Justia Constitutional Law Opinion Summaries

In 2010, Petitioner was convicted of three counts of juvenile molestation in violation of La. Rev. Stat. Section 14:81.2. Petitioner appealed of the denial of his Section 2254 petition challenging those convictions and his sentence—specifically, his claim on appeal that the evidence at trial was legally insufficient for a conviction on the last count.   The Fifth Circuit affirmed the district court’s denial of his Section 2254 petition. The court wrote that it did not find that the state court was objectively unreasonable in rejecting Petitioner’s claim that there was insufficient evidence to convict him on Count III. The court explained that the evidence was clearly sufficient for a rational jury to find that the described acts were “lewd and lascivious”—and Petitioner’s alternative explanations do not disturb this conclusion. Petitioner’s counsel’s argument, for instance, that it can be normal for adults to “squeeze and pinch” a child’s behind under their clothes flies in the face of common sense. Petitioner provided examples of when such behavior might occur—such as when a child needs help with the restroom—are far afield of the facts before the court. Equally unavailing is counsel’s suggestion that acts must be painful in order to be obscene or indecent. Finally, Petitioner contends that the evidence was insufficient to establish that any molestation occurred in Louisiana as opposed to Mississippi. The court explained that the place of the crime is not an element of the offense of molestation of a juvenile under Louisiana law. View "Terry v. Hooper" on Justia Law

Officers told Plaintiff that he could distribute his tokens in designated zones, referred to as Free Speech Zones, outside the entry gates but not inside the festival itself. Plaintiff nevertheless purchased a ticket, entered the festival, began handing out tokens, and was subsequently ejected. He brought suit alleging that the Cal Expo fairgrounds, in their entirety, constitute a traditional “public forum,” analogous to a public park, thereby entitling his speech to the most robust constitutional protections.   The Ninth Circuit affirmed the district court’s summary judgment for Defendants. The panel first held that the enclosed, ticketed portion of the fairgrounds constituted a nonpublic forum under the United States Constitution and the California Speech Clause. The space did not permit free access, its boundaries were clearly delineated by a fence, and no evidence suggested that access had previously been granted as a matter of course. The panel further noted that California courts have drawn distinctions between ticketed and unticketed portions of venues, and Plaintiff pointed to no case holding that an enclosed area with a paid-entry requirement constitutes a public forum. The panel determined that it need not decide whether the area outside the fence was a public forum under the First Amendment because the California Speech Clause provided independent support for Plaintiff’s argument that it was indeed such a forum, albeit subject to reasonable restrictions on speech. The panel concluded that the Free Speech Zones in the exterior fairgrounds were a valid regulation of the time, place, and manner of Plaintiff’s speech. The guidelines on distributing literature in the enclosed area were likewise permissible. View "BURT CAMENZIND V. CALIFORNIA EXPOSITION AND STATE FAIR, ET AL" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this action seeking to confiscate money under Indiana's civil forfeiture statute, holding that the right to a jury trial applies in such an action.The State filed a complaint to forfeit $2,435 in cash that police officers recovered after stopping Alucious Kizer for a traffic violation, alleging that the money had been "furnished or intended to be furnished" in exchange for a crime, that it had been "used to facilitate" a crime, or that it was "traceable as proceeds" of a crime. Kizer requested a jury trial. The State moved to strike the demand, arguing that no such right existed under either the Indiana or United States Constitution. The court of appeals reversed, concluding that Kizer was not entitled to trial by jury. The Supreme Court vacated the court of appeals' opinion and affirmed the trial court, holding (1) Ind. Const. Art. I, 20 protects the right to a jury trial for in rem civil forfeitures; and (2) therefore, Kizer had a constitutional right to trial by jury. View "State v. $2,435 in U.S. Currency" on Justia Law

