Justia Constitutional Law Opinion Summaries

Evelyn-Natasha La Anyane was convicted of driving under the influence (DUI) of alcohol less safe and other traffic offenses. During a traffic stop, she was read the statutory implied-consent warning and consented to a blood test, which revealed a blood alcohol content above the legal limit. La Anyane argued that Georgia’s implied-consent statutory scheme is unconstitutional, claiming it coerces drivers into consenting to blood tests by falsely stating that refusal can be used against them at trial. She also contended that the trial court made evidentiary errors by not allowing her to cross-examine an expert with a study on field sobriety tests and by admitting evidence of her blood alcohol content.The trial court denied La Anyane’s motion to suppress the blood test results and admitted the evidence at trial. The jury found her guilty of all charges. La Anyane appealed, arguing that the implied-consent warning was unconstitutionally coercive and that the trial court made evidentiary errors.The Supreme Court of Georgia reviewed the case and held that the implied-consent warning was not unconstitutionally coercive. The court found that the warning did not state that consent was mandatory and that the statement about refusal being used at trial was not false. The court also determined that La Anyane’s consent to the blood test was freely and voluntarily given, making the search valid under the Fourth Amendment. Consequently, her as-applied and facial challenges to the implied-consent statutory scheme failed.Regarding the evidentiary issues, the court held that the trial court did not abuse its discretion in excluding the study on field sobriety tests due to lack of proper foundation and in admitting evidence of La Anyane’s blood alcohol content, as it was relevant to the DUI less safe charge and not unfairly prejudicial. The Supreme Court of Georgia affirmed the trial court’s judgment. View "LA ANYANE v. THE STATE" on Justia Law

James Christopher Jones was charged with murder after police identified her using cell phone location history obtained through search warrants. The warrants allowed police to get an anonymized list of devices near the victim’s home during the murder and identifying information for relevant devices. Jones moved to suppress this evidence, arguing the warrants violated the Fourth Amendment due to lack of probable cause and particularity. The trial court denied the motion, and Jones appealed.The trial court found the warrants were supported by probable cause and were sufficiently particular. The first warrant was based on evidence that the suspect used a cell phone near the victim’s home, and the second warrant, obtained after analyzing the anonymized data, identified a specific device linked to the suspect. The court concluded that the affidavits provided a fair probability that the location data and identifying information would yield evidence of the crime. The court also found the warrants were particular enough, specifying the crime, date, time, location, and a reasonable 100-meter radius.The Supreme Court of Georgia affirmed the trial court’s decision. The court held that the warrants were supported by probable cause, as the suspect was seen using a cell phone near the crime scene, and the location data was likely to help identify the suspect. The court also found the warrants met the particularity requirement, as they provided specific guidance on the information to be accessed and avoided unfettered discretion. The court rejected Jones’s arguments about overbreadth and lack of particularity, noting that the warrants were appropriately tailored to the investigation and did not authorize a general search. The judgment was affirmed. View "JONES v. THE STATE" on Justia Law

In this case, José M. Rojas-Tapia appealed the denial of his 28 U.S.C. § 2255 petitions for post-conviction relief, which he filed in the District of Puerto Rico. Rojas's convictions and sentences stem from his October 2000 guilty pleas to charges related to two separate post office robberies. The first indictment involved the Levittown Post Office, and the second involved the Sabana Seca Post Office. Both indictments included charges under 18 U.S.C. § 2114(a) for assaulting postal employees with intent to rob, and under 18 U.S.C. § 924(c) for using a firearm during a crime of violence. Additionally, Rojas was charged under 18 U.S.C. § 922(g) for being a felon in possession of a firearm.Rojas did not challenge his convictions or sentences on direct appeal. However, in 2017, he filed two habeas petitions challenging his § 924(c) convictions and the application of the Armed Career Criminal Act (ACCA) to his § 922(g) convictions. He argued that his § 924(c) convictions could not stand under Johnson v. United States (2015) and United States v. Davis (2019), as his underlying offenses did not qualify as crimes of violence. He also contended that his ACCA-enhanced sentences were improper because his prior convictions did not qualify as violent felonies or serious drug offenses.The United States District Court for the District of Puerto Rico denied both petitions. The court concluded that Rojas's federal mail robbery convictions under § 2114(a) qualified as crimes of violence under the force clause of § 924(c). Additionally, the court found that Rojas's prior convictions for attempted murder, second-degree murder, and armed carjacking under Puerto Rico law qualified as violent felonies under the ACCA.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court held that Rojas's convictions for aggravated mail robbery under § 2114(a) qualified as crimes of violence under § 924(c)'s force clause. The court also rejected Rojas's argument that his aiding and abetting convictions did not qualify as crimes of violence, reaffirming that aiding and abetting liability under 18 U.S.C. § 2 does not alter the application of the categorical approach. The court did not address Rojas's ACCA-related arguments, as his request for a Certificate of Appealability on those claims had been denied. View "Rojas-Tapia v. United States" on Justia Law

