Justia Constitutional Law Opinion Summaries

A jury found the defendant guilty of second-degree assault. At the sentencing hearing, the trial judge initially announced a sentence of one year, suspending all but nine months to be served on home detention, followed by three years of supervised probation. While the judge was advising the defendant of his post-trial rights, the prosecutor questioned whether the sentence properly reflected the intended punishment and raised concerns about the remaining active time if probation was violated. After a brief colloquy and clarification, the judge revised the sentence, increasing it to five years, suspending all but nine months on home detention, and three years of supervised probation.The defendant appealed to the Appellate Court of Maryland, arguing that the trial judge had illegally increased the sentence after it had been imposed, in violation of Maryland Rule 4-345, which restricts modifications to sentences once they are imposed. The Appellate Court rejected this argument, holding that the sentence was not illegally increased because the revision occurred before the sentencing proceeding concluded, and Rule 4-345 was therefore not triggered.On further appeal, the Supreme Court of Maryland affirmed the decision of the Appellate Court. The Supreme Court held that under Maryland law, a sentence is not considered “imposed” under Rule 4-345 until the sentencing proceeding ends. Thus, a trial court retains authority to modify or increase a sentence during an ongoing sentencing hearing. Since the revision to the defendant’s sentence occurred before the conclusion of the sentencing proceeding—while the defendant was still present and the case was not over—Rule 4-345 did not apply, and the increase did not violate double jeopardy protections. The judgment of the Circuit Court for Prince George’s County was affirmed. View "Reyes v. State" on Justia Law

An individual went to a police station to report being assaulted, and officers responded to take his statement. While at the hospital, where the individual had been transported, officers observed that he was intoxicated and later placed him in custody for transport to a detoxification facility under Oregon’s civil detox statutes. The individual had a backpack with him. During an inventory of his property, an officer opened the closed, opaque backpack and discovered a butterfly knife, which led to a criminal history check and a subsequent arrest for possession of a restricted weapon.Initially, the Washington County Circuit Court denied a motion to suppress evidence from the backpack. On appeal, the Oregon Court of Appeals upheld both the seizure and the inventory search of the backpack, reasoning that, under established case law, police could open closed, opaque containers likely to contain valuables if done pursuant to a lawful inventory policy. The Court of Appeals relied heavily on its prior decisions, concluding the inventory search was permissible under the relevant county ordinance and inventory policy.The Supreme Court of the State of Oregon reviewed the case. It held that, under Article I, section 9 of the Oregon Constitution, inventory searches of closed, opaque containers that do not announce their contents are not permitted when a person is taken into custody on a civil detox hold, even if executed under a valid, non-discretionary inventory policy. The court emphasized that in the civil detox context, compliance with an inventory policy does not alone render such a search reasonable; privacy interests and the non-criminal nature of the detention require a higher level of protection. The Supreme Court of Oregon reversed the decisions of the lower courts and remanded the case for further proceedings. View "State v. Wilcox" on Justia Law

Police responded to a report of a disturbance at a man’s home, where they learned from his girlfriend that he was a convicted felon in possession of firearms. The man admitted that he knew about the firearms and had purchased two for his children. He led officers through his home, where they recovered three firearms and ammunition. The State charged him with three counts of unlawful possession of a firearm by a convicted felon.The case progressed through the Idaho courts, beginning with the magistrate court, where the man repeatedly stated he could not afford an attorney and wanted “effective assistance of counsel,” rather than representation. The magistrate court suggested he did not qualify for a public defender due to his employment, and the preliminary hearing proceeded with the defendant unrepresented, after which he was bound over to the district court. Throughout proceedings before the district court, the man continued to appear without counsel, filing many pro se motions. Eventually, after much confusion about his wishes, the district court appointed “shadow counsel” to assist him at trial, but continued to treat him as self-represented. The jury convicted him on all counts, and the district court denied his post-trial motions.The Supreme Court of the State of Idaho reviewed the case after the Idaho Court of Appeals affirmed the convictions. The Supreme Court held that the appointment of “shadow counsel” did not satisfy the Sixth Amendment right to counsel because the defendant, not an attorney, controlled and managed his defense. The Court further held that the record did not show the defendant knowingly, intelligently, and voluntarily waived his right to counsel, as required by law. As a result, the Supreme Court vacated the judgment of conviction and remanded the case for further proceedings. View "State v. Knight" on Justia Law

