Justia Constitutional Law Opinion Summaries

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This case concerns the constitutionality of several Montana election laws. The plaintiffs, a variety of political and human rights organizations, sued the Montana Secretary of State, arguing that certain election laws were unconstitutional. The challenged laws included provisions restricting absentee voting, changing voter registration deadlines, banning paid absentee ballot collection, and revising voter ID requirements.The Montana Supreme Court affirmed the lower court's judgment, finding that each of the challenged statutes were unconstitutional. The Court held that the laws either impermissibly interfered with or minimally burdened the right to vote, a fundamental right under the Montana Constitution. The Court applied a strict scrutiny or a middle-tier analysis, depending on the extent of the burden on the right to vote, and determined that the state failed to show that the laws were the least onerous path to a compelling state interest or were reasonable and more important than the burden on the right to vote. The Court rejected the Secretary of State's argument that the laws were necessary for administrative efficiency and to ensure the integrity, reliability, and fairness of the election process. View "Democratic Party v. Jacobsen" on Justia Law

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In a case before the United States Court of Appeals for the Ninth Circuit, the petitioner, Terry Eugene Iversen, appealed the district court’s denial of his 28 U.S.C. § 2254 petition for a writ of habeas corpus. Iversen had been sentenced to life without parole (LWOP) for the crime of public indecency under Oregon’s sex offender recidivism statute due to his extensive criminal history, which included prior convictions for public indecency, rape, and sodomy. Iversen argued that the LWOP sentence was grossly disproportionate to his offense, in violation of the Eighth Amendment’s prohibition against cruel and unusual punishment.The court, applying the demanding standard required by the Antiterrorism and Effective Death Penalty Act, upheld the district court’s decision. The court found that the Oregon state court’s decision concerning Iversen’s sentence was not contrary to Supreme Court’s Eighth Amendment jurisprudence. The court considered Iversen’s extensive history of adult felony recidivism, his mental health record, his failed opportunities to reform, and the fact that he remained dangerous to others. The court also noted Oregon’s public-safety interest in incapacitating and deterring recidivist felons like Iversen.The court concluded that Iversen’s sentence did not raise an inference of gross disproportionality given the gravity of his offense and criminal history. Therefore, the court affirmed the district court’s denial of Iversen’s habeas petition. View "Iversen v. Pedro" on Justia Law

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In this case, an eight-year-old child disclosed during an interview with a detective in 2016 that her music teacher, defendant Donnie E. Harrell, had touched her inappropriately on multiple occasions during school hours. In 2019, a grand jury indicted Harrell on charges of sexual assault and endangering the welfare of a child, with additional official misconduct charges added in a superseding indictment later that year. In 2021, the trial court approved the admission of the child's entire recorded statement under the "tender years" hearsay exception. However, while preparing for trial in 2022, the child could not recall most of the events she had originally reported.The trial court decided to limit her trial testimony to the one incident she recalled, ruling that her lack of memory rendered her unavailable for cross-examination on the incidents she could not recall, which would violate the defendant's right of confrontation. The Appellate Division reversed this decision, stating that the defendant's right of confrontation was not dependent on the child's ability to recall the details, but on the defendant's opportunity to probe her lack of recollection on cross-examination.The Supreme Court of New Jersey affirmed the judgment of the Appellate Division, holding that the admission of the child's entire video-recorded statement does not violate the Confrontation Clause as long as the child testifies at trial and is subject to cross-examination, even if she doesn't recall all the details. The court also emphasized that it is essential for the State to act expeditiously in investigating and prosecuting matters that rely heavily on a young child's ability to recall events, to avoid memory decay over time. View "State v. Harrell" on Justia Law

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A high school student, identified as J.G., was required to undergo daily searches for weapons as part of a safety plan after committing firearm-related offenses. However, when J.G. returned to school for his tenth-grade year, he was not searched on the first two days. On his third day, school administrators discovered a loaded handgun in his backpack and he was arrested and charged with weapons-related offenses. J.G. moved to suppress evidence of the handgun, arguing that the search violated his Fourth Amendment rights as the safety plan was no longer in effect at the time of the search. His motion was denied by the juvenile court which found that the safety plan, with its requirement for daily searches, was still in place when the handgun was found.The Supreme Court of the State of Colorado affirmed the lower court's decision. The court held that a search of a student conducted on school grounds in accordance with an individualized, weapons-related safety plan is reasonable under the Fourth Amendment. The court reasoned that J.G.'s behavior did not create individualized reasonable suspicion on the day he was searched. However, the presence or absence of individualized suspicion is not the full extent of the inception prong of the reasonableness test. The court held that the search of J.G.’s backpack was reasonable at its inception because it was carried out in conformity with a formal safety plan and it was appropriately limited in its scope. The court also found that J.G. had sufficient notice of the search requirement to diminish his expectation of privacy in his backpack. View "People In re J.G." on Justia Law

