Justia Constitutional Law Opinion Summaries

The case revolves around Quasim Hastings, a prisoner convicted of second-degree murder in 2004 and eligible for parole consideration. Hastings, diagnosed with a mental disability, is entitled to a parole hearing that provides him with protections under the Massachusetts Constitution and Federal and State statutes prohibiting discrimination based on disability. Prior to a 2023 parole hearing, Hastings' counsel filed a motion for funds to retain a forensic psychologist and a social services advocate to assist with preparing a prerelease plan. While the motion for a forensic psychologist was approved, the request for a social services advocate was denied by a different Superior Court judge, who reasoned that the indigency statute limits his authority to approve funds to pending proceedings or appeals in any court.The judge's denial of the motion for funds was reported to the Appeals Court, and Hastings's application for direct appellate review was granted by the Supreme Judicial Court. The Supreme Judicial Court concluded that Hastings's motion for funds to retain a social services advocate implicates his State constitutional right to reasonable disability accommodations. Therefore, the constitutionally mandated exception to the indigency statute applies, and the order denying Hastings's motion for funds was reversed. The court held that a judge has the discretion to allow a motion for funds to pay for expert assistance as reasonably necessary to safeguard the indigent prisoner's constitutional rights prohibiting discrimination on the basis of disability. View "Commonwealth v. Hastings" on Justia Law

The Supreme Court of Pennsylvania was asked to clarify the use of hearsay evidence in establishing a prima facie case at a preliminary hearing. The case involved Ronald Harris, who was charged with multiple crimes, including attempted murder. The victim did not appear at the preliminary hearings, and the Commonwealth proceeded with the testimony of two police officers who relayed the victim's out-of-court statements. Harris's counsel objected to the use of hearsay evidence, but the trial court overruled the objections and bound all charges over for trial.Harris filed a motion to quash the charges, arguing that the Commonwealth's case was established solely through hearsay, which he claimed was not legally competent evidence. The trial court granted the motion, and the Commonwealth appealed to the Superior Court, which affirmed the decision. The Superior Court held that all material elements of a criminal offense need to be proved at a preliminary hearing by non-hearsay evidence to avoid violating a defendant's constitutional rights to due process.The Commonwealth appealed to the Supreme Court of Pennsylvania, arguing that the Superior Court's ruling was too broad and that hearsay evidence could be used to establish some elements of the crimes charged. The Supreme Court affirmed the Superior Court's decision but disapproved of its rationale. The Supreme Court held that while hearsay evidence could be used to establish a prima facie case that an offense has been committed, it could not be used alone to prove a prima facie case as to the defendant's identity. The court clarified that the Commonwealth must produce some non-hearsay or admissible hearsay evidence to sustain its prima facie burden as to the defendant's identity. View "Commonwealth v. Harris" on Justia Law

The case involves Anthony Willis, who was charged with being a felon in possession of a firearm. Willis requested to represent himself in court, a request that was granted by the magistrate judge after a hearing confirmed Willis was competent to do so and had knowingly and voluntarily waived his right to counsel. Willis was warned that his right to self-representation could be revoked if he conducted himself in an obstructive or disruptive manner. Throughout the pretrial proceedings, Willis repeatedly asserted "sovereign citizen" arguments and defenses.The district court revoked Willis's right to represent himself on the morning of the trial after he ignored a warning and again asserted his sovereign citizen theories and defenses. Willis was then represented by standby counsel, and a jury convicted him. Willis appealed his conviction and sentence, arguing that the district court erred by revoking his right to represent himself on the morning of the trial.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision to revoke Willis’s right of self-representation de novo. The court concluded that the record at the time the district court revoked Willis’s right to represent himself does not reflect that he had engaged or would engage in the “serious and obstructionist misconduct” that Faretta and controlling precedents require. Therefore, the court reversed the judgment of conviction and remanded for further proceedings. View "United States v. Willis" on Justia Law

