Justia Constitutional Law Opinion Summaries

Police officers investigating a recent carjacking and kidnapping at an Oklahoma City motel received information from the motel manager that a man matching the suspect’s description was staying in a particular room. Upon arrival, one officer looked through a one-inch gap in the window curtains from an open-air walkway outside the room and saw the defendant, Cameron Watkins, sitting on a bed next to a handgun with an extended magazine. This observation led to Watkins’s arrest and the subsequent discovery of a firearm and ammunition in the room. Watkins was later charged with being a felon in possession of a firearm and, in a superseding indictment, with being a felon in possession of ammunition found at a separate crime scene.The United States District Court for the Western District of Oklahoma denied Watkins’s motion to suppress the evidence, finding that the officer’s observation was made from a public area—the motel’s exterior walkway—which was accessible to other guests and staff, and not part of the room’s curtilage. The court concluded there was no Fourth Amendment violation because the officer did not intrude upon a protected area or the defendant’s reasonable expectation of privacy. Watkins pleaded guilty to the firearm charge, reserving his right to appeal the suppression ruling, and was convicted by a jury on the ammunition charge.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed both convictions. The court held that the officer’s visual observation through the window gap, made from a public walkway using only his unaided senses, did not constitute a search under the Fourth Amendment. The walkway was not curtilage, and the defendant did not have a reasonable expectation of privacy against such observation. The court therefore upheld the district court’s denial of the suppression motion and affirmed the convictions. View "United States v. Watkins" on Justia Law

An inmate in Missouri, facing imminent execution, requested that his two daughters—both ordained ministers—be allowed to serve as his spiritual advisors in the execution chamber. One daughter would administer communion and anoint him with oil, then move to the viewing area, while the other would enter the chamber to pray over and touch him during the execution. The Missouri Department of Corrections denied this request, citing security concerns, but offered alternatives: a non-relative spiritual advisor, prison clergy, or his attorney could perform the rituals, with his daughters directing the proceedings from behind glass.After exhausting administrative remedies and just five days before his scheduled execution, the inmate filed suit in the United States District Court for the Eastern District of Missouri. He alleged that the Department’s refusal violated his rights under the First Amendment’s Free Exercise Clause and the Religious Land Use and Institutionalized Persons Act (RLUIPA). He sought a preliminary injunction and a stay of execution. The district court denied his requests and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of a stay of execution. The court focused on whether the inmate had shown a likelihood of success on the merits, specifically whether the Department’s policy imposed a “substantial burden” on his religious exercise under RLUIPA. The court found that, while the inmate preferred his daughters as spiritual advisors, he did not demonstrate that only they could perform the rituals in accordance with his beliefs. The court concluded that the Department’s alternatives did not significantly inhibit his religious exercise and that security concerns justified the restriction. The Eighth Circuit denied the motion for a stay of execution. View "Shockley v. Adams" on Justia Law

A longtime Alaska resident with extensive experience in personal-use and commercial fishing brought suit against the State of Alaska, alleging that the State’s management of chinook and chum salmon populations in the Yukon and Kuskokwim Rivers violated the sustained yield principle mandated by the Alaska Constitution. The plaintiff claimed that the significant decline in these salmon populations since statehood was evidence of unconstitutional management. He did not challenge any specific policy, regulation, or action, but instead sought a declaration that the State’s management had been unconstitutional for decades and requested injunctive relief to compel the State to fulfill its sustained yield obligations.The Superior Court for the Fourth Judicial District, Bethel, granted the State’s motion to dismiss for failure to state a claim. The court found that the claims presented nonjusticiable political questions reserved for the legislative branch, that the plaintiff failed to allege a concrete injury or identify specific State actions causing harm, and that deference to agency expertise was warranted in the absence of a challenge to a particular policy or action.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s dismissal. The Supreme Court held that the claims for injunctive relief were nonjusticiable because they would require the judiciary to make initial fisheries policy determinations, a function constitutionally committed to the legislative and executive branches. The Court further held that the claim for declaratory relief was not justiciable because it would not clarify or settle the legal relations between the parties, as it did not identify specific actions or policies to be addressed. The Court concluded that, absent a challenge to a particular State action or policy, the claims did not present an actual controversy suitable for judicial resolution. View "Forrer v. State of Alaska" on Justia Law

