Justia Constitutional Law Opinion Summaries

The case involves Jeffery S. Armstrong, who was charged with carrying a concealed weapon, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony after police discovered a handgun under the passenger seat of a vehicle in which he was sitting. Corporal Treva Eaton claimed she approached the vehicle because she smelled marijuana emanating from it. Armstrong moved to suppress the gun as evidence, arguing it was obtained through a search that violated the Fourth Amendment.The Wayne Circuit Court ruled that Armstrong was seized when officers surrounded the vehicle and that probable cause was required before ordering him out. The court concluded that the smell of marijuana alone did not establish probable cause to search or justify removing Armstrong from the vehicle and ruled that the plain-view exception did not apply. Consequently, the trial court granted Armstrong’s motion to suppress and dismissed the case.The prosecution appealed, and the Michigan Court of Appeals affirmed the trial court’s decision. The appellate court held that the rule from People v. Kazmierczak, which allowed the smell of marijuana alone to establish probable cause, was superseded by the Michigan Regulation and Taxation of Marihuana Act (MRTMA). The court concluded that the smell of marijuana is no longer necessarily indicative of unlawful activity and that the trial court did not clearly err in finding that the gun was not discovered in plain view.The Michigan Supreme Court reviewed the case and held that the Kazmierczak rule is no longer valid in light of the MRTMA. The court ruled that the smell of marijuana is one factor in the probable-cause determination but is insufficient on its own to support a search. The court affirmed the lower courts' decisions, upholding the suppression of the evidence and the dismissal of the charges against Armstrong. View "People Of Michigan v. Armstrong" on Justia Law

The City of Bakersfield operates multiple weirs on the Kern River to divert water for its use and for several water agencies, including the North Kern Water Storage District (NKWSD) and the Buena Vista Water Storage District. Environmental groups, including Bring Back the Kern (BBTK) and Water Audit California (WAC), sought and obtained a preliminary injunction from the Superior Court of Kern County. The injunction prohibited Bakersfield from operating the weirs in a manner that reduced Kern River flows below the volume sufficient to keep fish downstream in good condition. The trial court refused to consider the potential harm to the City or the water agencies in determining the applicability of the injunction.The water agencies filed motions for reconsideration, arguing that the injunction and the subsequent order setting a flow rate were issued without proper consideration of their interests. The trial court stayed the flow rate order and modified the injunction, but the water agencies appealed the injunction and the order setting a flow rate.The California Court of Appeal, Fifth Appellate District, held that under the self-executing provisions of article X, section 2 of the state Constitution, courts must always consider the reasonableness of water use when adjudicating such cases. The court found that the trial court's failure to consider the reasonableness of the water use it was ordering in the injunction was a constitutional error. Consequently, the appellate court reversed the injunction and the order setting a flow rate and remanded the case for further proceedings. The appellate court also addressed issues related to the bond requirement and the due process rights of the water agencies, concluding that the trial court erred in setting a nominal bond and in issuing an implementation order that affected the water agencies without their agreement. View "Bring Back the Kern v. City of Bakersfield" on Justia Law

Two plaintiffs, Beth Cummings and Dena Burnham Johnson, filed a petition to annul or void an election that provided additional funds for the Great Falls Public Library. They alleged discrepancies in the election process, including a mathematical error in the ballot and a lack of clear information provided to voters. The election, held in June 2023, resulted in the approval of a mill levy increase to support the library.The Eighth Judicial District Court of Montana dismissed the plaintiffs' petition under Rule 12(b)(6) for failure to state a legally cognizable claim. The court found that the plaintiffs' allegations did not demonstrate a violation of their constitutional rights to suffrage or due process. The court also noted that the mathematical error on the ballot was minor and did not mislead voters to the extent that it would invalidate the election results. Additionally, the court determined that the plaintiffs' claims of election law violations were not applicable to the mill levy election.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision. The court held that the plaintiffs' right of suffrage was not violated, as they were not prevented from voting and were not misled by the ballot language. The court also concluded that the due process claim was unfounded, as the election process and materials provided sufficient information to voters. Furthermore, the court agreed with the lower court that the plaintiffs' claims under state election laws were not relevant to the mill levy election.The Supreme Court also upheld the lower court's denial of the plaintiffs' motion to amend their petition, finding that the proposed amendments would be futile and would cause substantial prejudice to the defendants. The court concluded that the plaintiffs' additional legal arguments did not present a valid controversy and that the defendants had already expended significant resources in the case. View "Cummings v. Kelly" on Justia Law

