Justia Constitutional Law Opinion Summaries

The defendant was apprehended after two separate incidents in which he was found in possession of firearms and drugs. In the first incident, after a car accident, he attempted to dissuade the other driver from calling the police due to the presence of contraband in his vehicle, then fled but was quickly caught. In the second incident, a traffic stop led to the discovery of additional firearms, ammunition, and drugs. He was charged with two counts of possessing a firearm as a convicted felon and pleaded guilty.The United States District Court for the Eastern District of Kentucky calculated his base offense level under the Sentencing Guidelines as twenty-two, based in part on a prior Kentucky conviction for second-degree manslaughter, which the court classified as a “crime of violence.” The defendant did not object to this calculation at sentencing and was sentenced to 145 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Kentucky’s second-degree manslaughter qualifies as a “crime of violence” under the Sentencing Guidelines, applying plain error review because the issue was not raised below. The court held that the Kentucky statute’s “wantonness” mens rea is functionally equivalent to “recklessness” as defined in Borden v. United States, 593 U.S. 420 (2021), and does not meet the standard for a “crime of violence,” which requires purposeful or knowing conduct. The court found that the district court’s reliance on this conviction to enhance the sentence was plain error, affected the defendant’s substantial rights, and undermined the fairness of the proceedings. Accordingly, the Sixth Circuit vacated the sentence and remanded for resentencing. View "United States v. Tooley" on Justia Law

Iowa enacted a law making it a state crime for certain noncitizens who had previously been denied admission, excluded, deported, or removed from the United States to enter or be found in Iowa. The law also required state judges to order such individuals to return to the country from which they entered and prohibited state courts from pausing prosecutions based on pending or possible federal immigration status determinations. Two noncitizens residing in Iowa, both of whom had previously been subject to federal removal orders but later lawfully reentered the United States, along with a membership-based immigrant advocacy organization, challenged the law, arguing it was preempted by federal immigration law.The United States District Court for the Southern District of Iowa found that the plaintiffs had standing and granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on the merits of their claim that the Iowa law was preempted by federal law under both conflict and field preemption doctrines. The district court also found that the plaintiffs would suffer irreparable harm if the law went into effect and that the balance of equities and public interest favored an injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, reviewing legal conclusions de novo and factual findings for clear error. The Eighth Circuit affirmed the preliminary injunction, holding that the plaintiffs had standing and were likely to succeed on the merits because every application of the Iowa law would conflict with federal immigration law by interfering with the discretion Congress grants to federal officials. The court also found that the other factors for a preliminary injunction were met. The Eighth Circuit remanded for the district court to determine the appropriate scope of the injunction in light of recent Supreme Court guidance. View "IA Migrant Movement for Justice v. Bird" on Justia Law

A police officer applied for a search warrant for a residence based on information from a confidential reliable informant (CRI). The CRI reported that, within the previous 72 hours, they had visited the residence and observed people smoking methamphetamine and meth pipes inside. The CRI was not directed by law enforcement to visit the house and had a history of providing reliable information to the police. Based on this information, a district court judge issued a search warrant. When the warrant was executed, officers found drug paraphernalia and items testing positive for methamphetamine. The resident was charged with two drug-related offenses.The defendant moved to suppress the evidence, arguing that the warrant was not supported by probable cause. The Swift County District Court denied the motion, finding the warrant application sufficient. After a jury found the defendant guilty, the Minnesota Court of Appeals affirmed the conviction in a divided opinion. The majority held that the totality of the circumstances, including the CRI’s reliability and basis of knowledge, established probable cause, and rejected the argument that corroboration of the CRI’s tip was always required. The dissent argued that corroboration was necessary and that the lack of it meant probable cause was lacking.The Minnesota Supreme Court reviewed the case to clarify whether corroboration of a confidential reliable informant’s tip is an independent requirement for probable cause. The court held that corroboration is not an independent requirement but is always a relevant factor in the totality-of-the-circumstances analysis. Applying this standard, the court concluded that the limited, uncorroborated observations in the warrant application did not establish a fair probability that contraband or evidence of a crime would be found in the house at the time of the search. The court reversed the decision of the court of appeals and remanded the case for further proceedings. View "State of Minnesota vs. Nagle" on Justia Law

In the early morning hours of September 17, 2024, police responded to a report that a man had drawn a knife and approached a woman in her vehicle at a Fargo gas station. Surveillance video captured the incident, and Shawn King was apprehended near the scene. He was charged with terrorizing, carrying a concealed weapon, and possession of drug paraphernalia, though the drug paraphernalia charge was dismissed before trial. At trial, the victim testified that King approached her on a bicycle, threw it down, brandished a knife, and advanced toward her in an angry manner, causing her to fear for her safety. The jury viewed the surveillance footage and heard testimony from three officers. Ultimately, the jury found King guilty of terrorizing but acquitted him of carrying a concealed weapon.Following the jury’s verdict, the District Court of Cass County, East Central Judicial District, entered judgment and sentenced King to five years, with four years to be served and one year suspended during two years of supervised probation. King appealed, arguing that the terrorizing statute was unconstitutionally vague and overbroad as applied to his conduct, and that the combination of the terrorizing and concealed weapon statutes violated his right to lawfully carry a weapon. He did not raise these constitutional arguments in the district court.The Supreme Court of North Dakota reviewed King’s claims for obvious error, as they were not preserved below. The court held that King failed to demonstrate any clear or obvious deviation from current law regarding the constitutionality of the statutes as applied to him. The court found that the terrorizing statute incorporates both subjective and objective standards, and that King’s overbreadth and Second Amendment arguments did not establish plain error. The Supreme Court of North Dakota affirmed the district court’s judgment. View "State v. King" on Justia Law

