Justia Constitutional Law Opinion Summaries

The case involves Jacob Lickers, who was convicted for transporting and possessing child pornography. The conviction was based on evidence found on Lickers' devices, which were seized during a traffic stop and subsequent arrest for drug possession. The initial search of the devices was authorized by a state court warrant, which later suppressed the evidence due to the unconstitutionality of the initial stop and arrest. However, the case was referred to federal authorities who conducted a second search of the devices under a federal warrant. The federal warrant application did not mention the state court's suppression ruling.In the lower courts, Lickers' attorney challenged the constitutionality of the initial stop and arrest, and the adequacy of the state search warrant. The state court agreed, suppressing all evidence seized during the stop and any statements made by Lickers. The state charges were subsequently dismissed. However, in the federal court, the same arguments were unsuccessful. Lickers pleaded guilty, reserving the right to appeal the denial of his motion to suppress. The district court sentenced him to concurrent terms of 132 months' imprisonment on each count.In the United States Court of Appeals For the Seventh Circuit, Lickers argued that his trial and appellate counsel rendered ineffective assistance by failing to argue that the federal agent acted in bad faith by omitting the state court's suppression ruling from the federal warrant application. The court disagreed, finding that the link between the state court's suppression ruling and the federal warrant application was too attenuated to obligate the attorneys to explore the possibility of bad faith. The court affirmed the district court's denial of relief. View "Lickers v. United States" on Justia Law

The case revolves around Anthony Gay, a convicted felon, who was found guilty of possessing firearms and ammunition, both of which he was prohibited from possessing due to his prior felony convictions. Gay was a passenger in a car that was stopped by the police, and upon being pursued, he fled on foot. The police testified that they found a gun where Gay had fallen and later discovered bullets in a motel room he had rented. Gay was subsequently indicted and convicted on one firearms count and one ammunition count, leading to a sentence of 84 months' imprisonment on each count, to run concurrently, plus three years' supervised release.Previously, Gay had contested the admissibility of the bullets found in the motel room, arguing that their discovery violated his Fourth Amendment rights. However, the district court denied his motion to suppress the bullets, stating that Gay's right to occupy the room had expired, the motel manager had found the bullets before the police were involved, and the manager had the right to admit the police under state law. Furthermore, the court noted that Gay, being on parole, had a diminished expectation of privacy.In the United States Court of Appeals for the Seventh Circuit, Gay argued that the evidence did not support his conviction on the firearms charge, suggesting that the weapon may have been planted. However, the court found that the evidence, including the bullets found in the motel room, supported the firearms charge. The court also dismissed Gay's argument that the reduction of two weeks in preparation time for his second trial was prejudicial, stating that the parties had just been through a trial and the evidence had been assembled.Gay also contended that the prosecution was unconstitutional, arguing that the Second Amendment permits persons with felony convictions to possess firearms and ammunition. However, the court affirmed the lower court's decision, citing precedents that upheld the validity of "longstanding prohibitions on the possession of firearms by felons." The court concluded that Gay, having been convicted of 22 felonies and being on parole, did not fit the description of a "law-abiding, responsible citizen" who has a constitutional right to possess firearms. View "United States v. Gay" on Justia Law

George Sheetz sought to build a small, prefabricated home on his residential parcel of land in El Dorado County, California. However, to obtain a permit, he was required to pay a substantial fee to mitigate local traffic congestion. Sheetz challenged this fee as an unlawful “exaction” of money under the Takings Clause, arguing that the fee amount should be necessary to offset traffic congestion attributable to his specific development. The County’s predetermined fee schedule, Sheetz argued, failed to meet that requirement.The trial court rejected Sheetz’s claim and the California Court of Appeal affirmed. The Court of Appeal asserted that the Nollan/Dolan test, which requires permit conditions to have an “essential nexus” to the government’s land-use interest and “rough proportionality” to the development’s impact on the land-use interest, applies only to permit conditions imposed “on an individual and discretionary basis.” Fees imposed on “a broad class of property owners through legislative action,” it said, need not satisfy that test. The California Supreme Court denied review.The Supreme Court of the United States vacated the judgment of the California Court of Appeal. The Supreme Court held that the Takings Clause does not distinguish between legislative and administrative permit conditions. The Court found no basis in constitutional text, history, or precedent for affording property rights less protection in the hands of legislators than administrators. The Court did not address the parties’ other disputes over the validity of the traffic impact fee, including whether a permit condition imposed on a class of properties must be tailored with the same degree of specificity as a permit condition that targets a particular development. The case was remanded for further proceedings not inconsistent with this opinion. View "Sheetz v. El Dorado County" on Justia Law

