Justia Constitutional Law Opinion Summaries

Blake Jeffreys was arrested during a sting operation after unknowingly communicating with an undercover police officer and arranging to meet at a hotel for sex in exchange for $120. On May 14, 2021, Jeffreys pled guilty to promoting human trafficking. The Jefferson Circuit Court sentenced him to one year in prison, probated for five years, and ordered him to pay a $10,000 fee under KRS 529.130. Jeffreys requested the trial court waive the payment under KRS 534.030(4), but the court declined. Jeffreys appealed, arguing the fee was an unconstitutional excessive fine and should be waived.The Court of Appeals rejected Jeffreys' arguments and affirmed the trial court's decision. Jeffreys sought discretionary review from the Kentucky Supreme Court, focusing solely on the argument that the fee should be waived. The Kentucky Supreme Court granted the motion for review.The Kentucky Supreme Court affirmed the Court of Appeals' decision. The court held that KRS 529.130 imposes a human trafficking victims service fee, not a fine, and is not subject to waiver under KRS 534.030(4). The court also found that KRS 453.190, which defines a "poor person" for the purpose of waiving court costs, does not apply to the fee imposed under KRS 529.130. However, the court noted that Jeffreys could seek a show cause hearing under KRS 534.020(3)(a)1 to potentially reduce or waive the payment based on his ability to pay. The court emphasized that the trial court should consider various factors, including the defendant's financial status and dependents, when determining the ability to pay. View "JEFFREYS V. COMMONWEALTH OF KENTUCKY" on Justia Law

Matthew Ryan Hunt was charged with violating 18 U.S.C. § 922(g)(1), which prohibits individuals convicted of a crime punishable by imprisonment for a term exceeding one year from possessing firearms. Hunt's 2017 conviction for breaking and entering in West Virginia served as the predicate offense. In May 2022, Hunt pleaded guilty without raising a Second Amendment challenge. On appeal, Hunt argued that § 922(g)(1) violated the Second Amendment both facially and as applied to him. He also contended that the district court erred in applying a four-point enhancement to his offense level under the federal sentencing guidelines.The United States District Court for the Southern District of West Virginia accepted Hunt's guilty plea and applied the four-point enhancement, finding that Hunt had fired a gun inside an apartment building during a domestic violence incident, which constituted wanton endangerment under West Virginia law. Hunt appealed the decision, arguing that the statute was unconstitutional and that the district court's factual findings were erroneous.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court reaffirmed that § 922(g)(1) is facially constitutional, consistent with its prior decision in United States v. Canada. The court also rejected Hunt's as-applied challenge, holding that neither the Supreme Court's decisions in New York State Rifle & Pistol Association, Inc. v. Bruen nor United States v. Rahimi abrogated the Fourth Circuit's precedent foreclosing as-applied challenges to § 922(g)(1). Additionally, the court concluded that § 922(g)(1) would survive Second Amendment scrutiny even if decided anew.The Fourth Circuit also upheld the district court's application of the four-point enhancement, finding no clear error in the factual determination that Hunt fired a gun in the apartment. Consequently, the court affirmed the district court's judgment. View "US v. Hunt" on Justia Law

A group of 16 youths sued the State of Montana, the Governor, and multiple state agencies, alleging that the State's actions exacerbated the harm they were experiencing from climate change. They sought declaratory and injunctive relief, specifically challenging certain provisions of Montana's State Energy Policy Act and the Montana Environmental Policy Act (MEPA) as unconstitutional. The plaintiffs argued that these provisions violated their constitutional right to a clean and healthful environment by promoting fossil fuel development and prohibiting the consideration of greenhouse gas (GHG) emissions in environmental reviews.The First Judicial District Court found in favor of the plaintiffs, declaring the challenged provisions unconstitutional and enjoining the State from acting in accordance with them. The court concluded that the right to a clean and healthful environment includes a stable climate system and that the MEPA Limitation violated this right. The court also denied the State's motion for psychiatric examinations of the plaintiffs, finding no good cause for such examinations.The Supreme Court of the State of Montana affirmed the District Court's decision. The court held that the right to a clean and healthful environment under the Montana Constitution includes a stable climate system. The court found that the plaintiffs had standing to challenge the MEPA Limitation, as it infringed on their constitutional rights. The court also held that the MEPA Limitation was unconstitutional because it arbitrarily excluded GHG emissions from environmental reviews, thereby violating the plaintiffs' right to a clean and healthful environment. The court affirmed the permanent injunction against the State from acting in accordance with the unconstitutional provisions. View "Held v. State" on Justia Law

