Constitutional Law - Justia Case Law Summaries

Betts v Boone County

2026-06-15T11:30:55-08:00

In 1977, Louise Betts was kidnapped, raped, and murdered in Boone County, Illinois. The county coroner, Wesley Hyland, conducted an autopsy and returned her body to her family for burial. Decades later, it was revealed that Hyland had secretly kept Louise’s skull, along with the skulls of other deceased individuals, as macabre trophies. In 2022, after Hyland’s death, the coroner’s office notified Louise’s brothers, Gary and Earl, of the skull’s existence, which led the family to exhume her casket to reunite her remains. The Betts brothers filed a lawsuit in the United States District Court for the Northern District of Illinois, Western Division, against Boone County and the current coroner, alleging that the county, through Hyland’s actions, violated their Fourteenth Amendment due process rights by retaining Louise’s skull without notice. They pursued their claim under 42 U.S.C. § 1983, arguing that Hyland’s conduct constituted an official county policy of unconstitutionally retaining property. The district court allowed them to amend their complaint several times but ultimately dismissed the case for failure to state a claim, concluding that Hyland’s actions did not represent official county policy under Monell v. Department of Social Services of City of New York. Upon review, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the county was not liable under Monell because Illinois law expressly requires coroners to return all bodily remains to the next of kin. Hyland’s actions were contrary to, rather than representative of, official county policy. The court concluded that a municipality cannot be held liable under § 1983 when its official acts in direct violation of state law, and thus, no official policy of unconstitutional retention was established by Hyland’s conduct. View "Betts v Boone County" on Justia Law

Pineau v. Attorney General

2026-06-15T04:06:28-08:00

Four Massachusetts voters challenged the Attorney General's certification of an initiative petition proposing significant changes to the Commonwealth’s marijuana laws, seeking to place it on the November 2026 ballot. The proposed measure would repeal statutes governing recreational marijuana and its taxation, but would leave medical marijuana laws largely intact. Under the proposal, adults age twenty-one and older could possess up to one ounce of marijuana without penalty, and possession of up to two ounces would be subject only to a civil fine. The measure would also eliminate programs and regulations related to social equity, host community agreements, and statutory protection for marijuana accessories, among other provisions. After the Attorney General certified the petition as meeting constitutional requirements and prepared a summary for the ballot, the plaintiffs filed a complaint in the Supreme Judicial Court for the county of Suffolk. They argued that the petition violated the Massachusetts Constitution’s requirement that initiative petitions contain only related subjects, and that it was inconsistent with the constitutional right to compensation for property appropriated to public use. They further contended that the Attorney General’s summary was not fair because it omitted key changes the petition would make to existing law. A single justice reserved and reported the case to the full Supreme Judicial Court. The Supreme Judicial Court of Massachusetts reviewed the Attorney General's certification de novo. The court held that the petition satisfied the constitutional relatedness requirement because its provisions were operationally connected to the overall purpose of restricting recreational marijuana. The court also concluded that, on the limited facts properly considered at the certification stage, the petition did not necessarily effect a taking of private property without compensation. Finally, the court found that the Attorney General’s summary was fair, as it accurately conveyed the main outlines of the measure. The case was remanded for entry of judgment declaring compliance with constitutional requirements. View "Pineau v. Attorney General" on Justia Law

Jackson v. Jones

2026-06-12T11:31:33-08:00

A candidate for the Republican nomination for Governor of Georgia, who was not the incumbent, challenged a unique provision of Georgia’s campaign finance law. This law allows only the incumbent Governor and Lieutenant Governor to establish and control so-called “leadership committees” with the ability to receive unlimited contributions and coordinate spending directly with their campaigns, advantages not available to challengers or other candidates. The challenger entered the 2026 gubernatorial primary and quickly discovered that his opponent, the sitting Lieutenant Governor, had amassed substantial campaign resources through such a leadership committee, while the challenger remained subject to standard contribution limits. After filing suit in the United States District Court for the Northern District of Georgia, the challenger sought a preliminary injunction to stop the Lieutenant Governor’s leadership committee from raising or spending further funds in support of his campaign. The district court initially issued a temporary restraining order, then, after further proceedings, granted a preliminary injunction, holding that the challenger was likely to succeed on his claim that the law violated the First Amendment’s guarantee of free speech and that the leadership committee’s actions could be fairly attributed to state action. The district court determined that the law’s favoritism toward select officials could not be justified and that the harm to the challenger was irreparable. However, the injunction was stayed pending appeal. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s grant of a preliminary injunction. The court held that the selective fundraising advantage granted to certain incumbents by the leadership committee statute was unconstitutional under the First Amendment, as it imposed different contribution limits on candidates for the same office without sufficient justification. The court also found that the leadership committee’s conduct constituted state action, making it subject to suit under 42 U.S.C. § 1983. The preliminary injunction was affirmed. View "Jackson v. Jones" on Justia Law

Ward v. Brotzke

2026-06-12T11:00:38-08:00

A man was observed by Detroit police officers in a convenience store with a partially concealed handgun. Upon being questioned, he admitted he did not have a concealed pistol license. An officer ordered him to keep his hands raised, but he failed to comply and instead pulled out the weapon, pushing the officer and attempting to flee. Two other officers responded; one fired twice but missed, while another fired several shots as the man moved toward the exit, hitting him multiple times. The man survived and subsequently sued the officers for excessive force under both federal and Michigan state law. The United States District Court for the Eastern District of Michigan granted summary judgment for the officers, finding they were protected by qualified immunity. The plaintiff appealed, but only pursued claims against the two officers who fired their weapons, abandoning his claims against the third officer. The district court’s decision was based on its determination that the officers had not violated the plaintiff’s constitutional rights and were entitled to immunity. The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo, considering the facts most favorably to the plaintiff and using video evidence to resolve disputed facts. The court held that the officer who fired and hit the plaintiff seized him, but that the officer who fired and missed did not seize him under the Fourth Amendment. The court further concluded that the force used by the officer who struck the plaintiff was reasonable, given the circumstances and the officer’s perception of an immediate threat. The Sixth Circuit also found that both officers were entitled to state-law immunity for assault and battery claims under Michigan law. The district court’s judgment was affirmed. View "Ward v. Brotzke" on Justia Law

State of Iowa v. Mahana

2026-06-12T06:04:01-08:00

A defendant was convicted under Iowa’s felon-in-possession law for carrying a .22 caliber handgun and ammunition into a police station after being informed he could not lawfully possess firearms due to a 2018 aggravated misdemeanor conviction for carrying weapons. He openly sought arrest to challenge the law’s constitutionality, arguing that his prior offense had been repealed and asserting rights under both the Second Amendment and article I, section 1A of the Iowa Constitution. The defendant’s criminal history also included guilty pleas to carrying weapons (again), domestic abuse assault causing injury, and felony criminal mischief. The Iowa District Court for Cerro Gordo County denied motions to dismiss based on constitutional arguments, finding both facial and as-applied challenges lacked merit. The court considered the defendant’s entire criminal record and determined that Iowa Code sections 724.25(1) and 724.26(1) were constitutional. The defendant was convicted and sentenced to five years in prison, suspended to run concurrently with sentences in other cases. On appeal, the Iowa Supreme Court reviewed the conviction de novo. The Court rejected both facial and as-applied constitutional challenges, holding that Iowa’s felon-in-possession law does not violate the Second Amendment or article I, section 1A. The Court found that disarming individuals with relevant criminal histories is supported by historical analogues and, under the Iowa Constitution’s strict scrutiny standard, is narrowly tailored to further the compelling interest of public safety. The Court noted that the repeal of the predicate offense did not affect the constitutionality of the current conviction. The conviction and sentence were affirmed. View "State of Iowa v. Mahana" on Justia Law

iCare Child Development Center LLC v. Cicero-Brown

2026-06-11T11:31:35-08:00

A childcare provider operating multiple daycare centers in Georgia participated in the state’s childcare voucher program, which is funded primarily by a federal grant and administered by the Georgia Department of Early Care and Learning. The provider agreement requires daycare centers to maintain arrival and departure records for each child and to make these records immediately available during on-site audits. In 2023, the Department conducted simultaneous audits at four of the provider’s locations. Only one location produced the required records during the audits, and the Department determined that the provider failed to comply with the investigation. The Department dismissed all of the provider’s centers from the voucher program, issuing notice that the dismissal was not appealable but allowing a grievance process. The provider attempted to contest the dismissal, but was repeatedly told it had no right to appeal. The provider brought suit in the United States District Court for the Northern District of Georgia against several Department officials, alleging a violation of due process and seeking a preliminary injunction for reinstatement in the program. The district court found that while the provider might suffer irreparable harm, it was unlikely to succeed on the merits of its due process claim because it lacked a property interest in continued participation in the program, and denied the motion for a preliminary injunction. The United States Court of Appeals for the Eleventh Circuit reviewed the denial of the preliminary injunction. Assuming without deciding that the provider had a property interest in continued participation, the court held that the provider was not entitled to a pre-deprivation hearing under the Due Process Clause. Applying the balancing test from Mathews v. Eldridge, the court concluded that additional procedural safeguards would not significantly reduce the risk of erroneous deprivation in this context. The court affirmed the denial of the preliminary injunction. View "iCare Child Development Center LLC v. Cicero-Brown" on Justia Law

McLellan v. Brown

2026-06-11T07:17:41-08:00

Two individuals, each with multiple convictions for driving under the influence (DUI) within seven years in Washington State, challenged a state law that temporarily prohibits people with such convictions from possessing firearms. Their applications for concealed carry permits were denied based on this statute, and they subsequently filed a declaratory judgment action, arguing that the law violated their rights under the Second Amendment. The statute in question allows individuals disarmed under this provision to petition for restoration of firearm rights after five years of law-abiding conduct. The Spokane County Superior Court denied the State’s motion for judgment on the pleadings but granted its request for further factual development, ruling that there were material issues of fact—specifically, whether either petitioner posed a credible threat to public safety. The trial court allowed the as-applied constitutional challenge to proceed, focusing on whether an individualized assessment of dangerousness was required under recent Supreme Court precedent. The Supreme Court of the State of Washington granted direct interlocutory review. It held that, under the Second Amendment, the state may temporarily disarm individuals convicted of multiple DUI offenses without requiring an individualized determination of dangerousness. The court examined the nation’s historical tradition of firearm regulation, finding that longstanding analogs support disarmament of groups with a proven risk of dangerous conduct, such as repeated DUI convictions. The court reasoned that the law at issue is justified by the legislature’s determination that recidivist drunk drivers pose a special danger of firearm misuse, and that such temporary restrictions are consistent with historical tradition. The court reversed the superior court’s decision and remanded with instructions to enter judgment on the pleadings in favor of the State. View "McLellan v. Brown" on Justia Law

State v. Hawley

2026-06-11T07:16:36-08:00

A police officer in Aberdeen, South Dakota, stopped a driver after observing him make a right turn at an intersection. The officer initiated the traffic stop because he believed the driver had violated a statute requiring a turn signal to be activated for at least 100 continuous feet before turning. The stop led to an arrest for driving under the influence, and a subsequent blood test showed a high blood alcohol concentration. The driver moved to suppress the evidence, arguing that the officer lacked legal justification for the stop because the relevant traffic law did not require a turn signal under the circumstances. The magistrate court held a suppression hearing and denied the motion, finding the statute required use of a turn signal for at least 100 feet before any turn. A court trial on stipulated facts followed, resulting in a conviction for DUI. The driver appealed to the Circuit Court for the Fifth Judicial Circuit, which affirmed the magistrate’s decision. The Circuit Court determined the officer had reasonable suspicion to stop the vehicle based on his observation of what he believed to be a traffic violation, and concluded that the statutory language encompassed the circumstances of the stop. Upon review, the Supreme Court of the State of South Dakota reversed. The Supreme Court held that the statutes governing turn signals require a signal only when another vehicle may be affected by the turn, and that the officer’s belief that a signal was always required was an objectively unreasonable mistake of law. Because the officer did not have reasonable suspicion based on a valid interpretation of the law, the stop was unconstitutional. The Supreme Court reversed the lower courts’ rulings and remanded the case for further proceedings. View "State v. Hawley" on Justia Law

HOLLOWAY v. STATE OF ARKANSAS

2026-06-11T07:01:46-08:00

In this case, the defendant was convicted of two counts of capital murder and three counts of terroristic threatening, with firearm enhancements, following the deadly shooting of a woman, Sade Turner, and her unborn child. The prosecution’s evidence included testimony that the defendant, along with his brother, drove to a location in Little Rock and fired multiple shots into a car driven by Turner. After the incident, the brothers returned home, and a burned vehicle matching their Jeep was later found. A key piece of evidence involved a phone conversation overheard by Mykell McFee, who later recounted this conversation to law enforcement during an investigation into a separate murder. During the trial in the Pulaski County Circuit Court, McFee was called as a witness but claimed not to recall the details of his statements made during his interview with police. The prosecution played a recording of McFee’s interview over the defendant’s objection, which was based on the argument that McFee’s lack of memory rendered him unavailable for effective cross-examination, thus violating the defendant’s Sixth Amendment confrontation rights. The Pulaski County Circuit Court overruled the objection, determining that because McFee was present and subject to questioning, there was no confrontation violation. On appeal, the defendant argued to the Supreme Court of Arkansas that the introduction of statements made by another individual, now deceased, within the recorded interview further violated his confrontation rights. The Supreme Court of Arkansas held that this particular argument was not preserved for appellate review because it had not been specifically raised at trial. The court affirmed the conviction, concluding that only the objection presented to the trial court was preserved and that the new confrontation argument could not be considered. View "HOLLOWAY v. STATE OF ARKANSAS" on Justia Law

Boddy v. Grech

2026-06-10T12:30:37-08:00

At a school board meeting in Xenia, Ohio, a member of the public sought to use her allotted time during the public comment period to criticize the school district’s handling of alleged critical race theory instruction, as well as the conduct of the superintendent and board. Although her remarks were calmly delivered, board president Mary Grech interrupted her, threatened to cut her microphone, and eventually did so, recessing the meeting amid disruptions from the audience. The speaker was not permitted to complete her five-minute comment, nor was she allowed additional time after the meeting resumed. The individual who was silenced brought a lawsuit against the school board and its president under 42 U.S.C. § 1983, arguing that her First Amendment rights were violated. She sought a preliminary injunction to prevent enforcement of the board’s public comment policy against her in the future. The United States District Court for the Southern District of Ohio conducted a hearing and denied the request for a preliminary injunction. The court concluded that the plaintiff had not demonstrated a strong likelihood of success on the merits or irreparable harm, and found the facts and motives for the board president’s actions to be equivocal. The United States Court of Appeals for the Sixth Circuit reviewed the matter and reversed the district court’s denial of the preliminary injunction. The appellate court held that the plaintiff’s speech—critical of school officials—was protected by the First Amendment and did not fall into any unprotected category. The court found that the board president engaged in impermissible viewpoint discrimination by curtailing speech because of its critical content, and also ratified a heckler’s veto by silencing the speaker rather than the disruptive audience. The Sixth Circuit concluded that the plaintiff demonstrated a strong likelihood of success on the merits and that irreparable harm to constitutional rights was presumed. The case was remanded with instructions to grant the preliminary injunction. View "Boddy v. Grech" on Justia Law

Jewel Sanitary Napkins, LLC v Busy Beaver Publications, LLC

2026-06-10T11:30:47-08:00

Jewel Sanitary Napkins, a Georgia-based company, sells feminine hygiene products that it claims provide health benefits, including products containing graphene. The company developed a market among the Amish community and advertised its products through Busy Beaver Publications, which circulates regional advertising papers to that community. In August 2022, Busy Beaver published an ad submitted by a reader, Betty Lantz, that questioned the safety of Jewel's products, suggesting that graphene could attract electrical waves or radiation and pose health risks. The ad was published anonymously at Lantz’s request. Jewel asserted that the ad contained false statements and damaged its reputation. After the ad’s publication, Jewel contacted Busy Beaver to request a retraction, but Busy Beaver instead offered free advertising, consistent with its policy of not issuing retractions. Jewel declined and sued in the United States District Court for the Western District of Wisconsin for libel and trade libel. During discovery, Jewel sought the original ad submission. Busy Beaver initially believed the form had been destroyed per company practice, but later obtained it from Lantz and provided it to Jewel. Jewel withdrew a related spoliation motion but then sought sanctions over the delay. The district court denied Jewel’s motions, including a request to reopen summary judgment briefing, and granted summary judgment to Busy Beaver. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. It held that, under Wisconsin law and the First Amendment standard for public figures, Jewel failed to present evidence that Busy Beaver acted with actual malice when publishing the ad. The appellate court also found no abuse of discretion in denying sanctions against Busy Beaver. The court affirmed the district court’s judgment in favor of Busy Beaver. View "Jewel Sanitary Napkins, LLC v Busy Beaver Publications, LLC" on Justia Law

United States v. Evans

2026-06-09T08:31:58-08:00

A 15-year-old girl, E.R., stayed overnight at her friend G.T.’s home, where G.T.'s uncle, Rayford Evans, also lived. The morning after the sleepover, E.R. saw a cell phone through a bathroom transom window while she was bathing, which was quickly withdrawn. She believed Evans had tried to record her and reported this to G.T., who, with E.R., informed G.T.'s father, Ancel Teal. Teal coordinated with E.R.'s parents, one of whom was a sheriff’s deputy. Law enforcement was notified, and Officer Smith from the Doniphan Police Department responded. He confronted Evans at the home, requested Evans’s phones, and ultimately seized one phone after Evans initially objected but then acquiesced. Evans then consented in writing to a search of the phone, which led to the discovery of videos of E.R. nude in the bathroom. In the United States District Court for the Eastern District of Missouri, Evans was charged with attempted sexual exploitation of a minor. He moved to suppress the evidence from the warrantless seizure and search of his cell phone, arguing his consent was involuntary and that neither exigent circumstances nor the inevitable discovery doctrine applied. The district court denied the motion, found Evans guilty after a bench trial, and sentenced him to 252 months’ imprisonment. Evans renewed his suppression motion and sought a new trial, both of which were denied. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that exigent circumstances justified the warrantless seizure of Evans’s phone because there was a reasonable belief Evans could imminently destroy evidence, and probable cause existed. The subsequent written consent to search the phone was voluntary. The court also held that sufficient evidence supported the conviction for attempted sexual exploitation of a minor. The judgment was affirmed. View "United States v. Evans" on Justia Law

Hundley v. Brookhart

2026-06-09T08:31:17-08:00

A group of correctional officers was terminated by the Illinois Department of Corrections after an incident involving a wheelchair-dependent inmate who refused to comply with orders to place his hands through a cuffing port for removal of handcuffs. Instead of following certain established protocols, the lead officer decided not to activate the tactical team or notify a supervisor, but instead assembled additional officers to enter the inmate’s cell. The officers attempted to remove the handcuffs, leading to a physical altercation in which the inmate resisted, was dragged out of his cell, sprayed with pepper spray, and then left tethered in a shower area for two hours. Incident reports filed by the officers failed to accurately describe the use of force, omitting details such as dragging the inmate. Following an internal investigation, administrative hearings, and review by the Illinois Civil Service Commission, the officers were discharged for violating rules that require force to be used only as a last resort and for submitting false reports. The Commission found that the officers had other options available, had sufficient time to consider alternatives, and that the use of force was not justified as a first response. The Commission also concluded that the failure to report the incident accurately was egregious. The officers filed suit in the United States District Court for the Central District of Illinois, contending that the Department’s use-of-force rules were unconstitutionally vague and thus their termination violated their Fourteenth Amendment due process rights. The district court granted summary judgment to the defendants, finding the rules were sufficiently clear. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. It held that the “force as a last resort” rule was not unconstitutionally vague as applied to the officers, providing fair warning of prohibited conduct, and that the truthful reporting requirements were also sufficiently clear. The grant of summary judgment for the defendants was affirmed. View "Hundley v. Brookhart" on Justia Law