In this case, two police officers responded to a robbery at a car dealership and pursued the suspects on the highway. During the chase, one officer was shot multiple times by a hidden suspect, and both officers exchanged gunfire with the perpetrator, who was ultimately killed. One officer suffered serious injuries and required extensive medical care. Following the incident, a newspaper reporter requested public records from the Columbus Police Department, including body camera and dash camera footage of the shootout. The police department denied the request for unredacted video footage, citing statutory provisions that protect the privacy of crime victims, specifically Marsy's Law and related Ohio statutes.The Columbus Police Department eventually released redacted versions of the body camera footage, concealing the identities of the two officers and ending the video before the shooting. The newspaper maintained that, as public officials acting in the line of duty, the officers could not be considered "victims" under Marsy's Law and filed an original action in the Supreme Court of Ohio seeking a writ of mandamus to compel production of the unredacted footage.The Supreme Court of Ohio reviewed whether the officers were "victims" under Article I, Section 10a of the Ohio Constitution (Marsy's Law), and thus entitled to privacy protections under the Victim Privacy Law and the Public Records Act. The court held that police officers are "persons against whom crimes can be committed" and therefore qualify as victims under Marsy's Law. As a result, the statutory provisions apply, and the redaction of identifying information from the footage was proper. The court denied the newspaper's request for a writ of mandamus, holding that the newspaper was not entitled to unredacted body camera and dash camera footage identifying the officers. View "State ex rel. GateHouse Media Ohio Holdings II, Inc. v. Columbus Police Dept." on Justia Law

An attorney who chaired the Davidson County Election Commission was also employed at a law firm that represented the Metropolitan Government of Nashville and Davidson County. The Election Commission became involved in a dispute over whether a citizen-initiated tax-repeal referendum should be placed on the ballot, a measure opposed by the city government and certain city council members. The attorney, acting as commission chair, supported certifying the referendum. Following pressure from city officials, including a council member who threatened to withdraw city business from the law firm if the attorney continued supporting the referendum, the law firm terminated the attorney’s employment after he refused to change his position.The attorney filed suit in the United States District Court for the Middle District of Tennessee, asserting violations of his First Amendment rights under 42 U.S.C. § 1983, among other claims. The district court denied motions to dismiss based on qualified immunity filed by both the council member and the law firm. The court concluded that the council member’s alleged conduct violated clearly established First Amendment law and that the law firm, as a private entity, was not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit determined that both the council member and the law firm were eligible to assert qualified immunity due to their public functions in this context. The court held that the council member was not entitled to qualified immunity because the complaint plausibly alleged he violated clearly established First Amendment rights by causing the attorney’s firing due to protected speech. However, the court found that the law firm was entitled to qualified immunity, as there was no clearly established law prohibiting a law firm from firing an employee in response to client pressure under these circumstances. Accordingly, the Sixth Circuit affirmed the denial of qualified immunity for the council member, reversed as to the law firm, and remanded for further proceedings. View "DeLanis v. Metropolitan Government of Nashville" on Justia Law

