Justia Constitutional Law Opinion Summaries

The case concerns the constitutional rights of a criminal defendant, A.Z., who was involuntarily hospitalized for a competency determination under Massachusetts law, G. L. c. 123, § 15 (b). The Supreme Judicial Court of Massachusetts held that the involuntary commitment of a criminal defendant for a competency determination infringes upon a defendant's fundamental right to liberty and thus must satisfy strict scrutiny under the Massachusetts Declaration of Rights and the United States Constitution. To pass strict scrutiny, the involuntary commitment must be the least restrictive means available to vindicate the governmental interest at stake. Therefore, it is unconstitutional for a court to hospitalize a pretrial defendant for a clinical evaluation and observation of competency, absent a finding by the judge, by clear and convincing evidence, that hospitalization is the least restrictive means available to adequately determine a criminal defendant's competency to stand trial. The judge in this case did not make such findings, so the court concluded that the defendant's constitutional rights were violated. View "Commonwealth v. A.Z." on Justia Law

In a case before the United States Court of Appeals for the Fourth Circuit, the defendant, Curtis Davis, had been arrested and charged with drug and firearm offenses after law enforcement officers executing a search warrant observed him attempting to place baggies of controlled substances into an air vent. More baggies of controlled substances, firearms, cash, cell phones, and additional controlled substances were found in the residence. The district court denied Davis's motion to suppress the evidence, arguing that the search warrant was not supported by probable cause.On appeal, the Fourth Circuit upheld the district court's decision. The court found that the search warrant was valid at least as to evidence of firearms offenses. The controlled substances found on Davis's person and in his bedroom were lawfully seized either incident to Davis's arrest or because they were in plain view of the officers conducting the search. Furthermore, Davis's cell phone was lawfully seized as an instrumentality of drug trafficking found in plain view. The court emphasized that for a cell phone to be seized in plain view, the "additional evidence or indicators" of criminality have significant work to do to establish probable cause. In this case, Davis's phone was found in the residence along with substantial quantities of controlled substances that were packaged for distribution, cash, firearms, and ammunition, all found on Davis's person or in his bedroom. This evidence provided law enforcement with sufficient probable cause to seize Davis's cell phone. The judgment of the district court was affirmed. View "US v. Curtis Davis" on Justia Law

In San Diego, California, Kevin Eugene Cartwright was convicted of first-degree murder with special circumstances, robbery, burglary, being a felon in possession of a firearm, and owning or possessing ammunition as a prohibited person. Cartwright appealed the judgment, arguing that the trial court erred in denying his motion to suppress video footage from the City of San Diego's "City IQ" streetlight camera program and evidence derived from the footage. Cartwright contended that the police conducted a warrantless search when they accessed the streetlight camera footage and any evidence obtained as a result of the footage should be considered "fruit of the poisonous tree."The Court of Appeal, Fourth Appellate District, Division One, State of California, disagreed with Cartwright's argument. 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 the streetlight cameras only captured short-term movements and did not create a retrospective database of everyone's movements across the city. The court concluded that the police did not conduct a "search" when they accessed footage from the City of San Diego's streetlight cameras, and there was no violation of the Fourth Amendment. Therefore, the court affirmed the judgment against Cartwright. View "People v. Cartwright" on Justia Law

In "King County v. Michael J. Abernathy et al.", the Supreme Court of the State of Washington answered a question certified by the United States District Court for the Western District of Washington. The case involved a dispute over the ownership of a 3.6 mile section of land along the shore of Lake Sammamish, known as the Corridor. In 1887, prior to Washington becoming a state, a railroad company was granted a "right-of-way" to build a railroad over the Corridor. Since then, the Corridor and surrounding shorelands have been used by various parties including individual property owners, the state, and the county. The certified question asked whether a right-of-way approved by the United States Department of the Interior under the General Railroad Right-of-Way Act of 1875 is a conveyance "patented by the United States" under Article XVII, Section 2 of the Washington State Constitution. If the land was "patented" by the federal government, it would have been owned by the railroad and later King County. If the land was not patented, Washington would have owned it at the time of statehood and later conveyed it to private parties, and the shoreland would currently belong to the homeowners, the Abernathys. The Washington Supreme Court held that the right-of-way was an easement and did not constitute a land conveyance patented by the United States. Therefore, the land belonged to Washington at the time of statehood and is presently owned by the homeowners. View "King County v. Abernathy" on Justia Law

