Justia Constitutional Law Opinion Summaries

The case involves Roger Ouellette, who was convicted of Operating Under the Influence (OUI) following a police stop in his driveway. The police officer had observed Ouellette's vehicle crossing the center line of the road, which led the officer to suspect a violation of traffic laws. Ouellette entered a conditional guilty plea after his motion to suppress evidence obtained from the stop was denied by the trial court.The trial court found that the officer had reasonable suspicion to stop Ouellette due to his observed traffic violation. Ouellette argued that the stop was unjustified as the officer lacked reasonable suspicion of wrongdoing. However, the court determined that the stop was supported by reasonable articulable suspicion that Ouellette had violated the motor vehicle statute requiring vehicles to be operated within a single lane.On appeal, Ouellette argued that the stop was an unreasonable seizure under the Fourth Amendment because it occurred within the curtilage of his home without a warrant and without any applicable exception to the warrant requirement. The Maine Supreme Judicial Court affirmed the lower court's decision, concluding that the court's failure to grant Ouellette’s motion on that ground did not constitute obvious error and that the stop was justified based on reasonable suspicion. The court also found that Ouellette's argument regarding the stop occurring within the curtilage of his home was unpreserved and did not amount to obvious error. View "State of Maine v. Ouellette" on Justia Law

In Arkansas, attorney Chris Corbitt and other plaintiffs sought to challenge the prohibition of firearms in courthouses. Corbitt had previously attempted to bring a firearm into the Pulaski County District Courthouse and the Juvenile Justice Complex, but was denied. He filed a complaint, which was dismissed by the circuit court and later affirmed by the Supreme Court of Arkansas. Despite this, Corbitt and other plaintiffs filed another complaint after encountering firearm restrictions in a different courthouse. This complaint was also dismissed.The circuit court ruled that Corbitt was not entitled to injunctive relief, declaratory judgment, or a writ of mandamus. The court also found that even if issue preclusion were not applicable, it would rule similarly to Judge Wright’s decision regarding the interpretation of Arkansas Code Annotated section 5-73-122. The court rejected the plaintiff’s argument, stating that it was based on a flawed premise that misread the plain meaning of the statute and ignored the importance of Amendment 80 to the Arkansas Constitution. The circuit court emphasized that Amendment 80 gives the Arkansas Supreme Court the power to regulate court procedure, including the discretion to determine when weapons should be allowed in courtrooms.The Supreme Court of Arkansas held that Corbitt was collaterally estopped from pursuing his claims due to the previous litigation, but the remaining plaintiffs could proceed. The court further held that attorneys, as officers of the court, are authorized by statute to possess handguns in courthouses. The court reversed the circuit court’s denial of the petition for a declaratory judgment as it pertains to the remaining plaintiffs and remanded for further proceedings consistent with this opinion. View "CORBITT v. PULASKI COUNTY CIRCUIT COURT" on Justia Law

In 1998, Robert Keith Woodall was sentenced to death for the kidnapping, rape, and murder of a teenage girl. In 2015, Woodall filed a Motion to Vacate the Death Sentence Due to Intellectual Disability, arguing that he is intellectually disabled and thus the imposition of the death penalty would violate his constitutional rights. The trial court denied his motion without a hearing. On appeal, the Supreme Court of Kentucky reversed and remanded the case for an evidentiary hearing.On remand, the trial court held an evidentiary hearing and again denied Woodall’s motion. The court found that Woodall had not proven by the preponderance of the evidence that he is intellectually disabled. Woodall appealed this decision to the Supreme Court of Kentucky.The Supreme Court of Kentucky affirmed the decision of the trial court. The court found that the trial court's factual findings were supported by substantial evidence and that Woodall had not proven that he is intellectually disabled by a preponderance of the evidence. The court also rejected Woodall's arguments that the trial court violated his due process rights and Confrontation Clause rights by admitting and relying on a report without requiring the report's author to testify at the hearing. View "WOODALL V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case involves four appellants who are parole-eligible inmates serving life sentences in the Kentucky Department of Corrections. They were denied any further opportunity at parole for the remainder of their sentences by the Kentucky Parole Board. The appellants challenged the Board's authority to issue a "serve-out," arguing that it violates the constitutional separation of powers.The Franklin Circuit Court concluded that the Board was within its statutory authority to issue a serve-out on a life sentence and granted summary judgment to the Board. The Kentucky Court of Appeals affirmed the lower court's decision, reasoning that the legislature had not prohibited the Board from authorizing serve-outs on life sentences.The Supreme Court of Kentucky affirmed the decisions of the lower courts. The court held that the Board has the power to issue a serve-out to an inmate serving a life sentence. The court reasoned that while the current statutory scheme may not explicitly authorize the Board to grant serve-outs, the relevant legislative and administrative history indicates that the legislature has condoned the Board’s use of this power. The court also held that the Board's power to issue a serve-out does not violate the constitutional separation of powers. The court concluded that a serve-out is authorized by the legislature and is not constitutionally impermissible. View "CONN V. KENTUCKY PAROLE BOARD" on Justia Law

