Justia Constitutional Law Opinion Summaries

The case involves a group of employees and students at the University of Colorado Anschutz Campus who challenged the university's COVID-19 vaccine mandate. The plaintiffs, identified as Jane Does 1-11 and John Does 1, 3-7, argued that the university's policies regarding religious exemptions from the vaccine mandate violated their First Amendment rights.The university initially allowed individuals to attest to their exemption based on religious beliefs using a simple form. However, in August 2021, the university implemented a new policy that required individuals seeking a religious exemption to provide additional information about their religious beliefs and to demonstrate that their religion opposes all immunizations. The university denied all of the plaintiffs' requests for religious exemptions under this policy and enforced the vaccine mandate against them.The plaintiffs filed a lawsuit seeking a preliminary injunction against the university's policies. The district court denied their motion, ruling that the plaintiffs had failed to show that they were likely to succeed on the merits of their claims. The plaintiffs appealed this decision.The United States Court of Appeals for the Tenth Circuit reversed the district court's decision. The appellate court found that the university's policies were not neutral or generally applicable and were likely motivated by religious animus. The court held that the policies violated the Free Exercise and Establishment Clauses of the First Amendment and were subject to strict scrutiny, which they did not survive. The court concluded that the plaintiffs were likely to succeed on the merits of their claims and that they were entitled to a preliminary injunction against the university's policies. View "Doe v. Board of Regents of the University of Colorado" on Justia Law

The case involves Douglas Smith, a non-Indian, who was convicted of involuntary manslaughter for an act he committed on his property located within the exterior boundaries of the Pueblo of Santa Clara. Smith shot and killed Maria Gallegos, who he saw trying to break into a trailer on his property. Prior to trial, Smith moved to dismiss the case for lack of federal jurisdiction, arguing that the federal district court lacked criminal jurisdiction over crimes committed on his property and that Congress acted outside its constitutional authority when it passed the Indian Pueblo Land Act Amendments of 2005. The district court denied his motion.Smith's case was appealed to the United States Court of Appeals for the Tenth Circuit. The appellate court had to decide whether federal criminal jurisdiction extends to land owned by a non-Indian within the exterior boundaries of a Pueblo. The court affirmed the district court's decision, concluding that Smith's property is Indian country under 18 U.S.C. § 1151, and therefore, his crime is subject to federal criminal jurisdiction under 18 U.S.C. § 1152.Smith also claimed that the 2005 Amendment is unconstitutional as applied to him. The court disagreed, holding that the 2005 Amendment did not unconstitutionally extend federal criminal jurisdiction to Smith's land. The court reasoned that the 2005 Amendment only exercised preexisting federal jurisdiction over Smith's land and was thus not an unconstitutional enactment as applied to Smith.Lastly, Smith contended that the district court erred in declining his request for a two-level sentence reduction for accepting responsibility for his crime. The appellate court found no clear error in the district court's determination, noting that Smith had challenged the factual element of intent at trial, which provided a clear basis to conclude that he did not accept responsibility. The court affirmed the district court's decision. View "United States v. Smith" on Justia Law

The case revolves around Deonta Boyd, an inmate at the Richland Correctional Institution, who pleaded guilty in 2006 to aggravated murder with a firearm specification, felonious assault, and aggravated burglary. The trial court accepted Boyd's pleas and sentenced him to life imprisonment with parole eligibility after 41 years. Boyd did not appeal his convictions or sentence but has attempted unsuccessfully to withdraw his guilty pleas multiple times. In March 2023, Boyd filed a complaint for a writ of prohibition, claiming that the trial court violated his rights under the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution and their counterparts in the Ohio Constitution. He alleged that the trial court failed to inform him that he was waiving his constitutional right to compulsory process at the 2006 plea hearing.The Sixth District Court of Appeals dismissed Boyd's prohibition complaint, holding that Boyd could have challenged any defect in the plea colloquy on direct appeal and that any issue concerning the trial court’s alleged failure to advise him of his right to compulsory process is therefore barred by res judicata. Boyd appealed the dismissal of his complaint.The Supreme Court of Ohio affirmed the Sixth District Court of Appeals' judgment. The court found that Boyd had adequate remedies in the ordinary course of the law to raise his claim, including a direct appeal, a petition for postconviction relief, and a motion to withdraw his guilty pleas. The court also found that the trial court did not patently and unambiguously lack subject-matter jurisdiction to convict him. Therefore, Boyd was not entitled to a writ of prohibition, and the Sixth District correctly dismissed the prohibition action. View "State ex rel. Boyd v. Tone" on Justia Law