New Mexico Trappers Association v. Torrez

2026-06-08T08:01:36-08:00

Several non-profit organizations focused on trappers’ rights challenged a New Mexico statute that broadly prohibits the use of traps, snares, or wildlife poison to capture, injure, or kill animals on public land. The statute includes an exception allowing enrolled members of federally recognized Indian nations, tribes, or pueblos to trap for religious or ceremonial purposes under rules that have not yet been promulgated. The plaintiffs did not contest the general prohibition on trapping, but argued that the exception violates constitutional and statutory rights, specifically invoking the Equal Protection and Establishment Clauses of both the U.S. and New Mexico Constitutions, as well as the New Mexico Civil Rights Act. The United States District Court for the District of New Mexico dismissed the plaintiffs’ federal and state constitutional claims without prejudice, holding that the plaintiffs lacked standing. The court found their economic, recreational, aesthetic, and psychological injuries were not redressable because striking the exception would not lift the general ban on trapping. It also determined that their alleged stigmatic injury was not judicially cognizable and, in any event, their claims were not ripe because the rules implementing the exception had not been issued. The court declined to exercise supplemental jurisdiction over the remaining state statutory claim. The United States Court of Appeals for the Tenth Circuit affirmed. The court held that the plaintiffs failed to establish standing. First, their alleged injuries from not being allowed to trap were not redressable, as invalidating the exception would not affect the underlying prohibition. Second, their claims of psychological and stigmatic injury were not ripe for review, as the exception had not been implemented, and any harm was too abstract and generalized to support standing. The appellate court also found no error in the district court’s decision to decline supplemental jurisdiction over the state law claim. View "New Mexico Trappers Association v. Torrez" on Justia Law

STATE v. CITY OF MCALLEN

2026-06-05T14:22:49-08:00

Several cities challenged recent Texas legislative changes that reduced the fees cities could charge telecommunications companies for using public property alongside city streets. The cities argued that requiring them to charge less than market rates for this use amounted to an unconstitutional gift to the telecom companies, contrary to the Texas Constitution’s Gift Clauses. Seeking a judicial declaration to this effect, the cities sued the State of Texas as the sole defendant, asserting that the statutory rate reductions were unconstitutional. At the trial level, the district court partially granted the cities’ request for a declaratory judgment. The Court of Appeals for the Third District of Texas went further, largely siding with the cities and holding that the statutory reductions violated the Gift Clauses. The State then sought review by the Supreme Court of Texas. The Supreme Court of Texas determined that the lower courts lacked jurisdiction over the case because the cities had sued the wrong defendant. The court explained that in constitutional challenges to state statutes, the proper defendant must be the officer or agency with authority to enforce the challenged law, not the State of Texas in the abstract. The court noted that the cities failed to identify any such officer or agency, and there was no indication that any state official had enforced or threatened to enforce the challenged statutes against the cities. Because a judgment against the “State of Texas” would not redress the cities’ alleged injuries nor bind the telecommunications companies, the dispute lacked the concrete adversarial parties necessary for a justiciable controversy. The Supreme Court of Texas vacated the judgments of the lower courts and dismissed the case for lack of jurisdiction. View "STATE v. CITY OF MCALLEN" on Justia Law

State v. Ellway.

2026-06-05T14:03:37-08:00

The defendant was arrested for suspicion of driving under the influence of alcohol after a breath test revealed a blood alcohol content of 0.113, above the legal limit. He was charged with Operating a Vehicle Under the Influence of an Intoxicant (OVUII) and his bench trial began before a district court judge, who heard testimony from the State’s first witness. Before the trial was completed, that judge was elevated to the circuit court and was no longer able to finish presiding over the trial. After the first judge's departure, a second district court judge was assigned to the case. The second judge reviewed the prior record and continued the trial, denying any objection from defense counsel, who after consulting with the defendant, did not object to the substitution. The second judge heard the remainder of the State’s evidence, conducted a colloquy, and found the defendant guilty. The defendant appealed to the Intermediate Court of Appeals (ICA), arguing that his double jeopardy rights were violated by being tried before a second judge without a proper mistrial or on-the-record consent. The ICA affirmed the conviction, finding no error in the substitution or in the lack of an on-the-record colloquy. The Supreme Court of the State of Hawai‘i reviewed the case and held that the district court plainly erred by continuing the bench trial before a new judge after jeopardy had attached, without declaring a mistrial or obtaining the defendant’s consent to terminate the first trial. The court determined that, after the first judge left, the defendant was effectively subjected to a second prosecution for the same offense, in violation of his constitutional protection against double jeopardy. The Supreme Court vacated the ICA’s judgment and the district court’s conviction, and remanded the case for dismissal of the charge with prejudice. View "State v. Ellway." on Justia Law

Sligo Creek Center v. Health and Human Services

2026-06-05T10:30:43-08:00

After two employees and a former resident at a Medicare-participating nursing home in Maryland were diagnosed with active tuberculosis in 2015, county health officials determined that the facility was at high risk for transmission. The officials directed the facility’s staff to take responsibility for testing and follow-up for residents. The facility carried out skin tests and chest x-rays, identifying several residents with latent tuberculosis, but did not proceed to evaluate or treat those residents for latent TB, nor did it document reasons for not treating them. Over a year later, a state health agency investigated and concluded that the facility failed to ensure proper follow-up and documentation, violating federal infection control regulations. The Department of Health and Human Services (HHS) agreed, found that the noncompliance created “immediate jeopardy,” and imposed a per-day civil monetary penalty. The facility challenged the findings and penalty before an administrative law judge, who rejected its arguments and upheld both the finding of noncompliance and the penalty. The Departmental Appeals Board affirmed the administrative law judge’s decision. On review, the United States Court of Appeals for the Fourth Circuit considered whether the Seventh Amendment entitled the facility to a jury trial in HHS’s administrative proceedings for monetary penalties. The court held that there is no Seventh Amendment right to a jury trial in this context because the enforcement action at issue involves “public rights,” not common law claims. The court reasoned that Congress created novel statutory obligations for Medicare-participating facilities, not merely reclassified common law causes of action, and that these obligations are enforced through an administrative scheme distinct from common law torts or contract actions. The court also found that HHS’s actions were neither arbitrary nor capricious and that its decision was supported by substantial evidence. The petition for review was denied. View "Sligo Creek Center v. Health and Human Services" on Justia Law

US v. Goode

2026-06-05T10:30:42-08:00

The defendant pleaded guilty in the United States District Court for the Eastern District of North Carolina to charges including conspiracy to distribute controlled substances and unlawful possession of a firearm by a felon. As part of his plea agreement, he waived his right to appeal his conviction or sentence except for claims of ineffective assistance of counsel or prosecutorial misconduct. At sentencing, the district court found that three prior North Carolina convictions—including second-degree murder—qualified as violent felonies under the Armed Career Criminal Act (ACCA), resulting in an enhanced sentence of 360 months’ imprisonment. The defendant withdrew all objections to the presentence report at sentencing and was sentenced accordingly. On appeal to the United States Court of Appeals for the Fourth Circuit, the defendant argued that his North Carolina second-degree murder conviction did not qualify as a violent felony under the ACCA, and also that his firearm conviction was unconstitutional under the Second Amendment. The government moved to dismiss only the Second Amendment challenge based on the appeal waiver, and argued the merits regarding the ACCA issue. The court dismissed the Second Amendment challenge, but deferred ruling on the ACCA claim. The government later attempted to invoke the appeal waiver against the ACCA challenge, but the court found this argument forfeited as the government had already argued the merits without raising the waiver. The United States Court of Appeals for the Fourth Circuit held that the government forfeited its right to enforce the appeal waiver by failing to timely assert it. On the merits, the court held that North Carolina’s second-degree murder statute categorically qualifies as a violent felony under the ACCA, as it requires malice amounting to extreme recklessness akin to knowledge and always involves the use of physical force. The judgment of the district court was affirmed. View "US v. Goode" on Justia Law

Liu v Mullin

2026-06-05T10:00:47-08:00

An American citizen married to a Chinese national with valid H-1B status sought to have his spouse classified as an immediate relative under immigration law, the first step for her to obtain permanent residency. The citizen had a prior conviction for aggravated criminal sexual abuse involving a minor, which triggered application of the Adam Walsh Child Protection and Safety Act. Under this Act, a U.S. citizen with such a conviction can only sponsor an immediate-relative petition if the Secretary of Homeland Security, in “sole and unreviewable discretion,” determines the citizen poses no risk to the beneficiary. The United States Citizenship and Immigration Services (USCIS) denied both of the citizen’s petitions, finding he failed to show he posed no risk to his spouse. The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, raising statutory and constitutional challenges to the USCIS decisions. The district court dismissed all but one statutory claim for lack of jurisdiction, relying on the Act’s jurisdiction-stripping provisions and the “sole and unreviewable discretion” language. The remaining statutory claim was dismissed for failure to state a claim, with the district court finding that the Adam Walsh Act applies to beneficiaries of any age, not just minors. On appeal, the United States Court of Appeals for the Seventh Circuit agreed with the district court. The court held that it lacked jurisdiction to review statutory and constitutional claims attacking the USCIS’s denial and the processes used, as Congress clearly barred judicial review of both the decision and the methods for reaching it. The court further held that the one statutory claim they could review failed because the Act unambiguously applies to beneficiaries of any age. The court affirmed dismissal of all claims, either for lack of jurisdiction or for failure to state a claim. View "Liu v Mullin" on Justia Law

PIZZUTO V. VALLEY

2026-06-05T08:31:39-08:00

In 1985, Gerald Ross Pizzuto, Jr. was convicted by a jury in Idaho state court of murdering Berta and Del Herndon during a robbery, and he was sentenced to death. Over the following decades, Pizzuto challenged his conviction and death sentence through numerous state and federal post-conviction proceedings, but those efforts were unsuccessful. In 2021, Pizzuto sought clemency from the Idaho Commission of Pardons and Parole, which recommended that his death sentences be commuted to life without parole. However, the Governor of Idaho rejected this recommendation in accordance with an Idaho statute requiring gubernatorial approval for commutation in capital cases. Following the Governor’s denial, Pizzuto argued in Idaho state court that the Governor lacked authority under the Idaho Constitution to overrule the Commission’s recommendation. The Idaho Supreme Court upheld the statute granting the Governor final authority in capital commutation cases, concluding that a 1986 amendment to the Idaho Constitution permitted the legislature to establish the procedures for granting clemency. Pizzuto filed a petition for rehearing, asserting that the Idaho Supreme Court’s decision was so arbitrary as to violate his federal due process rights, but the Idaho Supreme Court summarily denied rehearing. Pizzuto then brought a habeas corpus petition in the United States District Court for the District of Idaho, raising the due process claim. The district court denied relief, finding that the claim was not cognizable in federal habeas and would fail on the merits. On appeal, the United States Court of Appeals for the Ninth Circuit affirmed. The court held that Pizzuto’s claim essentially challenged the Idaho Supreme Court’s interpretation of state law, which is not a cognizable federal habeas claim. Even if the claim were cognizable, the court determined that Pizzuto did not demonstrate a due process violation under clearly established federal law, and the Idaho Supreme Court’s decision was not so arbitrary as to support habeas relief. View "PIZZUTO V. VALLEY" on Justia Law

Associated Press v Neal

2026-06-05T08:30:46-08:00

Several media organizations challenged an Indiana policy that restricts attendance at state executions to a limited set of individuals, including prison officials, spiritual advisors, a small number of people invited by the inmate, and immediate family members of the victim. The policy does not allow members of the press or the general public to attend executions unless they are specifically invited by the inmate. While the guidelines permit media representatives to be present outside the execution chamber and to report freely on the event, they cannot witness the execution itself unless included on the inmate’s guest list. After filing suit under 42 U.S.C. § 1983 in the United States District Court for the Southern District of Indiana, the plaintiffs alleged that Indiana’s policy violated their First Amendment rights—specifically, the qualified right of access to certain government proceedings and the Press Clause. They sought declaratory and injunctive relief and soon requested a preliminary injunction to prevent enforcement of the state’s attendance restrictions for upcoming executions. The district court denied their motion, finding that the plaintiffs were unlikely to succeed on the merits. The court concluded that Supreme Court precedent on public access to criminal proceedings did not extend to executions and that Indiana’s rules did not discriminate against the press because they were treated the same as the public. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that executions have not historically been open to the press or the general public, so no qualified First Amendment right of access attaches. The court also determined that Indiana’s policy is generally applicable and does not target the press for unfavorable treatment in violation of the Press Clause. Accordingly, the denial of the preliminary injunction was affirmed. View "Associated Press v Neal" on Justia Law

State v. Allen

2026-06-05T06:34:05-08:00

A man was charged with aggravated kidnapping and rape after holding a woman hostage and abusing her over several months. After his arrest, the State filed charges, and during pretrial proceedings, questions arose regarding his competency to stand trial and his desire to represent himself rather than be represented by counsel. The district court found him competent and, upon his request, allowed him to proceed pro se, appointing standby counsel. He represented himself during several pretrial hearings, including a competency hearing in March 2018 and a motions hearing in May 2018, before ultimately requesting counsel during trial, at which point standby counsel took over. He was found guilty on all counts and sentenced to 331 months in prison. The Kansas District Court conducted the initial proceedings, including the hearings at issue. On appeal, a panel of the Kansas Court of Appeals concluded that the March and May 2018 hearings were critical stages at which the defendant did not have counsel and had not validly waived his right to counsel. The panel determined that these errors were structural and not subject to harmless error analysis, reversing his convictions and remanding for a new trial. The Supreme Court of the State of Kansas reviewed the case. It agreed that the March 2018 competency hearing and the portion of the May 2018 hearing regarding the State’s motion were critical stages and that the defendant had not validly waived his right to counsel at those stages. However, the court held that such errors are not categorically structural and may be subject to harmless error analysis, depending on the extent and circumstances of the deprivation. In this instance, the court found the errors harmless beyond a reasonable doubt because they did not affect the trial’s outcome. The court affirmed the district court’s judgment and partially affirmed and partially reversed the Court of Appeals’ decision. View "State v. Allen " on Justia Law

Hudson v. Department of Corrections

2026-06-05T01:21:39-08:00

A woman convicted of attempted murder and sentenced to twenty-five years in the custody of the Mississippi Department of Corrections (MDOC) participated in various educational and rehabilitative programs during her incarceration. Despite her reclassification to minimum security and her involvement in these programs, MDOC did not grant her trusty earned time, which could reduce her sentence. She challenged this denial through MDOC’s Administrative Remedy Program, arguing that the legislature had not excluded those convicted of attempted murder from eligibility for trusty time and that MDOC lacked the authority to expand the list of ineligible offenses. She further asserted that, if such authority were delegated, it would violate the Mississippi Constitution’s separation of powers. After MDOC denied her request, citing internal policy and recent legislative changes, she sought judicial review in the Circuit Court of Rankin County. The circuit court upheld MDOC’s decision, concluding that the department had the statutory discretion to deny trusty earned time to her. She then appealed to the Supreme Court of Mississippi. The Supreme Court of Mississippi reviewed whether MDOC’s policy violated Mississippi Code Section 47-5-138.1 and whether the statute, as applied, was unconstitutional. The court determined that MDOC has authority to define trusty status and that the statutory requirements for trusty time eligibility only apply to inmates whom MDOC has already granted trusty status. Because the appellant was never given trusty status under MDOC’s classification, the statute did not entitle her to trusty time. The court also concluded that denying trusty time did not increase her sentence or violate the separation of powers, as inmates are not entitled to such reductions. Accordingly, the Supreme Court of Mississippi affirmed the decisions of MDOC and the circuit court. View "Hudson v. Department of Corrections" on Justia Law

Walker v. Taylor

2026-06-05T01:20:26-08:00

A dispute arose following the April 22, 2025 Democratic primary runoff election for mayor of the City of Canton, Mississippi. The contest centered on whether residents of recently annexed areas—Kingston Subdivision, Westside Trailer Park, and the Trails of Madison—were appropriately allowed to vote. Although these areas had been annexed and their inclusion in municipal elections was upheld in Peco Foods, Inc. v. City of Canton (In re Enlarging City of Canton), concerns were raised that updates to the Statewide Elections Management System (SEMS) were incomplete, potentially disenfranchising voters. On the day before the election, a petition sought to delay certification and allow regular ballots for residents of the affected areas. The Madison County Circuit Court instead permitted eligible voters from those areas to cast affidavit ballots. After the election, in which Tim Scott Taylor won by forty-three votes, Comelia Walker requested a ballot-box examination and subsequently filed several petitions for judicial review and election contest in the Circuit Court. Walker alleged that failures in SEMS updates, lack of notification, and various ballot irregularities materially affected the election’s integrity. The circuit court, after hearing evidence, found that Walker failed to prove any eligible voters had been denied the right to vote, nor could she demonstrate that irregularities affected the election outcome. The circuit court denied and dismissed Walker's petitions with prejudice. On appeal, the Supreme Court of Mississippi reviewed Walker’s claims of disenfranchisement, equal protection violations, and ballot irregularities. The Court concluded that affidavit voting did not disenfranchise voters, that no evidence supported equal protection violations, and that the alleged irregularities were either minor or unsupported by evidence. The Supreme Court of Mississippi affirmed the circuit court’s judgment, holding that no statutory departures occurred sufficient to destroy the election’s integrity or make the will of the voters impossible to ascertain. View "Walker v. Taylor" on Justia Law

USA V. DEBORBA

2026-06-04T15:01:12-08:00

The defendant entered the United States in 1999 and remained without legal status after his tourist visa expired in 2000. He applied for and received a Washington concealed pistol license in 2019, falsely claiming to be a U.S. citizen. He also submitted Bureau of Alcohol, Tobacco, Firearms, and Explosives forms indicating citizenship to register handguns. A series of domestic violence incidents led to multiple restraining orders against him, each including a prohibition on owning or possessing firearms. Law enforcement seized firearms, ammunition, and a silencer from his residence in 2022. The defendant admitted to being a Brazilian citizen and acknowledged that he was not permitted to possess firearms due to his immigration status and domestic violence convictions. The United States District Court for the Western District of Washington denied the defendant’s motions to dismiss charges on Second Amendment, materiality, and vagueness grounds. The defendant was convicted in a bench trial based on stipulated facts for unlawful possession of firearms and ammunition as a noncitizen and as a person under a domestic violence restraining order, making false statements during firearm purchases, falsely claiming U.S. citizenship, and unlawful possession of a firearm silencer. The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed all convictions. The court held that precedent from United States v. Vazquez-Ramirez controlled challenges to 18 U.S.C. § 922(g)(5)(A), confirming the constitutionality of prohibiting firearm possession by noncitizens unlawfully present. Materiality challenges to false statement convictions failed because the Second Amendment does not protect firearm possession by such individuals. The court found that United States v. Rahimi and United States v. VanDyke foreclosed challenges to convictions based on domestic violence restraining orders. The court held that the National Firearms Act’s silencer regulations do not violate the Second Amendment or the Fifth Amendment’s vagueness doctrine. The panel affirmed the district court’s judgment. View "USA V. DEBORBA" on Justia Law

