US v. Claybrooks

Court: US Court of Appeals for the Fourth Circuit

Docket: 22-4426

Opinion Date: January 4, 2024

Areas of Law: Constitutional Law, Criminal Law

In this case, the defendant, Jahsir Claybrooks, pleaded guilty to possession of a stolen firearm. The probation office determined that at the time of the offense, Claybrooks was an unlawful user of controlled substances and under indictment for a felony, making him a "prohibited person" not allowed to possess a firearm. As a result, his sentence was calculated based on this status. Claybrooks challenged this designation, arguing that he was not an unlawful drug user and that the statute was unconstitutionally vague. He also asserted that the district court erred in determining he was under indictment at the time of his offense and in imposing a sentence above the recommended guidelines. Finally, Claybrooks argued that the district court should have conducted an analysis of the firearms statutes at issue in accordance with a recent Supreme Court case. The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, concluding that the district court did not commit reversible error. The court found that the district court correctly determined that Claybrooks was an unlawful user of controlled substances at the time of the offense, the relevant statute was not unconstitutionally vague, and the district court did not err in imposing an above-guidelines sentence. The court also dismissed Claybrooks' argument regarding the need for an analysis of the firearms statutes, as he raised this issue for the first time on appeal.

NAACP v. Tindell

Court: US Court of Appeals for the Fifth Circuit

Docket: 23-60647

Opinion Date: January 4, 2024

Areas of Law: Constitutional Law, Government & Administrative Law

The United States Court of Appeals for the Fifth Circuit denied the NAACP and other plaintiffs' emergency motions for an injunction to halt the implementation of Mississippi's House Bill 1020 (H.B. 1020). This law created a new lower court for Jackson’s Capitol Complex Improvement District (CCID), which allegedly has a disproportionate share of Jackson's white residents. The judge and prosecutors for this new court would be appointed by the Chief Justice of the Mississippi Supreme Court and the Mississippi Attorney General, respectively, rather than by locally elected officials, as is typical for other municipal courts in Mississippi. The plaintiffs claimed that this appointment process violated their Fourteenth Amendment rights to equal protection of the law.

However, the court found that plaintiffs lacked standing because they failed to demonstrate a legally protected interest in the accountability of the CCID court to locally elected officials, or that H.B. 1020 would affect their voting rights by diluting the local government's control over the enforcement of its laws within the CCID's borders. The court also rejected the plaintiffs' claim of stigmatic harm, finding that they did not allege discriminatory treatment as required. Finally, the court found no merit in the argument that benefits from the CCID court would primarily go to a disproportionately white population, as the plaintiffs failed to show how H.B. 1020 would erect a barrier making it more difficult for members of one group to obtain benefits than another.

Raper v. Commissioner of Social Security

Court: US Court of Appeals for the Eleventh Circuit

Docket: 22-11103

Opinion Date: January 3, 2024

Areas of Law: Constitutional Law, Government & Administrative Law, Health Law

In this appeal, Marcus Raper contested the Social Security Administration’s (SSA) 2020 denial of his claim for disability insurance benefits. Raper raised three arguments: (1) that the administrative law judge's (ALJ) initial lack of constitutional appointment under the Appointments Clause tainted his later constitutionally appointed review of his case, (2) that the ALJ failed to clearly articulate good cause for not fully crediting his treating physician’s medical opinion, and (3) that the ALJ wrongly discredited his subjective complaints of pain by not properly considering evidence other than objective medical evidence.

The United States Court of Appeals for the Eleventh Circuit affirmed the lower court’s decision. First, the court found no Appointments Clause violation as the ALJ's initial decision, made when he was unconstitutionally appointed, had been vacated on the merits and the case was remanded to the same ALJ who was then constitutionally appointed. Second, the court held that the ALJ articulated good cause for discounting Raper's treating physician’s opinion, finding the opinion inconsistent with the record. Lastly, the court found that the ALJ had properly considered Raper’s subjective complaints in light of the record as a whole and adequately explained his decision not to fully credit Raper’s alleged limitations on his ability to work.

Sitka Tribe of Alaska v. State of Alaska

Court: Alaska Supreme Court

Docket: S-18114

Opinion Date: December 29, 2023

Areas of Law: Constitutional Law, Government & Administrative Law, Native American Law

In this case, the Sitka Tribe of Alaska challenged the State of Alaska's management of a commercial fishery, arguing that it harmed a subsistence fishery. The tribe argued that the state violated the subsistence priority statute and the common use and sustained yield clauses in the Alaska Constitution. The tribe also claimed that the state was misinterpreting a regulation controlling the fishery and sought a preliminary injunction to prevent the state from managing the fishery according to that interpretation during the upcoming season. The superior court denied the preliminary injunction.

The tribe eventually won on its statutory and regulatory claim, but the superior court denied its constitutional claim and its request for attorney’s fees. The tribe appealed to the Supreme Court of Alaska.

The Supreme Court of Alaska affirmed the superior court’s decisions. It held that the hard look doctrine, requiring agencies to consider all relevant information, already existed and there was no need to create a constitutional requirement not in the plain language of Article VIII, Section 4 of the Alaska Constitution. The court also declined to review the tribe’s motion for a preliminary injunction under the public interest exception, as the issue was moot and did not justify application of the public interest exception. Lastly, the court held that the superior court did not abuse its discretion by declining to award attorney’s fees as the tribe had not shown that the superior court's decision was arbitrary, capricious, manifestly unreasonable, or stemmed from an improper motive.