Mike Dennis developed mycosis fungoides, a subtype of non-Hodgkin’s lymphoma, after regularly applying Roundup, a glyphosate-based herbicide manufactured by Monsanto, for approximately 20 years. Dennis claimed his cancer resulted from exposure to Roundup, which he alleged was sold and marketed without adequate warnings about its carcinogenic risks, despite Monsanto’s knowledge of the potential danger. He brought claims for design defect, failure to warn (under both negligence and strict liability), and negligence. At trial, the jury found that Monsanto was liable for failing to warn about the cancer risk, determining Monsanto knew or should have known of the risk, failed to provide adequate warnings, and acted with malice or oppression. The jury awarded Dennis $7 million in economic damages and $325 million in punitive damages.Following the verdict, Monsanto moved for a new trial and for judgment notwithstanding the verdict (JNOV). The Superior Court of San Diego County denied Monsanto’s requests to overturn the liability findings but reduced the punitive damages award from $325 million to $21 million, finding the original award disproportionate to the compensatory damages. Monsanto timely appealed, arguing that Dennis’s failure to warn claims were preempted by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and that the punitive damages were excessive and unconstitutional.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that FIFRA does not preempt state law failure to warn claims that parallel federal misbranding requirements, in line with United States Supreme Court precedent and California decisions. The court also found that the punitive damages award, as reduced by the trial court, did not violate due process, as it was based on highly reprehensible conduct directly related to Dennis’s harm. The Court of Appeal affirmed the judgment in full. View "Dennis v. Monsanto Co." on Justia Law

On July 30, 2022, police responded to Omar Johnson's home after a 911 call reported domestic violence. While investigating, officers discovered a loaded pistol in Johnson's moped and determined he did not possess a valid firearm license. Johnson was arrested and indicted for multiple counts of criminal weapon possession and possession of ammunition. These events occurred shortly after the U.S. Supreme Court issued its decision in New York State Rifle & Pistol Association, Inc. v. Bruen, but before New York amended its firearm licensing laws.Johnson moved to dismiss the indictment in the Supreme Court of New York County, arguing that Bruen invalidated the state's "proper cause" requirement for firearm licenses and, by extension, rendered the entire licensing scheme unconstitutional. The Supreme Court denied the motion, holding that Johnson lacked standing because he had not applied for a license and that Bruen invalidated only the "proper cause" requirement, not the entire scheme. Johnson pleaded guilty, waiving his right to appeal, and was sentenced to probation. On appeal, the Appellate Division, First Department, affirmed, concluding that the appeal waiver was valid, Johnson lacked standing, and his conviction was not unconstitutional under Bruen.The New York Court of Appeals reviewed the case. It held that Johnson’s facial constitutional challenge to the licensing scheme was not waived by his appeal waiver, as such claims implicate broader societal interests. The Court determined that Johnson had standing to raise a facial challenge, even though he never applied for a license, because his conviction directly resulted from the licensing scheme. On the merits, the Court concluded that Bruen’s invalidation of only the "proper cause" requirement did not render the entire New York firearm licensing scheme unconstitutional, as the requirement is severable. The order of the Appellate Division was affirmed. View "People v Johnson" on Justia Law

Sheryl Robertson was arrested in Custer County, Idaho, for felony possession of methamphetamine and ultimately pleaded guilty pursuant to a plea agreement. The district court sentenced her to a ten-year term, retained jurisdiction for one year, and later placed her on probation with additional requirements after she admitted to multiple probation violations. These requirements included completing 100 hours of community service and successfully participating in a treatment court program. Robertson entered the Bonneville County Wood Court but encountered issues with the program and requested transfer to a different treatment court. The State subsequently moved to terminate her participation in Wood Court and revoke her probation, alleging further rule violations.Robertson waived her right to a termination hearing in Wood Court using forms that referenced only the treatment court termination, not probation revocation. The district court proceeded directly to disposition on the alleged probation violation, reasoning that Robertson’s waiver in Wood Court extended to her right to a probation-revocation hearing. Robertson was sentenced to a modified term of incarceration, and she appealed. The Idaho Court of Appeals affirmed the district court, finding that the procedures under the Idaho Rules for Treatment Courts (I.R.T.C.) were followed and provided the required due process, but declined to address whether Robertson had received the process required by the Fourteenth Amendment as articulated in Morrissey v. Brewer.The Supreme Court of the State of Idaho reviewed the case and held that Robertson’s waiver of her right to a probation-revocation hearing was not knowing and intelligent, as required by the Due Process Clause of the Fourteenth Amendment. The forms she signed did not clearly communicate that waiving the Wood Court termination hearing also constituted a waiver of the right to a probation-revocation hearing. The Supreme Court vacated the district court’s order revoking probation and imposing a modified sentence, and remanded the case for a probation-revocation hearing. View "State v. Robertson" on Justia Law

