Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition ordering the trial court to vacate his criminal sentence, holding that Appellant was not entitled to a writ of mandamus or prohibition.Appellant was convicted of escape, retaliation, and other offenses and sentenced to 26.5 years in prison. Appellant later brought the current action seeking writs of prohibition and mandamus ordering the trial court to vacate his sentencing entries and to grant any other relief to which he was "entitled." The court of appeals dismissed the complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law through direct appeal to raise his claim that the Sixth Amendment requires that a defendant be expressly informed of his right to counsel at each critical stage of the proceeding and that the trial court's failure to do so in his case rendered his sentence void. View "State ex rel. Rarden v. Butler County Common Pleas Court" on Justia Law

The San Bernardino County District Attorney (the District Attorney) appealed a trial court order granting Karla Coca’s petition under Penal Code section 1473.7 to vacate a misdemeanor conviction. After review, the Court of Appeal concluded Coca failed to demonstrate by a preponderance of the evidence that “the conviction . . . being challenged is currently causing or has the potential to cause removal or the denial of an application for an immigration benefit, lawful status, or naturalization.” The Court accordingly reversed the order. View "California v. Coca" on Justia Law

The First Circuit vacated the judgment of the district court convicting Defendant on federal drug- and gun-related charges, holding that the district court erred by failing to suppress incriminating statements Defendant made to law enforcement because the government failed to satisfy its burden to show that Defendant validly waived his rights under Miranda v. Arizona, 384 U.S. 436 (1966).Defendant was charged with conspiracy to distribute and to possess with intent to distribute heroin, cocaine, cocaine base, and fentanyl; possession with intent to distribute those drugs; and being a felon in possession of a firearm. Defendant filed a motion to suppress statements he made to law enforcement immediately following his arrest, arguing that the statements were obtained in violation of his Miranda rights. The district court denied the motion to suppress, concluding that Defendant understood his Miranda rights and knowingly, intelligently and voluntarily waived them. The First Circuit reversed, holding that the government failed to show that Defendant validly waived his Miranda rights, and this error was not harmless. View "United States v. Donald" on Justia Law

The Ventura County District Attorney charged Defendant with being a felon in possession of a firearm, ammunition and a machine gun. As to each charge, it was alleged that Defendant suffered a 2021 prior strike conviction for possessing a firearm for the benefit of a criminal street gang. Assembly Bill No. 333 amended section 186.22 to require evidence that the firearm possession provides more than a reputational benefit to the street gang. Because no such evidence supported Defendant’s prior conviction, the trial court concluded that it no longer qualified as a strike. Defendant pleaded no contest to the three charges against him and was sentenced to two years in state prison. The district attorney appealed.   The Second Appellate District vacated the judgment and reversed the order granting Defendant’s motion to dismiss the strike allegations. The court explained that when it enacted Assembly Bill No. 333, the Legislature found that gang enhancements have not been shown to reduce crime or violence. The Legislature also found that these enhancements have been applied inconsistently and disproportionately against people of color. They have additionally been applied to minor crimes and have been used to “legitimize severe punishment.” However, the court explained that while these are valid concerns, it is not the province of the court to apply legislative concerns to a statutory scheme the Legislature has left unchanged. View "P. v. Aguirre" on Justia Law

The Supreme Court vacated Defendant's conviction of attempt to possess pseudoephedrine in an altered state and remanded this case for further proceedings, holding that the circuit court plainly erred by finding a factual basis for Defendant's no contest plea.Defendant was charged in an indictment with possession of pseudoephedrine in an altered state, a felony. Defendant pled nolo contendere to attempt to possess pseudoephedrine in an altered state and was sentenced to one to three years' imprisonment. Defendant appealed, challenging the circuit court's denial of his motion to dismiss. The Supreme Court vacated Defendant's conviction, holding that the circuit court erred when it found that a factual basis existed for a plea to attempt to commit possession of pseudoephedrine in an altered state where the only evidence was Defendant's possession of completed methamphetamine. View "State v. Finley" on Justia Law

The Supreme Court held that the "anti-abrogation clause" set forth in Ariz. Const. art. XVIII, 6 guaranteeing that the "right of action to recover damages for injuries shall never be abrogated" does not extend to dram-shop actions because they were recognized after statehood.At issue was whether the anti-abrogation clause extends to rights of action created after the Arizona Constitution was ratified, such as the common law dram-shop action recognized in Ontiveros v. Borak, 136 Ariz. 500 (1983). Plaintiffs sued Defendant, the owner of Jaguars Club in Phoenix, under theories of statutory and common law dram-shop liability. The jury found Defendant was liable under the common law dram-shop action recognized in Ontiveros but not liable under the dram-shop cause of action codified at Ariz. Rev. Stat. 4-311(A). The jury apportioned forty percent of the fault to Defendant. The Supreme Court remanded the case to the trial court for entry of judgment in favor of Defendant, holding that the legislature's limitation of dram-shop liability to actions brought under section 4-311 did not run afoul of the anti-abrogation clause by abrogating the common law dram-shop action recognized in Ontiveros. View "Torres v. JAI Dining Services, Inc." on Justia Law

