Justia Constitutional Law Opinion Summaries

In a drug trafficking case, the defendant, Amanda Cowette, appealed the district court's denial of her motion to suppress statements she made to law enforcement officers on July 16 and 17, 2018. Cowette argued that she unequivocally invoked her Fifth Amendment right to counsel and any subsequent questioning by law enforcement officers was in violation of that right. She contended that the district court's ruling to the contrary was in error. The United States Court of Appeals for the First Circuit agreed with Cowette and held that she properly invoked her Fifth Amendment right to counsel. The court found that the phrase "I guess" used by Cowette did not create any ambiguity in her clear invocation of her right to counsel. The court vacated the decision of the district court in part, affirmed in part, and remanded for proceedings consistent with this opinion. View "US v. Cowette" on Justia Law

The case involves Tylor Buttolph who appealed his conviction of stalking. Buttolph had been charged with eight counts of felony stalking, allegedly occurring between October 17, 2019, and April 6, 2020. For each count of stalking, the State listed only one act of misconduct. However, the stalking statute requires a "course of conduct" involving two or more acts. The State used evidence of prior, uncharged conduct to prove the "course of conduct" element.The Supreme Court of the State of Montana reversed the conviction. The court held that Buttolph's constitutional right to due process was violated when the State used an act not charged in the information to prove "course of conduct" for the offense of stalking. The court reasoned that the State cannot shift its theory of criminality on the day of trial without violating Buttolph's fundamental right to due process. The charging document was silent as to the second act constituting the course of conduct element of the offense, and thus, there was no "statement of facts constituting the offense charged". View "State v. Buttolph" on Justia Law

The New York Court of Appeals held that the New York State Independent Redistricting Commission (IRC) failed to fulfill its constitutional duties for redistricting maps after the 2020 census. The court affirmed a lower court decision ordering the IRC to reconvene and deliver a second set of lawful redistricting maps.In 2014, New York voters amended the state constitution to mandate that the IRC, not the courts or the legislature, draw legislative districts. However, the IRC failed to deliver the required maps, resulting in a court-ordered redistricting plan for the 2022 elections.The court clarified that such court-directed plans are limited to the "extent" that the court is "required" to do so, and are not meant to last longer than necessary to remedy a violation of law. Therefore, the existing court-drawn districts are limited to the 2022 election.The court dismissed arguments that it was too late to compel the IRC to act, explaining that the court-ordered maps were not required to last a decade and that the IRC's constitutional obligation could be enforced at any time, unless barred by laches. The court also rejected arguments that the lawsuit was a collateral attack on an earlier decision, which dealt with a different issue.The ruling orders the IRC to submit a second set of redistricting maps and implementing legislation to the legislature as soon as possible, but no later than February 28, 2024. View "Matter of Hoffmann v New York State Ind. Redistricting Commn." on Justia Law

In this case, a group of New Hampshire voters challenged the constitutionality of the state's new boundaries for state senate and executive council districts. The plaintiffs claimed that the legislature violated the New Hampshire Constitution by drawing districts that unfairly benefitted one political party at the expense of another. They sought a declaration that the districts violated various parts of the state constitution and an injunction preventing the implementation of the new boundaries.The Supreme Court of New Hampshire held that the issue of partisan gerrymandering raised a non-justiciable political question because the New Hampshire Constitution committed the task of redistricting to the legislature and did not provide any legal standard for the courts to review such decisions. The court noted that the plaintiffs did not claim that the redistricting plans violated any mandatory requirements of the state constitution.The court also rejected the argument that the constitution's guarantees of free speech, equal protection, and association were violated by the alleged gerrymandering. The court found that these constitutional provisions did not provide clear and manageable standards for adjudicating claims of extreme partisan gerrymandering.The court affirmed the lower court's decision to dismiss the plaintiffs' complaint, concluding that the challenge to the constitutionality of the districts based on claims of excessive political gerrymandering presented non-justiciable political questions. View "Brown v. Secretary of State" on Justia Law

