Justia Constitutional Law Opinion Summaries

A group of teenagers, including the appellants, committed a series of armed robberies and a murder over a three-day period in October 2018 in Suwanee, Georgia. The crimes included the shooting death of Willian Tunchez and the robberies of four other individuals. The group, associated with the Gangster Disciples street gang, planned and executed these crimes, often using firearms and dividing the stolen proceeds. Evidence included testimony from accomplices, physical evidence recovered from the defendants’ residences, and digital evidence from cell phones and social media.Following these events, a Gwinnett County grand jury indicted several individuals on multiple counts, including malice murder, armed robbery, aggravated assault, and violations of the Street Gang Terrorism and Prevention Act. Some co-defendants agreed to testify for the State. After a joint jury trial in the Superior Court of Gwinnett County, the jury found the appellants guilty on most counts. The trial court sentenced both to life imprisonment without parole for malice murder, with additional concurrent and consecutive sentences for other offenses. The court merged certain counts for sentencing and vacated others by operation of law. Both appellants filed timely motions for new trial, which were denied, and then appealed to the Supreme Court of Georgia.The Supreme Court of Georgia reviewed the sufficiency of the evidence, claims of ineffective assistance of counsel, and alleged sentencing errors. The Court held that there was sufficient direct evidence to support the convictions, that trial counsel was not constitutionally ineffective, and that most sentencing decisions were correct. However, the Court found that the trial court erred by failing to merge one aggravated assault count with an armed robbery count for one appellant, vacating that sentence but otherwise affirming the convictions and sentences. View "Evans v. State" on Justia Law

A group of broadband internet providers in Georgia entered into contracts with the Georgia Department of Transportation to install and maintain their equipment along public rights of way. These contracts set annual permit fees and included a clause stating that the contracts would remain in effect until the parties entered into a new agreement. In 2021, the Department amended its rules, increasing permit fees and requiring providers to sign new contracts. The providers refused, and the Department notified them that, absent new agreements, they would be subject to the new rules. The providers then filed suit, seeking a declaratory judgment that their contracts were enforceable, not terminable at will, and that the Department’s actions impaired their contractual rights in violation of the United States and Georgia Constitutions.The Superior Court denied the State’s motion to dismiss, finding that sovereign immunity was waived under Article I, Section II, Paragraph V(b) of the Georgia Constitution because the providers sought declaratory relief from alleged unconstitutional acts. The court granted summary judgment to the providers, holding that the contracts were enforceable and not terminable at will by the Department.On appeal, the Supreme Court of Georgia reviewed the case. The Court agreed with the lower court that sovereign immunity was waived for this declaratory judgment action, as the providers sought relief from acts allegedly violating constitutional provisions. However, the Supreme Court of Georgia disagreed with the trial court’s interpretation of the contracts. It held that the contracts were of indefinite duration and, under longstanding Georgia law, were terminable at will by either party with notice. The Court affirmed the waiver of sovereign immunity but vacated the judgment granting declaratory and injunctive relief, remanding the case for further proceedings consistent with its opinion. View "State v. Dovetel Communication, LLC" on Justia Law

An inmate at the Louisiana State Penitentiary participated in the Angola Prison Rodeo from 1996 to 2019, selling leather belts and earning approximately $80,000. He alleged that prison officials confiscated about $16,000 of his earnings, claiming the deductions were for taxes, commissions, and maintenance fees. The inmate filed a grievance through the prison’s administrative process, arguing that the deductions were unauthorized and that he was denied a due process hearing regarding the seizure of his property. The prison denied his grievance, explaining the deductions, and the inmate exhausted his administrative remedies. He then sought relief in Louisiana state court through a petition for writ of mandamus, which remained unresolved for over a year.Subsequently, the inmate filed a pro se complaint in the United States District Court for the Middle District of Louisiana under 42 U.S.C. § 1983, alleging that various prison officials conspired to deny him due process in connection with the confiscation of his property. The defendants moved to dismiss the complaint, asserting qualified immunity and failure to state a claim. A magistrate judge recommended dismissing any standalone claims regarding the denial of the prison grievance but allowed the conspiracy and due process claims to proceed. The district court adopted this recommendation, and the defendants appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the defendants were entitled to qualified immunity. The court found that the inmate’s complaint did not adequately allege a pre-deprivation due process claim and that, at the time of the alleged conduct, it was not clearly established that the inmate had a protected property interest in the proceeds from the sale of crafts made and sold under prison auspices. The Fifth Circuit reversed the district court’s denial of qualified immunity and remanded the case for further proceedings. View "Savage v. Westcott" on Justia Law

