Justia Constitutional Law Opinion Summaries

In this case, the United States Court of Appeals for the Fifth Circuit ruled on a civil rights lawsuit filed by James Everard and Christopher Grisham against the City of Olmos Park and several police officers. Everard and Grisham, self-identified "Second Amendment protestors", claimed their arrests on March 27, 2018, violated their First, Fourth, and Fourteenth Amendment rights. They were arrested after 911 operators received several calls about a man "with an AK-47" around his neck, standing on a busy street corner in Olmos Park. The officers arrived and found Everard with a large gun in a holster in front of his chest, and Grisham with a handgun in a holster on his hip. Everard and Grisham were charged with disorderly conduct and interference with the duties of a public servant respectively, but all charges were dismissed for insufficient evidence.The district court granted summary judgment in favor of the City and the officers, a decision that Everard and Grisham appealed. The Court of Appeals, however, affirmed the district court's decision, agreeing that the officers had probable cause to believe that Plaintiffs were engaging in criminal activity and that the officers were not objectively unreasonable in believing such probable cause existed.The court also rejected the Plaintiffs’ First Amendment claims, stating that officers cannot execute their law enforcement duties while someone is engaging in speech, where probable cause exists. The court ruled that the officers had probable cause to make the arrests for disorderly conduct and resisting arrest, thus precluding the arrestees’ retaliatory arrest claims. The court further rejected the Plaintiffs’ Fourth Amendment claims, stating that the officers are protected by qualified immunity since both Everard and Grisham could not point to any clearly established law that such force was unreasonably excessive under the circumstances. Lastly, the court affirmed the dismissal of the Plaintiffs' municipal liability claims, as they failed to establish that there were constitutional violations. View "Grisham v. Valenciano" on Justia Law

This case relates to the admission of an investigator's testimony from a preliminary hearing in a subsequent trial. The appellant, Maurice Kent, was a member of a violent gang and was charged with RICO conspiracy and five other substantive crimes, including the attempted murder of Shadeed Muhammad. The government alleged that the gang murdered a former member, Qualeef Rhode, for cooperating with the police’s investigation into the attempted murder. The government introduced an investigator’s testimony from a preliminary hearing in a related case, which identified Rhode as cooperating with law enforcement to implicate Kent in the attempted murder. Kent argued that this testimony was hearsay and its admission violated his Confrontation Clause rights.The United States Court of Appeals for the Eleventh Circuit rejected Kent's arguments and affirmed the decision of the district court. The court held that the investigator's testimony was not hearsay because it was offered for the effect it had on the listeners (other gang members) and not for the truth of the matter asserted. It was relevant because it influenced Kent and the other gang members who heard the testimony at the preliminary hearing, providing them with a motive to murder Rhode. The court also determined that the district court had sufficiently reduced the risk that the jury would improperly consider the out-of-court statement for the truth of the matter asserted by redacting the most prejudicial portions of the testimony and instructing the jury to consider the testimony only for its effect on the listeners. Therefore, the admission of the testimony did not violate Kent's rights under the Confrontation Clause. View "United States v. Kent" on Justia Law

In this case, Tony Doolin was sentenced to 60 months of imprisonment and four years of supervised release for distribution of crack cocaine. After his release, Doolin lived in Iowa and possessed a medical-marijuana card, which permitted him to obtain medical marijuana under Iowa law. However, his supervised release was revoked due to his ongoing marijuana use and his distribution of medical marijuana to his girlfriend. Doolin appealed this decision, arguing that it violated the Appropriations Clause of the United States Constitution, due to the Consolidated Appropriations Act (CAA) of 2023. This act prohibits the Department of Justice (DOJ) from using funds to prevent states from implementing their own medical marijuana laws.The United States Court of Appeals for the Eighth Circuit affirmed the decision of the District Court for the Northern District of Iowa, holding that the revocation of Doolin's supervised release did not violate the Appropriations Clause or the CAA of 2023. The court noted that marijuana possession remains illegal under federal law, regardless of any state laws or limits on prosecutorial funding. Federal courts are required to impose a prohibition on a defendant’s unlawful possession or use of all controlled substances, including marijuana, as a condition of any term of supervised release. Even if section 531 of the CAA prohibits the DOJ from funding marijuana-related prosecutions or revocations, where doing so prevents a state from implementing its medical marijuana laws, the district court did not abuse its discretion in revoking Doolin’s supervised release. Doolin engaged in unlawful conduct, even under Iowa’s medical-marijuana regime, as private distribution of marijuana is illegal under Iowa law, as is smoking marijuana, even for medical purposes. Therefore, the court found that the revocation of Doolin's supervised release was not prohibited by the CAA, and the district court did not abuse its discretion in revoking Doolin's supervised release. View "United States v. Doolin" on Justia Law