The case revolves around a dispute between Long Lake Township and Todd and Heather Maxon. The township alleged that the Maxons were storing junk cars on their property, violating a zoning ordinance, a nuisance law, and a 2008 settlement agreement. As the property was not visible from the street, the township hired a drone operator to take aerial photographs and video of the property without the Maxons' permission or a warrant. The Maxons moved to suppress the aerial photographs and all other evidence obtained by the township from the drone, asserting that the search was illegal under the Fourth Amendment.The Grand Traverse Circuit Court denied the Maxons’ motion, reasoning that the drone surveillance did not constitute a search. The Court of Appeals, in a split decision, reversed the lower court's ruling, holding that the drone surveillance violated the Fourth Amendment. The township appealed to the Supreme Court, which ordered the parties to file supplemental briefs regarding whether the exclusionary rule applied to the facts of this case. The Supreme Court then vacated its earlier order and remanded the case to the Court of Appeals for consideration of whether the exclusionary rule applied. On remand, the Court of Appeals, in a split decision, held that the exclusionary rule did not apply and that the photographs and video could not be suppressed regardless of whether the township unreasonably searched the Maxons’ property.The Michigan Supreme Court, in a unanimous opinion, held that the exclusionary rule may not be applied to civil enforcement proceedings that effectuate local zoning and nuisance ordinances and seek only prospective, injunctive relief. The court found that the costs of excluding the drone evidence outweighed the benefits of suppressing it, and the exclusionary rule therefore did not apply. The decision of the Court of Appeals was affirmed, and the case was remanded to the trial court for further proceedings. View "Long Lake Township v. Maxon" on Justia Law

The case revolves around Taunia Marie Whiteaker, who was convicted of second degree burglary, first degree criminal trespass, third degree assault, and harassment following a physical altercation at her mother-in-law's house. Whiteaker appealed her conviction, arguing that the district court erred by failing to merge her conviction for first degree criminal trespass into her conviction for second degree burglary.The Colorado Court of Appeals rejected Whiteaker's argument, relying on a previous ruling that first degree criminal trespass is not a lesser included offense of second degree burglary. The court reasoned that even though subsequent opinions cast doubt on the previous ruling, it was the prerogative of the Supreme Court alone to overrule its cases. One judge disagreed, believing that a recent opinion had abrogated the previous ruling, but agreed that both convictions should survive because the district court's error in failing to merge the two offenses was not plain.The Supreme Court of the State of Colorado reversed the judgment of the Court of Appeals. The court agreed with Whiteaker that first degree criminal trespass is a lesser included offense of second degree burglary, and that her overlapping convictions violated the double jeopardy clauses of the federal and state constitutions. The court held that double jeopardy sentencing errors require automatic reversal even when the error isn't obvious to the district court. Therefore, Whiteaker's convictions for trespass and burglary merge. The court remanded the case to the Court of Appeals to instruct the district court to amend the mittimus to reflect the merger of Whiteaker's conviction for first degree criminal trespass into her conviction for second degree burglary. View "Whiteaker v. People" on Justia Law

The case revolves around Denis Navratil, his wife Dimple Navratil, and their business, Dimple’s LLC, who filed a lawsuit against the City of Racine and Mayor Cory Mason. The lawsuit was based on several constitutional claims and a defamation claim against Mason. The core of the claims was the city's decision not to grant an emergency grant to Dimple’s LLC because Denis had attended a rally protesting the statewide “Safer at Home Order” that limited public gatherings, travel, and business operations to combat the COVID-19 pandemic. The rally was a violation of the Safer at Home Order and a permit required for holding rallies at the State Capitol had been denied due to the pandemic.The case was initially heard by a magistrate judge who granted summary judgment for both defendants on all claims. The plaintiffs appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The court found that Denis's attendance at the rally was not protected First Amendment activity because the rally was prohibited by two valid time, place, and manner restrictions—the Safer at Home Order and the state permit requirement. The court also rejected the plaintiffs' equal protection claims, finding no evidence of political animus or similarly situated comparators. The court further dismissed the plaintiffs' due process claims, finding no deprivation of any constitutionally protected property or liberty interest. Lastly, the court found that Mayor Mason's statements were substantially true or pure opinion and thus not actionable under defamation law. View "Denis Navratil v. City of Racine" on Justia Law

