Justia Constitutional Law Opinion Summaries

The case involves a challenge to the constitutionality of several Nevada statutes regulating "ghost guns," or unfinished firearm frames or receivers. The respondent, Polymer80, Inc., a manufacturer of gun-related products, argued that the definition of "unfinished frame or receiver" in the statutes was impermissibly vague, making the statutes unconstitutional. The district court agreed with Polymer80, concluding that the definition did not clearly explain key terms or notify individuals when raw materials would become an unfinished frame or receiver. The court also found that the definition allowed for arbitrary and discriminatory enforcement.The Supreme Court of the State of Nevada disagreed with the lower court's findings. The court found that the terms used to define "unfinished frame or receiver" had ordinary meanings that provided sufficient notice of what the statutes prohibited. The court also concluded that the statutes were general intent statutes that did not lack a scienter requirement and did not pose a risk of arbitrary or discriminatory enforcement. Therefore, the court reversed the district court's decision, holding that the statutes were not unconstitutionally vague. View "Sisolak v. Polymer80, Inc." on Justia Law

The case revolves around an initiative petition proposed by Nevadans for Reproductive Freedom (NRF) to establish a constitutional right to reproductive freedom. The petition would grant every individual the right to make decisions regarding all matters related to pregnancy, including prenatal care, childbirth, postpartum care, birth control, vasectomy, tubal ligation, abortion, abortion care, management of a miscarriage, and infertility care. Respondents Donna Washington and Coalition for Parents and Children challenged the petition in district court, alleging that it failed to meet statutory and constitutional requirements and sought to prevent the Secretary of State from placing the initiative on the ballot. They argued that the initiative petition violated the single-subject requirement because it considered multiple medical procedures, instead of being limited to only pregnancy or abortion. The district court granted the injunction, finding the initiative petition invalid for three reasons: it does not contain a single subject, its description of effect is misleading, and it requires an expenditure of money without raising the necessary revenue.The Supreme Court of Nevada reversed the district court's decision. The court found that all the medical procedures considered in the initiative petition concern reproduction and are germane to each other and the initiative's single subject of establishing a right to reproductive freedom. The court also concluded that the description of effect was legally sufficient and the initiative petition does not require an expenditure of funds. Therefore, the court held that the district court erred in preventing the Secretary of State from placing the initiative petition on the ballot. View "Nevadans for Reprod. Freedom v. Washington" on Justia Law

Tyrone Cameron was convicted of being a felon in possession of ammunition following a three-day trial. The district court sentenced him to 120 months' imprisonment and a three-year term of supervised release. Cameron appealed, arguing that there was insufficient evidence to support his conviction, that his conviction violated the Second Amendment, that the district court should not have admitted his prior felony convictions involving firearms into evidence, and that the government engaged in prosecutorial misconduct during closing arguments.The district court had reviewed the evidence, including surveillance footage and testimonies, and found sufficient circumstantial evidence to support Cameron's conviction. The court also admitted Cameron's prior felony convictions into evidence, which were relevant to show that Cameron knew he was a felon and knowingly possessed ammunition.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that a reasonable jury could have found there existed ample circumstantial evidence to support Cameron’s conviction. The court also rejected Cameron's Second Amendment challenge, noting that the Supreme Court's decision in New York State Rifle & Pistol Ass’n, Inc. v. Bruen did not cast doubt on longstanding prohibitions on the possession of firearms by felons. The court found no error in the district court's admission of Cameron's prior felony convictions, as they were relevant to the case and not unfairly prejudicial. Lastly, the court found no prosecutorial misconduct, as the government's remarks during closing arguments were permissible interpretations of the evidence. View "United States v. Tyrone Cameron" on Justia Law

