Justia Constitutional Law Opinion Summaries

Matthew Morrison was convicted of a sexually violent offense and sentenced to prison. Before his release, the Santa Clara County District Attorney filed a petition to commit him as a sexually violent predator under the Sexually Violent Predator Act (SVPA). The trial court found the petition true, declared Morrison a sexually violent predator, and committed him to the State Department of State Hospitals for an indeterminate term.Morrison appealed, arguing that the trial court violated his constitutional rights by not personally advising him of his right to a jury trial and securing a personal waiver of that right. He claimed that the SVPA’s failure to require a personal jury trial advisement and waiver, unlike other civil commitment statutes, violated the constitutional equal protection guarantee.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court determined that Morrison’s equal protection challenge was subject to rational basis review. Since Morrison did not raise the issue in the trial court, the appellate court conditionally affirmed the commitment order and remanded the matter to allow Morrison to raise his equal protection claim before the trial court. The appellate court provided guidance on the principles the trial court should apply when resolving Morrison’s constitutional claim. View "P. v. Morrison" on Justia Law

Darrell Robinson was convicted of being a felon in possession of firearms, in violation of 18 U.S.C. § 922(g), after law enforcement officers found six firearms in his vehicle during a search. Robinson pled guilty to the charge and was sentenced to 50 months’ imprisonment and three years of supervised release. The district court also imposed a special condition of supervised release that allowed for the search of Robinson’s electronic devices upon reasonable suspicion of a violation of a condition of supervision.The United States District Court for the Eastern District of New York adopted the Presentence Investigation Report (PSR) without modification and imposed the special search condition as recommended in the PSR. Robinson did not object to the PSR or the special condition during sentencing but later moved to correct the judgment, arguing that the electronic search condition was not orally pronounced at sentencing. The district court denied the motion, finding that it had met its obligation by referencing the PSR.The United States Court of Appeals for the Second Circuit reviewed Robinson’s appeal, where he argued that the electronic search condition was not orally pronounced, was procedurally unreasonable, and violated his Fourth Amendment rights. The court found that the district court’s reference to the PSR was sufficient to impose the special condition, and the need for the condition was self-evident given Robinson’s extensive criminal history and dishonesty with law enforcement. The court also held that the condition, which required reasonable suspicion, did not violate Robinson’s Fourth Amendment rights due to his diminished expectation of privacy while on supervised release.The Second Circuit affirmed the judgment of the district court, upholding the special condition of supervised release allowing for the search of Robinson’s electronic devices. View "United States v. Robinson" on Justia Law

David Knellinger and Robert Storey discovered that the state of Colorado had taken possession of their property under the Revised Uniform Unclaimed Property Act (RUUPA). They filed a lawsuit under 42 U.S.C. § 1983, claiming that Colorado's unclaimed property scheme violated the Takings Clause of the Fifth Amendment. The plaintiffs alleged that Colorado took their property for public use without just compensation and did not provide them with notice or compensation.The United States District Court for the District of Colorado dismissed the plaintiffs' claims for lack of standing. The court found that Knellinger and Storey failed to sufficiently allege ownership of the property at issue, partly because they did not file an administrative claim to establish ownership as required by RUUPA. The district court also dismissed the plaintiffs' equitable claims, concluding that § 1983 provided an adequate basis for obtaining just compensation.The United States Court of Appeals for the Tenth Circuit reviewed the case and determined that the district court erred in dismissing the plaintiffs' claims for monetary relief. The appellate court held that Knellinger and Storey had plausibly alleged that Colorado took their property for public use without just compensation, which is sufficient to confer standing. The court emphasized that property owners need not file administrative claims with Colorado before suing for just compensation under the Takings Clause. However, the appellate court affirmed the district court's dismissal of the plaintiffs' equitable claims, as § 1983 provides an adequate remedy for obtaining just compensation.The Tenth Circuit reversed the district court's dismissal of the plaintiffs' damages claims and remanded the case for further proceedings consistent with its opinion. View "Knellinger v. Young" on Justia Law