USA v. Niksich

2026-06-04T12:01:06-08:00

The case involves an individual who, following advice from his accountant, opened and maintained several foreign bank accounts in Switzerland and Panama between 2006 and 2012. He did not timely file the required Reports of Foreign Bank and Financial Accounts (FBARs) disclosing these accounts to the United States government. The accounts were significant in value and were sometimes held under an alias. The individual self-prepared his tax returns during this period, and while he reported domestic investment income, he did not disclose his foreign accounts. In 2014, after learning of the FBAR requirements, he entered an IRS voluntary disclosure program, filed untimely FBARs, and attempted to resolve his liabilities with the IRS through a settlement, which was ultimately not honored by the IRS. The United States initiated a civil suit in the United States District Court for the Northern District of Georgia to collect penalties for the willful failure to file timely FBARs. The individual moved for summary judgment, asserting affirmative defenses of accord and satisfaction and equitable estoppel, based on his attempted settlement with the IRS. The United States also moved for summary judgment, seeking a finding of willfulness as a matter of law. The district court granted summary judgment to the United States, finding the failure to file was willful, rejecting the affirmative defenses, and holding that the Eighth Amendment's Excessive Fines Clause did not apply to FBAR penalties. The United States Court of Appeals for the Eleventh Circuit reviewed the case. It affirmed the district court’s rulings on willfulness and rejection of the affirmative defenses, holding that the failure to file FBARs was willful under an objective standard and that the IRS agents lacked authority to bind the government to a settlement. However, the Eleventh Circuit reversed the district court’s determination regarding the Excessive Fines Clause, holding that FBAR penalties are subject to the Eighth Amendment and remanding for factual development on whether the penalties were unconstitutionally excessive. View "USA v. Niksich" on Justia Law

Shaw v. Foreman

2026-06-04T11:00:32-08:00

While incarcerated at Sussex 1 State Prison in Virginia, the plaintiff was accused of indecent exposure in July 2017. He consistently denied the charge and urged prison officials to review video footage from a RapidEye camera, which he claimed would show he was elsewhere when the incident occurred. The officials did not review the footage, stating it was of poor quality and not helpful, and ultimately found the plaintiff guilty after a delayed hearing. As a result of this conviction, and considering his prior offenses, the plaintiff’s security classification was increased and he was transferred to a higher-security facility. He requested that the video footage be preserved, but the prison officials failed to do so. The plaintiff filed suit, alleging procedural due process and First Amendment retaliation claims. The United States District Court for the Eastern District of Virginia initially dismissed the due process claim and granted summary judgment on the retaliation claim. On appeal, the United States Court of Appeals for the Fourth Circuit reversed, noting the importance of the missing video evidence to the plaintiff’s case and remanded for further proceedings. During discovery on remand, it became clear that the video footage had not been preserved, leading the plaintiff to move for spoliation sanctions. The magistrate judge began considering the sanctions motion, but the district court granted summary judgment to the defendants on all claims before ruling on the sanctions issue. The United States Court of Appeals for the Fourth Circuit held that the district court abused its discretion by granting summary judgment before addressing the plaintiff’s motion for sanctions related to the missing video footage. Because the footage was central to the claims, the appellate court vacated the district court’s decision and remanded with instructions to fully consider the sanctions motion. View "Shaw v. Foreman" on Justia Law

Lutheran Church v. Christian

2026-06-04T09:30:30-08:00

A nonprofit religious corporation, incorporated under Missouri law, sought to restore its governance authority over a university in Texas that was established as an agency of the church. The university, although separately incorporated, was subject to church governance under its charter and bylaws. In 2022, the university’s regents unilaterally amended their governing documents to reject the church’s authority. The church’s internal adjudicatory body declared these amendments void, and the church’s convention directed action to restore church control. The university refused to recognize church-appointed regents as its governing body. Litigation ensued in the United States District Court for the Western District of Texas. The church, through its corporate body, sued the university and its leaders in federal court, asserting diversity jurisdiction. The university counter-sued in Texas state court, naming the church as an unincorporated association. The federal actions were consolidated. The district court, adopting a magistrate judge’s report, held that the church was an unincorporated association and the real party in interest, and that joining the church as a plaintiff destroyed diversity jurisdiction because its members included Texas citizens. The court dismissed the federal suit and remanded the state suit to state court. The United States Court of Appeals for the Fifth Circuit reversed the district court’s dismissal. The appellate court held that the district court’s approach violated the church autonomy doctrine under the First Amendment by imposing secular interpretations on the church’s governance structure and disregarding the church’s own description of its internal polity. The court found that the nonprofit corporation is the appropriate party for civil litigation and that diversity jurisdiction exists. The case was remanded for further proceedings. View "Lutheran Church v. Christian" on Justia Law

Moran v. Meadowlark Academy Inc.

2026-06-04T07:22:17-08:00

A minor child, S.M., through a conservator, alleged abuse at a residential facility operated by Meadowlark Academy, asserting several tort claims against Meadowlark and two individuals. Meadowlark responded by filing counterclaims, including breach of contract, based on an alleged pre-litigation settlement agreement. S.M. (at that time, not yet represented by a conservator) failed to timely answer the counterclaims. There was a substantial delay before a conservator, Mr. Moran, was formally appointed and filed an amended complaint. Meadowlark then sought and obtained entry of default against Moran for failing to answer the counterclaims. Moran eventually answered, but only after default had been entered and a motion for default judgment was pending. The District Court of Laramie County denied Meadowlark’s initial motion to dismiss, finding that S.M. had standing despite procedural irregularities regarding the appointment of a conservator, and that there was no enforceable settlement agreement. After Meadowlark asserted counterclaims, the court entered default when those claims were not answered. Moran filed a late answer and opposed default judgment but did not specifically move to set aside the default under the relevant procedural rules or provide supporting legal authority. The district court granted default judgment to Meadowlark and, by implication, denied Moran’s oral motion to set aside the default. On appeal, the Supreme Court of the State of Wyoming affirmed the district court’s order. The Supreme Court held that Moran failed to establish good cause to set aside the entry of default under Wyoming Rules of Civil Procedure 55(c) and 60(b), as he did not articulate a valid legal justification or provide supporting argument and authority. The court also held that Moran’s due process rights were not violated, as he had notice and an opportunity to be heard through his counsel. The judgment was affirmed. View "Moran v. Meadowlark Academy Inc." on Justia Law

State v. Hogan

2026-06-04T06:50:12-08:00

The case concerned a Black defendant who was convicted of second-degree felony murder. During jury selection, the prosecution used a peremptory challenge to exclude juror 40, who was white and had selected “prefer not to answer” regarding gender on a questionnaire. This juror had expressed strong concerns about racial bias in law enforcement and the criminal justice system. Defense counsel objected to the State’s peremptory strike by citing General Rule 37 (GR 37), but specifically raised only an argument about gender identity discrimination, not race or ethnicity. At trial, the King County Superior Court allowed the State’s challenge, finding that juror 40’s political views and demeanor, not their (presumed) gender identity, were valid grounds for exclusion. On appeal, the Washington Court of Appeals affirmed the conviction, holding that defense counsel’s objection based on gender identity did not preserve a GR 37 claim related to race, and thus the trial court did not err. The Supreme Court of the State of Washington reviewed the case. It clarified that an objection to a peremptory strike under GR 37 can be preserved by simply invoking the rule, but in this instance, defense counsel undermined the objection by focusing solely on gender identity. However, the Supreme Court exercised its discretion to review the race discrimination claim, emphasizing the importance of addressing racial bias even if not properly preserved below. The Supreme Court held that the State failed to comply with GR 37(i) procedures by relying on uncorroborated demeanor-based justifications for its peremptory challenge, which could not be considered. While the State’s use of juror 40’s views on law enforcement as a justification was presumptively invalid under GR 37(h), the totality of circumstances rebutted this presumption. The court concluded that an objective observer could not view race as a factor in the State’s strike and affirmed the lower court’s decision. View "State v. Hogan" on Justia Law

FCC v. AT&T

2026-06-04T06:45:05-08:00

This case involved two major cellular service providers that were investigated by the Federal Communications Commission (FCC) for allegedly mishandling customer location data, potentially violating laws and regulations concerning confidentiality. Following reports of security breaches, the FCC issued notices of apparent liability to the companies and, after reviewing their responses, assessed monetary penalties—about $57 million against one provider and $47 million against the other. The companies paid these penalties but challenged the process, contending that their Seventh Amendment right to a jury trial was violated because the FCC imposed penalties through an administrative process without the involvement of a jury. One of the companies sought review in the United States Court of Appeals for the Fifth Circuit, which ruled in its favor, holding that the FCC’s process violated the Seventh Amendment since the agency found facts, interpreted the law, and assessed penalties without a jury. The other provider’s case was heard by the United States Court of Appeals for the Second Circuit, which upheld the FCC’s process. The Second Circuit reasoned that the FCC’s forfeiture order did not, by itself, compel payment, and any actual collection would require the Department of Justice to file a civil suit, at which point a jury trial would be available. The Supreme Court of the United States reviewed both cases to resolve the conflict. The Court held that the FCC’s procedures did not violate the Seventh Amendment because the forfeiture orders did not create a binding obligation to pay, nor were the FCC’s factual findings conclusive. Instead, a party could insist on a jury trial in a de novo civil enforcement action brought by the government to collect the penalty. The judgment of the Fifth Circuit was reversed and remanded, while the judgment of the Second Circuit was affirmed. View "FCC v. AT&T" on Justia Law

BAPTISTE v. State

2026-06-04T04:42:30-08:00

The defendant was indicted for aggravated sexual assault of a child. During the trial, an associate judge presided over the voir dire proceedings, including ruling on two Batson challenges raised by the defendant and denying his request to supplement the record with exhibits related to those challenges. The elected district judge later addressed the defendant's request to supplement the record, handled the excusal of a problematic juror, and presided over the remainder of the trial, ultimately pronouncing the sentence. The jury convicted the defendant of the lesser-included offense of indecency with a child by sexual contact and assessed a five-year prison sentence. Following the conviction, the defendant appealed to the First Court of Appeals in Houston, arguing that his conviction was void because an associate judge presided over voir dire. The appellate court rejected this contention, affirming both the conviction and sentence. The defendant then petitioned the Texas Court of Criminal Appeals for discretionary review, raising a facial constitutional challenge to certain provisions of the Texas Government Code that authorize associate judges to conduct voir dire in felony cases. The Texas Court of Criminal Appeals reviewed whether the defendant had preserved his constitutional challenge for appellate review. The court held that, because the defendant did not object at trial to the associate judge presiding over voir dire or to the relevant statutes, he failed to preserve his complaint. The court also found that the defendant’s claim did not fit within any recognized exceptions for void judgments. As a result, the court affirmed the judgment of the First Court of Appeals, holding that facial constitutional challenges to statutes must be preserved at trial before they can be raised on appeal. View "BAPTISTE v. State" on Justia Law

Allen v. Milligan

2026-06-03T06:45:05-08:00

In this matter, Alabama enacted a congressional district map in 2023 that included only one district in which Black voters constituted a majority. Plaintiffs challenged the map, arguing that it diluted Black voting strength in violation of Section 2 of the Voting Rights Act and the Fourteenth Amendment. The essential factual dispute centered on whether Alabama’s map failed to provide an additional district offering Black voters an opportunity to elect their preferred candidates, and whether the State had intentionally avoided implementing a remedial map previously ordered by the court. The United States District Court for the Northern District of Alabama first enjoined the use of Alabama’s 2023 congressional map, finding it violated Section 2 because it did not include an additional Black-opportunity district and concluding that the State’s actions also violated the Fourteenth Amendment as a deliberate refusal to comply with prior remedial requirements. After the Supreme Court vacated this injunction in light of its decision in Louisiana v. Callais, the District Court issued a new injunction on similar grounds. State officials then applied to the Supreme Court for a stay of the District Court’s order. The Supreme Court of the United States granted Alabama’s application for a stay, holding that the State is likely to succeed on the merits. The Court concluded that the District Court failed to apply the updated standards for Section 2 liability announced in Callais, particularly the requirement that a plaintiff’s alternative map must perform “just as well” with respect to all constitutionally permissible districting criteria, and erred in its evaluation of alleged discriminatory intent. The Supreme Court stayed the District Court’s order pending further proceedings, emphasizing the importance of not altering election rules close to an election. View "Allen v. Milligan" on Justia Law

USA v. Squire

2026-06-02T15:31:46-08:00

Curtis Squire was indicted on a federal charge for possessing a firearm as a convicted felon after police found a handgun in his home during a search related to a shooting investigation. Although the firearm was not linked to the shooting and state charges were dropped, Squire was charged under 18 U.S.C. § 922(g)(1) due to his prior felony convictions, which included drug trafficking, firearm offenses, obstruction of justice, burglary, and unauthorized use of a motor vehicle. The United States District Court for the Eastern District of Louisiana denied Squire’s motion to dismiss the indictment. Squire’s motion argued, among other things, that § 922(g)(1) was unconstitutional as applied to him under the Second Amendment, particularly following New York State Rifle & Pistol Ass’n v. Bruen and United States v. Rahimi. He contended that his right to possess a firearm in his home was protected by historical tradition. After the denial, Squire pleaded guilty without a plea agreement and was sentenced to fifty-two months’ imprisonment and three years of supervised release. He preserved his right to appeal and timely did so. The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and considered whether the Second Amendment protects a convicted drug trafficker from being dispossessed of a firearm in his home. The court held that, in light of historical tradition and its own precedent, Congress may disarm individuals convicted of dangerous offenses like drug trafficking, even within the home. The court clarified that this holding is narrow and does not address whether Congress may disarm individuals in the home based on non-dangerous convictions. The Fifth Circuit affirmed the judgment of conviction and sentence. View "USA v. Squire" on Justia Law

USA v. James

2026-06-02T15:31:46-08:00

In June 2000, a woman identified as M.M. was attacked in her barracks at Fort Hood, where she was stabbed multiple times and sexually assaulted by an unknown assailant. The investigation initially went cold after DNA collected at the scene did not match any suspects. Nearly two decades later, forensic genetic genealogy linked the DNA to Allen James, who had been stationed at Fort Hood and matched the description of the attacker. He was indicted and ultimately convicted by a jury for attempted murder based on DNA evidence and M.M.'s testimony. Proceedings in the United States District Court for the Western District of Texas resulted in James's conviction for attempted murder. At sentencing, the district court used the 2023 Sentencing Guidelines Manual, which prescribed a higher advisory range than the 1998 Manual that was in effect when the offense occurred. James was sentenced to 200 months’ imprisonment and three years of supervised release. He appealed, arguing insufficient evidence of intent to kill, erroneous jury instructions regarding intent, and a violation of the Ex Post Facto Clause due to use of the later Guidelines Manual. The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court held that the evidence was sufficient for a rational jury to find specific intent to kill, and the jury instructions, while imperfect, did not constitute reversible error because any defect was invited by James’s own proposed language and did not result in manifest injustice. However, the court found plain error in the district court’s application of the later Guidelines Manual, in violation of the Ex Post Facto Clause, as this resulted in a higher sentencing range. The Fifth Circuit affirmed James’s conviction, vacated his sentence, and remanded for resentencing under the correct Guidelines Manual. View "USA v. James" on Justia Law

State v. Olson

2026-06-02T14:36:59-08:00

A man was charged with Incest in Montana after his daughter, a minor, alleged that he had sexually abused her over a period of years. The allegations first arose when the daughter disclosed the abuse during a private conversation with her stepfather, who subsequently reported the matter to authorities. Forensic interviews with the daughter revealed detailed descriptions of sexual acts and physical sensations. During the investigation, it was discovered that the daughter’s brother had pornography on his phone, and there were vague suggestions of inappropriate touching between the siblings. The defense argued that these were possible alternative sources for the daughter's sexual knowledge, seeking to rebut the State’s anticipated argument that such knowledge must have come from the defendant’s alleged abuse. The case proceeded to trial in the Fourth Judicial District Court, Missoula County. Before trial, the State moved to exclude evidence of the pornography and alleged sibling touching under Montana’s rape shield statute. The District Court granted the State’s motion, finding the proposed evidence speculative, lacking a clear connection to the daughter’s knowledge, and carrying a risk of undue prejudice. The court stated it would reconsider if the daughter’s trial testimony established a relevant foundation, but no such foundation emerged during testimony. The jury ultimately convicted the defendant, and he was sentenced to 100 years, with 85 years suspended. On appeal, the Supreme Court of the State of Montana reviewed whether the District Court’s exclusion of the evidence violated the defendant’s constitutional rights to present a defense and confront witnesses. The Supreme Court found that the District Court properly balanced the protections of the rape shield statute with the defendant’s constitutional rights, did not act arbitrarily or unreasonably, and that the excluded evidence was speculative and lacked a sufficient connection to the charged conduct. Thus, the conviction was affirmed. View "State v. Olson" on Justia Law

Hiller v. Marin Municipal Water Dist.

2026-06-02T14:02:52-08:00

A public agency adopted an ordinance to increase water service rates after following procedural steps, such as conducting a cost-of-service analysis, notifying the public, and holding hearings as required by Proposition 218 of the California Constitution. After adopting the new rates, the agency initiated a validation action in court to confirm the validity of the ordinance, providing notice to interested parties by publication in a local newspaper, as authorized by statute. No one responded to contest the action within the required time, so the court entered default judgment upholding the ordinance. Subsequently, an individual who had previously submitted administrative claims to the agency challenging the rates filed a class action and mandamus lawsuit seeking refunds and declaratory and injunctive relief, alleging violations of Proposition 218 and constitutional rights. The agency responded with a demurrer, arguing that the plaintiff's claims were barred by the prior validation judgment and the statutory scheme requiring such challenges be brought through validation procedures. The Marin County Superior Court agreed, sustaining the demurrer without leave to amend and finding that the plaintiff's opportunity to challenge the rates had been foreclosed by the unchallenged validation judgment. The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that under Government Code section 53759 and the related validation statutes, any legal challenge to ordinances adopting water service fees must be brought through specified validation proceedings, including constitutional claims. Since the plaintiff neither intervened in the agency's validation action nor filed a timely reverse validation action, her claims were barred. The court also found that due process was satisfied by the published notice required by statute, and that mandamus proceedings are not exempt from these requirements. The appellate court affirmed the judgment in favor of the agency. View "Hiller v. Marin Municipal Water Dist." on Justia Law

People v. Lawrence

2026-06-02T07:32:43-08:00

The defendant, who was a minor at the time he was arrested, was charged in district court by direct filing with several serious offenses, including first degree murder and attempted first degree murder. He was initially detained at a Division of Youth Services (DYS) facility. After turning eighteen, he was transferred to the county jail by law enforcement. The day after his transfer, the defendant objected, asserting that the transfer was unlawful and unconstitutional, and argued that the district court had discretion to keep him in DYS custody. He also claimed that his transfer to county jail violated his right to equal protection because another defendant in a different case had been allowed to remain in DYS custody after turning eighteen. The La Plata County District Court reviewed the People’s motion to transfer the defendant to county jail. After a hearing, the district court concluded that section 19-2.5-305(4)(g) of the Children’s Code required the defendant’s transfer to county jail upon turning eighteen and provided no discretion to rule otherwise. The court expressed discomfort with the result but determined it was bound by the statute. The defendant then sought relief in the Supreme Court of Colorado through an original proceeding. The Supreme Court of Colorado held that section 19-2.5-305(4)(g) plainly and unambiguously requires a person who turns eighteen while detained on charges filed directly in district court to be transferred to county jail, leaving no discretion for the district court to order continued DYS custody. The court further held that the defendant’s equal protection rights were not violated because he was not similarly situated to the other defendant who remained in DYS custody. Consequently, the Supreme Court discharged its order to show cause and remanded the case for further proceedings. View "People v. Lawrence" on Justia Law

People ex rel. T.J.W.