Several months before an election, complaints were filed with the Alaska Public Offices Commission alleging that two political groups, A Stronger Alaska and the Republican Governors Association, had violated Alaska’s campaign finance laws by coordinating with a gubernatorial campaign and failing to comply with disclosure requirements. The Commission initiated expedited proceedings, held hearings where officials from the groups testified, and then chose not to make a final determination on the alleged violations. Instead, the Commission remanded the matters to its staff for further investigation on a regular, non-expedited basis. The Commission’s staff subsequently issued administrative subpoenas seeking documents and communications from the groups, but the groups refused to comply.The Commission sought judicial enforcement of its subpoenas in the Superior Court for the State of Alaska, Third Judicial District. The groups opposed enforcement, arguing that the subpoenas were unnecessary because the Commission already had relevant testimony, that further investigation was barred by res judicata, and that the process violated their due process rights. They also challenged the constitutionality of the statutory scheme authorizing the expedited process. The superior court rejected all of these arguments, granted summary judgment in favor of the Commission, and ordered enforcement of the subpoenas.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s decision. The court held that the subpoenas were not unreasonable or oppressive simply because prior testimony had been given, as documentary evidence could still be relevant. The court also held that res judicata did not apply because the Commission had not issued a final decision on the merits, and that the process did not violate substantive due process or result in an absurd or unconstitutional statutory scheme. The court affirmed the order granting summary judgment to the Commission. View "Republican Governors Association v. Hebdon" on Justia Law

A sheriff’s deputy in Geary County, Kansas, stopped a vehicle driven by Brian Beck after observing that a license plate frame partially obscured the state name on the plate. Beck was not committing any driving infractions. During the stop, Beck appeared nervous and gave an unusual explanation for his travel route. A canine unit was called, and after the dog alerted, Beck consented to a search of his car, which led to the discovery of over two pounds of methamphetamine. Beck was charged with possession with intent to distribute, possession without a drug tax stamp, and interference with law enforcement. He moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion, but the Geary District Court denied the motion. At trial, Beck renewed his objection, which was again overruled, and a jury convicted him on all counts.On appeal, the Kansas Court of Appeals affirmed the convictions, holding that the partial obstruction of the state name justified the stop under Kansas law, specifically K.S.A. 8-133, which requires license plates to be “clearly visible” and “clearly legible.” The appellate panel reasoned that covering half of the state name violated the statute, regardless of whether the plate could otherwise be identified.The Supreme Court of the State of Kansas reviewed only the statutory interpretation issue. It held that Kansas law does not require the state name to be clearly legible on license plates, except as it appears on registration decals. The court found that the lower courts had misapplied the statute by treating the obscured state name as a violation. The Supreme Court reversed the decisions of both the district court and the Court of Appeals on this issue and remanded the case for further proceedings consistent with its interpretation of the statute. View "State v. Beck " on Justia Law

The defendant was originally sentenced in 2005 to a 10-year prison term for assault with a deadly weapon, with additional time added for inflicting great bodily injury, personal use of a weapon, and three prior prison commitments. Nearly two decades later, the defendant sought recall and resentencing under Penal Code section 1172.75, which invalidates certain prior prison term enhancements. However, by this time, the defendant was no longer serving the original sentence that included the enhancements; instead, he was incarcerated for offenses committed while in prison, with those sentences running consecutively to the original term.After the California Department of Corrections and Rehabilitation identified the defendant as potentially eligible for relief, the Superior Court of Riverside County examined whether he qualified under section 1172.75. The court found, based on the defendant’s record, that he had completed the sentence containing the prior prison term enhancements and was now serving time solely for in-prison offenses. Relying on People v. Escobedo, the court concluded that section 1172.75 only applies to individuals currently serving a sentence that includes the now-invalidated enhancements, and not to those serving subsequent, separate sentences for in-prison offenses. The court also rejected the defendant’s equal protection argument, finding a rational basis for the legislative distinction.The California Court of Appeal, Fourth Appellate District, Division Two, affirmed the lower court’s decision. The appellate court held that eligibility for resentencing under section 1172.75 is limited to defendants currently serving a sentence that includes a prior prison term enhancement. Because the defendant was serving a sentence for in-prison offenses, not the original judgment with the enhancements, he was ineligible for relief. The court also found no equal protection violation in the statutory scheme. View "People v. McKean" on Justia Law

Three siblings, all under the age of 14, lived with their father across the street from the defendant between 2015 and 2017. During this period, the children frequently played with the defendant’s children. In 2021, after moving in with a legal guardian due to their father’s poor health and subsequent death, the siblings disclosed that the defendant had repeatedly sexually abused them over a prolonged period. The abuse included acts of sexual intercourse, sodomy, and oral copulation, often accompanied by threats involving firearms. The defendant was charged with multiple counts of continuous sexual abuse of a child, sexual intercourse or sodomy with a child 10 years of age or younger, and oral copulation or sexual penetration with a child 10 years of age or younger.A jury in the Lake County Superior Court found the defendant guilty on all nine counts and found true the multiple-victim allegation. The defendant was sentenced to 75 years to life in prison, with sentences on the remaining counts stayed. On appeal to the California Court of Appeal, First Appellate District, Division Three, the defendant argued that Penal Code section 288.5 was unconstitutional under the Sixth Amendment’s jury unanimity requirement as interpreted in Ramos v. Louisiana, and also challenged the jury instructions regarding unanimity.The California Court of Appeal, First Appellate District, Division Three, held that section 288.5 does not violate the Sixth Amendment’s jury unanimity requirement. The court reasoned that the statute requires unanimity as to the continuous-course-of-conduct element, even if jurors may disagree on the specific acts constituting that conduct. The court also found the jury instruction claim forfeited, as the instructions given were accurate and did not affect the defendant’s substantial rights. The judgment was affirmed. View "People v. Hill" on Justia Law