The case concerns a defendant who was convicted by a jury of multiple sexual offenses, including rape, against his young daughter. The central issue on appeal relates to the jury selection process, specifically whether the defendant’s trial counsel was constitutionally ineffective for failing to challenge a particular juror, referred to as Juror McCarthy, for cause. During voir dire, Juror McCarthy expressed some initial uncertainty about his ability to be impartial in a case involving a child witness and indicated discomfort with the presumption of innocence, but also participated in group responses affirming his willingness to be fair and follow the law.After conviction, the defendant appealed to the Twelfth District Court of Appeals, arguing that his counsel’s failure to challenge Juror McCarthy deprived him of a fair trial. The appellate court reviewed the voir dire transcript and concluded that Juror McCarthy’s statements reflected an internal struggle common to many jurors faced with difficult subject matter, rather than actual bias against the defendant. The court also noted that Juror McCarthy, through group responses and direct questioning, indicated he could be fair and impartial. The appellate court therefore rejected the ineffective assistance claim and affirmed the convictions.The Supreme Court of Ohio reviewed the case, focusing on whether a reviewing court may consider group answers during voir dire when determining actual juror bias, and whether a juror who expresses partiality can be rehabilitated through such group responses. The court held that, in assessing actual bias, the entire voir dire record—including group answers—must be considered. The court found that the defendant failed to demonstrate that Juror McCarthy was actually biased, and thus did not establish ineffective assistance of counsel. The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. View "State v. Rogers" on Justia Law

During the 2023–2024 academic year, students at a private university in Massachusetts engaged in a series of pro-Palestinian protests following violence in the Middle East. The protests included rallies, walkouts, chalk messages, and an encampment near the campus Hillel center. Some Jewish and Israeli students reported feeling unsafe or unwelcome, and a few specific incidents were alleged, such as being blocked from campus areas or subjected to hostile remarks. The university responded by revising protest policies, suspending student groups, and eventually clearing the encampment, but did not discipline all protestors or end the demonstrations immediately.The United States District Court for the District of Massachusetts dismissed the plaintiffs’ suit, which alleged violations of Title VI of the Civil Rights Act, the Ku Klux Klan Act, and state law, for failure to state a claim. The court found that the plaintiffs had not plausibly alleged actionable harassment or that the university was deliberately indifferent to any such harassment. The court also declined to exercise supplemental jurisdiction over the state-law claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that most of the protestors’ conduct constituted protected speech under the First Amendment and did not amount to actionable harassment under Title VI. The court further found that the university was not deliberately indifferent, as it took a series of escalating actions in response to the protests. The court also concluded that the plaintiffs failed to state a claim under the Ku Klux Klan Act because they did not plausibly allege a conspiracy with the purpose of depriving Jewish or Israeli students of their rights. The dismissal of the state-law claims was affirmed, and the court found no abuse of discretion in denying further leave to amend the complaint. View "StandWithUs Center for Legal Justice v. MIT" on Justia Law

Several healthcare employees in Colorado, including those at the University of Colorado Hospital Authority and South Denver Cardiology Associates, were terminated after refusing to comply with their employers’ COVID-19 vaccination mandates. These mandates, implemented in 2021, required employees to either be vaccinated or obtain a medical or religious exemption. The plaintiffs declined vaccination and did not seek exemptions, resulting in their dismissal.Following their terminations, the plaintiffs filed separate lawsuits in the United States District Court for the District of Colorado, asserting nearly identical claims. They alleged violations of statutory, constitutional, and contractual rights, including claims under 42 U.S.C. § 1983, state-law breach of contract and tort claims, and an implied private right of action under the Food, Drug, and Cosmetic Act. The defendants moved to dismiss on grounds such as sovereign immunity, qualified immunity, and failure to state a claim. The district courts dismissed all claims, finding that the plaintiffs had not adequately pled any viable legal theory. The courts also denied the plaintiffs’ requests to amend their complaints after judgment was entered.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the dismissals de novo. The court held that none of the statutes cited by the plaintiffs—including the Emergency Use Authorization statute, the PREP Act, and 10 U.S.C. § 980—unambiguously conferred individual rights enforceable under § 1983. The court also found that the constitutional claims, including those based on due process and equal protection, were not adequately pled and that the breach of contract claim was waived for lack of argument. The Tenth Circuit affirmed the district courts’ judgments, holding that the plaintiffs failed to state any claim upon which relief could be granted and that the lower courts did not abuse their discretion in denying leave to amend. View "Timken v. South Denver Cardiology Associates" on Justia Law

