting his six convictions was insufficient.Previously, the defendant had been indicted on one count of conspiracy to distribute and to possess with intent to distribute 400 grams or more of fentanyl, and five counts of distribution and possession with intent to distribute forty grams or more of fentanyl. Each of the distribution counts corresponded with a particular controlled buy. The defendant moved to suppress the fruits of a traffic stop and the fruits of a search of an apartment, arguing that the stop was unconstitutional because it was not supported by probable cause or reasonable suspicion. The district court denied the motions, finding that the agents possessed reasonable suspicion to effectuate the stop.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that the Terry stop was reasonable, grounded in articulable suspicion, and that the verdicts were supported by the record evidence. The court also found that the agents who stopped the defendant possessed a reasonable, articulable suspicion that he was involved in past criminal conduct, making the Terry stop permissible. The court further held that the evidence presented at trial established that a rational factfinder could conclude, beyond a reasonable doubt, that the defendant was guilty of the charges. View "US v. Carmona" on Justia Law

In 1995, Jerry E. Russell Sr. was convicted of the murder of Pamela Foddrill, along with other crimes, and was sentenced to life imprisonment without parole (LWOP) plus 120 years. Russell appealed his sentence, which resulted in a modification of his sentences for criminal confinement and criminal deviate conduct, reducing his total sentence to LWOP plus 73 years. In 2003, Russell filed a Petition for Post-Conviction Relief (PCR), which was dismissed in 2019 in exchange for a resentencing hearing. The resentencing court upheld Russell's original sentence of LWOP plus 73 years.Russell appealed the resentencing order, arguing that he was intellectually disabled and therefore ineligible for an LWOP sentence, that his convictions violated double jeopardy protections, and that his sentence was inappropriate given the nature of the offenses and his character. The Indiana Supreme Court rejected all of Russell's arguments and affirmed the resentencing court's order. The court found that Russell had not proven that he was intellectually disabled, that his convictions did not violate double jeopardy protections, and that his sentence was not inappropriate given the nature of the offenses and his character. The court also found that Russell had not been denied due process during his resentencing hearing. View "Russell v. State of Indiana" on Justia Law

The case involves the American Alliance for Equal Rights (the Alliance), a membership organization dedicated to ending racial classifications and preferences in America, and Fearless Fund Management, LLC (Fearless), a venture capital fund that invests in businesses led by women of color. Fearless organized the "Fearless Strivers Grant Contest," a funding competition open only to businesses owned by black women. The Alliance, representing several members who wished to participate in the contest but were not black women, sued Fearless, alleging that the contest violated 42 U.S.C. § 1981, which prohibits private parties from discriminating on the basis of race when making or enforcing contracts.The district court denied the Alliance's request for a preliminary injunction to prevent Fearless from closing the application process. The court concluded that the Alliance had standing to sue and that § 1981 applied to Fearless's contest. However, it also concluded that the First Amendment "may bar" the Alliance's § 1981 claim on the ground that the contest constitutes expressive conduct, and that the Alliance hadn't demonstrated that it would suffer irreparable injury.The United States Court of Appeals for the Eleventh Circuit held that the Alliance has standing and that preliminary injunctive relief is appropriate because Fearless's contest is substantially likely to violate § 1981, is substantially unlikely to enjoy First Amendment protection, and inflicts irreparable injury. The court affirmed the district court's determination that the Alliance has standing to sue but reversed its decision and remanded with instructions to enter a preliminary injunction. View "American Alliance for Equal Rights v. Fearless Fund Management, LLC, et al" on Justia Law

The case revolves around Christopher Oneil Tarr, who struck a pedestrian with his car while allegedly intoxicated. At the hospital, Tarr refused to have his blood drawn for alcohol testing, despite being informed that under Colorado’s Expressed Consent Statute, he had already consented to such a test by driving. The police proceeded with the blood draw without a warrant, and the results were used to charge Tarr with several crimes, including vehicular homicide—DUI. Tarr moved to suppress the results of the blood draws, arguing they were unconstitutional as he had clearly revoked his consent and the police did not yet have a warrant when his blood was drawn. The trial court denied the motion, and Tarr was found guilty.The trial court's decision was based on a previous case, People v. Hyde, which held that there is no constitutional right to refuse a blood-alcohol test. The court of appeals affirmed the trial court's decision, agreeing with its interpretation of Hyde. Tarr then petitioned the Supreme Court of the State of Colorado for certiorari review.The Supreme Court of the State of Colorado reversed the lower courts' decisions. It held that a conscious driver can revoke their statutory consent to a blood draw. Once consent has been revoked, the police are generally required to obtain a warrant before trying to conduct a blood draw. Otherwise, any evidence obtained from the blood draw should be excluded from trial unless one of the recognized exceptions to the exclusionary rule applies. The case was remanded for consideration of any outstanding arguments concerning the admissibility of the evidence. View "Tarr v. People" on Justia Law

