Justia Constitutional Law Opinion Summaries

Emanuel Dameron was charged with possessing a firearm as a felon after police officers spotted him on a live video feed from a pole camera, observed an "L-shaped object" resembling a gun in his waistband, and subsequently found a gun on him during a frisk search on a public bus in Chicago. Dameron moved to suppress the firearm and other evidence gathered during the stop, arguing that the police's search violated the Fourth Amendment and the standards set in Terry v. Ohio. The district court denied Dameron's motion, and he was found guilty at trial.The district court held an evidentiary hearing, during which the officer operating the pole camera testified about his familiarity with the neighborhood, its history of gang and narcotic activity, and his observation of the "L-shaped object" in Dameron's waistband. The court concluded that the visible bulge in Dameron's waistband and his presence in a high-crime area generated reasonable suspicion to justify the Terry stop. Dameron was subsequently found guilty and sentenced to 110 months' imprisonment.On appeal to the United States Court of Appeals for the Seventh Circuit, Dameron renewed his contention that the search violated the Fourth Amendment. He argued that Illinois permits the concealed carrying of firearms and that the police had no way of knowing whether he was an authorized license holder. The court declined to address this argument as it was not presented to the district court. Instead, the court focused on the fact that Dameron was on a public bus when the search occurred, noting that the Illinois Concealed Carry Act prohibits carrying a firearm on public transportation. The court concluded that the officers had reasonable suspicion to believe Dameron had violated the law and that their pat-down search did not violate the Fourth Amendment. The court affirmed the lower court's decision. View "United States v. Dameron" on Justia Law

A dispute arose between the Alabama-West Florida Conference ("the Conference") of the United Methodist Church, Inc. ("the UMC"), and 44 Methodist churches in the Conference ("the churches"). Amid disagreements within the UMC over issues of human sexuality, the churches sought to leave the UMC with their properties under a provision of the Book of Discipline, the governing law of the UMC. After the Conference denied the churches the ability to vote to disaffiliate under that provision, the churches asked the Montgomery Circuit Court to order the Conference to grant them that vote. The trial court dismissed the suit for lack of subject-matter jurisdiction under the Establishment Clause of the First Amendment to the United States Constitution.The Montgomery Circuit Court held an emergency hearing and heard evidence. The next day, the court dismissed the suit for lack of subject-matter jurisdiction because, according to the court, the relief that the churches requested was "ecclesiastical in nature and would require Court interference in matters of church autonomy," which would violate the Establishment Clause of the First Amendment. The churches appealed that judgment.The Supreme Court of Alabama reviewed the case and affirmed the trial court's judgment. The churches argued that the trial court erred in dismissing their suit for lack of subject-matter jurisdiction because, they said, the case presents only "civil and property issues." However, the Supreme Court of Alabama held that the churches' central claims turn entirely on the interpretation of the provision of the Book of Discipline and whether their efforts to leave the UMC were consistent with that church law. Under existing First Amendment law and the court's precedent, that interpretive issue constitutes an ecclesiastical question that courts do not have jurisdiction to decide. Therefore, the court affirmed the judgment. View "Aldersgate United Methodist Church of Montgomery v. Alabama-West Florida Conference of the United Methodist Church, Inc." on Justia Law

The case involves the State of Oregon and Stephen Andrew Aranda. Aranda was charged with first-degree rape and chose to testify in his own defense. The state sought to impeach his testimony with evidence of his prior felony convictions, including two counts of first-degree sexual abuse and one count of second-degree assault. Aranda argued that the court should weigh the probative value of his conviction history against its potential for unfair prejudice before admitting it as evidence. The trial court denied his motion, and Aranda was subsequently convicted.On appeal, the Court of Appeals agreed with Aranda's argument and reversed his conviction, holding that due process required the trial court to conduct a balancing test before admitting his prior convictions as impeachment evidence. The state appealed to the Supreme Court of Oregon.The Supreme Court of Oregon reversed the decision of the Court of Appeals and affirmed the judgment of the circuit court. The court held that the Court of Appeals erred in concluding that due process required a balancing test before admitting a defendant's prior convictions as impeachment evidence. The court found that neither historical practice nor principles of fundamental fairness required such a balancing test. The court noted that while the admission of prior convictions could be prejudicial, it was also highly relevant to a defendant's credibility as a witness. The court concluded that due process did not require a balancing test under Oregon Evidence Code 403 before admitting a defendant's prior convictions as impeachment evidence under Oregon Evidence Code 609. View "State v. Aranda" on Justia Law