Jill Esche, who was seven months pregnant, was admitted to Renown Regional Medical Center in Nevada with severe hypertension and erratic behavior. Hospital staff, believing she was mentally ill and a danger to herself and her fetus, petitioned for her involuntary commitment under Nevada law. While the petition was pending, Esche was kept in the hospital, given psychiatric and medical treatment against her will, restricted from visitors and phone use, and not informed that a public defender had been appointed for her. After giving birth by C-section, the hospital decided to withdraw the commitment petition but allowed Esche to leave while she was still in fragile condition. She died outside near the hospital that night. Her estate and survivors sued the hospital and several staff members, alleging violations of her constitutional rights under 42 U.S.C. § 1983 and Nevada law.The United States District Court for the District of Nevada granted summary judgment to the defendants on some claims, including unreasonable seizure and procedural due process claims, but denied summary judgment on others, such as substantive due process, conspiracy, and failure-to-train-or-supervise claims. The court also denied the defendants’ assertion of a good-faith defense to § 1983 liability, finding that the defense did not apply because the hospital was not required by law or directed by a public official to hold Esche involuntarily. Both sides appealed: the defendants challenged the denial of the good-faith defense, and the plaintiffs cross-appealed the dismissal of other constitutional claims.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the district court’s denial of the good-faith defense was not immediately appealable under the collateral order doctrine, as the defense is a defense to liability, not an immunity from suit. The court dismissed both the defendants’ appeals and the plaintiffs’ cross-appeal for lack of jurisdiction. View "Estate of Esche v. Bunuel-Jordana" on Justia Law

The case concerns a challenge by the leaders of the Arizona Senate and House of Representatives to the Voters’ Right to Know Act, a voter-approved initiative that imposes new campaign finance disclosure requirements and grants broad enforcement powers to the Citizens Clean Elections Commission. The legislative leaders argue that the Act unconstitutionally delegates legislative authority to the Commission, an executive agency, and that the challenged provisions are so integral to the Act that, despite a severability clause, their invalidity would render the entire measure void.After the Act was approved by voters, the legislative leaders, authorized by their respective chambers, filed a facial constitutional challenge in the Superior Court of Maricopa County against the Secretary of State and the Commission. The Arizona Attorney General and the political action committee that sponsored the Act intervened to defend it. The superior court denied the leaders’ motion for a preliminary injunction, finding no specific injury had occurred, and also denied the defendants’ motions to dismiss, allowing the leaders to amend their pleadings. On appeal, the Arizona Court of Appeals held that the leaders lacked standing to challenge the entire Act but had standing to challenge a specific provision (§ 16-974(D)) that prevented the Legislature from limiting the Commission’s rules or enforcement actions. The court of appeals found this provision unconstitutional but severable, and enjoined its enforcement while upholding the rest of the Act.The Supreme Court of the State of Arizona reviewed the case and held that the legislative leaders have standing to challenge the Act, as the alleged unconstitutional delegation of legislative power constitutes an institutional injury. However, the Court determined that it is premature to address the severability of the challenged provisions before a ruling on their constitutionality. The Supreme Court reversed the superior court’s decision, vacated the court of appeals’ decision, and remanded the case for further proceedings. View "Montenegro v. Fontes" on Justia Law

