Justia Constitutional Law Opinion Summaries

The case concerns a late-night car crash in Bloomington, San Bernardino County, where Steven Richard Castro collided with a parked vehicle, injuring its occupant. Neighbors restrained Castro, who tried to flee, and emergency personnel transported him to the hospital due to his combative behavior. CHP Officer Pope, stationed at the hospital on another matter, was notified about Castro's arrival and subsequently observed Castro sedated and unresponsive in the ER. Pope noted the smell of alcohol and, after gathering information from witnesses and the victim, arrested Castro on suspicion of DUI causing injury. Without seeking a warrant, Pope ordered a blood draw, relying on implied consent law. The blood test showed a high BAC.In the San Bernardino County Superior Court, Castro moved to suppress the blood test results, arguing that a warrant should have been obtained. The magistrate denied the motion, citing exigent circumstances per Mitchell v. Wisconsin, reasoning that Officer Pope’s time in the hospital justified the warrantless blood draw. Castro renewed his suppression request in a pretrial motion, but the court again found the officers’ actions constitutional based on the totality of circumstances and Castro’s unconsciousness, leading Castro to enter a no contest plea.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that the record did not support a finding of exigency sufficient to excuse the failure to obtain a warrant for the blood draw. The court emphasized that Mitchell v. Wisconsin does not create a categorical rule for unconscious DUI suspects and, following its reasoning in People v. Alvarez, found no evidence that obtaining a warrant would have interfered with other pressing duties. The judgment was reversed, and the matter remanded with directions to grant the suppression motion and permit Castro to withdraw his plea. View "People v. Castro" on Justia Law

A man was convicted for malice murder and related offenses stemming from a murder-for-hire scheme in 2000, where the victim was killed in her Georgia apartment. The prosecution argued that the murder was orchestrated by the victim’s father-in-law, who opposed her marriage, and that the appellant was the hired killer, with testimony from accomplices and witnesses supporting this theory. The appellant's trial was marked by difficulties in securing expert witnesses and conducting mitigation investigations due to funding shortfalls in Georgia’s indigent defense system, which hampered his defense’s ability to prepare. Eventually, he was convicted on several counts and initially sentenced to death, with subsequent modifications after further proceedings.After conviction, the appellant’s attorneys from the Capitol Defender’s Office filed a motion for a new trial, later amended and supplemented by other attorneys from the same office. The Superior Court of Fulton County partially granted the motion, ordering a new trial solely on the issue of “mental retardation” for sentencing purposes, due to the late development of evidence related to this issue, which was attributed to a breakdown in indigent defense funding. Later, a new judge re-sentenced the appellant to life without parole in accordance with that order. Other grounds for a new trial were denied, and the appellant retained private counsel to pursue his appeal.The Supreme Court of Georgia reviewed the case and determined that, because this appeal was the appellant’s first opportunity to raise ineffective assistance of counsel claims (having been continuously represented by the same public defender’s office), the record was insufficiently developed on this issue. The Court vacated the trial court’s judgment in part and remanded the case for an evidentiary hearing on the ineffective assistance claims. Other claims regarding denial of a continuance and competency to stand trial were rejected, as the appellant failed to show harm or preserve those issues. Judgment was affirmed in part and vacated and remanded in part. View "CLARK v. THE STATE" on Justia Law