The case revolves around the legality of the Emergency Management Act (the Act) in Minnesota, which allows the Governor to declare a peacetime emergency in response to a pandemic. The appellants, led by Drake Snell, challenged the Act, arguing that it did not authorize the Governor to declare a peacetime emergency in response to the COVID-19 pandemic and that it violated the nondelegation doctrine.Previously, the district court had dismissed Snell's case, concluding that the Act was a constitutional delegation of power to the Governor. The court of appeals affirmed this decision, stating that the Act granted the Governor the authority to declare a peacetime emergency in response to the COVID-19 pandemic. The court of appeals declined to consider Snell's argument that the Act violated the nondelegation doctrine, holding that it was not within the scope of remand.The Supreme Court of Minnesota affirmed the decision of the court of appeals. The court concluded that the Act does authorize a governor to declare a peacetime emergency in response to a public health crisis such as a pandemic. Furthermore, the court found that Governor Walz was authorized under the Act to declare a peacetime emergency in response to the COVID-19 pandemic. Lastly, the court rejected Snell's contention that the Act violates the nondelegation doctrine, stating that the Act does not represent an unconstitutional delegation of legislative authority. The court noted that the Act places durational limits on the powers and subjects them to termination by the Legislature, thus providing a check on the Governor's powers. View "Procaccini vs. Walz" on Justia Law

The Minnesota Supreme Court ruled that the Legal Marijuana Now Party (LMNP) does not meet the requirements to be classified as a major political party under Minnesota law. The case was initiated by Ken Martin, the chair of the Democratic-Farmer-Labor Party, who filed a petition arguing that the LMNP failed to comply with certain requirements for major political parties. Specifically, Martin claimed that the LMNP did not maintain a state central committee subject to the state convention’s control, as required by Minnesota law.The case was referred to a referee, who concluded that the LMNP had indeed failed to meet the requirements to be a major political party. The LMNP objected to these findings and argued that the relevant statutes unconstitutionally infringed upon its First Amendment associational rights.The Minnesota Supreme Court rejected the LMNP's arguments. It found that the LMNP's single committee, The Head Council, was not subject to the control of the LMNP’s state convention, as required by law. The court also rejected the LMNP’s constitutional challenge, finding that the party failed to demonstrate how the statutory requirements specifically burdened its associational rights. As a result, the court held that the LMNP does not meet all the statutory requirements to maintain its status as a major political party for the upcoming state primary and general elections. View "Martin vs. Simon" on Justia Law

The case involves Anthony James Trifiletti, who was convicted of second-degree unintentional felony murder. The conviction followed a second trial after the first ended in a mistrial due to a deadlocked jury. During the second trial, one of the State’s witnesses was exposed to COVID-19 and was deemed unavailable to testify in person. The district court allowed the transcript of her testimony from the first trial to be read into the record instead of live testimony. Trifiletti appealed, arguing that this violated his right to confrontation under the Sixth Amendment to the United States Constitution and Article I, Section 6, of the Minnesota Constitution.The Minnesota Supreme Court held that the district court erred in determining that the witness was unavailable under the Confrontation Clause. The court found that the State failed to establish that the witness would not have been available to testify in person at some reasonable point in time during the trial. The court also rejected the State's argument that Trifiletti invited the error by choosing to have the witness's prior testimony read aloud for the jury rather than having her testify via video. However, the court concluded that the error was harmless beyond a reasonable doubt, as the jury's determination that Trifiletti did not act in self-defense was surely unattributable to the witness's testimony. Therefore, the court reversed the decision of the court of appeals. View "State of Minnesota vs. Trifiletti" on Justia Law

The case revolves around the 1986 murder of Nancy Daugherty. The defendant, Michael Allan Carbo Jr., was charged with two counts of first-degree murder. The prosecution's case was based on DNA evidence collected from the crime scene and Carbo's garbage, which matched Carbo's DNA. Carbo sought to suppress this evidence, arguing that the collection and analysis of his DNA violated his Fourth Amendment rights. He also sought to introduce evidence suggesting that another individual, B.E., was the actual perpetrator.The district court denied Carbo's motion to suppress the DNA evidence, ruling that Carbo had abandoned his expectation of privacy by leaving his semen at the crime scene and his garbage in a communal bin. The court also denied Carbo's motion to introduce alternative-perpetrator evidence, concluding that the proffered evidence did not have an inherent tendency to connect B.E. to the crime.The Minnesota Supreme Court affirmed the lower court's decision regarding the DNA evidence. It held that Carbo had indeed abandoned his subjective expectation of privacy in the genetic information gathered from the crime scene and his garbage. However, the court reversed the lower court's decision on the alternative-perpetrator evidence. It found that the district court had abused its discretion by holding Carbo's evidentiary proffer to an unobtainable legal standard, thereby violating his constitutional right to present a complete defense. The court concluded that the error was not harmless and remanded the case for further proceedings. View "State of Minnesota vs. Carbo" on Justia Law