In 2009, a defendant was sentenced to an indeterminate term of 28 years to life under California’s original Three Strikes law after his third felony conviction, which was not classified as serious or violent. He also received three one-year enhancements for prior prison terms. In 2012, California voters passed the Three Strikes Reform Act (Proposition 36), which limited indeterminate life sentences to cases where the third strike was serious or violent, and allowed those serving indeterminate sentences for nonserious, nonviolent felonies to petition for resentencing, subject to a discretionary public safety determination by the court.After the Reform Act, the defendant petitioned for resentencing under section 1170.126, but the Santa Barbara County Superior Court denied the petition, finding his release would pose an unreasonable risk to public safety. The California Court of Appeal affirmed this decision. In 2021, the Legislature enacted Senate Bill No. 483, which retroactively invalidated certain prior prison term enhancements and required courts to recall and resentence affected defendants, applying any changes in law that reduce sentences. The defendant sought resentencing under this new law, and the trial court resentenced him to a determinate eight-year term. The Santa Barbara District Attorney challenged this, arguing that the new law unconstitutionally amended the voter-enacted Reform Act by bypassing its public safety requirement. The Court of Appeal agreed and reversed the trial court’s decision.The Supreme Court of California reviewed whether Penal Code section 1172.75, as applied, unconstitutionally amended the Reform Act. The Court held that section 1172.75 must be interpreted to incorporate the Reform Act’s discretionary public safety determination for nonserious, nonviolent third strike offenders seeking resentencing. This interpretation harmonizes the statutes and avoids constitutional conflict, allowing the revised penalty provisions to apply only if the court finds resentencing does not pose an unreasonable risk to public safety. The Court reversed the Court of Appeal and remanded for further proceedings consistent with this holding. View "P. v. Guevara" on Justia Law

The defendant was charged with murder and contributing to the delinquency of a minor after allegedly killing his wife in their home while their two young children were present. Before trial, the prosecution requested that the children be allowed to testify remotely, arguing that testifying in the defendant’s presence would cause them significant emotional distress and impair their ability to communicate. The district court held hearings, received testimony from mental health professionals who had treated the children, and ultimately granted the State’s motion, finding that remote testimony was necessary to prevent serious emotional trauma to the children.The District Court of Cass County, East Central Judicial District, presided over the case. The defendant pleaded guilty to the charge of contributing to the deprivation of a minor, and the murder charge proceeded to trial. The court instructed the jury that the children’s remote testimony was permissible by law and should not influence their deliberations. The children testified via two-way electronic communication, and the jury found the defendant guilty of murder. The court entered a judgment sentencing him to life imprisonment without parole. The defendant appealed, arguing that the district court failed to make the findings required by statute for remote testimony and that his constitutional right to confront witnesses was violated.The Supreme Court of North Dakota reviewed the case. It held that the district court made the necessary findings under North Dakota Century Code § 31-04-04.2(1), specifically that testifying in the defendant’s presence would likely cause the children serious emotional distress or trauma impacting their ability to communicate. The Supreme Court found these findings were supported by the evidence and not contrary to the manifest weight of the evidence. The court concluded that the defendant’s confrontation rights were not violated and affirmed the criminal judgment. View "State v. Moen" on Justia Law

A billboard company sought to erect a sign in a Michigan township, but its application was denied because the proposed billboard did not comply with local height and size restrictions. Instead of appealing the denial or seeking a variance, the company filed a federal lawsuit challenging the township’s sign ordinance on First Amendment grounds, including claims that the ordinance imposed content-based restrictions, constituted an unconstitutional prior restraint, and was unconstitutionally vague. The company did not challenge the height and size restrictions themselves. The township’s ordinance only allowed billboards in certain industrial zones adjacent to interstate freeways, but, according to the company, no such zones existed in the township.The United States District Court for the Eastern District of Michigan granted summary judgment to the township, finding the company lacked standing because its alleged injuries were not caused by the challenged provisions and would not be redressed by a favorable decision. The United States Court of Appeals for the Sixth Circuit affirmed, holding that the company failed to meet the requirements for standing on any of its claims.Subsequently, the company filed a new lawsuit in the same district court, again alleging that the ordinance was a prior restraint on speech. The district court dismissed the suit, holding that res judicata (claim preclusion) barred the action. On appeal, the United States Court of Appeals for the Sixth Circuit held that issue preclusion, not claim preclusion, applied. The court concluded that issue preclusion barred the company from relitigating its prior-restraint claim based on its earlier application, but did not bar claims based on new facts—specifically, the company’s allegation that it was self-censoring and not applying for any billboards due to the ordinance’s discretionary variance process. The Sixth Circuit affirmed in part, vacated in part, and remanded for further proceedings on the new factual allegations. View "Outdoor One Communications LLC v. Charter Twp. of Canton, Mich." on Justia Law