In this case, the United States Court of Appeals for the Ninth Circuit affirmed the lower court's decision to deny a preliminary injunction requested by Thomas Eugene Creech, a death row inmate. Creech raised constitutional claims concerning his execution method, arguing that the State failed to provide sufficient information about its lethal injection drug, pentobarbital, and that the execution protocol was deficient. The Court, however, found that Creech was unlikely to succeed on his claims, noting that the State had adequately disclosed the planned execution method and that Creech's arguments about the drug's provenance were speculative. Creech's Eighth Amendment claims, which focused on potential unnecessary pain during execution, were rejected as he had not identified an alternative execution method and did not have any known conditions that create a substantial risk of severe pain. Additionally, Creech's argument about the protocol's lack of requirement for an anesthesiologist and a brain monitor were dismissed as they were against Supreme Court precedent. The Court also found that the balance of equities and public interest did not favor Creech. Thus, the Court affirmed the lower court's denial of Creech's request for preliminary injunctive relief. View "CREECH V. TEWALT" on Justia Law

In the case under review, the plaintiff-appellant, Thomas Eugene Creech, currently on death row for the 1981 murder of David Dale Jensen, had sought commutation of his death sentence. The State of Idaho had granted Creech a commutation hearing before the Commission of Pardons and Parole, which ultimately denied his petition. Consequently, Creech filed a § 1983 action in federal court, alleging various due process violations during the commutation proceedings and sought a preliminary injunction. The United States District Court for the District of Idaho denied his motion, and he appealed.The United States Court of Appeals for the Ninth Circuit affirmed the lower court's decision. The Court held that the state had met the minimal procedural safeguards required by the Due Process Clause of the Fourteenth Amendment in the commutation proceedings. It rejected Creech's arguments that he was not given adequate notice of the issues to be considered by the Commission and the evidence to be presented at the commutation hearing. Additionally, the Court found that Creech was not entitled to the appointment of a replacement commissioner when one Commissioner recused himself. The Court also refuted Creech's claims that the Ada County Prosecuting Attorney’s Office violated his due process rights by suggesting to the Commission that Creech had committed another murder and got away with it, and by introducing misleading or fabricated evidence during the hearing. The Court found no violation or arbitrariness that would warrant judicial intervention. View "CREECH V. BENNETTS" on Justia Law

The United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal of a habeas corpus petition filed by Thomas E. Creech, a death row inmate in Idaho. Creech was sentenced to death in 1981 for killing a fellow prisoner while serving two life sentences for first-degree murder. In his habeas corpus petition, Creech raised an Eighth Amendment claim, arguing that societal standards have evolved since Ring v. Arizona (2002) to deem a death sentence imposed by a judge rather than a jury as unconstitutional. The Ninth Circuit disagreed, stating that Creech's claim was barred by 28 U.S.C. § 2244(b), which mandates the dismissal of most claims filed in "second or successive" federal habeas petitions. The court held that Creech's claim was ripe and could have been brought in his prior petition challenging the same judgment, making his current petition second or successive. The court also dismissed as moot Creech's motion to stay his execution while the appeal was pending. View "Creech v. Richardson" on Justia Law

