Justia Constitutional Law Opinion Summaries

The defendant was charged with murder and contributing to the delinquency of a minor after allegedly killing his wife in their home while their two young children were present. Before trial, the prosecution requested that the children be allowed to testify remotely, arguing that testifying in the defendant’s presence would cause them significant emotional distress and impair their ability to communicate. The district court held hearings, received testimony from mental health professionals who had treated the children, and ultimately granted the State’s motion, finding that remote testimony was necessary to prevent serious emotional trauma to the children.The District Court of Cass County, East Central Judicial District, presided over the case. The defendant pleaded guilty to the charge of contributing to the deprivation of a minor, and the murder charge proceeded to trial. The court instructed the jury that the children’s remote testimony was permissible by law and should not influence their deliberations. The children testified via two-way electronic communication, and the jury found the defendant guilty of murder. The court entered a judgment sentencing him to life imprisonment without parole. The defendant appealed, arguing that the district court failed to make the findings required by statute for remote testimony and that his constitutional right to confront witnesses was violated.The Supreme Court of North Dakota reviewed the case. It held that the district court made the necessary findings under North Dakota Century Code § 31-04-04.2(1), specifically that testifying in the defendant’s presence would likely cause the children serious emotional distress or trauma impacting their ability to communicate. The Supreme Court found these findings were supported by the evidence and not contrary to the manifest weight of the evidence. The court concluded that the defendant’s confrontation rights were not violated and affirmed the criminal judgment. View "State v. Moen" on Justia Law

A billboard company sought to erect a sign in a Michigan township, but its application was denied because the proposed billboard did not comply with local height and size restrictions. Instead of appealing the denial or seeking a variance, the company filed a federal lawsuit challenging the township’s sign ordinance on First Amendment grounds, including claims that the ordinance imposed content-based restrictions, constituted an unconstitutional prior restraint, and was unconstitutionally vague. The company did not challenge the height and size restrictions themselves. The township’s ordinance only allowed billboards in certain industrial zones adjacent to interstate freeways, but, according to the company, no such zones existed in the township.The United States District Court for the Eastern District of Michigan granted summary judgment to the township, finding the company lacked standing because its alleged injuries were not caused by the challenged provisions and would not be redressed by a favorable decision. The United States Court of Appeals for the Sixth Circuit affirmed, holding that the company failed to meet the requirements for standing on any of its claims.Subsequently, the company filed a new lawsuit in the same district court, again alleging that the ordinance was a prior restraint on speech. The district court dismissed the suit, holding that res judicata (claim preclusion) barred the action. On appeal, the United States Court of Appeals for the Sixth Circuit held that issue preclusion, not claim preclusion, applied. The court concluded that issue preclusion barred the company from relitigating its prior-restraint claim based on its earlier application, but did not bar claims based on new facts—specifically, the company’s allegation that it was self-censoring and not applying for any billboards due to the ordinance’s discretionary variance process. The Sixth Circuit affirmed in part, vacated in part, and remanded for further proceedings on the new factual allegations. View "Outdoor One Communications LLC v. Charter Twp. of Canton, Mich." on Justia Law

A federal inmate serving a 210-month sentence challenged the method used by the Federal Bureau of Prisons (BOP) to calculate his good conduct time credits under 18 U.S.C. § 3624(b)(1), as amended by the First Step Act of 2018. The inmate argued that, following the amendments, he should receive a full 54 days of good conduct time credit for the last six months of his sentence, rather than a prorated amount. The BOP, however, interpreted the amended statute to require prorating the credit for any partial year, resulting in the inmate receiving 26 days of credit for the final six months instead of 54.The United States District Court for the District of New Jersey denied the inmate’s habeas petition. The court found that the plain language of the amended statute allowed for proration of good conduct time credits for partial years. As an alternative basis, the District Court also relied on Chevron deference to uphold the BOP’s interpretation. The court rejected the inmate’s additional claims under the Administrative Procedure Act (APA) and the Due Process Clause, finding them either precluded by statute or inapplicable to the rulemaking context.On appeal, the United States Court of Appeals for the Third Circuit reviewed the statutory interpretation de novo. The Third Circuit affirmed the District Court’s judgment, holding that the First Step Act’s amendments, while deleting the word “prorated,” introduced language (“for each year”) that sets a rate of 54 days per year, thereby requiring proration for any partial year. The court concluded that the statute’s natural reading supports the BOP’s method of prorating credits for the last portion of a sentence. The Third Circuit also rejected the inmate’s constitutional and APA-based arguments, and found no basis for applying the rule of lenity. View "Thieme v. Warden Fort Dix FCI" on Justia Law