Andrew Czarnecki and Montario Taylor were convicted of first-degree premeditated murder in separate cases. Czarnecki was 19 years old at the time of his crime, while Taylor was 20 years old. Both were sentenced to mandatory life in prison without the possibility of parole (LWOP) as required by Michigan law. They argued that their sentences were unconstitutional under Michigan’s prohibition against cruel or unusual punishment.Czarnecki’s conviction and sentence were affirmed by the Michigan Court of Appeals, which reasoned that the precedent set in People v Hall, which upheld mandatory LWOP for felony murder, remained binding. Taylor’s conviction and sentence were similarly affirmed by the Michigan Court of Appeals, which also relied on Hall and other binding decisions. Both defendants sought leave to appeal to the Michigan Supreme Court.The Michigan Supreme Court extended its decision in People v Parks, which held that mandatory LWOP for 18-year-olds was unconstitutional, to include individuals who were 19 or 20 years old at the time of their crime. The Court held that mandatory LWOP for 19- and 20-year-olds violates the principle of proportionality and constitutes cruel punishment under the Michigan Constitution. The Court ruled that Czarnecki and Taylor are entitled to individualized sentencing procedures before LWOP can be imposed. The Court reversed the Court of Appeals’ decisions, vacated the defendants’ sentences, and remanded the cases for resentencing in accordance with the new ruling. This decision applies retroactively to cases on collateral review. View "People v. Czarnecki" on Justia Law

Several college volleyball players accused their coach of physical, verbal, psychological, and sexual abuse. The players alleged that the coach engaged in a pattern of sexual harassment and abuse, including inappropriate touching and forcing players to engage in uncomfortable physical interactions. They also claimed that the coach's misconduct was reported to various university administrators and assistant coaches, who either witnessed or were informed of the abuse.The United States District Court for the Southern District of Alabama dismissed the players' Title IX and § 1983 claims with prejudice for failure to state a claim. The court found that the players had abandoned their breach-of-contract claims and dismissed those with prejudice. The court also declined to exercise supplemental jurisdiction over the remaining state-law claims, dismissing them without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The court held that the players failed to state a Title IX claim because only certain university administrators were "appropriate persons" to receive notice of the misconduct, and the players did not provide sufficient actual notice of sexual harassment to those individuals. The court also found that the university did not act with deliberate indifference upon receiving the notice.Regarding the § 1983 claims, the court held that the players did not show that the university employees' conduct violated clearly established substantive-due-process principles. The court concluded that the employees were entitled to qualified immunity because the players did not provide case law with indistinguishable facts, a broad statement of principle, or conduct so egregious that it clearly violated constitutional rights.The Eleventh Circuit affirmed the district court's order dismissing the players' Title IX and § 1983 claims. View "DeMarcus v. University of South Alabama" on Justia Law

A minor, J.H.-M., was adjudicated guilty of second-degree rape by forcible compulsion. The juvenile court imposed a Special Sex Offender Disposition Alternative, including 30-40 weeks of confinement, suspended for a 24-month supervision period. Conditions of supervision included maintaining employment or school enrollment, compliance with treatment requirements, and registration. Although the sentencing judge verbally declined to impose a condition prohibiting sexually explicit material, the written order included this prohibition.J.H.-M. appealed to the Court of Appeals, arguing that the condition prohibiting sexually explicit material was unconstitutionally vague and overbroad. The State initially moved to concede error based on the judge's verbal statement, but Division One of the Court of Appeals denied the motion and directed briefing on the merits. The Court of Appeals affirmed the condition, concluding it was not unconstitutionally vague or overbroad, distinguishing it from a similar condition in a previous case, State v. Padilla.The Supreme Court of the State of Washington reviewed the case. The court held that the condition prohibiting sexually explicit material was not unconstitutionally vague. The court reasoned that the term "sexually explicit conduct" was sufficiently defined by prior case law and the referenced statute, former RCW 9.68A.011(4), which provided specific examples of prohibited acts. The court concluded that the condition provided adequate notice of proscribed conduct and ascertainable standards to prevent arbitrary enforcement. The Supreme Court affirmed the imposition of the condition and the decision of the Court of Appeals. View "State v. J.H.-M." on Justia Law

The defendant was charged with reckless driving and recklessly endangering another person. Unable to secure counsel, the defendant represented himself at trial, where his arguments were not responsive to the charges, leading to his conviction by a jury. On appeal, the defendant continued to represent himself, filing a pro se brief with arguments similar to those made at trial. The state interpreted the brief as challenging the sufficiency of the evidence, and the Court of Appeals affirmed the convictions in a nonprecedential opinion.After the defendant was appointed appellate counsel in a separate case, the Court of Appeals also appointed counsel for this case. However, the case had already been submitted for decision. The appellate counsel filed an emergency motion to withdraw the case from submission to file a brief, arguing that the defendant had not validly waived his right to counsel and that the trial court erred in not ordering a competency evaluation. The Court of Appeals denied the motion but invited a petition for reconsideration, which was also denied.The Oregon Supreme Court reviewed the case and allowed the petition for review. The court granted the joint motion for remand, vacating the Court of Appeals' decision and the circuit court’s judgment of conviction. The Supreme Court agreed with the parties that the record did not show the defendant had validly waived his right to counsel, as there was no colloquy or indication of a knowing and intelligent waiver. The case was remanded to the circuit court for further proceedings, ensuring the defendant's right to a new trial with proper legal representation. View "State v. Cotter" on Justia Law

