Constitutional Law - Justia Case Law Summaries

USA v. Jones

2026-07-31T09:01:42-08:00

Federal agents obtained a warrant to search the defendant’s mobile home in Moline, Illinois, for evidence of drug trafficking. The warrant was based on an affidavit describing a lengthy investigation into a drug organization operating between Arizona and the Quad Cities area. Key facts included intercepted packages containing money and drugs, suspicious phone calls linked to the defendant, phone records connecting him to individuals involved in the drug operation, and utility records showing a person of interest lived with him. In addition, agents conducted two searches of trash outside his residence, finding small amounts of discarded marijuana, mail addressed to the defendant and his housemate, vacuum-seal bags, and a shipping box. When agents executed the warrant, they discovered marijuana and over eight hundred grams of methamphetamine. In the United States District Court for the Central District of Illinois, the defendant moved to suppress evidence obtained during the search, arguing the warrant lacked probable cause. The district court acknowledged that the information connecting the defendant’s address to the drug organization was somewhat stale and attenuated, but ultimately found that the marijuana recovered from the trash alone supplied probable cause for the search under United States v. Leonard. The defendant entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Seventh Circuit reviewed the district court’s denial of the motion to suppress. The court applied a standard giving great deference to the issuing magistrate judge but reviewed legal conclusions de novo. The Seventh Circuit affirmed the denial, holding that officers reasonably relied on the warrant in good faith because the affidavit’s information, taken as a whole, came close enough to establishing probable cause for drug trafficking. The court did not rely solely on the marijuana found in the trash but emphasized the broader context of the ongoing investigation and ties to the defendant’s residence. View "USA v. Jones" on Justia Law

Hartmann v. Chudzik

2026-07-31T09:00:12-08:00

Several individuals arrested in Lancaster County, Pennsylvania, were detained pending trial after cash bail was set at their preliminary arraignments. At these arraignments, which were conducted via video without counsel present, the Magisterial District Judges allegedly imposed bail without considering the defendants’ ability to pay or other required factors under state law. Because they could not afford bail, the plaintiffs remained incarcerated. They brought a class action against four Magisterial District Judges (in their official capacities), Lancaster County, and the Warden of the county prison, alleging violations of their rights to equal protection, due process, and counsel. The United States District Court for the Eastern District of Pennsylvania first dismissed the plaintiffs’ Sixth Amendment claim, holding that the right to counsel attaches at the preliminary arraignment but does not require counsel’s presence at that proceeding, relying on Supreme Court precedent. The District Court later abstained from hearing the equal protection and due process claims under the doctrine established in Younger v. Harris, reasoning that federal intervention would improperly intrude upon ongoing state criminal proceedings and that state courts could address the plaintiffs’ bail-related claims. On appeal, the United States Court of Appeals for the Third Circuit reviewed both rulings. The Third Circuit held that Younger abstention was inappropriate because the plaintiffs did not seek to enjoin ongoing state criminal prosecutions but rather challenged procedures ancillary to those prosecutions—specifically, the process by which bail was set. Therefore, the District Court’s abstention was vacated and the matter remanded for further proceedings on the equal protection and due process claims. However, the Third Circuit affirmed the dismissal of the Sixth Amendment claim, holding that the preliminary arraignment under Pennsylvania law is not a “critical stage” requiring the presence of counsel, even though the right to counsel attaches at that point. View "Hartmann v. Chudzik" on Justia Law

De la Torre v. Cassidy

2026-07-31T07:32:08-08:00

After a major healthcare system filed for bankruptcy in 2024, a Senate committee initiated an investigation to understand the causes. The committee subpoenaed the system’s former CEO, who had overseen its operations, to testify at a hearing about the bankruptcy. The CEO objected, arguing that the committee’s actions—including the subpoena and subsequent contempt proceedings—violated his Fifth Amendment rights, particularly after he formally invoked those rights and refused to appear. The committee nevertheless proceeded, holding hearings and passing both civil and criminal contempt resolutions, with the full Senate adopting the criminal contempt resolution unanimously. The CEO then filed suit in the United States District Court for the District of Columbia against the committee and most of its members, seeking to declare their actions unlawful and to quash the subpoena. He also asked the court to enjoin further punishment for his refusal to testify. The committee moved to dismiss the case, relying on the Speech or Debate Clause of the Constitution, which protects legislative acts from judicial inquiry. The district court agreed, dismissing the case for lack of jurisdiction and denying the CEO’s request for jurisdictional discovery, finding the challenged actions fell squarely within the protected legislative sphere. The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court held that the Speech or Debate Clause absolutely barred the suit because the conduct challenged—issuing the subpoena, conducting the hearing, and voting on contempt resolutions—were core legislative acts. The court further determined that the CEO’s invocation of the Fifth Amendment did not deprive these acts of their legislative character, nor did allegations about the senators’ motives create an exception. The court affirmed the district court’s dismissal and its denial of discovery. View "De la Torre v. Cassidy" on Justia Law

USA v. Johnson

2026-07-31T07:32:07-08:00

The defendant in this case used an encrypted filesharing site to acquire hundreds of videos containing child sexual abuse material (CSAM), which he then uploaded to his Google Drive account and stored on his computer. In October 2020, Google’s automated software identified some of these files as likely CSAM and, following federal law, sent so-called “CyberTip” reports to the National Center for Missing & Exploited Children (NCMEC). NCMEC’s automated system, in turn, forwarded the reports and files to law enforcement, specifically a detective in the Metropolitan Police Department in Washington, D.C. The detective initially viewed some of the CSAM files without a warrant, then consulted a federal prosecutor and sought a warrant to review the files. A magistrate judge, however, advised that no warrant was needed, citing the “private search” doctrine, and the detective proceeded accordingly. Subsequent searches led to further evidence and ultimately to the defendant’s arrest and indictment for possession and transportation of CSAM. The United States District Court for the District of Columbia denied the defendant’s motions to suppress the evidence, reasoning that even if there was a Fourth Amendment violation when the detective first viewed the files without a warrant, suppression was unwarranted under the good-faith exception and independent-source doctrine. The court also rejected the argument that the residential search warrant only permitted seizure, not search, of digital devices. After an eight-day trial, a jury convicted the defendant on multiple counts related to possession and transportation of CSAM. The court further declined to reduce the sentencing offense level as requested by the defendant. The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s judgment. The appellate court held that, even assuming a Fourth Amendment violation occurred when the detective viewed the files without a warrant, suppression was not warranted because the government later obtained lawful authority from a magistrate judge and the detective acted in good faith. The court also found the residential search warrant authorized both seizure and search of digital devices and upheld the sentencing determination. View "USA v. Johnson" on Justia Law

North End Chamber of Commerce, Inc. v. City of Boston

2026-07-30T14:00:04-08:00

During the COVID-19 pandemic, the City of Boston implemented a temporary outdoor dining program that allowed restaurants across the city to use outdoor spaces for dining under relaxed licensing rules. In 2022, the City adopted a special plan for the North End neighborhood, which included higher fees, a shorter outdoor dining season, and additional restrictions compared to other neighborhoods. The City cited quality-of-life concerns, such as congestion and sanitation, and ongoing complaints from residents as reasons for the North End-specific rules. In 2023 and 2024, the City went further and banned on-street dining in the North End, while permitting it elsewhere. These actions prompted a group of North End restaurants and the local Chamber of Commerce to sue the City, alleging constitutional and state law violations. The United States District Court for the District of Massachusetts dismissed the plaintiffs’ lengthy complaint, finding that it violated Rule 8 of the Federal Rules of Civil Procedure by being excessively long and repetitive, and also determined that the complaint failed on the merits. The court denied the plaintiffs leave to amend, citing their multiple prior complaints and the substantive deficiencies in their claims. On appeal, the United States Court of Appeals for the First Circuit affirmed the dismissal of the federal constitutional claims (counts I–V) with prejudice, agreeing that the complaint was overly burdensome and failed to plausibly allege violations of equal protection, due process, or arbitrary action by the City. The Court held that disparate impact or political controversy alone does not suggest unconstitutional discrimination or retaliation, and the City’s actions had a rational basis. The First Circuit vacated the dismissal of the state law tax claim (count VI) and remanded with instructions to dismiss that claim without prejudice, as the federal court declined to reach its merits after disposing of the federal claims. View "North End Chamber of Commerce, Inc. v. City of Boston" on Justia Law

DOE v THE CORPORATION

2026-07-30T13:02:23-08:00

Three children, through their representatives, brought claims against a religious organization, individual clergy, and others after their father, Paul Adams, sexually abused them over several years. During the abuse, Paul disclosed his actions to two bishops of his church—first in private meetings and then in a formal disciplinary council where other church members were present. The bishops considered these disclosures confidential under church doctrine and did not report Paul’s admissions to authorities. Years later, law enforcement discovered evidence of the abuse, leading to criminal charges against Paul and his wife. After learning about Paul’s prior disclosures to church officials, the children sued the church and the clergy for, among other things, failing to report the abuse as required by Arizona law. The Cochise County Superior Court granted summary judgment to the church defendants, holding that the bishops’ knowledge of the abuse came exclusively from confidential religious communications. The court found that, under Arizona’s reporting statute and the so-called “clergy exemption,” the bishops were not required to report the abuse because they determined withholding the information was “reasonable and necessary” under the concepts of their religion. The court also ruled that it was not the role of the court or a jury to second-guess the clergy’s interpretation of their religious doctrine. The Arizona Court of Appeals vacated the lower court’s decision, finding that genuine issues of material fact remained as to whether the communications were truly confidential, whether the clergy-penitent privilege was waived by the presence of non-clergy, and whether church doctrine actually required non-reporting. The Supreme Court of the State of Arizona reversed the court of appeals and reinstated summary judgment for the church defendants. The court held that the First Amendment prohibits courts and juries from examining whether clergy properly applied religious doctrine in deciding not to report abuse under the reporting statute. It further ruled that, absent fraud or collusion for secular purposes, factfinders must defer to a religious institution’s definitions of “confession,” “confidential communication,” and “clergy.” The court concluded that all statutory requirements for the clergy exemption were met and affirmed the trial court’s judgment. View "DOE v THE CORPORATION" on Justia Law

Vapor Technology Association v. Wooten

2026-07-30T10:30:32-08:00

Several vape industry businesses and a vape user challenged a North Carolina law that restricts the sale of vape products lacking approval from the Food and Drug Administration (FDA). North Carolina’s statute, enacted in 2024, requires manufacturers to certify annually to the North Carolina Department of Revenue that their vape products either have FDA approval, were on the market by August 8, 2016 with a timely FDA application, or are exempt due to superficial changes. Products not listed in the resulting state directory cannot be sold in North Carolina, and violations can result in fines, product seizure, or lawsuits for deceptive trade practices. Before reaching the United States Court of Appeals for the Fourth Circuit, the plaintiffs sued North Carolina officials in the United States District Court for the Eastern District of North Carolina, arguing that the state law was preempted by federal law and violated the Equal Protection Clause. They sought a preliminary injunction to block enforcement of the law, relying only on the preemption argument. The district court denied the motion, finding that the plaintiffs had standing due to the threat of economic harm but were unlikely to succeed on the merits because the federal Tobacco Control Act did not preempt North Carolina’s regulation of vape product sales. The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that the commercial plaintiffs had standing due to the risk of substantial economic harm from enforcement of the law. On the merits, the court concluded that North Carolina’s law was not preempted by the relevant federal statutes. The state law was found to regulate sales, an area expressly preserved for state regulation by the federal Tobacco Control Act’s savings clause, and did not amount to impermissible enforcement of the FDA’s exclusive authority under federal law. The denial of a preliminary injunction was therefore affirmed. View "Vapor Technology Association v. Wooten" on Justia Law

Doe v. Weymouth

2026-07-30T07:38:14-08:00

After a divorce in September 2024, one party engaged in a series of acts directed at the other, including making a sexually suggestive and violent Facebook post, slamming a metal mailbox while delivering a child support payment despite requests for direct deposit, and posting a “warning poster” in the other party’s neighborhood implying she was a “black widow.” The recipient of these actions, who had previously experienced the other party’s alcohol misuse, anger, suicidal statements, and gun ownership, filed for a protection from abuse order. The District Court in Rockland issued a temporary protection order and then, after a final hearing, found by a preponderance of the evidence that the actions constituted abuse under Maine law, specifically 19-A M.R.S. § 4102(1)(B) as amended in 2024. The court determined that the conduct placed the plaintiff in fear of bodily injury, and that the defendant consciously disregarded a substantial risk that his speech would cause such fear. The court issued a final protection order prohibiting contact. The defendant appealed, arguing that his conduct constituted protected speech under the First Amendment, referencing Counterman v. Colorado, 600 U.S. 66 (2023), and challenging the sufficiency of the evidence regarding recklessness and “true threats.” The Maine Supreme Judicial Court reviewed the case, applying clear error review to the trial court’s factual findings and de novo review to the First Amendment challenge. The court held that the trial court properly considered the context and history between the parties, and that sufficient evidence supported the finding that the defendant’s actions and communications amounted to a course of conduct that placed the plaintiff in reasonable fear of bodily injury, and that he acted recklessly. The judgment of the District Court was affirmed. View "Doe v. Weymouth" on Justia Law

State of Maine v. Witham

2026-07-30T07:38:14-08:00

The case concerns a defendant who was convicted in two separate matters in Hancock County, Maine. In the first, he was found guilty by a jury of several offenses, including domestic violence aggravated assault with a dangerous weapon, after an incident in June 2020 in which he assaulted his romantic partner in his home, engaged in multiple acts of violence, and threatened both her and her child. In the second, he entered a conditional guilty plea to tampering with a witness. The court sentenced him to concurrent terms totaling twenty-four years, with all but twenty-two years suspended, and six years of probation. After the trial, the defendant argued that the trial court erred in three main ways: (1) by denying him an evidentiary hearing regarding funds seized in an unrelated drug case, which he claimed violated his rights to counsel and due process; (2) by failing to provide a specific-unanimity jury instruction and denying his post-judgment request for a mental-condition examination; and (3) by increasing his sentence based on findings about firearms, his age, and his lack of acceptance of responsibility. The Maine Supreme Judicial Court found it lacked jurisdiction to review the issues related to the seized funds, as they were tied to a separate case. The Court held that no specific-unanimity instruction was required for the counts at issue, the trial court did not err in denying the request for a mental-condition examination, and the sentencing court properly considered the presence of firearms, the defendant’s age, and his lack of acceptance of responsibility. However, the Court concluded that certain counts should have been merged to avoid double jeopardy. The judgment was affirmed, but the sentence was vacated in part and the matter remanded for resentencing consistent with the required mergers. View "State of Maine v. Witham" on Justia Law

Iowans for Alternatives v. Mosiman

2026-07-30T07:31:02-08:00

In 2024, Iowa enacted legislation (HF 2677) prohibiting the manufacture and sale of electronic nicotine delivery systems (ENDS) that had not received marketing authorization from the United States Food and Drug Administration (FDA). The law required manufacturers to certify their compliance with federal premarket approval requirements or demonstrate that their products were pending FDA review. Several manufacturers, retailers, and consumers challenged the law, contending it was preempted by federal law, specifically the Family Smoking Prevention and Tobacco Control Act, and that it violated constitutional equal protection guarantees. The United States District Court for the Southern District of Iowa granted a preliminary injunction, halting enforcement of the law. The district court found that at least one plaintiff had standing, was likely to succeed on the merits of the preemption claim, and was not required to post a security bond. It dismissed claims against the Iowa Department of Revenue based on Eleventh Amendment immunity but allowed the case to proceed against the Director in her official capacity. The Department voluntarily stayed enforcement while the litigation continued. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s order. The Eighth Circuit held that at least one retailer plaintiff had Article III standing, as they plausibly alleged injury from the credible threat of enforcement. However, the appellate court concluded the plaintiffs were not likely to succeed on the merits of their preemption claim. The court determined that HF 2677 was not preempted by federal law, as it fell within the scope of the Tobacco Control Act’s savings clause, which permits state requirements relating to the sale and distribution of tobacco products. The Eighth Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Iowans for Alternatives v. Mosiman" on Justia Law

Fayetteville Public Library v. Murray

2026-07-30T07:30:58-08:00

Arkansas enacted Act 372 in 2023, which criminalizes furnishing materials deemed “harmful to minors” and requires public libraries to adopt written policies for curating their collections and responding to challenges about appropriateness. Plaintiffs, including libraries, bookstores, and patrons, filed suit against Arkansas officials, alleging that these provisions violated the First Amendment due to overbreadth and the Fourteenth Amendment due to vagueness, before the act took effect. The United States District Court for the Western District of Arkansas granted summary judgment for the plaintiffs. The court permanently enjoined enforcement of both challenged sections, finding them unconstitutional as overbroad and void for vagueness, and awarded nearly $450,000 in attorney fees and costs. Defendants, including prosecuting attorneys and the Attorney General, appealed. The United States Court of Appeals for the Eighth Circuit reviewed the appeal de novo. The court found that the librarian and bookstore plaintiffs had standing to challenge the criminal provision, but patrons lacked standing regarding the library policy requirement, as no concrete injury was shown. The court determined the challenges to the criminal provision were ripe. On the merits, the court held that the criminal section was not unconstitutionally overbroad, as plaintiffs failed to provide evidence of substantial unconstitutional applications among third parties, and the record did not establish a lopsided ratio of impermissible to permissible applications. The court also held the provision was not void for vagueness because its language was commonly understood and included scienter requirements. Ultimately, the court reversed the district court’s judgment, vacated its permanent injunction, and vacated the award of attorney fees and costs. View "Fayetteville Public Library v. Murray" on Justia Law

Adams v. Hon. Robison

2026-07-30T06:14:04-08:00

A man was cited and charged in the Salt Lake City Justice Court after allegedly causing a car accident while driving under the influence of alcohol. The charges included a class B misdemeanor for DUI, as well as other related offenses. Several months after the charges were filed, the defendant attempted to plead guilty, but the City refused to consent, invoking a state law requiring prosecutorial approval for guilty pleas in DUI cases. The justice court declined to accept his plea without the City’s consent. The defendant then moved the justice court to declare the prosecutorial consent law unconstitutional, arguing it violated Utah’s separation of powers doctrine and his due process rights. While this motion was pending, the Salt Lake County District Attorney filed enhanced, felony-level charges against him in the district court. The City moved to dismiss the justice court case without prejudice, and the justice court denied the defendant’s constitutional challenge, finding no violation of the separation of powers and concluding the due process argument was inadequately briefed. The case in the justice court was dismissed without prejudice. The Supreme Court of the State of Utah reviewed the defendant’s petition for extraordinary relief. The court found that the defendant had properly invoked its authority for relief under Utah Rule of Appellate Procedure 19 regarding the separation of powers claim, since no direct appeal was available. However, the court declined to reach the merits or grant relief, holding that the defendant had not shown he was likely to benefit from a favorable ruling because felony charges were already pending in district court and it was speculative that the justice court would accept his guilty plea. The court also rejected the due process challenge, finding the defendant had not addressed the justice court’s basis for rejection. The petition for extraordinary relief was denied. View "Adams v. Hon. Robison" on Justia Law

