Justia Constitutional Law Opinion Summaries

Albert Bustillos, an independent journalist, was filming content for his YouTube channel outside the Navajo oil refinery in Artesia, New Mexico. He was approached by refinery security and later by officers from the Artesia Police Department, including Corporal David Bailey. Despite Bustillos asserting he was on public property and had not broken any laws, Bailey arrested him for failure to identify himself in violation of New Mexico law.Bustillos sued Bailey and the City of Artesia, alleging violations of his First and Fourth Amendment rights and New Mexico law. The defendants moved for summary judgment, arguing that Bailey was entitled to qualified immunity. The district court denied the motion, rejecting Bailey’s qualified immunity defense.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of qualified immunity. The court found that Bailey lacked reasonable suspicion of a predicate crime, which is required to lawfully arrest someone for concealing identity. The court also found that Bustillos had met his burden to show that Bailey violated his clearly established Fourth Amendment rights. The court dismissed the portion of the appeal relating to Bustillos’s state-law claims, as the defendants had failed to meet their burden to support pendent appellate jurisdiction. View "Bustillos v. City of Artesia" on Justia Law

Jeremy Travis Payne, a California parolee, was arrested and charged with possession with intent to distribute fentanyl, fluorofentanyl, and cocaine. The charges stemmed from evidence obtained from a house in Palm Desert, California, and from Payne's cell phone, which was unlocked by police using Payne's thumbprint during a traffic stop. Payne moved to suppress the evidence, arguing that the search of his phone and the house violated his Fourth and Fifth Amendment rights.The district court denied Payne's motion. It found that the search of Payne's phone was reasonable under the Fourth Amendment given Payne's parole status and the conditions of his parole, which allowed for suspicionless searches of his property. The court also determined that the use of Payne's thumbprint to unlock his phone was not testimonial and therefore did not violate his Fifth Amendment privilege against self-incrimination.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the search of Payne's phone did not violate the Fourth Amendment. It found that the search was authorized under a general search condition of Payne's parole, which allowed for the suspicionless search of any property under Payne's control. The court also held that the search of Payne's phone was not unreasonable under California law, which prohibits arbitrary, capricious, or harassing searches.Regarding the Fifth Amendment claim, the court held that the use of Payne's thumbprint to unlock his phone was not testimonial because it required no cognitive exertion. Therefore, the Fifth Amendment did not apply.Finally, the court held that there was sufficient probable cause to support the issuance of a search warrant for the house in Palm Desert, California, without regard to observations made during a challenged protective sweep of the house. View "USA V. PAYNE" on Justia Law

Devonte Veasley was charged with possessing a firearm while using a controlled substance, following an incident where he shot at his drug dealer. Veasley pleaded guilty to the charge. However, after the Supreme Court ruled in New York State Rifle & Pistol Ass’n v. Bruen that a New York law requiring "proper cause" to carry a firearm violated the Second Amendment, Veasley sought to withdraw his plea or have the indictment dismissed. He argued that the federal statute under which he was charged, 18 U.S.C. § 922(g)(3), which criminalizes the possession of a firearm by someone using or addicted to a controlled substance, was facially unconstitutional. The district court did not allow him to withdraw his plea or dismiss the indictment.On appeal, the United States Court of Appeals for the Eighth Circuit rejected Veasley's facial challenge to the statute. The court reasoned that the prohibition of firearm possession by drug users or addicts does not always violate the Second Amendment. The court drew analogies to historical regulations that restricted the rights of certain groups, such as the mentally ill and those who used firearms to terrorize others, to bear arms. The court concluded that, at least for some drug users, the statute imposes a comparable burden on the right to bear arms and serves a comparable justification. Therefore, the court affirmed the judgment of the district court. View "United States v. Veasley" on Justia Law

