Justia Constitutional Law Opinion Summaries

In this case, the defendant applied for U.S. citizenship in 2011 and, on his application and during an interview, denied ever having committed a crime for which he was not arrested. However, in 2013, he pleaded guilty in North Carolina state court to attempted statutory rape for conduct that occurred in 2008, admitting to engaging in a sexual act with a minor. He did not disclose this conduct on his naturalization application. Years later, a federal grand jury indicted him for naturalization fraud, alleging he knowingly concealed his criminal history to obtain citizenship.The United States District Court for the Western District of North Carolina denied the defendant’s motion to dismiss the indictment for unconstitutional preindictment delay, finding he had not shown actual prejudice from the delay. The court also denied his motion to suppress evidence of his state guilty plea, ruling that he could not collaterally attack the validity of his state conviction in federal court except for a deprivation of counsel, which did not apply here. At trial, the court limited the testimony of the defendant’s expert witness regarding his cognitive abilities, excluding certain opinions about his capacity to understand the application question. The jury convicted the defendant, finding he knowingly made a false statement, and the court sentenced him to six months in prison and revoked his citizenship.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit held that the defendant failed to demonstrate substantial actual prejudice from the preindictment delay, that the district court properly refused to suppress the state guilty plea, and that while the limitation of the expert’s testimony was error under recent Supreme Court guidance, the error was harmless given the other evidence presented. The conviction and sentence were therefore affirmed. View "US v. Palmer" on Justia Law

Drexel Starks was arrested for possession of a controlled substance and taken to the St. Louis County Justice Center, where he reported heroin withdrawal symptoms. Jail medical staff placed him on a withdrawal protocol, which included comfort medication and regular nurse assessments. Over the next day, nurses noted some improvement in his symptoms. However, there is no evidence of further assessments as required by protocol. On August 6, a correctional officer found Drexel on the floor with withdrawal symptoms; he was transferred to the infirmary and then to a hospital, where he died. The medical examiner attributed his death to withdrawal from heroin and cocaine, dehydration, and cardiac dysrhythmia.Margaret Starks, Drexel’s mother, filed suit in the United States District Court for the Eastern District of Missouri under 42 U.S.C. § 1983, alleging that jail nurses and a correctional officer were deliberately indifferent to Drexel’s serious medical needs, and that nurse supervisors and St. Louis County failed to train or supervise staff and maintained an unlawful policy of denying medical care. The district court granted summary judgment for the defendants, finding that Margaret failed to establish a violation of Drexel’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that no reasonable jury could find Drexel had an objectively serious medical need that was obvious to a layperson or supported by medical evidence, nor that the defendants acted with deliberate indifference akin to criminal recklessness. The court also held that, absent an underlying constitutional violation, claims against the nurse supervisors and the County for failure to train or supervise, or for unlawful policy, could not succeed. The judgment of the district court was affirmed. View "Starks v. St. Louis County" on Justia Law

In April 2019, a man and his girlfriend, along with her children, were living in an apartment in DeKalb County, Georgia. After being told to move out by the apartment’s primary resident, the man became angry and assaulted his girlfriend in the presence of her child, inflicting multiple injuries including choking, hitting, and stomping. He later transported her, with the help of his daughter, to another apartment in Fulton County, where further violence occurred. The girlfriend was eventually taken to a hospital and pronounced dead. Medical evidence showed she suffered extensive internal and external injuries, including blunt force trauma and strangulation, which were determined to be the cause of death.A DeKalb County grand jury indicted the man for malice murder and related offenses. At trial in the Superior Court of DeKalb County, the jury found him guilty on all counts. He was sentenced to life imprisonment without parole for malice murder, with the other counts vacated or merged. The defendant filed a motion for a new trial, which was denied, and then appealed.The Supreme Court of Georgia reviewed the case. The court held that the evidence was sufficient to support the conviction for malice murder and to establish venue in DeKalb County, as the fatal injuries were inflicted there. The court also rejected the defendant’s challenges to the constitutionality of the venue statute and related jury instruction, finding no conflict with state or federal constitutional requirements. Finally, the court found the defendant’s arguments regarding the proportionality and constitutionality of his sentence to be factually unsupported or abandoned. The Supreme Court of Georgia affirmed the conviction and sentence. View "TAYLOR v. THE STATE" on Justia Law

