Justia Constitutional Law Opinion Summaries

In December 1990, Victor Tony Jones fatally stabbed his employers, Jacob and Matilda Nestor, during a robbery at their business in Miami-Dade County. Jones was found at the scene with the victims’ belongings and admitted to the killings at the hospital. He was convicted by a jury of two counts of first-degree murder and two counts of armed robbery. The trial court, following the jury’s recommendation, imposed death sentences for both murders, citing three aggravating factors and no mitigation. The Florida Supreme Court affirmed the convictions and sentences, and the United States Supreme Court denied certiorari in 1995.Over the following decades, Jones filed multiple unsuccessful motions for postconviction relief in the Circuit Court for Miami-Dade County and petitions for habeas corpus in state and federal courts. After Governor Ron DeSantis signed Jones’s death warrant in August 2025, Jones filed a sixth successive motion for postconviction relief, arguing newly discovered evidence of abuse at the Okeechobee School for Boys, racial disparities in Miami-Dade capital prosecutions, and due process violations in the warrant process. He also made post-warrant demands for public records related to the Okeechobee School. The circuit court summarily denied all claims and records requests.The Supreme Court of Florida reviewed the appeal and petition. It held that Jones’s claim of newly discovered evidence regarding abuse at the Okeechobee School was procedurally barred and meritless, as the alleged abuse was known to Jones long before trial and did not constitute evidence likely to yield a life sentence on retrial. The court also found no due process violation in the warrant process and no abuse of discretion in denying Jones’s public records requests. The habeas petition was denied as an improper attempt to relitigate previously decided issues. The court affirmed the circuit court’s orders, denied all relief, and refused to entertain any rehearing. View "Jones v. State" on Justia Law

A white man, after a dinner in Palm Harbor, Florida, targeted a Black man, his girlfriend, and his four-year-old daughter as they drove on a county-administered public road. The defendant, whom the victims did not know, repeatedly attempted to run their car off the road, shouted racial slurs, and made threatening gestures. At a red light, he exited his vehicle and physically confronted the Black man, continuing his racial abuse. Witnesses and police confirmed the defendant’s aggressive and racially charged conduct, and the defendant made further racist statements to law enforcement after his arrest. The defendant’s ex-girlfriend testified that such behavior was typical for him.A grand jury in the United States District Court for the Middle District of Florida indicted the defendant on two counts of violating 18 U.S.C. § 245(b)(2)(B), which prohibits racially motivated interference with the use of public facilities. The defendant moved to dismiss the indictment, arguing that the statute exceeded Congress’s authority under the Thirteenth Amendment and the Commerce Clause, and that the indictment violated the Double Jeopardy Clause. The district court denied these motions. At trial, the court instructed the jury that to convict, it must find the defendant acted “because of” the victim’s use of the public road, applying a “but-for” causation standard. The jury found the defendant guilty on one count and not guilty on the other. The district court denied the defendant’s motions for acquittal and a new trial, and sentenced him to 24 months in prison.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that 18 U.S.C. § 245(b)(2)(B) is a constitutional exercise of Congress’s power under the Thirteenth Amendment, as Congress may rationally prohibit racially motivated violence interfering with public facilities as a badge or incident of slavery. The court also found no error in the jury instructions, the handling of jury questions, or the sufficiency of the evidence. The conviction was affirmed. View "United States v. Leahy" on Justia Law

The petitioner was convicted in 2016 of conspiracy to commit robbery, burglary, robbery, and first-degree kidnapping, receiving concurrent sentences including 8 to 20 years for robbery and 5 years to life for kidnapping. In November 2022, the Nevada Board of Parole Commissioners assessed him as a high risk to reoffend, denied parole, and scheduled his next hearing for January 2025. The petitioner requested a reassessment, arguing the risk level was incorrect. The Board found an error, reassessed him as moderate risk, and held a new hearing in April 2023, but again denied parole and rescheduled the next hearing for November 2025, nine months later than originally set.The petitioner sought a writ of mandamus from the Supreme Court of the State of Nevada, arguing that the Board unlawfully punished him for seeking reconsideration by delaying his next parole hearing. He claimed this delay was vindictive and violated his due process rights, relying on the presumption of vindictiveness established in North Carolina v. Pearce, 395 U.S. 711 (1969), and its progeny.The Supreme Court of the State of Nevada held that the presumption of vindictiveness may generally arise in parole proceedings if the Board, upon reconsideration, extends the time before a prisoner may be considered for parole again. However, the court concluded that the presumption does not apply when the Board corrects its own error without prompting from an outside tribunal. The court further found that the petitioner failed to demonstrate actual vindictiveness. The Board acted within its statutory discretion in scheduling the next hearing, and the petition for writ relief was denied. View "Stewart v. Board of Parole Commissioners" on Justia Law

