Justia Constitutional Law Opinion Summaries

Following a series of COVID-19-related continuances and other setbacks, Defendant was convicted by a jury of two counts of fentanyl distribution. Defendant argued that these delays violated his statutory and constitutional rights to a speedy trial. Defendant also argues the district court erred in denying his motion for acquittal.   The Fourth Circuit affirmed. The court explained that, in total, 357 days of 401 days were properly excluded. This means that, at most, only 44 days accrued towards Defendant’s speedy trial clock. The court concluded that Defendant’s rights under the Speedy Trial Act were not violated. Moreover, the court noted that Defendant has not “shown, or even argued, that any evidence was damaged or lost, that any witnesses could not be found, or that his case was harmed in any manner by the delay.” Further, the court wrote that substantial evidence supports Defendant’s convictions. Much of the evidence at trial came from the testimony of the confidential informant who purchased the drugs from Defendant. This informant testified that he knew Defendant because they had a mutual friend whose apartment they both frequented. He also testified that he and Pair had discussed doing business together prior to the informant cooperating with law enforcement. The court explained that viewing the evidence in the light most favorable to the government as the prevailing party below, any reasonable finder of fact could find beyond a reasonable doubt that Defendant was guilty of distributing fentanyl. View "US v. Quotez Pair" on Justia Law

Vidal-Martinez, a non-citizen, was arrested three times for operating a vehicle while intoxicated. DHS detained him and initiated deportation. Vidal-Martinez filed a habeas petition, arguing that his detention was unconstitutional because it impeded his ability to defend himself against the drunk-driving charges. ICE transferred Vidal-Martinez to county custody “until the completion of [the] criminal matter, then released to his ICE detainer.” Vidal-Martinez was convicted of DUI and sentenced to 236 days in jail. He was then returned to ICE custody. Due to a lack of evidence that he posed a flight risk or a danger to the community, the district court granted Vidal-Martinez’s habeas petition and ordered his release.Vidal-Martinez filed a FOIA request, 5 U.S.C. 552, seeking disclosure from ICE of documents related to his custody transfer. ICE produced 561 pages of responsive documents, some of which contained redactions. Vidal-Martinez challenged ICE’s redactions. ICE submitted a Vaughn index and a declaration from its FOIA officer explaining the legal justification for each redaction, citing attorney-client, work product, deliberative process privileges, and identifying information of government employees. Vidal-Martinez responded that ICE committed criminal conduct by transferring him to Indiana, so the crime-fraud exception to attorney-client privilege applied. The district court granted ICE summary judgment. The Seventh Circuit affirmed, finding no factual foundation in the record for criminal conduct or misconduct by ICE. The district court had an adequate factual basis to evaluate ICE’s withholdings. View "Vidal-Martinez v. United States Department Of Homeland Security" on Justia Law

After arresting Aaron Garnett in whose care were three young children, the police promptly sought to locate the children’s parent or guardian. This search, initiated before sunrise on a cold and rainy day, led the police to a house where they were told the children’s mother lived and was sleeping. Once there, the police knocked, then banged, on the front door and loudly announced their presence. When no one answered, one of the officers went to the rear of the house where, after another round of knocking and announcing, the officer noticed the back door was unlocked. He pushed open the unlocked door and, peering into the interior of the residence with the benefit of a flashlight, saw a motionless body under a blanket at the foot of a stairway. Joined now by fellow officers, he entered the residence and found the lifeless body of Naquita Hill, the mother of one of the children whose welfare had motivated the police’s visit. Seven or so hours later, Garnett confessed that, during a heated argument, he had choked Hill until she slumped to the floor and beat her with his fist after that. After a jury trial, Garnett was convicted of Naquita Hill’s murder. He appealed, but the Delaware Supreme Court found no reversible error and affirmed Garnett's conviction. View "Garnett v. Delaware" on Justia Law

Defendant-appellant Edward Parson was convicted by jury of aggravated sexual abuse of a child. Parson argued: (1) the district court erred in admitting expert testimony about the process of child-sexual-abuse disclosures and the characteristics and behaviors of children who make such disclosures; and (2) the district court erred in admitting specific testimony of the expert that children are four times more likely to omit facts than to make up facts in the process of disclosing abuse. The Tenth Circuit determined the district court did not abuse its discretion in admitting the expert testimony, and his second claim of error was unpreserved and Parson failed to demonstrate an entitlement to relief under the difficult-to-satisfy plain error standard. Thus, the district court’s judgment of conviction was affirmed. View "United States v. Parson" on Justia Law