USA v. Hunter

2026-07-29T15:30:30-08:00

The defendant, Munson Hunter, was indicted on multiple counts of bank and wire fraud for his role in a scheme that caused significant financial losses. After raising concerns about his mental health and undergoing a competency evaluation, Hunter pleaded guilty to one count in exchange for the dismissal of the remaining charges. His plea agreement included a waiver of the right to appeal his conviction and sentence, except for claims of ineffective assistance of counsel. At sentencing, the United States District Court for the Southern District of Texas imposed a term of supervised release with a special condition requiring Hunter to participate in a mental health program and take any medication prescribed by his physician. Hunter objected to being compelled to take medication. Despite the appellate waiver, Hunter appealed the medication condition, arguing it infringed on his due process rights. The United States Court of Appeals for the Fifth Circuit initially dismissed his appeal, relying on circuit precedent that recognized only limited exceptions to appeal waivers. The Supreme Court of the United States subsequently granted certiorari and announced a new rule: appeal waivers are unenforceable if their enforcement would result in a "miscarriage of justice"—that is, if they would leave in place an obvious and egregious error undermining the integrity of the judicial system. On remand, the United States Court of Appeals for the Fifth Circuit applied the Supreme Court’s new standard. The court determined that the record supported the imposition of the medication condition, finding no "blatant" constitutional error or egregious statutory violation. The court concluded that requiring Hunter to take prescribed medication as part of supervised release did not constitute the kind of obvious judicial error that would render the waiver unenforceable. Accordingly, the Fifth Circuit held that Hunter’s appeal waiver remained effective and dismissed the appeal. View "USA v. Hunter" on Justia Law

Joliet Avionics, Inc. v City of Aurora

2026-07-29T12:30:58-08:00

A company that operated as a fixed-base operator at a municipal airport sued the city that owns and operates the airport. The company alleged that the city provided more favorable lease terms and selectively excused certain regulatory requirements for a competing operator, thereby disadvantaging the plaintiff. The city’s leases with the plaintiff and with its competitor differed in several respects, including rent abatement periods, required capital investments, and compliance with fuel storage and insurance requirements. The plaintiff argued that these differences, along with the city’s alleged failure to strictly enforce its own policies and federal grant assurances, constituted both an equal protection violation under a “class-of-one” theory and a breach of contract. The lawsuit was originally filed in Illinois state court, but the city removed it to the United States District Court for the Northern District of Illinois. The plaintiff amended its complaint to drop claims against the competitor and proceeded against the city for breach of contract and equal protection violations. After discovery, both sides moved for summary judgment. The district court granted summary judgment for the city on both claims, finding that the class-of-one theory did not apply in the context of government contracting and that the contractual documents did not incorporate the policies or grant assurances as enforceable obligations. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that a class-of-one claim under the Equal Protection Clause is not available where a company challenges the terms of its lease or its competitor’s treatment under a different lease, absent any class-based discrimination. The court also held that the city’s policy and grant assurances were not incorporated into the plaintiff’s lease as enforceable contract terms, nor did the law provide a private right to enforce them in this context. The court affirmed the district court’s summary judgment in favor of the city. View "Joliet Avionics, Inc. v City of Aurora" on Justia Law

Myles Standish Associates, LP v. The City of Providence

2026-07-29T08:49:30-08:00

A restaurant owner applied for a liquor license for a property in Providence, Rhode Island. Nearby property owners, including the appellant, filed an objection to the license under a state law that allows such objections to bar issuance of liquor licenses within 200 feet of their property. After the local licensing board could not issue the license due to this objection, the restaurant owner lobbied the General Assembly, which enacted a special law allowing the Providence Board of Licenses to exempt this specific address from the objection rule. This exemption applied only to the property at 225 Waterman Street and was enacted without a vote by local Providence voters. After the special law was passed, the restaurant owner reapplied, and the Board granted the license over objections. The appellant appealed to the Rhode Island Department of Business Regulation (DBR), which stayed the license but did not rule on the constitutional issue. The appellant then filed suit in the Rhode Island Superior Court, arguing that the special exemption was unconstitutional because Article 13, Section 4 of the Rhode Island Constitution requires local voter approval for legislation relating specifically to the property, affairs, or government of a particular city or town. The Superior Court granted summary judgment for the defendants, holding that liquor licensing is a matter of statewide concern and does not require local voter approval. On appeal, the Supreme Court of Rhode Island reviewed the constitutionality of the special law. The court held that the legislation, which singled out a specific property in Providence for exemption from a generally applicable law, related to the property, affairs, and government of a particular city. Because the law did not receive local voter approval as required by Article 13, Section 4, it was void. The Supreme Court vacated the judgment of the Superior Court and remanded for entry of judgment in favor of the appellant. View "Myles Standish Associates, LP v. The City of Providence" on Justia Law

USA V. YATES

2026-07-29T08:01:16-08:00

A man who had recently been released on parole was stopped by police in San Pablo, California, while driving with his young niece and nephew. After a brief delay in pulling over, the officer learned of his parole status and asked the occupants to exit the car. The officer found a loaded, modified Glock pistol on the nephew, and text messages showed the man had instructed his mother to retrieve the child because he was carrying the gun. The gun and ammunition were manufactured outside California, and the gun was modified to fire automatically. A federal grand jury indicted the defendant for being a felon in possession of a firearm and ammunition. He sought to dismiss the indictment on constitutional grounds and to suppress the evidence, but while the United States District Court for the Northern District of California granted the suppression motion, the Ninth Circuit summarily reversed and remanded after a related case clarified that asking about parole status during a stop was permissible. The defendant then requested a stipulated-facts bench trial, after his request for a conditional plea was refused by the government. The district court found him guilty following the bench trial. At sentencing, the district court applied a two-level reduction for acceptance of responsibility but, over its stated disagreement, did not apply a third point because the government declined to move for it, citing resources expended preparing for trial. The court also applied an enhancement for possessing the firearm in connection with child endangerment, a “wobbler” offense under California law, finding the conduct was felonious. The United States Court of Appeals for the Ninth Circuit affirmed, holding that the government has broad discretion to withhold the motion for the third acceptance point under U.S.S.G. § 3E1.1(b), and the district court properly exercised its discretion in treating the child endangerment offense as a felony for sentencing purposes. View "USA V. YATES" on Justia Law

Onosamba-Ohindo v. Ball

2026-07-29T07:00:09-08:00

A noncitizen from the Democratic Republic of the Congo was detained in New York pending removal proceedings and was ordered released on bond, which he could not pay. He then brought a class action and habeas petition on behalf of similarly situated noncitizens, challenging government bond-hearing procedures as violating due process. Specifically, he argued that the procedures wrongly placed the burden of proof on detainees, failed to consider ability to pay, and did not require consideration of alternatives to detention. The United States District Court for the Western District of New York initially certified the class and issued a preliminary injunction requiring changes to bond-hearing procedures, with the government complying for nearly two years. After the Supreme Court decided Garland v. Aleman Gonzalez, which held that lower courts lack jurisdiction to issue class-wide injunctive relief under certain immigration statutes, the district court vacated the injunction. It then decertified the class entirely, concluding that neither class-wide injunctive nor declaratory relief was appropriate, and dismissed the case. The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court did not abuse its discretion in decertifying the class for injunctive relief, as lower courts lack authority for such relief post-Aleman Gonzalez. However, it found that the district court erred by decertifying the class for declaratory relief based on factors irrelevant to the Rule 23(b)(2) class-certification analysis. The Second Circuit clarified that while injunctive relief is unavailable, district courts retain authority to grant class-wide declaratory relief in these cases. Accordingly, the Second Circuit vacated the district court’s judgment and remanded for further proceedings. View "Onosamba-Ohindo v. Ball" on Justia Law

Civil Rights Corps v. LaSalle

2026-07-29T07:00:03-08:00

A group of plaintiffs, including Civil Rights Corps and several law professors, filed twenty-one grievance complaints against New York state prosecutors with the Attorney Grievance Committee of the Second Judicial Department. The complaints alleged unethical conduct based on public information and judicial findings. After the Committee informed the plaintiffs that any resulting proceedings against the prosecutors would remain confidential under Section 90(10) of the New York Judiciary Law, the plaintiffs brought suit under 42 U.S.C. § 1983, contending that the statute violated their First Amendment right of access as applied to their complaints. The United States District Court for the Southern District of New York reviewed the case at summary judgment. It held that a First Amendment presumption of access attaches to formal disciplinary hearings in the Second Department, to records necessary to understand those hearings, and to final dispositions by the Grievance Committee. The court found Section 90(10) unconstitutional as applied to the plaintiffs’ complaints, concluding it impermissibly interfered with their right of access. On appeal, the United States Court of Appeals for the Second Circuit considered whether the plaintiffs’ claims were ripe and whether abstention was warranted under O’Shea v. Littleton. Applying de novo review, the Second Circuit found the claims ripe and abstention unnecessary. The court applied the experience-and-logic test and determined that a qualified, presumptive First Amendment right of access exists for formal disciplinary hearings in the Second Department, pertinent records, and select Committee dispositions. The State may restrict access only if it makes specific, on-the-record findings justifying confidentiality. The Second Circuit affirmed the district court’s judgment. View "Civil Rights Corps v. LaSalle" on Justia Law

State v. Allen

2026-07-29T06:08:52-08:00

The defendant was convicted of the murder of Lannie Silver, Jr., based primarily on the testimony of Ruby Waller, who identified the defendant as the shooter and recounted the events leading up to Silver’s death. Waller, who had a history of drug convictions, initially provided her statement to police before she faced any pending charges, but by the time of trial, she had an unresolved shoplifting charge. During trial, she testified she was not expecting any benefit for her testimony. Years after conviction, the defendant alleged that the prosecution failed to disclose Waller’s 1991 plea agreement, in which she had received a reduced sentence in exchange for testifying against a co-defendant in an unrelated case, arguing that this could have been used to impeach her credibility. Following his conviction and unsuccessful direct appeal in the Superior Court, Appellate Division, and after a failed habeas petition in federal court, the defendant filed a motion in state court for a new trial based on the newly discovered plea agreement. The trial court denied the motion, concluding the evidence was not material. On appeal, the Appellate Division agreed with the trial court’s result but found it had used the wrong legal standard, ultimately holding that the standards for materiality under Brady v. Maryland and State v. Carter were essentially the same, and that the error was harmless. The Supreme Court of New Jersey clarified that the Brady standard for materiality—whether there is a reasonable probability that the result would have been different—is less demanding than Carter’s requirement that new evidence would probably change the verdict. The Court held these standards are not the same. Nonetheless, the Court affirmed the Appellate Division’s result, finding that the undisclosed plea agreement did not create a reasonable probability of a different outcome, and thus the defendant did not meet the Brady materiality standard. View "State v. Allen" on Justia Law

African People's Education and Defense Fund, Inc. v. Pinellas County

2026-07-29T05:01:41-08:00

A nonprofit organization in Florida, serving the Black community in St. Petersburg, applied twice for COVID-19 relief grants from funds distributed by Pinellas County. The group’s first grant application was initially approved, but after a newly seated Board member raised concerns about the group’s association with the “Uhuru Movement” and its perceived ties to Black empowerment and alleged antisemitic organizations, the Board revoked the grant. The group’s second application, for a backup generator, was later denied despite being highly ranked by an independent review foundation. The nonprofit alleged that similar grants were awarded to other organizations serving predominantly white communities for comparable purposes. After the denial, the nonprofit sued Pinellas County in the United States District Court for the Middle District of Florida, alleging violations of the First Amendment (retaliation for expressive association), the Equal Protection Clause (racial discrimination), and the Due Process Clause (lack of notice and opportunity to be heard). The district court dismissed all claims with prejudice, concluding there was no actionable First Amendment or equal protection violation and that the nonprofit did not have a property interest protected by due process. The United States Court of Appeals for the Eleventh Circuit reviewed the appeal. It held that the nonprofit plausibly alleged First Amendment retaliation, as the facts showed the county may have revoked and denied grants based on the group’s expressive association, and that the organization was entitled to full First Amendment protection as a grant applicant. The court also held that the nonprofit stated a plausible claim for intentional racial discrimination under the Equal Protection Clause. However, the panel affirmed dismissal of the due process claim, finding the nonprofit lacked a constitutionally protected property interest in the grants. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "African People's Education and Defense Fund, Inc. v. Pinellas County" on Justia Law

People Of Michigan v. Langston

2026-07-29T05:00:02-08:00

In 1976, the defendant was convicted by a jury of first-degree felony murder for aiding and abetting an armed robbery in which another individual committed a fatal shooting at a grocery store. The defendant was not present during the actual shooting but had provided information about the store’s occupants to the principal. He was sentenced to life imprisonment without the possibility of parole. The trial court’s instructions to the jury did not require a finding of malice as later defined by Michigan law. On direct appeal, the Michigan Court of Appeals reversed the conviction due to improper jury instructions regarding the mens rea for felony murder. However, the Michigan Supreme Court reinstated the conviction after its decision in People v Aaron, which redefined malice for felony murder but applied only to trials in progress or later. The case returned to the Court of Appeals, which affirmed the conviction, and the Michigan Supreme Court denied further review. In 2020, the defendant filed for post-judgment relief, arguing that his sentence was unconstitutional because the jury did not make a finding of malice as required by Aaron, and that mandatory life without parole was cruel or unusual punishment. The trial court denied his motion, stating it was bound by precedent, and the Court of Appeals denied leave to appeal. The Michigan Supreme Court held that mandatory life without parole for pre-Aaron felony murder constitutes cruel or unusual punishment under the Michigan Constitution if the jury was not instructed on malice as defined by Aaron, unless the prosecution can prove beyond a reasonable doubt that a jury would have found malice based on the trial evidence. If the prosecution fails to meet this burden, the no-parole aspect of the sentence must be struck, making the defendant eligible for parole. The trial court’s order was vacated in part, and the case was remanded for further proceedings. View "People Of Michigan v. Langston" on Justia Law

State v. Keaton

2026-07-29T04:03:13-08:00

The case involved a fatal shooting that took place during a nighttime street vigil in Hartford, where the defendant was identified as the shooter through surveillance video footage and subsequent police investigation. The police obtained and compiled footage from multiple street cameras using a software program called Milestone, which synchronized the various video feeds. During a police interview, the defendant identified himself in the video footage and admitted to being in the vicinity of the shooting. At trial, both the video compilation and the recording of the defendant’s interview were admitted into evidence. The case was tried before the Superior Court in the judicial district of Hartford, where the jury found the defendant guilty of murder and criminal possession of a firearm. During the trial, the defense did not object to the admission of either the video compilation or the recorded police interview and related waiver forms. The trial court rendered judgment in accordance with the jury’s verdict and sentenced the defendant to fifty-five years of imprisonment. On appeal, the defendant argued before the Connecticut Supreme Court that his confrontation rights were violated by the admission of the video compilation, claiming he was entitled to cross-examine the developer of the Milestone software. He also contended that his right to counsel was violated during the police interview. The Supreme Court held that the defendant’s confrontation clause claim was affirmatively waived because his counsel expressly stated “[n]o objection” to the admission of the evidence at trial. The court further found the record inadequate to review the confrontation claim and determined that the right-to-counsel claim was unreviewable under established standards due to waiver. The court declined to exercise its supervisory authority to adopt new rules or reverse the conviction. Accordingly, the conviction was affirmed. View "State v. Keaton" on Justia Law

Terry v. Drummond

2026-07-28T08:02:03-08:00

A group of young activists in Oklahoma City participated in racial-justice protests in the summer of 2020. During one incident, they were involved in a confrontation with a police officer near a permitted mural painting. The activists were later charged under Oklahoma’s riot-related statutes, with allegations that they surrounded a patrol car, yelled threats and expletives, and confined the officer briefly. Several of the plaintiffs pleaded guilty to lesser misdemeanor charges, while one had charges dismissed after proving non-involvement. The activists subsequently filed a federal lawsuit in the United States District Court for the Western District of Oklahoma against state and county officials, challenging the constitutionality of Oklahoma Statutes, title 21, section 1311 (the Riot Statute). They argued the statute was unconstitutionally overbroad under the First Amendment and unconstitutionally vague under the Fourteenth Amendment. Plaintiffs sought a preliminary injunction to block enforcement of the statute. The district court denied their request, construing the statute to include intent elements based on Oklahoma case law, and found plaintiffs were unlikely to succeed on the merits of their claims. On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the case. Because of unsettled state law questions, the Tenth Circuit certified questions to the Oklahoma Court of Criminal Appeals, which clarified that the Riot Statute requires a showing of willfulness and a common intent to use or threaten violence, but does not require proof of recklessness. Relying on this construction, the Tenth Circuit held that plaintiffs failed to demonstrate a substantial likelihood of success on their facial overbreadth and vagueness challenges. The court affirmed the district court’s denial of a preliminary injunction. View "Terry v. Drummond" on Justia Law

United States v. Bogan

2026-07-28T07:01:09-08:00

The defendant, after joining a gang at age 14, participated in a drive-by shooting in Iowa that resulted in the death of a bystander. He was convicted by a state jury of first-degree murder, but the conviction was reversed on appeal. He subsequently pleaded guilty to voluntary manslaughter and related charges and was sentenced to up to 25 years in state prison. Following his release in 2014, he was convicted of being a felon in possession of a firearm and later, after further criminal activity including high-speed chases and renewed gang involvement, conspired to distribute cocaine and participated in a shooting incident in 2020. Surveillance footage captured him firing a weapon, and he was later charged federally with RICO conspiracy and felon-in-possession offenses. The United States District Court for the Southern District of Iowa denied the defendant’s pretrial motions to dismiss the indictment. He had argued that the inclusion of his juvenile conduct in the RICO charge violated the Juvenile Delinquency Act (JDA), and challenged the constitutionality of the felon-in-possession statute under New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The district court rejected both arguments, and the defendant entered a conditional guilty plea, preserving his right to appeal the denial of his motions. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s rulings de novo. It held that post-majority ratification of a conspiracy allows pre-majority conduct to be considered as part of a federal RICO prosecution, making the JDA inapplicable in this context. The court also held that circuit precedent foreclosed the defendant’s Bruen-based challenge to the felon-in-possession statute. The Eighth Circuit affirmed the district court’s denial of the motions to dismiss. View "United States v. Bogan" on Justia Law

United States v. Striplin

2026-07-28T07:01:06-08:00

Benjamin Striplin was apprehended after leading police on a high-speed chase that ended with his arrest. During a search of his vehicle, officers found a loaded pistol and a makeshift device used for smoking methamphetamine. Striplin admitted to regularly using methamphetamine and to owning the firearm at the time of his arrest. Based on these admissions, a grand jury charged him with possessing a firearm as an unlawful user of a controlled substance, in violation of federal law. Before trial, Striplin moved to dismiss the indictment, arguing that the statute under which he was charged violated the Second Amendment and was unconstitutionally vague, both on its face and as applied to him. A magistrate judge recommended denial of the motion, reasoning that historical firearm regulations supported restrictions on possession by certain categories of persons, and concluded that vagueness challenges could not be resolved until trial. The United States District Court for the Western District of Missouri adopted these recommendations, denied the motion to dismiss, and later found Striplin guilty at a bench trial based on stipulated facts. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss. The appellate court rejected Striplin’s vagueness challenge, finding the statute clear as applied to someone who admitted to regular drug use contemporaneous with firearm possession. However, regarding the Second Amendment claim, the Eighth Circuit noted that recent case law requires a fact-specific analysis to determine whether the application of the statute aligns with historical firearm regulation traditions. Because the district court did not conduct this analysis, the appellate court reversed the district court’s judgment and remanded the case for further proceedings consistent with current legal standards. View "United States v. Striplin" on Justia Law