2026-06-02T07:07:58-08:00

An assistant principal at a Colorado high school received an anonymous tip through the Safe2Tell program reporting that a student, identified as “T.J.,” was seen smoking marijuana in a biology class around 12:30 p.m. The tip included a description of the student and his location during the alleged incident. The assistant principal confirmed that the only student known as “T.J.” at the school, T.J.W., was present in the described class at the specified time and matched the physical description provided. After bringing T.J.W. to his office and without observing any signs of drug use, the assistant principal searched T.J.W.’s backpack and found a marijuana vape pen. Subsequently, the People filed a delinquency petition against T.J.W. for possession of marijuana or marijuana concentrate. T.J.W. moved to suppress the evidence, arguing the search was unlawful because it was based solely on an anonymous tip with no corroboration of criminal activity. The District Court for Douglas County held a suppression hearing and granted the motion, finding that the search violated the Fourth Amendment as the tip was insufficiently corroborated to establish reasonable suspicion. The Supreme Court of Colorado reviewed the district court’s suppression order on interlocutory appeal. The court applied the two-part test from New Jersey v. T.L.O., focusing on whether the search was “justified at its inception.” It found that the anonymous Safe2Tell tip was sufficiently corroborated by the assistant principal’s verification of T.J.W.’s identity, location, and physical characteristics, creating reasonable suspicion. The Supreme Court of Colorado held that the search was justified at its inception and reversed the district court’s order suppressing the evidence, remanding for further proceedings. View "People ex rel. T.J.W." on Justia Law

People v. Baker

2026-06-02T05:31:14-08:00

Two police officers stopped a vehicle at night in a high-crime area of Denver because it lacked a front license plate. The officers observed the driver and the passenger, Troy J. Baker, making movements with their elbows above their shoulders, which they interpreted as "furtive" and possibly indicative of concealing contraband. After obtaining the occupants’ names, the officers learned that Baker had recently been arrested for possession of a weapon by a previous offender (POWPO). With backup present, Baker was removed from the vehicle and patted down. Shortly thereafter, police searched the passenger compartment and found a handgun under the seat Baker had occupied. Additional searches discovered drugs and more contraband in the vehicle. The District Court for the City and County of Denver conducted a suppression hearing, during which it found the initial stop justified due to the missing license plate but concluded that the detention and subsequent vehicle search exceeded the stop’s original justification. The district court was not persuaded that the observed movements constituted sufficient grounds for a protective sweep and found no specific, articulable facts supporting a reasonable belief that the occupants were dangerous. As a result, the district court suppressed all evidence obtained from the search. The Supreme Court of Colorado reviewed the case on interlocutory appeal. It held that the officers acted within constitutional limits. The court determined that the combination of the observed movements, Baker’s recent POWPO arrest, and the high-crime setting provided an objectively reasonable basis for a protective sweep of the passenger compartment. The subsequent search of the vehicle was also found lawful under the automobile exception, as probable cause existed to believe the vehicle contained evidence of a crime. The Supreme Court of Colorado reversed the district court’s suppression order and remanded for further proceedings. View "People v. Baker" on Justia Law

SOCKWELL CORNERS, LLC v. NEWTON COUNTY

2026-06-02T04:16:17-08:00

Sockwell Corners, LLC owned a parcel of land zoned as agricultural-residential in Newton County. The company, along with proposed purchasers and developers, sought to have the property rezoned. The Newton County Board of Commissioners denied their rezoning application on July 16, 2024. The applicants then filed a verified complaint in the Superior Court of Newton County, arguing that the county’s zoning ordinance was unconstitutional as applied to their property. After a bench trial, the Superior Court ruled against the applicants, rejecting their as-applied constitutional challenge in an order dated August 7, 2025. The applicants appealed directly to the Supreme Court of Georgia, asserting that appellate jurisdiction was proper due to the constitutional issues raised and on the basis that recent statutory amendments permitted a direct appeal under OCGA § 5-6-34(a)(14), which they claimed allowed direct review of final judgments or orders reviewing zoning decisions. The Supreme Court asked for supplemental briefing on whether the discretionary application procedures of OCGA § 5-6-35 should have been followed instead. The Supreme Court of Georgia held that the recent legislative amendments to the Zoning Procedures Law and the Appellate Practice Act did not abrogate its prior precedent, specifically Diversified Holdings, LLC v. City of Suwanee, 302 Ga. 597 (2017). That precedent requires appeals from superior court decisions reviewing local administrative agency decisions—such as the denial of a rezoning request for a specific property—to proceed by discretionary application. The Court found that the statutory amendments did not modify the relevant language or the nature of the decisions at issue. Because the appellants failed to file a discretionary application as required, the Supreme Court of Georgia dismissed the appeal. View "SOCKWELL CORNERS, LLC v. NEWTON COUNTY" on Justia Law

SHEFFIELD v. THE STATE

2026-06-02T04:16:17-08:00

The case concerns the conviction of a man for the malice murder of his wife, who was found shot and burned in the carport of their home in January 2013. The evidence at trial showed that the defendant was close to the crime scene at the time of the murder, behaved suspiciously upon arrival (not asking about his wife but instead expressing concern over possessions in the house), and had a possible motive linked to an ongoing relationship with another woman. Evidence indicated that the murder weapon was likely a shotgun owned by the couple, and there was no sign of burglary, as valuables were left untouched. The defendant argued that intruders committed the crime, but the prosecution presented circumstantial evidence suggesting his guilt. After an extensive investigation, the defendant was arrested in December 2018 and tried in October 2021. The Superior Court of Coffee County jury found him guilty of malice murder, and he was sentenced to life in prison. Following the conviction, the defendant filed a motion for a new trial, which was denied after hearings. He appealed, arguing that the evidence was insufficient for conviction and that his constitutional right to a speedy trial was violated during the nearly 34-month delay between arrest and trial. The appeal was transferred to the Supreme Court of Georgia. The Supreme Court of Georgia held that the evidence was sufficient to support the conviction when viewed in the light most favorable to the verdict, rejecting the alternative hypothesis of a burglar as unreasonable based on the facts. However, the Court found that the trial court erred in its application of the legal framework for evaluating the speedy trial claim, specifically by not properly calculating the length of the delay and failing to attribute responsibility for pre-pandemic delays. The Supreme Court vacated the trial court’s order denying the motion to dismiss and remanded the case for proper consideration of the speedy trial claim. View "SHEFFIELD v. THE STATE" on Justia Law

State v. Smith

2026-06-01T13:36:18-08:00

Law enforcement confronted a man after receiving reports from his wife that he had used his cellphone to secretly record his 13-year-old stepdaughter while she was undressing in the bathroom, and that a hidden camera had captured him engaging in sexual activity outside his stepdaughters’ bedroom doors. The wife provided police with video evidence, and prior incidents of similar behavior had also been reported. When detectives approached the man at his workplace and asked to see his phone, he handed it to them. Police immediately informed him that they were seizing the device. The next day, investigators obtained a warrant to search the contents of the phone, which revealed incriminating photos and videos. Based on this evidence, the man was indicted on multiple counts related to sexual exploitation and voyeurism of minors. The case proceeded in the District Court of the Fourth Judicial District, Ada County. The defendant moved to suppress the evidence from the cellphone, arguing its seizure violated his Fourth Amendment rights because it was taken without a warrant or a recognized exception. At a suppression hearing, the court heard testimony about the risk that evidence could be quickly deleted and the practicalities of obtaining a warrant. The district court denied the motion, finding the seizure justified by exigent circumstances due to the imminent risk of evidence being destroyed, and concluded the police acted reasonably in timing and duration. The defendant entered a conditional guilty plea, preserving his right to appeal. On appeal, the Supreme Court of the State of Idaho reviewed whether the warrantless seizure met constitutional standards. The court held that the seizure was justified by the exigency of potential destruction of evidence, that probable cause existed, and that the police acted in compliance with the Fourth Amendment. The judgment of the district court was affirmed. The issue of parole conditions was deemed moot because those conditions were removed in an amended judgment. View "State v. Smith" on Justia Law

Abdullah v. State

2026-06-01T13:36:16-08:00

The appellant was convicted of first-degree murder and multiple related offenses following the 2002 death of his wife and a fire set in their home while children were present. Evidence at trial included proof of premeditation, the cause of death as asphyxiation and poisoning, arson, and circumstantial evidence linking the appellant to the crime. The defense argued the death was a suicide, but the jury found the appellant guilty and sentenced him to death, also imposing lengthy consecutive prison sentences for the other crimes. Over the next seventeen years, the appellant pursued a direct appeal and three petitions for post-conviction relief, all unsuccessful in overturning his conviction or sentence. Following the United States Supreme Court’s decision in Shinn v. Ramirez, the appellant filed a third successive post-conviction petition, arguing that changes in federal habeas law justified a new post-conviction proceeding. He advanced claims of ineffective assistance of counsel and sought to introduce new evidence and arguments regarding his innocence, equal protection, and separation of powers. The District Court of the Fourth Judicial District, Ada County, summarily dismissed the petition as untimely under Idaho Code section 19-2719, which imposes a strict 42-day deadline for post-conviction relief in capital cases, except in narrow circumstances not applicable here. On appeal, the Supreme Court of the State of Idaho affirmed the district court’s dismissal. The Court held that there is no actual innocence exception to the 42-day statute of limitations for capital post-conviction relief under Idaho law, declined to overrule its prior precedent, and found no violation of equal protection or separation of powers. The holding clarifies that the statutory deadline is not subject to judicially-created exceptions apart from those provided by the legislature, and it does not violate constitutional guarantees. The judgment of dismissal was affirmed. View "Abdullah v. State" on Justia Law

Committee to Protect and Preserve v. State

2026-06-01T13:36:03-08:00

A group of organizations and individuals challenged the constitutionality of Idaho’s parental choice tax credit, which provides a refundable tax credit for parents, legal guardians, or foster parents who incur certain educational expenses, including private school tuition, for their dependent children. The tax credit is capped annually, prioritizes lower-income applicants, and cannot be claimed for a student enrolled in public school during the relevant semester. Petitioners argued that the credit violated Article IX, section 1 of the Idaho Constitution by creating a publicly funded, nonpublic education system distinct from the public school system, and further violated the public purpose doctrine by primarily benefiting private interests. The case was brought directly to the Idaho Supreme Court through a Verified Petition for Writ of Prohibition, seeking to stop the Idaho State Tax Commission from implementing the tax credit. The petitioners included advocacy groups, a school district, the state education association, a former superintendent, a legislator, an educator, and parents of public school students. The State of Idaho and the Idaho State Legislature (which intervened) opposed the petition, disputing both standing and the claim of unconstitutionality. The Supreme Court of the State of Idaho first held that the petitioners lacked traditional standing but relaxed standing requirements due to the urgent constitutional question and the unlikelihood that another party would bring the challenge. The Court then held that Article IX, section 1 imposes a duty to establish a public school system but does not prohibit the legislature from supporting additional educational initiatives such as the tax credit. The Court also found the tax credit did not violate the public purpose doctrine, as education serves a public purpose even if private actors incidentally benefit. The petition was denied, and the Tax Commission was awarded attorney fees against the school district; costs were awarded to both the Tax Commission and the Legislature. View "Committee to Protect and Preserve v. State" on Justia Law

Doyle v. The Harris Ranch Community Infrastructure District No. 1

2026-06-01T13:36:00-08:00

A group of residents and a taxpayers’ association challenged decisions made by the board of a special taxing district in Boise, Idaho, which resulted in higher property taxes for homeowners. The district, created in 2010 at the request of a developer who owned all land within its boundaries, was formed to finance infrastructure projects such as roadways and stormwater facilities. Over the years, the district board authorized bonds to reimburse the developer for these projects, and in 2021 approved new resolutions for additional payments and a general obligation bond to cover those costs. Residents objected to these actions, arguing that the approved projects did not satisfy statutory requirements and raised various constitutional concerns. Reviewing the case, the District Court of the Fourth Judicial District, Ada County, ruled in favor of the district and the developer. The court found that some residents’ arguments, particularly those challenging the district’s formation and earlier bond authorizations, were barred by the statute of limitations in the Community Infrastructure District Act. It also applied Idaho’s preservation doctrine, declining to consider arguments not raised before the district board. The court rejected residents’ remaining arguments, finding that the challenged projects qualified as community infrastructure under the law, and denied attorney fees. On appeal, the Supreme Court of the State of Idaho independently reviewed the record. It held that the district court erred in applying the preservation doctrine due to the unique procedural circumstances, but found this error harmless because the barred arguments and evidence would not change the outcome. The Supreme Court affirmed that challenges to the district’s formation and earlier bond authorizations were time-barred, and that the challenged projects met statutory requirements. The court also rejected constitutional claims and requests for attorney fees, affirming the district court’s decision and awarding costs to the prevailing parties. View "Doyle v. The Harris Ranch Community Infrastructure District No. 1" on Justia Law

People v. Torres

2026-06-01T09:38:15-08:00

After learning of an outstanding warrant, the defendant voluntarily surrendered to police and was placed in custody. During an interrogation at the police station, the detective advised him of his Miranda rights and asked if he wished to speak. The defendant initially replied, “Nah, I just don’t know why I am doing this,” but immediately continued speaking, seeking information about the reason for his arrest. The detective explained that he could not discuss details unless the defendant waived his rights. After further discussion, the defendant agreed to speak, signed a Miranda waiver, and answered questions, ultimately making several incriminating statements. Months later, the defendant was indicted on multiple charges related to drugs, weapons, and human trafficking. At the Boulder County District Court, the defendant moved to suppress his statements, asserting that he had invoked his right to remain silent, that his subsequent waiver was not voluntary, and that his statements were coerced. The district court agreed, finding that law enforcement failed to honor an unambiguous invocation of the right to remain silent, that the waiver was not voluntary, and that the statements resulted from police coercion. The court granted the motion to suppress, and the prosecution brought an interlocutory appeal. The Supreme Court of Colorado reviewed the district court’s order. Applying the totality of the circumstances standard and independently reviewing the interrogation recording, the court determined that the defendant’s initial response was ambiguous and did not clearly invoke the right to remain silent. The court also concluded that the waiver of rights was voluntary, as there was no evidence of coercion or overbearing police conduct. Additionally, the court found the defendant’s statements to be voluntary and admissible. Accordingly, the Supreme Court of Colorado reversed the district court’s suppression order and remanded the case for further proceedings. View "People v. Torres" on Justia Law

People v. McGee

2026-06-01T09:38:13-08:00

A fourteen-year-old girl reported to police that, the previous year, she had met a man online known as “Ashton,” whose last name began with “Mc,” and who she believed was in his thirties. She described exchanging sexually explicit messages with the man, who continued to communicate with her after learning she was thirteen. The girl provided additional details, including that the man’s birthday was March 29, and that they met in person several times at Rolland Moore Park in Fort Collins, where he arrived on a scooter and engaged in sexual contact with her. Acting under police supervision, the girl’s father communicated with the suspect via Discord and arranged a meeting at the park. When a man in his thirties arrived on a scooter about twenty-four minutes after the scheduled time, police arrested him without questioning or confirming his identity. The Larimer County District Court conducted a suppression hearing on the defendant’s motion to suppress evidence obtained from the warrantless arrest. The court found that the description used to identify the defendant—a male in his thirties on a scooter at the park—was too vague given the park’s size and popularity. The court concluded that the officers lacked probable cause to believe the defendant was the individual who committed the alleged offenses and suppressed all evidence obtained as a result of the arrest, including subsequent statements and items seized pursuant to search warrants. The Supreme Court of Colorado reviewed the case on interlocutory appeal. It held that, under the totality of the circumstances, the officers lacked probable cause to arrest the defendant because the description used was not sufficiently specific to establish a nexus between him and the alleged crimes. The court affirmed the district court’s order suppressing all fruits of the arrest and remanded the case for further proceedings consistent with its opinion. View "People v. McGee" on Justia Law

Talbott v. USA

2026-06-01T09:04:24-08:00

A group of current and prospective military service members challenged a new federal policy that disqualified individuals with a history of gender dysphoria or those perceived as expressing a gender identity different from their sex assigned at birth from serving in the military. This policy, known as the Hegseth Policy, was issued following an executive order by the President in 2025. The policy went further than prior military policies by not only excluding individuals with a recent diagnosis of gender dysphoria or those undergoing transition, but by broadly disqualifying anyone with any history of the condition or who had attempted social transition, regardless of current fitness or stability. The United States District Court for the District of Columbia reviewed the plaintiffs’ motion for a preliminary injunction. After extensive hearings, the District Court found the Hegseth Policy to be motivated by animus against transgender individuals, characterizing it as a blanket ban that was not justified by legitimate military interests. The court applied intermediate scrutiny, concluded that the policy was not substantially related to the stated goals of military readiness or cohesion, and found that it violated the plaintiffs’ right to equal protection under the Fifth Amendment. The District Court issued a preliminary injunction, preventing enforcement of the policy against both current servicemembers and those seeking to enlist. The United States Court of Appeals for the District of Columbia Circuit reviewed the government’s appeal of the preliminary injunction. The Court of Appeals held that the Hegseth Policy, as applied to current servicemembers, was likely unconstitutional because it relied on arbitrary classifications and was motivated at least in part by impermissible animus. The court affirmed the preliminary injunction for current servicemembers but vacated it as to individuals seeking to join the military, reasoning that the equities and public interest differed for prospective enlistees. The case was remanded for further proceedings consistent with the court’s opinion. View "Talbott v. USA" on Justia Law

P. v. Demolle

2026-06-01T09:03:37-08:00

An 11-year-old girl disappeared while visiting her parents in Oakland in July 1999 and was found dead the next day. Investigators discovered she had been raped and strangled. Within weeks, the defendant, a nearby resident, confessed to the crime after matching DNA evidence was found. In his confession, the defendant described luring the victim into his apartment, assaulting and killing her, and disposing of her body. The prosecution further corroborated the confession with testimony from a neighbor and other witnesses, and confirmed the DNA link. The defense did not present evidence at the guilt phase but presented mitigating evidence at the penalty phase, including character witnesses and information about the defendant’s background. The Superior Court of Alameda County conducted the trial. Before trial, the court denied the defendant’s motion to suppress evidence related to the police’s collection of his blood sample and confession, finding the encounter to be consensual and not a detention under the Fourth Amendment. The defendant was convicted of first-degree murder with special circumstances and sentenced to death. His post-trial motions, including those to discharge a juror and for a mistrial based on alleged juror bias, were denied. The Supreme Court of California reviewed the case on automatic appeal. The court held that the defendant was not unlawfully detained before consenting to the blood draw, that evidence obtained was admissible, and that no juror bias or improper admission of evidence rose to the level of reversible error. The court also addressed and rejected challenges to victim impact evidence, admission of unadjudicated criminal acts, and claims of constitutional violations in the penalty phase, including a claim under California’s Racial Justice Act regarding the prosecutor’s language. The judgment, including the death sentence, was affirmed. View "P. v. Demolle" on Justia Law