Residents of Jackson, Mississippi, brought a class action lawsuit alleging that the city knowingly contaminated their drinking water with lead, failed to treat the water to prevent lead leaching, and misled the public about the water’s safety. The complaint details how city officials ignored warnings about the water system’s vulnerabilities, failed to repair critical treatment equipment, switched water sources in a way that worsened contamination, and delayed notifying residents of dangerous lead levels. Plaintiffs claim they and their families suffered significant health effects, including lead poisoning and related medical and developmental issues, as a result of consuming the contaminated water.The United States District Court for the Southern District of Mississippi granted the defendants’ motion for judgment on the pleadings. The court found that the plaintiffs failed to state a substantive due process claim against the city and that the individual city officials were entitled to qualified immunity. The district court also declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The Fifth Circuit held that the plaintiffs plausibly alleged a violation of their Fourteenth Amendment right to bodily integrity by claiming the city affirmatively introduced toxins into the water supply, misrepresented the water’s safety, and thereby deprived residents of the ability to make informed decisions about their health. The court also formally adopted the state-created danger doctrine as a viable theory in the circuit. The court reversed the dismissal of the due process claims against the city and vacated the dismissal of the state-law claims, remanding for further proceedings. However, the court affirmed the dismissal of claims against the individual city officials on qualified immunity grounds, finding the relevant rights were not clearly established at the time. View "Sterling v. City of Jackson" on Justia Law

The case concerns a man who, along with his wife, adopted two young girls through the foster care system. Years later, when one of the girls was nearly 17, she disclosed to a friend’s mother that she had been sexually abused by her adoptive father over several years. This disclosure led to a law enforcement investigation, during which the defendant voluntarily went to the sheriff’s department to “turn himself in.” He was subsequently interrogated by two officers in a closed interview room at the station. During the third segment of questioning, after persistent and increasingly accusatory interrogation techniques, the defendant confessed to engaging in sexual acts with one of the victims.The Superior Court of San Bernardino County heard pretrial motions regarding the admissibility of the defendant’s statements to law enforcement. The prosecution sought to admit the statements, while the defense moved to suppress them, arguing they were obtained in violation of the defendant’s constitutional rights. The trial court ruled the interrogation was not custodial and admitted the statements. At trial, the prosecution presented testimony from the victims and law enforcement, while the defense highlighted inconsistencies and lack of physical evidence. The jury found the defendant guilty on all counts, and he was sentenced to over 120 years to life in prison.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, reviewed whether the defendant’s confession should have been suppressed under Miranda v. Arizona. The appellate court held that while the initial questioning was noncustodial, the interrogation became custodial during the third segment, at which point Miranda warnings were required but not given. The court found the admission of the confession was prejudicial and not harmless beyond a reasonable doubt. Accordingly, the judgment was reversed and the case remanded for further proceedings. View "People v. NavaAdame" on Justia Law

The petitioner, a native and citizen of Mexico, entered the United States unlawfully several decades ago. In 2017, the Department of Homeland Security initiated removal proceedings against him, alleging that he was inadmissible under the Immigration and Nationality Act due to his illegal entry. The petitioner admitted the allegations and sought cancellation of removal, arguing that he met the statutory requirements, including continuous residence and good moral character for the preceding ten years. He also requested voluntary departure as an alternative form of relief.The Immigration Judge (IJ) denied the application for cancellation of removal, finding that the petitioner had not demonstrated good moral character for the required ten-year period. The IJ acknowledged positive evidence regarding the petitioner’s family and work history but emphasized his history of alcohol abuse and criminal conduct, specifically noting a 2017 DUI conviction that was his fourth such offense, with the previous three occurring in 1995 and 1996. The IJ concluded that the 2017 conviction was not an isolated incident but part of a pattern of recidivist behavior. The IJ granted voluntary departure. The petitioner appealed to the Board of Immigration Appeals (BIA), which dismissed the appeal, agreeing with the IJ that the 2017 DUI conviction reflected recidivism and outweighed positive equities. The BIA also rejected the petitioner’s due process claim.The United States Court of Appeals for the Tenth Circuit reviewed the BIA’s decision de novo, focusing on whether the BIA improperly considered DUI convictions outside the ten-year statutory period for good moral character. The court held that the BIA properly considered the recidivist nature of the petitioner’s 2017 DUI conviction, even though the earlier convictions occurred outside the statutory period, because recidivism aggravates the seriousness of the most recent offense. The court denied the petition for review. View "Luna-Corona v. Bondi" on Justia Law

Robert Hutton secretly installed a hidden camera in the bathroom of his home and, over the course of about a year, recorded several nude videos and images of his 14-year-old stepdaughter without her knowledge. He edited some of the footage to focus on moments when the victim was visibly nude. The victim discovered the existence of these files after seeing a suspicious file name on Hutton’s phone and subsequently reported the matter to the police. A search of Hutton’s residence uncovered additional child pornography, including images of other minors.The United States District Court for the Eastern District of Washington presided over a bench trial based on stipulated facts. Hutton was charged with sexually exploiting a minor under 18 U.S.C. § 2251(a). He moved for a judgment of acquittal, arguing that the images were not “lascivious,” that the statute was unconstitutionally vague as applied, and that he did not “use” the victim within the meaning of the statute. The district court denied these motions, found Hutton guilty, and sentenced him to 20 years’ imprisonment.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed Hutton’s arguments de novo where appropriate and for clear error regarding factual findings. The court held that existing Ninth Circuit precedent foreclosed Hutton’s arguments on all grounds. Specifically, the court found that the district court did not clearly err in determining the images were “lascivious” under the Dost factors, that § 2251(a) is not unconstitutionally vague as applied, and that Hutton’s conduct constituted “use” of a minor under the statute. The court also held that the Supreme Court’s decision in Dubin v. United States, which interpreted the term “use” in a different statutory context, did not undermine the Ninth Circuit’s precedent regarding § 2251(a). The Ninth Circuit affirmed the conviction. View "USA V. HUTTON" on Justia Law