The Supreme Court affirmed the judgment of the circuit court holding that the Arkansas Racing Commission's (ARC) decision to award the Pope County casino license to Cherokee Nation Businesses, LLC (CNB) and Legends Resort and Casino, LLC (Legends) was a "legal nullity, void and of no effect," holding that the circuit court did not err.In this third iteration of appeals involving the issuance of the license Gulfside Casino Partnership (Gulfside) argued that the ARC's action was ultra vires because it was issued in violation of the clear language of amendment 100 to the Arkansas Constitution. The circuit court granted summary judgment for Gulfside, concluding that the casino license issued by the ARC jointly to CNB and Legends was an ultra vires action. The Supreme Court affirmed, holding that the circuit court did not err in its decision. View "Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership" on Justia Law

This appeal presents the issue of whether Deputy John Allen and Sheriff Louis Roberts are entitled to qualified and state-agent immunity from Plaintiff’s complaint that he was arrested pursuant to a warrant based on a false affidavit. After Plaintiff drove a methamphetamine trafficker to an undercover drug sting, Allen obtained a warrant from a magistrate judge and arrested him. Florida charged Plaintiff with aiding and abetting drug trafficking and detained him for over six months before dismissing the charges. Plaintiff sued Allen and Roberts under federal and state law, alleging that Allen illegally arrested, detained, and prosecuted him and that Roberts was deliberately indifferent to and negligently caused Allen’s misconduct. The district court granted summary judgment for the officers.   The Eleventh Circuit affirmed, holding that Allen’s warrant affidavit—excluding any false statements—supplied probable cause for Plaintiff’s arrest. The court explained that Plaintiff’s argument that Allen conspired to violate his constitutional rights fails. The court wrote that Plaintiff cannot identify an underlying constitutional violation. “A plaintiff may state a Section 1983 claim for conspiracy to violate constitutional rights by showing a conspiracy existed that resulted in the actual denial of some underlying constitutional right.” Accordingly, in the absence of a constitutional violation, Plaintiff cannot prove a derivative-conspiracy claim. View "Tyler Land v. Sheriff of Jackson County Florida, et al." on Justia Law

Governor DeSantis signed into law the Individual Freedom Act, also called the Stop W.O.K.E. Act. Seven professors and one student from public universities in Florida challenged the law in the district court as violative of their civil rights. Plaintiffs served subpoenas on fourteen non-party legislators—thirteen co-sponsors of the Act and one legislator who supported the bill during a Florida House of Representatives debate. The district court partially granted and partially denied the legislators’ motion. After the legislators appealed, the district court stayed the discovery order pending the resolution of this appeal. At issue on appeal is whether a common-law privilege shields state legislators from a discovery request made for the purpose of determining the legislators’ motives in passing a law.   The Eleventh Circuit reversed and remanded, holding that factual documents are within the scope of the privilege, which is unqualified in this kind of lawsuit. The court explained that according to Plaintiffs’ response to the Florida legislators’ motion to quash the subpoena, the plaintiffs served the subpoenas on the legislators to “determine whether there was a discriminatory motive behind the [Act].” By Plaintiffs’ own admission, the subpoenas’ purpose was to uncover the legislators’ motives in passing the law. “The privilege applies with full force against requests for information about the motives for legislative votes and legislative enactments.” So, the privilege applies with its usual force against the discovery of even the factual documents in the Florida legislators’ possession. Accordingly, the court held that the district court abused its discretion when it determined otherwise. View "Leroy Pernell, et al. v. Robert Alexander Andrade, et al." on Justia Law