In the Central District of California, defendant-appellant Christopher Esqueda was convicted for possession of a firearm as a felon, following the denial of his motion to suppress evidence collected during an undercover operation. Undercover agents, with Esqueda's consent, entered his motel room to conduct a controlled purchase of a firearm. The agents secretly recorded the encounter using audio-video equipment concealed on their persons. Esqueda argued that the secret recording of the encounter exceeded the scope of the "implied license" he granted when he consented to the officers' physical entry, hence infringing upon his Fourth Amendment rights.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The court held that no Fourth Amendment search occurred. It relied on longstanding Supreme Court precedents asserting that an undercover officer who physically enters a premises with express consent and secretly records only what he can see and hear by virtue of his consented entry does not trespass, physically intrude, or otherwise engage in a search violative of the Fourth Amendment. The court noted that the Supreme Court's decisions in Florida v. Jardines and United States v. Jones, which outline a property-based, trespassory test for Fourth Amendment violations, do not disturb this principle. View "USA V. ESQUEDA" on Justia Law

The United States Court of Appeals for the Eighth Circuit heard an appeal from Jacob Bermel, who had pleaded guilty to two child pornography offenses following the denial of his motion to suppress evidence that was found on a camera he had hidden in his daughter's bathroom. Bermel argued that the warrantless seizure and subsequent search of the camera and its memory card violated his Fourth Amendment rights. However, the district court found that the seizure was justified by exigent circumstances and that the search was lawful due to the daughter's consent.On appeal, Bermel made three arguments: (1) minor children cannot consent to a search of their parents' property, (2) even if minors can consent, his daughter lacked such authority, and (3) the district court erred in finding that his daughter had consented to the search of the camera and memory card.The Court of Appeals affirmed the district court's decision. It rejected Bermel's first argument, stating that there is no legal precedent for a per se rule that minors cannot consent to a search of their parents' property. The court also found that the daughter had apparent authority to consent to the search given her joint access and control over the camera and its memory card. Finally, the court determined that the daughter had indeed consented to the search of the camera and its memory card. The court noted that lack of verbal response did not negate consent and the scope of her consent reasonably extended to the camera's memory card. View "United States v. Bermel" on Justia Law

In this case, Michael W. Langeman, a former Special Agent with the Federal Bureau of Investigation (FBI), appealed against the dismissal of his complaint for failure to state a claim. Langeman was terminated from his position after an investigation by the Department of Justice (DOJ) revealed his mishandling of the investigation into sexual abuse allegations against USA Gymnastics Physician Lawrence Gerard Nassar. Langeman claimed that his termination violated his constitutional rights protected by the Fifth Amendment’s Due Process Clause. He argued that his termination violated a constitutionally protected property interest in his continued employment and deprived him of a constitutionally protected liberty interest in his reputation, thereby damaging his future employment in law enforcement.The United States Court of Appeals for the District of Columbia Circuit disagreed with Langeman's arguments. The court held that Langeman failed to sufficiently plead deprivation of a property interest or liberty interest without due process. The court found that the FBI had explicitly retained the discretion to summarily terminate employees, and this did not create a legitimate property interest sufficient to state a claim under procedural due process. As for Langeman's claim of deprivation of a liberty interest, the court found that Langeman did not establish that any allegedly defamatory conduct accompanied his dismissal from government employment.Therefore, the court affirmed the district court’s dismissal of Langeman’s complaint for failure to state a claim. It also found that Langeman could not demonstrate a clear right to relief for his mandamus claim due to his deficient due process allegations, therefore mandamus relief was not available to him. View "Langeman v. Merrick Garland" on Justia Law

