Justia Constitutional Law Opinion Summaries

In this case, Jamie Avila Reyes, the appellant, appealed his 15-year prison sentence for crimes including homicide by vehicle in the first degree and driving under the influence of alcohol. Reyes, an undocumented immigrant, contended that the trial court improperly considered his immigration status during sentencing, violating his due process and equal protection rights under the Fourteenth Amendment. Reyes also argued that OCGA § 17-10-1.3, a Georgia statute that allows a trial court to consider potential deportation when determining whether to probate a convicted person's sentence, is unconstitutional both on its face and as applied to him.The Supreme Court of Georgia held that OCGA § 17-10-1.3 is constitutional. The court found that the statute survived rational basis review because it bears a rational relationship to the legitimate governmental interest in ensuring the complete execution of judicial sentences. The court also held that the trial court did not violate Reyes' due process or equal protection rights when it applied the statute and declined to probate any portion of his sentence due to his impending deportation. The court noted that there was no evidence the trial court based its sentence on discriminatory animus towards undocumented noncitizens. Therefore, the court affirmed the judgment of the trial court. View "REYES v. THE STATE" on Justia Law

In Georgia, the Fair Dismissal Act (FDA) offers certain protections to public school teachers after they have fulfilled a contract for the fourth consecutive school year with the same local board of education. This case considered whether the Charter Schools Act's waiver provision, which relieves public charter schools from complying with Title 20 (including the FDA), impairs the vested rights of teachers who had earned FDA protections before their school converted to a charter system. The Supreme Court of Georgia decided that the teachers' constitutional claims failed as a matter of law. The justices reasoned that the 1993 Charter Schools Act had already clarified that the FDA did not afford teachers any rights enforceable against charter schools. Therefore, the Charter Systems Act's retention of an FDA exemption for charter schools did not impair any rights for teachers who earned FDA rights after the 1993 Charter Schools Act was enacted. View "WOODS v. BARNES" on Justia Law

The case concerns an appeal by Carl Monroe Gordon against his conviction on the grounds of aggravated sexual abuse of a child, traveling to engage in illicit sexual conduct, and abusive sexual contact with a child. Gordon argued that his statutory and constitutional rights to a speedy trial were violated due to delays in bringing him to trial and the denial of his motion to dismiss the indictment by the district court. The United States Court of Appeals for the Fifth Circuit affirmed the district court's judgment. The Court held that the delay in bringing Gordon to trial did not violate the Speedy Trial Act since the period of delay was attributed to other proceedings related to the defendant and ends-of-justice continuances due to the COVID-19 pandemic. Furthermore, the Court determined that Gordon's Sixth Amendment right to a speedy trial was not violated as he failed to demonstrate actual prejudice resulting from the delay. View "United States v. Gordon" on Justia Law

In October 2018, Warren G. Treme, a member of AJSJS Development, LLC, leased minerals on a tract of land in St. John the Baptist Parish, Louisiana, from Dr. Christy Montegut and his siblings. AJSJS intended to join a joint venture formed in 2010 between Treme, AIMS Group, Inc., and Fred Kinsley. The joint venture aimed to extract and process clay material from the tract for a U.S. Army Corps of Engineers project. However, to conduct mining and excavation activities, the plaintiffs needed to change the zoning classification of the tract. Despite multiple applications for rezoning, the Parish Council denied the applications after hearing complaints from affected residents. The plaintiffs then sued the Parish and the Council, alleging that the denial of the rezoning application constituted a regulatory taking without compensation in violation of the United States and Louisiana Constitutions. The plaintiffs also alleged violations of procedural and substantive due process and equal protection rights under the Fourteenth Amendment.The United States Court of Appeals for the Fifth Circuit held that the plaintiffs lacked standing to bring a takings claim because their mineral lease was not yet in effect, meaning they had no vested property interest in the tract. The court interpreted the lease to have a suspensive condition that required the plaintiffs to obtain governmental approvals for the lease to become effective. As the plaintiffs had not obtained these approvals, the lease had not yet come into effect. Consequently, the court affirmed the district court’s decision but modified the judgment to be a dismissal without prejudice. View "Treme v. St. John the Baptist" on Justia Law

In this case, the State of Vermont appealed the superior court’s dismissal of charges against defendant Michael Armstrong on speedy-trial grounds. It had been more than nineteen years since the charges against defendant were first brought and more than fifteen years since defendant was adjudicated incompetent to stand trial. The trial court dismissed the charges, finding that the State had failed in its obligation to reevaluate defendant’s competency, thereby violating defendant’s constitutional right to a speedy trial. The Vermont Supreme Court reversed the trial court's decision, finding that the delay was primarily due to defendant's incompetency, which was not attributable to the State, and the State had no duty to seek a reevaluation of the defendant's competency absent an indication of changed circumstances. The Court concluded that the defendant did not make a sufficient claim of denial of his right to a speedy trial, reversed the trial court’s dismissal of the charges, and remanded for further proceedings. View "State v. Armstrong" on Justia Law

