Justia Constitutional Law Opinion Summaries

Plaintiff a practicing Baptist, was incarcerated in the Green Haven Correctional Facility from 2002 until 2018. After prison officials failed to update the Protestant services “call-out list,” Wiggins was excluded from all religious services for over five months. He sued Green Haven officials Thomas Griffin, M. Kopp, D. Howard, and Dr. G. Jebamani under 42 U.S.C. Section 1983, alleging that they violated his constitutional rights. The district court granted Defendants’ motion for summary judgment, reasoning that (1) Defendants did not substantially burden Plaintiff’s free exercise of religion, (2) Defendants were entitled to qualified immunity, and (3) if there were a constitutional violation, Kopp was not personally involved in it.   The Second Circuit affirmed in part, vacated in part, and remanded to the district court for further proceedings. First, the court concluded that Defendants’ failure to update the Protestant services call-out list, which prevented Plaintiff from attending worship services for over five months, substantially burdened his religious exercise. Second, because disputed issues of material fact remain, qualified immunity cannot shield Defendants from liability at this juncture. Third, Plaintiff sufficiently alleged Kopp’s personal involvement in a First Amendment violation by pleading that Kopp took no action even after she was informed that Plaintiff’s rights were being infringed. Finally, the court held that a Section 1983 free exercise claim requires a plaintiff to demonstrate the defendant’s deliberate indifference to the plaintiff’s rights. View "Wiggins v. Griffin, et al." on Justia Law

On April 28, 2020, defendant Amandeep Tiwana, while driving in Jersey City, struck a police officer and collided with two police cruisers. Defendant and three injured officers were transported to Jersey City Medical Center. Defendant’s blood alcohol content was 0.268%, three times the legal limit. Detective Anthony Espaillat of the Regional Collision Investigation Unit of the Hudson County Prosecutor’s Office arrived at the hospital and spoke first to the injured officers in the emergency room. Two uniformed police officers were stationed outside the curtain separating defendant’s bed from other patients. Detective Espaillat walked up to defendant’s bed, introduced himself as a detective with the Prosecutor’s Office, and explained that he was assigned to investigate the accident. Espaillat testified that, as soon as he had spoken, defendant immediately complained of chest pain and said “she only had two shots prior to the crash.” Espaillat directed defendant not to make any other statements. He clarified that he did not come to the hospital to ask her questions and that he wanted to interview her at a later date at the Prosecutor’s Office. The entire interaction lasted “less than five minutes.” The next day, defendant went to the Prosecutor’s Office and invoked her Miranda rights. The issue this case presented for the New Jersey Supreme Court consideration was whether the detective’s self-introduction to defendant at her bedside in the hospital initiated a custodial interrogation or its functional equivalent warranting the administration of Miranda warnings. Pretrial, the State moved to admit defendant’s statement at the hospital. The trial court denied the State’s motion and the Appellate Division affirmed. Both courts found that a custodial interrogation occurred at the hospital and the detective’s failure to give Miranda warnings rendered defendant’s statement inadmissible. The Supreme Court reversed: defendant was in custody at the hospital in light of the police presence around her bed area. But no interrogation or its functional equivalent occurred before her spontaneous and unsolicited admission. Miranda warnings were therefore not required, and defendant’s statement -- that she “only had two shots prior to the crash” -- was admissible at trial. View "New Jersey v. Tiwana" on Justia Law

The California Department of Corrections and Rehabilitation (CDCR) identified defendant-appellant Ryan Christianson as an inmate potentially eligible for relief under California Penal Code section 1172.75, but the trial court corrected the original sentence by administratively striking section 667.5(b) enhancements that had been stayed by the original sentencing court, and thus concluded resentencing was unnecessary. On appeal, the parties asked the Court of Appeal to decide whether section 1172.75 applied in cases like this, where the abstract of judgment on which an inmate was currently serving time included one or more section 667.5(b) enhancements that were previously imposed but stayed. To this, the Court concluded that it did and that therefore resentencing was required. Accordingly, the Court reversed the trial court’s order denying Christianson’s request for resentencing. View "California v. Christianson" on Justia Law

C.P. struck the victim on her head with a mallet, causing significant injuries. The issue on review was whether the juvenile court misconstrued the governing statute, ORS 419A.258, in ordering disclosure of confidential records in youth’s file to the victim before youth’s delinquency dispositional hearing. The Oregon Court of Appeals concluded that the victim was unable to show that disclosure was “necessary to serve a legitimate need” of the requesting party, as required by ORS 419A.258(7). The Oregon Supreme Court concluded after review of the text, context, and legislative history of ORS 419A.258 that the statute, properly construed, gave juvenile courts some discretion in weighing the interests at stake before determining whether and to what extent disclosure was necessary to serve a legitimate need of the person seeking disclosure under the circumstances of a given case. The Supreme Court rejected the Court of Appeals’ interpretation of what was necessary to serve a victim’s legitimate need and concluded that the juvenile court in this case acted within the range of discretion granted by the statute in ordering disclosure to the victim. Accordingly, the Court of Appeals' judgment was reversed and the juvenile court's order was affirmed. court. View "Oregon v. C. P." on Justia Law

