Justia Constitutional Law Opinion Summaries

In the State of Washington, a man named Mitchell Heng was charged with murder, arson, and robbery. He was brought before a judge for a preliminary hearing without counsel, during which the judge set bail among other things. Heng argued that counsel should have been present at this hearing. The Supreme Court of the State of Washington agreed, noting that a person charged with a crime has a right to counsel under the state and federal constitutions and under court rules. However, the court found that Heng did not demonstrate that the hearing was a critical stage of the prosecution, and it believed that the absence of counsel did not contribute to the verdict. Consequently, the court affirmed the decisions of the lower courts.The facts of the case reveal that Heng was implicated in a robbery at Sifton Market during which Amy Hooser was killed. Surveillance footage showed Heng at the scene with a blood-stained shirt and a lighter in his hands. He was charged the next day with first degree murder, first degree robbery, and first degree arson. Heng was held in jail for 31 months before his trial, during which time he made inconsistent statements during recorded phone calls about the events of the night of the crime. He was eventually convicted of first degree murder and first degree arson and was sentenced to 374 months in prison.Heng appealed his conviction, arguing that his right to counsel had been violated at a critical stage of the prosecution. The Supreme Court of the State of Washington held that while Heng should have had counsel present at his preliminary hearing, this did not constitute a critical stage of the prosecution. The court also noted that in order for an error to be considered structural and thus necessitate automatic reversal, it must have substantively affected the outcome of the case. The court determined that Heng’s case was not demonstrably affected by his counsel’s absence. As such, the court applied constitutional harmless error analysis, which requires the court to reverse unless it is persuaded beyond a reasonable doubt that the error did not contribute to the verdict. The court concluded that the failure to have counsel present at Heng’s preliminary hearing was harmless beyond a reasonable doubt, and thus affirmed the decisions of the lower courts. View "State v. Heng" on Justia Law

Michael Shawn Charlton was arrested and charged with third-degree child rape, third-degree child molestation, and indecent liberties. He appeared in preliminary hearings without counsel, which he argued on appeal was a denial of his constitutional right to counsel at critical stages of the prosecution. The Supreme Court of the State of Washington held that while the absence of counsel was indeed a constitutional error, it did not constitute a critical stage of litigation requiring automatic reversal. The court reasoned that nothing in the record suggested that Charlton's rights were lost, defenses were waived, privileges were claimed or waived, or that the outcome of the case was otherwise substantially affected by the absence of counsel. Furthermore, the court concluded that any error in not having counsel present was harmless beyond a reasonable doubt. This is because there was no evidence to suggest that the lack of counsel affected the verdict in any way. Consequently, the court affirmed the decision of the Court of Appeals. View "State v. Charlton" on Justia Law

In the case presented, plaintiff Bette Bennett alleged that she suffered a traumatic brain injury due to medical negligence by the defendant, the United States. However, the cause of her injury was not diagnosed until after the eight-year statute of repose for medical malpractice actions under Washington law had expired, making it impossible for her to timely commence her lawsuit. The United States moved to dismiss her complaint as time-barred.The Supreme Court of the State of Washington was asked to decide whether the statute of repose violates certain provisions of the Washington Constitution. The court held that while the legislature has broad authority to set time limits for commencing an action, the eight-year statute of repose for medical malpractice actions under RCW 4.16.350(3) violates the privileges and immunities clause of article I, section 12 of the Washington Constitution. The court reasoned that the statute implicates the fundamental right of state citizenship by limiting the pursuit of common law claims against certain defendants, but it does not satisfy the "reasonable ground" test under the state constitution. Therefore, the court concluded that the statute of repose is unconstitutional under independent state law. The court declined to reach the second certified question regarding whether the statute of repose unconstitutionally restricts a plaintiff's right to access the courts in violation of the Washington Constitution. View "Bennett v. United States" on Justia Law

In the case before the Supreme Court of Arkansas, Rodney Dale Harmon, who was convicted of multiple drug-related felonies and sentenced to 40 years in prison, appealed the denial of his petition for postconviction relief under Arkansas Rule of Criminal Procedure 37. The appeal was mainly based on the presence of an HBO documentary film crew while a search warrant was executed at his home, and he argued that this violated his Fourth Amendment rights.The court ruled that claims related to the presence of the film crew during the search could not be used to void the judgment, as even constitutional violations are not in themselves enough to trigger application of Rule 37. The court further noted that issues of evidence, including those possibly obtained by illegal search or seizure, are not of such a fundamental nature as to void the judgment.Harmon also claimed that his trial counsel was ineffective for failing to raise the Fourth Amendment violation as an independent ground to suppress the evidence obtained in the search. The court disagreed, stating that even though the violation was established law, the remedy was not, and that counsel was not deficient for failing to raise a novel argument.Thus, the court affirmed the circuit court's denial of Harmon's petition for postconviction relief. View "HARMON v. STATE OF ARKANSAS" on Justia Law