The City of Tea passed a resolution imposing a special assessment on properties abutting a road construction project, including property owned by KJD, LLC. The City found that the improvement conferred special benefits on the abutting properties beyond those experienced by the public. KJD objected to the assessment, arguing it was unconstitutional as the project did not confer a special benefit on its property. The circuit court held that KJD did not rebut the presumption that the City’s assessment was valid and did not prove by clear and convincing evidence that the City’s findings were incorrect, thus denying KJD’s objection.KJD appealed to the Supreme Court of South Dakota. The Supreme Court reviewed the case de novo, noting that the City’s findings in its resolution are presumed correct and that KJD had the burden to rebut this presumption with substantial, credible evidence. The Court found that KJD failed to present such evidence, particularly as it did not provide testimony or evidence at a trial to counter the City’s findings. The Court also noted that the City’s method of calculating the assessment based on the cost of the project was constitutionally permissible and that the City’s findings regarding the special benefits, such as improved aesthetics and safety, were supported by the project’s features.The Supreme Court of South Dakota affirmed the circuit court’s decision, holding that KJD did not meet its burden to prove that the special assessment was unconstitutional. The Court concluded that the City’s findings and the special assessment were valid and did not exceed the value of the benefits conferred on KJD’s property. View "KJD, LLC v. City of Tea" on Justia Law

Jonathan and Melissa Brizendine applied to become foster parents in January 2022. After completing their application, a DHS employee conducted a home visit and asked various questions, including about their religious affiliation. The Brizendines, who are non-religious, were also asked to provide additional information on Melissa’s PTSD and medical-marijuana use. On May 19, 2022, DHS denied their foster-parent application. The Brizendines filed a complaint on June 8, 2023, alleging that their application was denied due to their atheism and medical-marijuana use, claiming violations of the Arkansas Constitution, the Religious Freedom Restoration Act, and the Arkansas Medical Marijuana Amendment.The Pulaski County Circuit Court granted the State appellees' motion to dismiss, concluding that the Brizendines' complaint failed to state a claim under Arkansas Rule of Civil Procedure 12(b)(6) and that the State appellees were entitled to sovereign immunity. The court found that the Brizendines did not plead sufficient facts to show that the State’s actions were illegal or unconstitutional.The Supreme Court of Arkansas reviewed the case and affirmed the circuit court's decision. The court held that the Brizendines' complaint was speculative and did not meet the fact-pleading requirements necessary to overcome sovereign immunity. The court noted that the complaint lacked specific facts to support the claim that DHS denied the application based on religious preferences and medical-marijuana use. Additionally, the complaint did not establish any involvement of Governor Sanders or the Child Welfare Agency Review Board in the application process. Therefore, the State appellees were entitled to sovereign immunity, and the dismissal was affirmed. View "Brizendine v. Department of Human Services" on Justia Law

In March 2023, the State charged Christopher Allman with multiple counts of domestic violence, felonious restraint, and terrorizing, alleging he assaulted his wife and their live-in girlfriend, locked them in a room, and refused to let them leave. The parties agreed Allman would undergo a mental health examination to determine his criminal responsibility. The examination was delayed due to issues with obtaining Allman’s records from the Veterans Administration. The evaluation, completed in August 2024, concluded Allman did not suffer from a mental condition precluding criminal liability. A jury trial in August 2024 resulted in guilty verdicts on all counts, and Allman was sentenced to consecutive five-year terms of imprisonment, with credit for time served on one count.The District Court of McKenzie County, Northwest Judicial District, oversaw the initial proceedings. Allman appealed, arguing errors related to the criminal responsibility evaluation, his fitness to stand trial, his right to a speedy trial, and the legality of his sentence. He claimed his constitutional rights were violated by the evaluation order, asserting it was against his will and violated his right against self-incrimination. He also argued the court should have ordered a fitness evaluation and that his right to a speedy trial was denied due to the delays in obtaining his mental health records.The Supreme Court of North Dakota reviewed the case. It held that the district court did not err in ordering the criminal responsibility evaluation because the parties had stipulated to it. The court found no grounds to doubt Allman’s fitness to stand trial and noted he did not request a fitness evaluation. The court also determined that Allman’s right to a speedy trial was not violated, as the delays were not due to the State’s conduct, and Allman did not properly assert his right. Finally, the court affirmed the legality of Allman’s sentence, rejecting his argument about credit for time served. The Supreme Court of North Dakota affirmed the district court’s judgment. View "State v. Allman" on Justia Law