Justia Constitutional Law Opinion Summaries

The defendant was charged with reckless driving and recklessly endangering another person. Unable to secure counsel, the defendant represented himself at trial, where his arguments were not responsive to the charges, leading to his conviction by a jury. On appeal, the defendant continued to represent himself, filing a pro se brief with arguments similar to those made at trial. The state interpreted the brief as challenging the sufficiency of the evidence, and the Court of Appeals affirmed the convictions in a nonprecedential opinion.After the defendant was appointed appellate counsel in a separate case, the Court of Appeals also appointed counsel for this case. However, the case had already been submitted for decision. The appellate counsel filed an emergency motion to withdraw the case from submission to file a brief, arguing that the defendant had not validly waived his right to counsel and that the trial court erred in not ordering a competency evaluation. The Court of Appeals denied the motion but invited a petition for reconsideration, which was also denied.The Oregon Supreme Court reviewed the case and allowed the petition for review. The court granted the joint motion for remand, vacating the Court of Appeals' decision and the circuit court’s judgment of conviction. The Supreme Court agreed with the parties that the record did not show the defendant had validly waived his right to counsel, as there was no colloquy or indication of a knowing and intelligent waiver. The case was remanded to the circuit court for further proceedings, ensuring the defendant's right to a new trial with proper legal representation. View "State v. Cotter" on Justia Law

The City of Tea passed a resolution imposing a special assessment on properties abutting a road construction project, including property owned by KJD, LLC. The City found that the improvement conferred special benefits on the abutting properties beyond those experienced by the public. KJD objected to the assessment, arguing it was unconstitutional as the project did not confer a special benefit on its property. The circuit court held that KJD did not rebut the presumption that the City’s assessment was valid and did not prove by clear and convincing evidence that the City’s findings were incorrect, thus denying KJD’s objection.KJD appealed to the Supreme Court of South Dakota. The Supreme Court reviewed the case de novo, noting that the City’s findings in its resolution are presumed correct and that KJD had the burden to rebut this presumption with substantial, credible evidence. The Court found that KJD failed to present such evidence, particularly as it did not provide testimony or evidence at a trial to counter the City’s findings. The Court also noted that the City’s method of calculating the assessment based on the cost of the project was constitutionally permissible and that the City’s findings regarding the special benefits, such as improved aesthetics and safety, were supported by the project’s features.The Supreme Court of South Dakota affirmed the circuit court’s decision, holding that KJD did not meet its burden to prove that the special assessment was unconstitutional. The Court concluded that the City’s findings and the special assessment were valid and did not exceed the value of the benefits conferred on KJD’s property. View "KJD, LLC v. City of Tea" on Justia Law

Jonathan and Melissa Brizendine applied to become foster parents in January 2022. After completing their application, a DHS employee conducted a home visit and asked various questions, including about their religious affiliation. The Brizendines, who are non-religious, were also asked to provide additional information on Melissa’s PTSD and medical-marijuana use. On May 19, 2022, DHS denied their foster-parent application. The Brizendines filed a complaint on June 8, 2023, alleging that their application was denied due to their atheism and medical-marijuana use, claiming violations of the Arkansas Constitution, the Religious Freedom Restoration Act, and the Arkansas Medical Marijuana Amendment.The Pulaski County Circuit Court granted the State appellees' motion to dismiss, concluding that the Brizendines' complaint failed to state a claim under Arkansas Rule of Civil Procedure 12(b)(6) and that the State appellees were entitled to sovereign immunity. The court found that the Brizendines did not plead sufficient facts to show that the State’s actions were illegal or unconstitutional.The Supreme Court of Arkansas reviewed the case and affirmed the circuit court's decision. The court held that the Brizendines' complaint was speculative and did not meet the fact-pleading requirements necessary to overcome sovereign immunity. The court noted that the complaint lacked specific facts to support the claim that DHS denied the application based on religious preferences and medical-marijuana use. Additionally, the complaint did not establish any involvement of Governor Sanders or the Child Welfare Agency Review Board in the application process. Therefore, the State appellees were entitled to sovereign immunity, and the dismissal was affirmed. View "Brizendine v. Department of Human Services" on Justia Law

