Justia Constitutional Law Opinion Summaries

A prisoner in the Illinois Department of Corrections was issued two disciplinary tickets for alleged gang affiliation after a gang-related questionnaire, purportedly filled out by him, was found in another inmate’s belongings. The first ticket was dismissed after a hearing, but a second, nearly identical ticket was issued shortly thereafter, leading to his immediate placement in segregation. The second ticket included additional allegations, such as handwriting analysis and claims of self-admitted gang membership. The prisoner remained in segregation for three months under conditions he described as inhumane, including exposure to mold, mildew, insects, rust, and leaking sewage. He filed grievances challenging the process and the conditions, and the ticket was eventually expunged for failure to follow internal procedures, but only after he had served the segregation term.The United States District Court for the Southern District of Illinois granted summary judgment to the defendants, holding that even if there were factual disputes about whether the prisoner was denied witnesses, he had not demonstrated that the conditions of segregation constituted an “atypical and significant hardship” sufficient to implicate a protected liberty interest under the Due Process Clause.On appeal, the United States Court of Appeals for the Seventh Circuit assumed, without deciding, that the prisoner’s conditions in segregation established a liberty interest. However, the court held that, under its recent precedent in Adams v. Reagle, prisoners who do not face the loss of good-time credits or other sentence-lengthening punishments are entitled only to informal, nonadversarial due process. The court found that the prisoner received the required process: notice of the charges, an opportunity to respond, and an impartial decisionmaker. Accordingly, the Seventh Circuit affirmed the district court’s judgment. View "Torres v Brookman" on Justia Law

In 2023, Charlotte Chemuti was arrested by officers from the Mooresville Police Department for resisting a public officer. To prepare for her trial, Chemuti served a subpoena on the police department requesting body camera footage related to her arrest. The Town of Mooresville responded, arguing that the requested recordings were confidential under North Carolina General Statute § 132-1.4A and could only be released through the procedure outlined in that statute, not by subpoena.Chemuti subsequently filed a motion in the District Court of Iredell County, without notice to the town, seeking release of the recordings. The district court granted her request, finding that while the statutory petition in superior court was the generally accepted practice, it was not the exclusive method for obtaining such evidence, and ordered the town to comply with the subpoena. The town appealed to the North Carolina Court of Appeals, which dismissed the appeal for lack of appellate jurisdiction, concluding that the order did not affect a substantial right. The town then petitioned the Supreme Court of North Carolina for review.The Supreme Court of North Carolina held that orders compelling disclosure of information protected by statutory confidentiality are immediately appealable, and the Court of Appeals erred in dismissing the appeal. On the merits, the Supreme Court determined that N.C.G.S. § 132-1.4A provides the exclusive procedure for obtaining law enforcement recordings in criminal cases, requiring a petition in superior court, and that district court subpoenas cannot be used to compel their release. The Court further held that this procedure does not violate constitutional rights to present a complete defense, as courts must still ensure defendants’ constitutional protections. The Supreme Court vacated the district court’s order and remanded for further proceedings. View "State v. Chemuti" on Justia Law

Law enforcement officers investigated a breaking and entering at a market in Fletcher, North Carolina, where cash, cigarettes, and lottery tickets were stolen. Days later, someone attempted to redeem one of the stolen lottery tickets at a store in Edneyville. Security footage showed a woman leaving the store and entering a black Dodge Durango with distinctive features. Detective Diaz traced the vehicle to a nearby residence, discovered it had a fictitious license plate, and observed items inside the vehicle that appeared related to the theft. Officers later conducted a search of the vehicle and the residence, recovering stolen property and tools linked to the crime.The Superior Court of Henderson County denied the defendant’s motion to suppress evidence, which argued that law enforcement’s observations at the residence and of the vehicle were improper without a warrant. The defendant subsequently pled guilty to several charges but reserved the right to appeal the suppression ruling. The North Carolina Court of Appeals affirmed the trial court’s decision, holding that probable cause existed for the search warrant and that officers acted lawfully at the scene. The majority also found that the inevitable discovery doctrine would apply, while a dissenting judge disagreed on both points.The Supreme Court of North Carolina reviewed the case and held that, even excluding information obtained during the contested “knock and talk,” the remaining facts in the warrant affidavit established probable cause to search the vehicle. The Court did not decide whether the officers’ conduct during the knock and talk was unconstitutional, nor did it address the inevitable discovery doctrine. The Court modified and affirmed the decision of the Court of Appeals, holding that the search warrant was properly issued based on probable cause supported by untainted evidence. View "State v. Norman" on Justia Law

