Justia Constitutional Law Opinion Summaries

A man was convicted by a jury of several offenses related to a shooting outside a nightclub in Washington, D.C. in July 2021. The evidence showed that the defendant, who was twenty years old at the time, shot another individual and then hid the firearm. He was identified by a witness, and DNA evidence linked him to the recovered handgun. The defendant initially told police he was not the shooter, but at trial, he admitted to firing the gun, claiming self-defense.Prior to trial in the Superior Court of the District of Columbia, the defendant moved to dismiss charges related to carrying a pistol without a license, possession of an unregistered firearm, and unlawful possession of ammunition. He argued that the District’s laws, which require individuals to be at least twenty-one years old to obtain a firearm registration or license, violated the Second Amendment, especially in light of the Supreme Court’s decision in New York State Rifle & Pistol Association, Inc. v. Bruen. The trial court denied the motion, finding the age-based restrictions consistent with the Second Amendment and historical firearm regulation. At trial, the government impeached the defendant’s credibility by highlighting inconsistencies between his initial statements and his trial testimony. The jury convicted him on all counts.On appeal, the District of Columbia Court of Appeals reviewed the constitutionality of the District’s age-based firearm registration and licensing statutes and the propriety of the government’s arguments regarding the defendant’s credibility. The court held that the age-based statutes are constitutional because they are consistent with the nation’s historical tradition of firearm regulation. The court also found that the government’s arguments about the defendant’s change in defense theory were not improper. The court affirmed the convictions but remanded for the limited purpose of merging certain convictions and resentencing as necessary. View "Picon v. United States" on Justia Law

In this case, the appellant was convicted of simple assault with a bias enhancement after an incident at a Metro station. The government’s evidence showed that the appellant approached a group, made derogatory remarks about their sexual orientation, and physically assaulted one of them multiple times. The assailant was later apprehended at a different Metro station and identified as the appellant. The charges were eventually narrowed to simple assault with a bias enhancement, and the appellant was found guilty by a jury.Prior to trial in the Superior Court of the District of Columbia, the appellant objected to the composition of the jury venire, arguing that it did not reflect a fair cross-section of the community, as only three of fifty-four potential jurors appeared to be African American. The trial judge denied the motion to strike the panel, finding that the appellant had not shown systematic exclusion of a group from the jury selection process. The judge also denied a subsequent, untimely request for access to jury selection records, reasoning that the request came only after the motion to strike had been denied and that no prior efforts had been made to obtain such records.On appeal, the District of Columbia Court of Appeals reviewed the sufficiency of the evidence and the fair cross-section claim. The court held that there was sufficient evidence for a reasonable juror to find the appellant guilty beyond a reasonable doubt, based on the testimony of the arresting officer and the circumstances of the arrest. The court also held that the trial court did not err in denying the motion to strike the jury panel or the belated request for jury selection records, finding that the denial was based on the untimeliness of the request rather than an improper threshold requirement. The judgment of the Superior Court was affirmed. View "Brown v. United States" on Justia Law

Police received reports of a group committing robberies or attempted robberies in a white Nissan Rogue that had been reported stolen. Officers tracked the vehicle, observed it being driven recklessly, and saw it crash. Four individuals, including E.A., fled from the car. E.A. was apprehended shortly after the crash, frisked, and found to have a handgun in his sweatshirt pocket. He was subsequently charged with carrying a pistol without a license and possession of an unregistered firearm.The Superior Court of the District of Columbia denied E.A.’s motion to suppress the handgun, finding that officers had reasonable articulable suspicion to stop and frisk him based on his association with the group suspected of recent robberies and the stolen vehicle, as well as his flight from the crash. The court also concluded that, even if the officers’ actions exceeded the scope of a Terry stop, they had probable cause to arrest E.A. for multiple offenses, justifying a search incident to arrest. E.A. was adjudicated delinquent on both firearms charges and appealed, challenging the denial of his suppression motion.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court’s judgment. The appellate court held that the officers had reasonable articulable suspicion to stop and frisk E.A., relying on the collective knowledge from radio dispatches, corroborated by officers’ observations and the circumstances of the stop. The court further held that the officers’ use of handcuffs and drawn weapons did not convert the stop into an arrest, given the safety concerns and flight risk. Therefore, the search and seizure of the handgun did not violate the Fourth Amendment, and the judgment was affirmed. View "In re E.A." on Justia Law

