Justia Constitutional Law Opinion Summaries

After an adult son sent text messages threatening a mass shooting at a local high school and referenced access to thousands of rounds of ammunition, the city police investigated the home he shared with his father. The father owned multiple firearms and large quantities of ammunition. Evidence showed the son had a history of mental health crises, including involuntary holds, and was subject to a lifetime ban from possessing firearms. Despite this prohibition, the son had access to firearms through his father, participated in shooting competitions, and had knowledge of how to access gun safes in the home. The father failed to turn in all firearms and ammunition as required by a temporary restraining order, and some safes were not adequately secured.The Superior Court of Orange County held an evidentiary hearing, where both the father and a police investigator testified. The trial court found, by clear and convincing evidence, that the father’s failure to adequately secure his firearms and ammunition, combined with his son’s mental health history and credible threat of mass violence, posed a significant danger to others. The court concluded the father’s conduct enabled his son’s access to firearms and found no adequate, less restrictive alternatives to a Gun Violence Restraining Order (GVRO). A three-year GVRO was issued against the father.The Court of Appeal of the State of California, Fourth Appellate District, Division Three, reviewed the case. It held that substantial evidence supported the trial court’s findings and that the GVRO statute was not unconstitutionally vague or overbroad. The court concluded the trial court reasonably interpreted statutory causation and properly considered alternatives. The father’s Second Amendment and hearsay objections were deemed forfeited for not being raised below. The appellate court affirmed the trial court’s order granting the GVRO. View "Anaheim Police Dept. v. Crockett" on Justia Law

The plaintiff, an inmate in an Arkansas correctional facility, was placed in isolation for approximately six weeks during the summer, in a cell lacking air conditioning. He claimed that, as a dialysis patient subject to fluid restrictions, exposure to excessive heat caused him significant discomfort and posed a risk to his health. Throughout his confinement, he submitted several grievances to prison officials, asserting that his medical condition required air-conditioned housing. Although medical staff and other personnel were consulted, no documented medical restriction indicated that air conditioning was medically necessary for him, and prison officials relied on a physician’s opinion that his situation did not constitute an emergency.After discovery, the plaintiff brought a civil rights action under 42 U.S.C. § 1983 against three prison officials, alleging cruel and unusual punishment in violation of the Eighth and Fourteenth Amendments. The United States District Court for the Western District of Arkansas granted summary judgment in favor of the defendants, finding them entitled to qualified immunity. The plaintiff’s motion for reconsideration was denied.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court assumed, for purposes of analysis, that the plaintiff’s medical condition presented an objectively serious risk. However, the court concluded that the record lacked evidence of deliberate indifference by the defendants: they consulted medical professionals, responded to grievances, implemented measures to mitigate heat, and treated the plaintiff’s medical complaints. Because the defendants did not violate a clearly established constitutional right, they were entitled to qualified immunity. The Eighth Circuit affirmed the district court’s judgment, holding that the prison officials were not deliberately indifferent to the plaintiff’s serious medical needs and did not subject him to cruel and unusual punishment. View "Hamilton v. Earl" on Justia Law

After being stopped by police while driving with his teenage daughter as a passenger, the defendant admitted to consuming alcohol and marijuana. He failed several field sobriety tests, and a drug recognition expert concluded that he was impaired by the combination of alcohol and cannabis, rendering him unable to safely operate the vehicle. The prosecution presented an indictment to the grand jury for aggravated driving while ability impaired by a combination of drugs and alcohol, with a child in the vehicle, as defined in the Vehicle and Traffic Law.The Monroe County Court granted the defendant’s request to use the impairment standard from People v Caden N., which equated impairment from drugs or drugs and alcohol with the higher threshold for intoxication. Since the grand jury had not been instructed under this standard, the County Court dismissed the primary count of the indictment. The Appellate Division, Fourth Department, reversed and reinstated the charge, holding that the Cruz definition of impairment should apply consistently to all subdivisions of the statute, including those involving drugs or a combination of drugs and alcohol. The court reasoned that the statutory text and legislative history supported a single definition of “impaired,” distinct from “intoxicated,” and rejected the rationale of Caden N.The New York Court of Appeals reviewed the case. It held that the term “impaired” in Vehicle and Traffic Law § 1192 should be defined as affecting a driver’s abilities “to any extent,” consistent with the standard established in People v Cruz, regardless of whether the impairment stems from alcohol, drugs, or their combination. The Court affirmed the Appellate Division’s order, rejecting the Caden N. approach and confirming that “impaired” has a uniform meaning throughout the statute. View "People v Dondorfer" on Justia Law