Edwin Diaz was stopped by law enforcement in Ida Grove, Iowa, after Deputy Clausen observed his truck parked with only one working headlight, broken taillights, and impeding traffic. Upon approaching the vehicle, Clausen smelled marijuana and saw Diaz drop an item later identified as methamphetamine. Diaz and his passenger, Mikaela Breen, were arrested and charged with state drug offenses. Days later, Breen reported to police that Diaz had coerced her into signing a statement taking responsibility for the drugs found in the truck. Based on Breen’s account and Diaz’s criminal history, law enforcement obtained a warrant to search Diaz’s residence, where they found drugs, paraphernalia, and a firearm.The United States District Court for the Northern District of Iowa reviewed Diaz’s motion to suppress evidence from both the truck and home searches. The magistrate judge recommended denying the motion, finding that the truck search was lawful due to probable cause from observed traffic violations and the smell of marijuana, and that the good faith exception applied to the home search despite questions about the warrant’s nexus to the residence. The district judge agreed that the truck search was justified by probable cause and that the good faith exception protected the home search evidence, even though the warrant affidavit did not establish a sufficient nexus between the drugs and Diaz’s home.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of the suppression motion. The court held that the initial encounter with Diaz was supported by reasonable suspicion and probable cause due to multiple traffic violations and the odor of marijuana, justifying the truck search. For the home search, the court found that the Leon good faith exception applied because it was not entirely unreasonable for officers to believe that a drug dealer would store contraband at his residence, even if the warrant affidavit lacked a direct nexus. The judgment was affirmed. View "United States v. Diaz" on Justia Law

A seventeen-year-old defendant was charged with murder after the shooting death of a victim in a Bridgeport housing complex stairwell. Surveillance footage showed the defendant leading the victim into the building and exiting alone minutes later, covering his face with a mask. The victim was later found naked and bleeding outside the basement door, having been shot six times. Police investigation led to a search of the defendant’s home, where a .45 caliber pistol and matching ammunition were found in his bedroom. The defendant, interviewed at home in the presence of his legal guardian, admitted to owning the gun and being with the victim but denied involvement in the shooting. Nineteen minutes into the interview, he invoked his right to remain silent, but questioning continued. The defendant was later located in Florida and returned to Connecticut for trial.In the Superior Court for the judicial district of Fairfield, the defendant moved to suppress statements made during the police interview, arguing he had not knowingly and voluntarily waived his Miranda rights. The court found, under the totality of the circumstances, that the waiver was valid, considering the defendant’s age, education, prior experience with law enforcement, and the presence of his guardian. The court suppressed only statements made after the defendant invoked his right to remain silent. The jury convicted the defendant of murder, and he was sentenced to forty-five years’ incarceration.On appeal to the Connecticut Supreme Court, the defendant challenged the validity of his Miranda waiver, sought greater protection under the state constitution, alleged prosecutorial impropriety, and objected to a consciousness of guilt jury instruction. The Supreme Court held that the waiver was knowing, intelligent, and voluntary, declined to adopt a rule requiring consultation with an interested adult before a juvenile’s waiver, found no prosecutorial impropriety, and determined any error in the consciousness of guilt instruction was harmless. The judgment was affirmed. View "State v. Cooper" on Justia Law