A nineteen-year-old man was convicted for his involvement in two murders in Wyoming. He was sentenced in 2006 to three consecutive terms of life imprisonment without the possibility of parole, following a jury trial in which he was acquitted of one count of first-degree murder but convicted of conspiracy to commit murder and first-degree murder for the other offenses. The crimes involved the killing of a roommate and a sixteen-year-old, with the defendant playing a significant role in both. At sentencing, the jury declined to impose the death penalty and instead issued mandatory life without parole sentences, as required by Wyoming law at the time.After his direct appeal was denied by the Wyoming Supreme Court, the defendant filed a motion in 2024 to correct his sentences, arguing that mandatory life without parole for “emerging adults” (those aged eighteen to twenty-one) is unconstitutional under both the Wyoming and United States Constitutions. He claimed that new scientific evidence and evolving legal standards, particularly those established in Miller v. Alabama and related U.S. Supreme Court cases, should extend protections against mandatory life without parole to offenders in his age group. The District Court of Campbell County denied his motion, finding that the relevant constitutional protections and precedents did not apply to adults over eighteen.The Supreme Court of Wyoming reviewed the case and affirmed the district court’s decision. The court held that the Wyoming Constitution does not provide broader categorical protections for “emerging adults” than the Eighth Amendment. It concluded that the state’s constitutional provisions on cruel or unusual punishment and on the penal code’s humane principles do not prohibit mandatory life without parole sentences for offenders over eighteen. The court also found no violation of equal protection or entitlement to a new sentencing hearing. The holding clarified that, while Wyoming’s constitution is distinct from the federal constitution, it does not require categorical relief for emerging adults sentenced to life without parole. View "Hicks v. The State of Wyoming" on Justia Law

The case concerns a shooting that occurred on March 15, 2022, in Griffin, Georgia, resulting in the death of Wildarius Draggs and the assault of Rayshon Goodrum. Surveillance footage showed that Draggs and Goodrum were sitting on a porch when a car containing Isaac Reid, Kinesa Harvey, DeQuivon McMullin, and Cameron Barkley drove by. Later, Reid, McMullin, and Barkley exited the car, walked behind a nearby house, and shortly thereafter, shots were fired at Draggs and Goodrum. Barkley, a co-defendant, testified that Reid fired the shots, motivated by the belief that a rival gang member was present. Physical evidence included shell casings at the scene and a photograph of a gold gun allegedly used in the shooting. Draggs died from his injuries, and Goodrum survived.The Superior Court of Spalding County conducted a joint trial for Reid, Harvey, and McMullin. The jury acquitted Harvey of all charges, found Reid guilty of malice murder and other offenses (but not guilty on one gang-related count), and found McMullin guilty of aggravated battery and felony murder predicated on that battery. Reid was sentenced to life without parole plus consecutive sentences for aggravated assault and a gang violation. Reid filed a motion for new trial, which was denied. He then appealed.The Supreme Court of Georgia reviewed the case after it was transferred from the Court of Appeals. The Court held that the evidence was sufficient under federal due process standards to support Reid’s convictions, finding that the jury could reasonably conclude Reid was the shooter based on the surveillance footage, testimony, and corroborating evidence. The Court also found that the statutory requirement for corroboration of accomplice testimony was met. The denial of Reid’s motion for new trial was affirmed, and his convictions were upheld. View "REID v. THE STATE" on Justia Law

The case concerns the fatal shooting of Michael Riley in his home on June 30, 2013. Police investigation revealed that Riley’s wife, Antoinette Riley, and her daughter, Katrina Ledford, were involved in a plot to kill Riley, with Tarell Momon, who was incarcerated and romantically involved with Ledford, allegedly orchestrating the murder. Cell phone records showed extensive communication between Momon, Ledford, and Antoinette, as well as with two other individuals, Terrance Griswould and Travis Berrian, who were implicated as co-conspirators. The evidence included text messages indicating planning and coordination of the murder, and testimony about Momon’s gang affiliation and prison conduct.A Bulloch County grand jury indicted Momon, Griswould, Ledford, and Antoinette Riley for malice murder and possession of a firearm during the commission of a felony. Ledford and Antoinette pleaded guilty, while Momon and Griswould were tried together. The jury found Momon guilty of murder but acquitted him of the firearm charge; Griswould was acquitted on all counts. Momon was sentenced to life in prison with the possibility of parole. He filed a motion for a new trial, which was denied by the trial court after several amendments and delays.The Supreme Court of Georgia reviewed Momon’s appeal, in which he argued that his trial counsel was constitutionally ineffective for failing to make certain evidentiary objections and that the cumulative effect of these alleged errors denied him a fair trial. The court held that Momon failed to demonstrate either deficient performance by his counsel or resulting prejudice under the standard set by Strickland v. Washington. The court found that the challenged evidence was either admissible, cumulative, or not prejudicial, and that counsel’s decisions were within the bounds of reasonable trial strategy. The judgment of the trial court was affirmed. View "MOMON v. THE STATE" on Justia Law