Felton v Johnson

2026-07-27T13:00:47-08:00

A correctional officer with almost nineteen years of service was terminated by the state corrections department after he disclosed information about an upcoming search (“shakedown”) to his son, who was incarcerated at a different facility. The department conducted an investigation following a recorded phone call and statements gathered from both the officer and his son. The officer’s son allegedly boasted about receiving advance notice of the search, while the officer admitted in the investigation that he inadvertently shared information. After the investigation, the officer was fired for violating departmental policy. The officer attempted to appeal his termination, but filed his grievance with the wrong agency and did not follow up for over two years. The United States District Court for the Eastern District of Wisconsin dismissed the son’s First Amendment retaliation claim at the screening stage and later granted summary judgment in favor of the corrections department on the officer’s First Amendment retaliation and Fourteenth Amendment procedural due process claims. The district court determined that the officer’s speech was not protected because it did not address a matter of public concern, and that adequate pre- and post-termination procedures were available to the officer, despite his procedural missteps. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decisions. The appellate court held that the officer’s statement about the shakedown was not protected speech under the First Amendment, as it was private and not of public concern. It also found that the officer received sufficient notice and opportunity to respond before termination, and that adequate avenues for post-termination review were available, even if he failed to properly use them. The court further concluded that the son’s claim did not state a constitutional violation. The district court’s dismissal and summary judgment orders were affirmed. View "Felton v Johnson" on Justia Law

US v. Jaqu

2026-07-27T11:01:34-08:00

The defendant was convicted by a jury of multiple drug-trafficking and firearm offenses following a three-day trial, during which he was represented by court-appointed counsel. After the trial and before sentencing, the defendant filed a notice expressing his desire to remove his counsel and represent himself at sentencing. At a subsequent hearing, despite being advised against self-representation, the defendant maintained his wish to proceed pro se for sentencing. The sentencing hearing had not yet been scheduled at the time of his request. The United States District Court for the District of South Carolina denied the defendant’s request to represent himself at sentencing, finding it untimely because it was made several months after the jury verdict and after objections to the presentence report had been filed. The court relied on precedent that allows for denial of self-representation requests made after the commencement of trial and appointed new counsel to represent the defendant at sentencing. The defendant was ultimately sentenced with an enhancement under the Armed Career Criminal Act, and he appealed, arguing that his Sixth Amendment right to self-representation was violated. The United States Court of Appeals for the Fourth Circuit held that the district court erred in denying the defendant’s request to represent himself at sentencing on the basis of untimeliness. The appellate court clarified that a request to proceed pro se at sentencing, made after trial but before sentencing, is not untimely if sentencing has not yet been scheduled and the request does not disrupt proceedings. The court vacated the judgment and remanded the case for resentencing, instructing the district court to conduct a proper Faretta hearing to determine whether the waiver of counsel is knowing, intelligent, and voluntary. The court did not address arguments related to the Armed Career Criminal Act enhancement. View "US v. Jaqu" on Justia Law

Lichfield v. Kubler

2026-07-27T08:02:04-08:00

The plaintiff, who operated boarding schools and programs for troubled teens, was featured in a three-part documentary series that examined the troubled-teen industry and included depictions and commentary about his role in industry organizations and specific schools. The filmmaker, herself a former student at an affiliated program, created the series based on her personal experience and broader investigative reporting. The series, produced and distributed by a major streaming service, included segments which the plaintiff claimed falsely implied his responsibility for a teen’s death, omitted the ultimate dismissal of criminal charges against him following a facility raid in Costa Rica, and accused him of abusing children and committing crimes. The United States District Court for the District of Utah dismissed the plaintiff's complaint, which included claims for defamation, defamation per se, false light invasion of privacy, intentional infliction of emotional distress, and civil conspiracy. The court concluded that the challenged statements were either non-actionable opinions protected by law and the First Amendment, true, or not defamatory. The court also granted the defendants’ special motion to strike under anti-SLAPP statutes, awarding attorneys’ fees and costs, and declined to decide between Utah or California law because the outcome was the same under either. On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The Tenth Circuit held that none of the challenged documentary segments were capable of defamatory meaning under Utah law or the First Amendment. The court found the statements to be either protected opinion, not materially false, or not objectively verifiable. The court also found the anti-SLAPP fee award appropriate and rejected the plaintiff’s arguments regarding amendment and anti-SLAPP procedure, holding that any errors on those points were invited by the plaintiff’s own positions below. View "Lichfield v. Kubler" on Justia Law

USA V. PATTERSON

2026-07-27T08:01:19-08:00

The case concerns a defendant who pleaded guilty to being a felon in possession of a firearm, after police discovered a loaded pistol on his person during a traffic stop. The prosecution sought an enhanced sentence under the Armed Career Criminal Act (ACCA), based on the defendant’s prior Oregon state felony convictions: two for third-degree assault and one for strangulation. The defendant challenged the use of these convictions as ACCA predicate offenses, arguing they did not meet the definition of “violent felonies.” He also argued that his constitutional rights were violated because the judge, rather than a jury, determined that his prior offenses occurred on different occasions, a necessary finding to trigger the ACCA enhancement. The United States District Court for the District of Oregon found that the prior convictions were for violent felonies and had been committed on different occasions, and imposed the ACCA’s mandatory minimum sentence of 15 years. The defendant appealed, raising the same constitutional and statutory objections. The United States Court of Appeals for the Ninth Circuit reviewed the case. It concluded that, in light of the Supreme Court’s ruling in Erlinger v. United States, the district court had erred under Apprendi v. New Jersey by making the separate-occasions finding itself, rather than submitting it to a jury. However, the Ninth Circuit held that this error was harmless beyond a reasonable doubt, because the record contained overwhelming and uncontroverted evidence that the offenses occurred on different occasions. The court also held that the defendant’s Oregon convictions for third-degree assault and strangulation qualified as violent felonies under the ACCA. The court therefore affirmed the sentence imposed by the district court. View "USA V. PATTERSON" on Justia Law

United States v. Gendron

2026-07-27T07:00:03-08:00

In May 2022, Payton Gendron carried out a mass shooting at a supermarket in Buffalo, New York, killing ten Black individuals and injuring three others. He meticulously planned the attack to target Black victims, documenting his intentions and motives in a manifesto and online journal. Following the attack, a grand jury indicted Gendron on multiple federal charges, including hate crimes resulting in death and firearm offenses. The government sought the death penalty on certain counts and provided notice of both statutory and non-statutory aggravating factors, including the impact on surviving victims, Gendron’s racist motive, and his intent to incite further violence. The United States District Court for the Western District of New York struck the three contested non-statutory aggravating factors from the government’s notice. The court reasoned that the surviving victims’ injuries were irrelevant to the capital charges, that federal law precluded the government from presenting Gendron’s racist motive as an aggravator, and that citing his intent to incite further violence would violate his First Amendment rights by punishing protected speech. The United States Court of Appeals for the Second Circuit reviewed these rulings de novo. The Second Circuit held that all three non-statutory aggravating factors were permissible. It concluded that evidence of injury to surviving victims is relevant to the circumstances of the crime in a capital sentencing proceeding. The court determined that presenting Gendron’s racist motive does not violate statutory restrictions, as the motive itself, not the race of the victims, is at issue. Finally, the court held that referencing Gendron’s intent to incite further violence does not infringe upon his First Amendment rights when used to establish motive for the crime. The Second Circuit reversed the district court’s order and remanded for further proceedings. View "United States v. Gendron" on Justia Law

People Of Michigan v. Jennings

2026-07-25T05:00:02-08:00

A man was stopped by police while driving a car matching the description of a vehicle seen leaving the scene of a shooting. Police found a loaded handgun in the glovebox. During questioning, the driver admitted to being at the scene and driving the car, but when asked for a DNA sample to compare with the handgun, he refused and ended the interview. At trial, the prosecutor argued that the defendant’s decision to stop cooperating was evidence of a “guilty conscience,” displaying a board with that phrase to the jury and contrasting his actions with those of other occupants who continued their interviews. After closing arguments, the Macomb Circuit Court judge raised concerns that the prosecutor’s comments improperly used the defendant’s invocation of his right to silence against him. Defense counsel moved for a mistrial, which the court granted. The defendant argued that a retrial would violate double jeopardy, but the trial court denied this, finding no evidence that the prosecutor specifically intended to provoke a mistrial. At the second trial, the prosecution shifted its theory, and the defendant was convicted. The Michigan Court of Appeals affirmed, holding that retrial was not barred under the standard from Oregon v Kennedy, 456 US 667 (1982), because the prosecutor’s misconduct was not intended to goad the defense into requesting a mistrial but was instead reckless or negligent. On further appeal, the Michigan Supreme Court held that the Kennedy standard does not properly protect the double-jeopardy rights guaranteed by the Michigan Constitution. The Court rejected Kennedy and adopted the broader standard from Pool v Superior Court, 139 Ariz 98 (1984), holding that retrial is barred if a mistrial is granted due to intentional, prejudicial prosecutorial misconduct pursued for an improper purpose with indifference to the risk of mistrial, and the resulting prejudice cannot be cured short of a mistrial. The Court vacated the judgment of the Court of Appeals and remanded for application of the new standard. View "People Of Michigan v. Jennings" on Justia Law

Grant v. Trial Court of the Commonwealth of Massachusetts

2026-07-24T13:30:04-08:00

A group of individuals who wished to protest outside a high-profile murder trial in Massachusetts were prohibited from doing so by a Superior Court judge’s order establishing a 200-foot buffer zone around the courthouse, including nearby sidewalks and streets. After the buffer zone was imposed, the plaintiffs—demonstrators—filed suit in federal court against various public officials and entities, alleging violations of their First Amendment and due process rights. The United States District Court for the District of Massachusetts initially denied a preliminary injunction against the buffer zone, but the United States Court of Appeals for the First Circuit vacated that denial and remanded, suggesting that a restriction more closely tailored to demonstrations intended to interfere with justice might be permissible. In response, the Superior Court judge amended the order to include a requirement of intent to interfere with the administration of justice or influence trial participants. The district court then partially granted and partially denied a renewed motion for a preliminary injunction: it found the revised order survived a facial First Amendment challenge but agreed with plaintiffs that there had been unconstitutional as-applied enforcement, granting limited relief. After the murder trial concluded and the buffer zone order expired by its own terms, the plaintiffs continued to appeal the denial of broader injunctive relief. The United States Court of Appeals for the First Circuit held that the case was moot because the order was no longer in effect and there was no reasonable expectation the same plaintiffs would again face a similar restriction. The court determined that neither injunctive nor declaratory relief was available and that the “capable of repetition, yet evading review” exception did not apply. As a result, the First Circuit vacated the district court’s partial denial of the preliminary injunction and ordered dismissal of that portion of the case, leaving the remainder to the district court. View "Grant v. Trial Court of the Commonwealth of Massachusetts" on Justia Law

In re: K.B.

2026-07-24T11:08:27-08:00

A minor child, who had been in her grandmother’s custody due to her mother’s intellectual disabilities, became the subject of a child in need of assistance (CINA) case after concerns arose about missed medical appointments and poor academic performance. The Department of Social Services petitioned for CINA status, but the juvenile court initially allowed the child to remain with her grandmother under protective supervision. Over time, further review hearings were held, and eventually a magistrate recommended removing the child from her grandmother’s custody. The child and her grandmother objected, leading to a de novo exceptions hearing. At the exceptions hearing, the Circuit Court for Worcester County, sitting as a juvenile court, excluded the child from the hearing over the objection of her counsel, reasoning generally that it was inappropriate for children under 15, especially those with developmental delays, to attend such contested proceedings. The court later removed the child from her grandmother’s custody and placed her with the Department. The Appellate Court of Maryland affirmed the juvenile court, finding no abuse of discretion, and distinguished this case from prior precedent by concluding the juvenile court had considered the child’s due process rights. The Supreme Court of Maryland reviewed the case and held that, although the appeal was moot because the CINA proceedings had been terminated and custody restored to the grandmother, the case presented an issue of public importance warranting review. The Court held the juvenile court violated the child’s procedural due process rights by excluding her from her own CINA hearing without making individualized findings or balancing her due process interests against any potential harm from her presence. The Court articulated a new test requiring courts to make specific findings and narrowly tailor any exclusion of a child party. The judgment of the Appellate Court of Maryland was reversed. View "In re: K.B." on Justia Law

Fuentes v. Citizenship and Immigration Services

2026-07-24T10:30:33-08:00

Two naturalized U.S. citizens, who previously obtained lawful status through the Special Immigrant Juvenile (SIJ) program after state courts found parental abuse, neglect, or abandonment, sought to confer immigration benefits to their noncitizen mothers. Both mothers’ applications were denied by United States Citizenship and Immigration Services (USCIS), invoking an exclusion clause in the SIJ statute, 8 U.S.C. § 1101(a)(27)(J)(iii)(II), and an implementing regulation prohibiting parents of SIJ recipients from receiving immigration benefits based on parentage. The plaintiffs challenged both USCIS’s interpretation of the exclusion clause and the constitutionality of the clause, arguing it violated equal protection. The United States District Court for the Eastern District of Virginia, reviewing cross-motions for summary judgment, ruled in favor of USCIS. The court held that the regulation was consistent with the plain text of the exclusion clause and rejected the equal protection claim, concluding that plaintiffs lacked a direct constitutional injury and, in the alternative, that the exclusion survived rational basis review. Plaintiffs appealed, maintaining their APA and equal protection challenges. The United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the exclusion clause’s plain text establishes a permanent bar, preventing any parent of an SIJ recipient from receiving immigration benefits based solely on parentage, regardless of whether the parent was abusive or not. The court also held that USCIS’s regulation is consistent with the statute. On the equal protection claim, the Fourth Circuit found differential treatment but determined that the exclusion clause survives rational basis review, as it is rationally related to protecting children from harm. The judgment of the district court was affirmed. View "Fuentes v. Citizenship and Immigration Services" on Justia Law

Computer & Communications Industry Association v. Paxton

2026-07-24T09:30:53-08:00

Texas enacted a law imposing new requirements on certain social media platforms, termed "digital service providers" (DSPs), to restrict minors’ access to specific categories of content. These requirements included monitoring and filtering content deemed harmful, prohibiting targeted ads to minors, preventing unlawful ads, verifying user age for access to certain material, and requiring age registration for account creation. Two groups challenged the law: one group, including technology industry organizations, contested the monitoring and filtering requirement; another group, comprised of a student coalition, individuals, and an ad agency, challenged several provisions, including the monitoring and filtering, targeted ads, unlawful ads, and age-verification requirements. In the United States District Court for the Western District of Texas, both plaintiffs sought preliminary injunctions against enforcement of the law. The district court granted injunctions in part, enjoining the monitoring and filtering requirements for both groups, and enjoining the targeted ads, unlawful ads, and age-verification requirements for the student coalition group. The court found these provisions likely unconstitutional or vague, and held that the plaintiffs had standing based on the chilling effect on their speech and listening rights. The Attorney General of Texas appealed, and the United States Court of Appeals for the Fifth Circuit consolidated the cases. The United States Court of Appeals for the Fifth Circuit held that the student coalition plaintiffs lacked standing to challenge the monitoring and filtering, targeted ads, and unlawful ads requirements, as they were not directly regulated and failed to show a substantial risk of imminent harm. Their challenge to the age-verification requirement was foreclosed by Supreme Court precedent. However, the court held that the monitoring and filtering requirement, as challenged by the industry groups, is preempted by Section 230 of the Communications Decency Act. The Fifth Circuit affirmed the district court’s injunction as to the industry group, but vacated and remanded the injunction as to the student coalition plaintiffs. View "Computer & Communications Industry Association v. Paxton" on Justia Law

Johnson v. DC

2026-07-24T08:02:46-08:00

A long-serving correctional officer at the District of Columbia Department of Corrections was terminated from her position after nearly three decades of service. During the COVID-19 pandemic, she became increasingly vocal about perceived failures in the Department’s response to the crisis. In her role as a union leader, she forwarded internal Department emails to union attorneys and participated in a local television interview criticizing the Department’s pandemic management. The Department launched an investigation, ultimately determining that she violated confidentiality policies and terminated her employment, despite a hearing officer’s recommendation for a lesser penalty. After her termination, she filed suit in D.C. Superior Court against the Department’s leadership, alleging that her firing violated her First Amendment rights. The defendants removed the case to the United States District Court for the District of Columbia, where both sides moved for summary judgment. The district court found triable issues of fact regarding whether her termination was motivated by protected speech and denied qualified immunity to the individual defendants. The defendants sought reconsideration, which was denied, and then appealed to the United States Court of Appeals for the District of Columbia Circuit. The United States Court of Appeals for the District of Columbia Circuit held that the officials were entitled to qualified immunity with respect to her claim that she was fired for forwarding confidential emails, finding no violation of a clearly established First Amendment right in those circumstances. However, the court affirmed the denial of qualified immunity for the claim that she was fired for giving a media interview, concluding that if her termination was motivated by the interview, it would violate clearly established First Amendment law. The case was remanded for further proceedings. View "Johnson v. DC" on Justia Law

United States v. Williams

2026-07-24T07:30:38-08:00

The case concerns a defendant who was arrested after his girlfriend reported to police that he had struck her, taken her handgun, chambered a round, and threatened her with it. Forensic evidence later confirmed his DNA on the weapon. The defendant gave conflicting accounts, initially denying knowledge of the gun, then claiming he took it from his girlfriend to protect himself. Officers arrested him, and he was charged in state court with domestic violence and illegal firearm possession. While out on bond, federal prosecutors indicted him for being a felon in possession of a firearm after an earlier felony conviction. During execution of a federal arrest warrant, officers found a stolen rifle in the home. The government offered a plea deal involving a single count, which the defendant declined, resulting in a superseding indictment on two counts. The United States District Court for the Northern District of Ohio denied the defendant’s motion to suppress the rifle and his motion to dismiss on Second Amendment grounds. The defendant ultimately pleaded guilty to both counts without a written plea agreement. At sentencing, the district court applied an enhancement for possessing a firearm in connection with a felony offense, based on evidence that he had threatened his girlfriend with the handgun, and imposed a 100-month prison sentence. The defendant appealed, raising constitutional arguments and challenging the sentencing enhancement. The United States Court of Appeals for the Sixth Circuit held that, because the defendant pleaded guilty unconditionally and did not comply with Federal Rule of Criminal Procedure 11(a)(2), he waived his right to appeal pre-plea constitutional issues. The court declined to address his ineffective assistance of counsel claim on direct appeal, finding the record undeveloped. Reviewing the sentencing enhancement for clear error, the court found ample evidence to support the district court’s application of the enhancement and affirmed the sentence. View "United States v. Williams" on Justia Law

Sims v. State of Mississippi

2026-07-24T01:24:16-08:00

In 2019, a man was indicted in Coahoma County, Mississippi, on three charges: sexual battery of a child under fourteen, felonious child abuse, and exposing another to HIV. The case involved his eight-year-old daughter, who moved to live with him that year. After the child disclosed abuse to her older sister, she was taken to the hospital, where injuries consistent with sexual abuse were observed. Medical professionals and law enforcement became involved, and the child underwent further examinations and interviews. During the investigation, the defendant admitted to law enforcement that he was HIV positive. A jury in the Coahoma County Circuit Court found the defendant guilty on all three counts. The trial court sentenced him to twenty years for sexual battery, and five years each for child abuse and exposing another to HIV, all to be served concurrently. The defendant’s motion for a new trial was denied. On appeal to the Supreme Court of Mississippi, the defendant challenged only his conviction for exposing another to HIV, arguing the trial court violated his Confrontation Clause rights by admitting Mississippi Department of Health records without the opportunity to cross-examine their custodian and that the State presented insufficient evidence of knowing exposure. The Supreme Court of Mississippi held that the Confrontation Clause argument was procedurally barred because it was not raised at trial and, alternatively, the admitted records were non-testimonial business records not subject to the Confrontation Clause. The court also determined that the State had presented sufficient evidence for a rational juror to convict under the plain language of the statute, which required proof that the defendant was HIV positive and knowingly exposed the child. The conviction and sentence were affirmed. View "Sims v. State of Mississippi" on Justia Law