In Maine, former President Donald J. Trump submitted a petition for his candidacy for the Republican Party’s presidential primary. Three challengers subsequently claimed that Trump was disqualified from running because he had previously sworn to support the U.S. Constitution as President and then engaged in insurrection, which they argued precluded him from holding office under Section 3 of the Fourteenth Amendment. The Secretary of State held a hearing and decided that Trump was not qualified to appear on the ballot. Trump appealed this decision to the Superior Court, which remanded the matter back to the Secretary of State for a new ruling after the Supreme Court reaches a decision in a related case. The Secretary of State and the three challengers appealed to the Maine Supreme Judicial Court, which dismissed the appeal as interlocutory and not justiciable, holding that it was not from a final judgment. The court reasoned that uncertainties regarding issues of federal law pervaded the proceedings and were likely to require additional proceedings. The court deemed that an immediate review would likely result in an advisory opinion and could cause additional delay that the existing interlocutory order might avoid. View "Trump v. Secretary of State" on Justia Law

In California, a man named Clifford James Smyth, who was categorized as a tier two sex offender, sought to be removed from the California sex offender registry. However, at the time of his petition, he was living and registered as a sex offender in Oregon, not California. The Superior Court of Glenn County denied his petition, stating that he was not currently registered as a sex offender in California. On appeal, Smyth argued that the denial of his petition violated equal protection and was contrary to the legislative intent of California's sex offender registration laws.The Court of Appeal of the State of California Third Appellate District affirmed the lower court's decision. The court found that the California law, which was restructured to establish three tiers of registration for sex offenders, only allowed people registered in California to petition for termination from the California sex offender registry. The court disagreed with Smyth's argument that excluding out-of-state registrants from obtaining relief was contrary to the legislative intent and was absurd. The court reasoned that as someone not registered in California, the legislative concerns did not apply to Smyth.Furthermore, the court rejected Smyth's equal protection claim, concluding that out-of-state registrants are not similarly situated to California registrants for purposes of the California law, as they do not contribute to the problems identified by the Legislature when it decided to adopt the statute. The court also noted that even if out-of-state registrants were similarly situated, the distinction between the two groups would survive the requisite degree of scrutiny as there was a rational relationship between the disparity of treatment and a legitimate governmental purpose. View "People v. Smyth" on Justia Law

In this case, Alden Satas, the petitioner, sought parenting rights for his ex-wife's biological child from a previous relationship. The couple, Satas and Courtney Crabtree-Satas, the respondent, had married when the child was about two and a half years old. They divorced in 2017 and Satas never adopted the child, but the child continued to live with him for some time after the divorce. In December 2020, Satas filed a petition seeking a parenting plan concerning the child. Crabtree-Satas moved to dismiss the petition on the grounds that Satas' status as the child's stepparent ended when the parties divorced. The trial court found that Satas had standing to request parenting rights and responsibilities.The Supreme Court of New Hampshire was asked to consider three questions in this case. The first question was whether the trial court erred in finding that Satas was the stepparent of the child, given that the definition of a stepparent implies a current marital relationship, and Satas and Crabtree-Satas had been divorced since 2017. The Supreme Court of New Hampshire agreed that Satas is not a stepparent for the purposes of RSA 461-A:6, V because he was no longer married to the child's mother at the time he filed his petition for visitation privileges. The court thus found that the trial court had erred in ruling to the contrary.The second question asked whether the trial court erred in finding that Satas had standing to bring a petition for parenting rights and responsibilities on the basis that he had established an in loco parentis status with respect to the child. However, since the court had already found that Satas was not a stepparent, it did not need to address this question.The third question concerned whether the trial court violated the respondent's constitutional rights. However, the court did not need to answer this question as it had already resolved the appeal on statutory grounds.In conclusion, the Supreme Court of New Hampshire vacated the trial court's order and remanded the case with instructions to dismiss the petitioner's petition. View "In the Matter of Satas & Crabtree-Satas" on Justia Law

