Justia Constitutional Law Opinion Summaries

In 2024, the Supreme Court of Florida affirmed the convictions and death sentences of Everett Glenn Miller for the first-degree premeditated murders of Kissimmee Police Officers Matthew Baxter and Richard “Sam” Howard. In August 2017, Miller had interrupted a conversation Officer Baxter was having with three individuals, requesting the presence of a superior officer at the scene. After Sergeant Howard arrived, Miller shot both officers twice in the head from close range. At the time of his arrest later that night, Miller was found carrying two firearms, including the murder weapon.Prior to the murders, Miller, a former Marine, had been posting hateful anti-police and race-based comments on social media. At trial, Miller did not dispute that he had killed the officers, but his defense argued that premeditation was lacking and that the murders should be considered second-degree. The jury convicted Miller of two counts of first-degree premeditated murder and unanimously recommended death for each murder.Miller raised seven issues on appeal, including arguments about the admissibility of certain evidence, the qualifications of an expert witness, the presence of the cold, calculated, and premeditated (CCP) aggravating factor, and the constitutionality of Florida's capital punishment scheme. The court found no merit in any of these arguments and affirmed Miller's convictions and death sentences. View "Miller v. State of Florida" on Justia Law

In this appeal of a criminal case, the Supreme Court of the State of Utah concluded that the police officers' warrantless entry and search of Alexander Hung Tran’s home were reasonable and justified under the emergency aid exception to the Fourth Amendment of the United States Constitution. The court also declined to recognize broader protection under the Utah Constitution in the emergency aid context. The case arose when Tran appealed the district court’s denial of his motion to suppress evidence that police officers obtained during a warrantless entry and search of his home. The officers had entered Tran's home due to their belief that two individuals inside were in need of immediate aid, which was supported by a range of factors. The court held that the totality of the circumstances known to the police officers at the time they entered Tran’s home supported an objectively reasonable basis to believe that the two individuals were in need of immediate aid, thus falling within the emergency aid exception to the Fourth Amendment's warrant requirement. View "State v. Tran" on Justia Law

In this case, the United States Court of Appeals for the Fourth Circuit was asked to determine the constitutionality of a process for selecting a student member of a county school board in Howard County, Maryland. Two parents sued the board, arguing that allowing public-school students to elect the student member diminishes adults’ voting power, violating the Equal Protection Clause, and that the selection process violates the Free Exercise Clause as it excludes students who opt not to attend public schools, including those who do so for religious reasons.The court affirmed the dismissal of both claims. It held that the selection process was "basically appointive rather than elective," therefore, the one-person, one-vote principle derived from the Equal Protection Clause was not applicable. The court also found that the selection process was neutral and generally applicable, thus it did not violate the Free Exercise Clause. The process excluded students who chose not to attend public school for any reason, not just those who did so for religious reasons. View "Kim v. Board of Education of Howard County" on Justia Law

In the case before the United States Court of Appeals for the Eighth Circuit, Jesse and Dustin Sierra, convicted of various charges including kidnapping, interstate domestic violence, and aiding and abetting both offenses, respectively, appealed their convictions. Jesse Sierra challenged the district court’s decision to exclude evidence of the victim’s other traumatic experiences, arguing that it violated his Fifth and Sixth Amendment rights. He also argued that the government suppressed exculpatory or impeachment material, violating the Brady v. Maryland precedent. Dustin Sierra challenged the sufficiency of the evidence for his convictions and argued that his trial should have been severed from Jesse's trial due to the prejudicial nature of the testimony and evidence presented. The Court of Appeals affirmed the district court’s decisions, holding that the exclusion of the victim's other traumatic experiences did not violate Jesse's constitutional rights, and that no Brady violations had occurred. The court also found that the evidence against Dustin was sufficient for the convictions and that there was no severe prejudice warranting a separate trial. View "United States v. Jesse Sierra" on Justia Law

The Supreme Court of Montana overturned the conviction of Daniel Christopher Rowe for sexual assault, a felony. Rowe was initially charged with the offense for multiple instances of abuse that allegedly took place over several years against H.B., who was under sixteen years of age at the time of the offenses. The case was remanded for a new trial due to two significant issues.First, the court found the lower court erred in admitting a subsequent uncharged act of sexual assault as proof of motive or plan to commit the earlier sexual assaults charged under a "common scheme." The court reasoned that the State had charged Rowe with a non-existent offense not recognized under Montana law, which led to the improper admission of other bad acts evidence.Second, the court found that the lower court erred in giving the jury both conduct-based and result-based definitions of "knowingly" for the sexual assault charge without specifying to the jury which definition applied to which elements of the offense. The court determined that this lowered the State's burden of proof, which violated Rowe's right to due process. The Supreme Court of Montana reversed Rowe's sexual assault conviction and remanded the case for further proceedings. View "State v. Rowe" on Justia Law