The Court of Appeals of the State of Nevada was reviewing a petition for a writ of certiorari challenging an order from the district court. Petitioner Lina Marie Willson had been convicted of obstructing a public officer. This conviction arose from an incident where Willson had yelled at police officers from her front yard while they were attending to a separate incident involving a potentially suicidal juvenile. Willson appealed her conviction, arguing that the law under which she was convicted, NRS 197.190, was unconstitutionally vague or overly broad.The court held that NRS 197.190 was not unconstitutionally vague or overly broad, either on its face or as applied to Willson. The court interpreted the law to apply only to physical conduct or fighting words that are specifically intended to hinder, delay, or obstruct a public officer in the performance of their duties. Although the court found that Willson's claims failed, it did acknowledge that her claims implicated the sufficiency of the evidence in relation to the court's interpretation of NRS 197.190.The court therefore granted the petition and directed the clerk of the court to issue a writ of certiorari upholding the constitutionality of NRS 197.190 and instructing the district court to reconsider Willson's direct appeal. The purpose of this reconsideration was to determine whether, given the court's interpretation of NRS 197.190, sufficient evidence existed to support Willson's conviction. View "Willson v. First Jud. Dist. Ct." on Justia Law

In the State of Nevada, Alexander M. Falconi, operating as the press organization Our Nevada Judges, petitioned against the Eighth Judicial District Court, the Honorable Charles J. Hoskin, District Judge, and parties in interest, Troy A. Minter and Jennifer R. Easler. Falconi challenged local rules and a statute that required certain court proceedings to be closed to the public.Falconi filed a media request for camera access in a child custody proceeding between Minter and Easler. Minter opposed the request, arguing it was not in the child's best interest to have his personal information publicly available. The district court denied Falconi's request, citing that the case was sealed and thus required to be private according to local rules.The Supreme Court of the State of Nevada held that the public has a constitutional right to access court proceedings. The local rules and the statute, NRS 125.080, requiring the district court to close proceedings, bypassed the exercise of judicial discretion and were not narrowly tailored to serve a compelling interest. Thus, the court held that these local rules and NRS 125.080 were unconstitutional to the extent they permitted closed family court proceedings without exercising judicial discretion.The court instructed the district court to reverse its order denying media access in the underlying child custody case. The court emphasized the importance of public access to court proceedings, including family court proceedings, which historically have been open to the public. The court rejected the automatic closure of such proceedings and emphasized the necessity of case-by-case judicial discretion in deciding whether to close proceedings. View "Falconi v. Eighth Jud. Dist. Ct." on Justia Law

Adrian L. Johnson was pulled over by a Deputy Sheriff for driving with a suspended license. The officer's trained dog indicated the presence of a controlled substance in Johnson's car, leading to a search of the vehicle. The officer found drugs, drug paraphernalia, and two handguns. Johnson was subsequently charged with possession of drugs with intent to distribute and possession of a firearm in furtherance of a drug trafficking crime. He moved to suppress all evidence, arguing that the search of his car violated his Fourth Amendment rights. The district court denied the motion, and Johnson pled guilty, reserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit agreed with the district court, holding that the officer did not unconstitutionally prolong the stop to conduct the dog sniff, and that the subsequent search of Johnson's car did not violate the Fourth Amendment. The officer had probable cause to search the car because the dog's alerts indicated the presence of contraband. Therefore, the judgment of the district court was affirmed. View "USA v. Johnson" on Justia Law

In the case at hand, the United States Court of Appeals for the Third Circuit affirmed the dismissal of claims brought by a group of students and Children’s Health Defense, Inc. against Rutgers University. The plaintiffs challenged the university's COVID-19 vaccination policy, which required in-person students to be vaccinated or else enroll in online programs or seek exemptions for medical or religious reasons. The court found that the university's policy did not violate the plaintiffs' constitutional or statutory rights.The court held that there is no fundamental right to refuse vaccination. It applied the rational basis review and concluded that Rutgers University had a rational basis for its policy given the challenges posed by the COVID-19 pandemic. The court also rejected the plaintiffs' claim that the policy was ultra vires under New Jersey law, determining that Rutgers was authorized to require COVID-19 vaccinations under state law. Furthermore, the court dismissed the plaintiffs' equal protection claim, concluding that Rutgers had a rational basis for its differential treatment of students and staff, as well as vaccinated and unvaccinated students. View "Children's Health Defense Inc. v. Rutgers, the State University of New Jersey" on Justia Law

In this case, the defendant, Kevin Eugene Cartwright, was convicted of first-degree murder with special circumstances, robbery, burglary, being a felon in possession of a firearm, and being a prohibited person owning or possessing ammunition. He was sentenced to life without the possibility of parole plus 50 years to life, and a determinate prison term of 20 years four months. On appeal, Cartwright contended that the trial court erred by denying his motion to suppress video footage from the City of San Diego’s “City IQ” streetlight camera program and evidence derived from that footage. The Fourth Appellate District Division One of the Court of Appeal for the State of California affirmed the trial court's decision. The court held that Cartwright did not have an objectively reasonable expectation of privacy when he traversed a public right of way in downtown San Diego in the middle of a business day. The court found that accessing the recordings from the City’s streetlight cameras did not amount to a search within the meaning of the Fourth Amendment and, consequently, did not require a warrant. The court distinguished the cameras in this case from the aerial surveillance images and integrated police department systems addressed in other precedents, stating that the City's camera program stands alone and does not reveal the transit patterns of people throughout the county. The court concluded that the police did not conduct a "search" when they accessed footage from the City's streetlight cameras and, accordingly, there was no violation of the Fourth Amendment. View "People v. Cartwright" on Justia Law