Justia Constitutional Law Opinion Summaries

After being found not guilty of a crime by reason of insanity, C.F. was admitted to a state hospital, where he was treated with antipsychotic medication under a court order. When the Department of State Hospitals sought to renew the order authorizing involuntary medication, the trial court held an evidentiary hearing. C.F.’s counsel did not request a court reporter, though one could have been provided at no cost by simply submitting a form. Consequently, no verbatim record of the hearing was made, and C.F. did not attend, with his counsel waiving his appearance.The Superior Court of Napa County heard from the Department’s expert witness and found, by clear and convincing evidence, that C.F. lacked capacity to refuse treatment, granting the renewal for up to one year. C.F. appealed, arguing that he was denied effective assistance of counsel because his lawyer did not secure a record of the hearing. When C.F. later applied for a settled statement to reconstruct the hearing for appellate review, the trial court denied the request, finding he had waived his right to a record by not requesting a reporter.The Court of Appeal of the State of California, First Appellate District, Division Five, found that C.F.’s counsel’s failure to request a reporter constituted deficient performance, with no tactical explanation and resulting prejudice. The absence of a hearing record rendered meaningful appellate review impossible, amounting to a denial of due process and effective assistance of counsel. The appellate court reversed the trial court’s order and remanded for a new hearing, noting that if the Department seeks to renew the order after its expiration, the new hearing may be combined with any future renewal petition. View "People v. C.F." on Justia Law

Nathaniel Martin was a passenger in a vehicle stopped by a United States Forest Service law enforcement officer in the Monongahela National Forest after the vehicle was found illegally parked on a single-lane bridge. The officer, Joshua Radford, initially cited the parking violation as the reason for the stop. However, as soon as the stop began, Radford immediately shifted focus, asking about firearms in the vehicle and then further questioning both the driver and Martin regarding other possible contraband. Firearms were discovered, and Martin was eventually arrested after a check revealed prior felony convictions. Notably, the officer did not issue a citation for the parking offense, and the initial minutes of the stop were not captured on bodycam video.After more than two years, Martin was charged in the United States District Court for the Southern District of West Virginia with being a felon in possession of a firearm. He moved to suppress the evidence and his statements, arguing that the stop violated his Fourth Amendment rights because the officer had abandoned the original purpose of the stop. The district court denied the motion to suppress, finding that the officer’s actions remained within the permissible scope of the stop and did not unlawfully extend it. Martin then entered a guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the officer’s immediate pivot from addressing the parking violation to investigating potential criminal activity was not reasonably related in scope to the original justification for the stop. The court distinguished this situation from prior precedent by noting the absence of circumstances suggesting officer safety concerns. The court reversed the district court’s denial of the suppression motion and vacated Martin’s guilty plea. View "US v. Martin" on Justia Law

Charles Byers was shot and killed by Corporal Gordon Painter, a Chesterfield County police officer, after an emergency call reported that Byers had tried to break into two homes and vandalized one. Byers, who suffered from schizoaffective disorder, was seen wandering barefoot in a neighborhood holding a hatchet. When police arrived, Byers refused multiple commands to drop the hatchet, but kept the weapon lowered at his side and did not make threatening movements. After a taser was deployed without effect, Officer Painter fired three shots at Byers, who was about 25 feet away with his head turned away. Byers then turned to flee, and Officer Painter fired additional shots, striking Byers in the back and causing his death.Byers' parents, as co-administrators of his estate, sued Officer Painter under 42 U.S.C. § 1983 for excessive force in violation of the Fourth Amendment, and for negligence under Virginia law, in the United States District Court for the Eastern District of Virginia. The district court denied Officer Painter’s motion to dismiss the § 1983 claim on qualified immunity grounds, finding that Byers did not pose an immediate threat at the time he was shot, and granted the motion to dismiss the negligence claim. Officer Painter appealed the denial of qualified immunity.The United States Court of Appeals for the Fourth Circuit reviewed the district court's denial of qualified immunity de novo, applying recent Supreme Court guidance that requires courts to consider the totality of the circumstances, not just the moments before deadly force is used. The Fourth Circuit held that, even considering the totality, Officer Painter’s use of deadly force was not objectively reasonable under the Fourth Amendment, and that the violation was clearly established at the time. The court affirmed the district court’s denial of Officer Painter’s motion to dismiss on qualified immunity grounds. View "Byers v. Painter" on Justia Law