Kevin LaMarcus Mitchell, who has a history of criminal conduct, was previously convicted of being an unlawful user of a controlled substance in possession of a firearm under 18 U.S.C. § 922(g)(3), a felony offense. Years later, during the execution of an unrelated arrest warrant, law enforcement found firearms in the room he occupied and Mitchell admitted to daily marijuana use. Based on his prior § 922(g)(3) conviction, Mitchell was indicted in the United States District Court for the Southern District of Mississippi for being a felon in possession of a firearm under § 922(g)(1).After his indictment, Mitchell moved to dismiss the charge on several constitutional grounds, including an as-applied Second Amendment challenge in light of New York State Rifle & Pistol Ass’n, Inc. v. Bruen. The district court denied his motion, after which Mitchell entered a conditional guilty plea, reserving his right to appeal the Second Amendment issue. He was sentenced to sixty-four months’ imprisonment and three years of supervised release.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial de novo. The Fifth Circuit held that, under Bruen and its own precedent, the Second Amendment’s plain text covers Mitchell’s conduct and that the only relevant predicate offense for an as-applied challenge is his prior § 922(g)(3) conviction. The court found that the government failed to identify a historical tradition justifying permanent disarmament of individuals with a predicate offense based solely on habitual marijuana use, in the absence of evidence of active intoxication while possessing a firearm. Therefore, the Fifth Circuit ruled that § 922(g)(1) is unconstitutional as applied to Mitchell’s predicate offense, reversed the district court’s denial of his motion to dismiss, and vacated the judgment of conviction and sentence. View "United States v. Mitchell" on Justia Law

A nonprofit religious organization operates several Zen Buddhist temples in California, providing residential training programs where participants, known as Work Practice Apprentices (WPAs), live and work at the temples. Participants perform various tasks, including cleaning, cooking, and guest services, as part of their Zen training. Upon completing the WPA program, individuals may become staff members, continuing similar duties while residing at the temple. The plaintiff participated as a WPA and later as a staff member, performing duties such as guest services, food preparation, and facility maintenance. She received modest monthly stipends and room and board, but ultimately challenged the compensation as inadequate under California wage-and-hour laws.After her affiliation with the organization ended, the plaintiff filed a wage claim with the Labor Commissioner, seeking unpaid regular and overtime wages, meal period premium wages, and liquidated damages. The Labor Commissioner ruled in her favor against the organization and two individual leaders, holding the individuals personally liable as employers under Labor Code section 558.1, and awarded her $149,177.15. The defendants appealed to the Superior Court of San Francisco, posting an undertaking only on behalf of the organization, not the individual defendants. The trial court denied the plaintiff’s motion to dismiss the appeals by the individuals for lack of undertakings and granted summary judgment for all defendants, finding the ministerial exception under the First Amendment barred the wage-and-hour claims.The California Court of Appeal, First Appellate District, Division Five, reversed. It held that the ministerial exception does not bar wage-and-hour claims by ministers unless such claims would require judicial inquiry into ecclesiastical matters or religious doctrine. Because there was no evidence that adjudicating the plaintiff’s wage claims would entangle the court in religious concerns, the exception did not apply. The court also held that the trial court lacked jurisdiction over the individual defendants’ appeals due to their failure to post the required undertakings. View "Lorenzo v. San Francisco Zen Center" on Justia Law