On July 4, 2021, Gavin Wallmow was arrested for violating his probation and was taken to Oneida County jail. During his booking, Wallmow denied any suicidal tendencies or mental health issues. Two days later, Wallmow's probation officer visited him and noticed a change in his behavior, including him hitting himself and expressing "demonic" thoughts. The officer reported this to a corrections officer at the jail, who then informed her superior. Despite these reports, Wallmow was observed behaving normally during routine checks. On July 8, Wallmow was found unresponsive in his cell, having committed suicide. His estate brought a series of constitutional claims under 42 U.S.C. § 1983, alleging that the jailers failed to protect Wallmow from himself.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the record did not support an inference that any defendant knew Wallmow faced a serious risk of harm. The court also found no reason to think the County's policies were inadequate, given the absence of any pattern of suicides to put it on notice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The appellate court found that the jail's employees had taken reasonable precautions, including checking on Wallmow at least 37 times per day. The court also noted that Wallmow had thrice disavowed any risk of suicide, and nothing indicated otherwise after his talk with his probation officer. The court concluded that the jail's actions complied with the Constitution's requirements. View "Estate of Wallmow v. Oneida County, Wisconsin" on Justia Law

The case involves a challenge to New Jersey's primary election ballot design, known as the "county-line" ballot. The plaintiffs, Andy Kim, Sarah Schoengood, and Carolyn Rush, who are all Democratic candidates for various offices, argue that the county-line ballot design infringes their First Amendment rights. They contend that the design unfairly favors candidates endorsed by local party leaders, placing them in prime ballot positions, while disadvantaging those who are not endorsed or choose not to associate with certain candidates.The case was initially heard in the United States District Court for the District of New Jersey, where the plaintiffs sought a preliminary injunction to prevent the use of county-line ballots and require the use of office-block format ballots instead. The District Court granted the injunction, finding that the plaintiffs had shown a severe burden on their First Amendment rights and that the state's interests did not outweigh these burdens.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals agreed that the county-line ballot design imposed a severe burden on the plaintiffs' First Amendment rights. It also found that the design likely violated the Elections Clause of the Constitution, which limits a state's power to regulate elections. The court concluded that the plaintiffs had demonstrated a substantial likelihood of success on the merits of their claims, and that they would suffer irreparable harm without the injunction. The court also found that the balance of harms and the public interest favored the plaintiffs. View "Kim v. Hanlon" on Justia Law

Albert Bustillos, an independent journalist, was filming content for his YouTube channel outside the Navajo oil refinery in Artesia, New Mexico. He was approached by refinery security and later by officers from the Artesia Police Department, including Corporal David Bailey. Despite Bustillos asserting he was on public property and had not broken any laws, Bailey arrested him for failure to identify himself in violation of New Mexico law.Bustillos sued Bailey and the City of Artesia, alleging violations of his First and Fourth Amendment rights and New Mexico law. The defendants moved for summary judgment, arguing that Bailey was entitled to qualified immunity. The district court denied the motion, rejecting Bailey’s qualified immunity defense.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of qualified immunity. The court found that Bailey lacked reasonable suspicion of a predicate crime, which is required to lawfully arrest someone for concealing identity. The court also found that Bustillos had met his burden to show that Bailey violated his clearly established Fourth Amendment rights. The court dismissed the portion of the appeal relating to Bustillos’s state-law claims, as the defendants had failed to meet their burden to support pendent appellate jurisdiction. View "Bustillos v. City of Artesia" on Justia Law