The defendant was indicted on multiple charges, including two counts of first-degree murder, stemming from an armed robbery in which two victims were killed and another was left paralyzed. During jury selection at his trial in Cleveland County Superior Court, the State used peremptory challenges to excuse two black female prospective jurors. The defense objected, raising a Batson challenge and arguing that the State’s strikes were racially discriminatory. The trial court heard arguments from both sides, including the State’s race-neutral explanations for the strikes, and ultimately denied the Batson challenge, finding no prima facie case of discrimination.Following his conviction on all charges and sentencing to consecutive life terms plus additional imprisonment, the defendant appealed. The North Carolina Court of Appeals, in a divided decision, found that the trial court had moved past Batson’s first step by soliciting and hearing the State’s race-neutral reasons before ruling. The majority held that this rendered the first step moot and remanded the case for a new Batson hearing under the procedural requirements established in State v. Hobbs, 374 N.C. 345 (2020). The dissent argued that the trial court had not actually proceeded to Batson’s third step and that the first step was not moot.The Supreme Court of North Carolina reviewed whether the Court of Appeals erred in holding Batson’s first step moot and remanding for a new hearing. The Supreme Court held that the mootness exception to Batson’s three-step process is to be applied cautiously and only when the trial court has fully completed all three steps. Because the trial court had clearly ruled at step one and had not proceeded to step three, the Supreme Court reversed the Court of Appeals and remanded for consideration of whether the trial court’s step-one determination was clearly erroneous. View "State v. Wilson" on Justia Law

Law enforcement in New Hanover County received information from a confidential source that the defendant was trafficking and distributing large quantities of cocaine. Based on this tip, Detective Wenk applied for a court order to obtain cell-site location information (CSLI) for the defendant’s phone, along with other investigative tools. The trial court found probable cause and granted the order, allowing law enforcement to monitor the defendant’s CSLI. This data showed the defendant’s phone traveling from Wilmington, North Carolina, to Hayward, California, and back, coinciding with suspected drug trafficking activity. Officers later stopped and searched the defendant’s vehicle, discovering trafficking amounts of cocaine. The defendant was indicted on multiple drug-related charges and moved to suppress the evidence obtained from the CSLI and subsequent searches.The Superior Court of New Hanover County denied the motion to suppress, finding reasonable suspicion supported the order and the vehicle stop. The defendant entered an Alford plea but appealed the suppression ruling. The North Carolina Court of Appeals reversed the trial court’s decision, holding that the order for CSLI was not supported by probable cause as required by the Fourth Amendment, and that the evidence should be suppressed. The appellate court rejected the State’s argument that a statutory good faith exception applied, citing prior precedent that the North Carolina Constitution did not recognize such an exception.The Supreme Court of North Carolina reviewed the case and held that the statutory good faith exception in N.C.G.S. § 15A-974 applies only to evidence obtained in substantial violation of Chapter 15A, not to evidence obtained in violation of constitutional rights. However, the court further held that neither the United States Constitution nor the North Carolina Constitution required exclusion of the CSLI in this case, and formally adopted a good faith exception under the state constitution equivalent to the federal standard. The Supreme Court reversed the Court of Appeals, upholding the trial court’s denial of the suppression motion. View "State v. Rogers" on Justia Law

A police officer observed a vehicle late at night on a rural road in Vermont, where the passenger-side wheels of the vehicle left the paved portion of the road twice in quick succession. The road had only a center line and no edge markings. The officer, who had extensive training and experience in detecting impaired driving, interpreted the vehicle’s movements as erratic and indicative of possible impairment. The officer stopped the vehicle, and the driver was subsequently arrested for suspicion of driving under the influence (DUI) and driving with a suspended license. The officer’s observations were recorded on the cruiser’s camera.The defendant moved to suppress the evidence obtained during the stop, arguing that the officer lacked reasonable suspicion to justify the stop. The Vermont Superior Court, Addison Unit, Criminal Division, held a hearing and denied the motion to suppress, finding the officer’s testimony credible and concluding that the observed driving behavior—specifically, the vehicle’s wheels leaving the paved road twice—constituted erratic driving and provided reasonable suspicion of impairment. The defendant then entered a conditional guilty plea to the DUI charge and appealed the denial of her suppression motion to the Vermont Supreme Court. The charge for driving with a suspended license was dismissed with prejudice.The Vermont Supreme Court reviewed the trial court’s factual findings for clear error and considered de novo whether those facts met the legal standard for reasonable suspicion. The Court held that the officer had reasonable and articulable suspicion to stop the defendant based on the totality of the circumstances, specifically the erratic driving observed. The Court affirmed the trial court’s denial of the motion to suppress, concluding that the stop was justified under both the Fourth Amendment and Article 11 of the Vermont Constitution. View "State v. Norton" on Justia Law