A physician licensed in Florida worked at a weight management clinic, where he was responsible for maintaining a federal registration to dispense controlled substances. After a report of missing controlled substances at the clinic, local police and the Drug Enforcement Administration (DEA) began investigating. The investigation revealed that the physician had issued numerous prescriptions for controlled substances without proper documentation of a doctor-patient relationship, failed to maintain required records, did not properly report or store controlled substances, and dispensed medication in violation of labeling requirements. The physician claimed that another clinic employee had forged his signature on some prescriptions and denied personal wrongdoing.The DEA issued an Order to Show Cause, notifying the physician of its intent to revoke his registration and deny pending applications, citing violations of federal and state law. The physician submitted a Corrective Action Plan but did not request a hearing. The DEA Administrator reviewed the evidence, including expert testimony and the physician’s admissions, and found that the physician’s continued registration would be inconsistent with the public interest. The Administrator revoked the registration and denied all pending applications, emphasizing the physician’s failure to accept responsibility and the inadequacy of his proposed corrective measures.The United States Court of Appeals for the Eleventh Circuit reviewed the DEA’s final order under an abuse of discretion standard, deferring to the agency’s factual findings if supported by substantial evidence. The court held that the physician received adequate procedural due process, as he was given notice and an opportunity for a hearing, which he declined. The court also rejected the argument that the DEA was required to find knowing or intentional misconduct under Ruan v. United States, holding that such a mens rea requirement does not apply to administrative revocation proceedings under 21 U.S.C. § 824. The petition for review was denied. View "Ashraf v. Drug Enforcement Administration" on Justia Law

Andrew Scott, a professional process server and licensed private investigator in Colorado, was hired to serve a subpoena on State Trooper Charles Hiller. The service attempt became contentious, leading Hiller to file complaints against Scott with both the Colorado Office of Private Investigator Licensure and the Process Servers Association of Colorado. Hiller alleged that Scott endangered his safety by including personal information in an affidavit of service, potentially violating Colorado Revised Statute § 18-9-313(2.7), which prohibits publishing law enforcement officers’ personal information online if it poses an imminent and serious threat. The Office of Private Investigator Licensure dismissed its complaint, but the Association expelled Scott, citing a violation of the statute. Scott subsequently created a website, copscore.org, intending to publish information about police misconduct, but refrained from posting content due to fear of prosecution under the statute.Scott filed suit in the United States District Court for the District of Colorado against the local District Attorney, seeking a declaration that the statute was unconstitutional both facially and as applied. The district court granted summary judgment for the defendants, dismissing Scott’s complaint on the grounds that he lacked standing for a pre-enforcement challenge. The court found Scott had not demonstrated an injury in fact, reasoning that his conduct was not “arguably proscribed” by the statute, especially since Scott stated in his summary judgment briefing that he did not know of any imminent and serious threat to Hiller’s safety from the intended publication.On appeal, the United States Court of Appeals for the Tenth Circuit reversed the district court’s decision. The appellate court held that Scott had standing to pursue a pre-enforcement First Amendment challenge because his intended conduct was at least arguably prohibited by the statute, and the credible threat of prosecution chilled his speech. The case was remanded for further proceedings on the merits. View "Scott v. Allen" on Justia Law

The defendant, a young man with a history of firearm-related offenses, was previously adjudicated delinquent for shooting at a person, making him a “Category I restricted person” under Utah law and barring him from possessing firearms. Despite this, he was found in possession of a handgun in April 2022 and was charged with a felony for possessing a dangerous weapon as a restricted person. On the day of his arraignment for that charge, he purchased another firearm. Later, in October 2022, he was found with this new firearm after allegedly firing it at a group of people.Following the October incident, a federal grand jury indicted him for illegal receipt of a firearm by a person under indictment, in violation of 18 U.S.C. § 922(n). He moved to dismiss the indictment, arguing that § 922(n) is facially unconstitutional under the Second Amendment, as interpreted by New York State Rifle & Pistol Ass’n v. Bruen. The United States District Court for the District of Utah denied his motion, finding that while the Second Amendment presumptively protected his conduct, § 922(n) was consistent with the nation’s historical tradition of firearm regulation. The court cited historical laws disarming dangerous groups and surety laws as analogues. The defendant then entered a conditional guilty plea, reserving his right to appeal, and was sentenced to 21 months’ imprisonment.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the constitutionality of § 922(n) de novo. The court held that § 922(n) is facially constitutional, finding it “relevantly similar” to founding-era practices of pretrial detention and bail, which imposed comparable, temporary restrictions on the right to bear arms for those accused of serious crimes. The Tenth Circuit affirmed the district court’s denial of the motion to dismiss and upheld the conviction. View "United States v. Ogilvie" on Justia Law

The case concerns a defendant who was arrested and indicted for the murder of an individual named Donald Blake, with the allegation being that the murder was committed by blunt force trauma. At trial, the court instructed the jury on both murder and, over the defendant’s objection, the lesser-included offense of voluntary manslaughter. After more than five hours of deliberation, the jury returned a verdict of not guilty on murder and guilty on voluntary manslaughter. During jury polling, the eleventh juror indicated that the guilty verdict for manslaughter was not her true verdict, explaining she had been pressured by other jurors and maintained a not guilty stance. The trial judge, without instructing the jury to continue deliberations and over the objections of both parties, questioned the dissenting juror individually and then declared a mistrial.Following the mistrial, the State sought to retry the defendant for murder. The defendant moved for habeas corpus and for entry of a verdict of acquittal, arguing that jeopardy had attached to the murder charge because the jury had returned a final not guilty verdict. The Circuit Court denied relief, holding that jeopardy had not attached and that the State could retry the defendant for murder. The defendant’s appeal to the South Carolina Court of Appeals was dismissed as not immediately appealable, and his petitions for supersedeas and habeas corpus were denied. The Supreme Court of South Carolina then issued a common law writ of certiorari to review whether the State could retry the defendant for murder, and later requested briefing on the voluntary manslaughter charge as well.The Supreme Court of South Carolina held that jeopardy attached to both the murder and voluntary manslaughter charges. The Court found the not guilty verdict on murder was final and that the trial court’s sua sponte declaration of a mistrial, without manifest necessity and without instructing the jury to continue deliberations, barred retrial on both charges under double jeopardy principles. The Court reversed the lower court’s ruling, holding the State may not retry the defendant for either offense. View "The State v. Erb" on Justia Law

