Justia Constitutional Law Opinion Summaries

In 1999, Sedrick White, then 20 years old, entered a blind guilty plea to one count of first-degree murder and was sentenced to 40 years in prison by the Cook County circuit court. Over 20 years later, White filed a pro se petition for postjudgment relief under section 2-1401(f) of the Code of Civil Procedure, arguing that his 40-year sentence constituted a de facto life sentence in violation of the Eighth Amendment of the U.S. Constitution and the proportionate penalties clause of the Illinois Constitution. The circuit court denied the petition, stating that the sentence did not violate the Eighth Amendment or the proportionate penalties clause.White appealed the circuit court's decision, arguing that his 40-year sentence violated the proportionate penalties clause. The appellate court affirmed the circuit court's decision, holding that White's guilty plea waived any potential constitutional claim regarding his sentence. The appellate court also found that the circuit court did not err in failing to recharacterize White's section 2-1401 petition as a petition under the Post-Conviction Hearing Act.The Supreme Court of Illinois reviewed the case and agreed with the parties that White's blind guilty plea did not waive his constitutional challenge to his sentence. The court clarified that a defendant who enters a blind guilty plea, with no agreement as to the sentence, does not waive the right to challenge the sentence. However, the court found that White's 40-year sentence was not a de facto life sentence and was not "wholly disproportionate to the offense as to shock the moral sense of the community." The court concluded that White failed to state a meritorious claim that his sentence violated the proportionate penalties clause and affirmed the judgments of the appellate court and the circuit court. View "People v. White" on Justia Law

Chad R. Clausen was charged with violating Nebraska’s Sex Offender Registration Act (SORA) after an investigation revealed he had been intermittently staying at his fiancé’s house without notifying authorities. Clausen was registered under SORA at an address in Douglas County, Nebraska, but law enforcement received an anonymous tip that he was residing at a Washington County address. Evidence showed that Clausen had been staying at his fiancé’s residence in Washington County for several months. Clausen admitted to staying there for three days and then returning to his registered address for three days. The district court found Clausen guilty of violating SORA, determining that he had established a habitual living location and temporary domicile at his fiancé’s house without registering.Clausen appealed to the Nebraska Court of Appeals, arguing that the State failed to prove he established a habitual living location or temporary domicile and that the definitions of these terms were unconstitutionally vague. The Court of Appeals affirmed the conviction, interpreting the definitions in line with a federal district court decision in Doe v. Nebraska, which required a person to stay at a location for three consecutive weekdays to establish a temporary domicile. The Court of Appeals found that Clausen’s admission of staying at the Washington County residence “most nights” allowed a rational trier of fact to conclude he stayed there for three consecutive weekdays.The Nebraska Supreme Court reviewed the case and disagreed with the Court of Appeals’ interpretation. The Supreme Court held that “working days” in the context of SORA refers to Mondays through Fridays, excluding legal holidays. The Court found that there was insufficient evidence to prove Clausen stayed at the Washington County residence for three consecutive weekdays or more than three consecutive days. Consequently, the Supreme Court reversed Clausen’s conviction and vacated his sentence, concluding that the State failed to prove he violated SORA’s registration requirements. View "State v. Clausen" on Justia Law

Damion Giglio, while on supervised release for a previous felony, was arrested and convicted for violating 18 U.S.C. § 922(g)(1), the felon-in-possession statute. He appealed, arguing that the statute is unconstitutional as applied to him and that the district court erred in calculating his sentencing guideline range, entitling him to a less severe sentence.The United States District Court for the Southern District of Mississippi denied Giglio's motion to dismiss the indictment, rejecting his constitutional challenge. Giglio pleaded guilty, and the court sentenced him to 27 months' imprisonment, noting that it would have imposed the same sentence regardless of any potential guideline calculation errors.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the government could regulate Giglio’s firearm possession without violating the Second Amendment, as historical practices support disarming individuals serving criminal sentences. The court also found that any error in the sentencing guideline calculation was harmless because the district court explicitly stated it would have imposed the same sentence regardless of the guideline range.The Fifth Circuit affirmed the district court's decision on both grounds, upholding Giglio's conviction and sentence. View "United States v. Giglio" on Justia Law

