Justia Constitutional Law Opinion Summaries

The case concerns Kenneth Robinson, who was convicted of malice murder and other offenses related to the shooting death of Devontae Jones and the aggravated assault of Charmisa Witherspoon. The evidence showed that Robinson, age fourteen at the time, was involved with the 9 Trey Bloods gang. After a gang member, Jesus Cintron, disappeared, the gang’s leader plotted to kill Witherspoon and her son, fearing Witherspoon would cooperate with law enforcement. Robinson and other gang members went to Witherspoon’s house, where Robinson participated in the assault. Witherspoon escaped, but her son was killed. Robinson was tried alongside several co-defendants.The Superior Court of Fulton County granted Robinson a directed verdict on several counts and dead docketed one count, later nol prossed. The jury found Robinson guilty on the remaining counts except one. He was sentenced to life plus forty-five consecutive years. Robinson filed a motion for new trial, which was denied. His initial appeal was dismissed due to a pending count, but after that count was nol prossed, he filed an amended notice of appeal.The Supreme Court of Georgia reviewed the case. Robinson argued that his trial counsel was ineffective for failing to communicate a plea offer, that his sentencing procedure violated constitutional and statutory rights, that the trial court misunderstood its sentencing discretion, and that certain counts should have merged for sentencing. The court held that trial counsel did communicate the plea offer, so there was no deficient performance. The court also found no constitutional or statutory violation in the sentencing procedure, noting that neither Robinson nor his counsel objected or requested to be heard. Claims regarding the trial court’s sentencing discretion and merger of counts were found to be waived or without merit. The Supreme Court of Georgia affirmed Robinson’s convictions. View "ROBINSON v. THE STATE" on Justia Law

A coastal town in Maine, known for its small population and proximity to a national park, experienced a significant increase in cruise ship tourism, with large vessels bringing thousands of passengers daily. In response to concerns about congestion, public safety, and the impact on local amenities, residents approved an ordinance capping the number of cruise ship passengers who could disembark in the town to 1,000 per day. The ordinance imposed fines for violations and was intended to address issues primarily at the waterfront and, to a lesser extent, in the downtown area.Several local businesses, a business association, and a pilots’ association challenged the ordinance in the United States District Court for the District of Maine. They argued that the ordinance was preempted by federal and state law, violated the Commerce Clause (including its dormant aspect), and infringed on due process rights. After a bench trial, the District Court largely ruled in favor of the town and an intervening resident, rejecting most claims but finding that the ordinance was preempted by federal regulations only to the extent it restricted crew members’ shore access. The court declined to enjoin the ordinance, noting the town’s intent to address this issue through further rulemaking.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s rejection of the state law preemption, federal preemption (except for the now-moot crew access issue), and due process claims. The First Circuit also affirmed the dismissal of discrimination-based Dormant Commerce Clause claims, finding no similarly situated in-state and out-of-state competitors. However, the court vacated and remanded the District Court’s dismissal of the Pike balancing Dormant Commerce Clause claim, instructing further analysis of whether the ordinance’s burdens on interstate commerce are clearly excessive in relation to its local benefits. The court dismissed as moot the appeals related to the crew access issue. View "Ass'n to Preserve and Protect Local Livelihoods v. Town of Bar Harbor" on Justia Law

Michael and Susan Mockeridge purchased a remote 40-acre property in northern Michigan, where they installed five prefabricated mini-cabins near their main cabin for family use. After neighbors became concerned that the property was being operated as a public campground, they filed complaints with local authorities. In response, three government officials—Harry Harvey, David Schmidt, and Kenneth Gibson—entered the Mockeridges’ property without a warrant or consent, inspected the mini-cabins and their surroundings, and gathered information regarding potential code violations. The officials’ entry was not via the customary driveway but through adjacent private land and dense woods, and at the time, the cabins were unoccupied.The Mockeridges subsequently received a letter from the county classifying their property as a campground and requiring licensing. After applying for permits and being told they would face penalties for prior unpermitted work, the Mockeridges filed suit in the United States District Court for the Eastern District of Michigan, alleging a violation of their Fourth Amendment rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of the Mockeridges on liability, denied qualified immunity to the officials, and found the only remaining issue was damages. The officials appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s denial of qualified immunity. The court held that the officials’ warrantless entry into the curtilage of the Mockeridges’ mini-cabins for the purpose of gathering information about code compliance constituted an unreasonable search under the Fourth Amendment. The court further held that the right to be free from such a warrantless search was clearly established at the time of the officials’ conduct. The court dismissed the Mockeridges’ cross-appeal and denied as moot a motion by Alcona County. View "Mockeridge v. Harvey" on Justia Law