The case concerns a defendant who was initially indicted for murder following the stabbing death of an individual in El Paso, Texas. The defendant was accused of killing the victim after a dispute during a sexual encounter, subsequently stealing the victim’s truck, and fleeing to Mexico. After his arrest, the defendant’s counsel repeatedly requested discovery and asserted readiness for trial, while the State delayed providing evidence and sought continuances, citing reasons such as incomplete forensic testing and missing witnesses.The 210th District Court of El Paso County first handled the case, where the defendant moved for dismissal on speedy trial grounds. In response, the State dismissed the murder indictment and reindicted the defendant for capital murder, announcing its intent to seek the death penalty. The defendant then moved to dismiss the new indictment, alleging prosecutorial vindictiveness—arguing that the State escalated the charges in retaliation for his assertion of speedy trial rights. The trial court found the State’s justifications not credible, determined that the reindictment was vindictive, and dismissed the case with prejudice. The State appealed, and the Eighth Court of Appeals affirmed, agreeing that the State acted vindictively and that dismissal with prejudice was warranted to neutralize the taint.The Texas Court of Criminal Appeals reviewed whether the trial court abused its discretion by dismissing the case with prejudice. The court held that, while the record supported a finding of prosecutorial vindictiveness, dismissal with prejudice was not necessary to neutralize the constitutional violation because the defendant’s speedy trial rights were not actually violated. The court concluded that the trial court exceeded its authority and modified the dismissal to be without prejudice, allowing the State to reindict the defendant for murder or a lesser-included offense at its discretion. The judgment of the Eighth Court of Appeals was reversed. View "STATE OF TEXAS v. GABALDON" on Justia Law

A woman was stopped by a sheriff’s deputy in Ravalli County, Montana, for driving a vehicle with expired registration. The stop followed a call from a citizen informant reporting unusual activity at a residence known for prior drug activity, and an off-duty trooper’s observation of the woman leaving that residence in the vehicle. During the stop, the deputy questioned the woman about her activities and associations with the residence, and she provided explanations consistent with her presence there for lawful reasons. The deputy, suspecting drug activity, ultimately seized the vehicle and the woman’s purse, later obtaining a search warrant that led to the discovery of methamphetamine and drug paraphernalia in the purse.The Twenty-First Judicial District Court, Ravalli County, denied the woman’s motion to suppress the evidence found in her purse. The court held that the deputy had particularized suspicion to extend the traffic stop beyond the registration issue to investigate possible drug activity, and that there was probable cause to seize the vehicle and its contents, including the purse. The court also found that the search warrant was supported by probable cause and that the woman had not shown any false statements in the warrant application.On appeal, the Supreme Court of the State of Montana reviewed whether the district court properly denied the motion to suppress. The Supreme Court held that while the deputy had particularized suspicion to extend the stop and inquire about drug activity, the suspicion was dispelled by the woman’s answers and did not ripen into probable cause to seize the vehicle or the purse. The Court found the district court’s findings regarding the woman’s demeanor and the basis for probable cause to be clearly erroneous. The Supreme Court reversed the district court’s denial of the motion to suppress. View "State v. Carter-Brueggeman" on Justia Law

The case concerns a defendant who was arrested at a gas station mini-mart after officers, investigating an earlier robbery, observed him enter a single-occupancy restroom marked “Out of Order.” The defendant did not lock the door. Officers entered the restroom shortly after and found him standing on the handicap bars, reaching into the ceiling. A firearm was recovered from the ceiling area, and a subsequent search of the defendant revealed cash and various controlled substances. The government conceded that the officers lacked probable cause or reasonable suspicion to believe the defendant had committed a crime at the time they entered the restroom.The United States District Court for the Northern District of Illinois, Eastern Division, denied the defendant’s motion to suppress the evidence, finding he lacked a reasonable expectation of privacy in the out-of-order restroom. The court also found sufficient evidence to convict him of unlawful possession of a firearm by a felon and possession with intent to distribute a controlled substance following a bench trial. The defendant appealed, challenging the denial of the suppression motion, the sufficiency of the evidence for the firearm conviction, and sought to preserve a constitutional challenge to 18 U.S.C. § 922(g).The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that the defendant did not have a subjective or objectively reasonable expectation of privacy in the unlocked, out-of-order restroom, so the officers’ entry did not constitute a search under the Fourth Amendment. The court also found that sufficient evidence supported the conviction for unlawful possession of a firearm by a felon, based on constructive possession. Finally, the court held that the defendant waived his constitutional challenge to § 922(g) by failing to present any legal argument on appeal. View "United States v. Scott" on Justia Law