Police officers discovered a semiautomatic firearm equipped with a 30-round magazine in the possession of Tyree Benson. The firearm was unregistered, contained ammunition, and Benson did not have a license to carry it. He was charged with possession of a large capacity ammunition feeding device (a magazine holding more than ten rounds), possession of an unregistered firearm, carrying a pistol without a license, and unlawful possession of ammunition. Before trial, Benson moved to suppress the evidence on Fourth Amendment grounds and to dismiss the indictment on Second Amendment grounds, arguing that the District of Columbia’s ban on magazines capable of holding more than ten rounds violated the Second Amendment, as did the District’s registration and licensure schemes. The trial court, the Superior Court of the District of Columbia, denied both motions, reasoning that Supreme Court precedent in New York State Rifle & Pistol Association v. Bruen did not invalidate D.C.’s gun laws. Following a bench trial on stipulated facts, Benson was convicted on all counts.On appeal to the District of Columbia Court of Appeals, Benson renewed his constitutional arguments. The United States, which had prosecuted Benson, ultimately agreed with him that the magazine ban was unconstitutional. However, the District of Columbia, as intervenor-appellee, continued to defend the ban.The District of Columbia Court of Appeals held that magazines capable of holding more than ten rounds are “arms” under the Second Amendment, that such magazines are in common and ubiquitous use by law-abiding citizens for lawful purposes, and that there is no historical tradition of banning arms in such common use. Accordingly, the court held that the District’s outright ban on 11+ round magazines violates the Second Amendment. Because the magazine ban rendered it impossible for Benson to register, license, or lawfully possess ammunition for his firearm, the court reversed all of his convictions. The court thus vacated Benson’s convictions and did not reach his other constitutional claims. View "Benson v. United States" on Justia Law

A marijuana dealer was shot and killed in the stairwell of his apartment building while making a sale. The government asserted that the defendant, although not the shooter, was guilty of felony murder because the killing occurred during a robbery he planned with the admitted shooter. Critical government witnesses included the shooter, who testified pursuant to a plea deal, and a mutual acquaintance who received immunity; both placed the defendant at the scene and as a participant in the robbery. However, no physical evidence connected the defendant to the crime scene, and a disinterested eyewitness testified that the defendant was not among the fleeing assailants.The defendant was convicted in the Superior Court of the District of Columbia of first-degree felony murder while armed and related offenses after a jury trial. He subsequently filed a motion under D.C. Code § 23-110, claiming ineffective assistance of counsel. At the post-conviction hearing, the trial court found the government’s case strong, credited much of trial counsel’s testimony about trial preparation, and denied the motion.On appeal, the District of Columbia Court of Appeals reviewed the denial of the § 23-110 motion. The appellate court found that trial counsel’s representation was constitutionally deficient in several respects, including misunderstanding the elements of felony murder, failing to adequately prepare the defendant to testify, and adopting a trial strategy that exposed the defendant to prejudicial information about his criminal history. The appellate court determined that these deficiencies created a reasonable probability that, but for counsel’s errors, the verdict would have been different. The court therefore reversed the Superior Court’s denial of the defendant’s motion and remanded for further proceedings. View "Truesdale v. United States" on Justia Law

A developer purchased property in the Brookland neighborhood that included a historic mural and an adjacent parking lot providing clear sightlines to the mural. Another individual, who sought to preserve the mural, had previously contracted to buy the property but the deal fell through amid allegations of contract forgery by the seller. The developer, holding a promissory note secured by a deed of trust, initiated foreclosure and ultimately purchased the property at auction. The unsuccessful buyer accused the developer of fraud and publicly made statements labeling him as corrupt and claiming he had “problems with the DOJ” and had taken the property “by theft and fraud.” These statements were repeated online via a media outlet controlled by the unsuccessful buyer.The developer sued for defamation and false light in the Superior Court of the District of Columbia. The defendant moved to dismiss under the District’s Anti-SLAPP Act, arguing that his statements were protected advocacy on matters of public interest and that the developer was a limited-purpose public figure, thus requiring proof of actual malice. The trial court found the developer to be a limited-purpose public figure and denied most of the motion, allowing the claims to proceed except those related to certain statements outside the statute of limitations.The District of Columbia Court of Appeals reviewed the case. It held that the Anti-SLAPP Act applied because the statements addressed issues of public interest, such as urban development and historic preservation. The court concluded that the developer was a limited-purpose public figure and therefore must show actual malice by clear and convincing evidence. The court found that the developer failed to demonstrate that the statements were false or made with actual malice. As a result, the court reversed the trial court’s denial of the Anti-SLAPP motion and remanded for further proceedings. View "Capitol Intelligence Group, Inc. v. Waldman" on Justia Law

Police officers stopped an individual driving a car in the District of Columbia, citing two reasons: failure to use a turn signal when making a turn and the presence of tint on the car’s front windshield. During the stop, an officer saw a handgun in the glove box, leading to a search that uncovered both the handgun and PCP. The officer testified that any tint on a front windshield is illegal, but did not measure the level of tint or issue a notice of infraction for either violation.After being charged, the individual moved to suppress the evidence, arguing that the stop lacked a lawful basis because D.C. law allows some level of front-windshield tint, and there was no corroboration of the alleged turn signal violation. The Superior Court of the District of Columbia denied the motion to suppress, finding that the officer had probable cause to believe a tint violation occurred, even though the officer was mistaken about the law. The court did not rely on the alleged failure to signal, finding it questionable.On appeal, the District of Columbia Court of Appeals reviewed the trial court’s ruling. The appellate court held that the government failed to show the officers had reasonable, articulable suspicion that the windshield tint was illegal, since the law permitted some tint and there was no evidence the tint actually exceeded legal limits. The officer’s misunderstanding of the law was not objectively reasonable. The court also found no basis to remand for reconsideration of the turn signal issue, as the government did not present sufficient evidence at the suppression hearing. As a result, the appellate court vacated the convictions and remanded the case for further proceedings. View "Griffin v. United States" on Justia Law