The defendant and his then-wife, J, lived in Deschutes County, Oregon, and their marriage ended in divorce proceedings after J obtained a restraining order against the defendant. The criminal charges arose from two separate incidents: one in December 2016, when the defendant dragged J from their bedroom to the yard in freezing weather, and another in July 2017, when the defendant damaged J’s car with a power drill and made threatening statements. The December incident led to a second-degree kidnapping charge, while the July incident resulted in a menacing charge. The state also filed a motion in limine to limit certain evidence related to the divorce proceedings.The Deschutes County Circuit Court denied the defendant’s motions for judgment of acquittal on both charges and granted the state’s motion in limine in part, restricting argument about whether J gained a tactical advantage in the divorce from her allegations. The jury convicted the defendant of both kidnapping and menacing. On appeal, the Oregon Court of Appeals, sitting en banc, affirmed both convictions, though several judges dissented on aspects of the kidnapping and menacing rulings and the scope of the motion in limine.The Supreme Court of the State of Oregon reviewed the case. It held that the evidence was insufficient to support the kidnapping conviction because the movement of J did not constitute taking her “from one place to another” as required by ORS 163.225(1)(a); specifically, the movement did not increase her isolation or restrict her freedom of movement in the manner contemplated by the statute. The court reversed the kidnapping conviction. However, the court affirmed the menacing conviction, finding that the defendant’s words and conduct were sufficient for a rational factfinder to conclude he intended to place J in fear of imminent serious physical injury. The court also affirmed the trial court’s ruling on the motion in limine. The case was remanded for further proceedings consistent with these holdings. View "State v. Anderson" on Justia Law

The defendant was charged in a single indictment with multiple counts of sexual abuse involving two minor victims, A and M, who are cousins. The alleged conduct toward A spanned four years and involved repeated touching, while the conduct toward M consisted of two isolated incidents. The defendant moved to sever the charges relating to each victim, arguing that joinder would cause substantial prejudice, particularly because the evidence against M was weaker and the jury might improperly use the stronger evidence regarding A to convict on the charges involving M. The trial court denied the motion to sever, and the case proceeded to trial. The jury convicted the defendant on all counts involving A and one count involving M.On appeal, the Oregon Court of Appeals affirmed the trial court’s denial of the motion to sever, finding that the defendant had not shown substantial prejudice beyond that inherent in joinder. However, the Court of Appeals reversed the mandatory 75-month Measure 11 sentence imposed for the conviction involving M, holding that it was unconstitutionally disproportionate under the Oregon Constitution.The Supreme Court of the State of Oregon reviewed both issues. It held that the trial court erred in denying the motion to sever because the defendant had articulated a case-specific theory of substantial prejudice, supported by the record, as required by State v. Delaney. The Supreme Court clarified that when such a showing is made, the trial court must provide some remedy to address the prejudice. However, the error was deemed harmless as to the counts involving A, so those convictions were affirmed. The conviction involving M was reversed and remanded for a new trial. The Supreme Court did not reach the sentencing issue in light of this disposition. The Court of Appeals’ decision was affirmed in part and reversed in part, and the case was remanded to the circuit court for further proceedings. View "State v. Hernandez-Esteban" on Justia Law

In 1985, a 20-year-old individual committed a burglary that resulted in the fatal stabbing of a 14-year-old boy. The following year, a jury convicted him of aggravated first degree murder. At that time, Washington law required a mandatory sentence of life without the possibility of parole (LWOP) for such a conviction, and the sentencing judge stated he had no discretion to impose any other sentence. The individual has been incarcerated for nearly 40 years under this sentence.After his conviction and sentence were affirmed by the Washington Court of Appeals in 1988, the petitioner sought resentencing in 2023, arguing that recent Washington Supreme Court decisions—specifically In re Personal Restraint of Monschke and State v. Carter—rendered his mandatory LWOP sentence unconstitutional. The King County Superior Court transferred his motion to the Court of Appeals, which then certified the case for direct review by the Washington Supreme Court.The Supreme Court of the State of Washington held that its decision in Monschke constituted a significant change in the law, exempting the petitioner’s claim from the one-year time bar for collateral relief. The court found that mandatory LWOP sentences for individuals aged 18 to 20 at the time of their offense, imposed without consideration of youth as a mitigating factor, are unconstitutional under the state constitution’s prohibition on cruel punishment. The court further held that a petitioner in this situation demonstrates actual and substantial prejudice if Monschke is material to their sentence. The court granted the personal restraint petition and remanded the case to the trial court for a new sentencing hearing. View "In re Personal Restraint of Schoenhals" on Justia Law

A man was convicted by a jury in Greene County, Arkansas, of five counts of rape involving a minor victim. The case involved evidence obtained from the defendant’s cell phone, including pornographic images, and testimony from the victim describing multiple incidents of sexual abuse, the use of sex toys, and exposure to child pornography. The victim’s account was corroborated by physical evidence, DNA analysis, and expert testimony from a sexual assault nurse examiner. The defendant denied the allegations, attributing the accusations to the victim’s desire to avoid blame for unrelated misconduct.After the conviction, the Arkansas Court of Appeals reversed and remanded, finding error in the admission of certain evidence. The State petitioned for review, which the Supreme Court of Arkansas granted, thereby reviewing the case as if it had been originally filed there. The defendant argued that the circuit court erred in denying his motion to suppress evidence from his cell phone, claiming the search warrant was facially deficient and lacked probable cause, and that the court improperly allowed cross-examination about prior orders of protection involving his girlfriend, in violation of evidentiary rules.The Supreme Court of Arkansas held that the circuit court did not err in denying the motion to suppress, finding that, under the totality of the circumstances, the officers acted in good faith and the warrant was not so deficient as to preclude reliance on it. The court also found that the circuit court abused its discretion in admitting evidence about the orders of protection, but concluded that the error was harmless because the evidence of guilt was overwhelming and the prejudicial effect was slight. The Supreme Court of Arkansas affirmed the convictions and vacated the opinion of the Court of Appeals. View "VASQUEZ v. STATE OF ARKANSAS" on Justia Law