Benjamin Francis was killed on May 10, 2023, after being shot five times on a sidewalk in Norcross, Georgia. Willie Lee Jones, who uses a wheelchair, was indicted for multiple offenses, including malice murder, felony murder, aggravated assault, and firearm possession. Surveillance footage showed Francis attacking Jones at a convenience store minutes before the shooting, attempting to steal from him with a utility knife. Later, Jones confronted Francis with a pistol, resulting in Francis being shot as he attempted to walk away and then returned toward Jones.A Gwinnett County grand jury indicted Jones for several charges. Jones was tried alone in the Superior Court of Gwinnett County. The jury acquitted him of malice murder but convicted him of felony murder based on aggravated assault and possession of a firearm during the commission of a felony. The trial court sentenced Jones to life imprisonment for felony murder and five consecutive years for the firearm charge. Other guilty verdicts were vacated or merged. Jones timely filed a motion for new trial, which was denied by the Superior Court, and then appealed.The Supreme Court of Georgia reviewed Jones’s claim that the evidence was constitutionally insufficient to support his convictions, arguing self-defense. Utilizing the standard from Jackson v. Virginia, the Court viewed the evidence in the light most favorable to the verdict. The Court held that the evidence authorized the jury to find that Jones did not reasonably believe deadly force was necessary, as Francis was not an imminent threat when shot. The jury was entitled to reject Jones’s claim of self-defense. The Supreme Court of Georgia affirmed the trial court’s judgment. View "JONES v. THE STATE" on Justia Law

Maria Owens was accused of causing the death of eleven-month-old Jaylen Kelly in 2011, after Jaylen’s parents left him in her care. Jaylen was healthy that morning, but by midday, Owens reported he was having trouble breathing. Emergency personnel transported him to the hospital, where he died. Medical evidence showed Jaylen suffered fatal blunt-force trauma to the torso, likely inflicted intentionally. Owens admitted to “patting” Jaylen on the back but claimed she may have exacerbated a preexisting injury. Expert testimony generally agreed the injury was caused intentionally and would have left Jaylen unable to walk.After her first trial, Owens was acquitted of malice murder but convicted of felony murder, involuntary manslaughter, aggravated assault, and first-degree child cruelty. The trial court sentenced her for involuntary manslaughter and purported to merge the other counts. On appeal, the Supreme Court of Georgia determined the verdicts for crimes with different mental states (intent and negligence) could be mutually exclusive, vacated all convictions, and remanded for a new trial. Subsequently, the Court overruled this mutual exclusivity precedent in Springer v. State, holding that verdicts for both intent and negligence crimes arising from the same act are not categorically mutually exclusive.At Owens’s 2020 retrial, the trial court instructed the jury that it could not convict her of both involuntary manslaughter and intent crimes, contrary to the Supreme Court’s revised doctrine. The jury convicted Owens of felony murder and child cruelty. Reviewing the case, the Supreme Court of Georgia held that the trial court’s instruction was erroneous and harmful as to the homicide charges, warranting reversal of the felony murder conviction. Owens may be retried for felony murder because the evidence was constitutionally sufficient. The conviction for child cruelty stands, but the sentence is vacated pending further proceedings. View "OWENS v. THE STATE" on Justia Law