This case involves a minor, J.H., whose father is in jail and whose mother passed away when he was less than three years old. The child's maternal grandmother was appointed as his guardian. The Supreme Court of New Hampshire was asked to review an order by the Circuit Court, which prohibited the grandmother from testifying against the father's release from prison at any parole or similar hearings without first obtaining permission from the Circuit Court.The grandmother appealed this order, arguing that it violated her right to freedom of speech. The Circuit Court denied her motion, reasoning that J.H.'s best interests outweighed the grandmother's free speech rights.The Supreme Court of New Hampshire reversed the Circuit Court's decision in part. The Supreme Court found that the Circuit Court exceeded its statutory authority by restricting the grandmother's ability to testify at the father's parole hearing. The Supreme Court interpreted the relevant statute, RSA chapter 463, and determined that while it does grant the Circuit Court the authority to limit or restrict the powers of a guardian or impose additional duties in the best interests of the minor, it does not permit the court to restrict the guardian from speaking at a parole hearing. The Supreme Court concluded that this restriction was unrelated to the grandmother's role as guardian and was therefore not within the scope of the court's authority. As a result, the case was remanded back to the Circuit Court for further proceedings. View "In re Guardianship of J.H." on Justia Law

In South Carolina, two hospitals, Walterboro Community Hospital and Trident Medical Center, appealed an Administrative Law Court (ALC) order which approved the certificate of need (CON) for the Medical University Hospital Authority (MUHA). MUHA had applied for a CON to construct a new general hospital in Berkeley County to address capacity issues at its existing hospital in Charleston. The appellant hospitals raised four issues against ALC's decision: 1) the ALC's dismissal of certain errors in the review by the South Carolina Department of Health and Environmental Control (DHEC), 2) a misinterpretation of the State Health Plan by the ALC, 3) the ALC's approval of MUHA's application conditional on the closure of a freestanding emergency department planned by MUHA, and 4) the appeal bond required by South Carolina law is unconstitutional.The Supreme Court of South Carolina affirmed the ALC's decision and held that despite errors in DHEC's review process and decision, the ALC's de novo review rendered these errors harmless. The court also agreed with ALC's interpretation of the State Health Plan and found no issue in the ALC's condition of approval. The court further held that the appeal bond requirement was not unconstitutional, as the appellant hospitals were statutory affected persons and there was a rational basis for different treatment for a party opposing an approved CON and a party appealing the denial of its own CON application. However, the court did instruct that the appeal bond be voided and returned to Trident Medical Center. View "Walterboro Comm Hospital v. SCDHEC" on Justia Law

In a case before the United States Court of Appeals for the Fifth Circuit, the parents of Ashtian Barnes, who was fatally shot by Officer Roberto Felix, Jr. during a lawful traffic stop, alleged violations under 42 U.S.C. § 1983 against Officer Felix and Harris County. The parents argued that Officer Felix's use of force was unreasonable because even if Barnes attempted to flee, he did not pose a threat justifying deadly force. The district court granted the defendants' motion for summary judgement, stating that Officer Felix did not violate Barnes's constitutional rights and was entitled to qualified immunity. The district court found that Barnes posed a threat of serious harm to Officer Felix in the moment the car began to move, thus making Officer Felix's use of deadly force reasonable and not excessive. On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court's judgment, concluding that under the Circuit's precedent on the "moment of threat" analysis, there was no violation of Barnes's constitutional rights. Consequently, the court also affirmed the grant of summary judgement to Harris County, as there was no finding of constitutional injury. View "Barnes v. Felix" on Justia Law