Justia Constitutional Law Opinion Summaries

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

The case involves Shirley Ann Carpin, who sued Vermont Yankee Nuclear Power Corporation and Clifton Associates on behalf of her mother's estate for negligence and wrongful death. She alleged that the defendants caused the asbestos exposure that led to her mother's mesothelioma and subsequent death. Her mother, Shirley Hilster, was exposed to asbestos through her husband, who worked as a pipefitter and regularly came home with asbestos-contaminated clothes. Hilster's husband worked for Vermont Yankee Nuclear Power Corp., where Clifton Associates had installed asbestos. Hilster was diagnosed with mesothelioma, a cancer caused by asbestos exposure, in July 2020 and died three months later.The Superior Court granted summary judgment to the defendants based on the twenty-year statute of repose under 12 V.S.A. § 518(a), finding the “last occurrence” to which her mother’s mesothelioma was attributed fell outside the repose period. Carpin appealed, arguing that her claims are not barred by § 518(a)’s repose period and, in the alternative, that § 518(a) violates the Vermont Constitution.The Vermont Supreme Court affirmed the lower court's decision. The court determined that the “last occurrence” to which Hilster’s mesothelioma was attributed was her last known exposure to asbestos in 1995. The court further concluded that the statute was constitutional. The court rejected Carpin's argument that the “last occurrence” was the cellular changes that resulted in her 2020 mesothelioma diagnosis. The court also rejected Carpin's constitutional challenge, finding that the statute of repose did not arbitrarily disadvantage any part of the community and was a valid legislative prerogative. View "Carpin v. Vermont Yankee Nuclear Power Corporation" on Justia Law

The defendant, John R. Cantu, was charged with multiple counts including felony stalking, violation of protection from stalking orders, criminal damage to property, criminal trespass, and felony criminal threat. During his trial, Cantu testified on his own behalf as the sole defense witness. However, during cross-examination, the judge removed Cantu from the stand for being uncooperative and, at the prosecutor's request, struck his entire testimony from the record. Cantu was subsequently convicted on several counts and appealed, arguing that the district court's decision to strike his entire testimony from the record deprived him of his constitutional right to testify, which was structural error requiring automatic reversal.The Court of Appeals agreed that the district court erred in ordering Cantu's testimony stricken from the record and that this error denied Cantu the constitutional right to testify. However, the panel held that the error was not structural, but could be analyzed using the harmless error standard. The panel concluded that the error was harmless and affirmed the convictions.The Supreme Court of the State of Kansas disagreed with the Court of Appeals' conclusion. The Supreme Court held that the complete and improper denial of a criminal defendant's constitutional right to testify is structural error. The court reasoned that the right to testify is a fundamental right grounded in multiple provisions of the United States Constitution. The court further explained that structural errors are defects affecting the fundamental fairness of the trial's mechanism, preventing the trial court from serving its basic function of determining guilt or innocence and depriving defendants of basic due process protections required in criminal proceedings. The court concluded that the complete and wrongful denial of a defendant's constitutional right to testify by improperly removing a defendant from the stand and striking the defendant's entire testimony is structural error because it renders the criminal trial fundamentally unfair, regardless of whether the outcome of the trial would have been different had the defendant been permitted to testify and his or her testimony been left intact. Therefore, the Supreme Court reversed Cantu's convictions and remanded for a new trial. View "State v. Cantu" on Justia Law

The case involves a convicted felon, Adam Aaron Rhodes, who was charged with possession of a firearm, a muzzleloader replica of an antique firearm, in violation of Iowa Code section 724.26(1). Rhodes argued that his muzzleloader, used to kill a deer, was not a firearm within the meaning of the statute because it was a replica of an antique firearm, which is excluded from the statutory definition of "offensive weapon," and federal law excludes such muzzleloaders from the federal definition of "firearm."The district court disagreed with Rhodes, finding him guilty of possessing a "firearm" under the common meaning of the term and the court's precedent. The court defined a "firearm" broadly to include "any instrument which will or is designed to discharge a projectile by the force of a chemical explosive such as gun powder." The court also rejected several affirmative defenses raised by Rhodes, including a void for vagueness constitutional challenge. Rhodes was sentenced to probation for a period not to exceed five years.On appeal, the Supreme Court of Iowa affirmed the district court's judgment. The court held that Rhodes's muzzleloader falls within the meaning of "firearm" in section 724.26. The court reasoned that the Iowa legislature declined to enact the federal definition of "firearm" and that the court's precedents apply the common meaning of "firearm" that encompasses this muzzleloader rifle. The court also rejected Rhodes's argument that the court should follow the federal felon-in-possession statute, 18 U.S.C. § 922(g), when interpreting Iowa’s felon-in-possession statute. The court concluded that the Iowa legislature is free to adopt the federal exception for antique firearms but has not done so. View "State of Iowa v. Rhodes" on Justia Law