Lucid Group USA, Inc., a company that sells new electric vehicles directly to consumers in other states, sought to open a retail location in Georgia. To do so, it applied for a dealer license from the Georgia Department of Revenue, which is required to sell new motor vehicles in the state. The Department denied Lucid’s application, citing Georgia’s Motor Vehicle Franchise Practices Act provisions that generally prohibit manufacturers and their affiliates from selling new motor vehicles directly to consumers or owning dealerships, thereby requiring sales to go through independent franchised dealers.Following the denial, Lucid filed suit against the State of Georgia, arguing that as applied to Lucid, these statutory provisions violate several sections of the Georgia Constitution, including the Due Process Clause, the Equal Protection Clause, and Article III, Section VI, Paragraph IV. Lucid also sought an injunction against enforcement of the law. The Superior Court permitted the Georgia Automobile Dealers Association to intervene and dismissed Lucid’s complaint. The court found Lucid’s due process and equal protection claims barred by Article III, Section VI, Paragraph II(c), which authorizes the legislature to regulate the motor vehicle industry “notwithstanding” those constitutional protections. The trial court also concluded Lucid had not stated a valid claim under Paragraph IV, reasoning the law was a general law with uniform operation.The Supreme Court of Georgia reviewed the case. It held that Paragraph II(c) does not bar all due process and equal protection challenges, but only those regulations enacted for the purpose of preventing frauds, unfair business practices, unfair methods of competition, impositions, or other abuses upon Georgia’s citizens. The Court vacated the trial court’s dismissal of Lucid’s due process and equal protection claims and remanded for further consideration. The Court affirmed in part and vacated in part the dismissal of Lucid’s Paragraph IV claims, specifically remanding for further proceedings regarding Lucid’s challenge to the 2015 statutory amendment. View "LUCID GROUP USA, INC. v. STATE OF GEORGIA" on Justia Law

The case involves a man who was convicted of first-degree murder in Broward County, Florida, after a fatal shooting during a domestic dispute with his girlfriend. The key evidence during trial was a confession obtained by police after the man initially invoked his right to counsel but later agreed to speak with detectives. This confession was not admitted as direct evidence at his second trial but was used extensively to impeach his testimony when he took the stand in his own defense. The prosecution also presented substantial physical and eyewitness evidence, including the testimony of two individuals present at the scene and expert forensic analysis.After his conviction, the defendant challenged the use of his statement in postconviction proceedings. The Florida trial court denied his motion for a new trial, and the Florida Fourth District Court of Appeal affirmed. The defendant later argued in a state postconviction proceeding that his trial counsel was ineffective for failing to challenge the statement on the grounds that it was coerced, in violation of the Due Process Clause. The state postconviction court, adopting the State’s response, found that the defendant was not prejudiced by any alleged error of his counsel, as the other evidence against him was overwhelming. The Fourth DCA affirmed without opinion.The United States Court of Appeals for the Eleventh Circuit reviewed the denial of federal habeas corpus relief. The court held that the state court had adjudicated the prejudice prong of the ineffective assistance claim on the merits, entitling its decision to deference under the Antiterrorism and Effective Death Penalty Act. The Eleventh Circuit found that the state court’s determination—that the outcome would not have been different even if the statement had been excluded—was neither contrary to nor an unreasonable application of federal law. Accordingly, the denial of habeas relief was affirmed. View "Calder v. Secretary, Florida Department of Corrections" on Justia Law