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The case in question concerns the defendant, Sharrieff M. Kent, who was convicted by a Plaquemines Parish jury of two counts of aggravated assault with a firearm, one count of aggravated criminal damage to property, and one count of illegal discharge of a firearm. The charges stemmed from an incident where Kent fired several shots at a pickup truck containing law enforcement officers as they were fleeing his property during an investigation. Kent claimed he was protecting his family from unknown intruders on his property.The Court of Appeal had reversed Kent's convictions, determining that the State violated Kent's right to due process by introducing evidence of other crimes and his Fifth Amendment right to remain silent. The Court of Appeal also found that the State violated Kent’s right to remain silent by referencing his post-arrest, post-Miranda silence.However, the Supreme Court of Louisiana disagreed with the Court of Appeal's determinations. It concluded that the references made to the officers conducting the trash pull as part of a narcotics investigation do not constitute impermissible references to other crimes or misconduct. Additionally, the Supreme Court found that the State did not violate the Fifth Amendment as the circumstances presented align more with the exceptions and non-application of Doyle than with Doyle itself.While the Supreme Court agreed that the State introduced the facts underlying Kent's prior conviction without first satisfying necessary prerequisites to their admission, it did not believe this error warranted a reversal of Kent's conviction. Considering the overwhelming testimonial and physical evidence showing Kent fired his weapon at a fleeing vehicle in the street, the Supreme Court concluded that the verdict was surely unattributable to the error. Consequently, the Supreme Court reversed the ruling of the Court of Appeal and reinstated Kent's convictions and sentences. View "STATE OF LOUISIANA VS. KENT" on Justia Law

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The Supreme Court of Louisiana ruled in a case involving allegations of child sexual abuse by a Roman Catholic priest. The plaintiffs alleged that the abuse occurred between 1971 and 1979 when they were aged between eight and fourteen. The defendants argued that the claims were subject to the one-year prescriptive period for delictual actions under former La. Civ. Code art. 3536(1).While this case was pending, the legislature amended La. R.S. 9:2800.9 to revive certain prescribed child sex abuse claims for a limited three-year period. However, the court found that the statutory enactment was contrary to the due process protections enshrined in the Louisiana Constitution and must yield to that supreme law. The court reversed and vacated the trial court's decision to the extent it found the statutory enactment to be constitutional.The court determined that once liberative prescription accrues, it becomes an accrued, vested right. It noted that the right to plead prescription in defense to a claim on the obligation itself is "property that cannot be taken from [the defendant]." Hence, when a party acquires the right to plead the defense of accrued prescription, his right becomes a vested property right protected by constitutional due process guarantees.The court concluded that the legislature lacked the authority to revive the prescribed claims set forth under the facts alleged in this case. However, the court remanded the case to the trial court to rule on the exception anew after plaintiffs have had an opportunity to raise any additional arguments regarding contra non valentem and the timeliness of their claims. View "BIENVENU VS. DEFENDANT 1" on Justia Law

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In Arizona, condominium unit owners Jie Cao and Haining Xia challenged the forced sale of their unit by their condominium association (the “Association”) following the dissolution of the condominium. The Association, which had been given power to sell under the Arizona Condominium Act, sold the unit to PFP Dorsey Investments, a company that had previously acquired the majority of units in the condominium.The Supreme Court of the State of Arizona held that the Arizona Condominium Act, which authorized the sale, did not violate the eminent domain provision of the Arizona Constitution. The court stated that the Act was incorporated into the condominium declaration, to which the owners had agreed. However, the court also held that in these circumstances, the Act required the sale of all property, rather than individual units as occurred in this case.The court noted that the Association's power to sell derived from the condominium declaration that all unit owners had signed. Thus, the Act didn't effect a taking of the owners' property. As such, the forced sale of the owners’ unit alone rather than as part of a sale of all common elements and units of the condominium was impermissible under the Act.The court vacated the court of appeals’ decision and remanded the case to the trial court for further proceedings consistent with its opinion. The court also granted the owners reasonable attorney fees for amounts expended to enforce the Declaration, excluding those attributable to the unsuccessful eminent domain claims. View "CAO v PFP DORSEY" on Justia Law