P. v. Chhuon

2026-06-01T09:03:37-08:00

Two defendants were jointly tried before separate juries for a series of violent crimes committed in Sacramento and Pomona in 1995. These included the robbery and murders of members of the Le family, the attempted murder of Quyen Luu, a burglary, an attempted robbery, and the murder of Miguel Vargas Avina with the attempted murder of Rodolfo Huerta. Both were also implicated in an uncharged murder (Bun) and alleged to have acted for the benefit of a criminal street gang. The prosecution relied on eyewitnesses, accomplice testimony, forensic evidence, and admissions from the defendants. The defense challenged witness identifications, introduced expert testimony on eyewitness reliability, and presented extensive mitigating evidence about the defendants' traumatic backgrounds. The Los Angeles County Superior Court allowed the charges from different counties to be joined under Penal Code section 790(b), leading to a joint capital trial. Both men were convicted of all charges and special circumstance allegations, and each jury returned a verdict of death. The trial court entered death judgments for both, finding true additional special circumstances. The Supreme Court of California reviewed the case automatically. For one defendant, the court affirmed the judgment except for vacating the gang enhancement finding, due to legislative changes that barred the use of the charged offense to establish a pattern of criminal gang activity. For the other defendant, the court reversed the judgment in its entirety. It held that defense counsel's closing argument conceding guilt on the defendant’s behalf, over his express objection, violated the defendant’s constitutional right to decide the objective of his defense, as articulated in McCoy v. Louisiana (2018). This error was deemed structural, requiring automatic reversal of all convictions and enhancements for that defendant. The case was remanded for further proceedings as to both defendants as specified. View "P. v. Chhuon" on Justia Law

Wenzler v Coast Guard

2026-06-01T09:01:43-08:00

James Wenzler, a long-serving member of the Coast Guard Auxiliary, was depicted in uniform on his LinkedIn profile and listed as a Branch Chief for Human Resources. In May 2022, after a public complaint about several of his LinkedIn posts—including accusations against Supreme Court Justices and a disparaging comment about the Girl Scouts—the Auxiliary investigated. Wenzler was directed to remove references to his position and uniform from social media. He refused to comply, responding with accusations of racism against the District Commodore who issued the directive. Despite further warnings, Wenzler continued to display his affiliation and make additional insensitive posts, prompting public concern about his suitability for leadership. After Wenzler persisted in disregarding the Auxiliary’s directives, he was suspended and then disenrolled following a formal disciplinary process. He unsuccessfully pursued administrative appeals and then filed suit in the United States District Court for the Western District of Wisconsin. He claimed that his removal constituted retaliation in violation of his First Amendment right to free speech. The district court granted summary judgment for the Coast Guard, finding that even if Wenzler’s posts addressed matters of public concern, the Coast Guard’s interest in maintaining effective and efficient service outweighed his interest in the speech. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The Seventh Circuit held that the Coast Guard Auxiliary is entitled to deference in assessing and responding to members’ public speech when they represent themselves as members in uniform. The court concluded that the Auxiliary’s interests in discipline, harmony, and maintaining public confidence justified Wenzler’s separation, and thus, his First Amendment rights were not violated under the Connick/Pickering balancing test. View "Wenzler v Coast Guard" on Justia Law

People Of Mi v. Shaver

2026-05-30T05:00:03-08:00

In 2004, the defendant was sentenced as a juvenile for three counts of third-degree criminal sexual conduct and became subject to Michigan’s Sex Offenders Registration Act (SORA), which at the time required reporting address changes within ten days. In 2010, the defendant was convicted for failing to comply with SORA’s registration requirements. After SORA was amended in 2011 to require address changes to be reported within three business days, the defendant’s address was incorrect for 19 days due to an aborted move. In 2015, he pleaded guilty to failure to comply with the 2011 SORA’s requirements and, as a fourth-offense habitual offender, received six months in jail and five years’ probation. After a probation violation, he was resentenced to 40 months to 15 years in prison. After the Michigan Supreme Court decided People v Betts in 2021—holding that the 2011 SORA was unconstitutional ex post facto punishment when applied to offenses committed before 2011—the defendant moved in Tuscola County Circuit Court to vacate his 2015 conviction. The trial court granted relief without allowing the prosecution to respond. The prosecution’s motion for reconsideration was denied. The Michigan Court of Appeals reversed, holding that Betts did not apply retroactively and that the trial court erred by not affording the prosecution an opportunity to respond, and remanded for reinstatement of the conviction. The Michigan Supreme Court reviewed the case and held that its decision in Betts applies retroactively to defendants on collateral review under both federal and state constitutional law. The Court reasoned that Betts announced a new substantive rule by prohibiting a category of punishment for a class of defendants based on their offense date, and such substantive rules are retroactively applicable. The Michigan Supreme Court reversed the Court of Appeals and remanded for further proceedings. View "People Of Mi v. Shaver" on Justia Law

State v. Adkisson

2026-05-29T12:16:20-08:00

A seventeen-year-old defendant was implicated in the fatal shootings of two individuals at an apartment complex in Milan, Tennessee. Law enforcement identified the defendant and a co-defendant as suspects based on anonymous tips and information from onlookers. The defendant was interrogated at the police station without the presence of his mother, despite her being at the station and his repeated requests for her. Over the course of nearly seven hours, he ultimately confessed to participating in the shootings after being told, among other things, that he could face the death penalty and subjected to other coercive tactics. No weapons were recovered, but ballistics indicated two firearms were used. Cell phone records and eyewitness testimony linked the defendant to the scene. The Gibson County Juvenile Court held a transfer hearing and, after considering statutory factors and the evidence presented, found probable cause and transferred the defendant to Circuit Court to be tried as an adult. The court suppressed the defendant’s confession for purposes of the transfer decision. Subsequently, the Circuit Court denied a motion to suppress the confession, finding it voluntary and admissible. At trial, the defendant was convicted by a jury of two counts of second-degree murder. The Tennessee Court of Criminal Appeals affirmed, holding that the transfer was appropriate and the confession voluntary. The Supreme Court of Tennessee reviewed the case. It held that the juvenile court properly transferred the defendant after finding probable cause and satisfying all statutory requirements. The Supreme Court further held that the defendant validly waived his Fifth Amendment right to remain silent. However, the court found that the confession was involuntary, having been obtained through coercion in violation of the Due Process Clause. As a result, the Supreme Court vacated the convictions and remanded the case for further proceedings, excluding the coerced confession from any retrial. View "State v. Adkisson" on Justia Law

Watts v Jones

2026-05-29T12:01:16-08:00

David Watts, an inmate at the Wisconsin Secure Program Facility, sent letters indicating he possessed information relevant to a murder investigation. Two detectives sought to interview him, but Watts declined, fearing that the inmate under investigation would discover his cooperation. Watts alleged that, despite his refusal, the detectives’ attempt to speak with him at his cell and reference to his letter exposed him to risk from other inmates. He claimed to have suffered threats and harassment, but not physical injury. The United States District Court for the Western District of Wisconsin largely granted Watts’s request to conduct the litigation under seal, and many filings were redacted. The district court denied the detectives’ motion for summary judgment based on qualified immunity, concluding that while Watts had not suffered physical harm, he could recover nominal and possibly punitive damages for emotional injury. The court relied in part on prior decisions suggesting that exposing a prisoner as an informant creates a constitutional risk, although no express promise of confidentiality had been made to Watts. The United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court found that Watts had not identified any law clearly establishing a constitutional right to recover damages for exposure to risk of harm that does not result in physical injury. The court distinguished the cited precedents, noting that they involved actual harm. The Seventh Circuit held that, absent a clearly established constitutional right, the detectives were entitled to qualified immunity, and thus to summary judgment. The court reversed the district court’s decision and ordered the case to proceed under the parties’ real names, finding anonymity unjustified. View "Watts v Jones" on Justia Law

Dannah v. City of Grand Rapids

2026-05-29T12:00:39-08:00

During a late-night traffic stop in Grand Rapids, Michigan, officers pulled over a vehicle for a traffic violation. The driver consented to a search of the car. Officers asked passenger Fahirri Dannah to exit the vehicle and attempted to frisk him for weapons. Despite repeated commands to place his hands on his head, Dannah moved his hands toward his waist and disregarded officers’ instructions. As the frisk began, Dannah pulled away and attempted to flee. Officers tackled him, and during a prolonged struggle marked by Dannah’s resistance, they used physical force, including punching and restraining him, until he was handcuffed. Dannah was arrested for assault, battery, and resisting a police officer. Dannah subsequently filed a federal lawsuit under 42 U.S.C. § 1983 against the officers and the City of Grand Rapids, alleging unlawful search, seizure, and excessive force. The United States District Court for the Western District of Michigan granted summary judgment to Officer Kaiser on the search and seizure claims and to the City on the Monell claim, but denied summary judgment to several officers on the excessive force claims, rejecting their qualified immunity defense. The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity. The court held that, even taking the facts in Dannah’s favor, precedent did not clearly establish that the officers’ use of force in response to Dannah’s active, physical resistance during an interrupted frisk was excessive under the Fourth Amendment. The court distinguished prior cases cited by Dannah and concluded that the officers did not violate any clearly established law. Therefore, the court reversed the district court’s denial of qualified immunity to the officers on the excessive force claims. View "Dannah v. City of Grand Rapids" on Justia Law

Courtemanche v. Noble

2026-05-28T13:00:04-08:00

Four residents of Worcester County, Massachusetts alleged that the Massachusetts State Police (MSP) secretly recorded their phone conversations with officers and stored the recordings in an online database. They claimed the MSP used these recordings to propose charges in at least 181 criminal cases but did not disclose the existence of the recordings to prosecuting agencies. The plaintiffs, none of whom alleged pending charges or convictions related to these recordings, sought declaratory and injunctive relief, asserting violations of the Massachusetts Wiretap Act (later voluntarily dismissed) and their federal constitutional rights under the Sixth and Fourteenth Amendments via 42 U.S.C. § 1983. The United States District Court for the District of Massachusetts allowed voluntary dismissal of the state law claim but denied the Superintendent’s motion to dismiss the § 1983 claim. The district court found that sovereign immunity did not bar the official-capacity suit under the Ex parte Young exception, as the plaintiffs sought only prospective relief for alleged ongoing violations of federal law. The court further concluded that the plaintiffs had standing, reasoning that the MSP’s counsel had not unequivocally stated that the challenged recording and withholding practices had ceased or that all recordings had been disclosed. On interlocutory appeal, the United States Court of Appeals for the First Circuit reviewed the standing determination. The First Circuit held that the plaintiffs failed to allege an injury in fact with sufficient concreteness or imminence to establish standing for prospective relief. Their allegations were found to be generalized and lacked any indication that they personally faced a substantial risk of future harm. As a result, the First Circuit reversed the district court’s denial of the Superintendent’s motion to dismiss and remanded for further proceedings. View "Courtemanche v. Noble" on Justia Law

PLANNED PARENTHOOD MAR MONTE, INC. VS. STATE

2026-05-28T11:07:32-08:00

A California nonprofit organization that operates health centers in Nevada, along with a physician, challenged the enforcement of a Nevada law, originally enacted in 1985, that imposed parental notification and judicial bypass requirements on minors seeking abortions. The law had never taken effect due to a long-standing federal injunction, but after Dobbs v. Jackson Women’s Health Organization overruled Roe v. Wade, the federal court vacated the injunction in 2025, allowing the law to become enforceable for the first time. The challengers argued that the law was unconstitutionally vague, exceeded legislative authority, and violated procedural due process rights, particularly focusing on the requirements for parental notification and the process for judicial bypass. When the plaintiffs sought a temporary restraining order and preliminary injunction in the Eighth Judicial District Court, the district court found standing and ripeness only as to certain aspects but held that the plaintiffs had not shown a likelihood of success on the merits or sufficient injury. As a result, the district court denied the motion for a preliminary injunction. On appeal, the Supreme Court of Nevada reviewed de novo the questions of standing, ripeness, and the legal standards for a preliminary injunction. The Supreme Court of Nevada held that the plaintiffs had standing and that the case was ripe for review. The court found that the parental notification and judicial bypass provisions were unconstitutionally vague under the higher standard applicable to statutes involving criminal penalties and constitutional rights, as they failed to provide clear guidance to physicians and allowed for arbitrary enforcement. The court concluded that the plaintiffs demonstrated a reasonable likelihood of success on the merits, irreparable harm, and that the balance of hardships and public interest favored granting relief. Accordingly, the Supreme Court of Nevada reversed the district court’s order and remanded with instructions to grant the preliminary injunction. View "PLANNED PARENTHOOD MAR MONTE, INC. VS. STATE" on Justia Law

Jackson v City of Madison

2026-05-28T11:00:45-08:00

A man visited the home of his estranged wife, became intoxicated, and after an altercation with a neighbor, was the subject of a 911 call reporting possible gunshots. Multiple police officers responded, believing they heard gunshots from the direction of the house. After attempts to contact the man inside the home over several hours failed, and learning that he had a history with weapons, the police treated the situation as a barricaded person incident and called in the full SWAT team. To gain compliance, officers broke windows and the door, then shot the man with non-lethal foam rounds as he refused commands and yelled at officers, eventually arresting him after further use of force. The United States District Court for the Western District of Wisconsin reviewed the man’s claims under 42 U.S.C. § 1983, which included allegations of excessive force, failure to intervene, warrantless arrest, and property damage. The district court granted summary judgment to the defendants. It found that exigent circumstances justified the warrantless arrest, no named defendant was responsible for the property damage, and the officers were entitled to qualified immunity on the excessive force and failure to intervene claims. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that the officers had probable cause for arrest and that exigent circumstances justified the warrantless entry. It determined that the officers were entitled to qualified immunity because the law was not clearly established that their actions during the prolonged standoff violated the Fourth Amendment. The court also found that the failure to intervene and property damage claims were waived due to insufficient argument or standing. The court concluded that, under the facts, the use of non-lethal force did not violate clearly established law, affirming the grant of summary judgment for all defendants. View "Jackson v City of Madison" on Justia Law

Hayes v Board of Education of the City of Chicago

2026-05-28T09:04:20-08:00

Kathleen Hayes worked as an administrator at Northwestern University, responsible for placing student teachers in Chicago Public Schools. During her employment, Hayes made several public social media posts criticizing the school district and its leadership. These posts were seen by at least one Chicago Public School principal, who shared them with Matthew Lyons, the district’s Chief Talent Officer. Lyons then contacted Hayes’s supervisors at Northwestern, expressing concerns about the impact of her comments on the partnership between CPS and Northwestern, but stated he would leave the matter to their discretion and did not recommend termination. Hayes’s direct supervisor soon sought and received permission to terminate her employment, citing the negative effects of her posts on the partnership. Hayes, whose job performance had previously been rated highly, was terminated, and her supervisor later informed Lyons of the action. Hayes filed suit in the United States District Court for the Northern District of Illinois against Lyons and the Board of Education of the City of Chicago. She brought several claims, including First Amendment retaliation, conspiracy, and tortious interference. The district court granted summary judgment to the defendants on all but the First Amendment retaliation claim. It denied summary judgment on that claim, reasoning that Lyons’s communication could constitute an actionable threat and that Lyons was not entitled to qualified immunity because the law was clearly established. The United States Court of Appeals for the Seventh Circuit reviewed only the denial of qualified immunity to Lyons. The court held that even assuming Lyons’s actions violated Hayes’s First Amendment rights, no sufficiently analogous precedent put Lyons on notice that his conduct was unconstitutional. Therefore, Lyons was entitled to qualified immunity and judgment as a matter of law. The Board was dismissed from the appeal, and Hayes’s request for sanctions was denied. The district court’s denial of summary judgment to Lyons was reversed and remanded. View "Hayes v Board of Education of the City of Chicago" on Justia Law

Fernandez v. United States

2026-05-28T06:45:05-08:00

Joe Fernandez was indicted in 2013 for his alleged role as the backup shooter in a double assassination connected to a drug ring. Prosecutors asserted Fernandez was paid to kill two gang members, firing 14 rounds after the primary shooter’s gun malfunctioned. Fernandez’s cousin, Patrick Darge, testified against him at trial. Fernandez’s defense claimed Darge was framing him to protect another relative. The jury convicted Fernandez of murder for hire and a firearms offense, resulting in two consecutive life sentences. After his conviction, Fernandez challenged the verdict in the United States District Court for the Southern District of New York, alleging Brady violations concerning the Government’s failure to disclose statements by another alleged co-conspirator, Luis Rivera. The District Court reviewed the relevant notes and found no exculpatory information but expressed concern about the Government’s lenient treatment of Rivera. The United States Court of Appeals for the Second Circuit affirmed the conviction and sentence, rejecting both the Brady claim and Fernandez’s argument that evidence was insufficient. Fernandez later filed two motions for postconviction relief under 28 U.S.C. §2255; the first was denied as meritless, while the second vacated the firearms conviction based on United States v. Davis, 588 U.S. 445, but left the murder-for-hire conviction intact. Fernandez then sought compassionate release under 18 U.S.C. §3582(c)(1)(A)(i), arguing that doubts about his guilt constituted extraordinary and compelling reasons for a sentence reduction. The District Court granted release based on concerns about the conviction’s validity. The United States Court of Appeals for the Second Circuit reversed, holding that challenges to the validity of a conviction are not cognizable as “extraordinary and compelling reasons” under §3582. The Supreme Court of the United States affirmed, holding that a prisoner who collaterally attacks the validity of his conviction must proceed under 28 U.S.C. §2255, not §3582, and that the alleged invalidity of a conviction is not a valid basis for compassionate release. View "Fernandez v. United States" on Justia Law

In Re: Smith

2026-05-27T12:46:45-08:00

After an altercation between neighbors, police arrested Alisha Shepard Smith and seized a loaded firearm magazine from her person as well as a handgun and another magazine from her home. Smith was charged with several offenses, including firearms violations, but the firearms charges were dismissed at the preliminary hearing due to insufficient evidence, and the remaining charges were later dismissed without prejudice when witnesses failed to appear. Smith then filed motions in the Philadelphia County Court of Common Pleas seeking the return of her seized firearm and magazines under Pennsylvania Rule of Criminal Procedure 588. The trial court denied her motions, finding—based on a police report and witness statements—that Smith had used the firearm in an unlawful manner, making the items derivative contraband. The court did not conduct a forfeiture proceeding, nor did the Commonwealth file for forfeiture; instead, the court ruled solely on the return motions. On appeal, the Superior Court affirmed, holding that because the Commonwealth had proven by a preponderance of the evidence that the property was used in criminal activity, Smith was not entitled to its return, despite the lack of statutory authorization for forfeiture. The Supreme Court of Pennsylvania reviewed the case to determine if Smith was entitled to the return of her property in the absence of statutory authority permitting forfeiture. The Court held that, where the Commonwealth neither asserts an ongoing evidentiary need for seized property nor identifies statutory authority permitting its forfeiture, the denial of a motion for return of property operates as a de facto civil forfeiture. Relying on Commonwealth v. Irland, the Supreme Court ruled that civil forfeiture of derivative contraband requires statutory authorization. Because no such authorization existed in Smith’s case, she was entitled to the return of her property. The decision of the Superior Court was reversed and the case remanded. View "In Re: Smith" on Justia Law

National Association for the Advancement of Colored People Missouri State Conference vs. Kehoe

2026-05-27T12:30:03-08:00

In August 2025, the governor of Missouri issued a proclamation calling for an extraordinary legislative session. The session was convened to address two issues: establishing new congressional districts and changing the initiative petition process. The governor explained that the legislature had adjourned without enacting new district boundaries, which could expose the state to legal challenges, and that changes to the initiative petition process were needed to address concerns about foreign influence and voter confusion. During this extraordinary session, the legislature passed a new congressional map and proposed a constitutional amendment related to initiative petitions. On the day the session was to begin, the NAACP and two individuals filed suit in the Circuit Court of Cole County, seeking a declaration that the governor’s proclamation did not state an “extraordinary occasion” as required by article IV, section 9 of the Missouri Constitution. They also sought to enjoin the session and later the implementation of the enacted measures. The circuit court, after a bench trial, ruled in favor of the state officials, finding that the governor had constitutional authority to call the extraordinary session and that the question was a political one, best decided by the governor. The Supreme Court of Missouri, reviewing the circuit court’s declaratory judgment, affirmed the decision. The court held that article IV, section 9 vests the governor with discretion to determine when an extraordinary occasion has arisen and to call an extraordinary session accordingly. The court rejected the argument that the governor’s discretion is limited by an objective definition of “extraordinary,” finding that neither the constitutional text nor its historical context imposed such a restriction. The judgment of the Circuit Court of Cole County was affirmed. View "National Association for the Advancement of Colored People Missouri State Conference vs. Kehoe" on Justia Law