In the case before the United States Court of Appeals for the Eighth Circuit, the defendant, Donavan Jay White Owl, appealed an order of the district court denying his motion to dismiss an indictment based on the Double Jeopardy Clause. White Owl had been indicted for felony murder and arson within Indian Country. A mistrial was declared during the initial trial after a dispute over White Owl’s access to information about a prosecution witness. White Owl argued that a new trial would violate his rights under the Double Jeopardy Clause of the Constitution.The Appeals Court, however, ruled that White Owl had impliedly consented to the mistrial. The court noted that while the defendant did not expressly request a mistrial, his actions and responses during the proceedings indicated his implicit agreement. Specifically, when the district court declared its intention to declare a mistrial and asked the parties for their views, White Owl did not object but instead emphasized the need for more time to prepare for cross-examination of a prosecution witness.In light of this, the court concluded that White Owl's lack of objection amounted to implied consent to a mistrial. Accordingly, the court affirmed the district court's order denying White Owl's motion to dismiss the indictment based on the Double Jeopardy Clause. View "United States v. Donavan White Owl" on Justia Law

In Kansas, Richard Daniel Showalter was convicted of two counts of first-degree premeditated murder, conspiracy to commit first-degree murder, and aggravated burglary. Showalter appealed his convictions, arguing that the trial court erred by admitting certain autopsy photographs, deposition testimony from an unavailable witness, and statements made by one of his co-conspirators. Regarding the autopsy photographs, Showalter argued they were gruesome and prejudicial, but the court found the photographs were relevant and their probative value outweighed any potential prejudice. As for the deposition testimony, Showalter claimed the court erred in finding the witness was unavailable to testify at trial, but the court ruled that the State made sufficient efforts to establish the witness’s unavailability. Regarding the co-conspirator's statements, Showalter argued they were irrelevant because the State did not prove he was aware of the co-conspirator’s claims, but the court found the statements were relevant to explain the motive and intent behind the murders. Lastly, Showalter argued that the cumulative effect of these alleged errors violated his constitutional right to a fair trial, but the court found no cumulative error as it did not find any individual errors. Accordingly, the court affirmed Showalter’s convictions. View "State v. Showalter" on Justia Law

The Supreme Court of Iowa was asked to consider whether the Iowa Constitution supports a legislative privilege that protects legislators from compelled production of documents related to legislation. The court concluded that the Iowa Constitution does indeed contain a legislative privilege that protects legislators from compelled document production, particularly in relation to communications with third parties about the legislative process. The case arose from subpoenas served on several Iowa legislators by the League of Latin American Citizens of Iowa (LULAC). LULAC sought discovery of communications related to recent legislative changes to voting procedures. The legislators objected to the subpoenas, arguing they were protected from compelled document production by a legislative privilege under the Iowa Constitution. The court ruled that the privilege extends to communications with third parties where the communications relate directly to the legislative process of considering and enacting legislation. However, the court did not decide whether this legislative privilege was absolute or qualified, as it concluded that the requested documents were not relevant to LULAC's claims and were therefore protected by the legislative privilege, regardless of its extent. The court reversed the district court's judgment granting in part LULAC's motion to compel and remanded with instructions to quash the subpoenas. View "Smith v. Iowa District Court for Polk County" on Justia Law

Donald Pierce was convicted of multiple counts of child molestation and of being a repeat sexual offender. The case revolved around the testimonies of the victim and several adults who had been told about the incidents. Pierce's lawyer did not object to the sequence of these testimonies, which violated an Indiana evidentiary rule. Pierce later petitioned for post-conviction relief, arguing that his lawyer's failure to object meant he was deprived of constitutionally adequate representation. This was denied by the Indiana Court of Appeals, which found that the lawyer's failure to object was strategic and did not constitute constitutionally deficient performance. Pierce then sought habeas relief, alleging the state appellate court had unreasonably applied Supreme Court precedent and made an unreasonable fact determination. However, the United States Court of Appeals for the Seventh Circuit affirmed the previous decision, finding that the state court did not unreasonably apply the precedent and its fact determination was not unreasonable. View "Pierce v. Vanihel" on Justia Law