The case involves Jameal M. Mosley, who was charged with unauthorized possession and transportation of a machine gun, being a felon in possession of a firearm for the benefit of a street gang, and being a felon in possession of ammunition. These charges stemmed from warrantless searches of Mosley's car and person, which yielded a loaded magazine and a Glock handgun with an automatic switch. Mosley filed a motion to suppress the magazine and handgun, arguing that the searches were unsupported by probable cause or reasonable suspicion.The trial court held a suppression hearing. The Sacramento County Sheriff’s Department had received a call about a group of men creating a music video in a parking lot, with one of them holding a handgun. The officers arrived at the scene and detained all members of the group, including Mosley. They found a firearm on one of the men, D.M., and another firearm in D.M.'s car. Mosley was detained for approximately 41 minutes before his car was searched, revealing a loaded magazine. A subsequent search of Mosley's person revealed a Glock handgun with a switch. The trial court denied Mosley's motion to suppress, finding that the officers had probable cause to search Mosley's car and that the detention was not prolonged.Mosley filed a petition for writ of mandate with the Court of Appeal of the State of California, Third Appellate District. The appellate court agreed with Mosley's argument that the trial court erred in finding the warrantless searches were supported by probable cause and reasonable suspicion. The court concluded that the officers lacked probable cause to search Mosley's car and that the detention was unlawfully prolonged. The court granted Mosley's petition, directing the trial court to vacate its order denying Mosley's motion to suppress and enter a new order granting the motion. View "Mosley v. Superior Court" on Justia Law

The case involves Clifford Alan Dilbert, who filed petitions for clemency and/or commutation of his prison sentence with the Governor's office in 2016, 2017, 2019, and 2021. Dilbert claimed that he had not received any communication from the Governor's office regarding the processing of his clemency petition. He sought a writ of mandate to compel Governor Gavin Newsom to process his applications and reapplications for clemency/commutation, render a decision on those applications, and notify him of the decision in a timely manner.The Superior Court of Sacramento County sustained the Governor’s demurrer to the petition without leave to amend. The court concluded that Dilbert does not have a due process right to have his applications processed within a particular time frame and the law imposes no duty to process clemency applications within a particular time frame. Dilbert appealed this decision.The Court of Appeal of the State of California Third Appellate District affirmed the trial court’s order. The appellate court found that neither the California Constitution nor any provision of Penal Code sections 4800 to 4813 contains an express requirement that the Governor process clemency applications within a specified time frame. The court also rejected Dilbert's argument that the application instructions created an obligation for the Governor to grant discretionary clemency within a certain amount of time. The court concluded that Dilbert does not have a due process right under the Fourteenth Amendment of the U.S. Constitution and article I, section 7 of the California Constitution to have his application processed within a certain time frame. View "Dilbert v. Newsom" on Justia Law

Travis Lester, a convicted felon, was arrested and charged with possession of a firearm after law enforcement officers found a stolen .40 caliber pistol in his motel room. The arrest occurred after Lester violated the terms of his supervised release from a previous conviction for possessing ammunition as a felon. During the arrest, officers found a baggie of crack cocaine and $869 in cash on Lester's person. Lester admitted to having marijuana in his motel room. Based on this information, officers obtained a search warrant for the room, where they found the pistol, a digital scale, and a small bag of marijuana.Prior to his trial, Lester filed a motion to suppress the evidence obtained from the officers' protective sweep of his motel room and his admission about the marijuana, arguing that these violated his Fourth Amendment and Miranda rights. The district court denied this motion, finding that the officers had not violated Lester's rights. At trial, the jury convicted Lester, and the district court sentenced him to 120 months in prison. The court also imposed an additional seventeen-month prison sentence to be served consecutively due to Lester's violation of the supervised-release conditions from his earlier conviction.On appeal to the United States Court of Appeals for the Sixth Circuit, Lester argued that his Miranda and Fourth Amendment rights were violated, that there were evidentiary errors, and that there were mistakes in his sentencing. The appellate court disagreed with Lester's claims and affirmed the district court's decision. The court held that the officer's question during Lester's arrest was not an interrogation under Miranda, and that the protective sweep of Lester's motel room did not violate his Fourth Amendment rights. The court also found no error in the district court's evidentiary rulings or in its sentencing of Lester. View "United States v. Lester" on Justia Law

