Justia Constitutional Law Opinion Summaries

Defendant Edwin Rodriquez appealed the denial of his motion to be resentenced. Defendant was charged with aggravated domestic assault and related criminal counts for physically assaulting his then-romantic partner. After defendant pled not guilty, the trial court ordered defendant to be held without bail. While awaiting trial, defendant remained incarcerated throughout the COVID-19 pandemic and unsuccessfully sought to be released on bail based on health concerns arising from conditions of his confinement. At a change-of-plea hearing in December 2021, defendant pleaded guilty to one count of aggravated domestic assault in the first degree and one count of domestic assault. As part of that plea agreement, the State agreed to a cap of twelve years of incarceration. in advance of his sentencing hearing, defendant submitted a sentencing memorandum in which he sought a 4- to 8-year sentence. Defendant referenced several mitigating factors in support of his sentence. The trial court evaluated the pertinent factors and arrived at what it considered an appropriate sentence: 9- to 12-years. On appeal, defendant argued the trial court failed to adequately consider the mitigating factors presented and improperly relied on prior uncharged conduct. Finding no reversible error, the Vermont Supreme Court affirmed the sentence. View "Vermont v. Rodriguez" on Justia Law

The Supreme Court affirmed the determination of the Utah State Tax Commission that the Property Tax Division correctly followed the requirements of the Aircraft Valuation Law, Utah Code 59-2-201 subsection 4, in determining the 2017 value of Delta Air Lines' aircraft, holding that Salt Lake County failed to demonstrate that the Law, as applied to Delta's 2017 assessment, violated the fair market value provision of the Utah Constitution.For tax year 2017, the Division valued Delta's aircraft according to section 59-2-201's preferred methodology. The County appealed, arguing that the valuation did not reflect the fair market value of Delta's aircraft, in violation of the Utah Constitution. The Commission upheld the assessment, concluding that the County did not establish that the Legislature's preferred method of valuation did not reasonably reflect fair market value. The Supreme Court affirmed, holding that the Aircraft Valuation Law was not unconstitutional as applied by the Commission to assess the value of Delta's aircraft for tax year 2017. View "Salt Lake County v. Utah State Tax Commission" on Justia Law

In a prior case before the Washington Supreme Court, the Court rejected Petitioner Amanda Knight’s claim her separate convictions for felony murder (based on first-degree robbery) and first degree robbery violated the constitutional protection against double jeopardy. Double jeopardy did not apply because Knight’s felony murder and robbery convictions were premised on different conduct: the felony murder charge was based on the robbery of a safe whereas the first degree robbery was based on the robbery of a ring. Knight moved for reconsideration and that petition was denied. Here, Knight argued that given the Court’s previous holding, her conviction for felony murder had to be reversed because the jury was presented with insufficient evidence to justify a conviction for robbery of the safe. The Supreme Court concluded the basis for the felony murder conviction could not be sustained, granted Knight’s petition for relief, vacated the felony murder conviction and remanded for resentencing. View "In re Pers. Restraint of Knight" on Justia Law

The Supreme Court held that Ark. Code Ann. 12-9-301, which provides immunity from both suit and liability for certain officials "except to the extent that they have be covered by liability insurance," does not apply to a federal cause of action brought under 42 U.S.C. 1983 but does apply to a state claim brought under the Arkansas Civil Rights Act.Plaintiff filed a complaint against the Benton School District, a principal in the strict (Lori Bacon), and an assistant superintendent (Lisa Gattis). The district court concluded that all Defendants were liable under section 1983 and the Arkansas Civil Rights Act for violating Plaintiff's rights to free speech and to petition the government under the First Amendment. The court granted Bacon and Gattis's motion for summary judgment on qualified immunity grounds but determined that their motion was limited to the extent they were covered by liability insurance. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) section 21-9-301 does not impact a claim brought under section 1983; and (2) the circuit court correctly ruled that section 21-9-301 immunity applies to claims arising under the Arkansas Civil Rights Act. View "Benton School District v. Greer" on Justia Law