The case involves Roger Ouellette, who was convicted of Operating Under the Influence (OUI) following a police stop in his driveway. The police officer had observed Ouellette's vehicle crossing the center line of the road, which led the officer to suspect a violation of traffic laws. Ouellette entered a conditional guilty plea after his motion to suppress evidence obtained from the stop was denied by the trial court.The trial court found that the officer had reasonable suspicion to stop Ouellette due to his observed traffic violation. Ouellette argued that the stop was unjustified as the officer lacked reasonable suspicion of wrongdoing. However, the court determined that the stop was supported by reasonable articulable suspicion that Ouellette had violated the motor vehicle statute requiring vehicles to be operated within a single lane.On appeal, Ouellette argued that the stop was an unreasonable seizure under the Fourth Amendment because it occurred within the curtilage of his home without a warrant and without any applicable exception to the warrant requirement. The Maine Supreme Judicial Court affirmed the lower court's decision, concluding that the court's failure to grant Ouellette’s motion on that ground did not constitute obvious error and that the stop was justified based on reasonable suspicion. The court also found that Ouellette's argument regarding the stop occurring within the curtilage of his home was unpreserved and did not amount to obvious error. View "State of Maine v. Ouellette" on Justia Law

In Arkansas, attorney Chris Corbitt and other plaintiffs sought to challenge the prohibition of firearms in courthouses. Corbitt had previously attempted to bring a firearm into the Pulaski County District Courthouse and the Juvenile Justice Complex, but was denied. He filed a complaint, which was dismissed by the circuit court and later affirmed by the Supreme Court of Arkansas. Despite this, Corbitt and other plaintiffs filed another complaint after encountering firearm restrictions in a different courthouse. This complaint was also dismissed.The circuit court ruled that Corbitt was not entitled to injunctive relief, declaratory judgment, or a writ of mandamus. The court also found that even if issue preclusion were not applicable, it would rule similarly to Judge Wright’s decision regarding the interpretation of Arkansas Code Annotated section 5-73-122. The court rejected the plaintiff’s argument, stating that it was based on a flawed premise that misread the plain meaning of the statute and ignored the importance of Amendment 80 to the Arkansas Constitution. The circuit court emphasized that Amendment 80 gives the Arkansas Supreme Court the power to regulate court procedure, including the discretion to determine when weapons should be allowed in courtrooms.The Supreme Court of Arkansas held that Corbitt was collaterally estopped from pursuing his claims due to the previous litigation, but the remaining plaintiffs could proceed. The court further held that attorneys, as officers of the court, are authorized by statute to possess handguns in courthouses. The court reversed the circuit court’s denial of the petition for a declaratory judgment as it pertains to the remaining plaintiffs and remanded for further proceedings consistent with this opinion. View "CORBITT v. PULASKI COUNTY CIRCUIT COURT" on Justia Law

In 1998, Robert Keith Woodall was sentenced to death for the kidnapping, rape, and murder of a teenage girl. In 2015, Woodall filed a Motion to Vacate the Death Sentence Due to Intellectual Disability, arguing that he is intellectually disabled and thus the imposition of the death penalty would violate his constitutional rights. The trial court denied his motion without a hearing. On appeal, the Supreme Court of Kentucky reversed and remanded the case for an evidentiary hearing.On remand, the trial court held an evidentiary hearing and again denied Woodall’s motion. The court found that Woodall had not proven by the preponderance of the evidence that he is intellectually disabled. Woodall appealed this decision to the Supreme Court of Kentucky.The Supreme Court of Kentucky affirmed the decision of the trial court. The court found that the trial court's factual findings were supported by substantial evidence and that Woodall had not proven that he is intellectually disabled by a preponderance of the evidence. The court also rejected Woodall's arguments that the trial court violated his due process rights and Confrontation Clause rights by admitting and relying on a report without requiring the report's author to testify at the hearing. View "WOODALL V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case involves four appellants who are parole-eligible inmates serving life sentences in the Kentucky Department of Corrections. They were denied any further opportunity at parole for the remainder of their sentences by the Kentucky Parole Board. The appellants challenged the Board's authority to issue a "serve-out," arguing that it violates the constitutional separation of powers.The Franklin Circuit Court concluded that the Board was within its statutory authority to issue a serve-out on a life sentence and granted summary judgment to the Board. The Kentucky Court of Appeals affirmed the lower court's decision, reasoning that the legislature had not prohibited the Board from authorizing serve-outs on life sentences.The Supreme Court of Kentucky affirmed the decisions of the lower courts. The court held that the Board has the power to issue a serve-out to an inmate serving a life sentence. The court reasoned that while the current statutory scheme may not explicitly authorize the Board to grant serve-outs, the relevant legislative and administrative history indicates that the legislature has condoned the Board’s use of this power. The court also held that the Board's power to issue a serve-out does not violate the constitutional separation of powers. The court concluded that a serve-out is authorized by the legislature and is not constitutionally impermissible. View "CONN V. KENTUCKY PAROLE BOARD" on Justia Law