The case involves a defendant who was convicted of malice murder and other related crimes following the fatal shooting of a convenience store owner late at night. Surveillance footage captured the movements of three assailants before and after the shooting, and law enforcement linked the defendant to the crime through evidence including a matching vehicle, clothing, cell phone records, and an anonymous tip. During the investigation, police obtained multiple search warrants that led to the seizure of various pieces of evidence, such as cell phones and ammunition. The defendant challenged the legitimacy of these warrants, arguing that the affidavits supporting them included material misrepresentations and omissions by police.After being indicted and tried in the Superior Court of DeKalb County, the defendant was convicted on all counts and sentenced to life imprisonment without parole for malice murder, with additional consecutive sentences for other offenses. The trial court merged some counts and vacated others as required by law. The defendant moved for a new trial, which was denied after a hearing. He then appealed, arguing that the trial court erred in denying his motion to suppress evidence due to alleged false statements in the search warrant affidavits and that his right to confront witnesses was violated by the admission of substitute expert testimony.The Supreme Court of Georgia reviewed the case. The court held that the trial court had not properly applied the standard from Franks v. Delaware for assessing whether false statements in warrant affidavits were made knowingly, intentionally, or with reckless disregard for the truth. The Supreme Court of Georgia vacated the trial court’s judgment on the motion to suppress and remanded the case for further proceedings consistent with the proper Franks analysis, leaving other issues unresolved pending that review. View "MILLER v. THE STATE" on Justia Law

A pharmaceutical manufacturer participating in the federal 340B Drug Pricing Program challenged a Missouri law that prohibits manufacturers from restricting the delivery of discounted 340B drugs to contract pharmacies associated with covered entities. The manufacturer argued that its policy of limiting deliveries to only one contract pharmacy conflicted with Missouri’s statute, which requires delivery to all contract pharmacies designated by covered entities. The manufacturer sought declaratory and injunctive relief, claiming the Missouri statute violated the dormant Commerce Clause and was preempted by federal law.The United States District Court for the Western District of Missouri granted a motion to dismiss the manufacturer’s preemption claims, finding Missouri’s statute did not conflict with federal patent or drug exclusivity laws or the 340B Program, and that Eighth Circuit precedent foreclosed the field preemption argument. The court denied the motion to dismiss the dormant Commerce Clause claim, but ultimately denied the manufacturer’s motion for a preliminary injunction, concluding the manufacturer was unlikely to succeed on the merits of its claims, had not shown irreparable harm, and that the balance of equities and public interest weighed against preliminary relief.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of preliminary injunction under the abuse of discretion standard. The appellate court affirmed the district court’s decision, holding that the Missouri statute regulates only in-state delivery of 340B drugs and does not impermissibly control extraterritorial commerce, discriminate against interstate commerce, or impose excessive burdens in relation to local benefits. The court also found the manufacturer’s preemption claims foreclosed by Eighth Circuit precedent and concluded the statute is neither field nor conflict preempted. The district court’s denial of preliminary injunctive relief was affirmed. View "Novartis Pharmaceuticals Corp. v. Hanaway" on Justia Law

Texas Tobacco Barn operated a laboratory and retail shop in Lubbock, Texas, manufacturing and selling e-liquids and vape products. After applying for authorization to sell over 2,200 vape products, including Barn Brewed Beetle Juice e-liquids, the FDA denied approval and warned that these products were considered “adulterated” and “misbranded.” Despite assurances from Texas Tobacco Barn that it would cease sales, a subsequent FDA inspection revealed continued sale of unauthorized products. The FDA initiated proceedings seeking a civil penalty of $19,192 for violations.The enforcement action began with an administrative hearing before an HHS administrative law judge (ALJ), who reviewed evidence including inspection photos and testimony from an FDA inspector. Texas Tobacco Barn admitted that the e-liquids lacked FDA authorization but disputed the inspector’s findings and challenged the FDA’s regulatory authority. The ALJ concluded that the FDA proved its case by a preponderance of the evidence and imposed the civil penalty. On appeal, the HHS Departmental Appeals Board affirmed the ALJ’s ruling, agreeing the ALJ lacked jurisdiction to address constitutional challenges but offering advisory comments on those defenses.Reviewing the agency’s final decision, the United States Court of Appeals for the Fifth Circuit considered Texas Tobacco Barn’s statutory and constitutional arguments. The court rejected the nondelegation challenge, citing its own precedent and Supreme Court guidance clarifying FDA’s explicit authority to regulate vape products. However, the Fifth Circuit held that the administrative process violated Texas Tobacco Barn’s Seventh Amendment right to a jury trial. The court determined that civil penalties for FDCA violations are legal in nature and do not fall under the public-rights exception that would permit agency adjudication without a jury. As a result, the Fifth Circuit granted the petition and vacated the agency’s decision. View "Texas Tobacco Barn v. HHS" on Justia Law