Rodney Harrell appealed his conviction for trafficking in methamphetamine, trafficking in marijuana, and possession of drug paraphernalia. Harrell argued his convictions should have been vacated because: (1) the district court erred in denying his motion to suppress; and (2) the district court erred in denying his objection to the reduction of peremptory challenges imposed by the Idaho Supreme Court’s emergency order adopted in response to the COVID-19 pandemic. Finding no reversible error, the Supreme Court affirmed Harrell’s judgment of conviction. View "Idaho v. Harrell" on Justia Law

The Supreme Court reversed the judgment of the district court granting Defendant's motion to suppress evidence obtained during a traffic stop, holding that because Defendant's license plate cover violated Iowa Code 321.37 it was reasonable for Iowa State Patrol troopers to stop his SUV, the stop was not unconstitutional, the exclusionary rule did not apply, and there were no grounds to suppress evidence from the stop.Because Defendant's rear license plate was shrouded with a tinted plastic cover troopers found it difficult to read the plate. The troopers stopped Defendant to warn him that the cover violated Iowa law and during the stop uncovered evidence leading to Defendant's charges for operating while intoxicated and child endangerment. The district court granted Defendant's motion to suppress, concluding that the traffic stop was unconstitutional. The Supreme Court reversed, holding (1) the traffic stop was constitutional because the license plate cover violated an Iowa traffic statute; and (2) therefore, the district court erred in suppressing evidence from the stop. View "State v. Griffin" on Justia Law

Moses Ben Yalartai appealed after he pled guilty to gross sexual imposition. Yalartai argued the district court violated his right to self-representation and erred in denying his motion to withdraw his guilty plea. The North Dakota Supreme Court affirmed, concluding the court did not abuse its discretion in denying his motion to withdraw his guilty plea and Yalartai waived the right to challenge whether the court violated his right of self- representation by pleading guilty. View "North Dakota v. Yalartai" on Justia Law

Sean Kovalevich appealed a district court order denying his motion to correct an illegal sentence under N.D.R.Crim.P. 35(a). Kovalevich was subject to a pre-filing order prohibiting him from filing “any new litigation or any new documents in existing litigation” without first obtaining leave of the court. The North Dakota Supreme Court treated the court’s current order as denying Kovalevich leave of court to file new documents. Orders denying leave to file were not appealable. The Supreme Court therefore dismissed Kovalevich’s appeal. View "North Dakota v. Kovalevich" on Justia Law

Bradley Morales appealed a criminal judgment entered after he pleaded guilty to murder. Morales was convicted by jury of murdering his ex-girlfriend. He was granted a new trial after it was found Morales’ right to a public trial was violated. On the fourth day of the new trial, Morales sought to enter a guilty plea. In verifying his plea was made “knowingly, voluntarily and intelligently,” Morales made a lengthy statement, admitting to stabbing the victim. He apologized to the victim’s family. Roughly nine months later, Morales moved to withdraw his plea. He was thereafter sentenced to 35 years imprisonment. Morales argued the district court erred by not addressing a statement he made at the sentencing hearing indicating he was suffering from depression and anxiety. The North Dakota Supreme Court affirmed, concluding the district court did not abuse its discretion when it denied Morales’ motion to withdraw his guilty plea. View "North Dakota v. Morales" on Justia Law

The Supreme Court affirmed the judgment of the district court ordering reinstatement of D.H.'s firearm rights, holding that there was no error on the part of the district court.After D.H. attempted suicide in 1995 a mental health board obtained a mental health commitment. As a result of D.H.'s commitment, federal and state statutes restricted his rights to purchase and possess firearms. In 2011, the Legislature enacted Neb. Rev. State. 71-963, which created a procedure whereby those subject to firearm restrictions resulting from a mental health-related commitment or adjudication could petition to have those restrictions removed. D.H. filed a motion to remove his firearm restrictions under section 71-963. The Mental Health Board of the 10th Judicial District of Nebraska denied the petition. The district court initially affirmed the denial but, upon reconsideration, granted the petition. The Supreme Court affirmed, holding that the district court did not commit an error of law or abuse its discretion in sustaining D.H.'s motion to reconsider, alter, or amend. View "In re Interest of D.H." on Justia Law