Gary Jordan, the defendant, pled guilty to armed bank robbery and other crimes, receiving a thirty-year prison sentence. After his plea, he discovered that prosecutors had recorded his attorney-client meetings before he entered his plea. Although the prosecutors claimed they did not watch the recordings, Jordan moved to vacate his guilty plea, arguing that the prosecutors' actions rendered his plea unconstitutionally unknowing and involuntary.The United States District Court for the District of Kansas denied Jordan's motion, stating that he could only challenge his guilty plea through an ineffective assistance of counsel claim, as the alleged unconstitutional conduct occurred before the plea. Jordan did not raise a claim of prejudice or ineffective assistance of counsel, relying solely on the structural-error theory from Shillinger v. Haworth. The district court concluded that Jordan could not prevail on this basis.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, holding that under Tollett v. Henderson, a defendant who has pled guilty cannot raise independent claims of constitutional violations that occurred before the plea. Instead, the defendant must show that the plea was not knowing and voluntary due to ineffective assistance of counsel, unless the plea was induced by threats, misrepresentations, or improper prosecutorial promises. The court found that Jordan's challenge failed because he did not pursue an ineffective assistance of counsel claim and relied solely on the now-overruled structural-error rule from Shillinger. The Tenth Circuit affirmed the district court's denial of Jordan's motion to vacate his guilty plea. View "United States v. Jordan" on Justia Law

United Water Conservation District (United) filed a lawsuit against the United States, seeking just compensation for an alleged taking under the Fifth Amendment. United claimed that the National Marine Fisheries Service (NMFS) required it to increase the amount of water bypassing its diversion dam to protect an endangered species of trout, resulting in a loss of water that United could otherwise use for beneficial purposes.The United States Court of Federal Claims dismissed United's complaint for lack of subject matter jurisdiction, determining that the claim should be evaluated as a regulatory taking. The court reasoned that United had not yet exhausted its administrative remedies by applying for and being denied an incidental-take permit under the Endangered Species Act, making the claim not ripe for adjudication.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the lower court's decision. The appellate court agreed that United's claim was regulatory in nature, as the NMFS's actions did not constitute a physical appropriation of water already diverted by United. Instead, the actions required more water to remain in the river, representing a regulatory restriction on United's use of the water. The court held that United's claim was not ripe because it had not yet obtained a final agency action by applying for and being denied an incidental-take permit. Therefore, the dismissal for lack of subject matter jurisdiction was appropriate. View "UNITED WATER CONSERVATION DISTRICT v. US " on Justia Law

Jimmy Giddings, a drug dealer, was murdered during a home invasion at his residence in Dallas. Security cameras captured four masked men loitering near the scene before the crime. When Giddings arrived home, the men attacked, resulting in Giddings being fatally shot and his girlfriend, Nikita Dickerson, sustaining non-life-threatening injuries. The police used a "geofence" warrant to obtain location data from Google, which identified a device belonging to the appellant, Aaron Rayshan Wells, at the crime scene. This led to the identification of the other three assailants.The trial court denied Wells' motion to suppress the evidence obtained through the geofence warrant, ruling that the warrant was sufficiently particular. The Fifth Court of Appeals affirmed this decision, concluding that the warrant was narrowly tailored to capture only relevant data and that there was probable cause to believe the suspects carried cell phones with Google location services enabled.The Court of Criminal Appeals of Texas reviewed the case and affirmed the lower court's decision. The court held that the geofence warrant was supported by probable cause and met the Fourth Amendment's particularity requirement. The warrant was deemed sufficiently specific in terms of time and location, minimizing the risk of capturing data from uninvolved individuals. The court concluded that the warrant's three-step process did not require additional judicial oversight due to its narrow scope. View "WELLS v. STATE OF TEXAS" on Justia Law

John A. Poole was convicted in 2002 of first-degree murder, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony. He was 18 years old at the time of the crime and was sentenced to life imprisonment without the possibility of parole. The Michigan Court of Appeals affirmed his convictions, and the Michigan Supreme Court denied his application for leave to appeal. Poole filed multiple motions for relief from judgment, which were denied.Following the U.S. Supreme Court's decisions in Miller v. Alabama and Montgomery v. Louisiana, which addressed mandatory life sentences for juveniles, Poole sought relief again. The Michigan Supreme Court remanded the case to the Court of Appeals to determine if Poole was entitled to relief under the state constitution's prohibition on cruel or unusual punishment, as extended to 18-year-olds in People v. Parks. The Court of Appeals held that Parks applied retroactively and vacated Poole's sentence, remanding for resentencing.The Michigan Supreme Court reviewed whether Parks should apply retroactively to cases where the period for direct review had expired. The court held that Parks, which extended Miller's protections to 18-year-olds under the Michigan Constitution, announced a substantive rule and should be applied retroactively. The court overruled the state retroactivity analysis in People v. Carp to the extent it survived Montgomery. The court affirmed the Court of Appeals' decision to vacate Poole's sentence and remanded the case for resentencing under MCL 769.25a. View "People Of Michigan v. Poole" on Justia Law

