Justia Constitutional Law Opinion Summaries

The case involves Christopher Poller, who was convicted by the United States District Court for the District of Connecticut for possession with intent to distribute fentanyl and cocaine base, and possession of a firearm in furtherance of a drug trafficking crime. Poller pleaded guilty but reserved the right to appeal the denial of his motion to suppress evidence seized from his vehicle, which included the drugs and firearms forming the basis of his charges.The District Court denied Poller's motion to suppress, concluding that the officers' use of iPhone cameras to see through the tinted windows of Poller's car did not violate his reasonable expectation of privacy. The court also found that even if the officers' physical touching of the car constituted a trespassory search, suppression was unwarranted because the trespass was not the but-for cause of obtaining the evidence.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that Poller's expectation of privacy from all observation of the interior of his car was unreasonable. The use of iPhone cameras to view the car's interior did not transform those visual observations into "searches" under the Fourth Amendment. Additionally, assuming the officers' physical touching of the car constituted a trespassory search, suppression was unwarranted because the trespass was not the but-for cause of obtaining the evidence. Therefore, the Second Circuit affirmed the judgment of the district court. View "United States v. Poller" on Justia Law

In September 2022, Antoine Leon Richardson had an altercation with Mckyla Middleton at a liquor store in Lancaster, California. Richardson accused Middleton of cutting him off, threatened her, and flashed a gun at her from a satchel. In November 2022, police searched Richardson’s home and found ammunition but no firearms. Richardson admitted to brandishing the gun during the altercation and owning the ammunition.The Los Angeles County Superior Court charged Richardson with being a felon in possession of a firearm, being a felon in possession of ammunition, and misdemeanor exhibiting a concealable firearm in public. The jury found Richardson guilty on all counts and confirmed his prior felony convictions. The court sentenced him to three years and eight months in prison for the firearm and ammunition charges, with a concurrent 364-day term for the misdemeanor.The California Court of Appeal, Second Appellate District, reviewed the case. Richardson argued that his convictions for firearm and ammunition possession violated the Second Amendment, citing New York State Rifle & Pistol Association, Inc. v. Bruen. The court disagreed, stating that the Second Amendment protects law-abiding citizens, not felons. The court also found that substantial evidence supported the trial court’s finding that Richardson had separate objectives for possessing and exhibiting the firearm, thus allowing multiple sentences under Penal Code section 654.The Court of Appeal affirmed the trial court’s judgment, upholding Richardson’s convictions and sentences. View "People v. Richardson" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

In 2016, Robert Edward Smith was involved in a home invasion that resulted in the murder of Donna O'Neal. Smith was charged with first-degree felony murder, aggravated burglary, attempted aggravated robbery, two counts of aggravated assault, and criminal possession of a weapon. The case was delayed due to extensive pretrial litigation and the COVID-19 pandemic, leading to a mistrial in July 2021. Smith's retrial began in May 2023, where he was ultimately convicted on all charges.The Sedgwick District Court initially handled the case, where Smith raised several issues, including a violation of his constitutional right to a speedy trial, prosecutorial error, and the right to present a defense. The district court denied Smith's motions, including his motion to dismiss based on the speedy trial claim and his objections to the State's mid-trial amendment of the information.The Kansas Supreme Court reviewed the case and addressed multiple issues. The court found that the 21.5-month delay between Smith's mistrial and retrial did not violate his right to a speedy trial, considering the complexity of the case and the impact of the COVID-19 pandemic. The court also found no prosecutorial error in the prosecutor's comments during closing arguments and no violation of Smith's right to present a defense regarding the exclusion of third-party evidence and a probation violation warrant.However, the court agreed with Smith that the district court erred in including his 2003 criminal threat conviction in his criminal history score, as the statute under which he was convicted had been declared unconstitutional in State v. Boettger. The Kansas Supreme Court affirmed Smith's convictions but vacated his sentence and remanded the case for resentencing without including the 2003 conviction in his criminal history score. View "State v. Smith " on Justia Law