The defendant, a seventy-year-old man with a long history of alcohol use, was stopped by law enforcement after driving erratically and making multiple traffic violations. He was observed to be impaired, failed a field sobriety test, and later refused breath and blood tests, leading to a warrant for a blood draw that revealed a blood alcohol content over three times the legal limit. Investigation revealed he was driving with a suspended license and had three prior DUI convictions. He was charged with felony DUI (fourth or subsequent offense) and driving while suspended, but the latter charge was dismissed in exchange for his guilty plea to the DUI charge.The Montana Sixteenth Judicial District Court sentenced him to thirteen months with the Department of Corrections, recommended placement in an alcohol treatment program, and imposed a consecutive four-year suspended sentence. The court also imposed the statutory minimum fine of $5,000 but suspended half of it due to the defendant’s financial circumstances. The defendant appealed the imposition of the fine, arguing that the statute mandating the fine was unconstitutional based on recent case law. He maintained that the fine should not have been imposed without proper consideration of his ability to pay.The Supreme Court of the State of Montana held that the defendant did not waive his right to appellate review of the fine by agreeing to it in the plea agreement, as subsequent case law developments questioned the constitutionality of the statute. The Court reaffirmed that the sentencing court must impose the mandatory fine under the statute, then determine the defendant’s ability to pay, and may suspend any portion of the fine accordingly. The Supreme Court affirmed the imposition of the $5,000 fine but vacated the portion of the judgment relating to the fine and remanded to the District Court for explicit findings on the defendant’s ability to pay before determining how much of the fine should be suspended. View "State v. Hagberg" on Justia Law

Police responded to a domestic violence call involving the defendant after his girlfriend reported he had a firearm. Officers later found a purple handgun along the route the defendant had taken, and DNA evidence linked the gun to him. He was charged with felony domestic violence, misdemeanor unlawful carrying of a handgun, and felony unlawful carrying of a handgun by a felon with a prior conviction within the past fifteen years. The charging documents listed his two previous Texas felony convictions—one for Felon in Possession of a Weapon in 2014 and another for Aggravated Assault–Family Member in 2017—as the basis for the firearm charges.The Tippecanoe Superior Court dismissed both handgun-related charges, finding that the charging information was not sufficiently specific, did not constitute an offense, and that the statute used to enhance his charge was unconstitutionally vague under both federal and state constitutions. The trial court referenced an unrelated but identical dismissal for another defendant and issued a final judgment, allowing the State to appeal directly.The Indiana Supreme Court reviewed the case under its mandatory jurisdiction following a trial court finding of unconstitutionality. The court held that the charging information for both the misdemeanor and felony handgun counts was sufficiently certain and constituted an offense under Indiana law, as it included the necessary elements and identified the prior convictions. The court further held that the trial court had misapplied the relevant statute and that the enhancement to a felony did not require the prior out-of-state conviction to be substantially similar to an Indiana offense, only that it was a felony within fifteen years. The Indiana Supreme Court reversed the trial court’s dismissal of both handgun charges and remanded for further proceedings. View "State v. Jones" on Justia Law