In 2000, Antonio McDowell, a juvenile at the time, was convicted of capital murder and sentenced to life without parole. Following a 2012 Supreme Court ruling in Miller v. Alabama, which deemed mandatory life sentences without parole for juvenile defendants unconstitutional, McDowell's sentence was vacated. The trial court then proceeded with a jury trial for sentencing under Mississippi Code Section 99-19-101. The jury, after considering evidence related to the Miller criteria, was unable to agree on a sentence. The trial judge, instead of imposing a sentence of life, sentenced McDowell to life without parole, a decision that was affirmed by the Court of Appeals.The Mississippi Supreme Court, on certiorari review, found that the trial court's decision to proceed with a jury trial for sentencing under Section 99-19-101 made the section applicable to the entirety of the proceedings. This applicability continued when the jury failed to agree on a sentence. Therefore, the trial court erred by conducting the Miller analysis and sentencing McDowell to life without parole. The Supreme Court reversed the judgments of the Court of Appeals and the trial court and remanded the case back to the trial court for proceedings consistent with its opinion. View "McDowell v. State" on Justia Law

The case revolves around a local ordinance in the Borough of Camp Hill that regulates the display of signs on private property. The ordinance categorizes signs into about twenty different types, each with its own set of restrictions. Two residents, Katherine Pearson and Caroline Machiraju, displayed political signs on their lawns in the lead-up to the 2022 midterm elections. However, they were told to remove their signs as they violated the local sign ordinance. The ordinance categorized their signs as "Temporary Signs" and further classified them as "Personal Expression Signs," which express a non-commercial message. The ordinance limited the number of such signs a resident could display and the time frame within which they could be displayed.The residents complied with the directive but subsequently sued Camp Hill, challenging the provisions of the ordinance under the First Amendment. The United States District Court for the Middle District of Pennsylvania granted them summary judgment on their facial challenge, ruling that the provisions were content-based and failed strict scrutiny.The United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals found that the ordinance was content-based as it classified signs based on their content, favoring commercial expression over noncommercial and holiday messages over non-holiday messages. The court held that such content-based restrictions could only stand if they furthered a compelling government interest and were narrowly tailored to achieve that interest. The court found that Camp Hill's interests in traffic safety and aesthetics, while legitimate, were not compelling and that the ordinance was not narrowly tailored to serve those interests. The court concluded that the ordinance was unconstitutional on its face. View "Camp Hill Borough Republican Association v. Borough of Camp HIll" on Justia Law

The case involves Steven Duarte, who was convicted for violating 18 U.S.C. § 922(g)(1), a law that prohibits anyone previously convicted of a crime punishable by imprisonment for over a year from possessing a firearm. Duarte, who had five prior non-violent state criminal convictions, was charged and convicted under this law after police saw him discard a handgun from a moving car.Duarte appealed his conviction, arguing that § 922(g)(1) violated his Second Amendment rights. The United States Court of Appeals for the Ninth Circuit agreed with Duarte, finding that the law was unconstitutional as applied to him, a non-violent offender who had served his time in prison and reentered society. The court held that under the Supreme Court's decision in New York State Rifle & Pistol Ass'n v. Bruen, § 922(g)(1) violated the Second Amendment as applied to Duarte. The court concluded that Duarte's weapon, a handgun, is an "arm" within the meaning of the Second Amendment, and that the government failed to prove that § 922(g)(1)'s categorical prohibition, as applied to Duarte, is part of the historic tradition that delimits the outer bounds of the Second Amendment right. As a result, the court vacated Duarte's conviction and reversed the district court's judgment. View "USA V. DUARTE" on Justia Law