Two members of the Lipan-Apache Native American Church, Gary Perez and Matilde Torres, sued the City of San Antonio over its development plan for Brackenridge Park. They claimed that the plan, which involved tree removal and bird deterrence measures, would prevent them from performing religious ceremonies in the park, violating their rights under the First Amendment, the Texas Religious Freedom Restoration Act, and the Texas Constitution. They sought an injunction requiring the city to grant them access to the park for worship, minimize tree removal, and allow cormorants to nest.The district court granted them access to the park for religious ceremonies but declined to enjoin the city's planned tree removal and bird deterrence measures. Both parties appealed this decision.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court found that the city's development plan did not substantially burden the appellants' religious exercise. The court also found that the city's plan served two compelling interests: public health and safety, and compliance with federal law. The court concluded that the city's tree removal and bird deterrence plans were the least restrictive means to advance these interests. Therefore, the appellants failed to show a likelihood of success on the merits of their claims. The court also denied the appellants' emergency motion for an injunction pending appeal. View "Perez v. City of San Antonio" on Justia Law

The case involves Harold McGhee, who was convicted and sentenced for drug trafficking. In August 2021, law enforcement received information from a confidential source about a drug dealer distributing large amounts of cocaine in Peoria, Illinois. The dealer was said to drive a Chevy Malibu and supplied cocaine to a house on West Millman Street. With this information, along with details from other informants and a tracking warrant, the police identified McGhee as the suspected dealer. They conducted three controlled buys and a trash pull at McGhee's residence, which led to the discovery of rubber gloves and baggies with a white powdery residue that tested positive for cocaine. This evidence led to a search warrant for McGhee's residence, vehicle, person, and electronic devices, resulting in the discovery of nearly a kilogram of various drugs, a handgun, and other drug trafficking paraphernalia.McGhee sought to suppress the evidence recovered at his residence and moved for a hearing to challenge the validity of the search warrant. He argued that the affidavit's use of "SUBJECT PREMISES," in reference to both his residence and the Millman Street house, was impermissibly ambiguous. The district court denied the motion. McGhee later renewed his motion to suppress, arguing that the trash pull was constitutionally unreasonable because it was executed without a warrant. The court denied this motion as well.On appeal, McGhee raised ten challenges to the criminal proceedings resulting in his convictions and sentence. The court considered some of his arguments on the merits and resolved others on procedural grounds. Ultimately, the court affirmed the judgment of the district court in all respects. View "United States v. McGhee" on Justia Law

In this case, the plaintiffs, BABE VOTE and the League of Women Voters of Idaho, challenged two amendments to Idaho's election laws, House Bills 124 and 340, which modified the forms of identification voters can use to prove their identity when registering to vote and voting at the polls. The plaintiffs argued that the bills violated the Idaho Constitution's guarantee of equal protection and unduly burdened the right of suffrage. The Idaho Secretary of State, Phil McGrane, counterclaimed, seeking a judgment declaring that the bills did not violate these rights under either the Idaho or the United States Constitutions. The district court granted the Secretary’s motions and entered judgment in favor of the Secretary.The Supreme Court of the State of Idaho affirmed the decisions of the district court. The court held that the bills were a valid exercise of the legislature’s power to enact conditions on the right of suffrage under Article VI, section 4 of the Idaho Constitution. The court applied the rational basis test and found that the new laws were rationally related to their stated purpose to clarify and create uniformity by requiring only generally accepted, authentic, and reliable forms of identification as a reasonable condition to exercise the right of suffrage. The court also found that the bills did not violate the Equal Protection Clause of the Idaho Constitution. View "BABE VOTE v. McGrane" on Justia Law

The case revolves around Gregory Rogers, who was convicted of various drug and firearm-related crimes. The evidence leading to his conviction was obtained from his girlfriend's car, where he was found alone in the passenger seat. Rogers claimed that the evidence was collected in violation of his Fourth Amendment rights, arguing that he had a legitimate expectation of privacy in the vehicle.Previously, the trial court had denied Rogers' motion to suppress the evidence. The court ruled that Rogers lacked a legitimate expectation of privacy in the vehicle as he was neither the owner nor the driver of the car and failed to show that he had permission to occupy it. The court also determined that the search was a valid inventory search. After trial, a jury convicted Rogers on all six counts.The United States Court of Appeals for the Sixth Circuit affirmed the trial court's decision. The court agreed with the trial court that Rogers had no legitimate expectation of privacy in the vehicle. The court noted that Rogers had not exhibited a subjective expectation of privacy. He was neither the owner nor the driver of the vehicle, and he had not shown that he had "complete dominion and control" over the car. The court also noted that Rogers had twice informed the police that the car was not his and had loudly disclaimed his authority over the vehicle. Therefore, the court concluded that Rogers could not establish that the police had violated his Fourth Amendment rights. View "United States v. Rogers" on Justia Law