The Supreme Court of Kansas reviewed a case involving the League of Women Voters of Kansas and other organizations against the Kansas Secretary of State and the Kansas Attorney General. The plaintiffs challenged three new Kansas election laws, alleging that they violated various provisions of the Kansas Constitution. The laws in question prohibited the false representation of an election official, prohibited election officials from counting advance ballots that did not have a signature or had a signature that an election official determined did not match the signature on file, and prohibited any person from collecting and returning more than 10 advance ballots for other voters.The case was initially heard in the Shawnee County District Court, which denied the plaintiffs' request for a temporary injunction against the false representation statute. The court also granted the defendants' motion to dismiss the claims against the signature verification requirement and the ballot collection restriction. The plaintiffs appealed these decisions, and the cases were consolidated.The Supreme Court of Kansas held that the plaintiffs had demonstrated a likelihood of prevailing on the merits of their claim that the false representation statute was constitutionally infirm. Therefore, the district court erred in denying their request for a temporary injunction. The court also held that the signature verification requirement was a valid effort by the Legislature to provide "proper proofs" of the right to be a qualified elector. However, the court remanded the case to the district court to consider whether the statute and its implementing regulations complied with the constitutional guarantees of equal protection and due process. Finally, the court affirmed the district court's grant of the defendants' motion to dismiss the claim that the ballot collection restriction was constitutionally infirm, because the restriction was not a new qualification on the right to be an elector, and because the proscribed activity—the delivery of ballots—was not political speech or expressive conduct. View "League of Women Voters of Kansas v. Schwab" on Justia Law

This case involves two legal permanent residents, Carol Williams Black and Keisy G.M., who were detained by the U.S. government for several months without a bond hearing under the authority of 8 U.S.C. § 1226(c), pending the conclusion of their separate removal proceedings. Black and G.M. each sought habeas relief, asserting that their prolonged detentions without any bond hearing violated their Fifth Amendment rights to due process. The district court granted Black's petition and he was released, while G.M.'s petition was denied.In the United States Court of Appeals for the Second Circuit, the court concluded that the constitutional guarantee of due process precludes a noncitizen’s unreasonably prolonged detention under section 1226(c) without a bond hearing. The court affirmed the district court’s judgment granting habeas relief to Black, concluding that the district court properly required the government to show the necessity of his continued detention by clear and convincing evidence. As to G.M., the court concluded that his detention had become unreasonably prolonged and reversed the district court’s judgment denying habeas relief. View "Black v. Decker" on Justia Law

The Supreme Court of Texas reviewed a case involving the State of Texas, Ken Paxton in his official capacity as Attorney General of Texas, the Texas Medical Board, and Stephen Brint Carlton in his official capacity as Executive Director of the Texas Medical Board (collectively, the State) against a group of women and physicians. The plaintiffs challenged the constitutionality of Texas's abortion laws, specifically the Human Life Protection Act, which generally prohibits performing an abortion except when a pregnant woman has a life-threatening physical condition that poses a risk of death or serious physical impairment unless an abortion is performed.The case reached the Supreme Court of Texas as a direct appeal from a temporary injunction issued by the 353rd District Court, Travis County, Texas, which halted the enforcement of Texas's abortion laws in various circumstances. The State contested the injunction, arguing that the plaintiffs lacked standing, the State had sovereign immunity, and the current Texas law permitting life-saving abortion was not more limiting than the Texas Constitution permits.The Supreme Court of Texas held that one of the plaintiffs, Dr. Damla Karsan, had standing to challenge the Attorney General’s enforcement of the Human Life Protection Act against her. The court also concluded that the Declaratory Judgments Act waives the State’s immunity for a claim that a statute violates the state constitution. The court further clarified that under the Human Life Protection Act, a woman with a life-threatening physical condition and her physician have the legal authority to proceed with an abortion to save the woman’s life or major bodily function, in the exercise of reasonable medical judgment and with the woman’s informed consent. The court concluded that Dr. Karsan had not demonstrated that the part of the Human Life Protection Act that permits life-saving abortion is narrower than the Texas Constitution allows. As a result, the court vacated the lower court's injunction order. View "State v. Zurawski" on Justia Law

In the case before the Supreme Court of Pennsylvania, the appellant, the Commonwealth of Pennsylvania, challenged the Chester County Court of Common Pleas' ruling that the Sexual Offender Registration and Notification Act (SORNA) was unconstitutional. The appellee, George Torsilieri, had been convicted of sexual offenses and was subject to SORNA's registration and notification requirements. Torsilieri argued that SORNA's presumption that individuals who commit sexual offenses pose a high risk of committing additional sexual offenses was an unconstitutional irrebuttable presumption violating due process. He also contended that SORNA's requirements constituted criminal punishment, which served as the basis for various constitutional challenges.The lower court agreed with Torsilieri, finding that the presumption was not universally true and that the registration and notification requirements were punitive. The court declared Subchapter H of SORNA unconstitutional, and the Commonwealth appealed directly to the Supreme Court of Pennsylvania.The Supreme Court of Pennsylvania reversed the lower court's decision. The court held that Torsilieri failed to establish that SORNA's irrebuttable presumption was constitutionally infirm. The court also concluded that Torsilieri failed to demonstrate that SORNA constituted criminal punishment. Therefore, the court rejected Torsilieri's subsidiary constitutional challenges and reinstated his duty to comply with SORNA. View "Commonwealth v. Torsilieri" on Justia Law