Christopher Adams faced multiple counts of battery for allegedly assaulting two men and his girlfriend, Stephanie Lang, outside a bar. Lang initially identified Adams as the attacker but later claimed she did not remember the incident during a preliminary hearing. Due to her inconsistent statements, the State charged Lang with perjury and interference with law enforcement and warned her of additional perjury charges if she testified similarly at Adams' trial. Lang invoked the Fifth Amendment privilege against self-incrimination, citing the risk of incrimination in her pending perjury case and potential new perjury charges.The Ellis District Court ruled that Lang could invoke the Fifth Amendment privilege despite the State offering her use and derivative use immunity, which would make her trial testimony and any evidence derived from it inadmissible in her pending perjury case. The court found that the immunity did not protect her from a new perjury charge. A majority panel of the Kansas Court of Appeals affirmed the district court's decision, holding that the immunity was insufficient to protect Lang's Fifth Amendment rights due to the imminent risk of a perjury charge. Chief Judge Karen Arnold-Burger dissented, arguing that the threat of a future perjury charge cannot be the basis for invoking the Fifth Amendment privilege.The Kansas Supreme Court reviewed the case and reversed the decisions of the lower courts. The court held that Lang's Fifth Amendment privilege was extinguished by the State's grant of use and derivative use immunity, which is coextensive with the Fifth Amendment protection. The court further held that the risk of a future perjury charge is not a valid basis for invoking the Fifth Amendment privilege. The case was remanded to the district court with directions to compel Lang's testimony under the State's grant of immunity. View "State v. Adams " on Justia Law

Gregory W. Pheasant was charged with driving an off-road vehicle on public lands at night without a taillight, violating 43 C.F.R. § 8341.1(f)(5). This regulation was issued by the Secretary of the Interior under the Federal Land Policy and Management Act of 1976 (FLPMA). Pheasant allegedly refused to stop for Bureau of Land Management rangers, made obscene gestures, and sped away before being apprehended. He was indicted on three counts, including the taillight violation.The United States District Court for the District of Nevada dismissed the taillight count, ruling that section 303(a) of the FLPMA was an unconstitutional delegation of legislative power. The court held that the statute gave the Secretary of the Interior too much authority without sufficient guidance or restraint, violating Article I of the Constitution, which vests all legislative powers in Congress.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court reversed the district court's dismissal, holding that section 303(a) of the FLPMA satisfies the "intelligible principle" test established by the Supreme Court. The Ninth Circuit found that the FLPMA provides clear guidance by requiring the Secretary to manage public lands under principles of multiple use and sustained yield, ensuring the land's value is realized sustainably. The court concluded that these constraints are sufficient to meet constitutional requirements, and thus, section 303(a) does not constitute an unconstitutional delegation of legislative power. The case was remanded for further proceedings. View "USA V. PHEASANT" on Justia Law

A transgender woman, Darlene Griffith, filed a civil rights lawsuit regarding her pretrial confinement at the El Paso County Jail in Colorado. She alleged that the jail's policies, which assigned housing based on genitalia and denied her access to female clothing and products, violated her constitutional rights and the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The district court dismissed her complaint under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), leading to this appeal.The United States District Court for the District of Colorado dismissed Ms. Griffith’s complaint, concluding that she failed to state a plausible claim for relief. The court applied rational-basis review to her Equal Protection claim, finding that transgender individuals are not a protected class under existing precedent. The court also dismissed her ADA and Rehabilitation Act claims for lack of subject matter jurisdiction, as she did not properly name the county as a defendant according to state law requirements.The United States Court of Appeals for the Tenth Circuit reviewed the case and concluded that remand was required for some of Ms. Griffith’s claims. The court reversed and remanded for further proceedings on her Fourteenth Amendment Equal Protection claim against Sheriff Elder in his official capacity, her Fourth and Fourteenth Amendment cross-gender search claims against Sheriff Elder in his official capacity, and her Fourth Amendment abusive search claim against Deputy Mustapick. The court vacated the district court’s order dismissing Ms. Griffith’s ADA and Rehabilitation Act claims under Rule 12(b)(6) because those claims were dismissed without prejudice for lack of subject matter jurisdiction under Rule 12(b)(1), and that ruling was unchallenged on appeal. The court otherwise affirmed the district court’s dismissal of the remaining claims. View "Griffith v. El Paso County, Colorado" on Justia Law