In 1984, four women in Connecticut were robbed and sexually assaulted in their homes by an unknown assailant. The perpetrator blindfolded, restrained, and threatened each victim, then stole items before leaving. Police collected physical evidence from the crime scenes, but DNA testing was not available at the time. Years later, advances in forensic science allowed the state laboratory to develop DNA profiles from the evidence, which were uploaded to the Combined DNA Index System (CODIS). In 2020, a private forensic company provided investigative leads, ultimately implicating the defendant. Police lawfully collected trash from the defendant’s residence, including a belt, and submitted it for DNA analysis without a warrant. The DNA extracted from the belt matched the crime scene profiles. Police then obtained a warrant for a confirmatory DNA sample, which further implicated the defendant.The defendant was charged in the Superior Court for the judicial district of Hartford with eight counts of kidnapping in the first degree. At trial, the court instructed the jury on the elements of kidnapping, including the factors from State v. Salamon, which help determine whether restraint exceeded what was necessary for the underlying crimes. The next day, the court provided the jury with a flowchart outlining the kidnapping elements, but the chart omitted reference to the Salamon factors. The jury found the defendant guilty on all counts, and he was sentenced to seventy-two years in prison.On appeal to the Connecticut Supreme Court, the defendant argued that the warrantless collection and analysis of his DNA from the discarded belt violated his rights under the Fourth Amendment and the Connecticut Constitution, and that the omission of the Salamon factors from the flowchart misled the jury. The Connecticut Supreme Court held that neither the collection nor the analysis of DNA from the discarded belt constituted a search under the Fourth Amendment or the state constitution when performed for identification purposes only. The court also found that the jury was not misled by the flowchart, as the full instructions included the Salamon factors and the jury was properly directed to rely on those instructions. The judgment of conviction was affirmed. View "State v. Sharpe" on Justia Law

The plaintiff, who is civilly committed as a sexually violent predator at the Texas Civil Commitment Center, brought a pro se lawsuit under 42 U.S.C. § 1983 against the Commissioner of the Texas Department of Family Protective Services and the Executive Commissioner of the Texas Health and Human Services Commission. He alleged that these agencies failed to investigate his reports of misconduct and abuse at the facility, claiming violations of his Fourteenth Amendment rights to equal protection and due process, as well as rights under the Bill of Rights for Mental Health Patients. The plaintiff asserted that he should be able to file complaints with these agencies rather than being required to use the internal grievance procedure of the Texas Civil Commitment Office.The United States District Court for the Western District of Texas screened the complaint under 28 U.S.C. § 1915(e)(2)(B) because the plaintiff was proceeding in forma pauperis. The district court found that the plaintiff failed to state a claim for relief and that amendment would be futile, so it dismissed the complaint without prejudice. The plaintiff appealed, arguing that he had adequately stated equal protection and due process claims, that he should have been allowed to amend his complaint, and that the district court was biased.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to state an equal protection claim because he was not similarly situated to other Texas citizens and the different grievance procedures had a rational basis. The court also found no protected liberty or property interest to support a due process claim and concluded that the alleged conduct did not rise to the level of a substantive due process violation. The court further held that amendment would have been futile and found no evidence of judicial bias. The plaintiff’s motion for appointment of counsel was denied. View "Dunsmore v. Muth" on Justia Law