The Weld County Colorado Board of County Commissioners (“Weld County”) sought review of rules adopted by the Colorado Air Quality Control Commission (the “Commission”) to minimize emissions of certain pollutants from oil and gas wells. A Colorado court of appeals applied a specialized political subdivision standing test and concluded that Weld County did not have standing to pursue its claims. In Colorado State Board of Education v. Adams County School District 14, 2023 CO 52, __ P.3d __, the Colorado Supreme Court abandoned the political subdivision test because it generated unnecessary confusion, and that a political subdivision, just like any other plaintiff, had to satisfy only the standing test developed in Wimberly v. Ettenberg, 570 P.2d 535 (Colo. 1977). Applying that holding here, the Court examined whether Weld County has suffered (1) an injury in fact (2) to a legally protected interest. To this, the Court concluded that, although Weld County had a legally protected interest, it could not demonstrate an injury to that interest. Accordingly, Weld County lacked standing to pursue the claims raised here. We thus affirm the division’s judgment, albeit on different grounds. View "Weld County v. Ryan" on Justia Law

Two months after an apparent arson left five people dead, the Denver Police Department (“DPD”) had no suspects. They employed an unconventional investigative technique: a “reverse-keyword warrant.” Google disclosed to DPD a list that included five Colorado internet protocol (“IP”) addresses associated with devices that had searched for the location of the fire in a roughly two-week period before it occurred. Based in part on this information, law enforcement eventually charged Gavin Seymour and two others with multiple counts of first degree murder. Seymour moved to suppress the fruit of the warrant, arguing that it lacked probable cause and particularity. The trial court denied Seymour’s suppression motion. The Colorado Supreme Court affirmed, finding: (1) under the Colorado Constitution, Seymour had a constitutionally protected privacy interest in his Google search history even when revealed only in connection with his IP address and not his name and that, under both the Colorado Constitution and the Fourth Amendment, he also had a constitutionally protected possessory interest in that same history; (2) Seymour’s Google search history implicated his right to freedom of expression; (3) the warrant at issue adequately particularized the place to be searched and the things to be seized; (4) the warrant required individualized probable cause and that its absence here rendered the warrant constitutionally defective; and (5) law enforcement obtained and executed the warrant in good faith, so the evidence shouldn’t be suppressed under the exclusionary rule. "At every step, law enforcement acted reasonably to carry out a novel search in a constitutional manner. Suppressing the evidence here wouldn’t deter police misconduct." View "Colorado v. Seymour" on Justia Law

Petitioners appealed from orders of the district court denying their petitions for habeas relief pursuant to 28 U.S.C. Section 2255, following their 2012 convictions for conspiracy to commit Hobbs Act robbery and use of a firearm in furtherance of a crime of violence – specifically, the Hobbs Act robbery conspiracy – that caused the death of another person, in violation of 18 U.S.C. Section 924(c) and (j). On appeal, Petitioners contend that the district court erroneously enforced the collateral-attack waivers in their plea agreements, which they argue are unenforceable in light of Johnson v. United States, 576 U.S. 591 (2015), and United States v. Davis, 139 S. Ct. 2319 (2019).   The Second Circuit dismissed the appeal and explained that subsequent changes in the law do not allow Petitioners to back out of their valid agreements with the government; the waivers are enforceable. The court explained that a waiver of the right to bring a postconviction challenge is presumptively enforceable, even after the legal landscape shifts. A defendant who wishes to maintain his right to collaterally attack his conviction in the event of unforeseen legal developments may, of course, attempt to negotiate more favorable waiver terms with the government before pleading guilty. But where the waiver itself is clear, unambiguous, knowingly and voluntarily entered, and supported by consideration – here, the government’s agreement not to pursue charges or arguments that could have resulted in a much higher sentence – the terms of the plea agreements must be enforced. View "Cook v. United States" on Justia Law

Plaintiff is an Idaho prisoner facing execution by lethal injection. He challenged Idaho’s execution practices. He alleged that these practices: 1) interfere with his ability to challenge the State’s method of execution as cruel and unusual punishment; 2) inhibit his ability to seek clemency; 3) inflict mental anguish; 4) increase the risk of an unconstitutionally painful execution; 5) treat similarly situated prisoners unequally; 6) violate the separation of powers under the Idaho Constitution; and 7) contravene Idaho Code Section 19-2716’s requirement that the director of the Idaho Department of Correction (IDOC) establish procedures governing executions. On remand, and in light of then-co-plaintiff’s scheduled execution, the district court sua sponte dismissed the complaint for failure to state a claim under Federal Rule of Civil Procedure (“Rule”) 12(b)(6).   The Ninth Circuit affirmed in part, vacated in part, and remanded. The court rejected Plaintiff’s contention that the district court violated the rule of mandate by denying leave to amend in connection with the Rule 12(b)(6) dismissal of the complaint. The court explained that although its decision in Pizzuto I noted parenthetically that Plaintiff should be permitted to amend the complaint, the court did not foreclose the district court’s sua sponte dismissal of the complaint or address whether, in connection with such a dismissal, further amendment would be futile. The court agreed with the district court that amendment of several of Plaintiff’s claims would be futile. The court therefore affirmed the dismissal with prejudice of the First Amendment claims based on access to execution-related information. View "THOMAS CREECH, ET AL V. JOSH TEWALT, ET AL" on Justia Law