USA v. Debrow

2026-07-23T15:30:30-08:00

The defendant, after previously pleading guilty to aggravated criminal damage to property under Louisiana law, was found in possession of a firearm. His earlier offense involved intentionally damaging vehicles during a police traffic stop, endangering human life, which led to a three-year sentence. After serving his sentence, he was again found with a firearm, resulting in an indictment for possession of a firearm by a convicted felon under 18 U.S.C. § 922(g)(1). The United States District Court for the Western District of Louisiana reviewed the defendant’s motion to dismiss the indictment, in which he argued that § 922(g)(1) was unconstitutional as applied to him. The district court denied the motion. The defendant then entered a conditional guilty plea, reserving the right to appeal the denial, and was sentenced to 56 months’ imprisonment. On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the constitutionality of § 922(g)(1) as applied to the defendant, considering whether the government's justification for permanent disarmament was supported by a historical tradition consistent with the Second Amendment, as outlined in New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The Fifth Circuit found that the government had not met its burden to demonstrate a relevant historical analogue for disarming individuals with a property crime predicate like the defendant’s. The court declined to expand precedent by treating aggravated property damage as sufficiently violent for permanent disarmament under historical going-armed laws. The Fifth Circuit vacated the district court’s order denying the motion to dismiss and remanded the case for reconsideration. The main holding was that, absent sufficient evidence of a historical tradition supporting disarmament for this type of predicate felony, the government had not justified the application of § 922(g)(1) to the defendant. View "USA v. Debrow" on Justia Law

Carrin v. Smiledge

2026-07-23T11:32:32-08:00

Raymond Carrin was a federal detainee diagnosed with Hepatitis C who sought medical treatment while in custody at the Federal Detention Center in Tallahassee, Florida. Despite Carrin’s repeated requests and visible deterioration over more than a year—including emergency hospitalizations and symptoms consistent with advanced liver disease—medical staff did not provide him with the direct-acting antiviral treatment prescribed for his condition. The facility’s staff indicated that treatment would only begin once Carrin was transferred to his designated institution, a transfer that was delayed for various reasons. Carrin eventually died from hepatic cirrhosis without receiving the necessary medication. He did not file a formal grievance or seek relief under the prison’s Administrative Remedy Program (ARP) before his death. Carrin’s estate brought suit in the United States District Court for the Northern District of Florida against two federal prison officials, alleging violations of Carrin’s Fifth and Eighth Amendment rights and seeking damages under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). The district court initially denied the defendants’ motions to dismiss and for summary judgment. However, after the Eleventh Circuit’s decision in Johnson v. Terry, 119 F.4th 840 (11th Cir. 2024), the court granted judgment on the pleadings for the defendants, holding that the presence of the ARP constituted a special factor counseling against extending Bivens to these claims, and that Carrin’s case differed meaningfully from prior Supreme Court Bivens precedents. On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The court held that both the Eighth and Fifth Amendment claims arose in a new context distinct from Carlson v. Green, 446 U.S. 14 (1980), and that the existence of the ARP—regardless of its adequacy or accessibility to the estate—was a special factor precluding the extension of Bivens remedies. View "Carrin v. Smiledge" on Justia Law

Williams v. Superintendent Fayette SCI

2026-07-23T09:00:11-08:00

Stanford Williams was tried three times for the 1993 murder of Omar Massey. The first trial ended in a hung jury, and the second trial was interrupted when a key witness, John Faingnaert, changed his expected testimony regarding Williams’s exposure to gun residue. Williams’s attorney, John Elash, contemplated becoming a witness to rebut Faingnaert but acknowledged he could not continue representing Williams if he did so. The trial court concluded that Elash could not waive a potential ineffective assistance claim and, after discussion, granted a mistrial. Williams was convicted at his third trial and sentenced to life in prison. Following his conviction, Williams argued that the third trial violated his protection against double jeopardy, asserting that he had not requested or consented to the mistrial in the second trial. The Allegheny County Court of Common Pleas rejected this claim, finding that Williams had moved for a mistrial. The Pennsylvania Superior Court affirmed, holding that Williams waived his double jeopardy claim by not raising it before the third trial and that the claim lacked merit because he had requested the mistrial. Williams sought post-conviction relief, and the same trial judge found again that Williams requested the mistrial; the Superior Court affirmed this finding. Williams then filed for habeas corpus relief in the United States District Court for the Western District of Pennsylvania. The District Court granted his petition, holding that the third trial violated double jeopardy and that his counsel was ineffective for failing to raise the claim. On appeal, the United States Court of Appeals for the Third Circuit applied AEDPA deference to the state court’s findings and concluded that Williams did not provide clear and convincing evidence that the state court erred in finding he requested a mistrial. The Third Circuit held that the third trial did not violate the Double Jeopardy Clause and that Williams’s counsel was not ineffective for failing to raise a meritless double jeopardy claim. The District Court’s order was reversed. View "Williams v. Superintendent Fayette SCI" on Justia Law

State v. Fox

2026-07-23T05:43:07-08:00

The defendant was charged with continuous sexual abuse of his stepdaughter, following her disclosure of alleged abuse. He sought to introduce evidence that the accuser had engaged in an inappropriate online relationship with an adult male, including sexually explicit exchanges, arguing that she fabricated the allegations against him in retaliation for being disciplined after her mother discovered the relationship and terminated it. The defendant believed this evidence would support his theory that the accuser had a motive to lie. The District Court of Cass County, East Central Judicial District, held an in camera hearing under North Dakota Rule of Evidence 412 to consider the admissibility of the proposed evidence. The court conditionally denied the defendant’s motion, finding the evidence inadmissible under Rule 412(a) and determining that the defendant had not provided a sufficient offer of proof to invoke the constitutional exception under Rule 412(b)(1)(C). The court identified foundational deficiencies in the proffered evidence and allowed limited questioning about the fact and emotional impact of discipline, but not the explicit sexual content. The jury subsequently convicted the defendant of continuous sexual abuse, and the court entered judgment. On appeal to the Supreme Court of the State of North Dakota, the defendant argued that the exclusion of evidence violated his Sixth Amendment right to confrontation and constituted an abuse of discretion. The Supreme Court reviewed the constitutional claim de novo and the evidentiary ruling for abuse of discretion. It concluded that the District Court’s exclusion of the explicit evidence was neither arbitrary nor disproportionate, given the marginal probative value and the temporal gap between the events. The defendant’s confrontation rights were not violated because he was permitted to question the victim about discipline and emotional impact. The Supreme Court affirmed the criminal judgment. View "State v. Fox" on Justia Law

People of Michigan v. Wilkins

2026-07-23T05:00:03-08:00

A Michigan State Police trooper stopped a vehicle for speeding, driven by the defendant, with a passenger under the age of 21. The trooper smelled marijuana but did not see any in plain view, nor did the occupants appear intoxicated or in possession. After both initially denied possessing marijuana, the passenger admitted to having a small amount (“shake”), which under Michigan law is a civil infraction for those under 21. The trooper then searched the vehicle and found a concealed firearm, which the defendant admitted was his. At the preliminary examination, the defendant argued that the vehicle search violated the Fourth Amendment. The 63rd District Court bound him over on the concealed weapon charge. In Kent Circuit Court, the defendant moved to suppress the firearm, but the motion was denied. The Michigan Court of Appeals, after remand from the Michigan Supreme Court, affirmed the circuit court’s denial, holding the search did not violate the Fourth Amendment. The Supreme Court of Michigan reviewed the case and held that the warrantless search was unlawful under the automobile exception to the Fourth Amendment’s warrant requirement. The Court found that the trooper had probable cause only to believe a civil infraction (possession of a small amount of marijuana by a minor) had occurred, not a crime. The Court clarified that probable cause to believe only a civil infraction has been committed does not justify a warrantless search under the automobile exception. The presence of marijuana odor, without more, does not establish probable cause to believe a criminal amount is present. The judgment of the Court of Appeals was reversed, and the case was remanded to the circuit court for further proceedings. View "People of Michigan v. Wilkins" on Justia Law

People of Michigan v. Ellis

2026-07-23T05:00:02-08:00

The defendant pleaded guilty to attempted unarmed robbery in Michigan in 2021, following a prior conviction for attempted rape in Illinois in 1983. As part of the 2022 sentence, the Berrien Circuit Court imposed lifetime registration as a Tier III sex offender under Michigan’s Sex Offenders Registration Act (SORA), based on the statute’s “recapture” provision. This provision requires individuals with pre-SORA sexual offense convictions to register if they are later convicted of any felony after July 1, 2011. The defendant had not committed another sexual offense in the intervening decades, and his recent conviction involved theft and a disputed assault in a Walmart store. After sentencing, the defendant challenged the registration requirement, arguing it was unconstitutional and not applicable because he was an out-of-state resident. The Berrien Circuit Court denied his motion to correct an invalid sentence. The Michigan Court of Appeals affirmed, finding the registration requirement constitutional but held that the defendant, as a nonresident, did not have to register unless he moved to or worked in Michigan. The Michigan Supreme Court reviewed the case, focusing on whether SORA’s recapture provision constituted cruel or unusual punishment when imposed for nonsexual offenses. The Court held that imposing SORA registration on individuals convicted of nonsexual offenses who had a pre-SORA sexual offense conviction was unconstitutional under the Michigan Constitution. The Court found the registration requirement grossly disproportionate, ineffective for rehabilitation, and harsher than penalties imposed for similar offenses elsewhere. The judgment of the Court of Appeals was reversed, and the case was remanded to the trial court to remove the registration requirement from the defendant’s sentence. View "People of Michigan v. Ellis" on Justia Law

United States v. Fordham

2026-07-22T11:00:58-08:00

Three defendants, who held leadership positions in a nationwide gang operating in Michigan and Chicago, were charged after a lengthy federal investigation uncovered extensive drug distribution, violent acts, and strict internal codes of silence within the organization. Law enforcement used confidential informants, monitored communications, conducted controlled purchases, and executed search warrants on social media and personal devices to gather evidence. The defendants were indicted for racketeering conspiracy, drug conspiracies, and related offenses. While many co-defendants pled guilty, these three proceeded to trial. The United States District Court for the Eastern District of Michigan conducted a month-long trial, after which a jury convicted all three defendants on most counts. One defendant was acquitted of certain drug trafficking and firearm possession charges but convicted on racketeering, drug conspiracy, and possession with intent to distribute marijuana. At sentencing, the district court imposed lengthy prison terms for each defendant. The defendants appealed, raising suppression issues concerning wiretap evidence, social media searches, and cell phone searches; Sixth Amendment claims regarding prison mail policies and cross-examination limitations; sufficiency-of-the-evidence challenges; and a sentencing dispute. The United States Court of Appeals for the Sixth Circuit reviewed the case. It rejected all suppression arguments except for a procedural sentencing challenge raised by one defendant, finding that the district court failed to adequately address his objection to a sentencing enhancement based on acquitted conduct. The Court affirmed the convictions for all three defendants and rejected their constitutional and evidentiary claims, holding that the evidence and trial procedures met legal standards. However, it vacated the sentence for the one defendant on procedural grounds and remanded for resentencing, while affirming all other aspects of the district court’s judgment. View "United States v. Fordham" on Justia Law

In re McCowen

2026-07-22T08:32:57-08:00

A man was convicted of first-degree murder in 2001 after fatally shooting another individual during a confrontation at a woman’s apartment. At trial, a paramedic testified that the victim suffered two gunshot wounds—one to the chest and another to the head with brain matter visible—supporting the prosecution’s theory of premeditation. However, the pathologist’s autopsy report, which was not introduced at trial, indicated there was only one gunshot wound, entering through the upper chest or neck and exiting from the upper back, with the victim’s head found intact. After his conviction was affirmed on direct appeal by the California Court of Appeal, Fourth Appellate District, the defendant unsuccessfully sought relief in the San Bernardino County Superior Court and then again in the Court of Appeal, arguing that his conviction rested on false evidence. He filed a similar petition in the California Supreme Court, which issued an order to show cause, directing the Court of Appeal to consider whether the prosecution had violated due process by allowing false testimony about the number and nature of gunshot wounds. The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the pleadings and determined that the paramedic’s testimony was materially false and had been relied upon by the prosecution to argue for premeditation. The court found no procedural bar to the petition and concluded that the discrepancy between the trial testimony and the autopsy report required further factual development. The court granted the habeas corpus petition and remanded the matter to the superior court for an evidentiary hearing to determine the origins and impact of the false testimony, the prosecution’s knowledge of the autopsy report, and whether a new trial should be ordered. View "In re McCowen" on Justia Law

BBLI Edison, LLC v. City of Chicago

2026-07-22T08:00:46-08:00

A property owner acquired a Chicago apartment building through foreclosure in February 2024, after the city’s ordinance requiring new owners of foreclosed rental properties to negotiate new 12-month leases with existing tenants and provide a $10,600 relocation fee to those who decline new leases went into effect. Upon acquisition, the owner notified more than 220 tenants of their rights, and at least five tenants declined to sign new leases, requesting the relocation assistance. The property owner filed suit against the City of Chicago, claiming that the ordinance’s relocation fee requirement constituted an unconstitutional taking under the Fifth Amendment. The United States District Court for the Northern District of Illinois reviewed the owner’s complaint, which sought to enjoin enforcement of the ordinance. The court dismissed the complaint, concluding that the ordinance did not violate the Constitution, and the owner declined to amend its pleading before appealing. The United States Court of Appeals for the Seventh Circuit considered whether the ordinance’s relocation assistance requirement amounted to a physical or regulatory taking, or imposed an unconstitutional condition. The court held that the ordinance, which regulates the landlord-tenant relationship and imposes financial obligations similar to permissible rent control schemes, is not a per se physical taking. Applying the Penn Central factors, the court found no regulatory taking, noting the property owner’s lack of allegations regarding economic infeasibility and that the acquisition occurred after the ordinance’s enactment. The court also determined that the unconstitutional conditions doctrine did not apply, as the ordinance directly mandates a fee rather than leveraging a permitting process. The Seventh Circuit affirmed the district court’s dismissal, holding that the ordinance does not violate the Takings Clause. View "BBLI Edison, LLC v. City of Chicago" on Justia Law

Shuler v. State

2026-07-22T05:36:02-08:00

The case involved charges against a defendant for first-degree murder, second-degree murder, voluntary manslaughter, robbery with a dangerous weapon, and related firearms offenses after the shooting deaths of two individuals during a drug transaction. The defendant, who admitted to the shootings but claimed self-defense, was impeached at trial with a prior custodial statement in which he denied any involvement. The statement was made during a late-night, uncounseled custodial interrogation after the defendant was advised of his Miranda rights. At trial in the Circuit Court for Baltimore City, the defendant requested a jury instruction directing the jury to consider the voluntariness of his custodial statement before using it for impeachment. The trial court declined to give this instruction, finding there was no evidence suggesting the statement was involuntary. The jury acquitted the defendant of first- and second-degree murder but found him guilty of voluntary manslaughter, robbery, and several firearms offenses. He was sentenced to 70 years' imprisonment. The defendant appealed to the Appellate Court of Maryland, arguing he was entitled to the voluntariness instruction. The Appellate Court affirmed the conviction, holding that the instruction was not required since the statement was introduced only for impeachment, was exculpatory, and there was no “some evidence” of involuntariness. Upon further review, the Supreme Court of Maryland disagreed with the Appellate Court’s reasoning that the instruction was unnecessary because the statement was used for impeachment or was exculpatory. However, the Supreme Court determined the defendant failed to present “some evidence” that his statement was involuntary, as required to trigger the instruction. The Court also concluded that, even if it was error to deny the instruction, the error was harmless beyond a reasonable doubt given the nature of the evidence and the jury’s verdict. The Supreme Court of Maryland affirmed the judgment of the Appellate Court. View "Shuler v. State" on Justia Law

State v. Barnes

2026-07-22T05:07:04-08:00

A theft victim sought restitution from the person who broke into her office and stole property. The offender pleaded guilty to attempted breaking and entering and petty theft. At sentencing, the trial court did not award restitution, despite a request from the victim and supporting documentation. The victim initially filed a timely direct appeal, arguing for restitution under Marsy’s Law, which provides victims certain rights, including restitution. However, while her appeal was pending, she voluntarily dismissed it. Several years later, after related proceedings—including a writ of mandamus directing the trial court to determine restitution—the victim attempted to file a delayed appeal challenging the lack of restitution. After the victim’s direct appeal was dismissed, she sought mandamus relief in the Eighth District Court of Appeals, which partially granted her request by directing the trial court to consider restitution. The trial court scheduled a restitution hearing, but the offender appealed, and the Eighth District vacated the order for a hearing, holding the victim had forfeited the right to challenge restitution by dismissing her earlier appeal. The Supreme Court of Ohio declined jurisdiction over the victim’s appeal from that decision. The victim then moved for leave to file a delayed appeal of the original sentencing order, but the Eighth District denied her request, citing Appellate Rule 5(A), which allows delayed appeals only for defendants, not victims. The Supreme Court of Ohio held that victims seeking to appeal a trial court’s denial of restitution are subject to the procedural requirements of Appellate Rule 4(A) and Appellate Rule 5(A). The court concluded that neither the Ohio nor United States Constitutions require courts to allow victims to file delayed appeals, and that Appellate Rule 5(A)’s limitation to criminal defendants is valid. The judgment of the Eighth District was affirmed, and the victim’s motion for leave to file a delayed appeal was denied. View "State v. Barnes" on Justia Law

State v. Friscia

2026-07-21T14:37:40-08:00

A woman in Great Falls, Montana, made a frantic 9-1-1 call pleading for help because her former partner had locked her out of their residence, and had “our” baby inside. The call abruptly ended, and police responding to the scene were unable to reestablish contact. Officers spoke to a neighbor who referenced a disturbance, and then encountered loud, indiscernible screaming from the involved apartment. Upon identifying themselves and requesting entry, the occupant, Phillip Friscia, responded angrily, repeatedly opening and closing the door, sometimes holding the child, and stated he had the right to defend himself from people in his house. Officers, concerned for the safety of those inside, forcibly entered the residence, apprehended Friscia, and found the woman and child unharmed. The State charged Friscia with felony threatening an officer and misdemeanor destruction of a communication device. Friscia moved to suppress evidence, arguing the entry was unlawful and not justified by exigent circumstances, and challenged the constitutionality of the statute under which he was charged. The Eighth Judicial District Court, Cascade County, denied both motions, finding the police entry justified by exigent circumstances based on the totality of evidence and the statute constitutionally valid. Friscia entered an Alford plea, reserving his right to appeal these decisions. The Supreme Court of the State of Montana reviewed the appeal. It held that the District Court’s factual findings regarding exigent circumstances and probable cause were not clearly erroneous and properly supported the denial of the suppression motion. The Supreme Court further held that Montana’s statute, requiring a subjective mental state, was not facially unconstitutional or overbroad, and did not violate the First Amendment under Counterman v. Colorado. The Supreme Court affirmed the District Court’s rulings and Friscia’s conviction. View "State v. Friscia" on Justia Law