The case revolves around the defendant, Isaias Lobato-Rodriguez, who was convicted of second-degree murder. The victim, Connie Lopez, was found dead in a van that had crashed into a fence along a remote stretch of desert highway. The defendant approached law enforcement at the scene and admitted to killing Lopez, claiming he had to do so because she was going to kill him and kidnap and kill his daughter. During the prosecutor's opening statement, he mentioned that the defendant invoked his right to remain silent after his arrest. The defense counsel objected and requested a mistrial, but the district court denied the motion, stating that the isolated comment was unlikely to be a significant factor in the jury’s verdict given the evidence expected at trial.The Court of Appeals vacated the defendant's conviction, ruling that the prosecutor's comment on the defendant’s failure to speak to police violated his right to remain silent under the Fifth and Fourteenth Amendments to the United States Constitution, and that such violation was not harmless error. The Court of Appeals did not analyze the comment in the context of all of the evidence presented at trial but concluded that reversal was required because the defendant’s credibility was crucial since he testified at trial and the element of provocation was at issue.The Supreme Court of the State of New Mexico, however, disagreed with the Court of Appeals. While it agreed that the prosecutor’s comment violated the defendant’s constitutional rights, it concluded that the error was harmless in the context of the trial as a whole. The court reasoned that the prosecutor’s comment did not affect the jury’s verdict because the defendant’s testimony—even if fully credited—could not establish sufficient provocation as a matter of law. The court also noted that the prosecutor’s comment was an isolated remark at the beginning of the trial that, after admonishment by the district court, was not repeated or emphasized. Therefore, the Supreme Court reversed the decision of the Court of Appeals. View "State v. Lobato-Rodriguez" on Justia Law

The case revolves around a dispute between Roy Padilla and Ray Torres, where Padilla, the landlord, filed a petition in the metropolitan court under the Uniform Owner-Resident Relations Act (UORRA), alleging that Torres, his tenant, had not paid rent. The metropolitan court ruled in favor of Padilla, ordering Torres to pay past-due rent and costs amounting to $927. Torres appealed this judgment to the Second Judicial District Court, but the appeal was dismissed because Torres had failed to request a recording of the metropolitan court’s trial.The district court held that without a record of the trial, it could not effectively review Torres’s appeal. The court also rejected Torres’s assertion that he had a right to a recording, explaining that Torres, as appellant, was required to provide an adequate record on appeal. Torres then appealed the dismissal to the Court of Appeals, arguing that the metropolitan court’s practice of not recording civil proceedings except on a party’s request was inconsistent with Section 34-8A-6(B) (1993) and violated his state and federal constitutional rights.The Supreme Court of the State of New Mexico held that the failure to record the trial in this matter is contrary to Section 34-8A-6(B) (1993). The court concluded that the statute imposes a duty on the metropolitan court to create a record of its proceedings that will be sufficient to permit appellate review in this case. The court further held that Rule 3708(A) and other similar rules impermissibly conflict with Section 34-8A-6(B) to the extent that the rules condition the creation of this record on a party’s request. The court directed its committee for the Rules of Civil Procedure for the State Courts to correct the rules in conformance with its opinion. Finally, the court reversed and remanded this matter to the metropolitan court for a new trial. View "Padilla v. Torres" on Justia Law

The case involves Rudolph Amador, who was convicted of two counts of criminal sexual contact of a minor and one count of child abuse. The charges stemmed from allegations that Amador sexually abused his friend's eleven-year-old daughter. After the initial trial, the district court ordered a new trial due to prosecutorial misconduct and ineffective assistance of counsel. However, the court denied Amador's argument that the retrial was barred. Amador was retried and convicted on all three counts.Amador appealed to the Court of Appeals, arguing that the retrial was barred by double jeopardy and that he received ineffective assistance of counsel. The Court of Appeals rejected Amador's arguments and affirmed his convictions. Amador then petitioned for a writ of certiorari on both issues to the Supreme Court of the State of New Mexico.The Supreme Court of the State of New Mexico reversed the Court of Appeals' decision. The court held that Amador's second trial was barred by double jeopardy under Article II, Section 15 of the New Mexico Constitution. The court found that the prosecutor's misconduct, which included misrepresenting Amador's conditional discharge as a felony conviction and repeatedly referring to Amador as a pedophile during closing arguments, demonstrated a willful disregard of the resulting mistrial. The court remanded the case to the district court to vacate Amador's convictions and discharge him from any further prosecution in this matter. View "State v. Amador" on Justia Law