Several voters in Washington County, Pennsylvania, submitted mail-in ballots for the 2024 Primary Election that contained obvious errors, such as missing signatures or dates on the declaration envelope, or missing secrecy envelopes. Under a previous policy, the county board of elections notified voters of such defects and allowed them to correct the errors or vote provisionally. However, in April 2024, the board adopted a new policy eliminating notice and cure procedures. Instead, all returned mail-in ballots, including those with disqualifying errors, were coded identically in the state’s SURE system, which triggered an email to voters stating their ballot had been received and that they could not vote at the polls, regardless of whether their ballot was valid. As a result, voters whose ballots were set aside for errors were not informed of the disqualification and did not attempt to vote provisionally.The Washington County Court of Common Pleas found that the board’s policy violated voters’ procedural due process rights under the Pennsylvania Constitution by failing to provide notice that their ballots would not be counted, thus depriving them of the opportunity to challenge the decision or vote provisionally. The court issued an injunction requiring the board to notify affected voters, accurately code ballots in the SURE system, and ensure poll books reflected that such voters had not “voted,” allowing them to cast provisional ballots. The Commonwealth Court affirmed, holding that the right to vote and the statutory right to cast a provisional ballot are protected liberty interests, and that the board’s policy risked erroneous deprivation of those rights.The Supreme Court of Pennsylvania affirmed in large part, holding that the right to vote and the statutory right to cast a provisional ballot when a mail-in ballot is void are protected liberty interests under the Pennsylvania Constitution. The court held that due process requires county boards to provide accurate notice—via correct SURE system coding—when a mail-in ballot is segregated for a disqualifying error, so affected voters have the opportunity to vote provisionally. The court vacated the requirement for additional notice beyond accurate SURE coding and clarified that the right to challenge under 25 P.S. §3157 does not require pre-canvass challenges. The injunction otherwise remains in effect. View "Center for Coalfield Justice v. Washington County Board of Elections" on Justia Law

A prospective employee applied for a position as an occupational therapist with a rehabilitation company, which required COVID-19 vaccination as a condition of employment. The applicant requested a religious exemption, submitting a written statement and a supporting letter from a friend citing religious objections to vaccines developed with fetal cell lines. The company questioned the applicant about her vaccination history and, finding her responses insufficiently sincere, denied the exemption and rescinded the job offer. The applicant filed a complaint with the Kansas Department of Labor, which found the company had violated Kansas law by inquiring into the sincerity of her religious beliefs.The company sought judicial review in the Johnson District Court, which reversed the agency’s decision. The district court held that the relevant Kansas statute, which prohibits employers from inquiring into the sincerity of an employee’s religious beliefs when considering COVID-19 vaccine exemptions, was preempted by federal law—specifically, the federal Vaccine Mandate for Medicare and Medicaid providers and Title VII of the Civil Rights Act. The district court also found the Kansas statute violated due process because it lacked a rational basis.On appeal, the Supreme Court of the State of Kansas reviewed the case de novo. The court held that the federal Vaccine Mandate and Title VII do not expressly or impliedly preempt the Kansas statute, because federal law permits but does not require employers to inquire into religious sincerity. The court further held that the Kansas law does not violate due process, as it is rationally related to the legitimate state interest of protecting religious liberty and provides adequate procedural protections. The Supreme Court of Kansas reversed the district court’s judgment and remanded the case for further proceedings. View "Powerback Rehabilitation v. Dept. of Labor" on Justia Law