In Rhode Island Truck Center, LLC v. Daimler Trucks North America, LLC, the United States Court of Appeals for the First Circuit was asked to determine whether a Rhode Island truck dealer could challenge a ruling by a Rhode Island state agency that it lacked jurisdiction to grant relief for alleged violations of a Rhode Island law regulating motor-vehicle dealers and manufacturers. The violations in question were committed by an out-of-state truck manufacturer. The plaintiff, Rhode Island Truck Center, LLC ("RITC"), argued that the manufacturer's establishment of a dealership outside of Rhode Island violated the law and harmed RITC's business. The District Court granted summary judgment to the manufacturer, Daimler Trucks North America, LLC, arguing that the state agency lacked authority to apply Rhode Island law extraterritorially.The Court of Appeals concluded that it had subject-matter jurisdiction over the case under the federal-question jurisdiction. The court then certified a question of state law to the Rhode Island Supreme Court concerning whether a "relevant market area" specified in Rhode Island law could extend beyond Rhode Island's borders. The court affirmed the District Court's grant of summary judgment on another claim, where RITC challenged the Board's dismissal of a claim related to Daimler's denial of a Western Star franchise to RITC. The court held that the District Court did not err in concluding that the relief requested would have an extraterritorial effect that violated the Dormant Commerce Clause. View "Rhode Island Truck Ctr v. Daimler Trucks North America" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, plaintiff Shawn McBreairty claimed that a local school-board policy violated his First Amendment rights by restricting what he could say at the board's public meetings. McBreairty sought a temporary restraining order and preliminary injunction against the policy. The defendants were the School Board of Regional School Unit 22 in Maine and Heath Miller, the Board's chair. The policy in question prohibited public complaints or allegations against any school system employee or student during board meetings. It also allowed the Chair to terminate any presentation that violated these guidelines or the privacy rights of others.McBreairty had been stopped from criticizing school employees during two separate board meetings. Each time, after he mentioned a teacher's name and criticized their practices, the Chair warned him to stop, the video feed was cut, and the police were contacted to remove him from the premises. He was not arrested or charged with any crime on either occasion.The District Court denied McBreairty's request for a temporary restraining order and preliminary injunction. He then appealed this decision. While this appeal was pending, the School Board amended the policy in question.The Court of Appeals vacated the decision of the District Court, not on the merits of McBreairty's First Amendment claims, but on the grounds that he lacked standing to seek the injunctive relief at issue. The Court reasoned that McBreairty did not sufficiently demonstrate an intention to engage in the allegedly restricted speech at future board meetings, which is necessary to establish a concrete, live dispute rather than a hypothetical one. The Court thus concluded that it did not have jurisdiction to hear the case under Article III of the Constitution. The case was remanded to the District Court for further proceedings. View "McBreairty v. Miller" on Justia Law

In this case, Grace Katana appealed his conviction for conspiracy to interfere with interstate commerce by robbery in violation of the Hobbs Act. He argued that the indictment accused him of conspiring to rob Joseph Wilson, while the government only proved at trial that he had planned a break-in at Wilson's home. Katana claimed that this constituted a constructive amendment to the indictment in violation of his constitutional rights, that there was a prejudicial variance from the charge in the indictment, and that there was insufficient evidence to support his conviction.The United States Court of Appeals for the First Circuit rejected Katana's arguments and affirmed his conviction. The court found that the offense charged in the indictment was the same offense on which the court instructed the jury and on which the government presented evidence. The court also held that the identity of the robbery target was not an element of a robbery or conspiracy to commit robbery under the Hobbs Act, so focusing on Wilson's home business as the target at trial did not amount to a constructive amendment. The court further concluded that Katana failed to demonstrate that any variance from the indictment was prejudicial, as the record showed he had sufficient notice of, and was able to defend himself against, the government's theory at trial. Finally, the court ruled that a rational jury could have concluded that Katana and his co-conspirators planned to rob Wilson's home business, so there was sufficient evidence to support his conviction. View "US v. Katana" on Justia Law

In the case before the United States Court of Appeals for the First Circuit, the defendant, Randall Crater, was convicted of wire fraud, unlawful monetary transactions, and operating an unlicensed money transmitting business based on his involvement in a cryptocurrency scheme. The trial lasted eight days and was based on Crater's management of My Big Coin (MBC), a cryptocurrency company that allegedly misrepresented itself as a gold-backed digital currency and claimed a partnership with MasterCard. The defendant appealed two of the district court's rulings.Firstly, Crater argued that the district court violated his Sixth Amendment right to compulsory process by refusing to enforce subpoenas against three federal agency witnesses due to Crater's non-compliance with the agencies' Touhy regulations. Secondly, Crater contended that the district court did not perform its gatekeeping duty by admitting testimony from the government's cryptocurrency expert without holding a Daubert hearing.However, the Court of Appeals affirmed the district court's decision, stating that Crater's arguments could not be reconciled with controlling precedent or the record in the case. The court found that Crater's failure to show how the excluded testimony of the federal agents would have been both material and favorable to his defense invalidated his Sixth Amendment claim. Furthermore, the court held that Crater's objections to the expert witness's qualifications and methodology were insufficient to necessitate a Daubert hearing. View "US v. Crater" on Justia Law

In this case, the United States Court of Appeals for the Second Circuit affirmed a decision from the United States District Court for the District of Vermont. The defendant, Cory Johnson, had been convicted for the production of child pornography and challenged his conviction on the basis of a motion to suppress evidence and a motion to dismiss the indictment.The evidence in question was a video depicting the sexual abuse of a toddler, which had been found following a review of digital data seized from Johnson's devices. This review had taken place after his sentencing for an earlier prosecution. Johnson argued that this review violated his Fourth Amendment rights, as it had taken place after the sentencing and had looked for evidence of a new crime. The court disagreed, ruling that the review was within the scope of the original search warrant and did not violate the Fourth Amendment.Johnson also argued that his second prosecution was barred by his earlier plea agreement. He contended that the plea agreement prohibited future prosecution for offenses "known to the United States as of the date it signed the agreement." The court, however, found that the government had not been aware of Johnson’s sexual abuse of his daughter and his production of child pornography at the time of the agreement. Thus, the plea agreement did not preclude his subsequent prosecution for these crimes.In conclusion, the court affirmed Johnson's conviction. View "United States v. Johnson" on Justia Law