In March 2023, the State charged Christopher Allman with multiple counts of domestic violence, felonious restraint, and terrorizing, alleging he assaulted his wife and their live-in girlfriend, locked them in a room, and refused to let them leave. The parties agreed Allman would undergo a mental health examination to determine his criminal responsibility. The examination was delayed due to issues with obtaining Allman’s records from the Veterans Administration. The evaluation, completed in August 2024, concluded Allman did not suffer from a mental condition precluding criminal liability. A jury trial in August 2024 resulted in guilty verdicts on all counts, and Allman was sentenced to consecutive five-year terms of imprisonment, with credit for time served on one count.The District Court of McKenzie County, Northwest Judicial District, oversaw the initial proceedings. Allman appealed, arguing errors related to the criminal responsibility evaluation, his fitness to stand trial, his right to a speedy trial, and the legality of his sentence. He claimed his constitutional rights were violated by the evaluation order, asserting it was against his will and violated his right against self-incrimination. He also argued the court should have ordered a fitness evaluation and that his right to a speedy trial was denied due to the delays in obtaining his mental health records.The Supreme Court of North Dakota reviewed the case. It held that the district court did not err in ordering the criminal responsibility evaluation because the parties had stipulated to it. The court found no grounds to doubt Allman’s fitness to stand trial and noted he did not request a fitness evaluation. The court also determined that Allman’s right to a speedy trial was not violated, as the delays were not due to the State’s conduct, and Allman did not properly assert his right. Finally, the court affirmed the legality of Allman’s sentence, rejecting his argument about credit for time served. The Supreme Court of North Dakota affirmed the district court’s judgment. View "State v. Allman" on Justia Law

Three organizations, Inclusive Louisiana, Mount Triumph Baptist Church, and RISE St. James, sued St. James Parish, the Parish Council, and the Parish Planning Commission, alleging violations of their constitutional and statutory civil rights. They claimed that the Parish discriminated against them by directing hazardous industrial development towards majority-Black districts and Black churches, where their members and congregants live. They also argued that the Parish's actions desecrated and restricted access to cemeteries of their enslaved ancestors.The United States District Court for the Eastern District of Louisiana dismissed all claims. It held that the plaintiffs lacked standing for some claims and that other claims were time-barred, as they were based on the Parish's 2014 Land Use Plan. The court also dismissed claims related to religious injuries, stating that the injuries were not traceable to the Parish's actions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court erred in dismissing the claims as time-barred, noting that the plaintiffs alleged ongoing discriminatory practices, not just a single incident. The court also found that the plaintiffs had standing to sue for property injuries and health-related injuries. Additionally, the court held that the plaintiffs had standing to pursue claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA) and the Louisiana Constitution, as their alleged injuries were traceable to the Parish's conduct.The Fifth Circuit reversed the district court's dismissal of the claims and remanded the case for further proceedings. The court emphasized that the plaintiffs had sufficiently alleged ongoing discriminatory practices and injuries that were fairly traceable to the Parish's actions. View "Inclusive Louisiana v. St. James Parish" on Justia Law

Plaintiffs, Ohio voters and members of an initiative petition committee, sought to amend the Ohio Constitution through two ballot initiatives. The Ohio Attorney General, David Yost, rejected their proposed summaries eight times, preventing them from collecting signatures. Plaintiffs argued that this violated their First Amendment rights. The district court agreed, issuing a preliminary injunction ordering Yost to certify the summaries. However, the district court stayed the injunction pending appeal.The United States District Court for the Southern District of Ohio initially denied preliminary injunctive relief, but a panel of the Sixth Circuit reversed, finding that the fair-and-truthful review process likely violated Plaintiffs' First Amendment rights. The en banc Sixth Circuit later vacated this decision, deeming the case moot as the targeted election had passed. Plaintiffs then filed an amended complaint and sought a second preliminary injunction, which the district court granted, but stayed pending appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and agreed with the district court that Plaintiffs' First Amendment rights were likely violated. The court found that the fair-and-truthful certification process allowed the Attorney General to exercise editorial control over the petition summaries, which constituted a severe burden on Plaintiffs' core political speech. The court also determined that the other stay factors did not favor Yost. Consequently, the Sixth Circuit granted Plaintiffs' motion to lift the stay, allowing them to proceed with their petition efforts. View "Brown v. Yost" on Justia Law

A national consumer advocate law firm (C Co.) and its affiliate (S Co.) providing administrative support services sought injunctive and declaratory relief against the Department of Banking. The Department had initiated an administrative enforcement action against S Co. for allegedly engaging in unlicensed debt negotiation activities. The plaintiffs argued that S Co. was exempt from licensing requirements under a presumption established in a prior case (Persels & Associates, LLC v. Banking Commissioner), which holds that attorneys providing debt negotiation services as part of their legal practice fall under the exclusive regulation of the Judicial Branch.The trial court denied the Department's motion to dismiss the plaintiffs' action, concluding that the plaintiffs were not required to exhaust administrative remedies before seeking judicial intervention on whether the Persels presumption applied to S Co. The Department appealed, arguing that the Commissioner of Banking should first determine whether the presumption applied.The Supreme Court of Connecticut affirmed the trial court's decision, holding that the plaintiffs were not required to exhaust administrative remedies before seeking judicial intervention. The court reasoned that the Commissioner of Banking lacks the expertise to determine whether the Persels presumption applies, as this involves assessing whether the activities in question constitute the practice of law, which falls under the exclusive authority of the Judicial Branch. The court emphasized that allowing the commissioner to make this determination would violate the constitutional separation of powers. Therefore, the plaintiffs could seek declaratory and injunctive relief in the trial court without waiting for the commissioner to resolve the issue. View "Commonwealth Servicing Group, LLC v. Dept. of Banking" on Justia Law