In this case, the defendant was charged with the murder of German Carrillo while both were incarcerated in the Santa Cruz County jail in 2019. The prosecution alleged that the murder was committed for the benefit of a criminal street gang, specifically Nuestra Familia, and also charged the defendant with active participation in a criminal street gang. Evidence at trial included expert testimony about the gang’s structure and rules, testimony from former gang members about intra-gang discipline and removals, and details about the circumstances of Carrillo’s death, including surveillance footage and gang communications. The defendant testified about his own gang involvement, his actions during the incident, and his subsequent departure from the gang.The Santa Cruz County Superior Court conducted a jury trial, where the jury found the defendant guilty of murder with special circumstances and found the gang allegations true. The court sentenced the defendant to life in prison without the possibility of parole, imposed a consecutive gang enhancement, and a concurrent sentence for the gang participation count. The court also imposed a parole revocation fine, suspended unless parole was revoked. The defendant appealed, challenging the sufficiency of the gang evidence, the exclusion of certain mental health evidence, the constitutionality of his sentence, and the imposition of the parole revocation fine.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that substantial evidence supported the jury’s findings that the murder and predicate offenses provided a non-reputational benefit to the gang, as required by amended Penal Code section 186.22. The court found no reversible error in the exclusion of mental health evidence, determined the sentence was not unconstitutionally cruel or unusual, and upheld the imposition of the parole revocation fine based on statutory requirements. The judgment was affirmed. View "People v. Cortez" on Justia Law

Police responded to a 911 call in Marshfield, Wisconsin, reporting that Jaison Coleman had threatened to kill his wife, Lisa Coleman, and was still inside their home. Officer Jamie Kizer arrived and spoke with Lisa on the porch, asking about the safety of her children and the location of her husband. Lisa hesitated to answer questions about her children’s safety and initially declined to allow the officer inside. After a brief pause, Lisa returned to the doorway, and following further discussion, she agreed to let Officer Kizer and his colleagues enter the home. Once inside, Lisa directed the officers to the children’s location and indicated where Coleman might be. The officers found Coleman, conducted a protective pat down, and learned from the children that Coleman had threatened Lisa with a gun.Based on information obtained during their entry, the officers secured a warrant to search the home, which led to the discovery of several firearms. Coleman was indicted for unlawful possession of a firearm as a convicted felon under 18 U.S.C. § 922(g)(1). He moved to suppress the firearms, arguing that Lisa had not consented to the officers’ entry. A magistrate judge found that Lisa had consented and recommended denial of the motion. The United States District Court for the Western District of Wisconsin adopted the magistrate judge’s findings and denied the suppression motion, also concluding that the officers did not exceed the scope of Lisa’s consent. Coleman pleaded guilty but reserved the right to appeal the suppression ruling.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s findings for clear error. The appellate court held that Lisa’s consent was voluntary and that the officers acted within the scope of her consent. The court affirmed Coleman’s conviction, finding no error in the district court’s rulings. View "United States v. Coleman" on Justia Law

Petitioners, resident taxpayers and registered voters in Oklahoma County, challenged the constitutionality of Senate Bill 632, which sought to create business court divisions within the district courts of Oklahoma County and Tulsa County. The Act provided for the appointment of business court judges by the Governor, with confirmation by the Senate and candidate lists supplied by the Speaker of the House. It also set forth qualifications, terms, salaries, and operational details for these judges and courts. Petitioners argued that the Act violated their constitutional rights, particularly the right to elect district judges, and would result in the unlawful expenditure of public funds.Prior to review by the Supreme Court of the State of Oklahoma, the Honorable Lonnie Paxton and Kyle Hilbert, legislative leaders named as respondents, moved for dismissal based on legislative immunity, which the court granted. The Governor, the remaining respondent, moved to dismiss the case, arguing he was not a proper party. The court denied this motion, finding the Governor’s role in appointing business court judges central to the dispute. The Oklahoma Association for Justice filed an amicus brief supporting Petitioners. The court assumed original jurisdiction, issued a temporary stay of the Act’s effectiveness, and heard oral arguments.The Supreme Court of the State of Oklahoma held that Petitioners had standing as both taxpayers and voters. The court found Senate Bill 632 unconstitutional because it violated Article VII, Section 9 of the Oklahoma Constitution by circumventing the requirement that district judges be elected by voters. The court further determined that the unconstitutional provisions were not severable from the rest of the Act, rendering the entire Act void and unenforceable. The petition for declaratory relief was granted, and the temporary stay remained in effect pending any rehearing. View "White v. Stitt" on Justia Law