In 2021, the Montana Legislature passed House Bill 407 (HB 407), which preempted local ordinances, resolutions, initiatives, or referendums regulating the use, sale, or taxation of certain containers, including single-use plastics. Bozeman, which adopted a self-government charter in 2000, was affected by this bill. In 2023, a member of the Cottonwood Environmental Law Center submitted a local ballot initiative to regulate single-use plastics in Bozeman. The Gallatin County Election Administrator rejected the petition, citing the prohibition under § 7-5-131(2)(f), MCA. Cottonwood and other plaintiffs filed a complaint challenging the constitutionality of HB 407.The First Judicial District Court granted Cottonwood's motion for partial summary judgment, finding § 7-5-131(2)(f), MCA, unconstitutional under Article XI, Section 8, of the Montana Constitution. The court certified its order as final, allowing the initiative to be placed on the 2024 general election ballot, where it passed.The Supreme Court of the State of Montana reviewed the case. The court held that the Legislature may place limits on the powers of local government, including the power of local initiatives, as long as these limits do not infringe on other constitutional rights. The court found that § 7-1-111(21), MCA, which prohibits local government units with self-government powers from regulating auxiliary containers, is constitutional. Consequently, the court reversed the District Court's decision, holding that § 7-5-131(2)(f), MCA, is not facially unconstitutional under Article XI, Section 8, of the Montana Constitution. View "Cottonwood v. State" on Justia Law

Heather Rose Johnson was convicted of assault on a peace officer, driving under the influence, driving while suspended or revoked, and expired registration after a jury trial. The incident occurred on January 24, 2021, when Johnson, after drinking beer with a friend, drove to a gas station and was reported by a 911 caller for appearing intoxicated. Ravalli County Sheriff’s Office Sergeant Clarence Jessop stopped Johnson’s vehicle, observed signs of intoxication, and arrested her. During the arrest, Johnson kicked Sergeant Jessop, leading to the assault charge.The Twenty-First Judicial District Court, Ravalli County, admitted the 911 call in its entirety over Johnson’s hearsay objections. Johnson was convicted on all charges and sentenced. The court’s written judgment included an “Audit Hearing” condition not mentioned in the oral pronouncement of the sentence.The Supreme Court of the State of Montana reviewed the case. The court determined that the admission of the 911 call violated Johnson’s confrontation rights under the U.S. and Montana Constitutions because the caller’s statements that Johnson was intoxicated and about to commit DUI were testimonial. However, the court found this error to be harmless beyond a reasonable doubt due to the overwhelming evidence against Johnson, including video footage and testimony from law enforcement officers.The court affirmed Johnson’s convictions but remanded the case to the District Court to strike the “Audit Hearing” condition from the written judgment, as it conflicted with the oral pronouncement of the sentence. View "State v. H. Johnson" on Justia Law

In January 2016, the State of Montana charged Lavodrick Terelle Hogues with felony aggravated promotion of prostitution involving a 17-year-old female, Jane Doe. The charge stemmed from an undercover operation where officers discovered Doe and another woman, Phylicia Zubia, offering escort services online. Evidence linked Hogues to the operation through phone records, MoneyGram transfers, and other communications.The Thirteenth Judicial District Court of Yellowstone County handled the initial proceedings. Hogues faced multiple delays due to changes in legal representation and his own absconding. He eventually requested to represent himself, which the court granted four days before trial. The court also allowed Jane Doe to testify via remote video due to travel burdens and pandemic concerns, despite Hogues' objections.The Montana Supreme Court reviewed the case. It affirmed the lower court's decision to allow Hogues to represent himself, finding that he had made a voluntary, knowing, and intelligent waiver of his right to counsel. However, the court reversed the decision to admit Jane Doe's remote testimony. The court held that the State failed to demonstrate that her in-person testimony was impracticable or that remote testimony was necessary to further an important public policy. The court emphasized the importance of face-to-face confrontation under the Sixth Amendment and Montana Constitution.The Montana Supreme Court concluded that the denial of Hogues' right to face-to-face confrontation was not harmless error, given Jane Doe's critical role as the alleged victim. Consequently, the court reversed Hogues' conviction and remanded the case for a new trial. View "State v. L. Hogues" on Justia Law

In January 2015, Ian Mitcham was arrested for DUI in Scottsdale, Arizona. He consented to a blood test to determine alcohol concentration or drug content, and two vials of blood were drawn. Mitcham was informed that the second vial would be destroyed if not claimed within ninety days, but it was not destroyed. Mitcham was later convicted of a misdemeanor DUI. In February 2015, Allison Feldman was found murdered, and DNA evidence was collected from the crime scene. In 2017, a familial DNA search linked Mitcham’s brother to the crime scene DNA, leading police to Mitcham. Without a warrant, police used the second vial of blood to create a DNA profile, which matched the crime scene DNA.The Maricopa County Superior Court suppressed the DNA evidence obtained from the second vial and the subsequent buccal swabs collected under a search warrant, ruling that the warrantless search violated the Fourth Amendment and no exceptions to the exclusionary rule applied. The court of appeals reversed, with the majority finding that the inevitable discovery and independent source exceptions applied, while a concurring judge found no Fourth Amendment violation.The Arizona Supreme Court reviewed the case and held that the police violated Mitcham’s Fourth Amendment rights by conducting a warrantless search of the second vial of blood. However, the court found that the inevitable discovery exception to the exclusionary rule applied. The court reasoned that Mitcham’s DNA profile would have inevitably been discovered through lawful means due to his subsequent felony convictions, which required DNA profiling under Arizona law. Therefore, the trial court erred in suppressing the DNA evidence. The Arizona Supreme Court reversed the trial court’s suppression order and remanded the case for further proceedings. View "STATE OF ARIZONA v MITCHAM" on Justia Law