In November 2004, Julio Rodríguez-Méndez participated in a carjacking in Puerto Rico while possessing a firearm. He was first prosecuted in a Puerto Rico Commonwealth court for robbery of a motor vehicle and carrying a weapon without a license, to which he pleaded guilty and was sentenced to twelve years in prison. Subsequently, a federal grand jury indicted him on three counts related to the same carjacking, including unlawful possession of a firearm by a felon. Rodríguez pleaded guilty to the felon-in-possession count, and the other charges were dismissed. He was sentenced to 216 months in prison, partly due to being classified as an armed career criminal under the Armed Career Criminal Act (ACCA).Rodríguez filed a motion under 28 U.S.C. § 2255 seeking to vacate his conviction on double jeopardy grounds and to challenge his ACCA enhancement. The United States District Court for the District of Puerto Rico denied his motion, holding that double jeopardy did not apply and that his prior convictions for motor vehicle robbery qualified as ACCA predicates.The United States Court of Appeals for the First Circuit reviewed the case. The court rejected Rodríguez's double jeopardy claim, stating that the federal felon-in-possession offense and the Commonwealth firearm offense are separate offenses under the Blockburger test, as each requires proof of an element that the other does not. However, the court agreed with Rodríguez that his prior convictions under Article 173B of the Puerto Rico Penal Code did not qualify as ACCA predicates. The court found that the statute's definition of "intimidation" was broader than the ACCA's requirement for violent felonies, as it included threats against property, not just persons.The First Circuit affirmed the district court's denial of Rodríguez's double jeopardy claim but reversed the denial of his § 2255 motion regarding the ACCA enhancement, vacating his sentence and remanding for resentencing. View "Rodriguez-Mendez v. United States" on Justia Law

In 2011, Winston Sylvester Oliver II and his co-defendant, Warren Brown, were convicted of conspiracy to commit Hobbs Act robbery, attempted Hobbs Act robbery, and use of a firearm during these crimes. Oliver's firearm convictions were later vacated, necessitating resentencing for the remaining convictions. At his resentencing, Oliver argued that his Fifth and Sixth Amendment rights were violated when the court allowed Brown to invoke his Fifth Amendment right against self-incrimination due to his pending appeal. Oliver also contended that his sentence was procedurally and substantively unreasonable.The United States District Court for the Eastern District of Virginia initially sentenced Oliver to 630 months in prison. After his firearm convictions were vacated, the court resentenced him to 610 months. On appeal, the Fourth Circuit vacated his remaining firearm conviction and remanded for resentencing. At the second resentencing, Oliver's motion to recuse the entire bench of the Eastern District of Virginia was denied. The district court allowed Brown to invoke his Fifth Amendment right, excluded unauthenticated letters allegedly written by Brown, and calculated Oliver's Guidelines range, ultimately sentencing him to 480 months in prison.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court did not abuse its discretion in allowing Brown to invoke his Fifth Amendment right, as his testimony could have had adverse consequences due to his pending appeal. The court also found that the district court did not err in applying sentencing enhancements for Oliver's leadership role, obstruction of justice, and firearm discharge. The court concluded that the 480-month sentence was substantively reasonable, considering Oliver's extensive criminal history and the impact on the victims. The Fourth Circuit affirmed the district court's judgment. View "United States v. Oliver" on Justia Law

A journalist, Simon Ateba, sought preferred access to the White House Press Area through a special press credential known as a "hard pass." The White House issues hard passes only to reporters accredited by either the Supreme Court Press Gallery or a congressional press gallery. Ateba applied for membership in the Senate Daily Press Gallery as a prerequisite to securing a hard pass, but his application was still under consideration. In the meantime, he accessed the Press Area with a daily pass, which required him to wait for an escort. Ateba argued that the White House Hard Pass Policy violated the First Amendment because it burdened his access and conditioned fuller access on accreditation by the Senate Daily Press Gallery, which he claimed exercised unbridled discretion.The United States District Court for the District of Columbia granted summary judgment in favor of the White House. The court concluded that while Ateba had suffered a cognizable First Amendment injury, the White House acted reasonably under the First Amendment by outsourcing part of its press-credentialing process. The district court also ruled that the Senate Daily Press Gallery did not impermissibly exercise discretion in deciding who could become a member and that extraordinary procedural protections were not constitutionally required.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's judgment. The court held that the White House Hard Pass Policy was both reasonable and viewpoint neutral. It found that the policy's reliance on external credentialing bodies was reasonable given the White House's lack of its own vetting system. The court also determined that the Senate Daily Press Gallery's membership criteria, including the "of repute" standard, did not confer unbridled discretion because it was guided by concrete rules. Additionally, the court held that the First Amendment did not require the gallery to set a deadline for processing membership applications. View "Ateba v. Leavitt" on Justia Law