The case revolves around Viktoriya Usachenok, an employee of the Department of Treasury, who filed an internal complaint alleging sexual harassment and a hostile work environment created by her supervisor. As part of the investigation, Usachenok was directed not to discuss the investigation with others, a directive she was accused of violating when she consulted her husband, an attorney, about a document related to the investigation. Usachenok subsequently filed a complaint challenging the confidentiality directive.The Appellate Division rejected Usachenok’s constitutional challenge to the regulation, focusing on the change from a directive to a permissive “request” through an amendment. The court found that the plain language of the regulation did not restrict speech and did not constitute an improper prior restraint of speech.The Supreme Court of New Jersey, however, disagreed with the Appellate Division. The court held that the regulation, which requires state investigators to request that anyone interviewed not discuss any aspect of the investigation with others, is overbroad under the State Constitution. The court found that the regulation chills constitutionally protected speech, as it encompasses a significant amount of protected speech and its consequences are real. The court therefore struck the relevant part of the regulation, reversing the judgment of the Appellate Division and remanding the case to the trial court for further proceedings. View "Usachenok v. State of New Jersey Department of the Treasury" on Justia Law

A man named Douglas Bradford was convicted of first-degree murder in a "cold case" that was solved 35 years after the crime occurred. The case was based entirely on circumstantial evidence. The trial judge excluded exculpatory evidence of another viable suspect, Joseph Giarrusso, who had dinner with the victim on the evening of the murder and was the last known person to see her alive.The California Court of Appeal upheld the conviction, ruling that the exclusion of the evidence was consistent with the rules of evidence and therefore did not violate the Constitution. The court also found that the evidence related to Giarrusso was not sufficient to raise a reasonable doubt about Bradford's guilt.Bradford appealed to the United States Court of Appeals for the Ninth Circuit, arguing that the exclusion of the evidence violated his constitutional right to present a defense. The Ninth Circuit reversed the lower court's decision, finding that the exclusion of the evidence was both contrary to and an unreasonable application of clearly established Supreme Court law. The court also found that the decision was based on an unreasonable determination of facts. The court remanded the case with instructions to grant a conditional writ of habeas corpus, ordering Bradford's release unless the state of California notifies the district court within thirty days of the issuance of the court’s mandate that it intends to retry Bradford without excluding the evidence pertaining to Giarrusso, and commences Bradford’s retrial within seventy days of issuance of the mandate. View "BRADFORD V. PARAMO" on Justia Law

The case involves a juvenile, J.L.J., who was charged with first-degree felony murder and several other offenses after he opened fire on a car, killing a 12-year-old boy. J.L.J. was certified for adult prosecution and testified that he was acting in self-defense. The jury rejected his self-defense claim and convicted him on all charges.The case was previously heard in the Leavenworth District Court where J.L.J. was convicted. On appeal, J.L.J. raised several claims of error, including prosecutorial errors and the argument that the State unconstitutionally pitted his right to prepare for his defense against his right to testify at trial.The Supreme Court of the State of Kansas affirmed the lower court's decision. The court found that while the prosecutor erred by asking potential jurors if they would do their "job" and convict J.L.J., this error was harmless and did not affect the jury's verdict. The court also disagreed with J.L.J.'s argument that the prosecutor misstated the law on self-defense during closing argument. Furthermore, the court found that the State's impeachment of J.L.J. did not violate the unconstitutional-conditions doctrine. Lastly, the court declined to invoke an exception to the general preservation rule to address J.L.J.'s argument that the adult certification process violates his constitutional rights. View "State v. J.L.J." on Justia Law

The case revolves around two Senate Bills—2780 and 3064—passed by the Mississippi Legislature in 2022. Senate Bill 2780 established the Independent Schools Infrastructure Grant Program (ISIGP), which allowed independent schools to apply for reimbursable grants for infrastructure projects funded by the Coronavirus State Fiscal Recovery Funds under the federal American Rescue Plan Act (ARPA). Senate Bill 3064 allocated $10 million from the Coronavirus State Fiscal Recovery Fund to ISIGP. Parents for Public Schools (PPS), a nonprofit organization advocating for public schools, filed a complaint alleging that ISIGP violated the Mississippi Constitution by appropriating public funds to private schools. PPS sought injunctive and declaratory relief, asserting associational standing on behalf of its members.The Chancery Court of Hinds County found that PPS had established associational standing. It also found that Senate Bills 2780 and 3064 violated the Mississippi Constitution by appropriating public funds to private schools. The court denied a motion to intervene by the Midsouth Association of Independent Schools (MAIS), which sought to challenge the constitutionality of the relevant section of the Mississippi Constitution under the First and Fourteenth Amendments.The Supreme Court of Mississippi, however, found that PPS lacked standing to bring the lawsuit. The court determined that PPS failed to demonstrate an adverse impact different from that of the general public. The court noted that the funds at issue were federal, not state, funds earmarked for specific infrastructure needs, and were not commingled with state funds. The court also found that PPS's challenge to general government spending was too attenuated to bestow standing. As a result, the court vacated the judgment of the Hinds County Chancery Court and rendered judgment dismissing PPS's complaint. View "Midsouth Association of Independent Schools v. Parents for Public Schools" on Justia Law