Justia Constitutional Law Opinion Summaries

The case revolves around Dylan Ostrum, who was under investigation for drug dealing and possession of firearms. During a search of his home, Ostrum revealed that he had moved his belongings, including his car, to his father's house. However, the car, which was reported stolen by a rental company, was found nearby with Ostrum's belongings inside, including a gun, methamphetamine, and marijuana, all stashed in two safes. The key issues on appeal were whether Ostrum had standing to challenge the search of the stolen car and whether the search violated his Fourth Amendment rights.The investigation into Ostrum began after law enforcement agents found text messages between him and another individual, Ricky Blythe, showing that they repeatedly sold each other methamphetamine and marijuana. Based on this evidence and information from confidential informants, law enforcement obtained a valid warrant to search Ostrum’s residence. However, the search turned up little, and Ostrum informed the officers that he had moved his belongings to his father's house. The officers later located the car, which was reported stolen, and discovered the safes inside.Ostrum was charged with multiple counts related to drug possession and distribution, and being a felon in possession of a firearm. He moved to suppress the evidence found inside the car, arguing that it was the fruit of an illegal search. The district court denied the motion, finding that Ostrum lacked standing to challenge the search because the car was stolen, and that the search was valid under the automobile exception to the Fourth Amendment’s warrant requirement. Ostrum was convicted on all counts and received a 240-month sentence.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Ostrum failed to meet his burden on standing and that the existence of probable cause justified the search under the automobile exception to the Fourth Amendment’s warrant requirement. The court concluded that Ostrum had no reasonable expectation of privacy in the stolen car or its contents, and thus no standing to object to its search. View "USA v. Ostrum" on Justia Law

The case revolves around a defendant, Cid Franklin, who was arrested following a road rage incident that involved a firearm. The police searched the basement of Franklin's home, which he shared with his son and stepmother, and found a gun in a closet containing items belonging to both Franklin and his stepmother. Franklin was interviewed by an employee of the Criminal Justice Agency (CJA) while in Queens central booking prior to arraignment. The CJA employee recorded Franklin's address as the basement of his home. This information was central to the prosecution's case at trial, as no DNA or fingerprints were discernable on the gun, and no other direct proof was provided that Franklin lived in the basement.The trial court admitted the CJA form as either "a public document" or "a business record," rejecting the defense's objections that it was hearsay and violated Franklin's Sixth Amendment right of confrontation. Franklin was convicted of one count of second-degree criminal possession of a weapon. The Appellate Division reversed the decision, holding that the introduction of the report violated Franklin's Confrontation Clause rights.The Court of Appeals of New York, however, reversed the Appellate Division's decision. The court held that the primary purpose of the CJA interview report was administrative, not to create an out-of-court substitute for trial testimony, and thus it was not testimonial. The court noted that the CJA report was introduced as a business or public record, and the pedigree information collected, including the defendant's address, was pertinent to establishing community ties; it was only incidentally relevant in this case. Therefore, the introduction of the CJA interview report did not violate the defendant's right of confrontation. The case was remitted to the Appellate Division for consideration of the facts and issues raised but not determined on appeal to that Court. View "People v Franklin" on Justia Law

The Ute Indian Tribe of the Uintah and Ouray Indian Reservation brought a suit against the United States, alleging various claims concerning water rights and water-related infrastructure. The Tribe claimed that the United States breached duties of trust by mismanaging water rights and infrastructure held by the United States and operated for the Tribe, breached contracts with the Tribe, and effected unconstitutional takings of the Tribe’s property. The Claims Court dismissed all the breach of trust claims, held that one breach of contract claim was barred by a 2012 settlement agreement, and found the remaining breach of contract and takings claims time barred.The United States Court of Appeals for the Federal Circuit affirmed in part and vacated and remanded in part the Claims Court's decision. The Court of Appeals held that the Winters doctrine and the 1899 Act did not sufficiently establish trust duties to support Indian Tucker Act jurisdiction with respect to the Tribe’s claims that the United States has a duty to construct new infrastructure and secure new water for the Tribe. However, the Court found that the 1906 Act imposes trust duties on the United States sufficient to support a claim at least with respect to management of existing water infrastructure. The Court also affirmed the dismissal of one breach of contract claim, vacated and remanded another, and affirmed the dismissal of the takings claims. View "UTE INDIAN TRIBE OF THE UINTAH & OURAY INDIAN RESERVATION v. US" on Justia Law