An employee was hired by a company and, as a condition of employment, signed an agreement requiring all employment-related claims to be resolved through arbitration governed by the Federal Arbitration Act (FAA). The agreement specified that the employer would pay all arbitration costs except for certain fees. After the employee reported alleged workplace harassment and was subsequently terminated, he sued the employer in California Superior Court for retaliation and other violations. The employer moved to compel arbitration, which the court granted, and arbitration commenced. After about a year, the arbitrator issued invoices for fees, which the employer failed to pay within 30 days of receipt, as required by California Code of Civil Procedure section 1281.98. The employee then sought to withdraw from arbitration and proceed in court, arguing the employer’s late payment constituted a material breach under section 1281.98.The Superior Court denied the employee’s motion, reasoning that the arbitrator had set a new due date for payment and the employer paid within 30 days of that date. The California Court of Appeal reversed, holding that the statutory 30-day deadline applied from the original invoice date and that the employer’s late payment resulted in a material breach, allowing the employee to withdraw from arbitration. The Court of Appeal also held that section 1281.98 was not preempted by the FAA.The Supreme Court of California reviewed the case to determine whether section 1281.98 is preempted by the FAA. The court held that section 1281.98 is not preempted, but clarified that the statute does not abrogate longstanding contract principles allowing relief from forfeiture for non-willful, non-grossly negligent, or non-fraudulent breaches. The court reversed the Court of Appeal’s order lifting the stay and remanded for the trial court to determine whether the employer’s late payment was excusable and whether the employee suffered compensable harm. View "Hohenshelt v. Superior Court" on Justia Law

A religious association that supports abortion as part of its core beliefs challenged Idaho’s laws criminalizing abortion. The association, which operates a telehealth abortion clinic in New Mexico, claimed to have members in Idaho who would be affected by the abortion bans. However, it did not have any patients in Idaho, no clinic or doctors licensed to practice in Idaho, and could not identify any Idaho citizen who had sought or would imminently seek an abortion through the organization. The association argued that Idaho’s laws harmed its members and frustrated its mission, and that it had diverted resources to open its New Mexico clinic in response to abortion bans in Idaho and other states.The United States District Court for the District of Idaho granted the defendants’ motion to dismiss, finding that the association lacked both associational and organizational standing. The court also addressed the merits of the association’s constitutional claims and dismissed the complaint with prejudice.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal on the grounds of lack of Article III standing. The appellate court held that the association failed to show associational standing because it did not identify any specific member who had suffered or would imminently suffer an injury due to Idaho’s abortion laws. The court also found no organizational standing, as the association’s diversion of resources and alleged frustration of its mission were insufficient to establish standing under recent Supreme Court precedent. The Ninth Circuit did not reach the merits of the constitutional claims. The court remanded the case to the district court to determine whether the complaint could be saved by amendment, noting that dismissals for lack of jurisdiction should generally be without prejudice. View "THE SATANIC TEMPLE V. LABRADOR" on Justia Law

A man was involuntarily committed to the custody of Idaho’s Department of Health and Welfare under a state statute governing civil mental health commitments. After his commitment, hospital staff requested police assistance to transport him to another facility. When officers arrived, the man was cooperative and followed all instructions. Before placing him in the patrol car, an officer conducted a search for weapons. During this search, the officer felt an item in the man’s pocket that he suspected was drug-related, not a weapon. The officer reached into the pocket and found a small bag containing methamphetamine, leading to a felony drug possession charge.The Fifth Judicial District Court of Idaho reviewed the man’s motion to suppress the methamphetamine evidence, arguing that the search violated his Fourth Amendment rights. The district court found that the man was cooperative, showed no signs of being armed or dangerous, and that the officer did not have reasonable suspicion to believe he was carrying a weapon. The court concluded that the search was not justified under any recognized exception to the Fourth Amendment’s warrant requirement and granted the motion to suppress. The State’s subsequent motion for reconsideration was denied.On appeal, the Supreme Court of the State of Idaho considered whether the warrantless search of a person in civil protective custody under Idaho Code section 66-329 was permissible under the Fourth Amendment. The court held that the State failed to show the search fell within a well-recognized exception to the warrant requirement or was otherwise reasonable. The court clarified that the “community caretaking” function is not a standalone exception to the warrant requirement and that neither the search incident to arrest nor the special needs exception applied here. The Supreme Court of Idaho affirmed the district court’s order suppressing the evidence. View "State v. Adams" on Justia Law

Over a ten-day period in April 2020, a series of armed robberies targeted MetroPCS stores in the Miami area. The perpetrator, later identified as Francisco Louis, used a consistent method and attire, including a black Mercedes with a distinctive dent. After a police chase, Louis was apprehended, and evidence linking him to the robberies was recovered from his car, satchel, and residence. He was charged with six counts of Hobbs Act robbery.After his arrest, Louis spent several months in state custody before being transferred to federal custody in January 2021. The United States District Court for the Southern District of Florida granted four government-requested continuances for his arraignment and indictment, citing COVID-19 pandemic restrictions. Louis was indicted in April 2021, and his trial was initially set for August 2021. However, Louis, through counsel, requested three additional continuances to prepare for trial, resulting in the trial beginning in March 2022. He was convicted on all counts and sentenced to 218 months in prison.On appeal to the United States Court of Appeals for the Eleventh Circuit, Louis argued violations of both the Speedy Trial Act and the Sixth Amendment’s speedy trial guarantee, as well as challenges to the sufficiency of the evidence, jury instructions, and certain evidentiary rulings. The Eleventh Circuit held that Louis had waived his statutory Speedy Trial Act claim by failing to file a valid motion to dismiss before trial. Regarding the Sixth Amendment claim, the court found that although the delay was presumptively prejudicial, the reasons for delay were attributable to the pandemic and Louis’s own requests, and he failed to show actual prejudice. The court also rejected his other challenges and affirmed the conviction and sentence. View "USA v. Louis" on Justia Law