Recchia v. Campbell

2026-07-21T13:30:03-08:00

In this case, the owner of a Massachusetts gun store and the store itself challenged recent amendments to state law that prohibit the sale, transfer, or possession of certain "assault-style firearms" and related magazines. The plaintiffs argued that these provisions, enacted in 2024, violated their rights under the Second Amendment, the dormant Commerce Clause, and the Equal Protection Clause of the Fourteenth Amendment. They asserted that the law infringed on their ability to keep and bear arms, imposed unconstitutional burdens on interstate commerce by affecting out-of-state manufacturers and their own business, and discriminated against them compared to individuals and businesses in other states. The United States District Court for the District of Massachusetts granted the state defendants’ motion to dismiss for failure to state a claim. The district court concluded that the plaintiffs’ Second Amendment claim was foreclosed by the First Circuit’s earlier decision in Capen v. Campbell, which upheld a similar Massachusetts firearms ban. The court also found the plaintiffs’ dormant Commerce Clause and Equal Protection Clause claims inadequately pleaded, noting that the complaint did not plausibly allege discrimination against interstate commerce or that similarly situated persons were treated differently. The United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The First Circuit held that its prior decision in Capen v. Campbell controlled and that the challenged restrictions on assault-style firearms were consistent with the Nation’s historical tradition of firearm regulation and thus did not violate the Second Amendment. The court further held that the law did not discriminate against or impose an undue burden on interstate commerce, nor did it violate equal protection, as the right to make a living is not a fundamental right and the law had a rational basis. The district court’s judgment was affirmed. View "Recchia v. Campbell" on Justia Law

Occhicone v. State

2026-07-21T12:03:08-08:00

The case centers on a man convicted and sentenced to death for the 1986 murder of his ex-girlfriend’s mother in Florida. On the night of the crime, he returned to his ex-girlfriend’s home after being refused entry, armed himself, and cut the phone lines before fatally shooting the woman’s father outside and, after breaking in, shooting her mother inside. The jury recommended death for both murders, but the judge imposed a life sentence for the father's death and a death sentence for the mother's, finding several aggravating factors. Since his conviction became final in 1991, he has unsuccessfully challenged his conviction and sentence in multiple state and federal proceedings. After a death warrant was signed in 2026, he filed a second successive motion for postconviction relief in the Circuit Court for Pasco County, arguing: (1) that alleged shortages of the lethal injection drug etomidate and possible deviations from execution protocols violated his constitutional rights; (2) that executing him at his advanced age would constitute cruel and unusual punishment; and (3) that the pace of executions in Florida and the circumstances of his case rendered his execution unconstitutional and a manifest injustice. The circuit court summarily denied these claims, along with his requests for public records and a stay of execution. The Supreme Court of Florida reviewed the appeal and affirmed the circuit court’s summary denial. The court held that the public records request was properly denied because it was not tied to a colorable claim for postconviction relief and found the equal protection and Eighth Amendment challenges speculative, untimely, or lacking merit. The court also rejected arguments based on the pace of executions, alleged psychological effects on prison staff, and the sufficiency of the jury’s death recommendation under current law. The motion for a stay of execution was also denied, and the mandate was ordered to issue immediately. View "Occhicone v. State" on Justia Law

Schukar v Kenosha County

2026-07-21T12:00:56-08:00

During widespread civil unrest in Kenosha County, Wisconsin, following the police shooting of Jacob Blake, two photojournalists, Alyssa Schukar and Scott Olson, were documenting protests outside the Kenosha County Courthouse. The protest escalated, with some participants engaging in violent behavior and law enforcement responding with crowd-control measures, including foam baton rounds. Schukar and Olson were struck and injured by these rounds while covering the protest, though they did not observe who fired at them. Neither wore visible press credentials, but both carried cameras and equipment. Schukar and Olson brought suit in the United States District Court for the Eastern District of Wisconsin against two officers, Deputy Steven Robakowski and Officer Ryan Jacobs, alleging violations of their First Amendment rights through retaliatory targeting and Fourth Amendment rights through excessive force. The district court granted summary judgment for the officers. It found no evidence of retaliatory animus and concluded that if the officers struck the journalists, it was accidental and not a violation of their rights. The court also determined that an accidental use of force against unintended targets did not constitute a seizure under the Fourth Amendment. The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The Seventh Circuit held that the plaintiffs failed to present evidence showing the officers intentionally targeted them because of their protected activity. It further held that, given the unsettled legal landscape, it was not clearly established in 2020 that an officer’s intentional deployment of less-than-lethal munitions that accidentally struck an unintended target constituted a Fourth Amendment seizure. As a result, the court affirmed summary judgment and held that the officers were entitled to qualified immunity. View "Schukar v Kenosha County" on Justia Law

Abbott v. State

2026-07-21T11:04:24-08:00

The case concerns a defendant who, having previously been convicted of drug offenses in Virginia and Delaware, was classified under Delaware law as a “person prohibited” from possessing firearms or ammunition. In 2023, police discovered two separate firearms and corresponding ammunition in the defendant’s residence in Dover, Delaware, after the defendant voluntarily disclosed their locations. The defendant was subsequently indicted on two counts of possession of a firearm by a person prohibited and one count of possession of ammunition by a person prohibited. In the Superior Court of the State of Delaware, the defendant waived a jury trial. After a bench trial, the Superior Court found him guilty on all three counts. The court imposed separate sentences for each count, including substantial periods of incarceration and probation. The defendant appealed, arguing that his convictions were multiplicitous, in violation of the Double Jeopardy Clause of the U.S. Constitution. He contended that the Superior Court should have merged the counts into a single conviction and sentence because all the weapons and ammunition were possessed simultaneously. The Supreme Court of the State of Delaware reviewed the case. The court held that under the relevant statute, 11 Del. C. § 1448, the phrase “a deadly weapon” unambiguously sets the unit of prosecution as each individual weapon or item of ammunition, not all items collectively. Thus, the State may charge and sentence a person prohibited for each weapon or ammunition possessed at the same time. The court rejected the defendant’s arguments based on legislative history, statutory interpretation, and precedent, and affirmed the Superior Court’s judgment, holding that multiple convictions and sentences were proper under the statute. View "Abbott v. State" on Justia Law

State v. Thornton

2026-07-21T09:07:03-08:00

The case centers on the convictions of two defendants for offenses related to the 2019 murder of Donnell Brockington in Baltimore City. After the shooting, the suspects fled in a vehicle, which crashed, and four individuals—including the defendants—were apprehended. Police recovered multiple firearms from the vehicle and nearby, with DNA evidence linking all four co-defendants to the weapons. At trial, a State firearms examiner testified that certain ammunition recovered from the crime scene “was fired with” a Desert Eagle pistol found in the vehicle. None of the defendants challenged the reliability of this methodology before or during trial, nor requested a Daubert hearing. Following their convictions, the defendants appealed. During the pendency of their appeal, the Supreme Court of Maryland issued a decision in Abruquah v. State concerning firearms identification testimony. The Appellate Court of Maryland subsequently reversed the convictions on plain-error review, finding that the examiner’s unqualified testimony was prohibited by Abruquah. Additionally, one defendant challenged the trial court’s decision to close the courtroom during jury deliberations and to limit attendance at the verdict, which was prompted by escalating incidents of spectator misconduct, including direct contact between a co-defendant’s father and a juror. The Supreme Court of Maryland reviewed the case and held that the admission of the unqualified firearms examiner’s testimony was not “clear or obvious” error at the time of trial or appeal, making plain-error reversal inappropriate. The Court clarified that Abruquah was a case-specific Daubert determination, not a categorical ban. Regarding the courtroom closure, the Court adopted the Kelly framework for de minimis closures but found the closures justified under Waller v. Georgia due to legitimate concerns for juror safety and deliberative integrity. The Court reversed the convictions in part and affirmed in part, remanding for further proceedings. View "State v. Thornton" on Justia Law

Spiehs v. Morgan

2026-07-21T08:34:09-08:00

A man repeatedly visited the public library in Lawrence, Kansas, where he displayed various signs and flags inside the building. Library staff informed him that these actions violated library policies aimed at maintaining a peaceful environment and, after several incidents in which he refused to comply, staff called the police and temporarily suspended his library privileges. The library’s policies prohibited disruptive behavior and forbade activities—including holding signs, protesting, or similar expressive conduct—inside the library, though expressive clothing and certain other channels for communication remained allowed. He filed suit in the United States District Court for the District of Kansas against city and library officials. He alleged violations of his rights to free speech and equal protection, deprivation of procedural due process, and retaliation for protected speech. The district court granted summary judgment to the defendants on all claims. It concluded that he lacked standing for claims involving policies not applied to him, and that the challenged restrictions were content-neutral, narrowly tailored to a significant governmental interest, and left open alternative channels for expression. The court also found he was not similarly situated to others treated differently and that his due process and retaliation claims failed. On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Tenth Circuit held that the library’s restrictions on signs and similar expressive activities inside were content-neutral, narrowly tailored to maintain a quiet environment for reading and study, and left open ample alternative channels for communication. It further found that the plaintiff lacked standing for certain claims, was not treated differently from similarly situated patrons, and did not engage in constitutionally protected activity supporting a retaliation claim. The grant of summary judgment to the defendants was affirmed. View "Spiehs v. Morgan" on Justia Law

THEIS V. INTERMOUNTAIN EDUCATION SERVICE DISTRICT

2026-07-21T08:33:10-08:00

A licensed clinical social worker employed as an Education Specialist by a regional education service district in Oregon displayed books in his school offices that expressed particular viewpoints on gender identity. These books, visible to students during evaluations and meetings, prompted a complaint alleging that the displays constituted a hostile bias incident under the district’s policy designed to prevent discrimination and address bias in public education settings. The district investigated, concluded that the displays violated its policy, and ordered the employee to remove the books when students were present, warning that failure to comply could result in discipline, including termination. The employee filed a lawsuit in the United States District Court for the District of Oregon alleging violations of his First Amendment free speech rights and sought a preliminary injunction to prevent the district from enforcing its directive. The district court granted the injunction in part, allowing the employee to display the books when students were not present but prohibiting displays during student-facing activities. The court reasoned that, while engaging with students as part of his official duties, the employee spoke as a government employee rather than as a private citizen and therefore was not entitled to First Amendment protection for his displays. After the employee continued to display the books in the presence of students, the district initiated additional proceedings, resulting in his termination. The employee appealed both the partial denial of injunctive relief and the denial of his motion to enforce the injunction. The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decisions. The Ninth Circuit held that the employee’s display of the books while meeting with students in his official capacity was speech as a government employee and not protected by the First Amendment. Because this speech was undertaken pursuant to his professional responsibilities, the court did not apply the Pickering balancing test. The denial of preliminary injunctive relief was found not to be an abuse of discretion. View "THEIS V. INTERMOUNTAIN EDUCATION SERVICE DISTRICT" on Justia Law

USA v. Navarro

2026-07-21T08:02:34-08:00

Peter Navarro, a former senior adviser in the Trump administration, published materials and made public statements in 2021 about a plan to delay the certification of the 2020 presidential election. The U.S. House Select Committee investigating the January 6th Capitol attack subpoenaed Navarro for documents and deposition testimony related to these statements. Navarro refused to comply, asserting executive privilege before even seeing the subpoena and declining to engage with the Committee regarding his privilege claim. After the compliance deadline passed, the House voted to hold him in contempt, and a grand jury indicted him on two counts of contempt of Congress. In the United States District Court for the District of Columbia, Navarro moved to dismiss the indictment, arguing that former President Trump had invoked executive privilege on his behalf. After an evidentiary hearing, the district court found no evidence that Trump or his designee had actually invoked executive privilege in connection with the subpoena and denied the motion to dismiss. The court also granted a government motion to prevent Navarro from arguing at trial that a good-faith belief in executive privilege excused his noncompliance. A jury found Navarro guilty on both counts. The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that only the President or a designated official can invoke executive privilege and that the district court did not clearly err in finding no such invocation occurred for Navarro’s subpoena. The court further held that executive privilege, even if properly invoked, would not have excused Navarro’s blanket refusal to comply, especially regarding his public statements and writings. It also affirmed that a mistaken belief in the applicability of executive privilege is not a defense to contempt of Congress. The appellate court affirmed the district court’s judgment. View "USA v. Navarro" on Justia Law

USA V. COLAR

2026-07-21T08:01:27-08:00

A defendant was charged with 44 federal offenses, including bank fraud, wire fraud, aggravated identity theft, obstruction of official proceedings, and witness tampering, arising from an alleged scheme to defraud the Paycheck Protection Program. The defendant, a Black Muslim man, co-founded a nonprofit for transitional housing and allegedly used stolen identities and fraudulent loan applications for the nonprofit and two shell entities. He represented himself at trial, arguing law enforcement targeted him due to his race and religion. The United States District Court for the Northern District of California presided over the trial. During jury selection, an alternate juror expressed strong negative reactions to the defendant’s defense, stating he could not put aside his personal experiences and doubted his ability to be impartial. Despite the defendant’s request to excuse this juror, the district court deferred its inquiry and allowed the juror to serve as an alternate. When a regular juror was dismissed during trial, the alternate joined the deliberating jury after a brief, belated colloquy in which he claimed to have moved past his initial bias. The defendant objected, arguing the juror remained biased. The jury subsequently convicted the defendant on all counts, and the district court sentenced him to 204 months’ imprisonment. The United States Court of Appeals for the Ninth Circuit reviewed the proceedings and held that the district court abused its discretion by failing to promptly investigate the alternate juror’s bias and by conducting an inadequate inquiry after the juror had heard evidence. The appellate court found that these errors deprived the defendant of his Sixth Amendment right to an impartial jury and constituted structural error. The Ninth Circuit vacated the convictions, reversed the district court’s judgment, and remanded the case for a new trial. View "USA V. COLAR" on Justia Law

SEAGRAVES V. WASHINGTON STATE DEPARTMENT OF CHILDREN YOUTH AND FAMILIES

2026-07-21T08:01:27-08:00

A group of former employees of the Washington Department of Children, Youth, and Families challenged the agency’s implementation of a COVID-19 vaccine mandate issued by the Governor of Washington. After their requests for religious exemptions were granted, the agency denied their requests for reasonable accommodations that would allow them to remain unvaccinated and continue in their positions. The agency explained that, due to the nature of their roles, unvaccinated employees could not safely perform essential functions without posing a risk to others. The employees were ultimately separated from employment. They alleged constitutional violations and state law claims, asserting that the agency and certain officials discriminated against them based on religion and failed to provide required procedural protections. The United States District Court for the Western District of Washington dismissed all claims. It found that the employees had not sufficiently alleged ongoing violations of federal law for injunctive relief, nor had they adequately alleged personal involvement by any official in the claimed constitutional violations. The court dismissed the federal claims and all state law claims, initially granting leave to amend. After the employees filed an amended complaint naming additional officials and asserting similar legal theories without new factual allegations, the district court dismissed the case without leave to amend and denied reconsideration. The United States Court of Appeals for the Ninth Circuit reviewed the dismissal de novo. The court held that the employees failed to plausibly allege personal involvement by any official in constitutional violations, and that official-capacity claims for prospective injunctive relief were barred by the Eleventh Amendment because there was no ongoing violation of federal law. It further concluded that the district court acted within its discretion in denying leave to amend, as amendment would have been futile. The Ninth Circuit affirmed the district court’s dismissal and denial of leave to amend. View "SEAGRAVES V. WASHINGTON STATE DEPARTMENT OF CHILDREN YOUTH AND FAMILIES" on Justia Law

Mahdawi v. Trump

2026-07-21T07:00:03-08:00

The petitioner, a lawful permanent resident originally from the West Bank, lived in Vermont and was pursuing graduate studies at Columbia University. Following his vocal participation in student demonstrations protesting military actions in Gaza, he was arrested at a USCIS facility in April 2025 by Homeland Security agents, who commenced removal proceedings against him. The Notice to Appear cited a determination by the Secretary of State that his presence or activities posed potentially serious adverse foreign policy consequences, referencing his alleged rhetoric and conduct at protests. The government also presented prior allegations related to firearm purchases and drug possession, which the petitioner denied or had resolved. After his arrest, the petitioner’s attorney filed a habeas corpus petition in the United States District Court for the District of Vermont, alleging that the government targeted him for removal based on constitutionally protected speech. The petition sought to invalidate the Secretary of State’s determination, bar removal based on advocacy for Palestinian rights, and obtain his release. The district court granted his release pending review of the petition, finding a likelihood of success on the First Amendment claim and determining it had jurisdiction despite statutory provisions that restrict judicial review in immigration matters. The United States Court of Appeals for the Second Circuit reviewed the appeal. Applying a de novo standard for subject matter jurisdiction, the court concluded that 8 U.S.C. § 1252(b)(9) channels judicial review of questions arising from removal actions to the administrative process and ultimately to a petition for review of a final order of removal in the circuit courts. The court held that the district court lacked jurisdiction to entertain the habeas petition because the petitioner’s claims were intertwined with the removal proceedings. The court vacated the district court’s release order and remanded with instructions to dismiss the habeas petition for lack of jurisdiction. View "Mahdawi v. Trump" on Justia Law

Commonwealth v. Shivers

2026-07-21T06:13:12-08:00

The case involves a police encounter at a gas station in Philadelphia, which was known as a base for the Ozone Gang, a group associated with gun violence and drug activity. Officers arrived in an unmarked car and approached Phillip Shivers, who was seated near known gang members. Upon seeing the officers, Shivers fled, and police pursued and apprehended him, finding a loaded firearm in his possession. Shivers was charged with multiple firearm and related offenses. After a preliminary hearing, the case was set for trial in the Court of Common Pleas of Philadelphia County. Shivers filed motions to suppress the physical evidence and to compel the Commonwealth to produce objective evidence that the area was indeed a high-crime area. At the suppression hearing, Shivers argued the police lacked reasonable suspicion or probable cause to detain him, but did not specifically argue that Pennsylvania’s Constitution provided greater protection than federal law on this issue. The trial court denied suppression, finding Shivers’s unprovoked flight in a high-crime area gave officers reasonable suspicion, and subsequently convicted him on all charges. Shivers appealed, arguing the “high-crime area” factor should not suffice for reasonable suspicion under Article I, Section 8 of the Pennsylvania Constitution. The Superior Court affirmed the conviction, holding it was bound by prior precedent equating the state and federal constitutional standards in stop-and-frisk cases. On further appeal, the Supreme Court of Pennsylvania reviewed whether Shivers properly preserved his “departure claim”—that Article I, Section 8 should offer greater protection than the Fourth Amendment. The Court held that Shivers had not adequately preserved this claim in the trial court because he failed to provide any analysis or reasons for departure from federal law, as required by Commonwealth v. Bishop. The Court affirmed the Superior Court’s decision, holding the departure claim was waived. View "Commonwealth v. Shivers" on Justia Law

Punxsutawney Hunting Club v. PGC

2026-07-21T04:49:55-08:00

Two private hunting clubs, each owning substantial contiguous acreage in rural Pennsylvania, sought to maintain privacy over their lands, which are used by members and guests for hunting and other recreational activities. The clubs posted “no trespassing” signs, marked boundaries with purple paint, installed gates, and in some areas, fenced their properties. Despite these efforts to exclude non-members, officers from the Pennsylvania Game Commission repeatedly entered the clubs’ land without consent, a warrant, or probable cause, sometimes installing trail cameras and issuing citations for alleged hunting violations. The clubs argued that such warrantless searches violated their constitutional rights. The clubs filed a petition for declaratory and injunctive relief in the Commonwealth Court of Pennsylvania, naming the Game Commission and a game warden as respondents. They challenged specific provisions of the Game and Wildlife Code that authorize warrantless entry onto private land outside buildings and curtilage. The Commonwealth Court, sitting en banc, granted summary relief for the Commission and denied relief to the clubs, reasoning that it was bound by the Pennsylvania Supreme Court’s prior decision in Commonwealth v. Russo, which held that Article I, Section 8 of the Pennsylvania Constitution does not extend privacy protections to open fields. On appeal, the Supreme Court of Pennsylvania reviewed its precedent in Russo and conducted an independent constitutional analysis. The court overruled Russo, holding that Article I, Section 8 of the Pennsylvania Constitution provides more robust protection than the Fourth Amendment regarding open fields. Specifically, the court determined that landowners who take sufficient steps to exclude intruders—such as posting signs, fencing, or gating—have a reasonable expectation of privacy in their open fields. As a result, the Game Commission’s statutory authority to enter posted private land without a warrant was struck down as unconstitutional, and the Commonwealth Court’s order was reversed. View "Punxsutawney Hunting Club v. PGC" on Justia Law

