Justia Civil Rights Opinion Summaries

Petitioner was convicted of murder and related firearms offenses. The appellate court affirmed. Petitioner subsequently filed a petition for postconviction DNA testing, which the lower court denied. The Supreme Court affirmed. Thereafter, Petition filed a second petition for DNA testing. The lower court dismissed the petition on the basis of res judicata. The Supreme Court affirmed on an alternative ground, holding that the petition failed on the merits, as the reasonable probability standard, which requires access to DNA testing only if exculpatory results discovered by DNA testing would undermine confidence in the outcome of the trial, was not met in this case. View "State v. Dupigney" on Justia Law

Employee was discharged from his employment for allegedly engaging in sexual harassment. Employee's union filed a grievance against Employer, and the parties submitted the controversy to arbitration. The arbitrator reduced the dismissal to a one year suspension without pay, finding the dismissal was without just cause. Employer filed an application to vacate the arbitral award, claiming that enforcement of the award violated public policy. The trial court granted the application and vacated the arbitrator's award on public policy grounds. The appellate court affirmed, holding that the award violated the public policy against workplace sexual harassment. The Supreme Court affirmed, holding that the public policy against sexual harassment in the workplace required nothing less than Employee's termination. View "State v. AFSCME, Council 4, Local 391" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor and operating a motor vehicle while having an elevated blood alcohol content. Defendant appealed, arguing that the trial court erred in admitting certain evidence of his refusal to answer questions from the police. The appellate court affirmed, concluding that Defendant opened the door to evidence of his refusal to answer. The Supreme Court affirmed, holding that the appellate court did not err in determining that defense counsel opened the door to the admission of the evidence at issue. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the fourth degree and related crimes. Defendant appealed, contending that the trial court erred in precluding him from cross-examining the complainant about whether she had lied to the police on an unrelated matter in violation of his right to examine a witness' character for untruthfulness, his right to confrontation, and his right to present a defense. The trial court affirmed. The Supreme Court affirmed, holding that the appellate court properly determined the trial court reasonably concluded that inquiry into the collateral matter should not be permitted. View "State v. Annulli" on Justia Law

After a jury trial, Petitioner was convicted of murder and other offenses in connection with a shooting that left one man dead and two others seriously wounded. At trial, one of the victims testified falsely regarding the consideration he expected to receive in exchange for his testimony. Petitioner filed a petition for writ of habeas corpus, claiming that the State had deprived him of a fair trial by failing to correct the false testimony. The habeas court denied relief, concluding that Petitioner failed to demonstrate materiality. The appellate court reversed, finding that Petitioner was entitled to a new trial where there was a reasonable likelihood that the victim's testimony could have affected the jury's judgment. The Supreme Court affirmed, holding that the victim's perjurious testimony was significant enough that the State's failure to correct it warranted relief under the strict materiality standard applicable in this case. View "Adams v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of one count of criminally negligent homicide, two counts of cruelty to persons, and two counts of risk of injury to a child. The convictions arose from Defendant's restriction of fluids to a two-year-old child in order to correct certain behavioral problems. The child died of dehydration. Due to her low IQ, Defendant did not know that withholding liquids could cause the child to die, but Defendant did understand that depriving someone of fluids could cause dehydration. The appellate court affirmed the convictions. The Supreme Court affirmed, holding that the appellate court properly determined that the State presented sufficient evidence Defendant had the required mental state in order to convict her of the offenses. View "State v. Patterson" on Justia Law

After a jury trial, Defendant was convicted of, inter alia, promoting a minor in an obscene performance, risk of injury to a child, and possession of child pornography in the third degree. Defendant appealed, contending that the trial court erred in denying his motion to suppress evidence obtained from his Gmail account through the execution of a search warrant. Specifically, Defendant argued that the warrant was an extraterritorial search warrant for his Gmail account contained on Google's servers located in California. The Supreme Court affirmed without reaching the merits of Defendant's argument, holding that any impropriety in the issuance and execution of the warrant was, beyond a reasonable doubt, harmless error that did not affect the verdict. View "State v. Esarey" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and risk of injury to a child. The trial court sentenced Defendant to thirty-two years incarceration and lifetime sex offender registration. The appellate court affirmed. Defendant appealed, contending that the appellate court erred in finding that Defendant's objection to the admission of expert testimony was unpreserved. The Supreme Court affirmed, holding (1) the appellate court correctly found that defense counsel's objection was not preserved; and (2) therefore, the Court declined to review Defendant's claim that the State's expert improperly expressed an opinion on the ultimate issue. View "State v. Jorge P." on Justia Law

On a conditional plea of nolo contendere, Defendant was convicted of child pornography in the first degree. During the course of the proceedings, the trial court denied Defendant's motion to suppress numerous photographic and video recorded images depicting child pornography, which the police discovered in computer equipment that had been seized from Defendant's residence pursuant to a search warrant. Defendant appealed, claiming the trial court's denial of his motion to suppress was improper because the warrant authorizing the search of his residence was not supported by probable cause. The appellate court affirmed, concluding that the trial court properly determined the affidavit in support of the search warrant application contained sufficient facts to establish probable cause to believe that child pornography would be found at Defendant's residence. The Supreme Court affirmed, holding that the appellate court properly concluded probable cause existed to support the issuance of the warrant. View "State v. Shields" on Justia Law

After a jury trial, Defendant was convicted of manslaughter in the first degree and carrying a dangerous weapon. The appellate court affirmed. Defendant appealed, arguing, inter alia, that the trial court's instruction regarding Defendant's interest in the outcome of the trial in relation to the jury's credibility assessment of his testimony deprived him of his right to a fair trial. The Supreme Court affirmed, holding (1) the prosecutor did not commit prosecutorial improprieties that deprived Defendant of a fair trial; and (2) the trial court's instruction to the trial did not affect the fairness of the trial or prejudice Defendant. However, the Court directed trial courts in the future to refrain from instructing jurors, when a defendant testifies, that they may specifically consider the defendant's interest in the outcome of the case and the importance to him of the outcome of the trial. View "State v. Medrano" on Justia Law