The case involves parents (the "Parents") of a student at Baird Middle School in Ludlow, Massachusetts, who challenged the school's protocol regarding the use of a student's requested name and gender pronouns without notifying the parents unless the student consents. The Parents argued that this practice interfered with their parental rights under the U.S. Constitution. The school, represented by the Ludlow School Committee and various school officials, defended the protocol as necessary to ensure a safe and inclusive environment for students.In the United States District Court for the District of Massachusetts, the Parents' complaint was dismissed. The court held that the Parents failed to state a plausible claim that the school's protocol violated their fundamental right to direct the upbringing of their child. Specifically, the court found that the Parents did not adequately allege that the school's actions constituted medical treatment or that the conduct was so egregious as to shock the conscience, which is required to establish a substantive due process violation.The United States Court of Appeals for the First Circuit reviewed the case. The court concluded that the protocol is a form of legislative conduct, not executive conduct, and thus did not require the shock-the-conscience test. The court determined that the Parents had identified a fundamental right but failed to plausibly allege that the school's conduct restricted that right. The court found that the school's actions, including the use of the student's chosen name and pronouns, did not constitute medical treatment and that the protocol did not restrict the Parents' rights to direct their child's upbringing.The First Circuit held that the protocol was rationally related to the legitimate state interest of creating a safe and inclusive educational environment for students. Therefore, the court affirmed the district court's dismissal of the Parents' complaint. View "Foote v. Ludlow School Committee" on Justia Law

The case involves a challenge to the constitutionality of the Ethics Commission Reform Act of 2022, which established the New York State Commission on Ethics and Lobbying in Government. The plaintiff, Andrew M. Cuomo, argued that the Act unconstitutionally vests executive power in the Commission without sufficient oversight by the Governor, violating the separation of powers doctrine. The Act was designed to address issues of public trust in government by creating an independent body to enforce ethics and lobbying laws, particularly to mitigate the risk of self-regulation by the Executive Branch.In the lower courts, the Supreme Court of Albany County declared the investigation and enforcement provisions of the Act unconstitutional and enjoined proceedings against Cuomo. The Appellate Division stayed the order pending appeal but ultimately affirmed the Supreme Court's decision, concluding that the Act violated the separation of powers by expanding legislative power at the expense of the Executive Branch. The Appellate Division granted leave to appeal to the Court of Appeals.The New York Court of Appeals reviewed the case and concluded that the Act does not unconstitutionally encroach upon the powers of the Executive Branch. The court held that the Act is not unconstitutional in every conceivable application, emphasizing the flexible nature of the separation of powers doctrine in New York. The court noted that the Governor does not have exclusive powers of appointment and removal under the state constitution and that the Act's structure is consistent with the state's constitutional tradition. The court also found that the Act addresses a paramount state interest in maintaining public trust in government by ensuring impartial enforcement of ethics laws. The Court of Appeals reversed the Appellate Division's order, with costs, and declared the Act constitutional. View "Cuomo v New York State Commn. on Ethics & Lobbying in Govt." on Justia Law

Two defendants, Antonio Lemus and Carlos Daniel Canario-Vilomar, were convicted of cocaine-related charges under the Maritime Drug Law Enforcement Act (MDLEA). Lemus was apprehended on December 30, 2021, when U.S. Coast Guard officers intercepted a vessel north of Panama, found cocaine, and determined the vessel was without nationality after Colombia could not confirm its registration. Canario-Vilomar was arrested on December 6, 2021, when a similar vessel was intercepted north of Colombia, and the Dominican Republic could not confirm its registration. Both defendants were charged with conspiracy to possess and distribute cocaine on a vessel subject to U.S. jurisdiction.In the Southern District of Florida, Lemus pled guilty to both counts and was sentenced to 87 months in prison. In the Middle District of Florida, Canario-Vilomar pled guilty to conspiracy, and his motion to dismiss the indictment was denied. He was sentenced to 120 months in prison. Both defendants appealed, arguing that the MDLEA exceeded Congress's authority under the Felonies Clause of the Constitution and that their vessels were not stateless under international law. Canario-Vilomar also argued that his offense occurred in an Exclusive Economic Zone (EEZ), which he claimed was beyond Congress's regulatory authority.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Congress's authority under the Felonies Clause is not limited by international law, affirming that the MDLEA's definition of a "vessel without nationality" and the inclusion of the EEZ within the "high seas" were constitutional. The court also rejected Canario-Vilomar's due process argument, citing precedent that the MDLEA does not require a nexus to the United States for jurisdiction. Consequently, the Eleventh Circuit affirmed the convictions of both defendants. View "USA v. Canario-Vilomar" on Justia Law