P. v. Alvarez

Court: California Courts of Appeal

Docket: D080585(Fourth Appellate District)

Opinion Date: December 29, 2023

Areas of Law: Constitutional Law, Criminal Law

In this appeal, the court considered the constitutionality of a warrantless blood draw from a person involved in a car accident, where unconsciousness or unresponsiveness occurred in a hospital about 90 minutes after the incident. The defendant, Francisco Andres Alvarez, was involved in a fatal car accident and was transported to the hospital. He appeared unresponsive approximately 90 minutes after the accident. An officer, suspecting Alvarez was under the influence of alcohol, requested a blood draw without obtaining a warrant. The blood test revealed a 0.05 percent blood alcohol level with the presence of cocaine and THC.

Alvarez moved to suppress the blood testing results, arguing that the officer had ample time to obtain a warrant and that no exigent circumstances justified a warrantless blood draw. The trial court initially granted the motion, but later, following a U.S. Supreme Court decision (Mitchell v. Wisconsin), the court reconsidered and denied the motion, ruling that exigent circumstances permitted a blood test without a warrant.

On appeal, the Court of Appeal for the Fourth Appellate District of the State of California reversed the judgment and remanded the case. The court concluded that no exigent circumstances, as defined in Mitchell v. Wisconsin or Schmerber v. California, allowed a warrantless blood draw in this case. The court found that the officer had ample time to obtain a warrant and no emergency medical interventions were required that would have justified the warrantless blood draw. Furthermore, the court found that the officer did not reasonably and in good faith rely on California's implied consent statute, which allows for a blood draw without a warrant if the driver is unconscious or otherwise incapable of refusal. The court remanded the case with instructions to grant Alvarez's motion to suppress the blood test results and allow him to withdraw his guilty plea.

State v. James

Court: Supreme Court of Hawaii

Docket: SCWC-22-0000260

Opinion Date: January 3, 2024

Areas of Law: Constitutional Law, Criminal Law

In a case before the Supreme Court of the State of Hawai'i, the court ruled on the suppression of text message evidence in a sexual assault prosecution. The defendant, Dylan River James, allegedly admitted to the sexual assault during a text conversation with the alleged victim, who was directed by the police to contact him. The lower court suppressed these text messages, agreeing with James' argument that his rights to self-incrimination and counsel were violated. The lower court reasoned that the alleged victim was acting as a government agent, and thus, James should have been given Miranda warnings.

The Supreme Court of the State of Hawai'i vacated the lower courts' decisions. The court ruled that James was not in custody at the time of the text exchange, and thus, Miranda warnings were not required under either the federal or state constitutions. The court also ruled that James' right to counsel had not yet been attached, as adversarial judicial criminal proceedings had not yet been initiated.

The court further held that the Intermediate Court of Appeals (ICA) made an error in concluding that it did not have appellate jurisdiction over the lower court's order denying the State's motion for reconsideration. The Supreme Court stated that the State's right to appeal from an order granting a defendant’s motion to suppress includes a right to appeal from a related order denying the State’s motion for reconsideration. The case has been remanded to the lower court for further proceedings.

Worthington v. Crazy Thunder

Court: Idaho Supreme Court - Civil

Docket: 49976

Opinion Date: January 3, 2024

Areas of Law: Civil Procedure, Constitutional Law, Landlord - Tenant, Real Estate & Property Law

In the case before the Supreme Court of the State of Idaho, the plaintiffs, Dallen and Rachel Worthington, filed an expedited unlawful detainer action against the defendant, Carlene Crazy Thunder, for failure to pay rent. Crazy Thunder requested a jury trial, which was denied by the magistrate court. Following a bench trial, the magistrate court ruled that Crazy Thunder had unlawfully detained the Worthingtons’ property and ordered her to vacate the residence. Crazy Thunder appealed to the district court, arguing she had a right to a jury trial under Idaho’s constitution and Idaho Code section 6313. The district court agreed, concluding that section 6-311A conflicted with section 6-313, and that section 6-311A violated Article I, section 7 of the Idaho Constitution. The Worthingtons then appealed to the Supreme Court of Idaho.

The Supreme Court of Idaho held that Idaho Code section 6-311A does not violate the Idaho Constitution. The court reasoned that an action for unlawful detainer is an equitable claim, and under Article I, section 7 of the Idaho Constitution, the right to trial by jury only exists for legal claims, not equitable ones. However, the court also ruled that Crazy Thunder was entitled to a jury trial on her legal claims. The court held that in wrongful detainer cases like this one, when issues of fact are presented by the pleadings, those issues must be tried by a jury, unless such a jury is waived. As such, the Supreme Court of Idaho affirmed the district court’s decision, though on different grounds. The court further ruled that Crazy Thunder, as the prevailing party on appeal, was entitled to costs, but neither party was entitled to attorney fees.

Iowa Individual Health Benefit Reinsurance Ass’n v. State University of Iowa

Court: Iowa Supreme Court

Docket: 22-1213

Opinion Date: December 29, 2023

Areas of Law: Constitutional Law, Education Law, Health Law

The Supreme Court of Iowa ruled that the State University of Iowa, Iowa State University of Science and Technology, and the University of Northern Iowa were required to be members of the Iowa Individual Health Benefit Reinsurance Association (IIHBRA) and therefore had to pay assessments to the association. The universities had argued that they were not members of IIHBRA and that the statute requiring them to pay assessments violated the Iowa Constitution, which prohibits the state from acting as a surety for another. The court rejected these arguments, finding that the statutory scheme did not violate the constitution and that the universities, as providers of health benefit plans, were indeed members of IIHBRA. The court also ruled that IIHBRA was statutorily authorized to impose late payment fees against its members. However, the court denied IIHBRA's request for attorney fees and costs. The court affirmed in part, reversed in part, and remanded the case for further proceedings.