US v. Ellis

2026-07-20T10:31:40-08:00

The case involves Tamarcus Ellis, who was tried and convicted for conspiracy to traffic methamphetamine and actual drug trafficking in Greensboro, North Carolina. During his four-day trial in federal court, a government witness, Malcolm Russell, appeared intimidated while testifying. The U.S. Marshals Service reported that individuals in the gallery were making audible noises and gestures perceived as signaling disagreement with Russell’s testimony. Based on this, the district court partially closed the courtroom for approximately one hour during Russell’s testimony, excluding most members of the public but allowing Ellis’ family and defense counsel’s family to remain. After Ellis was convicted and sentenced to 480 months’ imprisonment by the United States District Court for the Eastern District of North Carolina, he appealed. Ellis argued that the partial closure violated his Sixth Amendment right to a public trial, asserting this was structural error requiring automatic reversal and a new trial. The United States Court of Appeals for the Fourth Circuit reviewed the appeal. The court acknowledged that the closure was not trivial and implicated the Sixth Amendment’s Public Trial Clause. It applied the modified Waller test for partial courtroom closures, which requires a “substantial reason” for the closure, that the closure be no broader than necessary, consideration of reasonable alternatives, and adequate findings by the trial court. The Fourth Circuit found that the district court had a substantial reason to partially close the courtroom to prevent witness intimidation, tailored the closure appropriately, considered alternatives, and made sufficient findings on the record. Therefore, the Fourth Circuit held that the partial closure did not violate Ellis’ Sixth Amendment right to a public trial and affirmed the district court’s judgment. View "US v. Ellis" on Justia Law

Shuler v. State

2026-07-20T05:07:44-08:00

Two individuals were found shot and killed in a car in Baltimore City after a planned marijuana sale. The investigation led police to Montay D. Shuler, who was observed near the scene, arrested, and interrogated. During a custodial interview, after being advised of his Miranda rights, Mr. Shuler denied involvement in the shooting. At trial, Mr. Shuler testified, admitting that he shot both victims but claimed self-defense. The State introduced his prior custodial statement, in which he denied involvement, for the purpose of impeaching his trial testimony. Mr. Shuler was tried in the Circuit Court for Baltimore City. The jury acquitted him of first- and second-degree murder but convicted him of voluntary manslaughter and several related offenses. Mr. Shuler requested a jury instruction requiring the jury to find his custodial statement voluntary before considering it. The trial court denied this request, reasoning there was no evidence the statement was involuntary. On appeal, the Appellate Court of Maryland affirmed, holding that no voluntariness instruction was required because the statement was only used for impeachment, was exculpatory, and there was no evidence of involuntariness. The Supreme Court of Maryland reviewed the case. It held that the trial court was not required to give the requested voluntariness instruction because Mr. Shuler did not present “some evidence” that his custodial statement was involuntary under either Maryland common law or constitutional standards. The Court clarified that the right to a voluntariness instruction is not limited to inculpatory statements or those offered in the State’s case-in-chief but must be generated by evidence of involuntariness. Even assuming error in failing to give the instruction, the Supreme Court of Maryland held the error was harmless beyond a reasonable doubt given the weight of the evidence and the jury’s verdict. The judgment of the Appellate Court was affirmed. View "Shuler v. State" on Justia Law

Commonwealth v. Dobson

2026-07-20T04:07:45-08:00

Police stopped a vehicle driven by the defendant for a window tint infraction in Boston. During the stop, officers observed the passenger making a suspicious motion toward the glove compartment. After ordering both occupants out of the car and conducting pat frisks, police discovered the glove compartment was locked and repeatedly requested the defendant provide the car key, which she refused. Officers attempted to handcuff her, leading to a brief physical struggle. Believing she had hidden the key on her person, officers conducted multiple searches, including two by female officers, but did not find the key. After a police dog indicated the presence of a firearm in the glove compartment, officers continued to urge the defendant to surrender the key, warning of potential damage to her car if they towed and searched it without the key. The defendant then handed over the key, and officers found a firearm and pills in the glove compartment. In the Superior Court, the defendant moved to suppress the evidence from the glove compartment, arguing it was the fruit of unlawful searches of her person. The judge found that while the initial stop, exit orders, and patfrisk were lawful, the subsequent more intrusive searches violated the defendant’s constitutional rights because they were not justified by officer safety concerns. However, the judge denied the motion, concluding the defendant had voluntarily consented to the search of the glove compartment by providing the key, and that the consent was sufficiently attenuated from the unlawful searches. The Supreme Judicial Court of Massachusetts reviewed the denial of the motion to suppress. It held that the searches of the defendant’s person were unlawful because they were conducted for an investigatory purpose unrelated to her arrest, violating statutory and constitutional protections. The Court further concluded that the defendant’s consent to search the glove compartment, given immediately following the unlawful and coercive searches, was not sufficiently attenuated from the misconduct and therefore was not valid. The order denying the motion to suppress was reversed. View "Commonwealth v. Dobson" on Justia Law

Jefferson Parish Firefighters Association, Local 1374 v. Roberts

2026-07-17T15:30:30-08:00

A fire captain who served as vice president of a local firefighters’ union was also a member of the Jefferson Parish Fire Civil Service Board. The union previously paid for legal counsel for members appearing before the Civil Service Board, but stopped doing so after the Louisiana Board of Ethics issued an advisory opinion, and later a binding declaratory opinion, stating that such payments violated Louisiana law while any union officer served on the board. The union challenged the Board of Ethics’ interpretation in state court, arguing that it misapplied state law, and then filed a federal lawsuit claiming this restriction violated its First Amendment rights. The United States District Court for the Eastern District of Louisiana granted the union a preliminary injunction on First Amendment grounds, preventing enforcement of the ethics board’s opinion against the union. The district court also declined to abstain under the doctrines established in Younger v. Harris and Railroad Commission of Texas v. Pullman Co. The Louisiana defendants appealed, arguing the district court should have abstained and that granting the injunction was an abuse of discretion. While the appeal was pending, all relevant state court proceedings concluded, and, just before oral argument, the fire captain resigned from the Civil Service Board. The United States Court of Appeals for the Fifth Circuit found that the case was moot due to the resignation, as neither party retained a legally cognizable interest in the outcome. The court determined that no live controversy remained, rejected arguments that mootness exceptions applied, and ruled that the appeal and the entire case must be dismissed for lack of jurisdiction. The court vacated the preliminary injunction and remanded to the district court with instructions to dismiss the case. View "Jefferson Parish Firefighters Association, Local 1374 v. Roberts" on Justia Law

Wood v. Straughn

2026-07-17T11:00:41-08:00

A West Virginia defendant was indicted in 2018 on multiple sexual offense charges involving a seven-year-old girl. Prior to trial, the court granted the defendant’s motions to exclude a video interview of the victim and records from her therapy sessions, limiting both the State and the defense from introducing certain hearsay evidence. During opening statements at the first trial, defense counsel referenced specific statements made by the victim in the excluded materials, suggesting an alternative perpetrator. The State objected after the opening statements, arguing that the defense had violated pretrial evidentiary rulings. The trial court found that the defense’s actions had gone “far afield” of its orders and, over the defendant’s objection, granted the State’s motion for a mistrial. The defendant moved to dismiss the indictment on double jeopardy grounds, arguing that the mistrial was not required by “manifest necessity.” The trial court denied the motion, finding that the defense had created the necessity for a mistrial. The Supreme Court of Appeals of West Virginia later affirmed, holding that the defendant’s right against double jeopardy was not violated because defense counsel’s conduct in opening statement created a manifest necessity for the mistrial. The defendant subsequently filed a federal habeas petition in the United States District Court for the Northern District of West Virginia, which granted relief, concluding that the defense had not violated any pretrial orders and that manifest necessity was lacking. On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court’s judgment. The Fourth Circuit held that, under the highly deferential standard of review required by AEDPA, the state court’s conclusion that manifest necessity justified the mistrial was neither contrary to nor an unreasonable application of clearly established Supreme Court precedent. The case was remanded with instructions to deny the habeas petition. View "Wood v. Straughn" on Justia Law

Association of New Jersey Rifle and Pistol Clubs I v. Attorney General

2026-07-17T10:00:13-08:00

New Jersey enacted laws that ban the possession of so-called “assault firearms”—including a list of over thirty models and types of semi-automatic rifles, such as the AR-15, and any firearm “substantially identical” to those listed—as well as laws restricting possession of “large capacity ammunition magazines” (LCMs), defined as magazines holding more than ten rounds. The statutes contain narrow exemptions, mostly for military, police, and certain target-shooting purposes, but in practice, they amount to a near-total prohibition on civilian possession of these weapons and magazines. Gun owners and advocacy groups challenged both sets of laws under the Second Amendment, and one group also raised a Takings Clause claim after New Jersey amended the LCM law in 2018 to further reduce the permitted capacity. The United States District Court for the District of New Jersey consolidated three related lawsuits and ruled on cross-motions for summary judgment. The District Court found New Jersey’s ban on the Colt AR-15 unconstitutional under the Second Amendment but upheld the LCM restrictions and rejected the Takings Clause challenge. The plaintiffs and the State appealed. The United States Court of Appeals for the Third Circuit, sitting en banc, applied the Supreme Court’s Second Amendment framework from New York State Rifle & Pistol Association v. Bruen and related cases. The Third Circuit held that the Second Amendment protects possession of semi-automatic rifles and large-capacity magazines, as both are “in common use for lawful purposes.” The court concluded New Jersey’s ban on semi-automatic rifles and its LCM restrictions are inconsistent with the Nation’s tradition of firearm regulation and thus violate the Second Amendment. The court modified the District Court’s order to invalidate the ban as to all semi-automatic rifles, reversed the ruling upholding the LCM provisions, and remanded for further proceedings, including as to other weapons regulated by the statutes. View "Association of New Jersey Rifle and Pistol Clubs I v. Attorney General" on Justia Law

Manutsom v. Town of Hollis

2026-07-17T05:10:42-08:00

A property in Hollis was owned by a trust with Wisarat Manutsom as trustee. The trustee, often traveling abroad, provided various mailing addresses—including in California, Manchester (New Hampshire), and later Maine—as well as an email address, to the town for tax-related correspondence. Mark Copp was authorized to act for the trust and provided his Manchester address. Over several years, the town sent multiple certified mail notices regarding unpaid property taxes and impending tax liens and deeds to these addresses; some were signed for and received, but several were returned as undeliverable. The town also communicated about the delinquent taxes by email. In 2019, after more undelivered certified mailings and no payment for 2016 taxes, the town executed a tax deed transferring ownership to itself, then sent post-deed notices by regular mail and, years later, by certified mail and email. The plaintiff sued in the Superior Court, alleging the town’s notice regarding the 2016 and 2018 tax liens and the 2016 tax deed was constitutionally deficient under the Fourteenth Amendment. The Superior Court granted summary judgment to the town, finding the notice sufficient. The plaintiff's motion for reconsideration was denied, and she appealed. The Supreme Court of New Hampshire reviewed the case de novo. It held that the town’s failure to take additional reasonable steps—such as emailing notice—after certified notices of the impending 2016 tax deed were returned undelivered, and before executing the deed, violated the plaintiff’s due process rights. The court also found the town’s notice of the 2016 tax lien insufficient because it relied on an address that had repeatedly failed. However, notice of the 2018 tax lien, sent to both Manchester and Maine addresses, was deemed sufficient. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Manutsom v. Town of Hollis" on Justia Law

Inendino v Nance-Holt

2026-07-16T09:01:22-08:00

A firefighter with sixteen years of service in the Chicago Fire Department (“CFD”) was terminated after an investigation revealed that he had posted racially offensive and derogatory content on his public Facebook account. He openly identified himself as a CFD firefighter on his page, which included photos in uniform, and his posts targeted Black and Asian Americans, groups served by the CFD. The posts prompted complaints from members of the public, leading to an Office of Inspector General investigation. The investigation concluded that the firefighter’s posts undermined public trust and recommended his dismissal, which the Fire Commissioner approved. The firefighter unsuccessfully challenged his termination through arbitration. He then sued the City of Chicago and two CFD officials in the United States District Court for the Northern District of Illinois, Eastern Division, alleging his termination violated his First Amendment rights and challenging the City’s social media policy as unconstitutionally vague and overbroad. The district court granted summary judgment for the City, holding that the firefighter’s posts were not protected by the First Amendment because they did not address matters of public concern. Alternatively, the court found that, even if the posts did touch on public concern, the City’s interest in departmental efficiency and maintaining public trust outweighed his free speech interests. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that the district court erred in its analysis of public concern, concluding that the posts could be seen as addressing matters of public concern. However, applying the Pickering balancing test, the appellate court held that the City’s interests in preserving public trust, especially given the firefighter’s public identification with the CFD and the nature of his posts, outweighed his speech interests. The court affirmed summary judgment in favor of the City. View "Inendino v Nance-Holt" on Justia Law

Barros v. State of Rhode Island

2026-07-16T07:38:35-08:00

Two men, Jamal Cruz and Rokiem Henley, attended a nightclub in Providence with friends. After the club closed, Cruz had a brief verbal disagreement with two other men, including Terrel Barros and Stephen Bodden. As Cruz and Henley were leaving, Bodden confronted Cruz outside, followed by gunshots that injured Henley and fatally wounded Cruz. Police officers nearby responded quickly, saw Bodden and Barros get into a car, and arrested both men. Barros was subsequently charged and convicted of first-degree murder and several related offenses, largely based on Cruz’s dying identification, eyewitness testimony, and evidence presented at trial. Following his conviction, Barros filed an application for postconviction relief in the Rhode Island Superior Court, alleging several constitutional violations, actual innocence, and the existence of newly discovered evidence. During the postconviction hearing, Barros introduced testimony from Gloria Parajon, Bodden’s cousin, who stated that Bodden had privately confessed to her, on multiple occasions, that he was the shooter. The hearing justice found Parajon’s testimony to be newly discovered, credible, and not merely cumulative, and concluded it could change the verdict at a new trial. The Superior Court granted Barros’s application for postconviction relief and vacated his conviction. On review, the Supreme Court of Rhode Island determined that the Superior Court did not err in admitting Parajon’s testimony as a statement against penal interest under Rule 804(b)(3) of the Rhode Island Rules of Evidence, and that her statements were sufficiently corroborated. The Supreme Court affirmed the judgment of the Superior Court, holding that Barros was entitled to postconviction relief based on newly discovered evidence, and remanded the case for further proceedings. View "Barros v. State of Rhode Island" on Justia Law

Johnson v. State of Florida

2026-07-16T07:05:22-08:00

A seventeen-year-old individual planned and carried out a violent attack resulting in the death of one person and serious injuries to two others. After purchasing a knife, he attended a dinner and sleepover with friends. Late at night, he attacked and fatally stabbed one victim, then proceeded to injure two others. The police apprehended him at the scene. He was charged with first-degree murder and two counts of attempted first-degree murder. The jury convicted him on all counts. Because he was a juvenile at the time, a separate sentencing hearing was held to consider mitigating factors under Florida law. The Circuit Court for Palm Beach County sentenced him to life without parole (LWOP) for each count, with the two attempted murder sentences running concurrently but consecutively to the murder sentence. The court announced that he would be eligible for judicial review after serving 25 years on the murder conviction, and again after serving another 25 years on the consecutive sentences for attempted murder. The defendant challenged his sentence, arguing that consecutive LWOP sentences for offenses committed in a single episode violated the Eighth Amendment, relying on Graham v. Florida. The Circuit Court denied relief, and on direct appeal, the Fourth District Court of Appeal upheld the sentences, holding that the structure provided a meaningful opportunity for release consistent with constitutional requirements. The Fourth District certified conflict with the Second District Court of Appeal’s decision in Mack v. State, which had found such consecutive sentences unconstitutional. The Supreme Court of Florida reviewed the case and held that the Eighth Amendment’s requirement of a “meaningful opportunity for release” from Graham v. Florida does not apply to juveniles convicted of homicide offenses. Instead, sentencing for juvenile homicide offenders is governed by Miller v. Alabama and Jones v. Mississippi, requiring individualized sentencing but permitting discretionary LWOP. The Court approved the Fourth District’s result, disapproved Mack, and upheld the sentences. View "Johnson v. State of Florida" on Justia Law

Doby v. United States

2026-07-16T06:33:19-08:00

Late one night, three police officers responding to a report of a recent nearby shooting observed a man walking on the street. The man appeared to have an L-shaped bulge in his right jacket pocket, which the officers believed could be a firearm. When the officers pulled their marked cruiser alongside him and asked if he had a gun, the man did not respond and instead fled on foot, clutching and “fiddling” with his pocket as he ran. After a brief pursuit, he surrendered, and officers conducted a pat-down, discovering a handgun in his jacket pocket. Before trial in the Superior Court of the District of Columbia, the defendant moved to suppress the gun, arguing that it was found as a result of an unlawful seizure and search in violation of the Fourth Amendment. The trial court denied the suppression motion, finding that the officers did not seize the defendant until after his flight and that, at that point, they had reasonable articulable suspicion to stop and frisk him based on his behavior, the observed bulge, his flight, and actions during the pursuit. The court then found the defendant guilty of unlawful possession of a firearm and related charges following a stipulated trial. On appeal, the defendant limited his argument to whether the officers had reasonable articulable suspicion to stop and frisk him when he surrendered. The District of Columbia Court of Appeals concluded that, considering the totality of the circumstances—including the recent shooting in the area, the observed bulge consistent with a firearm, the defendant’s apparent panic and evasive behavior, his flight, and his actions while fleeing—officers had reasonable articulable suspicion to justify the stop and frisk. The court affirmed the convictions, finding no Fourth Amendment violation. View "Doby v. United States" on Justia Law

USA v. Allred

2026-07-15T15:30:30-08:00

The defendant was convicted in Texas state court in 2004 for assault causing bodily injury to a family member, which qualifies as a misdemeanor crime of domestic violence under Texas law. The incident involved the defendant pushing his wife during an argument and, when she attempted to call 911, striking her in the face while trying to knock the phone from her hand. Based on this conviction, he was later indicted under 18 U.S.C. § 922(g)(9) for possessing a firearm after being convicted of a misdemeanor crime of domestic violence. Before the United States District Court for the Western District of Texas, the defendant moved to dismiss the indictment, raising two constitutional challenges: that the statute exceeds Congress’s power under the Commerce Clause, and that, as applied to him, it violates the Second Amendment. The district court denied the motion. The defendant then entered a conditional guilty plea, reserving the right to appeal the denial of his motion to dismiss, and was sentenced to imprisonment and supervised release. The United States Court of Appeals for the Fifth Circuit reviewed the case. It rejected the Commerce Clause challenge, extending the reasoning from United States v. Alcantar to § 922(g)(9). The court then addressed the as-applied Second Amendment challenge, applying the historical tradition test articulated in New York State Rifle & Pistol Ass’n v. Bruen and clarified in United States v. Rahimi. The Fifth Circuit concluded that § 922(g)(9), as applied to the defendant, is consistent with the nation’s historical tradition of disarming individuals found to threaten the physical safety of others. The court found that the statute’s rationale and burden are supported by historical analogues and that the defendant’s conduct was sufficiently dangerous to warrant disarmament. The judgment of the district court was affirmed. View "USA v. Allred" on Justia Law