The case involves SCS Carbon Transport LLC ("Summit") and a group of landowners. Summit plans to construct an interstate pipeline to transport carbon dioxide to sequestration sites in North Dakota and four other states. To determine the appropriate pipeline route, Summit needs to access the landowners' properties. However, the landowners denied Summit permission to enter their lands. Consequently, Summit filed lawsuits against the landowners, seeking a court order confirming its right under North Dakota law to enter the lands to conduct pre-condemnation surveys and examinations. The landowners counterclaimed, arguing that the statute authorizing entry is unconstitutional.The district courts granted summary judgment to Summit, concluding that the statute does not constitute an unconstitutional per se taking, Summit is a common carrier authorized to exercise eminent domain, and the proposed surveys and examinations are the type of minimally invasive surveys and examinations allowed under the statute. The courts confirmed Summit's right to enter the lands to complete civil, environmental, and archaeological/cultural surveys and examinations, including any necessary geotechnical/soil borings, archaeological/cultural resource surveys and examinations, and including any necessary core or water sampling activities subject to any conditions.The landowners appealed the judgments and order granting summary judgment, arguing that the statute is unconstitutional on its face and as applied to them under the Takings Clause of the Fifth Amendment and article I, § 16 of the North Dakota Constitution.The Supreme Court of North Dakota affirmed the lower courts' decisions. The court concluded that the landowners have not established a constitutional violation on the face of the entry statute or as applied to them, and the judgments and order do not exceed the scope of the entry statute. The court also found that the district court's judgment does not grant Summit an indefinite or perpetual right of access. The court held that a constitutionally permissible entry may not be longer or more invasive than necessary to complete the examination or survey needed to confirm and minimize the scope of the anticipated taking of private property. View "SCS Carbon Transport v. Malloy" on Justia Law

The case involves Howard Studhorse, who was charged with five counts of gross sexual imposition and one count of contributing to the deprivation or delinquency of minors. The charges were based on allegations involving three victims, identified as Jane Doe 1, Jane Doe 2, and Jane Doe 3. After a jury trial, Studhorse was found guilty on all six charges. He appealed, raising several issues including the district court's application of the North Dakota Rules of Evidence, the sufficiency of the evidence supporting his convictions, and potential violations of his right to remain silent and his protection against double jeopardy.Studhorse argued that the district court misapplied the North Dakota Rules of Evidence by allowing Jane Doe 3 to testify without taking an oath or affirmation to tell the truth. The Supreme Court of North Dakota found that the district court's discussion with Jane Doe 3 impressed upon her the duty to tell the truth, which complied with the rules. Therefore, this was not an obvious error.Studhorse also claimed that the State improperly elicited testimony about his silence, implying his guilt. The court found that any error in this regard was harmless and did not require reversal of Studhorse's convictions.Studhorse further argued that he was convicted of non-cognizable offenses on counts IV and V because the jury instructions did not require that he touched the victims on "sexual or other intimate parts," as required by the statute. The court found that the lack of specificity in the jury instructions did not create a non-cognizable crime.Studhorse also claimed that his convictions on counts II and V violated his right against double jeopardy. The court found that the jury instructions for counts IV and V permitted a conviction for both counts on the basis of the same conduct, which was an obvious error. Therefore, the court reversed Studhorse's conviction on count V as duplicative to count IV.Finally, Studhorse argued that the evidence was insufficient to convict him of counts I and II. The court found that the evidence was insufficient to prove a sexual act in count I, and reversed Studhorse's conviction on that count. However, the court affirmed the conviction on count II. View "State v. Studhorse" on Justia Law

The case revolves around Lasondra Johnson, who was charged with first-degree murder following a series of events that led to her shooting and killing Jada YoungMills. Johnson claimed she acted in self-defense, invoking Iowa's "stand your ground" law, which negates the requirement to retreat before using force if one is lawfully present and not engaged in illegal activity. The jury acquitted Johnson of first-degree murder but found her guilty of the lesser charge of assault causing serious injury. Johnson appealed, arguing that the district court incorrectly instructed the jury on the stand-your-ground defense and a related instruction on the presumed reasonableness of using deadly force.The Iowa Court of Appeals affirmed Johnson's conviction but reversed the restitution order. Johnson sought further review, arguing that the jury instructions were misleading and confusing because there was no evidence to support an instruction to the jury that she was engaged in a separate illegal activity—assault—at the time of the shooting. She also argued that the district court imposed an unconstitutional restitution award against her and erred in relying on improper considerations and by applying a fixed sentencing policy.The Supreme Court of Iowa found that the jury instructions were indeed misleading and confusing. The court noted that the instructions allowed the jury to consider the shooting itself as an assault, which would defeat Johnson's justification defense. This interpretation would effectively nullify the stand-your-ground statute, as every use of deadly force could be considered an assault. The court concluded that the jury instructions failed to convey the law in such a way that the jury had a clear understanding of Johnson's justification defense. As a result, the court reversed Johnson's conviction, vacated the sentence, and remanded the case for a new trial. View "State v. Johnson" on Justia Law