The case involves Jerry Arnold Westrom, who was convicted of first-degree premeditated murder and second-degree intentional murder. The victim, Jeanie Childs, was found stabbed to death in her apartment in 1993. The case went cold until 2018 when police began working with the FBI to review Childs’ murder. They sent a DNA sample from the crime scene to DNA Solutions, Inc. to create a single nucleotide polymorphism (SNP) profile that could be compared with profiles on commercial genealogical databases to identify the source’s relatives. A potential match was located on MyHeritage that appeared to be a first cousin to the source of the crime scene DNA. Law enforcement then used the match to construct a family tree that identified Westrom as the likely source.The district court denied Westrom’s motion to suppress all evidence stemming from the police’s comparison of the SNP profile created from DNA gathered from the crime scene with other profiles on commercial genealogical databases. His motion also contested the admissibility of evidence obtained through the STR analysis of DNA taken from his discarded napkin. The district court concluded that no search had occurred because Westrom held no expectation of privacy in the information contained within his DNA when police only used his DNA for the purpose of identification.The Minnesota Supreme Court affirmed Westrom’s conviction of first-degree premeditated murder. The court found that the district court did not err in concluding that the genetic analysis of a napkin discarded by Westrom was not a search under the United States or Minnesota Constitutions. The court also found that the circumstantial evidence was sufficient to support Westrom’s convictions. However, the court reversed the second-degree murder conviction and remanded to the district court to vacate that conviction, as it was an error to convict Westrom of both first-degree felony murder and the lesser-included offense of second-degree intentional murder. View "State of Minnesota vs. Westrom" on Justia Law

The case involves the Alaska Trappers Association and the National Trappers Association (collectively, the Trappers) who challenged a city ordinance enacted by the City of Valdez. The ordinance regulated animal trapping within the city limits, barring trapping in certain areas for the purpose of protecting public safety and domesticated animals. The Trappers argued that the ordinance was invalid and unconstitutional, asserting that it was preempted by state law and violated the Alaska Constitution.The Superior Court of the State of Alaska, Third Judicial District, Valdez, granted summary judgment in favor of the City of Valdez. The court concluded that the legislature's delegation of authority to the Board of Game was limited and did not grant the Board exclusive control of trapping. The court also determined that the ordinance did not directly contradict state regulations.Upon appeal, the Supreme Court of the State of Alaska affirmed the lower court's decision. The Supreme Court held that the ordinance was not prohibited by the Alaska Constitution or the legislature’s delegation of authority over fish and game to the Board. The court concluded that the ordinance was not impliedly prohibited by state law, as it was enacted pursuant to Valdez's authority to regulate land use and public safety, and was not substantially irreconcilable with the State's authority to regulate the conservation, development, or utilization of game. View "Alaska Trappers Association, Inc. v. City of Valdez" on Justia Law

The case involves Maria Esparraguera, a career appointee in the Senior Executive Service (SES), who was removed from her position by the Department of the Army. Esparraguera claimed that her constitutional due process rights were violated by the Army. The district court dismissed her suit, stating that she failed to show that the removal implicated a property interest protected by the Due Process Clause.Previously, the district court had dismissed Esparraguera’s due process claim, finding that she had no constitutionally protected property interest in her SES status. The court did not address whether the process Esparraguera received (or the absence thereof) complied with the Due Process Clause. Esparraguera appealed this decision.The United States Court of Appeals for the District of Columbia Circuit reversed the district court's decision. The appellate court found that Esparraguera had a protected property interest in her SES status. The court reasoned that the statutory and regulatory provisions applicable to her case gave Esparraguera a property interest in her SES status. The court also concluded that the government was required to provide her, at a minimum, some form of meaningful notice and an opportunity to be heard before removing her from the SES. The case was remanded back to the district court for further proceedings. View "Esparraguera v. Department of the Army" on Justia Law