The case involves Clive Phillips, who was convicted of six counts of aggravated battery and pleaded guilty to one count of voluntary manslaughter. Phillips had attacked Adrian Carriaga and Alexzandria Buhl, killing Adrian and severely injuring Buhl. Phillips challenged his convictions, arguing that double jeopardy bars the multiple convictions except for one count of battery for attacking Buhl and one count of manslaughter for attacking and killing Carriaga.The lower courts had mixed rulings. The district court disagreed with Phillips' double jeopardy argument and sentenced him to twenty-five years imprisonment, suspending seven years. On appeal, the Court of Appeals affirmed some convictions, reversed others, and concluded that the battery and manslaughter convictions violated double jeopardy because a reasonable jury could have found either unitary conduct or distinct acts.The Supreme Court of the State of New Mexico disagreed with the Court of Appeals' application of the presumption of unitary conduct. The court concluded that the manslaughter conviction and the challenged battery convictions were each based on distinct conduct and therefore did not violate Phillips' right against double jeopardy. The court affirmed Phillips' manslaughter conviction and all five of his aggravated battery convictions. The court also clarified that in conducting a double jeopardy analysis for a conviction rendered by a guilty plea, a reviewing court should examine what the record shows about whether a defendant’s acts are distinct rather than what a reasonable jury could have found. View "State v. Phillips" on Justia Law

The case involves Oakland Tactical Supply, LLC and five Michigan residents who sued Howell Township, Michigan, alleging that the township's zoning restrictions, which prevented Oakland Tactical from constructing and operating a commercial shooting range, violated the Second Amendment. The district court granted the township's motion for judgment on the pleadings, concluding that the zoning restrictions did not violate the Second Amendment. The plaintiffs appealed this decision.The district court's decision was made before the Supreme Court announced a new framework for deciding Second Amendment challenges in New York State Rifle & Pistol Ass'n, Inc. v. Bruen. The Court of Appeals for the Sixth Circuit remanded the case for reconsideration in light of Bruen, and the district court again granted judgment for the township.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that while the Second Amendment protects the right to engage in commercial firearms training as necessary to protect the right to effectively bear arms in case of confrontation, it does not extend to training in a particular location or at the extremely long distances Oakland Tactical seeks to provide. The court concluded that the plaintiffs' proposed conduct—commercial training in a particular location and long-distance commercial training—was not protected by the plain text of the Second Amendment. Therefore, the township's zoning restrictions did not violate the Second Amendment. View "Oakland Tactical Supply, LLC v. Howell Township" on Justia Law

A Rhode Island oral and maxillofacial surgeon, Dr. Stephen T. Skoly, refused to comply with a COVID-19 Emergency Regulation issued by the Rhode Island Department of Health (RI DOH) that required all healthcare workers and providers to be vaccinated against COVID-19. Following his public declaration of noncompliance, the RI DOH issued a Notice of Violation and Compliance Order against him. Skoly then filed a lawsuit in federal court against the state and its officials, alleging violations of equal protection, due process, and First Amendment rights. The district court dismissed his complaint under Federal Rule of Civil Procedure 12(b)(6).The district court's decision was based on the fact that the state officials were either entitled to absolute or qualified immunity for their actions. The court held that the RI DOH directors were exercising prosecutorial authority delegated to them by Rhode Island law, thus granting them absolute immunity. As for Governor McKee, the court found that he was protected by qualified immunity as Skoly had no clearly established right to continue practicing while violating the vaccine mandate. The court also rejected Skoly's First Amendment retaliation claim, stating that the posting of the Notice constituted government speech, which could not form the basis of a plausible First Amendment retaliation claim.Upon appeal, the United States Court of Appeals for the First Circuit affirmed the district court's dismissal of Skoly's complaint. The appellate court agreed with the lower court's findings that the state officials were entitled to either absolute or qualified immunity and that Skoly's constitutional claims were without merit. The court also upheld the dismissal of Skoly's First Amendment retaliation claim, stating that Skoly had not sufficiently alleged that he was targeted due to his opposition to the First Emergency Regulation. View "Skoly v. McKee" on Justia Law