Lukehart v. State

2026-05-27T12:02:53-08:00

In this case, the appellant was convicted and sentenced to death for the 1996 murder of a five-month-old child in Jacksonville, Florida. The appellant, who was living with the victim’s mother at the time, initially claimed the child had been abducted, prompting an extensive police search. He later confessed to killing the child and disposing of her body in a pond. At trial, the appellant’s explanations about the cause of death were inconsistent with the medical evidence, which showed multiple fatal head injuries. The jury convicted him of first-degree murder and aggravated child abuse, and he was sentenced to death based partly on aggravating factors including a prior conviction for child abuse. After his conviction and sentence were affirmed by the Supreme Court of Florida on direct appeal, the appellant pursued multiple rounds of postconviction relief in both state and federal courts, all of which were unsuccessful. Most recently, following the signing of a death warrant, the appellant filed a third successive postconviction motion in the Circuit Court for the Fourth Judicial Circuit. He argued that Florida’s lethal injection protocol was unconstitutional as applied to him and on its face, that the short period between the warrant and execution deprived him of due process, and that he was wrongly denied additional public records. The circuit court summarily denied all claims. The Supreme Court of Florida reviewed the circuit court’s summary denial de novo and affirmed. The court held that the as-applied and facial Eighth Amendment challenges to Florida’s lethal injection protocol were both untimely and meritless. The court also found no due process violation in the expedited warrant litigation schedule and no abuse of discretion in denying the requests for additional public records. The appellant’s motion for a stay of execution was denied, and the summary denials of postconviction relief and records requests were affirmed. View "Lukehart v. State" on Justia Law

State v. Rohena

2026-05-27T04:02:10-08:00

The case centers on the fatal shooting of a man outside his Hartford residence. An eyewitness, Shamar Coachman-Brown, who was personally familiar with the defendant due to past family connections, was present before, during, and after the shooting. Coachman-Brown initially hesitated to identify the defendant in a police photo array, only later doing so after repeated questioning and pressure from detectives. The defendant was subsequently charged with murder and criminal possession of a firearm. At the Superior Court for the judicial district of Hartford, the defendant moved to suppress Coachman-Brown’s out-of-court identification, arguing that the identification procedure was unnecessarily suggestive and likely to lead to misidentification. The trial court agreed, suppressing the out-of-court identification but later granted the State’s motion to allow Coachman-Brown to identify the defendant in court, finding his identification to have an independent basis. The murder charge was tried to a jury which found the defendant guilty, while the firearm charge was tried to the court, which also found the defendant guilty. The defendant was sentenced to forty-five years and appealed. The Connecticut Supreme Court reviewed whether the admission of the in-court identification violated the defendant’s federal and state due process rights, given the prior suppression of the out-of-court identification. The court held that Coachman-Brown’s in-court identification was based on an independent source, supported by his prior familiarity with the defendant, ample opportunity to observe him during the crime, and his expressed certainty. The court declined to adopt a new rule that would have presumptively barred such identifications, reaffirming the independent source doctrine. The judgment of conviction was affirmed. View "State v. Rohena" on Justia Law

USA v Fillyaw

2026-05-26T13:30:47-08:00

Law enforcement officers arrested an individual in a public parking lot while he was carrying a backpack. The arrest was pursuant to a warrant based on allegations of arson. After detaining him, officers seized the backpack and searched it a few minutes later, discovering a loaded handgun and drugs inside. The individual was subsequently charged with federal offenses. The defendant filed a motion in the United States District Court for the Northern District of Illinois, Eastern Division, seeking to suppress the evidence found in the backpack. He argued that the search violated the Fourth Amendment. The district court denied the motion, holding that the search was permissible under the inventory search exception to the warrant requirement. The defendant then pleaded guilty, reserving his right to appeal the suppression ruling. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the search of the backpack was lawful. The court held that law enforcement may take custody of an arrestee’s personal property when the arrest occurs in a public place, and that an inventory search conducted according to established procedures is lawful. The court found that, although there were minor deviations from departmental policy in the way the search was conducted and documented, these did not render the search unreasonable. The court also rejected the defendant’s argument that officers acted in bad faith, finding no evidence to support this claim. Additionally, the court declined to consider a Fourth Amendment challenge to law enforcement’s use of a license plate reader database because the defendant forfeited the issue by not raising it earlier. Accordingly, the Seventh Circuit affirmed the district court’s denial of the suppression motion. View "USA v Fillyaw" on Justia Law

Margolin v. National Association of Immigration Judges

2026-05-26T12:45:04-08:00

An association representing immigration judges challenged a policy issued by the Executive Office for Immigration Review, which required judges to obtain supervisory approval before making public statements relating to their official duties. The association claimed this policy violated its members’ First and Fifth Amendment rights. The dispute centered on whether such claims must proceed through the administrative review process established by the Civil Service Reform Act of 1978 (CSRA), which channels most work-related federal employee grievances to the Merit Systems Protection Board and the Special Counsel rather than federal district courts. The United States District Court for the Eastern District of Virginia concluded that the CSRA did indeed cover the claims, and therefore dismissed the association’s case for lack of district court jurisdiction. The association appealed, maintaining that its constitutional claims fell outside the scope of the CSRA’s jurisdiction-stripping provisions, but did not dispute that the CSRA generally channels review of covered claims out of district court. On appeal, the United States Court of Appeals for the Fourth Circuit agreed that the association’s claims were covered by the CSRA. Nonetheless, the appellate court vacated the District Court’s judgment and remanded the case for additional factfinding, raising on its own initiative concerns about the current operation of the CSRA’s administrative review scheme—specifically, issues arising from challenges to tenure protections and the lack of a quorum at the Merit Systems Protection Board. The Supreme Court of the United States found that the Fourth Circuit erred by addressing issues not raised or argued by the parties, thus violating the principle of party presentation. The Supreme Court reversed the judgment of the Fourth Circuit and remanded for further proceedings consistent with its opinion. The main holding is that appellate courts may not decide cases on grounds not presented or argued by the parties. View "Margolin v. National Association of Immigration Judges" on Justia Law

People v. Molina

2026-05-26T12:31:45-08:00

The appellant was convicted in 2001 of lewd or lascivious conduct with a child aged 14 or 15, where he was at least 10 years older than the child, under California Penal Code section 288(c)(1). He also sustained a misdemeanor conviction for contributing to the delinquency of a minor. The section 288(c)(1) conviction required him to register as a tier three sex offender, which mandates lifetime registration. In 2022, the trial court reduced his section 288(c)(1) conviction to a misdemeanor, but this did not affect his tier three registration status. Following the reduction, he petitioned the Santa Clara County Superior Court under section 290.5 to terminate his sex offender registration, arguing that the lifetime registration requirement violated his right to equal protection because it treated offenders under section 288(c)(1) more harshly than those under section 288(a), who register as tier two offenders for a minimum of 20 years. The trial court summarily denied his petition, finding him statutorily ineligible for termination as a tier three registrant. The court relied on the Third District Court of Appeal’s decision in Legg v. Department of Justice, which upheld lifetime registration for section 288(c)(1) convictions against an equal protection challenge. The appellant timely appealed the denial. The California Court of Appeal, Sixth Appellate District, reviewed the appeal and determined that rational basis review applied, as sex offender registration does not involve a suspect class or fundamental right. The court held that there is a rational basis for imposing lifetime registration on section 288(c)(1) offenders, due to the minimum age gap and heightened concern about exploitation by significantly older adults. The court concluded that the legislative classification is constitutionally valid and affirmed the trial court’s order denying the petition to terminate sex offender registration. View "People v. Molina" on Justia Law

People v. Cardenas

2026-05-26T11:32:01-08:00

The case involves a defendant who shot and killed a 15-year-old during an attempted theft of his cell phone. The defendant, who was armed due to concerns over personal safety as a delivery driver, agreed to meet the buyer at a community center. When the victim grabbed the phone and fled, the defendant fired multiple shots, ultimately killing the victim. After the incident, the defendant cooperated with the police, turning himself in and providing his account of the events, asserting that he fired because he believed the victim was armed. The Superior Court of Los Angeles County charged the defendant with murder and a firearm enhancement. At trial, the jury acquitted the defendant of murder but convicted him of voluntary manslaughter and found the firearm enhancement true. After conviction, the defendant exercised his right to a jury trial on three aggravating sentencing factors. The trial court denied defense counsel’s request to argue these factors to the jury, instead instructing the jury directly and receiving findings that all three aggravating factors were true. The court imposed the middle term for manslaughter but the upper term for the firearm enhancement based on these findings. The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the case. The court held that a defendant has the right to have counsel argue to the jury regarding aggravating circumstances when those factors are submitted for a jury’s determination under Penal Code section 1170, subdivision (b)(2). The court found that denial of this right was not harmless error under the standard of Chapman v. California, as there was reasonable doubt that the jury would have reached the same findings absent the error. The appellate court reversed the jury’s findings on the aggravating circumstances and vacated the upper-term sentence for the firearm enhancement, affirming the judgment in all other respects and remanding for further proceedings. View "People v. Cardenas" on Justia Law

Town of Fenwick Island v. State

2026-05-26T10:09:48-08:00

Renewable Redevelopment, LLC, a subsidiary of U.S. Wind, owns property in Sussex County, Delaware, and sought a conditional use permit from Sussex County to build an electrical substation supporting a major offshore wind project. The county’s Planning and Zoning Commission recommended approval, but after a public hearing, the Sussex County Council denied the permit. Renewable Redevelopment challenged the denial in the Superior Court. While that case was pending, the Delaware General Assembly enacted Senate Bills 159 and 199, which retroactively mandated approval of qualifying electrical substation permits and prohibited counties from actions that would undermine such applications. The Governor signed the bills the same day. Following this legislative action, Sussex County and the Town of Fenwick Island filed suit in the Court of Chancery, claiming the new statute violated the Delaware Constitution’s separation of powers, Article II, Section 25 (delegation of zoning authority), Article II, Section 16 (one-subject rule), and public due process rights. The Court of Chancery expedited the case, denied a temporary restraining order, and ultimately granted summary judgment for the defendants. The court found that Fenwick Island lacked standing, that separation of powers did not bar the General Assembly’s actions, that the Assembly retained ultimate zoning authority, that the statute’s title and subject matter complied with constitutional requirements, and that due process protections did not apply to the counties in this context. On appeal, the Supreme Court of Delaware reviewed the constitutional challenges de novo, affirmed the judgment, and held that: (1) separation of powers does not operate vertically within a branch and the General Assembly may override delegated zoning decisions; (2) Article II, Section 25 does not restrict the Assembly’s power to reclaim zoning authority; (3) the statute’s title and subject matter satisfied Article II, Section 16; and (4) no due process violation was shown. The Court affirmed the Court of Chancery’s summary judgment for the defendants. View "Town of Fenwick Island v. State" on Justia Law

Kopp v. State

2026-05-26T10:05:36-08:00

Police received a call from a resident in a townhouse community who was personally acquainted with a local police officer, Sergeant Muollo. The caller, who contacted the officer directly on his cell phone rather than through the usual police line, reported that an unfamiliar black sedan with multiple occupants had been parked on her street for an extended period, with cell phones visibly in use inside the car, and expressed her suspicion that the occupants might be engaged in illegal activity, possibly breaking into vehicles. The officer, considering the caller credible due to their longstanding relationship, responded to the location, observed the described car, and, along with backup, blocked the vehicle’s exit. As the officer approached, the car moved slowly forward, which the officer interpreted as an attempt to turn around. He then activated his emergency lights, approached, and detected the odor of marijuana and observed contraband, leading to the arrest of the driver, who was also found in possession of a firearm. In the Circuit Court for Montgomery County, the defendant moved to suppress the evidence, arguing the stop was unsupported by reasonable suspicion. The circuit court denied the motion, finding the officer had reasonable suspicion based on the informant’s tip, the general level of crime in the area, and the movement of the vehicle when police approached. The defendant entered a conditional guilty plea and appealed. The Appellate Court of Maryland affirmed, concluding that, under the totality of the circumstances, the officer had reasonable suspicion, citing the tip from a known resident, the officer’s corroboration of the car’s presence, and testimony that the area experienced significant crime. The Supreme Court of Maryland reversed. The court held that, under the totality of the circumstances, the officer lacked reasonable suspicion to stop the car. The tip provided no basis for suspecting criminal activity beyond the car’s unfamiliarity and presence, and the officer’s corroboration only confirmed innocuous facts. The court further found the testimony about the area being high-crime was insufficiently particularized and not based on information known to the officer at the time of the stop. The judgment was reversed. View "Kopp v. State" on Justia Law

USA v. Girard

2026-05-26T09:00:11-08:00

This case concerns two defendants, Paul Girard and Kareem Harry, who were tried and convicted in the U.S. Virgin Islands for multiple drug, firearm, and racketeering offenses connected to a violent criminal enterprise. Their trial took place in March 2022, shortly after COVID-19 restrictions on in-person court proceedings were partially lifted. On the first day of trial, public access to the courtroom was restricted, and spectators—including the defendants’ mothers—were directed to an overflow room with an audiovisual feed. Although the court later allowed some spectators into the courtroom, federal marshals continued to prevent the defendants’ mothers from entering for several days, even when seats were available. Following their convictions, Girard and Harry moved for a new trial in the District Court of the Virgin Islands, arguing that these restrictions violated their Sixth Amendment right to a public trial. The District Court held a hearing but ultimately found that public access was provided through the overflow room and that any interruptions in the audiovisual feed were brief. The court denied the motions for a new trial, concluding that the public was not excluded from the proceedings. On appeal, the United States Court of Appeals for the Third Circuit reviewed the case for plain error due to the lack of adequate contemporaneous objections during trial. The Third Circuit found that the defendants’ Sixth Amendment rights were violated when the courtroom was closed to all spectators on the first day and when their mothers were excluded on subsequent days without justification. However, the court held that these errors did not seriously affect the fairness, integrity, or public reputation of the proceedings. The court also rejected Harry’s claims regarding his rights to compulsory process and due process. Accordingly, the Third Circuit affirmed the judgments of conviction. View "USA v. Girard" on Justia Law

USA V. JOHNSEN

2026-05-26T08:01:14-08:00

Law enforcement identified an individual using the eMule peer-to-peer file-sharing platform who was sharing files with hash values matching those of known child pornography. The account was traced to the defendant, who had a prior record of offenses involving minors. Despite being unable to directly download the flagged files from the defendant’s account, agents matched the hash values and observed filenames indicative of child pornography. The officers obtained a search warrant, searched the defendant’s residence, and seized numerous electronic devices. Forensic analysis uncovered tens of thousands of images and hundreds of videos containing child pornography. The United States District Court for the District of Arizona reviewed several pretrial motions. The defendant moved to suppress evidence, arguing the search warrant lacked probable cause since agents had not visually confirmed the files’ content and that the review of his publicly shared files violated his Fourth Amendment rights and the Wiretap Act. The defendant also moved to dismiss the indictment, claiming prejudice from forensic analysis conducted without counsel present, and argued selective prosecution due to his status as a registered sex offender. Following hearings, the district court denied all motions. After a jury convicted the defendant on all counts, the court also denied his Rule 29 motion for judgment of acquittal, and sentenced him to concurrent prison terms and supervised release. The United States Court of Appeals for the Ninth Circuit affirmed the conviction. The court held that hash value matches, even without visual confirmation, provided probable cause to support the search warrant, especially when reinforced by descriptive filenames and the defendant’s criminal history. The court found no Fourth Amendment or Wiretap Act violations because the files had been made publicly available. It ruled there was no right to counsel during the non-critical stage of forensic analysis and found no evidence supporting selective prosecution. The court declined to review the sufficiency of the evidence claim due to lack of argumentation. View "USA V. JOHNSEN" on Justia Law

THAKUR V. TRUMP

2026-05-26T08:01:13-08:00

Several researchers at the University of California received multi-year federal grants from agencies including the Environmental Protection Agency, the National Science Foundation, and the National Endowment for the Humanities. In April 2025, these agencies terminated the research grants by issuing form letters, citing shifts in agency priorities and referencing multiple Executive Orders issued by the President, some of which explicitly aimed to eliminate diversity, equity, and inclusion (DEI) and related initiatives from the federal government. The affected researchers alleged these terminations resulted in lost funding, harm to their reputations, and disruption to their projects, with no ready alternative sources of support. The researchers filed a class action lawsuit in the United States District Court for the Northern District of California, asserting constitutional and statutory claims, including violations of the First Amendment and the Administrative Procedure Act (APA). The district court provisionally certified two classes: one consisting of researchers whose grants were terminated by form letter without grant-specific explanation (the Form Termination Class), and another whose grants were terminated specifically due to the DEI Executive Orders (the DEI Termination Class). The district court granted a preliminary injunction, ordering the reinstatement of the grants for both classes. The government appealed. The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiffs had established Article III standing. It reversed the preliminary injunction for the Form Termination Class, concluding that the district court likely lacked jurisdiction over their APA claim because the claim was essentially contractual and thus barred by the Tucker Act. However, the Ninth Circuit affirmed the preliminary injunction for the DEI Termination Class, finding that the class was likely to succeed on its First Amendment claim because the grant terminations were based on viewpoint discrimination. The court remanded for further proceedings. View "THAKUR V. TRUMP" on Justia Law

State v. Rowdy

2026-05-22T07:41:32-08:00

After observing a traffic violation, a sheriff’s deputy attempted to stop a driver who did not immediately pull over, instead proceeding to an apartment complex known for high criminal activity. The deputy observed the driver, who had prior narcotics and weapons convictions, behaving evasively and refusing to answer questions. Both the initial deputy and another responding officer detected the odor of marijuana emanating from the vehicle. During a frisk for weapons, an officer found what was believed to be a marijuana blunt in the driver’s pocket; the driver did not claim it was legal hemp. A subsequent warrantless search of the vehicle uncovered a firearm. The driver was indicted for carrying a concealed weapon and possession of a stolen firearm. In the Superior Court of Forsyth County, the defendant moved to suppress evidence from the searches, arguing that the odor and sight of marijuana could not, in light of the legalization of industrial hemp, provide reasonable suspicion or probable cause. The trial court denied the motion, citing the driver’s failure to stop, the high-crime location, prior convictions, evasive conduct, and the odor of marijuana as sufficient under the totality of the circumstances. The jury found the defendant guilty of carrying a concealed weapon but not guilty of possessing a stolen firearm. The North Carolina Court of Appeals affirmed, holding that the trial court did not err in denying the motion to suppress and that the defendant received a fair trial. On discretionary review, the Supreme Court of North Carolina held that under the totality of the circumstances—including but not limited to the odor of marijuana—officers had reasonable suspicion to frisk the defendant and probable cause to search the car. The odor of marijuana remains a relevant factor despite the existence of legal hemp. The decision of the Court of Appeals was modified and affirmed. View "State v. Rowdy" on Justia Law