Defendant-Appellant Anthony Mason was convicted by a jury of assault of an intimate or dating partner by strangulation and Oklahoma first-degree burglary. The Presentence Report (PSR) initially calculated an offense level of 22 and a criminal history category of III, resulting in an advisory guideline range of 51 to 63 months’ imprisonment. But when a statutorily required minimum sentence is greater than the maximum of the guideline range, as was the case here, the statutorily required minimum was the guideline sentence. For convictions of first-degree burglary, Oklahoma state law imposed a sentence “not less than seven (7) years.” Accordingly, the PSR recommended a sentence of 84 months’ imprisonment, 21 months more than the initial advisory guideline range. Mason objected to the PSR sentence, arguing that his eligibility for a suspended or deferred sentence under the Oklahoma sentencing scheme meant that it did not impose a “true mandatory minimum.” Finding no reversible error in the calculation of Mason's sentence, the Tenth Circuit affirmed. View "United States v. Mason" on Justia Law

The Court of Appeals held that the legislature's grant of rulemaking authority to the Commission on Forensic Sciences was sufficient to authorize the Commission's promulgation of the Familial DNA Search (FDS) Regulations codified at 9 N.Y.C.R.R. 6192.1 and 6192.3.In 2017, the DNA Subcommittee submitted to the Commission a recommendation to authorize familial DNA searches. The Commission adopted the recommendation, and the New York State Division of Criminal Justice Services (DCJS) formally adopted the recommendation as part of the FDS Regulations. Petitioners brought this N.Y. C.L.P.R. 78 proceeding arguing that Respondents lacked statutory authority to promulgate the FDA Regulations, therefore violating the New York Constitution's separation of powers doctrine. Supreme Court denied the petition on the merits, and the appellate division affirmed. The Court of Appeals reversed, holding that the Commission had the statutory authority to promulgate the FDS Regulations. View "Stevens v. N.Y. State Division of Criminal Justice Services" on Justia Law

The Court of Appeals affirmed the order of the appellate division affirming the judgment of Supreme Court denying Defendant's motion to suppress the firearm found in the vehicle he was driving, holding that the People sustained their burden of demonstrating that the inventory search protocol in this case met "the constitutional minimum."Two New York Police Department officers observed Defendant commit multiple traffic infractions while driving, stopped him, and arrested him for carrying a gravity knife in his pocket. At the precinct, the officers conducted an inventory search of the vehicle and recovered a firearm from the truck. Defendant filed a motion to suppress the firearm on the grounds that the NYPD's inventory search protocol was unconstitutional. The motion was denied, and Defendant pled guilty to criminal possession of a firearm. The Court of Appeals affirmed, holding that Defendant failed to overcome the People's proof establishing a valid inventory search protocol. View "People v. Douglas" on Justia Law

Appellants Joshua Rooks and Quatez Clark were convicted of malice murder and other crimes in connection with the 2016 shooting death of Christopher Dean. Rooks contended the evidence presented at trial was legally insufficient to support his convictions and that the trial court erred by failing to grant his motion for a directed verdict of acquittal. Clark similarly contended the trial court erred by failing to grant his motion for a directed verdict of acquittal on certain counts; he also claimed the court erred by failing to grant his motion for new trial on the “general grounds” set forth in OCGA §§ 5-5-20 and 5-5-21 and by admitting under OCGA § 24-4-404 (b) evidence showing that he participated in another murder 11 days after Dean’s murder and that he committed marijuana- and firearm-related crimes about two months after Dean’s murder. Finding no reversible error in either case, the Georgia Supreme Court affirmed convictions in both cases. View "Rooks v. Georgia" on Justia Law

Jessica Eubanks was convicted by jury of felony murder. Eubanks lived with her boyfriend, Shawn Hughes, and Shawn’s sister, Amy Hughes, who had severe developmental disabilities. Eubanks used heroin and methamphetamine and kept a large supply of heroin in the home. One evening when Shawn was out, Eubanks invited two people to the home to buy heroin. During the transaction, which she conducted in the main part of the home, some of the drug spilled “all over the place” and Eubanks tried to clean it up. Then she went out, leaving Amy home alone. The next morning Amy was found dead of heroin toxicity. Eubanks appealed. "Although Eubanks’s conviction tests the limits our felony-murder statute places on that offense," the Georgia Supreme Court concluded that based on precedent and the unusual facts of this case that the evidence was sufficient to authorize her conviction. "Eubanks’s possession of heroin with intent to distribute was dangerous to human life under the circumstances of this case because it was foreseeable that keeping a large amount of a deadly drug in a home where a highly vulnerable person lived, and engaging in drug transactions in areas that person could freely access, could lead to that person being fatally exposed to the drug." Finding no other reversible error, the Supreme Court affirmed the judgment of conviction. View "Eubanks v. Georgia" on Justia Law

Deveric Hardy was convicted of malice murder for the November 2016 shooting death of Kyree Smith. He appealed that conviction, arguing that his trial counsel provided constitutionally ineffective assistance by failing to introduce evidence that Smith had a violent character and by failing to request a jury instruction on accomplice corroboration. Finding no reversible error, the Georgia Supreme Court affirmed Hardy's judgment of conviction. View "Hardy v. Georgia" on Justia Law