Following the State’s dismissal of criminal charges against him, Nickolaus Oldenburg moved the district court to seal the criminal court file pursuant to Idaho Code section 67-3004(10). The State did not contest the motion. Nevertheless, the district court concluded that it did not have the authority to seal Oldenburg’s case file under section 67-3004(10) and, therefore, could not grant his request. As a result of its analysis, the district court denied Oldenburg’s motion. The Idaho Supreme Court held the district court correctly concluded that the legislature could not independently vest the district court with the authority to seal Oldenburg’s court file. "The control of court records resides within the prerogative of this Court, and this Court has adopted I.C.A.R. 32 to govern a defendant’s request to seal court records. ... When the statute is procedural, it is viewed as an attempt 'to control this Court’s processes' and is classified as an impermissible overreach into the authority of this Court to develop its own procedures." Thus, the district court correctly found that Idaho Code section 67-3004(10) impinged on the Supreme Court’s prerogative to make its own rules which governed its own procedure. Accordingly, the decision of the district court was affirmed. View "Idaho v. Oldenburg" on Justia Law

The Supreme Court affirmed Defendant's conviction for operating while intoxicated (OWI) and eluding, holding that the district court did not abuse its discretion in admitting evidence about a preliminary breath test (PBT) and that the evidence was sufficient to support the convictions.During the underlying jury trial, the district court admitted a portion of an officer body cam video showing Defendant agreeing to a PBT, after which the edited video jumped to Defendant's arrest for OWI. The Supreme Court held (1) this juxtaposition of the PBT and arrest violated Iowa R. Evid. 5.403 because it had minimal probative value while strongly implying that Defendant had failed the PBT, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's eluding conviction. View "State v. Amisi" on Justia Law

The Supreme Court held that the district court and court of appeals did not err in finding that Defendant was not seized before the law enforcement officer who eventually arrested him discovered his probable intoxication and that Defendant was lawfully detained on grounds of probable intoxication.In his motion to suppress, Defendant argued that he had been seized when the officers partially blocked him in while he was parked in a parking lot, trained a spotlight on him, and shined flashlights into his car from both sides. The trial court concluded that Defendant had not been "seized" before the police discovered his intoxication. The court of appeals affirmed, concluding that the officers' actions were not "sufficiently coercive" to constitute a seizure. The Supreme Court affirmed, holding that Defendant was lawfully detained because the officers did not seize him before his intoxication was observed. View "State v. Wittenberg" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to suppress and convicting him of firearm violations, holding that the law enforcement officer who arrested Defendant did not unlawfully seize Defendant.After a woman called the police to report a suspicion car parked in front of her home an officer responded in a patrol car and pulled alongside the parked car. The officer walked over to talk to the driver, smelled a strong odor of burnt marijuana, and searched Defendant and the car. In his suppression motion, Defendant argued that the officer did not unlawfully seize him. The court of appeals concluded that the trial court did not err in denying the motion to suppress. The Supreme Court affirmed, holding that the officer's conduct in this case did not constitute a seizure, and once the officer detected the odor of burnt marijuana he had a lawful ground to detain and search Defendant and the car. View "State v. Cyrus" on Justia Law

The Supreme Court affirmed Defendant's convictions for possession of a firearm by a prohibited person and unlawful discharge of a firearm, holding that there was no reversible error or abuse of discretion in the proceedings below.Specifically, the Supreme Court held (1) the evidence was sufficient to support Defendant's conviction for possession of a firearm by a prohibited person; (2) the evidence was sufficient to support Defendant's conviction for unlawful discharge of a firearm; (3) the district court did not abuse its discretion in overruling Defendant's motion for new trial; (4) Defendant's claims of ineffective assistance of counsel were not sufficiently pled; and (5) the cumulative error doctrine did not apply in this case. View "State v. Dap" on Justia Law

This case stemmed from a cold-case murder that took place in 1981. An armed robber broke into a gas station where Russell Douglas was working, shot him several times, robbed the station, and fled. Douglas's murderer eluded capture. Then, some 30 years later, forensic scientists retested DNA evidence found at the crime scene and turned up a match to the respondent here, Nathaniel Dennis, who was serving a 600-year sentence in Virginia for an unrelated crime. In 2011, an Alabama grand jury indicted Dennis for the murder of Douglas, and he was transferred to Alabama to stand trial. In 2019, after a series of pretrial delays, Dennis was convicted of murder made capital because it was committed during a burglary. Dennis appealed, arguing that the delay between his indictment and trial violated his right to a speedy trial. The Court of Criminal Appeals agreed, holding that the over-eight-year period between 2011 and 2019 required the trial court to "presume" that the delay prejudiced Dennis's liberty interests -- even though Dennis had not put forward any affirmative evidence of prejudice and likely could not have done so because he was already serving a 600-year sentence in Virginia. The Alabama Supreme Court concluded this was error: the speedy-trial inquiry turns on how much delay has been caused by the government, not the bare amount of time between the indictment and trial. In this case, the portion of the delay caused by government negligence fell well short of the amount needed to justify a presumption of prejudice. Absent that presumption, Dennis' speedy-trial claim failed. The Court reversed the appellate court's judgment and remanded for consideration of the other arguments Dennis raised in his appeal. View "In re: Dennis v. Alabama)" on Justia Law