State v. Nunnally

2026-05-22T07:41:27-08:00

The defendant was charged with two counts of assault with a deadly weapon and one count of possession of a firearm by a felon after an incident in which he confronted his former girlfriend and her uncle, brandished a firearm, struck his former girlfriend with the weapon, and fired several shots in their direction, though no one was injured. The defendant, his attorney, and the State entered into written stipulations acknowledging the defendant’s prior felony conviction and that he possessed a firearm during the incident. Both stipulations were discussed and consented to by the defendant in open court through separate colloquies with the trial judge. A jury in Superior Court, Durham County, found the defendant guilty of possession of a firearm by a felon and two counts of misdemeanor assault with a deadly weapon. The trial court sentenced him to consecutive terms. On appeal, the defendant argued that his counsel’s closing argument included an implicit admission of guilt to the firearm charge without his knowing consent, which he claimed was per se prejudicial under State v. Harbison and State v. McAllister. The Court of Appeals, in a divided opinion, found the record did not establish whether the defendant knowingly consented to his attorney’s admission of guilt and remanded for an evidentiary hearing on the issue of consent. The Supreme Court of North Carolina reviewed the case and reversed the Court of Appeals. The Supreme Court held that the defendant expressly consented on the record to the stipulations concerning his prior felony and firearm possession, following thorough colloquies. The Court further found that defense counsel’s actions did not exceed the scope of those stipulations nor did counsel explicitly or implicitly concede guilt beyond what the defendant had authorized. Therefore, the per se ineffective assistance of counsel rule from Harbison and McAllister was not triggered. The judgment of the Court of Appeals was reversed. View "State v. Nunnally" on Justia Law

Rarick v. Smidt

2026-05-22T06:04:22-08:00

A patient suffered an injury during knee surgery in March 2022 and, together with his wife, filed a medical malpractice lawsuit against the operating surgeon and the orthopedic clinic in January 2023. Iowa law requires medical malpractice plaintiffs to serve a certificate of merit affidavit within sixty days after the defendant’s answer to the lawsuit. The plaintiffs served a certificate of merit within the deadline. However, the document was not sworn before an authorized officer and did not include the phrase “penalty of perjury” as required by Iowa statutes. Over a year later, the plaintiffs served an amended certificate that met the affidavit requirements, but it was well past the statutory deadline. After the defendants answered and discovery proceeded for more than a year, the defendants moved to dismiss in the Iowa District Court for Polk County, arguing that the timely certificate did not comply with statutory requirements. The district court found that the initial certificate was neither a true affidavit nor a permissible substitute under the relevant statutes. The court also concluded that the late-filed, proper affidavit could not cure the statutory violation because it was not filed within the required sixty days and there was no extension by agreement or motion. The district court dismissed the case. The Iowa Supreme Court reviewed the appeal. It held that substantial compliance with the certificate of merit affidavit requirement means providing either a true affidavit executed before an authorized person or a statement under penalty of perjury within sixty days. The plaintiffs failed to do either within the deadline, and their later submission could not cure the defect. The court also rejected arguments that the defendants had waived the affidavit requirement or that the statutory scheme violated the Iowa Constitution. The decision of the district court was affirmed. View "Rarick v. Smidt" on Justia Law

State v. Baker

2026-05-22T05:39:41-08:00

The case involves a defendant who was alleged to have sexually assaulted a woman near the Red River in Fargo, North Dakota. The prosecution charged him with gross sexual imposition (GSI) by sexual contact, attempted GSI by sexual act, felonious restraint, and preventing arrest. At trial, the victim testified that the defendant forced her to the ground, pulled down her pants, and attempted but failed to penetrate her anus, while also engaging in other sexual contact. The jury was instructed to unanimously agree on the specific acts underlying each charge but was not required to specify which acts supported each conviction. The jury found the defendant guilty on all counts. Following the verdict, the District Court of Cass County sentenced the defendant to concurrent 20-year terms for GSI and attempted GSI, along with additional time for the other convictions. The defendant objected to being sentenced on both GSI and attempted GSI, arguing this constituted double jeopardy because both charges stemmed from the same criminal conduct. The court also declined to award good time credit for pretrial detention, reasoning that the defendant’s conduct while in jail did not merit such credit. On appeal, the Supreme Court of North Dakota reviewed whether the double jeopardy clause was violated and whether the defendant was entitled to good time credit for pretrial detention. The court held that imposing sentences for both GSI and attempted GSI violated the prohibition against double jeopardy, as the convictions could have been based on the same act, and the attempt merged into the completed offense. However, the court held that the defendant was not eligible for good time credit before sentencing. As a result, the Supreme Court of North Dakota vacated the sentence for attempted GSI and affirmed the judgment in all other respects. View "State v. Baker" on Justia Law

Rodriguez-Solis v. Blanche

2026-05-21T11:30:35-08:00

The petitioner, a Honduran national, entered the United States in 2010 and was served with a notice of removal for lacking lawful admission or parole. After her first master calendar hearing, she requested and received a transfer to North Carolina. She subsequently retained counsel, who conceded removability and submitted an asylum application. Over several years, her removal proceedings were administratively closed and later reopened at the government’s request, leading to repeated postponements and delays, mostly due to procedural matters and circumstances beyond her control, such as pregnancy and exposure to COVID-19. Just weeks before a key hearing and associated filing deadline, her longtime attorney withdrew, citing lack of cooperation, and the immigration judge allowed this withdrawal without findings or explanation. Following the attorney’s withdrawal, the petitioner sought additional time to secure new counsel, explaining she had only learned of the withdrawal about a month before the hearing and was unable to find an attorney to prepare her case. Despite her objections and the fact this was her first such request, the immigration judge denied her request for a continuance and proceeded with the merits hearing, during which she represented herself. The judge found her testimony not credible and ordered her removal to Honduras. The Board of Immigration Appeals affirmed the judge’s decision, concluding she had “sufficient time to retain counsel” and did not establish a violation of her statutory or due process rights. The United States Court of Appeals for the Fourth Circuit reviewed the Board’s decision and held that the immigration judge violated the petitioner’s statutory right to counsel under the Immigration and Nationality Act by not granting her a reasonable and realistic opportunity to obtain new representation after her attorney’s withdrawal. The court granted the petition for review, vacated the final order of removal, and remanded to the Board to determine whether this violation prejudiced the petitioner. View "Rodriguez-Solis v. Blanche" on Justia Law

State of Tennessee v. Johnson

2026-05-21T09:21:47-08:00

Three documents related to a criminal case in Davidson County were filed and sealed without a written order by the presiding judge, who subsequently recused herself. After the case was transferred to a new trial court, a news organization sought to intervene and unseal the documents, which included a motion for judicial disqualification and supporting affidavits. The documents were not listed on the public docket, and the clerk’s office explained that they were marked “Filed Under Seal” by the preparer, but no formal order authorized the seal. The Criminal Court for Davidson County allowed the news organization to intervene but denied its motion to unseal the documents. The trial court found that more compelling interests were at stake, including the risk of publishing unsupported claims, potential embarrassment or burden to involved persons, and possible delays or denials of due process. The court ordered that the documents remain sealed and later issued a separate order citing confidentiality under Supreme Court rules. The news organization then sought review in the Tennessee Court of Criminal Appeals, which denied both an extraordinary appeal and a writ of certiorari, concluding that interlocutory appeal was not available to media intervenors in criminal cases. The Supreme Court of Tennessee granted review to address the availability of interlocutory appeals for media intervenors and the standard for sealing judicial records. The court held that such appeals are available to media intervenors when judicial proceedings are closed or records are sealed. The court further ruled that sealing judicial records protected by the First Amendment requires a written order identifying a compelling interest and that the seal must be narrowly tailored. After conducting a de novo review, the court found no compelling interest justifying the seal and ordered the documents to be made public, reversing the Court of Criminal Appeals. View "State of Tennessee v. Johnson" on Justia Law

Bright v. Yenchko

2026-05-21T06:45:24-08:00

An individual was charged with a felony offense in Cook County, Illinois, and as a result, the Illinois State Police suspended his Firearm Owner’s Identification (FOID) card under state and federal law. After the felony charge was dismissed, he successfully appealed to the Illinois State Police for reinstatement of his FOID card. However, before the administrative process concluded, he filed a lawsuit in the circuit court of Randolph County, alleging his constitutional rights were violated by the suspension of his FOID card and seeking its reinstatement, as well as a broad injunction preventing future suspensions based solely on criminal charges. After the plaintiff’s FOID card was reinstated, the defendant argued that the case was moot. Nevertheless, the circuit court denied summary judgment on that ground, invoking the public interest exception to the mootness doctrine. The court then ruled that section 8(n) of the Firearm Owners Identification Card Act was facially unconstitutional to the extent that it authorized suspension or revocation of FOID cards for individuals charged, but not convicted, of felonies. The court issued declaratory and injunctive relief affecting all similarly situated individuals, not just the plaintiff. The Supreme Court of the State of Illinois reviewed the case on direct appeal, vacated the trial court’s judgment, and remanded with directions to dismiss the action. The Supreme Court held that the case was moot because the plaintiff’s FOID card had already been reinstated and no established exception to the mootness doctrine applied. The Court further held that the trial court erred by granting relief beyond the plaintiff’s as-applied claim, improperly expanding the case into a facial constitutional challenge and issuing remedies for nonparties. The Supreme Court expressed no opinion on the underlying constitutional issues. View "Bright v. Yenchko" on Justia Law

Bellin v. McDonald

2026-05-21T06:01:25-08:00

A Medicaid recipient in her late 80s, suffering from serious health conditions, applied in 2019 for 24-hour at-home personal care services through New York’s Medicaid program. The state, which provides varying levels of in-home care to eligible Medicaid recipients, partners with private managed long-term care plans (MLTCPs) to assess needs and offer care plans. The plaintiff was initially offered only eight hours of daily care by all MLTCPs she applied to, though she believed she required around-the-clock assistance. Under New York’s regulations, individuals cannot immediately appeal the initial level of care offered; they must first enroll in the plan, request an increase, and only appeal if that request is denied. The plaintiff followed this process and ultimately received 24-hour care after subsequent assessments, but with a delay and a gap in retroactive reimbursement for services. The United States District Court for the Southern District of New York granted summary judgment to the defendants—the State's Health Commissioner and the MLTCP—holding that the plaintiff did not have a cognizable property interest in a particular level of care, and therefore no due process rights were implicated. The court also denied class certification. The plaintiff appealed these decisions. The United States Court of Appeals for the Second Circuit reviewed the case de novo. The Second Circuit disagreed with the District Court’s conclusion regarding the existence of a property interest. It held that New York’s laws, regulations, and practices substantially restrict discretion in determining eligibility for 24-hour personal care services, thereby creating a property interest for qualifying Medicaid recipients and triggering due process protections. However, the court determined that New York’s current appeals procedures, though delayed, are constitutionally adequate because the delay is modest, expedited procedures exist for urgent cases, and the overall private interests at stake are sufficiently protected. On this alternative ground, the Second Circuit affirmed the District Court’s grant of summary judgment to the defendants. View "Bellin v. McDonald" on Justia Law

State of Minnesota vs. Nelson

2026-05-21T01:22:13-08:00

In this case, the defendant was tried for attempted second-degree murder, first-degree assault, and second-degree assault related to an incident in which the victim was struck multiple times with a metal object, resulting in serious injuries. The first trial ended in a mistrial due to a deadlocked jury. At the second trial, a key witness who had previously testified did not appear, and the State introduced the transcript of this witness’s prior testimony. The defendant’s attorney agreed to the admission of the transcript, and the trial proceeded without the witness’s live testimony. Following conviction and sentencing, the defendant appealed to the Minnesota Court of Appeals. He argued that the district court violated his constitutional right to confront witnesses by admitting the prior testimony without securing a personal, on-the-record waiver of the confrontation right from him, as opposed to a waiver by his attorney. The Minnesota Court of Appeals rejected this argument, holding that any error was not plain because there was no binding authority requiring a defendant’s personal waiver of the confrontation right under these circumstances. The Supreme Court of Minnesota reviewed the case. It held that the district court did not plainly err by admitting the prior testimony without obtaining a personal waiver from the defendant. The court explained that there is no clear or binding legal authority holding that a defendant must personally waive the confrontation right, as opposed to allowing counsel to do so. Because any error by the district court was not “plain” under existing law, the court affirmed the conviction. The Supreme Court of Minnesota thus concluded that, on plain-error review, a district court does not plainly err by accepting counsel’s waiver of the confrontation right for the admission of prior testimony when no binding precedent requires a personal waiver from the defendant. View "State of Minnesota vs. Nelson" on Justia Law

Karacson v. Shaver

2026-05-20T12:30:39-08:00

After a fire destroyed a Michigan home in 2017, investigators determined it was intentionally set, focusing their investigation on the homeowner, Steve Karacson. Evidence included the smell of gasoline, multiple fire origins, cell phone location data placing Karacson near the house just before the fire, and a receipt for gas and gloves purchased hours before the incident. Karacson, who had fire insurance, claimed he was out of state but evidence contradicted this. He was subsequently charged with arson and insurance fraud. Following his plea of not guilty, Karacson sought to replace his court-appointed attorney due to disagreements and grievances. The trial court initially denied his request, but his attorney withdrew, and a second attorney was appointed. This relationship also deteriorated, leading Karacson to request self-representation. On the day of jury selection, after warnings from the court about the risks and complexities of self-representation, Karacson affirmed his desire to proceed pro se, with standby counsel available. After a lunch break, he again requested new counsel, which the court denied due to the timing. Karacson proceeded to represent himself, and a jury convicted him on all counts. He received a seven-year sentence. Karacson appealed to the Michigan Court of Appeals, alleging deprivation of counsel, among other claims. The court rejected his arguments, finding that he had knowingly and voluntarily waived his right to counsel and was not entitled to substitute counsel at trial. The Michigan Supreme Court denied leave to appeal and reconsideration. Karacson then petitioned the United States District Court for the Eastern District of Michigan for habeas relief, claiming a Sixth Amendment violation. The district court denied relief, finding the state court’s determination reasonable, but granted a certificate of appealability. The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of habeas relief. The court held that under AEDPA’s highly deferential standard, the Michigan appellate court reasonably found Karacson’s waiver of counsel was knowing, intelligent, and voluntary. The court also determined that Karacson was not faced with a choice between unprepared counsel and no counsel, and thus was not deprived of a voluntary waiver. View "Karacson v. Shaver" on Justia Law

Roberts v. Thompson

2026-05-20T07:31:02-08:00

Black Hawk County, Iowa, charges jail inmates daily fees and a booking fee. Rather than pursuing the standard civil reimbursement process, which includes judicial review, the County requires inmates to sign confessions of judgment upon release, acknowledging the debt and agreeing to payment terms. Inmates’ money is seized and applied toward the debt, and the confession allows the County to file for judgment without further judicial review. Leticia Roberts and Calvin Sayers, former inmates who signed these confessions under coercive circumstances, allege that the County’s process deprived them of an opportunity to challenge the jail fees and violated their Fourteenth Amendment due process rights. Roberts made payments out of fear of further enforcement, while Sayers made one payment and had money seized by jail officials. The United States District Court for the Northern District of Iowa dismissed Roberts and Sayers’s claims for lack of standing and failure to state a claim. The district court reasoned that their injury was not traceable to the confession of judgment policy because they would owe jail fees regardless, and any payments were voluntary. The court also denied their motion for a preliminary injunction and leave to amend the complaint. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The Eighth Circuit held that Roberts and Sayers had standing to seek damages and injunctive or declaratory relief, as they plausibly alleged injuries traceable to the County’s policy and a real threat of recurring harm. The appellate court found reasonable inferences that the confessions of judgment were coercive and not voluntary, and that the County’s actions deprived Roberts and Sayers of property without constitutionally adequate process. The Eighth Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "Roberts v. Thompson" on Justia Law

Aleksey v. State

2026-05-20T06:13:56-08:00

The case involves Bayan Aleksey, who was convicted and sentenced to death for the murder of a South Carolina state trooper during a traffic stop in 1997. After his conviction and sentence were affirmed on direct appeal, Aleksey filed a post-conviction relief application alleging ineffective assistance of counsel, which was denied. Following the United States Supreme Court’s decision in Atkins v. Virginia, establishing that intellectually disabled persons cannot be executed, Aleksey filed a second post-conviction relief application asserting intellectual disability as a bar to execution. The Orangeburg County post-conviction relief (PCR) court held a hearing to determine Aleksey’s intellectual disability. Aleksey submitted five affidavits, including the Hammock affidavit, as evidence of deficits in adaptive functioning. The PCR court excluded the Hammock affidavit because the affiant was unavailable for cross-examination, leaving only non-expert evidence on adaptive functioning. After reviewing IQ scores, expert testimony, and school records, the PCR court found Aleksey failed to prove intellectual disability by a preponderance of the evidence, as his developmental-period IQ scores were above the threshold, his adaptive deficits stemmed from ADHD and emotional disturbance rather than intellectual disability, and no intellectual disability diagnosis manifested during his developmental years. The Supreme Court of South Carolina reviewed whether the PCR court erred in its findings and evidentiary rulings. The Court affirmed the PCR court’s decision, holding that the finding Aleksey is not intellectually disabled was supported by the evidence and not against its preponderance. The Court also found no abuse of discretion in the exclusion of the Hammock affidavit, emphasizing the necessity of cross-examination for contested issues. The PCR court’s denial of relief was therefore affirmed. View "Aleksey v. State" on Justia Law

State v. Pinkerton

2026-05-19T09:18:21-08:00

In this case, a young woman was fatally shot on a Providence street in August 2021 while standing with her boyfriend beside her parked car. The shooting involved a dark sedan that sped by and fired multiple shots, striking the victim. The case remained unsolved for several months until, in December 2021, police stopped a vehicle for traffic violations. The defendant, seated in the rear, was among the occupants. After observing suspicious behavior and a lowered window in inclement weather, officers retraced the vehicle’s route and found a satchel containing a firearm. Forensic testing later matched the gun to shell casings from the murder scene and identified the defendant as the primary DNA contributor. Investigators also obtained incriminating information from an associate of the defendant, including phone communications linking him to the crime. After the defendant was indicted on multiple charges related to the murder and weapon offenses, he filed pretrial motions in Providence County Superior Court to suppress cell phone records obtained via search warrant and DNA evidence from a buccal swab he had consented to during police questioning. Following an evidentiary hearing, the Superior Court denied both motions. At trial, the jury convicted the defendant of most counts, and the trial justice sentenced him to two consecutive life terms plus additional years. The defendant appealed, arguing that the cell phone warrant lacked probable cause and that his consent to the DNA swab was not voluntary. The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s judgment. It held that the affidavit supporting the cell phone warrant, when considered in totality, established probable cause. It further held that the defendant’s consent to the buccal swab was voluntary under the totality of the circumstances. The court found no constitutional violations and upheld the convictions. View "State v. Pinkerton" on Justia Law

USA v. Evans

2026-05-19T09:00:13-08:00

A man checked into a hotel room in New Jersey in April 2021 and later moved to a larger room, turning in his key for the first room. After the initial room was cleaned, hotel staff discovered two handguns and letters with distinctive handwriting in the room’s safe. Police, notified by the hotel manager, linked the man to the room and discovered he had an outstanding arrest warrant. After a standoff, police arrested the man in his new hotel room. A search warrant was obtained and, upon execution, police found large quantities of various drugs, drug packaging materials, cash, and additional evidence hidden above the room’s ceiling tiles, including drug trafficking paraphernalia and letters matching those previously found. A federal grand jury indicted the man for being a felon in possession of firearms, possessing fentanyl and methamphetamine with intent to distribute, and possessing a firearm in furtherance of a drug-trafficking crime. He moved to suppress the evidence obtained from the hotel room, arguing the search exceeded the warrant’s scope. The United States District Court for the District of New Jersey denied the motion, finding probable cause supported the warrant and, alternatively, the good-faith exception applied. At trial, the court allowed a detective to give lay opinion testimony about drug trafficking based on his experience. The jury found the defendant guilty on all charges, and he was sentenced to 192 months’ imprisonment. On appeal, the United States Court of Appeals for the Third Circuit reviewed three claims: that the search of the ceiling was improper, that improper lay opinion testimony was admitted, and that the court erred in denying a spoliation instruction related to missing body camera footage. The Third Circuit held the search did not violate the Fourth Amendment, the admission of some improper lay opinion testimony was harmless given overwhelming evidence, and the denial of a spoliation instruction was not an abuse of discretion. The court affirmed the convictions and sentence. View "USA v. Evans" on Justia Law

Sheboygan County v. N. A. L.