Three residents and taxpayers of a Minnesota school district challenged a provision in the collective bargaining agreement between the district and its teachers’ union. The agreement allowed teachers to take up to 100 days per year of paid leave to work for the union, with the union reimbursing the district for the cost of substitute teachers but not for the full salaries and benefits of the teachers on leave. The residents objected to the alleged political and campaign activities conducted by teachers during this leave and filed suit, claiming violations of the First Amendment, the Minnesota Constitution, and state labor law.Previously, the United States District Court for the District of Minnesota dismissed the case, finding that the residents lacked Article III standing. On an earlier appeal, the United States Court of Appeals for the Eighth Circuit held that the residents had adequately alleged municipal taxpayer standing at the motion to dismiss stage and remanded the case. On remand, the district court again granted summary judgment for lack of standing, concluding that the residents had not shown a sufficient injury in fact. The residents appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and held that two of the residents, as current municipal taxpayers, had Article III standing because they demonstrated that district funds were expended solely due to the challenged union leave policy. The court found that the expenditure of funds, even if partially reimbursed, constituted a direct injury to municipal taxpayers. The court also held that the intermingling of local, state, and federal funds in the district’s general fund did not defeat standing. The judgment of the district court was reversed, and the case was remanded for further proceedings. View "Huizenga v. ISD No. 11" on Justia Law

The defendant was convicted in 2012 of assaulting the mother of his child, which constituted a misdemeanor crime of domestic violence under New York law. Several years later, he was arrested in New York City for possessing a firearm, specifically a .380 caliber pistol, after having been previously convicted of that domestic violence misdemeanor. He pleaded guilty to one count of possessing a firearm after a domestic violence conviction, in violation of 18 U.S.C. § 922(g)(9). At sentencing, the district court considered his criminal history, including a 2013 state drug conviction, and imposed a forty-eight-month prison term and three years of supervised release.The United States District Court for the Southern District of New York determined that the 2013 state drug conviction did not qualify as a “controlled substance offense” under the federal Sentencing Guidelines, resulting in a lower base offense level for sentencing. Both the defendant and the government appealed: the defendant challenged the constitutionality of § 922(g)(9) under the Second Amendment and the reasonableness of his sentence, while the government contested the district court’s interpretation of the drug conviction under the Guidelines.The United States Court of Appeals for the Second Circuit held that § 922(g)(9) is constitutional, both facially and as applied to the defendant, because it is consistent with the nation’s historical tradition of disarming individuals deemed dangerous, such as those convicted of domestic violence misdemeanors. The court also found that the defendant’s sentencing challenges were moot, as he had completed his prison term and there was no indication the district court would reduce his supervised release. Additionally, the court agreed with the government’s concession that its cross-appeal was foreclosed by recent precedent. The court dismissed the appeal in part as moot and otherwise affirmed the district court’s judgment. View "United States v. Simmons" on Justia Law

In 1973, Fred Krug committed murder and other violent crimes while on parole, leading to his conviction and a life sentence plus additional consecutive terms. Over the years, Krug accumulated numerous disciplinary infractions in prison but had maintained a largely clean record since 2003, aside from a single incident in 2017. He was denied parole in 1994, 1995, 2012, and 2016. In 2022, at age 75, Krug became eligible for parole again. A two-member panel of the New Jersey State Parole Board denied his application in 2023, citing both old and new information, including his criminal history and institutional behavior, and set his next eligibility for thirty-six months later.Krug appealed the denial to the full Parole Board, arguing that the panel violated the 1979 Parole Act by failing to present new evidence since his last denial, as that Act required only “new information” to be considered at subsequent hearings. The full Board affirmed the denial, explaining that a 1997 amendment had removed the new-information limitation, allowing consideration of the entire record at each hearing. Krug then appealed to the Superior Court, Appellate Division, which upheld the Board’s decision, relying on its earlier ruling in Trantino v. State Parole Board (Trantino V) that the 1997 amendment was a procedural change and did not violate ex post facto protections.The Supreme Court of New Jersey reviewed the case and held that constitutional ex post facto prohibitions bar only punishment beyond what was contemplated at the time the crime was committed. Since the law in effect when Krug committed his offenses (the Parole Act of 1948) permitted the Board to consider all available information, the retroactive application of the 1997 amendment did not increase his punishment. The Court therefore rejected Krug’s ex post facto challenge and affirmed the lower court’s judgment as modified. View "Krug v. New Jersey State Parole Board" on Justia Law