Jones was convicted of robbery in Indiana, Kentucky, and federal courts. Jones’s Kentucky plea deal agreed to a commencement date for Jones’s accrual of time-served credits, not when officers actually took Jones into custody, as would ordinarily be the case, but on an earlier date. The sentencing court failed to adopt the plea agreement and ordered the Department of Corrections to calculate Jones’s time-served credit in accordance with “this judgment,” which made no mention of the negotiated agreement, and “the law.” The court did not provide Jones the opportunity to withdraw his plea. Jones did not appeal or seek correction of his sentence. Jones unsuccessfully asked prison administrators to honor the plea agreement’s time-served provision; doing so would have violated the judgment of conviction. Jones asked the sentencing court for clarification. The court ratified the administrators’ calculations. Jones did not appeal. The court subsequently instructed that Jones be given credit in accordance with the agreement. Jones was then released.Jones filed suit, alleging that Kentucky prison administrators violated his Eighth and Fourteenth Amendment rights through their alleged deliberate indifference to the prospect of incarcerating him beyond the length of his sentence. The Sixth Circuit reversed the denial of the defendants’ qualified immunity motions. The defendants—state corrections officials—neither caused nor contributed to Jones’s over-incarceration nor could they unilaterally remedy the matter, which was dictated by court orders. View "Jones v. Bottom" on Justia Law

Defendant n served five years in federal prison after pleading guilty to conspiring to provide material support to ISIS. He was released in 2020 subject to a lifetime of supervised release. Three years later, the district court found that Defendant had violated numerous conditions of his supervised release. The court sentenced him to a year’s imprisonment and reimposed a lifetime of supervised release. Defendant brought several challenges to this sentence.   The Fourth Circuit affirmed. The court explained that Defendant claims the lifetime term of his supervised release is an “extreme and unusual remedy” that should be “viewed critically.” He suggests that lifetime release should typically be affirmed only in cases involving “child pornography or violent crimes.” But the appropriateness of lifetime supervised release in one serious class of cases does not render it inappropriate for another. Defendant combined extremist ideology and technical sophistication to build widespread support online for ISIS’s brutal campaign of terror and violence. He simultaneously coaxed men into traveling to Syria with deadly consequences. Upon his release from prison, Defendant continued to spread toxic messages online, including a call to “exterminate” all non-believers of ISIS’s jihadist ideology—the vast majority of the global population. It was eminently reasonable for the district court to reimpose a lifetime of supervised release under these circumstances. View "US v. Ali Amin" on Justia Law

Plaintiff filed suit in federal district court against Judge Goldston and others present at the search. Plaintiff claimed that the warrantless search and seizure of his property violated his Fourth and Fourteenth Amendment rights, that the restrictions on recording the incident violated the First Amendment, and that Judge Goldston’s practice of conducting “home visits” violated the Equal Protection Clause by disadvantaging pro se litigants like himself. He sought compensatory and punitive damages under 42 U.S.C. Section 1983, as well as attorney’s fees and injunctive and declaratory relief. Judge Goldston moved for summary judgment, claiming she was entitled to absolute judicial immunity. The district court denied her motion. At issue on appeal is whether Judge Goldston is entitled to judicial immunity.   The Fourth Circuit affirmed, holding that judicial immunity protects only judicial acts. It does not shield the conduct of judges who step outside their judicial role, as Judge Goldston did when searching Plaintiff’s home. The court explained that while Judge Goldston might have had the authority to order a search, the proper authority to conduct the operation was the local sheriff’s department or some other appropriate law enforcement agency. The court explained that just as “judges do not do double duty as jailers,” so too they do not do double duty as sheriffs. View "Matthew Gibson v. Louise Goldston" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Petitioner to ten to twenty-five years' imprisonment after he pleaded guilty to second-degree sexual assault, holding that the circuit court's failure to explicitly discuss the mandatory mitigating circumstances listed in W. Va. Code 61-11-23(c) before ordering the final sentence was not prejudicial.On appeal, Petitioner argued that the circuit court failed to consider the "mitigating circumstances" set forth in section 61-11-23(c) and that his sentence was constitutionally disproportionate. The Supreme Court affirmed the sentence, holding (1) Petitioner's substantial rights were not affected by the circuit court's failure to acknowledge and consider the statutory mitigating circumstances; and (2) Petitioner's argument that his sentence was constitutionally disproportionate due to his age and mental capacity was unavailing. View "State v. Hall" on Justia Law