In the case before the Supreme Court of Arkansas, the appellant, Cordale Stacy, was convicted of three counts of capital murder and sentenced to life imprisonment without parole on each count, along with a consecutive fifteen years’ imprisonment for a firearm enhancement. The appellant argued that the circuit court erred in denying his motions to dismiss the capital-murder charges due to an alleged overlap of capital, first-degree, and second-degree murder statutes.The case arose from a shooting incident in a Forrest City apartment where three individuals, an adult and two children, were found deceased. Witnesses identified Stacy fleeing the scene and further investigations led to his arrest. Stacy was charged with three counts of capital murder, possession of a firearm by certain persons, and a felony-with-a-firearm enhancement.Stacy filed two motions to quash the felony information, arguing that the capital murder statute overlapped with the first-degree murder statute for the adult victim, and overlapped with the first-degree and second-degree murder statutes for the minor victims. He contended that this overlap exposed him to an impermissible uncertainty in the offenses, which should have led to their dismissal. The circuit court denied both motions.On appeal, the Supreme Court of Arkansas held that there was no constitutional infirmity in the overlap of these statutes. The Court noted that each offense set forth different elements to be proved by the State, and thus, any alleged overlap presented no constitutional issues. Furthermore, the Court affirmed that the discretion of the prosecutor to choose between overlapping offenses did not violate the Equal Protection or Due Process Clauses. Therefore, the Court affirmed the circuit court's denial of Stacy's motions to quash the felony information and dismiss the charges. As a result, Stacy's conviction and sentence were upheld. View "STACY v. STATE OF ARKANSAS" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit affirmed the United States District Court for the Eastern District of Arkansas's decision to sentence Jordan Cutler to 180 months in prison for distributing child pornography, a sentence that exceeded the Guidelines range of 108 to 135 months. Cutler appealed, arguing that the district court made a procedural error in calculating the Guidelines range and asserting that his sentence was substantively unreasonable. Cutler claimed that the district court erred in assessing one criminal history point under the Sentencing Guidelines for a set of uncounseled misdemeanors from 2010.The appellate court rejected this argument, explaining that Cutler's uncounseled misdemeanors were not voided by his lack of counsel, as the fines associated with these misdemeanors were constitutionally valid and could be used to enhance his punishment. The court clarified that the Sixth Amendment right to counsel for misdemeanor defendants only applies where the defendant receives a prison sentence, not when the defendant is merely fined.In terms of the substantive reasonableness of Cutler's sentence, the appellate court again affirmed the district court's decision. The court explained that although the Guidelines captured certain aspects of Cutler's offense, they did not reflect the "heinous" nature of his crimes, including threats to kidnap, rape, torture, and kill young girls. Cutler also argued that the district court improperly considered its reputation and public perception when determining his sentence. However, the appellate court disagreed, noting that the district court was considering the need for the sentence to reflect the seriousness of the offense, promote respect for the law, and provide just punishment for the offense.Therefore, the appellate court found no procedural or substantive error in Cutler's sentencing and affirmed the district court's judgment. View "United States v. Cutler" on Justia Law

Anthony Christopher Mendonca was convicted by a jury in the United States District Court for the Eastern District of New York for one count of possession of child pornography. He appealed, arguing that his Sixth Amendment right to a public trial was violated due to the public being excluded from substantial portions of his jury selection due to restrictions during the COVID-19 pandemic. He also argued that his inculpatory statements were coerced by law enforcement’s suggestion that he had “failed” a polygraph exam. Both challenges were not properly preserved in the lower court and therefore the United States Court of Appeals for the Second Circuit applied a plain-error review, ultimately affirming the judgment of the district court. The court emphasized the unique challenges posed by the pandemic and the effort made by the lower court to conduct a fair trial under these constraints. The court also found no clear or obvious error in the lower court's decision to admit Mendonca's incriminatory statements. View "United States of America v. Mendonca" on Justia Law