Katie Orndoff appeared as a witness for the prosecution in a felony domestic assault jury trial in the Circuit Court for Loudoun County. During her testimony, she repeatedly referenced the defendant’s prior arrests and incarceration, despite admonitions from the court and objections from defense counsel. The circuit court observed that Orndoff’s demeanor was unusual, including rocking in her chair and nearly falling over, and questioned her about possible substance use. Orndoff admitted to smoking marijuana earlier that day. The circuit court found her in summary contempt for “misbehavior in the presence of the court” due to voluntary intoxication, sentenced her to ten days in jail, and declared a mistrial.Orndoff appealed her contempt conviction to the Court of Appeals of Virginia. A three-judge panel reversed the circuit court’s finding, holding that the trial judge did not personally observe all essential elements of the alleged contempt and improperly relied on Orndoff’s admission rather than direct observation. The panel found that summary contempt was inappropriate and that Orndoff’s due process rights were violated. Upon rehearing en banc, the Court of Appeals was evenly divided, resulting in an affirmance of the circuit court’s judgment without opinion.The Supreme Court of Virginia reviewed the case and applied an abuse of discretion standard. It held that summary contempt requires the judge to personally observe all essential elements of the misconduct in open court. The Supreme Court found that the evidence did not establish beyond a reasonable doubt that Orndoff was voluntarily intoxicated while testifying, as the circuit court’s findings were contradicted by the record and relied on unreliable admissions. The Supreme Court reversed the judgment of the Court of Appeals, reversed the circuit court’s contempt finding, and vacated Orndoff’s conviction. View "Orndoff v. Commonwealth" on Justia Law

In this case, the defendant was found in possession of a firearm after having previously been convicted of multiple felonies, including several burglaries. When law enforcement approached his girlfriend’s home, he cooperated and led them to a pistol hidden in the woods, which bore his fingerprints. He was indicted on one count of being a felon in possession of a firearm. The presentence report listed twenty-two prior felony convictions, eleven of which were for burglary, with the offenses occurring over several years and involving different victims.The United States District Court for the Eastern District of Tennessee accepted the defendant’s guilty plea. At sentencing, the court determined, based on the presentence report, that the defendant qualified as an Armed Career Criminal under the Armed Career Criminal Act (ACCA), which mandates a minimum sentence for those with three prior violent felony convictions committed on different occasions. The court imposed a 180-month sentence. The defendant did not object to the factual accuracy of the presentence report but later challenged the application of the ACCA enhancement, arguing that the determination of whether his prior offenses were committed on different occasions should have been made by a jury, as clarified by the Supreme Court in Erlinger v. United States.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the failure to submit the “different occasions” question to a jury was not structural error and that, under harmless error review, no reasonable jury could have found that the defendant’s predicate burglaries occurred on the same occasion, given the significant gaps in time and different victims. The court also rejected the defendant’s double jeopardy argument, finding no plain error. The Sixth Circuit affirmed the enhanced sentence under the ACCA. View "United States v. Ballinger" on Justia Law

Several development groups entered into a public improvement contract with a Texas city, purchasing over 60 acres of land, much of it in a flood zone. The developers received a variance from the city, exempting them from obtaining a federal floodplain permit (CLOMR), and invested significant funds in developing the property, including constructing a bridge. In 2018, the parties executed updated agreements, including a Master Development Agreement (MDA), which required certain conditions to be met within five years or the contract would automatically terminate, ending the city’s reimbursement obligations. As the deadline approached, the city informed the developers that they would now need to obtain the previously waived CLOMR, citing a later-enacted ordinance. Unable to comply in time, the developers sought an extension, which the city council denied, resulting in termination of the MDA.The developers sued in Texas state court, alleging the city’s actions constituted an unconstitutional taking under federal and state law, and also brought claims for breach of contract and violations of the Texas Vested Rights Statute. The city removed the case to the United States District Court for the Northern District of Texas and moved to dismiss. The district court dismissed the federal takings and declaratory judgment claims, finding the developers had not sufficiently alleged that the city acted in its sovereign rather than commercial capacity, and remanded the remaining state-law claims to state court.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed. The court held that the developers’ allegations arose from a contractual dispute, not a sovereign act by the city, and thus did not state a plausible takings claim under the Fifth Amendment. The court also found no abuse of discretion in the district court’s decision to dismiss the declaratory judgment claim, as the core issues would be resolved in the remanded state court action. View "Mesquite Asset Recovery Grp v. City of Mesquite" on Justia Law