The case involves the Pennsylvania Public Utility Commission (PUC) and the City of Lancaster, Borough of Carlisle, and Borough of Columbia (collectively referred to as the Municipalities). The dispute centers around Section 59.18 of the PUC’s regulations, which gives natural gas distribution companies (NGDCs) the authority to determine the location of gas meters in historic districts. The Municipalities argued that this regulation violates Article II, Section 1 of the Pennsylvania Constitution, which vests legislative power in the General Assembly, not in private entities like NGDCs.The Commonwealth Court agreed with the Municipalities, concluding that Section 59.18 unlawfully delegates legislative authority to NGDCs without providing adequate standards to guide their decisions. The court therefore declared Section 59.18 unenforceable.The PUC appealed this decision to the Supreme Court of Pennsylvania. The PUC argued that Section 59.18 does not delegate legislative power to NGDCs, but rather is a regulatory act under the PUC’s administrative authority. The PUC also contended that the Commonwealth Court failed to consider the safety issues related to meter placement, which is the primary concern of the regulation.The Supreme Court of Pennsylvania reversed the decision of the Commonwealth Court. The court found that the General Assembly never enacted a statute giving the PUC legislative authority to determine the location of gas meters in historic districts. Therefore, the PUC could not have unlawfully delegated this authority to NGDCs. The court concluded that the Municipalities' disagreement with the PUC's regulation does not amount to a constitutional violation. The case was remanded to the Commonwealth Court for further proceedings. View "City of Lancaster v. PUC" on Justia Law

Michael Fuglesten was charged with driving under the influence of intoxicating liquor after a police officer entered his garage without a warrant. The officer had responded to a 911 call about a truck repeatedly driving by a house with loud music. The officer identified the truck as Fuglesten's, knew his license was suspended, and followed him to his home. The officer did not attempt a traffic stop or initiate his overhead lights. Upon reaching Fuglesten's home, the officer approached the garage on foot and interacted with Fuglesten, who was inside the garage. Fuglesten was subsequently arrested and charged.Fuglesten filed a motion to suppress the evidence, arguing that the officer's entry into his garage was unlawful. The district court denied the motion, and Fuglesten conditionally pled guilty to the charge, reserving the right to appeal the denial of his motion to suppress. The district court found that the officer had probable cause to believe Fuglesten had committed the offense of driving under suspension, but did not find evidence of exigent circumstances relating to dissipation or destruction of evidence.On appeal, the Supreme Court of North Dakota reversed the district court's decision. The court held that, under the U.S. Supreme Court's decision in Lange v. California, exigent circumstances were required for law enforcement to enter Fuglesten's garage without a warrant. The court found that the facts presented to the district court did not establish exigent circumstances. The court concluded that the officer's entry into Fuglesten's garage, without exigent circumstances, constituted an illegal entry. The court reversed the criminal judgment and remanded the case to allow Fuglesten to withdraw his guilty plea. View "State v. Fuglesten" on Justia Law

This case involves two appeals by West Maui Resort Partners LP and Ocean Resort Villas Vacation Owners Association against the County of Maui. The appellants, who manage nearly 700 time share units, challenged their Maui County tax assessments, arguing that the County's tax assessments were unconstitutional and violated the County's own code. They contended that the County's creation of a Time Share real property tax classification acted as an illegal tax on time share visitors. They also argued that time share units and hotel units have an identical "use" for real property purposes, and therefore, should be taxed in the same real property tax classification.The Tax Appeal Court granted summary judgment for the County in both cases. The court concluded that the County acted within its constitutional authority to tax real property in creating the Time Share classification and taxing properties assigned to it. The court also found that the County had several legitimate policy purposes rationally related to the creation of the Time Share classification, including raising revenue for infrastructure maintenance and addressing time share properties' unique impacts on the community.The appellants appealed to the Intermediate Court of Appeals, which transferred the cases to the Supreme Court of the State of Hawai‘i. The Supreme Court affirmed the Tax Appeal Court's summary judgment for the County in both cases, concluding that the County did not exceed its constitutional authority when creating the Time Share classification, nor did it violate its own code in doing so. The court also held that the Time Share classification's creation and rates were constitutional under the equal protection clauses of the Hawai‘i and U.S. Constitutions. View "In Re: West Maui Resort Partners LP v. County of Maui" on Justia Law

The plaintiff, Richard Rodgers, a prisoner with a history of scoliosis and back pain, had steel rods implanted in his back prior to his incarceration. During his time in prison, the rods broke, but this went undetected for over a year due to two radiologists misreading his x-rays. The prison's primary care physician, Dr. William Rankin, discovered the broken rods and arranged for corrective surgery. Rodgers sued the radiologists and Dr. Rankin, alleging violation of his Eighth Amendment rights.The district court dismissed Rodgers' claims against the radiologists, finding that he did not state a viable constitutional claim against them. The court allowed Rodgers to proceed against Dr. Rankin but eventually granted summary judgment in his favor. The court found that Rodgers had not provided evidence that would allow a reasonable jury to find that Dr. Rankin had violated the Eighth Amendment by acting with deliberate indifference toward Rodgers' serious medical condition.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court agreed that Rodgers' allegations against the radiologists amounted to no more than negligence, which is insufficient to state a viable Eighth Amendment claim. Regarding Dr. Rankin, the court found that the evidence would not support a reasonable finding that he acted with deliberate indifference to Rodgers' serious medical condition. The court noted that Dr. Rankin was the one who discovered the radiologists' errors and arranged for Rodgers' corrective surgery. View "Rodgers v. Rankin" on Justia Law