Jeremy Travis Payne, a California parolee, was arrested and charged with possession with intent to distribute fentanyl, fluorofentanyl, and cocaine. The charges stemmed from evidence obtained from a house in Palm Desert, California, and from Payne's cell phone, which was unlocked by police using Payne's thumbprint during a traffic stop. Payne moved to suppress the evidence, arguing that the search of his phone and the house violated his Fourth and Fifth Amendment rights.The district court denied Payne's motion. It found that the search of Payne's phone was reasonable under the Fourth Amendment given Payne's parole status and the conditions of his parole, which allowed for suspicionless searches of his property. The court also determined that the use of Payne's thumbprint to unlock his phone was not testimonial and therefore did not violate his Fifth Amendment privilege against self-incrimination.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that the search of Payne's phone did not violate the Fourth Amendment. It found that the search was authorized under a general search condition of Payne's parole, which allowed for the suspicionless search of any property under Payne's control. The court also held that the search of Payne's phone was not unreasonable under California law, which prohibits arbitrary, capricious, or harassing searches.Regarding the Fifth Amendment claim, the court held that the use of Payne's thumbprint to unlock his phone was not testimonial because it required no cognitive exertion. Therefore, the Fifth Amendment did not apply.Finally, the court held that there was sufficient probable cause to support the issuance of a search warrant for the house in Palm Desert, California, without regard to observations made during a challenged protective sweep of the house. View "USA V. PAYNE" on Justia Law

Devonte Veasley was charged with possessing a firearm while using a controlled substance, following an incident where he shot at his drug dealer. Veasley pleaded guilty to the charge. However, after the Supreme Court ruled in New York State Rifle & Pistol Ass’n v. Bruen that a New York law requiring "proper cause" to carry a firearm violated the Second Amendment, Veasley sought to withdraw his plea or have the indictment dismissed. He argued that the federal statute under which he was charged, 18 U.S.C. § 922(g)(3), which criminalizes the possession of a firearm by someone using or addicted to a controlled substance, was facially unconstitutional. The district court did not allow him to withdraw his plea or dismiss the indictment.On appeal, the United States Court of Appeals for the Eighth Circuit rejected Veasley's facial challenge to the statute. The court reasoned that the prohibition of firearm possession by drug users or addicts does not always violate the Second Amendment. The court drew analogies to historical regulations that restricted the rights of certain groups, such as the mentally ill and those who used firearms to terrorize others, to bear arms. The court concluded that, at least for some drug users, the statute imposes a comparable burden on the right to bear arms and serves a comparable justification. Therefore, the court affirmed the judgment of the district court. View "United States v. Veasley" on Justia Law

The case involves Jameal M. Mosley, who was charged with unauthorized possession and transportation of a machine gun, being a felon in possession of a firearm for the benefit of a street gang, and being a felon in possession of ammunition. These charges stemmed from warrantless searches of Mosley's car and person, which yielded a loaded magazine and a Glock handgun with an automatic switch. Mosley filed a motion to suppress the magazine and handgun, arguing that the searches were unsupported by probable cause or reasonable suspicion.The trial court held a suppression hearing. The Sacramento County Sheriff’s Department had received a call about a group of men creating a music video in a parking lot, with one of them holding a handgun. The officers arrived at the scene and detained all members of the group, including Mosley. They found a firearm on one of the men, D.M., and another firearm in D.M.'s car. Mosley was detained for approximately 41 minutes before his car was searched, revealing a loaded magazine. A subsequent search of Mosley's person revealed a Glock handgun with a switch. The trial court denied Mosley's motion to suppress, finding that the officers had probable cause to search Mosley's car and that the detention was not prolonged.Mosley filed a petition for writ of mandate with the Court of Appeal of the State of California, Third Appellate District. The appellate court agreed with Mosley's argument that the trial court erred in finding the warrantless searches were supported by probable cause and reasonable suspicion. The court concluded that the officers lacked probable cause to search Mosley's car and that the detention was unlawfully prolonged. The court granted Mosley's petition, directing the trial court to vacate its order denying Mosley's motion to suppress and enter a new order granting the motion. View "Mosley v. Superior Court" on Justia Law