Ryan Smith was shot and killed by Seattle police officers Christopher Myers and Ryan Beecroft during a response to a 911 call from Smith's girlfriend, Katy Nolan, who reported that Smith was threatening to kill both himself and her with a knife. When the officers arrived, they kicked in the door to Smith's apartment, and within 5.87 seconds, they shot Smith, who was holding a pocketknife. Smith raised his right arm across his chest and took a step forward before being shot. The officers did not issue any warnings before using deadly force.The United States District Court for the Western District of Washington denied the officers' motion for partial summary judgment based on qualified immunity. The district court found that there were factual disputes regarding whether a reasonable officer would have believed Smith posed an immediate threat and whether less drastic measures were feasible. The court concluded that the law was clearly established that officers may not use deadly force against suspects who do not pose an immediate threat.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The Ninth Circuit held that it had jurisdiction over the interlocutory appeal and that, viewing the evidence in the light most favorable to the plaintiffs, the officers were not entitled to qualified immunity. The court determined that a reasonable juror could conclude that Smith did not pose an immediate threat to the officers or others, and that the use of deadly force was not justified. The court emphasized that it was clearly established law that a fatal shooting under these circumstances violated the Fourth Amendment. The Ninth Circuit affirmed the district court's denial of qualified immunity. View "JOHNSON V. MYERS" on Justia Law

The case involves the Consumer Product Safety Commission's (CPSC) second attempt to regulate small, high-powered magnets that pose serious health risks to children when ingested. These magnets, used in various consumer products like jewelry and puzzles, can cause severe internal injuries or death if swallowed. The CPSC's first attempt to regulate these magnets was struck down by the Tenth Circuit in 2016 due to inadequate data supporting the rule. The CPSC then revised its approach and issued a new rule, which is now being challenged by industry groups.The industry groups petitioned for review of the CPSC's new rule, arguing that the CPSC's cost-benefit analysis was flawed and that the rule was promulgated by an unconstitutionally structured agency. They contended that the CPSC's data on magnet ingestions was unreliable, that the CPSC failed to consider the impact of its own enforcement efforts, and that the rule was underinclusive and arbitrary. They also argued that existing voluntary standards were sufficient to address the risks posed by the magnets.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court found that the CPSC's rule was supported by substantial evidence, noting that the CPSC had adequately addressed the shortcomings identified in the previous case and had conducted a thorough cost-benefit analysis. The court also held that the CPSC's structure, which includes removal protections for its commissioners, was constitutional, reaffirming its previous decision in Leachco, Inc. v. Consumer Product Safety Commission.The Tenth Circuit denied the petition for review, upholding the CPSC's rule regulating small, high-powered magnets. The court concluded that the rule was necessary to address the significant health risks posed by these magnets and that the CPSC had acted within its authority in promulgating the rule. View "Magnetsafety.org v. Consumer Product Safety Commission" on Justia Law

Jack William Morgan, a Messianic Jew, purchased a turkey log from the commissary at the Federal Correctional Institution (FCI) Thomson in May 2021, which led to the suspension of his kosher diet approval for thirty days by the institutional chaplain. Morgan claimed this forced him to choose between starvation and violating his religious beliefs, and he chose starvation. After exhausting administrative remedies, he sued the Federal Bureau of Prisons (BOP) and the prison warden, Andrew Ciolli, seeking changes to dietary policies and monetary damages under the Religious Freedom Restoration Act (RFRA). Morgan has since been transferred to a different BOP facility.The United States District Court for the Northern District of Illinois dismissed Morgan’s complaint with prejudice for failure to state a claim. The court found that Morgan did not provide sufficient factual allegations to show that the BOP’s dietary policies substantially burdened his religious exercise. Additionally, the court noted that the BOP is immune from suits for damages under RFRA and that Morgan’s complaint did not include allegations about Ciolli’s conduct.The United States Court of Appeals for the Seventh Circuit reviewed the case and focused on two threshold issues: subject-matter jurisdiction and sovereign immunity. The court determined that Morgan did not adequately allege standing to pursue his claim for injunctive relief, as his threat of future injury was too speculative. Furthermore, the court held that federal sovereign immunity barred Morgan’s claim for monetary damages, as RFRA does not waive the federal government’s sovereign immunity against damages suits. The court affirmed the district court’s dismissal but modified the judgment to reflect a jurisdictional dismissal. View "Morgan v BOP" on Justia Law