On July 4, 2021, Gavin Wallmow was arrested for violating his probation and was taken to Oneida County jail. During his booking, Wallmow denied any suicidal tendencies or mental health issues. Two days later, Wallmow's probation officer visited him and noticed a change in his behavior, including him hitting himself and expressing "demonic" thoughts. The officer reported this to a corrections officer at the jail, who then informed her superior. Despite these reports, Wallmow was observed behaving normally during routine checks. On July 8, Wallmow was found unresponsive in his cell, having committed suicide. His estate brought a series of constitutional claims under 42 U.S.C. § 1983, alleging that the jailers failed to protect Wallmow from himself.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the record did not support an inference that any defendant knew Wallmow faced a serious risk of harm. The court also found no reason to think the County's policies were inadequate, given the absence of any pattern of suicides to put it on notice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the lower court's decision. The appellate court found that the jail's employees had taken reasonable precautions, including checking on Wallmow at least 37 times per day. The court also noted that Wallmow had thrice disavowed any risk of suicide, and nothing indicated otherwise after his talk with his probation officer. The court concluded that the jail's actions complied with the Constitution's requirements. View "Estate of Wallmow v. Oneida County, Wisconsin" on Justia Law

The case involves a challenge to New Jersey's primary election ballot design, known as the "county-line" ballot. The plaintiffs, Andy Kim, Sarah Schoengood, and Carolyn Rush, who are all Democratic candidates for various offices, argue that the county-line ballot design infringes their First Amendment rights. They contend that the design unfairly favors candidates endorsed by local party leaders, placing them in prime ballot positions, while disadvantaging those who are not endorsed or choose not to associate with certain candidates.The case was initially heard in the United States District Court for the District of New Jersey, where the plaintiffs sought a preliminary injunction to prevent the use of county-line ballots and require the use of office-block format ballots instead. The District Court granted the injunction, finding that the plaintiffs had shown a severe burden on their First Amendment rights and that the state's interests did not outweigh these burdens.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court's decision. The Court of Appeals agreed that the county-line ballot design imposed a severe burden on the plaintiffs' First Amendment rights. It also found that the design likely violated the Elections Clause of the Constitution, which limits a state's power to regulate elections. The court concluded that the plaintiffs had demonstrated a substantial likelihood of success on the merits of their claims, and that they would suffer irreparable harm without the injunction. The court also found that the balance of harms and the public interest favored the plaintiffs. View "Kim v. Hanlon" on Justia Law

Albert Bustillos, an independent journalist, was filming content for his YouTube channel outside the Navajo oil refinery in Artesia, New Mexico. He was approached by refinery security and later by officers from the Artesia Police Department, including Corporal David Bailey. Despite Bustillos asserting he was on public property and had not broken any laws, Bailey arrested him for failure to identify himself in violation of New Mexico law.Bustillos sued Bailey and the City of Artesia, alleging violations of his First and Fourth Amendment rights and New Mexico law. The defendants moved for summary judgment, arguing that Bailey was entitled to qualified immunity. The district court denied the motion, rejecting Bailey’s qualified immunity defense.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s denial of qualified immunity. The court found that Bailey lacked reasonable suspicion of a predicate crime, which is required to lawfully arrest someone for concealing identity. The court also found that Bustillos had met his burden to show that Bailey violated his clearly established Fourth Amendment rights. The court dismissed the portion of the appeal relating to Bustillos’s state-law claims, as the defendants had failed to meet their burden to support pendent appellate jurisdiction. View "Bustillos v. City of Artesia" on Justia Law