The case revolves around Kyle Severson, who was convicted for mitigated deliberate homicide after shooting Tyler Hayden. Severson, his girlfriend, her sister, and his daughter were at a convenience store when Hayden and Dalton Watson arrived. Hayden approached Severson's car, and Severson shot him, claiming he feared Hayden would harm him or his daughter. Severson was charged with deliberate homicide and later found guilty of mitigated deliberate homicide, resulting in a forty-year prison sentence.Severson appealed his conviction, arguing that the District Court erred in denying his motion to dismiss based on the State's failure to disclose favorable evidence and that the cumulative effect of errors in the District Court denied him a fair trial. The undisclosed evidence included law enforcement investigative reports of a burglary at Severson's home and the contents of Watson's cell phone.The Supreme Court of the State of Montana concluded that the cumulative effect of errors in the proceedings denied Severson his constitutional rights to a fair trial and due process. The court found that the prosecutor's misconduct and the State's failure to disclose certain evidence had a direct bearing on the credibility of the witnesses at trial. The court reversed Severson's conviction and remanded the case for a new trial. View "State v. Severson" on Justia Law

The case involves a group of plaintiffs, including Forward Montana, Leo Gallagher, Montana Association of Criminal Defense Lawyers, and Gary Zadick, who challenged the constitutionality of two amendments to Senate Bill 319 (SB 319) passed by the Montana Legislature during the 2021 legislative session. The amendments, added during a closed-door committee meeting, were unrelated to the original subject of the bill, which was campaign finance. The plaintiffs argued that the amendments violated two sections of the Montana Constitution: Article V, Section 11(1), which requires that a law not be so altered or amended on its passage through the legislature as to change its original purpose, and Article V, Section 11(3), which requires that each bill contain only one subject, clearly expressed in its title.The District Court of the First Judicial District ruled in favor of the plaintiffs, finding that the amendments violated the aforementioned sections of the Montana Constitution. The court permanently enjoined the enforcement of the contested sections of SB 319. The State of Montana, the defendant in the case, did not appeal the decision, effectively acknowledging the unconstitutionality of the bill.The plaintiffs then sought attorney fees under the private attorney general doctrine and the Uniform Declaratory Judgments Act (UDJA). The District Court denied the request, finding that the case was a "garden-variety" constitutional challenge undeserving of attorney fees under the doctrine. The court also denied fees under the UDJA, finding that the circumstances did not make fees equitable.The Supreme Court of the State of Montana reversed the District Court's decision, ruling that the plaintiffs were entitled to attorney fees under the private attorney general doctrine. The court found that the plaintiffs had vindicated important constitutional rights and that private enforcement was necessary due to the State's defense of the unconstitutional law. The court remanded the case to the District Court for calculation of attorney fees. View "Forward Montana v. State" on Justia Law

The plaintiffs, Reverend Kenneth Simon, Reverend Lewis W. Macklin, II, and Helen Youngblood, collectively known as the "Simon Parties," filed a lawsuit against the Ohio Redistricting Commission and several of its members. They alleged that Ohio's congressional districts violated section 2 of the Voting Rights Act, the First Amendment, the Fourteenth Amendment, and the Fifteenth Amendment. The Simon Parties requested a three-judge court under 28 U.S.C. § 2284, which the Ohio Redistricting Commission opposed, and moved to dismiss the complaint.The district court denied the motion to convene a three-judge court and granted the motions to dismiss. The court also denied all other pending motions. The Simon Parties appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the district court incorrectly determined that the Simon Parties' Fourteenth Amendment claim did not raise a substantial federal question for jurisdictional purposes. The court stated that the Simon Parties' allegations on this claim were sufficient to establish federal jurisdiction. The court concluded that the district court lacked jurisdiction as a single judge to adjudicate any other pending motion because it was required to convene a three-judge court under 28 U.S.C. § 2284.The court reversed the district court's order denying the motion for a three-judge court, vacated the district court's orders granting the motions to dismiss and denying the motion for temporary restraining order and motion for class certification, and remanded the case to the district court with instructions for it immediately to initiate the procedures to convene a three-judge court under 28 U.S.C. § 2284. View "Simon v. DeWine" on Justia Law