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During an investigation of a stolen car, law enforcement officers followed a suspect into a nearby home where they discovered an illegal drug operation. One of the participants in the operation, the defendant, did not live at the residence and denied any ownership or control over the premises or the objects within, including a safe containing illegal items. The homeowner, who was also the defendant's uncle, consented to the search of the home. After the defendant was convicted of several drug-related offenses, he appealed, arguing that the evidence should have been suppressed because the police entered the home without a warrant.The Supreme Court of North Carolina was tasked with deciding if the defendant had standing to challenge the warrantless entry into the home, given that he had declared he did not live there. The Court of Appeals had previously reversed the trial court's denial of the motion to suppress, stating that the trial record did not support any finding that the defendant lacked a reasonable expectation of privacy in the home.The Supreme Court of North Carolina reversed the decision of the Court of Appeals, holding that the evidence presented at the suppression hearing could support findings that the defendant lacked standing to challenge the search. The court, however, noted that the trial court failed to make these findings despite the presence of materially conflicting evidence in the trial record. The case was remanded to the trial court for findings of fact based on the trial record. Depending on those findings, the trial court could again deny the motion to suppress, or it may grant the motion to suppress in whole or in part and order a new trial. View "State v. Jordan" on Justia Law

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In this case, the plaintiff, Frankie Delano Washington, was convicted of various serious felony offenses. During his trial, he asserted that his constitutional right to a speedy trial had been violated. His argument was initially rejected, but later won on appeal and his convictions were set aside. Subsequently, Washington and his son filed a suit against the State and various state and local officials, alleging that the State knowingly charged him for crimes he did not commit. Among the numerous claims brought forth, Washington argued for a common law claim against the State for damages caused by the deprivation of his state constitutional right to a speedy trial.However, the Supreme Court of North Carolina held that Washington had an adequate state law remedy and therefore, a separate Corum claim was not available. The court reasoned that the plaintiff had already received a meaningful remedy for the State's violation of his rights, as his criminal convictions had been permanently set aside. The court further clarified that an "adequate remedy" is one that meaningfully addresses the constitutional violation, even if the plaintiff might prefer a different form of relief. This decision upholds the foundational principle that a Corum claim is applicable when one's rights are violated, and the law offers either no remedy or a remedy that is meaningless. The court ultimately affirmed the decision of the Court of Appeals, which had upheld the trial court's entry of summary judgment. View "Washington v. Cline" on Justia Law

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The Supreme Court of North Carolina ruled on a case involving Halikierra Community Services LLC (Halikierra), a provider of home personal care services to Medicaid beneficiaries and the North Carolina Department of Health and Human Services (DHHS). DHHS had placed Halikierra on Medicaid reimbursement prepayment review following several overbilling complaints, leading to several post-payment audits. The audits revealed that Halikierra had erroneously received excess Medicaid reimbursement funds on multiple occasions and found suspicious reimbursement claims.Halikierra filed a lawsuit against DHHS, alleging that the decision to place them on prepayment review violated their substantive due process and equal protection rights under the North Carolina Constitution. The trial court granted summary judgment in favor of DHHS, leading to an appeal from Halikierra.The Supreme Court of North Carolina affirmed the trial court's decision, holding that summary judgment was properly entered against Halikierra. The Court found that Halikierra’s evidentiary forecast failed to disclose any genuine issues of material fact in support of its claims. The Court concluded that DHHS's actions were not arbitrary or capricious, as the prepayment review was rationally related to a legitimate government interest, namely combating Medicaid fraud and ensuring that claims meet the requirements of federal and state laws and regulations. The Court also found no evidence of unequal treatment of Halikierra compared to other Medicaid providers. View "Halikierra Cmty. Servs. LLC v. N.C. Dep't of Health & Hum. Servs" on Justia Law