2026-05-19T05:44:49-08:00

Nathan was emergently detained and subsequently subjected to involuntary commitment proceedings under Wisconsin law after reporting auditory hallucinations that suggested self-harm. During the circuit court hearings, Nathan’s counsel indicated that Nathan was not contesting the commitment or involuntary medication orders, and the court accepted this stipulation after some discussion on the record. Nathan expressed a desire for release but ultimately agreed to the commitment, particularly after assurances regarding his likely discharge timeline. Following entry of the six-month commitment and involuntary medication orders by the Sheboygan County Circuit Court, Nathan filed a post-disposition motion arguing his due process rights were violated because the court did not conduct a colloquy to ensure his stipulation was made knowingly, intelligently, and voluntarily. The circuit court denied this motion. Nathan appealed both the entry of the orders and the denial of his post-disposition motion. The Wisconsin Court of Appeals affirmed the circuit court’s orders. The Wisconsin Supreme Court reviewed whether constitutional due process requires a circuit court to conduct a colloquy before accepting a stipulation to orders for commitment and involuntary medication. The Court held that due process does not require such a colloquy in this context. The absence of a colloquy is not a structural constitutional error; rather, a due process violation would arise only if a waiver of fundamental rights was not entered knowingly, intelligently, and voluntarily. Because Nathan did not otherwise challenge the validity of his waiver, the Supreme Court affirmed the Court of Appeals’ decision. View "Sheboygan County v. N. A. L." on Justia Law

Downingtown Area SD v Chester Cnty Bd of Assmt.

2026-05-19T05:14:19-08:00

The case concerns an apartment complex owner who challenged a school district’s policy for appealing property tax assessments. The district’s policy only targeted properties for appeal if an increase would yield at least $10,000 in additional annual tax revenue. This policy, in place since 2012, did not discriminate by property type and had led to appeals involving various categories, including residential and commercial properties. For the tax year at issue, the district’s consultant identified fifteen properties meeting the threshold, and the district later added the taxpayer’s property, making a total of sixteen appeals. The taxpayer’s property had recently been sold, and its assessed value was significantly below its stipulated fair market value. After the Chester County Board of Assessment Appeals denied the school district’s appeal, the district sought review in the Chester County Court of Common Pleas. At a de novo hearing, the parties stipulated to the property’s fair market value. The main issue was whether the district’s policy was constitutional, both on its face and as applied. The county court sided with the district, finding the policy neutral and not discriminatory. The Commonwealth Court reversed, holding that the district arbitrarily applied its policy by not appealing all properties meeting the threshold, failing to justify certain choices, and by not appealing some properties for reasons unrelated to value. The Supreme Court of Pennsylvania reviewed the case. It held that a taxing district’s use of a monetary threshold for selecting properties to appeal does not violate the state constitutional requirement of tax uniformity, so long as the policy is neutral and not based on impermissible classifications such as property type. The Court further found that the district’s application of its policy in this instance was not arbitrary or discriminatory under the Uniformity Clause or Equal Protection Clause. The judgment of the Commonwealth Court was vacated and the case remanded for consideration of any remaining issues. View "Downingtown Area SD v Chester Cnty Bd of Assmt." on Justia Law

KAM v. THE STATE

2026-05-19T04:14:19-08:00

After a fatal shooting on May 9, 2021, the defendant and the victim, who were friends, co-workers, and neighbors, were involved in an altercation at their apartment complex in DeKalb County, Georgia. The defendant admitted to shooting the victim multiple times, including a fatal shot to the head. Evidence showed both men had been drinking prior to the incident, and there were conflicting accounts about the presence of an argument or whether the victim was armed. Forensic evidence indicated that the victim was shot in the head at close range while lying on the ground, and no firearm was found on or near the victim. The defendant was indicted and tried in the Superior Court of DeKalb County on charges including malice murder and possession of a firearm during the commission of a felony. His first trial ended in a hung jury. At a second trial, a jury convicted him on all counts. The court sentenced him to life imprisonment for malice murder and a consecutive suspended term for the firearm offense. Following the denial of his amended motion for new trial, the defendant appealed. The Supreme Court of Georgia reviewed the case. It held that the evidence was constitutionally sufficient to support the convictions, as a rational jury could find guilt beyond a reasonable doubt and reject the self-defense claim. The court found no abuse of discretion in admitting the defendant’s post-arrest statements, determining he understood his rights and communicated effectively in English. Although the court expressed concern over the shackling of the defendant during trial without specific findings, it concluded any error was harmless since the shackles were not visible to jurors. The exclusion of the victim’s blood alcohol content was deemed harmless error. Finally, the court determined that the verdict form did not violate due process. The Supreme Court of Georgia affirmed the convictions. View "KAM v. THE STATE" on Justia Law

HAYWOOD v. THE STATE

2026-05-19T04:14:18-08:00

Three individuals, including the appellant, devised a plan to rob a man from whom they had just purchased cocaine. The group entered the victim’s home; the appellant was armed with another accomplice’s gun. During the robbery, the appellant ordered an accomplice to restrain the victim on a sofa and directed the victim’s girlfriend to lie face-down on the floor. The girlfriend heard someone threaten to shoot the victim, followed by two gunshots. Testimony indicated that the victim tried to grab the appellant’s firearm during a momentary distraction, leading to a struggle in which the gun discharged. The appellant then shot the victim a second time. An autopsy showed the victim died from gunshot wounds to the face and chest. The Superior Court of Bibb County convicted the appellant of malice murder, among other charges. The appellant received a life sentence without parole. Two co-defendants pleaded guilty and testified against him. After conviction, the appellant, initially pro se and later with counsel, moved for a new trial. The trial court denied this motion following a hearing. The appellant then filed a timely appeal. The Supreme Court of Georgia reviewed the case. The appellant argued the trial court erred in rejecting his Batson challenge to the State’s use of peremptory strikes against black jurors and in refusing to instruct the jury on involuntary manslaughter. The Supreme Court held the prosecution provided facially race-neutral reasons for its peremptory strikes, and the trial court’s finding of no discriminatory intent was not clearly erroneous. The Court also found any error in refusing an involuntary manslaughter instruction was harmless because the jury’s malice murder verdict necessarily entailed a finding of intent to kill. The Supreme Court of Georgia affirmed the conviction. View "HAYWOOD v. THE STATE" on Justia Law

Cortez v. Rubio

2026-05-18T15:30:32-08:00

The plaintiff claimed he was born in Laredo, Texas, and used a U.S. passport for travel. After reporting his passport stolen in Mexico and later recovering it, he attempted to re-enter the United States, where the passport was retained. Over the following years, he submitted four separate passport applications, each denied by the Department of State. The agency cited concerns including a birth certificate filed by a birth attendant suspected of submitting false records, the existence of a conflicting Mexican birth certificate, and insufficient early life documentation to prove a U.S. birthplace. The plaintiff failed to provide requested records or adequate explanations for the discrepancies. After the repeated denials, the plaintiff petitioned the United States District Court for the Southern District of Texas for a writ of mandamus and declaratory relief, asserting claims under 8 U.S.C. § 1503(a), the Administrative Procedure Act (APA), the Mandamus Act, and constitutional provisions. The district court granted the defendant's motion to dismiss, finding the claims time-barred, jurisdictionally barred, or insufficiently pleaded. The United States Court of Appeals for the Fifth Circuit reviewed the appeal. The court held that the plaintiff’s claim under 8 U.S.C. § 1503(a) was untimely, as it was not brought within five years of the first final administrative denial, and equitable tolling was not warranted. The court affirmed that the APA and Mandamus Act claims were jurisdictionally barred because § 1503(a) provides an adequate remedy, regardless of whether the plaintiff timely pursued it. The court also held that the constitutional claims failed to state a claim, as no independent constitutional right to the relief sought existed beyond the statutory remedy. The Fifth Circuit affirmed the district court’s dismissal of all claims. View "Cortez v. Rubio" on Justia Law

Commonwealth v. Foster

2026-05-18T11:12:48-08:00

Police in Pittsburgh responded late at night to two ShotSpotter alerts that indicated five gunshots were fired near a specific residential address. Officer Powers arrived at the scene within seconds of the second alert and saw a parked car with its headlights on, occupied by the appellant in the driver’s seat and a woman in the passenger seat. As the officer approached with emergency lights on, the appellant exited the car and began walking toward a nearby house, while the passenger made movements inside the car. The officer ordered the appellant to return, and when he did not comply, police drew their weapons and forcibly detained him. Evidence subsequently obtained led to charges including driving under the influence and driving with a suspended license. The Court of Common Pleas of Allegheny County denied the appellant’s motion to suppress evidence, finding the investigative detention was supported by reasonable suspicion. At trial, the court found the appellant guilty on all charges. On appeal, the Superior Court affirmed, reasoning that the combination of the ShotSpotter alerts, the appellant’s proximity in time and space to the reported shots, his presence as one of only two people at the scene, his conduct upon police arrival, and the late hour supported reasonable suspicion for the stop. The Supreme Court of Pennsylvania reviewed whether the Superior Court gave too much weight to the appellant’s proximity to the ShotSpotter alerts in evaluating reasonable suspicion. The Supreme Court held that, although there was insufficient record support to consider the area a high-crime area, the totality of the circumstances—including the ShotSpotter alerts indicating gunfire, the rapid police arrival, the appellant and his companion being the only people present, and their evasive behaviors—provided reasonable suspicion for the investigative detention. The court therefore affirmed the Superior Court’s order upholding the denial of suppression. View "Commonwealth v. Foster" on Justia Law

Farella v. Anglin

2026-05-18T07:31:28-08:00

Two individuals were arrested by the Bentonville Police Department in Arkansas and appeared before a state district court judge two days and one day after their respective arrests. During these initial hearings, the judge set bail amounts for each individual without providing them with legal representation. Only after setting bail did the judge determine that they were indigent and appoint counsel for future proceedings. Both individuals remained incarcerated for several weeks before ultimately pleading guilty and being sentenced to time served. Following their experiences, these individuals, acting on behalf of a class of similarly situated pretrial detainees, filed suit in the United States District Court for the Western District of Arkansas. They alleged that the judge’s practice of setting bail without first appointing counsel violated their rights under the Sixth and Fourteenth Amendments. They sought declaratory and injunctive relief requiring that indigent defendants be provided with counsel at the start of their initial bail hearings. The district court denied motions to dismiss, certified the class, and ultimately granted summary judgment in favor of the plaintiffs. The district court held that the plaintiffs’ right to counsel attached at the initial hearing and that the bail-setting constituted a critical stage, thus granting declaratory and injunctive relief against the judge. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The Eighth Circuit held that the plaintiffs lacked Article III standing because they failed to show an ongoing or imminent injury that could be redressed by the prospective relief sought. The court found that the possibility of facing the same situation again was too speculative and that the requested relief would not redress any past harm already suffered. As a result, the Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of standing. View "Farella v. Anglin" on Justia Law

Christian v. James

2026-05-18T06:30:03-08:00

The plaintiffs challenged two provisions of New York’s Concealed Carry Improvement Act (CCIA): one that criminalizes carrying firearms on private property open to the public unless the owner has explicitly permitted it (the Private Property Provision), and another that prohibits firearm possession in “sensitive locations,” specifically public parks (the Public Parks Provision). Plaintiffs argued that these provisions violate the Second and Fourteenth Amendments. The Private Property Provision was challenged as applied to places open to the public, while the Public Parks Provision was subject to a facial challenge, with plaintiffs later attempting, unsuccessfully, to add an as-applied challenge concerning rural parks. The United States District Court for the Western District of New York permanently enjoined the State from enforcing the Private Property Provision as applied to private property open to the public, finding it unconstitutional because it was not consistent with the nation’s historical tradition of firearms regulation. The district court, however, granted summary judgment to the State on the Public Parks Provision, concluding that it was facially constitutional since historical analogues supported restrictions on firearms in public parks. The district court declined to consider plaintiffs’ as-applied challenge to the parks provision, ruling that this argument had not been properly raised. The United States Court of Appeals for the Second Circuit reviewed both appeals. It affirmed the permanent injunction against the Private Property Provision, holding that the State failed to show that the restriction is consistent with the historical tradition of regulating firearms, as required by New York State Rifle & Pistol Association, Inc. v. Bruen. The court also affirmed the judgment in favor of the State on the Public Parks Provision, finding it constitutional as applied to urban parks, and declined to consider the as-applied challenge regarding rural parks since it had not been raised below. View "Christian v. James" on Justia Law

Knight v. State

2026-05-15T13:02:28-08:00

Richard Knight was convicted of the first-degree murders of Odessia Stephens and her four-year-old daughter, Hanessia Mullings, with evidence including Knight’s presence at the scene, forensic findings tying him to the crime, and his confession to a fellow inmate. After a jury unanimously recommended the death penalty for both murders, the trial court imposed two death sentences, finding multiple aggravating factors and limited nonstatutory mitigation. On direct appeal, the Supreme Court of Florida affirmed Knight’s convictions and sentences. Subsequent postconviction and habeas proceedings in both state and federal courts were unsuccessful. After the Governor signed Knight’s death warrant, Knight filed a successive postconviction motion in the Circuit Court for Broward County, raising three claims: that unidentified fingerprint evidence constituted newly discovered evidence, that Florida’s lethal injection protocol was unconstitutional, and that the expedited death warrant process deprived him of due process. The circuit court summarily denied all claims and related motions. The Supreme Court of Florida reviewed the summary denial de novo and affirmed. The court held that the unidentified fingerprint claim was untimely, procedurally barred, and without merit, as the evidence was known at trial and did not undermine the case against Knight. The lethal injection claim was also found untimely, procedurally barred, and legally insufficient, as Knight failed to show a substantial risk of harm or propose a feasible alternative method. Lastly, the court rejected the due process claim, finding that Knight received adequate notice and opportunity to be heard. The court denied the request for a stay of execution, and ordered that no oral argument or rehearing would be permitted, with the mandate to issue immediately. View "Knight v. State" on Justia Law

Retail Energy Advancement League v. Brown

2026-05-15T10:30:35-08:00

Maryland enacted legislation regulating how retail electricity suppliers may market “green power” to consumers, seeking to address concerns that consumers were misled by claims about renewable energy. The statute prohibits suppliers from using terms such as “clean,” “green,” or “100% renewable” unless at least 51% of the energy is backed by renewable energy credits (RECs) from within a specific regional grid (the PJM region). Additionally, suppliers are required to include disclosures explaining the nature of RECs and their relationship to renewable electricity, with the exact disclosure language later specified by the Maryland Public Service Commission (PSC). Retail Energy Advancement League and Green Mountain Energy Company brought a facial First Amendment challenge against these provisions and sought a preliminary injunction in the United States District Court for the District of Maryland. The district court denied the injunction, applying intermediate scrutiny to the speech restriction and concluding that the plaintiffs were unlikely to prevail on the merits. The court also found that the statute’s disclosure requirements likely survived constitutional review. On appeal, the United States Court of Appeals for the Fourth Circuit found that the plaintiffs demonstrated a likelihood of success in showing the speech restriction was unconstitutional even under intermediate scrutiny, because the restriction did not materially advance Maryland’s asserted interest in preventing consumer deception and was not adequately tailored. The Fourth Circuit reversed the district court’s denial of a preliminary injunction as to the speech restriction and ordered an injunction against enforcement of that provision. However, regarding the compelled disclosure requirement, the Fourth Circuit remanded the case for the district court to review the constitutionality of the new PSC-promulgated disclosure language in the first instance. View "Retail Energy Advancement League v. Brown" on Justia Law

Ralston v. Board of Land and Natural Resources.

2026-05-15T10:02:31-08:00

A private company operating a hotel sought the renewal of a one-year, revocable state land permit for property fronting its hotel. A member of the public, who had long used the area for recreation, objected to the permit's renewal, particularly the practice of presetting hotel lounge chairs, which he argued deterred public use. He requested a formal contested case hearing on the permit renewal, asserting a property interest in the recreational and environmental quality of the public land. The Board of Land and Natural Resources (BLNR) denied his request for such a hearing, instead allowing only written and oral testimony at a public meeting. The objector appealed to the Circuit Court of the First Circuit, which upheld the BLNR's denial, finding that he had been afforded due process through the public meeting process. On further appeal, the Intermediate Court of Appeals (ICA) reversed, holding that the appellant had a constitutionally protected interest in a clean and healthful environment and was entitled to a contested case hearing before the permit could be renewed. Because the permit had expired, the ICA remanded the case to the circuit court to determine what relief, if any, remained available. The ICA granted costs but denied the appellant’s request for attorney fees under the private attorney general (PAG) doctrine, reasoning that the requirements for such fees were unmet since the scope of relief was not yet determined. The Supreme Court of the State of Hawai‘i vacated the ICA’s denial of attorney fees. The court held that the PAG doctrine does not require the prevailing party to obtain final relief before becoming eligible for attorney fees. Determining that all three prongs of the PAG test were met, the court remanded the matter for the ICA to determine the reasonableness of the appellant’s attorney fees and whether the hotel company was liable for them. View "Ralston v. Board of Land and Natural Resources." on Justia Law

STATE OF ARIZONA v MCCAULEY

2026-05-15T09:31:24-08:00

The defendant waited outside his estranged wife’s home late at night and, as she entered her car to leave for work, confronted and shot her eight times, causing her death. Immediately after the killing, he sent graphic text messages and explicit images to her family members, referencing the murder and making degrading statements about the victim. Police later found evidence at his residence, including a calendar marking the date as “judgment day.” He was indicted for first degree murder, and the prosecution sought the death penalty, alleging the crime was committed in an especially heinous, cruel, or depraved manner. At trial in the Superior Court in Maricopa County, the defense conceded the defendant killed his wife but argued there was no premeditation, requesting the jury consider lesser offenses. The jury convicted him of first degree murder. In the penalty phase, the jury found the aggravating factor of “especially heinous or depraved” and sentenced him to death. The defendant moved for a mistrial on various grounds, including alleged prosecutorial error, juror misconduct, and late disclosure of a prior conviction, but the trial court denied these motions and imposed the death sentence. The Supreme Court of the State of Arizona reviewed the case on direct appeal. The court held that the prosecutor committed some isolated errors, such as misstating the evidence and improperly suggesting the defense believed jurors were “bullies,” but found these errors neither individually nor cumulatively deprived the defendant of a fair trial. The court determined there was sufficient evidence to support the “especially heinous or depraved” aggravator, that the jury instructions were adequate, and that the trial court did not abuse its discretion in handling disclosure issues or juror misconduct. The court affirmed both the conviction and the imposition of the death sentence. View "STATE OF ARIZONA v MCCAULEY" on Justia Law