Two men were tried together for a shooting that resulted in the death of one person and injuries to two others. The evidence against them included surveillance videos, cell phone and social media records, DNA evidence, and expert testimony. The key factual dispute at trial was whether the two defendants were the men captured on video committing the shooting, as the government alleged. The prosecution also presented testimony from a firearms examiner who stated that there was “extremely strong support” that shell casings found at the scene were fired from a rifle recovered near the defendants’ crashed vehicle. One defendant was also linked to a distinctive blue puffer jacket seen on the shooter in surveillance footage.In the Superior Court of the District of Columbia, both defendants were convicted by a jury of first-degree murder, two counts of assault with intent to kill, and multiple firearm offenses. The trial judge permitted the firearms examiner’s testimony over defense objections, concluding it was consistent with existing law so long as the expert did not claim absolute certainty. The trial judge also limited defense counsel’s closing argument about the prevalence of blue puffer jackets, sustaining an objection to a portion of that argument.On appeal, the District of Columbia Court of Appeals assumed for argument’s sake that it was error to allow the firearms expert’s testimony and agreed that restricting the defense’s closing argument about the jacket was an abuse of discretion. However, the court held that any errors were harmless given the overwhelming evidence of guilt, including video, DNA, and witness identification. The court ordered that certain firearm convictions merge, leaving each defendant with one conviction for possession of a firearm during a crime of violence, and vacated one defendant’s conviction for carrying a rifle or shotgun outside the home, finding the statutory prohibition unconstitutional. All other convictions were affirmed. View "Stevenson v. United States" on Justia Law

Two Metropolitan Police Department investigators, while patrolling in an unmarked car, approached a parked vehicle with its headlights on and observed Brian K. Williams in the driver’s seat. As officers engaged Williams in conversation, one investigator noticed a thin, rectangular object on Williams’s right groin area, which the officer believed, based on his training and experience, resembled the receiver or slide of a firearm rather than a cell phone or part of Williams’s anatomy. Williams denied having contraband and, when the investigator indicated an intent to frisk him, Williams fled but was quickly apprehended. Officers found a firearm in his pants and arrested him.Williams was charged in the Superior Court of the District of Columbia with several firearm-related offenses, including unlawful possession of a firearm by a convicted felon, carrying a pistol without a license, possession of a large-capacity ammunition feeding device, possession of an unregistered firearm, and unlawful possession of ammunition. Before trial, Williams moved to suppress the evidence found during his arrest, arguing that officers lacked reasonable suspicion for the seizure. After a suppression hearing, the Superior Court denied his motion, crediting the investigator’s testimony and finding reasonable articulable suspicion based on the observed object, Williams’s movements, and recent shootings in the area. A stipulated trial resulted in convictions on all charges.The District of Columbia Court of Appeals reviewed the case and concluded that the officers had reasonable articulable suspicion to seize Williams, relying on the totality of the circumstances, including the specific characteristics of the object, Williams’s conduct, and recent violent crime in the area. The Court affirmed the convictions for all charges except possession of a large-capacity ammunition feeding device, which was vacated upon an unopposed government motion due to the statute’s unconstitutionality. The case was remanded for further proceedings. View "Williams v. United States" on Justia Law

In 1980, the appellant was convicted by a jury of oral sodomy under a District of Columbia statute that, at the time, criminalized all acts of sodomy regardless of consent. The incident involved C.P., a co-defendant, and a complaining witness who testified that she was forced to engage in sexual acts after accepting a ride from the defendants. The appellant claimed the acts were consensual. The trial court instructed the jury that consent was not a defense to sodomy under the law then in effect. C.P. was sentenced to incarceration and, after later enactments, required to register as a sex offender for life.After his conviction was affirmed on direct appeal by the District of Columbia Court of Appeals in 1981, C.P. filed several post-conviction motions. In 2004, he sought to vacate his conviction, arguing that subsequent legislative changes and the repeal of the sodomy statute rendered his conduct non-criminal. The Superior Court denied this motion, finding no retroactive effect for the legal changes. In 2018, C.P. challenged his lifetime sex offender registration under the Sex Offender Registration Act (SORA), arguing that the registration requirement was invalid without a jury finding of force. In 2021, he moved to vacate his conviction again, this time arguing that his conviction and resulting registration violated substantive due process under Lawrence v. Texas. The Superior Court denied both motions, holding the latter was procedurally barred as a successive writ and that C.P. had not shown exceptional circumstances to excuse the default.The District of Columbia Court of Appeals reviewed the denials of the 2018 and 2021 motions. It held that the motion to vacate was properly denied as an abuse of the writ, and that the challenge to SORA registration failed because the trial court had sufficient evidence to find forcible sodomy by a preponderance of the evidence. The court affirmed both denials. View "C.P. v. United States" on Justia Law