Granillo v. State

2026-07-15T13:04:08-08:00

The case concerns a man accused of kidnapping and sexually assaulting a woman in Maui in 1989. The prosecution’s case relied heavily on circumstantial evidence and expert testimony from an FBI agent, who analyzed hair and fiber samples. The expert testified that hair found in the defendant’s car was “consistent with” originating from the complainant, and that fibers found on her clothing were “consistent with” coming from the car’s seat cover and carpet. The defense challenged the complainant’s credibility but did not contest the expert testimony. The jury convicted the defendant, and he was sentenced to forty years. Nearly thirty years later, a letter from the Department of Justice revealed that the expert’s testimony about hair analysis overstated the science and was invalid. The defense then argued that both the hair and fiber testimony should be deemed unreliable based on scientific developments. The Circuit Court of the Second Circuit held a hearing and found that the hair analysis testimony exceeded the bounds of science but ruled the error harmless beyond a reasonable doubt due to other corroborative evidence. The court did not rule on fiber analysis. The Intermediate Court of Appeals (ICA) affirmed the denial of post-conviction relief, applying the State v. McNulty “newly discovered evidence” test. The ICA found that the fiber testimony was not impeached by the DOJ letter and considered the hair evidence cumulative, so it declined to address whether the new evidence would probably change the result at retrial. The Supreme Court of Hawai‘i reviewed the case and held that when scientific advances later invalidate expert testimony presented at trial, the “false evidence” standard applies, not the “newly discovered evidence” standard. The court found both the hair and fiber testimony materially false, took judicial notice of landmark scientific reports, and concluded there was a reasonable possibility the false evidence contributed to the conviction. The defendant’s due process rights were violated, and the court vacated the lower courts’ decisions, remanding for a new trial. View "Granillo v. State" on Justia Law

Muradyan v. Bonta

2026-07-15T13:02:58-08:00

In 2009, the appellant was convicted of violating California Penal Code section 288.4, subdivision (b), for arranging and attending a meeting with a minor with the intent to commit a sexual offense. The sentencing court imposed felony probation, jail time, and required him to register as a sex offender. In 2024, the appellant sought removal from the sex offender registry, arguing that the statutory scheme’s classification—placing his offense in tier three, which requires lifetime registration—violated his constitutional rights to equal protection. He contended there was no rational basis for imposing lifetime registration for his offense when other, allegedly more serious offenses, such as lewd acts under section 288, subdivision (a), did not require lifetime registration. The Superior Court of Los Angeles County reviewed the writ petition and denied relief. The court found that the Legislature could rationally distinguish between the appellant’s offense, characterized as a predatory “child luring” crime involving planning and a demonstrated unnatural interest in children, and the offenses he cited for comparison. The court explained that the statutory scheme was motivated by a legitimate governmental purpose: managing the risk of recidivism among offenders deemed most likely to reoffend and protecting public safety. The California Court of Appeal, Second Appellate District, Division Three, affirmed the lower court’s order. The appellate court held that under rational basis review, the Legislature had a conceivable and legitimate reason for classifying section 288.4, subdivision (b), offenses as warranting lifetime registration. The court emphasized that equal protection is not violated when the Legislature draws distinctions based on plausible risk assessments and societal interests, even if some other offenses are not treated identically. The appellate court concluded that the statutory classification survived constitutional scrutiny and awarded costs on appeal to the respondent. View "Muradyan v. Bonta" on Justia Law

Jonah B. v. State

2026-07-15T09:31:32-08:00

A father’s three children were taken into emergency custody by the Alaska Office of Children’s Services (OCS) in 2019 while he was incarcerated in another state. After his release, OCS worked with him but ultimately petitioned to terminate his parental rights, primarily due to the length of his incarceration and concerns about his progress toward reunification. In January 2023, a superior court terminated the parental rights of both parents. The following July, one child, Serena, was adopted by her foster family, and the court closed her child in need of aid (CINA) case, releasing her into her adoptive parents’ custody. The father appealed the termination of his parental rights. In December 2023, the Supreme Court of the State of Alaska reversed the termination order, finding OCS had not made reasonable efforts to reunify the family. On remand, the superior court reopened Serena’s CINA case but left her in the adoptive parents’ custody. The father was appointed counsel in the adoption case. However, more than one year after the adoption decree, the CINA case was declared moot at the request of the guardian ad litem, who cited Alaska’s statutory one-year limit on challenging adoption decrees. The father argued that the one-year bar did not apply because the adoptive parents had not “taken custody” of Serena and that his due process and right to effective counsel were violated. The Supreme Court of the State of Alaska affirmed the dismissal of the CINA case as moot. It held that the one-year statutory bar to challenging adoptions applied because Serena’s adoptive parents had taken custody. The court found no due process violation, as the father had notice, counsel, and opportunity to be heard, and rejected his ineffective assistance of counsel claim, finding no constitutional deficiencies. View "Jonah B. v. State" on Justia Law

State v. Moronta

2026-07-15T07:51:44-08:00

Police investigating suspected drug trafficking received information from a confidential informant about two individuals selling drugs. Surveillance linked the suspects to multiple addresses. The investigation included controlled drug buys and installation of a pole camera outside an apartment building. On April 4, 2023, the informant reported a possible deceased person inside one of the apartments. Surveillance footage showed the suspects and another individual entering and exiting the building. Police detained the suspects at a traffic stop and seized keys. Officers then entered the apartment building without a warrant, finding a deceased person in the second-floor apartment and, upon entering the third-floor apartment, discovering drug paraphernalia and contraband. The Providence County Superior Court held a hearing on the defendant’s motion to suppress evidence obtained during the warrantless search and seizure. The trial justice denied the motion, concluding that the police were responding to a sudden emergency involving a possible death and acted rationally to protect citizens from harm and prevent destruction of property. The defendant was subsequently found guilty on all charges following a bench trial and sentenced to twenty-five years, with twenty years to serve and five years suspended. The defendant appealed. The Supreme Court of Rhode Island reviewed the denial of the motion to suppress under the Fourth Amendment and article 1, section 6 of the Rhode Island Constitution, applying the totality of the circumstances standard and deferring to factual findings unless clearly erroneous. The Court held that police had no constitutionally permissible reason to enter the third-floor apartment after finding the deceased in the second-floor apartment and that the exigency justifying entry had evaporated. The Court concluded that the error was not harmless, vacated the conviction, and remanded for a new trial. View "State v. Moronta" on Justia Law

People Of Michigan v. Fenderson

2026-07-15T05:00:02-08:00

The defendant was arrested in connection with a fatal shooting and, following his arrest, was given Miranda warnings. Police initially did not interrogate him because they believed he was intoxicated. The next day, during a videorecorded interrogation, the defendant waived his rights but later invoked his right to counsel, stating he needed appointed counsel. Police then left, purportedly to locate an attorney, but after more than two hours returned and informed the defendant that no attorney was available and he did not have the money to hire one. The defendant expressed confusion and asked clarifying questions. Police indicated that unless the defendant agreed to speak without an attorney, they could not discuss the case further. The defendant ultimately agreed to speak without counsel, was given Miranda warnings again, and made incriminating statements. The Wayne Circuit Court, after reviewing the interrogation video, granted the defendant’s motion to suppress the statements. The court found that police communications had frustrated the required Miranda advice by suggesting that the defendant’s right to counsel depended on his ability to pay, thereby undermining his rights. The trial court also found that police had reinitiated interrogation after the defendant invoked his right to counsel. The Michigan Court of Appeals reversed the suppression order, holding that the defendant’s waiver was voluntary, knowing, and intelligent, and that police had not violated his constitutional rights. The defendant sought further review. The Michigan Supreme Court held that the defendant’s Fifth Amendment rights under Miranda were violated. The Court found that police undermined the required advice of rights by suggesting that the right to counsel depended on the defendant’s ability to pay and that the prosecution failed to show the defendant reinitiated the interrogation. The Court reversed the Court of Appeals’ judgment and remanded for further proceedings, ordering suppression of the defendant’s post-invocation statements. View "People Of Michigan v. Fenderson" on Justia Law

Adames-Garcia v. Divris

2026-07-14T13:30:03-08:00

A state prisoner challenged the denial of his federal habeas corpus petition after being convicted of several charges, including aggravated rape, in Massachusetts. The prosecution’s case was based on the victim’s testimony, physical evidence, and expert and witness accounts, while the defendant claimed the sexual encounter was consensual. During jury deliberations, seven not-guilty verdicts were returned on some charges, but deliberations continued on the remaining counts. After the weekend recess, a Facebook post by a former police officer urged community members to attend the next court session to support the victim, and a small demonstration took place at the courthouse with attendees wearing teal ribbons. The defense raised concerns about potential juror exposure to these influences, but the judge declined an individual juror inquiry, instead asking general questions about their ability to continue serving. Following conviction, the defense contacted jurors, and one juror reported seeing the Facebook post, being aware of the demonstration, and claimed that these factors led to greater weight being given to the victim’s testimony on the last day of deliberations. The trial court held an evidentiary hearing, found that some jurors were aware of the post and demonstration, but concluded that exposure was brief, not discussed during deliberations, and not prejudicial. The trial court specifically discredited the juror’s account of actual prejudice. The Massachusetts Appeals Court affirmed, and the Supreme Judicial Court declined review. In federal habeas proceedings, the U.S. District Court for the District of Massachusetts denied relief, holding that the state court’s examination of extraneous influence claims met federal constitutional standards and that its factual findings were owed deference. The United States Court of Appeals for the First Circuit affirmed, holding that the state court’s decision was neither contrary to nor an unreasonable application of clearly established Supreme Court precedent, and that its factual determinations were reasonable. The denial of habeas relief was affirmed. View "Adames-Garcia v. Divris" on Justia Law

Burey v. Blanche

2026-07-14T11:00:38-08:00

A Jamaican citizen who entered the United States on a work visa married a U.S. citizen and later experienced domestic violence from his spouse, who was eventually arrested. After his visa expired, removal proceedings were initiated, and an immigration judge ordered his removal. Under the Violence Against Women Act (VAWA), survivors of domestic violence have a one-year deadline to file a motion to reopen removal proceedings. On the last day of this period, the petitioner’s counsel attempted to file the motion electronically, but the system rejected it. When he tried to file in person, a court clerk refused to accept the paper copy, insisting it be filed electronically. After continued unsuccessful attempts, the motion was finally mailed and accepted, but after the deadline. The Immigration Judge denied the motion to reopen, finding it untimely and concluding that the petitioner did not provide sufficient proof he was prevented from timely filing. The Board of Immigration Appeals (BIA) affirmed, with the majority agreeing that the record did not support the claim of impeded filing and that no exception to the deadline applied. One BIA member dissented, noting clear evidence of repeated filing attempts thwarted by the court. The United States Court of Appeals for the Fourth Circuit reviewed both the Immigration Judge and BIA decisions. Applying de novo review to legal and constitutional questions and substantial evidence review to factual findings, the Fourth Circuit held that the record compelled the conclusion that the petitioner was prevented from timely filing. The court found this defect rendered the proceedings fundamentally unfair and prejudiced the petitioner’s case, thus violating his Fifth Amendment due process rights. The court granted the petition for review, reversed the BIA’s denial, and remanded for further proceedings. View "Burey v. Blanche" on Justia Law

P. v. Miranda

2026-07-13T14:33:33-08:00

The case involves an individual who broke the windows of a parked vehicle at a grocery store in Monrovia and entered the driver’s seat. The owner of the vehicle had kept a long knife under the seat for protection. After fleeing the scene, the individual was observed by police carrying a scooter, complied initially with commands, but then removed a knife from his waistband, dropped it, and ran before eventually being apprehended. The knife was 14 inches long with an eight-inch blade. Following these events, the Los Angeles County Superior Court charged the individual with felony vandalism and carrying a concealed dirk or dagger, with additional allegations regarding the amount of property damage and prior criminal conduct. A jury found the individual guilty on both counts and found true the allegation of damages exceeding $400. The court dismissed certain sentencing allegations and imposed a total sentence of two years in county jail. The defendant filed a timely appeal challenging both the constitutionality of California Penal Code section 21310, which prohibits carrying a concealed dirk or dagger, and the sentencing decision. The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. The court held that Penal Code section 21310 is constitutional under the Second Amendment. Applying the framework set out in New York State Rifle & Pistol Association, Inc. v. Bruen, the court found that bans on carrying concealed dirks or daggers are consistent with the nation’s historical tradition of arms regulation. The court also determined that the defendant forfeited his sentencing challenge by failing to object at the time of sentencing, in accordance with California procedural law. The judgment of the Superior Court was affirmed. View "P. v. Miranda" on Justia Law

US v. Cardozo

2026-07-13T10:30:28-08:00

A traveler arriving in the United States from Bolivia was subject to inspection by U.S. Customs and Border Protection at Washington Dulles International Airport. The officer requested that the traveler unlock his two iPhones, which he did. Within approximately two minutes, the officer accessed the photo galleries, including hidden folders, and discovered sexually explicit images of prepubescent girls. The traveler was subsequently arrested and indicted by a federal grand jury in the United States District Court for the Eastern District of Virginia on multiple counts relating to child pornography. The defendant moved to suppress the evidence obtained from the search of his phones, arguing that the search violated the Fourth Amendment. The district court held an evidentiary hearing, during which the officer explained her suspicions. The court denied the motion to suppress, finding that either individualized suspicion was present or, alternatively, that the officer acted in good faith. The defendant entered a conditional guilty plea to all counts, preserving his right to appeal the suppression ruling. He was sentenced to 18 years in prison and 25 years of supervised release. On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether manual searches of cell phones at the border are “routine” and thus exempt from the requirement of individualized suspicion under the Fourth Amendment. The Fourth Circuit held that manual searches of cell phones at the border are routine border searches and do not require individualized suspicion, distinguishing such searches from forensic searches, which are nonroutine and require some level of individualized suspicion. The court affirmed the district court’s denial of the motion to suppress. View "US v. Cardozo" on Justia Law

State v. Morgan

2026-07-13T08:39:41-08:00

Late at night, a police officer was dispatched to a Rio Rancho cul-de-sac after a report of a fight, with someone allegedly dragged through the street, and a party ongoing all day at a house. Upon arrival, the officer observed a loud argument between a man and a woman, with the man being restrained by another individual. The officer approached the group, did not announce himself, and instructed the man to stay. Instead, the man and his friend fled, prompting the officer to chase and seize the man by grabbing his wrist. A struggle ensued, resulting in the officer being assaulted and held down until backup arrived. The defendant was indicted in the District Court for aggravated battery upon a peace officer, false imprisonment, and criminal damage to property. He moved to suppress evidence of crimes committed after the seizure, arguing the officer lacked reasonable suspicion and failed to announce himself. The District Court found no reasonable suspicion, suppressed evidence of subsequent crimes, and dismissed the case. On appeal, the New Mexico Court of Appeals reversed, holding the new crime exception applied, making evidence of subsequent crimes admissible, and declined to address reasonable suspicion. The Supreme Court of the State of New Mexico reviewed the case, applying a de novo standard to the reasonable suspicion issue. The court held that the officer had reasonable suspicion to seize the defendant, based on dispatch information and personal observations of a reported fight, loud argument, and disorderly conduct. The Supreme Court vacated the Court of Appeals opinion, denied the defendant’s motion to suppress, and remanded to the District Court for further proceedings. The new crime exception arguments were not addressed because the seizure was found to be constitutional. View "State v. Morgan" on Justia Law

United States v. Baxter

2026-07-13T07:31:37-08:00

In this case, a man was involved in a fight between rival gangs in downtown Des Moines, Iowa. Law enforcement broke up the fight, but it resumed later, leading to a chase. During the pursuit, a bystander informed officers that the man had a gun. When confronted, he fled but was quickly apprehended. Officers found a loaded pistol and marijuana on him, and subsequent testing confirmed drug use. He was indicted for possessing a firearm as an unlawful drug user under federal law. Previously, the United States District Court for the Southern District of Iowa denied his motion to dismiss the indictment, in which he argued that the statute violated his Second Amendment rights and was unconstitutionally vague. He entered a conditional guilty plea, preserving his right to appeal. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s ruling on the vagueness issue but found the record insufficient to resolve the as-applied Second Amendment challenge, remanding for further proceedings. On remand, the district court held a bench trial on stipulated facts, found him guilty, conducted an evidentiary hearing, and again denied his motion to dismiss, concluding that the statute did not violate the Second Amendment as applied to him. The United States Court of Appeals for the Eighth Circuit reviewed the denial of the motion to dismiss de novo and affirmed. The court held that the government bears the burden of showing, by a preponderance of the evidence, that the application of the statute is consistent with this nation’s historical tradition of firearm regulation. The court concluded that the man’s conduct—chronic drug use, gang involvement, and aggressive behavior while armed—was sufficiently analogous to conduct historically prohibited under Founding-era “going armed to terrorize” laws. Thus, the statute was constitutional as applied to him, and the district court’s denial of the motion to dismiss was affirmed. View "United States v. Baxter" on Justia Law

United States v. Drayton

2026-07-13T07:31:35-08:00

On February 23, 2023, Cedar Rapids police, acting on information from a confidential informant, surveilled Robert Lee Drayton, Jr., who was suspected of packaging and distributing methamphetamine. Officers observed Drayton engage in several brief encounters consistent with drug transactions throughout the day. They conducted an initial traffic stop, discovering a firearm, MDMA pills, and methamphetamine, but did not detain Drayton. Later, after observing what appeared to be a delivery of a bag to Drayton’s vehicle, police initiated a second traffic stop after observing Drayton’s car hit the fog line multiple times and change lanes without signaling. During this stop, a canine unit alerted to the presence of drugs, leading to the discovery of a duffel bag containing several kilograms of methamphetamine and another firearm. Drayton was arrested, and subsequent searches of his home and cellphones yielded additional drugs, firearms, cash, and evidence of drug transactions. Drayton moved to suppress the evidence from the second stop, his stationhouse statements, the search of his home, and drug tests, arguing the stop lacked probable cause or reasonable suspicion and was unlawfully prolonged for the canine sniff. The United States Magistrate Judge for the Northern District of Iowa conducted an evidentiary hearing and recommended denial of the motion, finding the officers credible and concluding the stop and subsequent searches were constitutional. The United States District Court for the Northern District of Iowa adopted the recommendation, and Drayton entered a conditional guilty plea. The United States Court of Appeals for the Eighth Circuit affirmed. The court held that the second traffic stop was supported by reasonable suspicion based on Drayton’s observed driving and collective law enforcement knowledge of his suspected drug activity. The canine sniff did not unlawfully prolong the stop, and there was probable cause for the vehicle search. All challenged evidence was lawfully seized, and Drayton’s constitutional rights were not violated. View "United States v. Drayton" on Justia Law

Real Estate Board of New York, Inc. v. The City of New York

2026-07-13T07:30:13-08:00

A coalition of trade associations, real estate brokerage firms, landlords, and related entities challenged New York City’s Fairness in Apartment Rental Expenses Act (FARE Act), passed in November 2024. The Act prohibits brokers from charging tenants fees for apartments where they have published listings with a landlord’s permission or agreed to work for the landlord, and prevents landlords from making rental conditional on prospective tenants hiring agents. The plaintiffs argued that the Act infringed their federal and state free speech rights, particularly by burdening their ability to publish listings and receive compensation, and violated the Contracts Clause of the U.S. Constitution by rendering certain existing agreements unenforceable. The United States District Court for the Southern District of New York heard the case, with the City opposing injunctive relief and moving to dismiss the claims. The district court dismissed the plaintiffs’ First Amendment claims, finding the FARE Act to be content-neutral regulation of commercial speech that survived intermediate scrutiny under the Central Hudson test. The court denied the plaintiffs’ motion for a preliminary injunction on those claims. As for the Contracts Clause argument, the district court denied the City’s motion to dismiss, reasoning that factual issues remained, but denied a preliminary injunction after finding plaintiffs unlikely to succeed on the merits. The district court also rejected a state preemption claim. The United States Court of Appeals for the Second Circuit reviewed the appeal, affirming the district court’s judgment. The Second Circuit held that the FARE Act regulates commercial speech in a content-neutral manner and is valid under the Central Hudson test. It also concluded that the Act does not violate the Contracts Clause, as plaintiffs failed to establish a substantial likelihood of success on that claim. The court thus affirmed denial of injunctive relief and dismissal of the constitutional claims. View "Real Estate Board of New York, Inc. v. The City of New York" on Justia Law

County of Rockland v. Triborough Bridge & Tunnel Auth.