The Supreme Court of the State of Oklahoma reviewed the termination of parental rights of Victoria Rodriguez and Everardo Rodriguez, Sr., parents of four children who were adjudicated deprived. The children were removed from their parents' custody following allegations of severe sexual abuse against the eldest daughter, M.R., by her father over a two-year period, and the mother's failure to protect the children from this abuse.The District Court of Oklahoma County terminated the parents' rights after a jury trial. Both parents appealed separately, and their appeals were considered together in this opinion. The mother argued that the Indian Child Welfare Act (ICWA) was unconstitutional as it denied her equal protection under the law. However, the court found that she lacked standing to challenge the constitutionality of ICWA. The court also held that the trial court did not violate her right to equal protection under the law by failing to apply a heightened burden of proof under ICWA.The father argued that the trial court erred by not making certain required findings under federal and state law and by granting the State's Motion in Limine. The court found that the trial court did not err in these respects. The court affirmed the trial court's orders terminating the parental rights of both parents. View "In the Matter of M.R." on Justia Law

The case involves a dispute over the adjusted Medicaid reimbursement rates for for-profit residential health care facilities in New York. The New York State Department of Health and its Commissioner, in response to a legislative mandate, eliminated a component known as the "residual equity reimbursement factor" from the computation formula used to set these rates. This change was part of a broader effort to reduce Medicaid costs in the state. The petitioners, 116 for-profit nursing homes, challenged this adjustment, arguing that it was retroactively applied and violated their rights under the Public Health Law and the Equal Protection Clause.The Supreme Court partially granted the petitioners' motion for a preliminary injunction against enforcement of the clause pending a final determination of the proceeding. It also partially granted the respondents' motion for summary judgment, dismissing the petitioners' claims that the adjusted rates were not "reasonable and adequate to meet costs" under the Public Health Law and violated their equal protection rights. However, the court found that the adjusted rates were improperly applied retroactively. The Appellate Division affirmed the Supreme Court's decision.The New York Court of Appeals, in its review, held that the Department of Health did not violate the legislature's intent when it announced the recalculated rates for services provided on or after April 2, 2020. The court found that the legislature clearly expressed its intent for the elimination clause to be applied without delay, and that the initial implementing ratemaking was not subject to the usual 60-day advance notice requirement. The court also rejected the petitioners' claims that the adjusted rates were not "reasonable and adequate to meet costs" and violated their equal protection rights. The court modified the order of the Appellate Division in accordance with its opinion and, as so modified, affirmed it. View "In re Aaron Manor Rehabilitation & Nursing Ctr., LLC v Zucker" on Justia Law

The case revolves around Corey Dunton, who was convicted of attempted murder, assault, criminal possession of a weapon, and reckless endangerment after he opened fire at a skating rink, injuring two individuals. Dunton had a history of violent outbursts and disruptive behavior, both in and out of the courtroom. During the announcement of the verdict, Dunton, who was handcuffed for security reasons, disrupted the proceedings with verbal outbursts directed at the jury. As a result, the court ordered his removal from the courtroom.The Appellate Division, First Department, affirmed Dunton's conviction. However, following a similar case (People v Antoine), Dunton's appellate counsel contacted the Office of the Appellate Defender (OAD) regarding filing a writ of error coram nobis on Dunton's behalf. The OAD filed the writ, arguing that appellate counsel was ineffective for failing to raise certain claims, including that the trial court violated Dunton's constitutional and statutory right to be present during the rendering of the verdict when it removed him from the courtroom without prior warning. The Appellate Division granted the writ, reversed the judgment, and ordered a new trial.The case was then brought before the Court of Appeals. The court held that the trial court's removal of Dunton from the courtroom was appropriate given his history of violent outbursts and disruptive behavior. The court rejected the argument that any error was de minimis based on the timing of Dunton's removal from the courtroom. The court also held that the Appellate Division erroneously concluded that the trial court violated Dunton's right to be present, and therefore incorrectly granted Dunton's writ of error coram nobis on the sole ground that appellate counsel was ineffective for failing to raise this meritless claim on direct appeal. The court reversed the order of the Appellate Division and remitted the case to the Appellate Division for consideration of issues raised but not determined by that Court. View "People v. Dunton" on Justia Law