A New York wine retailer, Jean Paul Weg LLC, and its owner, Lars Neubohn, challenged New Jersey's regulations that require wine retailers to have a physical presence in the state and to purchase their products from New Jersey licensed wholesalers. These regulations prevent the retailer from directly shipping wine to New Jersey customers. The plaintiffs argued that these requirements violate the Commerce Clause by discriminating against out-of-state economic interests.The United States District Court for the District of New Jersey denied the plaintiffs' motion for summary judgment and granted summary judgment in favor of the defendants, including the Director of the New Jersey Division of Alcoholic Beverage Control and the Attorney General of New Jersey. The District Court found that New Jersey's regulations were justified by legitimate local purposes, such as ensuring alcohol sold to New Jersey consumers passes through the state's three-tier system and facilitating inspections to ensure compliance with regulations.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's decision. The Third Circuit held that New Jersey's regulations, while discriminatory in effect, were justified on legitimate nonprotectionist grounds. The court found that the physical presence requirement facilitates inspections and investigations, while the wholesaler purchase requirement helps quickly identify sources of contamination and facilitates product recalls. Additionally, the court determined that these regulations are essential features of New Jersey's three-tier system of alcohol regulation, which is "unquestionably legitimate" under the Twenty-first Amendment. Therefore, the challenged regulations were upheld as constitutional. View "Jean-Paul Weg LLC v. Director of the New Jersey Division of Alcoholic Beverage Control" on Justia Law

Kurt Beathard, a football coach at Illinois State University (ISU), was terminated from his position as offensive coordinator after posting a handwritten message on his office door that read, “All Lives Matter to Our Lord & Savior Jesus Christ.” This occurred during a period of tension and unrest on the ISU campus following the death of George Floyd. Beathard alleges that his termination was due to this personal speech, which he claims is protected by the First Amendment.The United States District Court for the Central District of Illinois reviewed the case. The defendants, Larry Lyons and Brock Spack, filed a motion to dismiss the complaint under Rule 12(b)(6), arguing that they were entitled to qualified immunity. The district court denied the motion, stating that factual development was necessary before resolving the question of qualified immunity. The court found that Beathard had made a viable claim that his speech was personal and protected, but it was premature to engage in the Pickering balancing test at the pleading stage.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court concluded that it lacked jurisdiction to hear the appeal because the district court had not made a definitive ruling on the qualified immunity defense but had instead postponed the decision pending further factual development. The Seventh Circuit emphasized that interlocutory orders, such as the denial of a motion to dismiss, are generally not immediately appealable unless they conclusively determine the issue of qualified immunity, which was not the case here. Therefore, the appeal was dismissed for want of appellate jurisdiction. View "Rogers v. Byroad" on Justia Law

Chanon Miller was arrested by deputies from the Palm Beach County Sheriff’s Office for simple battery against her ex-fiancé. She subsequently sued the Sheriff’s Office and unnamed deputies, alleging violations of her constitutional right to be free from unreasonable seizure, including claims of false arrest, false imprisonment, and malicious prosecution. Miller's complaint was amended to name specific deputies as defendants.The United States District Court for the Southern District of Florida denied the deputies' motion to dismiss based on qualified immunity, stating that the issue was more appropriately resolved at the summary judgment stage or later in the proceedings. The court found that Miller's allegations were sufficient to state a plausible claim for relief and allowed her to file an amended complaint naming the appropriate defendants. The district court reiterated its position when the deputies renewed their motion to dismiss after being named in the amended complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case and held that the district court erred by failing to adjudicate the defense of qualified immunity at the motion to dismiss stage. The appellate court emphasized that qualified immunity is an immunity from suit, not just a defense to liability, and must be resolved at the earliest possible stage in litigation. The court vacated the district court’s order and remanded the case with instructions to rule on the deputies' entitlement to qualified immunity, requiring a claim-by-claim and defendant-by-defendant analysis. View "Miller v. Ramirez" on Justia Law

Duane Gary Underwood, II was convicted of possession with intent to distribute methamphetamine, possession of a stolen firearm, and possession of a firearm in furtherance of a drug trafficking crime. Underwood appealed his conviction on ten grounds, including the constitutionality of 18 U.S.C. § 924(c)(1)(A), the legality of his detention and search, the validity of a search warrant for his phone, the admissibility of certain evidence, voir dire procedures, the sufficiency of the evidence, jury instructions, and the licensure status of the prosecuting Assistant U.S. Attorney (AUSA).The United States District Court for the Western District of Michigan denied Underwood's pretrial motions to suppress evidence and dismiss charges. The court admitted evidence from Underwood's phone and grand jury testimony under Rule 803(5). The jury convicted Underwood on all counts, and he was sentenced to 180 months' imprisonment. Post-trial, Underwood moved to dismiss his conviction, arguing that the AUSA's administrative suspension for nonpayment of bar dues constituted prosecutorial misconduct and a jurisdictional defect. The district court denied this motion.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's judgment. The court held that 18 U.S.C. § 924(c)(1)(A) is constitutional, the officers had reasonable suspicion to detain and search Underwood, and the search warrant for Underwood's phone was valid. The court found no abuse of discretion in admitting the contested evidence or in the voir dire procedures. The evidence was deemed sufficient to support the convictions, and the jury instructions were appropriate. The court also ruled that the AUSA's administrative suspension did not constitute prosecutorial misconduct or create a jurisdictional defect, and there was no Brady violation. View "United States v. Underwood" on Justia Law