2026-07-13T07:30:04-08:00

New York State created a congestion-pricing program in 2019, requiring vehicles entering the Central Business District (CBD) in Manhattan to pay a daily toll. The stated purposes of the program include reducing traffic congestion and raising funds to support mass transit projects. Rockland and Orange Counties, neighboring municipalities with limited mass-transit access to Manhattan, argued that this program disproportionately burdens their residents, who often rely on driving rather than transit. Before the program began, Rockland and Orange Counties sued the Triborough Bridge and Tunnel Authority and the Metropolitan Transportation Authority, alleging that the toll was an unauthorized tax, violated the right to travel, and infringed upon the Due Process, Equal Protection, and Excessive Fines Clauses of both the New York and U.S. Constitutions. The United States District Court for the Southern District of New York consolidated the cases and granted the defendants’ motion to dismiss for failure to state a claim, also denying leave to amend. The court found that the plaintiffs failed to plausibly allege constitutional violations and determined that any challenge to the toll as a tax should be brought in state court. The United States Court of Appeals for the Second Circuit reviewed the appeal, assuming without deciding that the toll was not a tax. The Second Circuit affirmed the district court’s dismissal, holding that the congestion-pricing program does not create invidious distinctions or more than a minor restriction on the right to travel and thus is reviewed for reasonableness. The court found the toll to be a reasonable user fee, rationally related to legitimate state interests in funding transit and reducing congestion. It also determined there was no due process, equal protection, or excessive fines violation. The Second Circuit further ruled that the district court did not abuse its discretion in denying leave to amend the complaints. View "County of Rockland v. Triborough Bridge & Tunnel Auth." on Justia Law

Warren Livestock, LLC v. Board of County Commissione

2026-07-13T07:22:58-08:00

Several property owners and ranching entities challenged amendments adopted in 2023 by the Albany County Board of County Commissioners to the Aquifer Protection Overlay Zone (APOZ) regulations. The Casper Aquifer, which supplies drinking water to many residents of Albany County and the City of Laramie, had been the subject of prior regulatory efforts. The 2023 amendments included a 35-acre minimum lot size requirement and revised procedures for changing the APOZ boundaries. Appellants argued that the Board exceeded its authority, violated equal protection guarantees, and acted arbitrarily and capriciously in enacting the amendments. Previously, in Bienz v. Board of County Commissioners, County of Albany, 2024 WY 102 (Bienz I), the Wyoming Supreme Court reviewed whether amendments to the APOZ regulations were subject to direct judicial review under the Wyoming Administrative Procedure Act (WAPA). The district court had concluded it lacked jurisdiction, finding the Board's actions legislative and not reviewable under the WAPA. The Supreme Court reversed, holding that legislative agency actions are reviewable, and remanded the case for the district court to consider the merits. While litigation was pending, the Board further amended the APOZ regulations, requiring the district court to identify which amendments remained at issue. The district court ultimately upheld the Board’s authority and the amendments. On appeal, the Supreme Court of Wyoming addressed whether the Board exceeded its authority, whether the amendment procedures violated equal protection, and whether the arbitrary and capricious standard applied to agency legislative action. The Court held the Board acted within its statutory authority in protecting the Casper Aquifer, the distinct procedures for overlay zone amendments did not violate equal protection guarantees, and agency legislative actions are subject to the arbitrary and capricious standard. It concluded the 2023 APOZ amendments, including the 35-acre minimum lot size, were not arbitrary, capricious, or contrary to law, and affirmed the district court’s decision. View "Warren Livestock, LLC v. Board of County Commissione" on Justia Law

Gmeiner v. Kent

2026-07-10T10:31:23-08:00

Stephen and Deborah Gmeiner owned waterfront property in Michigan and sought a permit to construct a walking path through wetlands to the lake. The Michigan Department of Environment, Great Lakes, and Energy initially denied their permit application, citing environmental concerns and suggesting a boardwalk as a less damaging alternative. The Gmeiners appealed, and an administrative law judge found that township ordinances made a boardwalk infeasible without constructing a home, so the permit was granted. When the Department issued the permit, it included an indemnification clause requiring the Gmeiners to hold the State harmless for claims arising from their actions in connection with the permit. The Gmeiners objected, arguing that the clause was unauthorized under Michigan law and imposed an unconstitutional condition on their First Amendment right to petition by potentially barring lawsuits against the State for its own misconduct. The United States District Court for the Western District of Michigan denied the Gmeiners’ request for a preliminary injunction and dismissed their complaint. The court interpreted the indemnification clause narrowly, holding that it only required indemnification for claims resulting from the Gmeiners’ own actions, not for state misconduct. It concluded that the clause did not violate the First Amendment Petition Clause and that sovereign immunity barred the state-law claim in federal court. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The court held that, even assuming the unconstitutional-conditions doctrine under the Takings Clause applied to the Petition Clause, the indemnification clause was limited to claims arising from the Gmeiners’ own conduct and did not bar them from suing the State for its own misconduct. The court also held that Michigan’s sovereign immunity barred the Gmeiners from seeking state-law relief against state officials in federal court. The district court’s judgment was affirmed. View "Gmeiner v. Kent" on Justia Law

Morse v. State

2026-07-10T07:22:00-08:00

A residential subdivision in Black Hawk, South Dakota, known as Hideaway Hills, was constructed atop land with a history of both underground and surface gypsum mining. The State of South Dakota, through the South Dakota Cement Plant Commission, purchased the property, conducted surface mining, and reclaimed the land to pasture before selling it at public auction, while retaining subsurface mineral rights. Subsequent private owners and developers, aware of prior mining activity, developed the land into residential lots. Years later, residents began experiencing foundational problems and sinkholes, which culminated in a significant sinkhole event in 2020, leading to evacuation and property devaluation. After previous lawsuits against various parties were dismissed, a class action was brought in the Circuit Court of the Fourth Judicial Circuit, Meade County, against the State and related entities. The plaintiffs alleged inverse condemnation, asserting that the State’s reclamation and retention of subsurface rights amounted to a taking or damaging of private property for public use under the South Dakota Constitution. The circuit court granted summary judgment to the State, holding that the plaintiffs’ claims were, in essence, tort claims barred by sovereign immunity. On appeal, the Supreme Court of the State of South Dakota affirmed the circuit court’s decision. The Supreme Court held that the plaintiffs failed to establish a viable inverse condemnation claim because the alleged governmental actions occurred while the State owned the property, and thus did not implicate “private property.” The Court further found that the State’s activities were not for “public use” within the meaning of the state constitution, as the retained mineral rights did not confer a public right of use. The Supreme Court affirmed summary judgment for the State. View "Morse v. State" on Justia Law

State v. Gardner

2026-07-10T06:35:16-08:00

Police investigating a fatal fentanyl overdose in Leavenworth, Kansas, suspected that a supplier was distributing drugs from a woman’s residence. Over several weeks, law enforcement surveilled the home and a related apartment, observing frequent short visits, repeated appearances by suspected dealers, and traffic consistent with narcotics sales. A trash pull at the residence yielded evidence of drug activity, including baggies with residue testing positive for controlled substances, a handwritten ledger, and mail addressed to the resident. Additional evidence included drug paraphernalia found in the resident’s car and information linking associates to drug distribution and overdoses. Based on these observations, an officer compiled an affidavit and obtained a search warrant, leading to a search that uncovered substantial drug evidence and resulted in criminal charges. In the Leavenworth District Court, the defendant moved to suppress the evidence, arguing that the affidavit failed to show probable cause. The district court agreed, finding the affidavit’s details—especially those about the trash pull and vehicle search—insufficient to connect the alleged criminal activity to the residence. The court also found that much of the supporting information was uncorroborated or indicative of innocent conduct. The State appealed, and the Kansas Court of Appeals agreed the affidavit was deficient, but held that the evidence was admissible under the good-faith exception. The Supreme Court of the State of Kansas reviewed the case and concluded that both the district court and the Court of Appeals used an incorrect legal standard by analyzing the affidavit’s facts in isolation rather than considering the totality of the circumstances. The Supreme Court held that the affidavit provided the issuing judge with a substantial basis for finding probable cause. The court affirmed the reversal of the suppression order but on different grounds, and remanded the case, vacating the Court of Appeals’ discussion of the good-faith exception. View "State v. Gardner " on Justia Law

USA v. Texas

2026-07-09T15:30:32-08:00

Texas law allows certain students, including those who are not lawfully present in the United States, to qualify for in-state tuition rates at public colleges if they meet residency requirements. The Texas Education Code provisions in question—sections 54.051(m) and 54.052(a)—permit illegal aliens who establish residency in Texas to pay discounted tuition, while out-of-state U.S. citizens must pay higher rates. The United States brought suit against Texas, alleging that these provisions violate federal law, specifically 8 U.S.C. § 1623(a), which bars states from granting postsecondary education benefits to illegal aliens based on residency unless all U.S. citizens and nationals are eligible for the same benefit regardless of residency. The United States District Court for the Northern District of Texas approved a consent judgment permanently enjoining Texas from enforcing the challenged provisions. After judgment, advocacy groups, a community college, and a student moved to intervene and sought to vacate or alter the judgment, arguing the provisions were not preempted by federal law. The district court denied intervention, reasoning it was legally futile because 8 U.S.C. § 1623(a) expressly preempts the Texas statutes. The United States Court of Appeals for the Fifth Circuit reviewed the denial de novo and affirmed. The court held that intervention was futile because federal law expressly preempts the Texas provisions, barring states from conferring in-state tuition benefits to illegal aliens based on residency unless all U.S. citizens and nationals may receive the same benefit without regard to residency. The court also dismissed the remaining claims for lack of appellate jurisdiction, as the movants were not parties to the case and therefore had no right to appeal the consent judgment. View "USA v. Texas" on Justia Law

USA v. Brillhart

2026-07-09T12:02:08-08:00

A man was investigated after Google and Yahoo flagged several of his email accounts for sending and storing what appeared to be child pornography. Both companies identified the user through information like a shared recovery phone number, birthdate, and selfies associated with the accounts. Yahoo manually reviewed and confirmed the images as child pornography before reporting them to the National Center for Missing and Exploited Children (NCMEC). Google used both human review and a hash-value matching protocol, whereby a file’s unique digital fingerprint was compared against a database of previously identified illegal images. One of the files in the defendant’s account matched the hash of a known child pornography image. Law enforcement, after receiving tips from NCMEC, conducted warrantless searches and confirmed the illicit nature of the files, leading to search warrants for the defendant’s residence and devices, which yielded more incriminating evidence. The United States District Court for the Middle District of Florida denied the defendant’s motions to suppress the evidence (arguing a Fourth Amendment violation), to dismiss one of the charges on double jeopardy grounds, and to exclude certain evidence. The court also rejected his arguments concerning the admissibility of defense evidence, the sufficiency of the evidence, and the jury instructions. The defendant was convicted by a jury on both distribution and possession charges and given an enhanced sentence based on a finding of a pattern of activity involving abuse or exploitation. His subsequent motions for psychological evaluation and sentencing continuance were also denied. On appeal, the United States Court of Appeals for the Eleventh Circuit held that Google’s use of hash-value matching constituted a valid private search under the Fourth Amendment, so the government’s warrantless review did not violate the defendant’s rights. The court also held that possession and distribution of child pornography are separate offenses for double jeopardy purposes. The appellate court affirmed all district court decisions except for the application of a pattern-of-activity sentencing enhancement, which it found improper; it vacated the sentence and remanded for resentencing. View "USA v. Brillhart" on Justia Law

Barnett v Raoul

2026-07-09T11:30:58-08:00

In response to a mass shooting in Illinois, the state enacted the Protect Illinois Communities Act, which criminalized the manufacture, sale, and possession of assault weapons and large-capacity magazines, with a grandfather clause allowing current legal owners to retain these items if they completed a registration process. Plaintiffs, including individuals and organizations, challenged the Act in federal court, arguing it violated the Second Amendment. The district court for the Southern District of Illinois consolidated four related cases and, after a bench trial, found that much of the Act violated the Second Amendment, concluding that its main provisions were not severable and enjoining the enforcement of the entire Act. Prior to this, at the preliminary injunction stage, the plaintiffs had received relief, but similar challenges in the Northern District of Illinois had been denied. The Seventh Circuit consolidated appeals from all these cases and previously held in Bevis v. City of Naperville that the plaintiffs were unlikely to prevail on the merits under the Supreme Court’s framework from New York State Rifle & Pistol Association v. Bruen. After further factual development and trial, the district court entered a permanent injunction against the Act, which the defendants appealed. The United States Court of Appeals for the Seventh Circuit reviewed the case de novo on constitutional grounds. The court held that the Act’s restrictions on AR-15 rifles and thirty-round magazines are consistent with the nation’s historical tradition of firearms regulation. The court reasoned that legislatures have long imposed restrictions on particularly dangerous weapons, and Illinois’s law fits within this tradition. The court also held that the registration requirement was constitutional. The Seventh Circuit reversed the district court’s judgment and ordered the entry of judgment for the defendants, upholding the Act’s central restrictions. View "Barnett v Raoul" on Justia Law

USA v Kendrick

2026-07-09T11:30:55-08:00

In this case, federal drug enforcement agents received information suggesting that the defendant was involved in the distribution of large quantities of narcotics in Indiana. Following surveillance and a traffic stop that yielded evidence of drug activity, officers became concerned that the defendant was aware of their investigation. They installed a camera on a utility pole across the street from the defendant’s leased auto-repair shop without first obtaining a warrant. The property was surrounded by a six-foot fence, but it had significant gaps, including a thirty-foot-wide opening allowing vehicle and pedestrian access. The pole camera recorded activities on the property for approximately two weeks, capturing movements consistent with drug trafficking. Subsequent searches, supported by warrants, resulted in significant seizures of narcotics, firearms, and cash. The United States District Court for the Southern District of Indiana denied the defendant’s motion to suppress evidence obtained from the pole camera. The court held that the fence did not create a reasonable expectation of privacy in the observed activities because the gaps allowed visibility from the street. The court also found that the pole camera’s use was not a search requiring a warrant under prevailing precedent, and concluded that even without the camera footage, there was probable cause to support the search warrants. The court determined that, if necessary, the good-faith exception to the exclusionary rule would apply. On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the use of the pole camera did not violate the Fourth Amendment. The court reasoned that the camera captured activities observable to passersby through the substantial gap in the fence, the technology was in common public use, and the officers were lawfully present. The court also emphasized that commercial properties receive less Fourth Amendment protection than residences. View "USA v Kendrick" on Justia Law

Estate of Thomson v. Behn

2026-07-09T08:00:45-08:00

Jason Thomson was transported to a hospital in Green Bay, Wisconsin after suffering a seizure, where he later became agitated and aggressive toward hospital staff. Officers from the Green Bay Police Department responded, restrained Thomson—who repeatedly complained that he could not breathe—and placed him in a WRAP restraint device. Officers monitored his breathing and obtained a medical clearance from hospital staff before transporting him to jail. During transport and upon arrival at the jail, Thomson continued to state he could not breathe. At the jail, medical staff determined he could not be admitted and needed further hospital evaluation. Shortly after, Thomson suffered a cardiac arrhythmia and died. The Estate of Jason Thomson filed suit in the United States District Court for the Eastern District of Wisconsin, alleging that the officers used excessive force and failed to provide adequate medical care in violation of the Fourth Amendment, and asserting a failure-to-train claim against the City of Green Bay under Monell v. Department of Social Services of the City of New York. The district court granted summary judgment to the officers, the city, and Brown County, finding that the officers’ actions were objectively reasonable, that they did not violate Thomson’s rights, and that they were entitled to qualified immunity. The claims against Brown County and its officers, as well as a claim against a nurse, were subsequently resolved or dismissed. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s rulings de novo. The court held that no reasonable jury could find that the officers violated Thomson’s constitutional rights regarding medical care or excessive force. The court further held that the officers were entitled to qualified immunity, and, because no underlying constitutional violation was established, the Monell claim against the city also failed. The Seventh Circuit affirmed the judgment of the district court. View "Estate of Thomson v. Behn" on Justia Law

State v. Porter

2026-07-09T07:45:08-08:00

The case centers on the fatal shooting of a seventeen-year-old during a street altercation in Providence, Rhode Island. The defendant was accused of firing a gun at the victim as she approached a fight between her sister and the defendant’s sister. Witnesses saw the defendant shoot in the victim’s direction, after which she collapsed and later died at the hospital. The defendant was apprehended and charged with second-degree murder and two firearms offenses. At the initial trial in the Rhode Island Superior Court, the prosecution exercised a peremptory strike against the only African-American prospective juror. The trial court allowed the strike, accepting the prosecutor’s asserted concern about potential workplace repercussions for the juror. The jury, which had no African-American members, convicted the defendant on the main charges. On appeal, the Rhode Island Supreme Court upheld the conviction, finding the peremptory strike was based on race-neutral grounds. After a habeas petition was denied by the federal district court, the United States Court of Appeals for the First Circuit reversed, holding that the strike was not race-neutral and ordered the state courts to vacate the conviction unless a new trial was held. At the retrial, again only one African-American venireperson was present. The prosecution sought to remove this juror for cause and, when that was denied, exercised a peremptory challenge, citing the juror’s pending criminal cases and lack of candor. The trial justice ultimately allowed the peremptory challenge, and a jury again lacking African-Americans convicted the defendant. The defendant’s motion for a new trial was denied. On appeal, the Supreme Court of Rhode Island held that the trial court failed to properly conduct the third step of the Batson analysis, which requires a probing inquiry into whether the prosecutor’s race-neutral explanation was genuine or pretextual. The court concluded this failure constituted structural error and vacated the conviction, remanding the case for a new trial. View "State v. Porter" on Justia Law

Davis v. City of Elgin, Illinois

2026-07-09T06:00:46-08:00

After threatening his ex-wife and her nephew with what appeared to be a firearm while intoxicated, an individual left his home and fell asleep at a neighbor’s house. Police were alerted, and, believing him to be inside and armed, surrounded the residence with S.W.A.T. teams and other tactical units. Negotiators eventually reached him by phone, during which he threatened self-harm and was reported to have threatened the officers, though he denied threatening the officers directly. When he exited the house, police fired non-lethal projectiles after he refused commands to come off the porch, seriously injuring his arm. After briefly retreating indoors, he reemerged and was shot three more times with similar ammunition when he acted aggressively and shouted threats at the officers. The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the officers and the City, holding that the plaintiff failed to show the police violated clearly established constitutional rights under the Fourth Amendment. The district court distinguished the facts of this case from prior circuit precedent, including Phillips v. Community Insurance Corp., and found that the officers’ actions did not clearly contravene established law. On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment ruling de novo. The appellate court held that qualified immunity shielded the officers because no binding precedent placed the unconstitutionality of their specific actions beyond debate, given the circumstances—namely, threats involving firearms and knives and the plaintiff’s aggressive behavior. The court also noted that the plaintiff failed to articulate a viable claim against the City of Elgin. The Seventh Circuit therefore affirmed the district court’s grant of summary judgment for all defendants. View "Davis v. City of Elgin, Illinois" on Justia Law