A father appealed a Family Court order terminating his parental rights. The Department of Services for Children, Youth and their Families (DFS) took custody of the father's son shortly after birth due to the father's mental health issues, substance abuse, unstable housing, employment status, previous involvement with DFS, history of domestic violence, and failure to plan for the child. DFS moved to be excused from case planning with the father under 13 Del. C. § 1103(d), arguing that grounds for termination existed under 13 Del. C. § 1103(a)(7) because the father's parental rights to another child had been involuntarily terminated in an earlier proceeding. The Family Court granted the motion and later terminated the father's parental rights after finding clear and convincing evidence that termination was in the best interests of the child.The father argued on appeal that Section 1103(d) is unconstitutional. The Supreme Court of Delaware reviewed the case and concluded that Section 1103(d) is not unconstitutional as applied to the father. The court found that the Family Court's analysis under Sections 1103(a)(7) and 1103(d) was supported by the record and that termination of the father's parental rights was in the best interests of the child. The court also rejected the father's argument that the "least restrictive means" standard should be applied, instead following the due process framework established by the U.S. Supreme Court in Mathews v. Eldridge.The Supreme Court of Delaware affirmed the Family Court's judgment, holding that the statutory grounds for termination were met and that the termination was in the best interests of the child. The court found that the father received sufficient process before the termination of his parental rights and that the Family Court's findings were supported by clear and convincing evidence. View "Schnell v. Department of Services for Children, Youth and their Families" on Justia Law

The case involves a challenge to an Arizona law that requires criminal defense attorneys and their agents to initiate any contact with crime victims through the prosecutor’s office. The plaintiffs, a group of criminal defense attorneys and their association, argue that this law violates the First Amendment's Speech Clause by restricting their ability to communicate directly with victims.The United States District Court for the District of Arizona initially dismissed the case for lack of standing, but the Ninth Circuit Court of Appeals reversed that decision, allowing the case to proceed. On remand, the district court held a bench trial and concluded that the law was unconstitutional on its face, issuing a permanent injunction against its enforcement. The district court found that the law's requirement for defense attorneys to communicate through the prosecutor's office was a content- and viewpoint-based regulation of speech.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s judgment. The Ninth Circuit held that the plaintiffs' facial challenge failed because they did not challenge the law's primary application to victim-interview requests, which remain regulated under a similar Arizona Rule of Criminal Procedure. The court noted that the unchallenged applications of the law, which include requests for victim interviews, are substantial and legitimate. Therefore, the challenged applications related to non-interview contacts are not substantial enough to render the entire statute unconstitutional.The Ninth Circuit vacated the permanent injunction and remanded the case for entry of judgment in favor of the defendants, concluding that the facial challenge to the Victim Contact Limit, as framed by the plaintiffs, must fail. View "ARIZONA ATTORNEYS FOR CRIMINAL JUSTICE V. MAYES" on Justia Law

Curtis Wells parked his car near Arlington Cemetery and was noticed by Officer Armstrong due to his animated gestures while on a phone call. Armstrong approached Wells and discovered that his car had an expired registration. Arlington County police were called, and they found that Wells did not have a driver's license and had weapons in his car. The police decided to tow Wells's car and conducted an inventory search, which revealed various weapons and tactical gear, including a ballistic plate carrier. Wells was sent home, but further investigation suggested that the plate might have been stolen from the Army. Nine days later, Wells was arrested for receiving stolen property.In the United States District Court for the Eastern District of Virginia, Wells brought state and federal claims against various officers and entities, alleging Fourth and Fifth Amendment violations, among other claims. The district court dismissed all his claims, reasoning that the officers were protected by qualified immunity and that Wells had not plausibly alleged the necessary elements for his state tort claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the officers' actions were protected by qualified immunity because Wells did not have a clearly established right against the officers' conduct. The court found that the initial approach by Officer Armstrong was justified under the community-caretaking exception, the inventory search of Wells's car was conducted according to standard procedures, and Wells had consented to the safekeeping of his property. Additionally, the court held that Wells's Second Amendment claims failed because the right to public carry was not clearly established in 2020. The court also dismissed Wells's state law claims, finding that he had not plausibly alleged the necessary elements for false imprisonment or malicious prosecution. View "Wells v. Fuentes" on Justia Law

Courthouse News Service, a news organization, sought remote online access to civil court records from the Circuit Court for Prince William County, Virginia, similar to the access granted to Virginia attorneys. Virginia law prohibits the clerk from providing such access to non-attorneys. Courthouse News sued, claiming this restriction violated its First Amendment and Equal Protection rights.The United States District Court for the Eastern District of Virginia dismissed Courthouse News's Equal Protection claim and granted summary judgment for the defendants on the First Amendment claims. The court found the restrictions to be content-neutral time, place, and manner regulations justified by the state's interests in the orderly administration of justice and protecting sensitive personal information.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's ruling on the First Amendment and Equal Protection claims, holding that the access restriction was a content-neutral regulation narrowly tailored to serve significant governmental interests. The court found that the restriction did not violate the First Amendment as it provided ample alternative channels for accessing court records and did not burden more access than necessary. The court also concluded that the restriction did not violate the Equal Protection Clause for the same reasons it passed First Amendment scrutiny.However, the court vacated the district court's ruling on the Dissemination Restriction claim, finding that Courthouse News lacked standing to challenge it since the restriction only applied to those with remote access, which Courthouse News did not have. The case was remanded for the district court to dismiss this claim without prejudice. View "Courthouse News Service v. Smith" on Justia Law