Prospect Crozer, LLC owned and developed 57.7 acres of real property in Upland Borough, Delaware County, assessed at $80,166,493 for tax years 2017-2019. Prospect appealed the assessment, but the Delaware County Board of Assessment Appeals denied it. Prospect then appealed to the Delaware County Court of Common Pleas, where the Chester Upland School District intervened. Senior Judge John L. Braxton, assigned by the Pennsylvania Supreme Court, presided over the de novo tax assessment proceedings. During this time, Judge Braxton was appointed to the Philadelphia Board of Revision of Taxes and received his first payment from the Board on June 16, 2019. He continued to preside over the tax appeals and issued orders in October 2019.The Delaware County Court of Common Pleas conducted a hearing to determine the timeline of Judge Braxton's dual service and found that he began receiving compensation from the Board on June 16, 2019. The Commonwealth Court then vacated the orders issued by Judge Braxton, concluding that his simultaneous service on the Board and as a judge violated Article V, Section 17(a) of the Pennsylvania Constitution, which prohibits judges from holding an office or position of profit in the government. The court held that this violation resulted in the automatic forfeiture of his judicial office, rendering the orders legal nullities.The Supreme Court of Pennsylvania reviewed the case and agreed that Judge Braxton violated Section 17(a) by holding a position of profit with a municipal corporation while serving as a judge. However, the court rejected the Commonwealth Court's conclusion that this violation resulted in the automatic forfeiture of his judicial office. Instead, the Supreme Court held that the violation created a constitutionally impermissible conflict of duties, requiring the vacatur of the orders entered in the tax appeals. The case was remanded to the Delaware County Court of Common Pleas for reassignment to a new judge. View "In re: Appeal of Prospect Crozer LLC From the Decision of the Board of Assessment Appeals of Delaware County, PA" on Justia Law

Steven M. Hohn, the defendant, was convicted of multiple drug and firearm charges. While awaiting trial, he was detained at CoreCivic, where the Kansas U.S. Attorney’s Office (Kansas USAO) obtained and listened to his attorney-client phone calls. Hohn later discovered this and filed a 28 U.S.C. § 2255 petition to vacate his judgment or reduce his sentence, arguing that the government’s intrusion violated his Sixth Amendment rights.The United States District Court for the District of Kansas denied Hohn’s § 2255 petition. The court found that Hohn did not have a reasonable expectation of confidentiality in his attorney-client call because he knew the call would be recorded and did not follow the proper steps to privatize it. The court also concluded that Hohn waived the attorney-client privilege by making the call despite knowing it would be recorded. Consequently, the court did not reach a direct Sixth Amendment analysis, as it determined that the privilege was a necessary underpinning of Hohn’s Sixth Amendment right.The United States Court of Appeals for the Tenth Circuit reviewed the case en banc. The court overruled its precedent in Shillinger v. Haworth, which had established a structural-error rule presuming prejudice when the government intentionally intrudes into the attorney-client relationship without a legitimate law-enforcement purpose. The Tenth Circuit held that a Sixth Amendment violation of the right to confidential communication with an attorney requires the defendant to show prejudice. Since Hohn conceded that he suffered no prejudice from the prosecution’s obtaining and listening to his six-minute call with his attorney, his claim failed. The Tenth Circuit affirmed the district court’s decision denying Hohn’s § 2255 petition. View "United States v. Hohn" on Justia Law

Jaylin Morton was indicted for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Morton moved to dismiss the indictment, arguing that the prosecution violated his Second Amendment rights. The district court denied his motion, and Morton conditionally pleaded guilty, retaining the right to appeal the denial of his motion to dismiss.The United States District Court for the Eastern District of Kentucky denied Morton’s motion to dismiss, reasoning that his prior felonies demonstrated that he was a serious and direct threat to public safety. The court concluded that § 922(g)(1) constitutionally applied to him. Morton then appealed the district court’s decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Morton’s criminal history, which included multiple violent offenses such as shooting at his ex-girlfriend and her family, and assaulting his then-girlfriend, demonstrated his dangerousness. The court applied the framework established in United States v. Williams, which allows for disarming individuals who are deemed dangerous based on their criminal history. The court concluded that Morton’s conviction was consistent with the Second Amendment as interpreted in Williams and affirmed the district court’s denial of Morton’s motion to dismiss the indictment. View "United States v. Morton" on Justia Law