Adam Gomez was charged with receiving and possessing a firearm that had an obliterated serial number. He moved to dismiss the indictment, arguing that the statute under which he was charged, 18 U.S.C. § 922(k), was unconstitutional. After the United States District Court for the Northern District of New York denied his motion, Gomez pleaded guilty to the offense. His appeal centers on the claim that the statute is facially unconstitutional in light of the Supreme Court’s decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, which clarified the scope of the Second Amendment.The United States District Court for the Northern District of New York denied Gomez’s motion to dismiss the indictment, rejecting his constitutional challenge to § 922(k). Following this denial, Gomez entered a guilty plea and was convicted. He then appealed the judgment, arguing that the statute violates the Second Amendment as interpreted by the Supreme Court in Bruen.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s judgment. The Second Circuit held that 18 U.S.C. § 922(k) is facially constitutional. The court reasoned that the statute does not infringe upon the right to bear arms because it does not prevent anyone from possessing any type of firearm, and firearms with obliterated serial numbers are not weapons in common use for lawful purposes. The court also noted that Gomez’s facial challenge failed because he did not demonstrate that the statute is unconstitutional in all its applications or that it lacks a plainly legitimate sweep. Accordingly, the Second Circuit affirmed the conviction. View "United States v. Gomez" on Justia Law

Several landowners in Walton County, Florida, owned beachfront properties that were affected by a county ordinance enacted during the early stages of the COVID-19 pandemic. In March and April 2020, the county first closed public beaches, then issued a new ordinance that closed all beaches—public and private—making it a criminal offense for anyone, including private owners, to access or use their own beachfront property. The ordinance was enforced by law enforcement officers who entered private property, excluded owners, and threatened arrest for violations. The ordinance remained in effect for about a month, after which it expired and was not renewed.The landowners filed suit in the United States District Court for the Northern District of Florida, raising several claims, including a Takings Clause claim under the Fifth Amendment, and seeking both damages and prospective relief. The district court dismissed the claims for prospective relief as moot, finding the ordinance had expired and was unlikely to recur. On the merits, the district court granted summary judgment to the county on all damages claims, holding that the ordinance was not a per se physical taking but rather a use restriction, and that the government’s actions during a public health emergency were entitled to deference.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the dismissal of the claims for prospective relief, agreeing that the ordinance’s expiration rendered those claims moot. However, the court reversed the district court’s judgment on the Takings Clause claim, holding that the ordinance constituted a per se physical taking because it barred owners from their property and allowed government officials to physically occupy and control access. The court remanded for a determination of just compensation, holding that no public emergency, including COVID-19, creates an exception to the Takings Clause. View "Alford v. Walton County" on Justia Law

A group of nonprofit associations representing non-residential property owners in New Castle County, Delaware, challenged a temporary state law enacted in response to a recent county-wide property reassessment. The reassessment, ordered by the Delaware Court of Chancery in a prior case, updated decades-old property valuations to reflect current fair market values, resulting in significant tax increases for many residential homeowners and shifting the overall tax burden toward residential properties. In reaction to public outcry, the Delaware General Assembly passed House Bill 242 (HB242), which authorized school districts in New Castle County to implement a one-year split-rate property tax system for the 2025-2026 tax year, imposing higher rates on non-residential properties and lower rates on residential ones.After the reassessment, school boards set new tax rates and issued tax warrants, and the County mailed revised tax bills. The plaintiffs filed suit in the Delaware Court of Chancery against the State, county officials, and school boards, arguing that HB242 and its implementation were unconstitutional and violated state law on several grounds, including the Uniformity Clause of the Delaware Constitution, statutory requirements for tax referenda, fair market value assessment, due process, and HB242’s own revenue neutrality provision.The Court of Chancery reviewed the plaintiffs’ constitutional and statutory claims. It held that HB242’s temporary split-rate system did not violate the Uniformity Clause, as reasonable classification between residential and non-residential properties is permitted. The court found that HB242 did not constitute a retroactive personal income tax, nor did it violate due process, given the availability of post-deprivation remedies for property reclassification. Statutory claims regarding referenda, fair market value, and revenue neutrality were also rejected, as HB242’s specific provisions and timing superseded general statutory requirements. Judgment was entered for the defendants on all counts. View "Newark Property Association v. State" on Justia Law