The defendant was convicted of possessing child pornography in the first degree, which requires proof of possessing fifty or more images of child pornography. The New Britain Police Department obtained a search warrant for the defendant’s cell phone, which revealed images of suspected child pornography. The state introduced fifty-seven images at trial, and the defendant was found guilty by a jury.The defendant appealed, arguing that thirteen of the images did not constitute child pornography as they depicted mere nudity, which is protected under the First Amendment. He also contended that the trial court improperly instructed the jury on the Dost factors, which are used to determine whether an image depicts a lascivious exhibition of the genitals or pubic area. The trial court had instructed the jury that it could consider these factors but was not obligated to do so.The Connecticut Supreme Court reviewed the case and concluded that at least eleven of the thirteen challenged images depicted a lascivious exhibition of the genitals or pubic area, thus constituting child pornography. The court also determined that the first five Dost factors are helpful in assessing whether a depiction is lascivious but should not be used to define the term. The sixth Dost factor, which considers whether the image is intended to elicit a sexual response in the viewer, should not be used in possession cases as it introduces a subjective element.The court found that the trial court’s instruction on the Dost factors, including the sixth factor, did not mislead the jury. The court also held that a specific unanimity instruction was not required, as the different images and categories of sexually explicit conduct are merely means of proving the elements of the offense. The court affirmed the trial court’s decision to admit exhibits showing file names of deleted images associated with the defendant’s email address, as they were probative of the defendant’s knowledge and possession of child pornography. The judgment was affirmed. View "State v. Inzitari" on Justia Law

Two state forensic chemists in Massachusetts tampered with drug evidence and falsified test results, affecting tens of thousands of drug cases. The Massachusetts Supreme Judicial Court (SJC) vacated over 30,000 criminal cases due to this misconduct. The SJC ruled that under the Fourteenth Amendment, affected individuals were entitled to the repayment of most funds collected due to their vacated convictions but not the automatic return of forfeited property. Instead, individuals had to file motions for relief from judgment under Rule 60(b) of the Massachusetts Rules of Civil Procedure.The plaintiffs, whose criminal convictions were vacated, sought a federal court order for the automatic return of their forfeited property and related relief. The Commonwealth defendants moved to dismiss the complaint, arguing that the claims were barred by the Eleventh Amendment, which prohibits suits in federal court against a state by its own citizens. The United States District Court for the District of Massachusetts dismissed the complaint in part, ruling that it could not order the automatic return of forfeited property but allowed other claims to proceed under the Ex parte Young exception to the Eleventh Amendment.The United States Court of Appeals for the First Circuit reviewed the case and concluded that the Eleventh Amendment bars all the relief sought by the plaintiffs. The court held that the plaintiffs' claims focused on a past wrong, and the Ex parte Young exception applies only to prospective relief against ongoing violations of federal law. Additionally, the state officials sued lacked the authority to enforce or change the state court procedures. The court reversed the district court's partial denial of the motion to dismiss and remanded with instructions to dismiss the case in full. View "Cotto v. Campbell" on Justia Law

In October 2019, Edward Magruder pleaded guilty to possession with intent to distribute more than a kilogram of heroin. He later sought to withdraw his plea, arguing that the district court erred by requiring him to assert his innocence to withdraw the plea and that his plea was tainted due to ineffective assistance of counsel. The investigation leading to his arrest involved the FBI and Colombian National Police, who identified Magruder through wiretaps and geolocation data as part of a drug-trafficking conspiracy. Magruder was arrested in June 2019 after being observed traveling between D.C. and New York with heroin in his backpack.The United States District Court for the District of Columbia denied Magruder's motions to withdraw his plea. The court found that Magruder failed to assert a viable claim of innocence and that his plea was not tainted by ineffective assistance of counsel. Magruder's new counsel filed multiple motions to withdraw the plea, all of which were denied. The district court sentenced Magruder to 180 months of imprisonment followed by 60 months of supervised release.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying Magruder's motion to withdraw his guilty plea. The appellate court found that even if the district court erred in requiring an assertion of innocence, the error was harmless because Magruder's Fourth Amendment claims were meritless. The court concluded that Magruder's counsel was not ineffective for failing to raise these claims, as the search of Magruder's backpack was lawful and the evidence obtained from the Louisiana search warrant was admissible under the good-faith exception. The judgment of the district court was affirmed. View "USA v. Magruder" on Justia Law