A woman was the primary caregiver for her friend, residing in her friend’s condominium for several years. After the friend passed away, ownership of the condo transferred to a living trust, and the caregiver became trustee. She continued living in the condo for a month to recover from illness and remove her belongings. The friend’s nephew contacted local police, claiming the right to evict her, and presented officers with a superseded will listing him as a beneficiary but not mentioning the condo. The officers accompanied the nephew to the condo, told the caregiver she had ten minutes to leave, threatened her with arrest, pushed her out, and took her key.The United States District Court for the Southern District of Ohio reviewed the case after the caregiver sued various parties, alleging Fourth Amendment violations. The court granted summary judgment to some defendants but denied it for the officers, reasoning that the caregiver, as trustee, held a possessory interest in the condo, and the officers’ actions constituted active participation in an eviction without proper legal authority. The court relied on Sixth Circuit precedent to find the seizure unreasonable and the right clearly established.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity. The appellate court held that the caregiver had a possessory interest in the condo at the time of the eviction, the officers actively participated in the eviction, and their conduct was unreasonable under the Fourth Amendment because there was no court order or exigent circumstances justifying the seizure. The court further held that existing precedent clearly established the unlawfulness of the officers’ actions. The Sixth Circuit affirmed the district court’s denial of summary judgment, leaving the officers subject to further proceedings. View "Bender v. Village of Mariemont" on Justia Law

After the 2020 mayoral election in Maricao, Puerto Rico, the Popular Democratic Party candidate, Wilfredo Ruiz-Feliciano, assumed office, replacing the New Progressive Party incumbent. Odette López Collazo, a longstanding NPP member who had served as Internal Auditor since 1994, was not reappointed by the new mayor. López Collazo alleged that her non-reappointment was due solely to her political affiliation and constituted political discrimination in violation of her First and Fourteenth Amendment rights. She also asserted related claims against other municipal officials regarding the failure to pay out her accrued leave, but only the claim against Ruiz-Feliciano for political discrimination remained at issue in this appeal.The United States District Court for the District of Puerto Rico granted summary judgment in favor of Ruiz-Feliciano. The court concluded that First Amendment protections against political discrimination did not apply to a decision not to hire or reappoint, and further reasoned that because the Internal Auditor position was a “trust” position under Puerto Rico law, the mayor could hire and fire at will, including for political reasons. López Collazo moved for reconsideration, which was denied, and then sought partial final judgment under Rule 54(b) to appeal. After resolving procedural questions regarding finality, all claims but the political discrimination claim against Ruiz-Feliciano were dismissed with prejudice, and the appeal proceeded.The United States Court of Appeals for the First Circuit reviewed the district court’s grant of summary judgment de novo. The Court of Appeals held that First Amendment protections do apply to a failure to hire or reappoint a public employee, and that legislative classification of a position as a “trust” position is not dispositive in determining whether political affiliation is an appropriate requirement. The appellate court vacated the district court’s summary judgment and remanded for further proceedings. View "Lopez Collazo v. Ruiz-Feliciano" on Justia Law

Deanthony Cullins was indicted on multiple counts, including malice murder and aggravated assault, stemming from a June 2022 incident in which he was accused of shooting at a vehicle, resulting in the death of Dy’Sheae Hall. Cullins claimed self-defense. In the lead-up to trial, the State sought a continuance days before the scheduled date, citing late receipt of deposition transcripts, but the trial court denied the request. The State also filed an untimely motion to admit other acts evidence, which was denied. During trial, the prosecutor questioned a detective about Cullins’s refusal to make a statement to police, prompting the defense to object on grounds that the questioning improperly commented on Cullins’s right to remain silent. The defense moved for a mistrial, suggesting the prosecutor’s conduct was intentional to provoke a mistrial, and the trial court granted the mistrial.After the mistrial, Cullins filed a plea in bar, arguing that retrial should be barred under the Double Jeopardy Clause because the State had intentionally provoked the mistrial. The Superior Court of DeKalb County held a hearing and found that the prosecutor’s actions were deliberate, noting the State’s lack of readiness for trial, the benefit to the State of a second chance, and the seasoned experience of those involved. The trial court concluded that the State had goaded the defense into seeking a mistrial.On appeal, the Supreme Court of Georgia reviewed whether the trial court clearly erred in finding that the State had intentionally provoked a mistrial. The Supreme Court determined there was evidence to support the trial court’s findings and that they were not clearly erroneous. The Court affirmed the grant of the plea in bar, holding that retrial was barred because the prosecutor’s conduct was intended to provoke a mistrial for a more favorable opportunity to convict. View "STATE v. CULLINS" on Justia Law