Ethel Barry Masters filed a petition against Jacob Dawson in 2019, alleging replevin, conversion, and unjust enrichment after Dawson refused to surrender possession of four vehicles that belonged to Masters' deceased long-term companion. Dawson disputed ownership and obstructed the legal process, including failing to respond to requests for admissions and barricading the vehicles to prevent towing. The circuit court granted partial summary judgment in favor of Masters, ordering Dawson to surrender the vehicles, which he did not comply with. Dawson's attorney withdrew due to ethical concerns, and subsequent attorneys also withdrew due to Dawson's failure to pay legal fees.The Circuit Court of St. Louis County scheduled multiple trial dates, which were postponed due to Dawson's actions, including retaining new attorneys and filing motions for continuance. Dawson failed to appear for a pretrial conference, leading the circuit court to cancel the jury trial and enter a default judgment in favor of Masters, awarding her $83,035.41 in actual damages and an equal amount in punitive damages. Dawson's conduct was deemed contemptuous, justifying punitive damages to deter similar behavior.The Supreme Court of Missouri reviewed the case and found that Dawson's constitutional claims regarding the right to a jury trial were unpreserved because he did not adequately raise them in his motion for a new trial. The court held that the circuit court did not abuse its discretion by sanctioning Dawson due to his pattern of obstructive behavior. The Supreme Court of Missouri affirmed the circuit court's judgment, upholding the damages awarded to Masters. View "Masters v. Dawson" on Justia Law

Michael A. Tanzi was sentenced to death for the murder of Janet Acosta. On March 10, 2025, Governor Ron DeSantis signed a death warrant scheduling Tanzi’s execution for April 8, 2025. Tanzi sought relief in the circuit court, which was denied, leading to his appeal to the Supreme Court of Florida.The circuit court had previously denied Tanzi’s first motion for postconviction relief under Florida Rule of Criminal Procedure 3.851, and the Florida Supreme Court affirmed this denial. Tanzi’s petition for state habeas relief was also denied. He then sought federal habeas relief, which was denied by the district court and affirmed by the Eleventh Circuit. Tanzi’s subsequent motion for postconviction relief under Hurst v. Florida was denied by the Florida Supreme Court, which found the Hurst error in his case harmless beyond a reasonable doubt.The Supreme Court of Florida reviewed Tanzi’s appeal of the denial of his third motion for postconviction relief, which raised claims about due process violations due to the compressed warrant period, the constitutionality of Florida’s lethal injection protocols, and the Governor’s authority in determining the timing of death warrants. The court affirmed the circuit court’s summary denial of these claims, finding them either procedurally barred or without merit. The court also denied Tanzi’s habeas petition, which argued that his death sentence was unconstitutional under Erlinger v. United States, and dismissed his emergency petition to invoke the court’s all writs jurisdiction.The Supreme Court of Florida held that the warrant litigation schedule did not violate Tanzi’s due process rights, the denial of public records requests was not an abuse of discretion, and the lethal injection protocol did not constitute cruel and unusual punishment. The court also upheld the Governor’s authority in signing death warrants and found no merit in Tanzi’s habeas petition. The court denied all of Tanzi’s motions and requests, including a stay of execution. View "Tanzi v. State" on Justia Law

Veterans Guardian VA Claim Consulting LLC, along with John F. Rudman and Andre Jesus Soto, challenged a New Jersey law that restricts charging for advice on claiming veterans benefits. Veterans Guardian, a consulting company, provides paid advice to veterans on how to claim benefits. The plaintiffs argued that the New Jersey law, which mirrors federal regulations but adds civil enforcement mechanisms, violates their First Amendment rights.The United States District Court for the District of New Jersey denied the plaintiffs' request for a preliminary injunction, concluding that the law did not trigger First Amendment scrutiny because it regulated conduct, not speech. The plaintiffs appealed this decision.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court made several errors. The Third Circuit held that Veterans Guardian's services likely constitute speech and that New Jersey's law burdens that speech by prohibiting charging for it. The court emphasized that laws restricting compensation for speech must survive First Amendment scrutiny. The Third Circuit also noted that the District Court failed to analyze the separate provisions of the New Jersey law, which impose different restrictions on speech. The court expressed skepticism about the constitutionality of the provision that bans accepting payment for services rendered before a veteran appeals the VA's initial benefits decision.The Third Circuit vacated the District Court's decision and remanded the case for further consideration, instructing the lower court to develop a fuller record and reconsider the plaintiffs' motion for a preliminary injunction with the guidance provided. View "Veterans Guardian VA Claim Consulting LLC v. Platkin" on Justia Law