An instrumentality of Iran attempted to wire nearly $10 million through an American bank, but the funds were blocked by the U.S. government under the International Emergency Economic Powers Act (IEEPA) due to Iran’s designation as a state sponsor of terrorism. Two groups of plaintiffs, each holding substantial judgments against Iran for its support of terrorist acts, sought to attach these blocked funds to satisfy their judgments. The funds had been frozen by the Office of Foreign Assets Control (OFAC) and were the subject of a pending civil-forfeiture action initiated by the United States.The United States District Court for the District of Columbia initially quashed the plaintiffs’ writs of attachment. The court reasoned, first, that the funds were not “blocked assets” as defined by the Terrorism Risk Insurance Act (TRIA) and thus were immune from attachment. Second, it held that the government’s earlier-filed civil-forfeiture action invoked the prior exclusive jurisdiction doctrine, barring any subsequent in rem proceedings against the same property. The district court also noted that the existence of the Victims of State Sponsored Terrorism Fund suggested Congress did not intend to encourage individual attachment actions.On appeal, the United States Court of Appeals for the District of Columbia Circuit reversed. The court held that the funds in question are “blocked assets” under TRIA, as they remain frozen by OFAC and are not subject to a license required by a statute other than IEEPA. The court further held that the prior exclusive jurisdiction doctrine does not bar multiple in rem proceedings filed in the same court. Accordingly, the court concluded that neither sovereign immunity nor the prior exclusive jurisdiction doctrine prevented the plaintiffs from seeking attachment of the funds and reversed the district court’s order quashing the writs of attachment. View "Estate of Levin v. Wells Fargo Bank, N.A." on Justia Law

A 16-year-old committed a violent home invasion, during which he sexually assaulted his former neighbor at knifepoint. He was convicted by a jury of multiple offenses, including rape, sodomy, oral copulation, robbery, burglary, and related enhancements. The original sentence was a combination of determinate and indeterminate terms, ultimately resulting in a total sentence of 44 years to life in prison, with parole eligibility at age 60 after a later modification.After serving more than 15 years, the defendant petitioned the Superior Court of Tulare County for recall and resentencing under California Penal Code section 1170(d), arguing that his sentence was the functional equivalent of life without parole (LWOP) and that excluding him from resentencing relief violated equal protection principles. The trial court denied the petition, finding that his sentence was not functionally equivalent to LWOP and that, under People v. Heard, he was not eligible for relief.On appeal, the California Court of Appeal, Fifth Appellate District, considered whether the functional equivalency analysis from People v. Contreras, which is rooted in Eighth Amendment jurisprudence, should apply to equal protection challenges under section 1170(d). The court declined to import the Eighth Amendment standard, instead applying a rational basis review as articulated in recent California Supreme Court decisions. The court held that the Legislature could rationally distinguish between juveniles sentenced to explicit LWOP and those, like the appellant, sentenced to lengthy terms with parole eligibility within their expected lifetimes. The court concluded that section 1170(d)’s limitation to LWOP sentences does not violate equal protection as applied to a 44-years-to-life sentence. The trial court’s denial of the petition was affirmed. View "People v. Baldwin" on Justia Law

Law enforcement officers obtained and executed a search warrant for “4279 Violet Circle, Lake Worth, FL,” believing it to be a single-family home occupied by the defendant. In reality, the property included a main residence and three efficiency apartments at the back, one of which was occupied by the defendant. These apartments had no separate addresses, mailboxes, or exterior markings. During the search, officers were directed by other residents to the defendant’s apartment, where they found firearms and drugs. The defendant was subsequently charged with multiple firearm and drug offenses.The defendant moved to suppress the evidence, arguing that the warrant was defective under the Fourth Amendment because it listed only the main address and not his specific apartment. The United States District Court for the Southern District of Florida held an evidentiary hearing, credited the testimony of the investigating officer, and found that the officers reasonably believed the property was a single-family home based on surveillance, property records, and the lack of distinguishing features for the apartments. The magistrate judge recommended denying the motion to suppress, and the district court adopted this recommendation. The defendant was found guilty after a stipulated-facts bench trial and sentenced to 144 months’ imprisonment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the denial of the motion to suppress. The court held that the search warrant satisfied the Fourth Amendment’s particularity requirement because the officers reasonably believed, after a diligent investigation, that the property was a single-family home. The court found no evidence that the officers knew or should have known about the separate apartments before executing the warrant. The court affirmed the denial of the motion to suppress and remanded for correction of a clerical error in the judgment. View "United States v. Schmitz" on Justia Law