A traffic stop conducted by Pennsylvania State Trooper Galen Clemons resulted in the arrest of Jamar Hunter after a loaded Glock-45 semi-automatic handgun was discovered in Hunter's waistband. This discovery followed a routine license and warrant check and an additional computerized criminal history check on Hunter and his passenger, Deshaun Davis. Hunter was later indicted for possession of a firearm as a convicted felon. Hunter moved to suppress the firearm evidence claiming that the computerized criminal history check extended the traffic stop beyond its constitutional authority.The United States District Court for the Eastern District of Pennsylvania granted Hunter's motion to suppress. The court reasoned that the computerized criminal history check was unrelated to the traffic stop's mission and, without reasonable suspicion, prolonged the stop, therefore violating the Fourth Amendment.The United States Court of Appeals for the Third Circuit reversed the District Court’s decision, finding that the lower court had applied a subjective standard of review, thereby erring as a matter of law. The appellate court held that the criminal history check, which lasted approximately two minutes, was an objectively reasonable safety precaution related to the mission of the traffic stop under Rodriguez v. United States, 575 U.S. 348 (2015) and the Fourth Amendment. The Court of Appeals found the check to be a negligibly burdensome officer safety precaution that fell within the stop's mission. The case was remanded for further proceedings consistent with this opinion. View "USA v. Hunter" on Justia Law

In the case before the Supreme Court of the State of Arizona, Phoenix Police Sergeant Stefani McMichael-Gombar appealed against her suspension for posting content on Facebook that violated the Phoenix Police Department’s Social Media Policy. She argued that the policy was overbroad and violated the First Amendment to the U.S. Constitution, or that she reasonably believed she had a First Amendment right to make the post. The Phoenix Civil Service Board upheld the suspension, and McMichael-Gombar sought relief in the superior court. The superior court dismissed her complaint, stating that the Phoenix City Charter neither requires nor authorizes the Board to consider the constitutionality of the City’s policies, and this is only tasked with determining if the allegations against an employee are true and if the level of discipline was appropriate. The court of appeals vacated this ruling, determining that the Board must consider whether the disciplinary action properly regards McMichael-Gombar’s constitutional rights.The Supreme Court of the State of Arizona affirmed the superior court’s decision, holding that the Board does not have the authority to decide whether a city policy is unconstitutional, as this power is not explicitly granted to it by the Phoenix City Charter, the rules governing disciplinary proceedings, or the Peace Officers Bill of Rights. However, the court did agree that McMichael-Gombar was entitled to argue and introduce supporting evidence that she reasonably believed she was acting within her First Amendment rights. The court concluded that McMichael-Gombar did not meet her burden to show that the Board precluded her from doing so. Thus, the court vacated the court of appeals’ opinion and affirmed the superior court’s order dismissing McMichael-Gombar’s special action complaint. View "MCMICHAEL-GOMBAR v PHOENIX CIVIL SERVICE" on Justia Law

In June 2021, Kenneth Bernard Kimbley, III, was convicted on four counts of lewd and lascivious conduct and sentenced to four concurrent sentences, each for a determinate period of not less than fifteen years and an indeterminate period of not more than fifteen years, for a total unified sentence not to exceed thirty years. Kimbley appealed his conviction, presenting multiple arguments to the Supreme Court of the State of Idaho.The court rejected Kimbley's argument that his Sixth Amendment right to a public trial was violated when his trial was livestreamed due to COVID-19 restrictions. The court determined that Kimbley had not objected to the livestreaming at the time and had therefore waived his right to object to it on appeal.Kimbley also argued that his right to counsel was violated as he was unable to communicate with his attorney during pretrial hearings in which his attorney appeared remotely. However, the court noted that Kimbley hadn't raised this issue at the lower court, nor had he demonstrated how this alleged violation affected the outcome of his trial.Kimbley further contended that the lower court erred by admitting evidence of his flight from prosecution and his firearm possession. The Supreme Court found that evidence of Kimbley's flight was relevant and admissible as it indicated a consciousness of guilt. Evidence of Kimbley's firearm possession was also deemed admissible as it was introduced by Kimbley's own counsel for the purpose of impeachment.Lastly, Kimbley argued that the prosecutor committed misconduct during closing arguments by discrediting a witness who had invoked her Fifth Amendment right. However, the court declined to consider this argument as Kimbley hadn't objected to the prosecutor's comments at the time and had not adequately argued that these comments constituted a fundamental error on appeal.In conclusion, the Supreme Court of the State of Idaho affirmed the judgment of the lower court, rejecting all of Kimbley's arguments on appeal. View "State v. Kimbley" on Justia Law