In 2014, Russia invaded and subsequently asserted control over Crimea, an area internationally recognized as part of Ukraine. Ukrainian businesses operating in Crimea—including an electricity distributor and a group of petrol station owners—had their assets seized and operations transferred to Russian-controlled entities without compensation. These businesses, having made investments under Ukrainian law and while the 1998 Agreement Between the Government of the Russian Federation and the Cabinet of Ministers of Ukraine on the Encouragement and Mutual Protection of Investments (“Investment Treaty”) was in effect, pursued arbitration against Russia for expropriation and treaty violations.The Ukrainian companies initiated separate arbitrations under the Investment Treaty’s arbitration clause. The arbitral tribunals found Russia liable for breaches and awarded significant damages to the companies. Russia challenged the arbitral jurisdiction and the awards in foreign courts, but those efforts were unsuccessful. The companies then filed petitions in the United States District Court for the District of Columbia to enforce the awards under the New York Convention and the Federal Arbitration Act. Russia moved to dismiss, arguing the courts lacked subject-matter and personal jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The District Court rejected Russia’s arguments, finding jurisdiction appropriate under the FSIA’s arbitration exception and personal jurisdiction proper upon valid service.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed whether the District Court correctly exercised jurisdiction. The appellate court held that the FSIA’s arbitration exception applied because the companies established the existence of an arbitration agreement, a qualifying arbitral award, and a treaty potentially governing enforcement. The court further held that foreign states are not entitled to the Fifth Amendment’s due process protections against personal jurisdiction. The judgments of the District Court were affirmed. View "Stabil LLC v. Russian Federation" on Justia Law

The defendant pleaded guilty to criminal confinement and interfering with reporting a crime, resulting in a five-year sentence: two years served through time already served and work release, followed by three years of probation. The plea agreement specified that violating any court-sponsored program, such as work release, would result in revocation and execution of the sentence. In 2023, the defendant failed to return to the work release facility, prompting his community corrections case manager to file a petition seeking revocation of his work release placement. The petition, however, did not mention probation or request revocation of the suspended portion of his sentence.After the defendant was later arrested and pleaded guilty to failure to return to lawful detention, the trial court addressed both the work release violation and, upon the State’s oral request, the defendant’s probation. Despite the defendant’s counsel objecting that revoking probation without a specific petition violated due process, the trial court revoked both his work release privileges and his probation, ordering the remainder of his sentence executed in the Department of Correction.On appeal, the Indiana Court of Appeals affirmed the trial court, holding that the court had statutory authority to revoke probation and that due process was satisfied through the plea agreement and the notice provided by the work release revocation petition. The defendant sought further review.The Indiana Supreme Court granted transfer, vacated the Court of Appeals opinion, and reversed the probation revocation. The Court held that due process requires that the State may only seek sanctions identified in the revocation petition or for which the defendant has actual notice. Because there was no petition or adequate notice seeking probation revocation, the trial court’s order revoking probation was improper. View "Ewing v. State" on Justia Law

A Texas-based company distributed files online that enabled the 3D printing of functional, untraceable firearms. After New Jersey’s Attorney General issued a cease-and-desist letter and the state legislature enacted a statute prohibiting the distribution of such files to unlicensed individuals, the company and an affiliated nonprofit restricted New Jersey residents from accessing these files. The plaintiffs challenged the actions, alleging violations of the First, Second, and Fourteenth Amendments.Initially, the plaintiffs filed suit in the Western District of Texas, which dismissed the case for lack of personal jurisdiction. Plaintiffs then filed a similar suit in the District of New Jersey, alleging the statute constituted criminal censorship. After complex procedural maneuvers—including appeals and transfers between Texas and New Jersey, and requests for retransfer—the litigation proceeded in the District of New Jersey, which consolidated the relevant cases.The United States Court of Appeals for the Third Circuit reviewed the District of New Jersey’s decision to dismiss the complaint with prejudice. The Third Circuit affirmed the lower court’s rulings. It held that the district court did not abuse its discretion in denying retransfer to Texas. The court further held that the plaintiffs lacked standing to bring a Second Amendment claim, as there were no allegations that any plaintiff or member was prevented from 3D-printing a firearm. The court also found the statute was not void for vagueness under the Due Process Clause, as it provided fair notice of prohibited conduct. Finally, the court held that plaintiffs failed to plead sufficient facts showing that the computer code at issue was expressive and entitled to First Amendment coverage, as the complaint did not detail the nature or expressive use of the files. The dismissal with prejudice was affirmed. View "Defense Distributed v. Attorney General New Jersey" on Justia Law