Six women who were formerly incarcerated at the Jasper City Jail in Alabama alleged that they suffered repeated sexual abuse by jailers, primarily by one officer, while serving as inmates. The plaintiffs described a range of sexual assaults and harassment, with one plaintiff also alleging abuse by a second jailer. The jail operated under the authority of the City of Jasper’s police chief, with a chief jailer and other supervisory staff responsible for daily operations. Jail policies expressly prohibited sexual contact between staff and inmates, and there were procedures for reporting grievances, but the plaintiffs claimed these mechanisms were ineffective or inaccessible.After the alleged abuse, the Alabama State Bureau of Investigation began an inquiry, leading to the resignation of the primary alleged abuser and, later, his indictment on state charges. The plaintiffs filed six separate lawsuits, later consolidated, asserting claims under 42 U.S.C. § 1983 for Eighth Amendment violations against the police chief, chief jailer, and the City, as well as claims under the Trafficking Victims Protection Reauthorization Act (TVPRA). One plaintiff also brought claims against a second jailer. The United States District Court for the Northern District of Alabama granted summary judgment to all defendants, finding insufficient evidence that the supervisory officials or the City had knowledge of, or were deliberately indifferent to, the alleged abuse, and that the claims against one jailer failed for lack of proper service.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs failed to establish a causal link between the actions or inactions of the supervisory officials or the City and the alleged constitutional violations, as there was no evidence of a widespread custom or policy of tolerating sexual abuse, nor of deliberate indifference or failure to train. The court also found that certain claims were time-barred and that the TVPRA claims failed due to lack of evidence that the City knowingly benefited from or had knowledge of the alleged trafficking. View "Bridges v. Poe" on Justia Law

In early October 2025, the President of the United States invoked his authority under 10 U.S.C. § 12406 to federalize and deploy members of the National Guard in Illinois, despite opposition from the state’s Governor. The President justified this action by citing the need to address violent assaults against federal immigration agents and property, particularly in the context of increased protests at an ICE facility in Broadview, Illinois, following the launch of “Operation Midway Blitz.” Although protests had grown in size and occasionally involved minor disruptions and isolated incidents of violence, state and local law enforcement consistently maintained control, and federal agencies reported continued success in their operations.The State of Illinois and the City of Chicago filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, challenging the federalization of the Guard. They argued that the statutory conditions for such action under § 12406 were not met, and that the move violated the Tenth Amendment and the Posse Comitatus Act. After an adversary hearing, the district court granted a temporary restraining order, finding insufficient evidence of rebellion or inability to execute federal law with regular forces, and enjoined the federalization and deployment of the Guard. The administration appealed and sought a stay of the order.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s order, applying clear error review to factual findings and de novo review to statutory interpretation. The Seventh Circuit held that the President’s decision to federalize the National Guard under § 12406 is judicially reviewable and that, even granting substantial deference to the executive, the statutory predicates for federalization were not met on the current record. The court denied the administration’s motion for a stay pending appeal as to deployment, but continued to stay the portion of the order enjoining federalization. View "Illinois v. Trump" on Justia Law

In this case, the petitioner was arrested after an incident in which he was accused of firing a gun into a neighbor’s trailer. Law enforcement recovered evidence at the scene and, following his arrest, the petitioner gave a written statement after being advised of his rights. He was indicted on two counts: shooting into a dwelling and possession of a firearm by a convicted felon. Due to a series of administrative errors, judicial conflicts, and continuances, the petitioner remained incarcerated for over three years before trial. During this period, a key defense witness died. The petitioner repeatedly asserted his right to a speedy trial through pro se motions.The Circuit Court of Tishomingo County, Mississippi, applied the four-factor test from Barker v. Wingo to the petitioner’s speedy trial claim. The court found a violation as to the first count (shooting into a dwelling) but not the second (firearm possession), and dismissed only the first count. The petitioner was tried and convicted on the remaining count and sentenced as a habitual offender. The Mississippi Court of Appeals affirmed, holding that the speedy trial right could be analyzed and remedied on a count-by-count basis in a multi-count indictment. The Mississippi Supreme Court and the United States Supreme Court denied further review.The United States Court of Appeals for the Fifth Circuit reviewed the case on habeas corpus. The court held that, under clearly established federal law as determined by the Supreme Court, when a speedy trial violation is found, the only permissible remedy is dismissal of the entire indictment, not just the affected count. The Fifth Circuit concluded that the Mississippi appellate court’s approach was an unreasonable application of federal law. The judgment of the district court was reversed, and the case was remanded with instructions to grant the writ of habeas corpus. View "Berryman v. Huffman" on Justia Law

Early one morning, law enforcement officers went to the home of an individual whose son was suspected of assault and possibly being armed. The officers approached the house from different sides, announced their presence, and knocked on the front and side doors. The resident, believing his son was at the door, opened the back door—where no officer had knocked—and walked back inside without seeing or speaking to any officer. An officer then entered the home through the open back door without a warrant or exigent circumstances, only announcing his presence after passing through the kitchen. The resident, who was in his bedroom, was confronted, tased, handcuffed, and detained outside for a period of time.The resident filed suit in the United States District Court for the Northern District of Florida, alleging unlawful entry and unlawful seizure (including excessive force) in violation of the Fourth Amendment. After discovery, the officer moved for summary judgment on the basis of qualified immunity. The district court denied summary judgment on both the unlawful entry and unlawful seizure claims, finding that material factual disputes precluded qualified immunity. The officer appealed.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court held that, construing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the officer entered the home without consent, in violation of clearly established Fourth Amendment law. The court affirmed the district court’s denial of summary judgment on the unlawful entry claim. However, the court found that the unlawful seizure and excessive force claims were entirely derivative of the unlawful entry claim, and therefore vacated the denial of summary judgment on those claims, remanding for the district court to treat them as subsumed within the unlawful entry claim. View "Dukes v. Gregory" on Justia Law