A West Virginia law, known as the "Save Women's Sports Act," stipulates that athletic teams or sports designated for females, women, or girls shall not be open to students of the male sex, with "male" defined as an individual whose biological sex determined at birth is male. The law was challenged by a 13-year-old transgender girl, B.P.J., who has been taking puberty-blocking medication and has publicly identified as a girl since the third grade. B.P.J. argued that the law violated the Equal Protection Clause and Title IX by preventing her from participating in her school's cross country and track teams.The United States District Court for the Southern District of West Virginia initially granted a preliminary injunction, allowing B.P.J. to participate in her school's sports teams. However, upon review of cross-motions for summary judgment, the court reversed its decision, rejecting B.P.J.'s claims and ruling that the law was constitutional and did not violate Title IX.On appeal, the United States Court of Appeals for the Fourth Circuit disagreed with the lower court's decision. The appellate court held that the law could not lawfully be applied to prevent B.P.J. from participating in her school's sports teams. The court found that the law's sole purpose and effect were to prevent transgender girls from playing on girls' teams, which was not substantially related to an important government interest. The court also found that the law violated Title IX by treating B.P.J. worse than people to whom she was similarly situated, depriving her of any meaningful athletic opportunities, and doing so on the basis of sex. The court dismissed the cross-appeal, vacated in part, reversed in part, and remanded the case with instructions to enter summary judgment for B.P.J. on her Title IX claims. View "B.P.J. v. West Virginia State Board of Education" on Justia Law

Richard DeVillier and over 120 other property owners in Texas alleged that the State of Texas had taken their property for stormwater storage without just compensation, in violation of the Takings Clause of the Fifth Amendment. The state had installed a barrier along a highway median to prevent stormwater from covering the road, which resulted in flooding on the petitioners' land during heavy rainfall. DeVillier argued that the Takings Clause itself authorized him to bring suit, even if the legislature had not affirmatively provided a cause of action.The District Court denied Texas' motion to dismiss the federal inverse-condemnation claim, concluding that a property owner may sue a State directly under the Takings Clause. However, the Court of Appeals disagreed, holding that the Fifth Amendment Takings Clause, as applied to the states through the Fourteenth Amendment, does not provide a right of action for takings claims against a state.The Supreme Court of the United States vacated the judgment of the Court of Appeals and remanded the case for further proceedings. The Court found that Texas law provides a cause of action that allows property owners to vindicate their rights under the Takings Clause. Therefore, DeVillier's claims may proceed under Texas' state-law cause of action. The Court did not resolve the question of whether a property owner may sue for just compensation directly under the Takings Clause, as it was not necessary to do so in this case. View "DeVillier v. Texas" on Justia Law

Austin Stryker was convicted for malice murder and other crimes related to the shooting and stabbing death of Hannah Bender. Stryker was a member of a small gang, and the prosecution argued that he killed Bender because he suspected she was informing on the gang's activities. Stryker was charged with multiple counts, including malice murder, felony murder, aggravated assault, aggravated battery, possession of a firearm and knife during the commission of a felony, violating the Street Gang Terrorism and Prevention Act, concealing the death of another, and tampering with evidence. The jury found him guilty on all counts, and he was sentenced to life in prison without the possibility of parole for malice murder, along with consecutive sentences for other charges.Stryker appealed his convictions, arguing that the trial court violated his constitutional right to present a complete defense when it prevented his counsel from making a closing argument that co-defendants Issac Huff and Dylan Reid would have faced minimum sentences of life in prison had they not pled guilty. He also contended that the prosecutor personally attacked his defense counsel in closing argument and that the trial court erred in failing to charge the jury on “grave suspicion” after the prosecutor allegedly misconstrued the beyond-a-reasonable-doubt standard in closing arguments.The Supreme Court of Georgia affirmed Stryker's convictions, concluding that his claims failed. However, the court identified merger errors in Stryker’s sentencing that required correction, and thus vacated part of the judgment. View "STRYKER v. THE STATE" on Justia Law

A California-based psychologist, Dr. Rick Q. Wilson, was investigated by the Drug Enforcement Administration (DEA) for potential violations of the Controlled Substances Act. The DEA issued an administrative subpoena to obtain Wilson's medical, prescription, and billing records. Wilson challenged the subpoena on statutory, constitutional, and privacy grounds.The district court initially dismissed the United States' petition to enforce the subpoena, finding it violated the Health Insurance Portability and Accountability Act (HIPAA) and the Fourth Amendment. However, upon reconsideration, the court granted the United States' motion to amend the petition and enforce a narrowed version of the subpoena.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that the modified subpoena complied with HIPAA, was not unreasonably burdensome under the Fourth Amendment, and did not violate Wilson's Fifth Amendment privilege against self-incrimination due to the required-records exception. The court held that the subpoena was issued within the DEA's authority, was relevant to the DEA's investigation, and was not unreasonably broad or burdensome. The court also found that the records requested fell within the required-records exception to the Fifth Amendment's privilege against self-incrimination. View "United States v. Wilson" on Justia Law