In this case handled by the Supreme Court of Texas, the parents of two children, Kate Cox and Justin Cox, along with their doctor, Dr. Damla Karsan, filed a suit to challenge the enforcement of Texas laws that prohibit abortion. Mrs. Cox was about 20 weeks pregnant with a baby diagnosed with trisomy 18, a serious genetic disorder. The suit sought to apply a medical-necessity exception provided in the Texas law, which allows an abortion if a woman's life is threatened or she faces a serious risk of substantial impairment of a major bodily function due to her pregnancy.The court, in its decision, clarified that the exception to the abortion prohibition is based on the reasonable medical judgment of a doctor, not a court. It was noted that Dr. Karsan presented a "good faith belief" that Mrs. Cox meets the exception's requirements but did not assert that her belief meets the objective standard of "reasonable medical judgment."The court held that judges lack the authority to broaden the statutory exception by interpreting it and held the trial court erred in applying a different, lower standard instead of requiring reasonable medical judgment. The court emphasized that the exception requires a doctor's decision whether a pregnant woman’s complications pose the required risks.The court conditionally granted relief and directed the trial court to vacate the temporary restraining order that had restrained the Attorney General from enforcing the abortion laws against Dr. Karsan and others related to the case, based solely on the verified pleading. The court also noted that nothing in their opinion prevents a physician from acting if, in that physician’s reasonable medical judgment, they determine that the pregnant woman has a life-threatening physical condition. View "IN RE STATE OF TEXAS" on Justia Law

In the case at hand, the defendant, Joshua Hart, and his girlfriend, Brittany Smith, entered the home of an elderly couple, Thomas Harty and his wife, Joanna Fisher, intending to steal their car and money. The couple ended up fatally attacking both Harty and Fisher, and then fled the state in the victims' vehicle. Hart was convicted on two counts of first-degree murder, and he appealed on several grounds.Hart argued that his confession to law enforcement was involuntary and should have been suppressed, but the Supreme Judicial Court of Massachusetts disagreed. The court found that Hart's confession was voluntary based on the circumstances of the interrogation, his experience with the criminal justice system, and his own actions and statements during the interrogation.Hart also argued that the trial should have been moved to another venue due to pretrial publicity. The court disagreed, stating that the defendant did not provide sufficient evidence to demonstrate that the pretrial publicity caused either presumptive or actual prejudice. The court found that less than 20% of potential jurors were excused due to pretrial publicity, and the judge took extensive steps to protect Hart's right to a fair trial.Hart further contended that a statement made by the deceased victim, Fisher, to her nurse, which was relayed to the jury through the nurse's testimony, should have been excluded from evidence as it was hearsay and violated his right to confront witnesses. The court determined that Fisher's statements were non-testimonial and thus did not violate the confrontation clause. The court also found that even if Fisher's statements were admitted in error, there was no prejudice because the Commonwealth presented other compelling evidence of the facts relayed in Fisher's statements.Finally, Hart argued that his sentences of life without the possibility of parole constituted cruel or unusual punishment because he was under 25 years old at the time of the crimes. The court rejected this argument, finding no reason to extend the prohibition of life sentences without parole for juveniles to individuals under the age of 25.Accordingly, the court affirmed Hart's convictions. View "Commonwealth v. Hart" on Justia Law

In this case, the United States Court of Appeals for the Fourth Circuit reversed and remanded a district court's dismissal of claims brought by Charles Willis Short, the husband and estate administrator of Victoria Christine Short, who died by suicide while in custody at the Davie County Detention Center. Mr. Short filed a lawsuit under 42 U.S.C. § 1983 against several employees of the Davie County Sheriff’s Department, alleging violations of the Fourteenth Amendment for deliberate indifference to Ms. Short’s risk of suicide. The district court dismissed all of Mr. Short's claims, applying a subjective standard for determining deliberate indifference.The Fourth Circuit disagreed with the lower court's application of the subjective standard, relying on the Supreme Court's decision in Kingsley v. Hendrickson, which established an objective standard for determining deliberate indifference in cases involving pretrial detainees. The court decided that pretrial detainees can state a Fourteenth Amendment claim for deliberate indifference to an excessive risk of harm on an objective standard, finding that the allegations in the complaint were sufficient to state a claim under any standard. Therefore, the court reversed the district court’s dismissal of the claims and remanded the case for further proceedings. View "Short v. Hartman" on Justia Law