Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals reversing the the trial court's decision ordering $1,615 in restitution for lost wages of the victim after Defendant pleaded guilty to two fifth-degree felony charges, holding that unless the loss of wages is directly and proximately caused by the offense, lost wages are not compensable as restitution.During the restitution hearing the victim testified that she was seeking restitution for lost wages relating to the wages she lost as a result of attending hearings for the criminal cases. The trial court ultimately ordered restitution for the lost wages of the victim. The court of appeals reversed. The Supreme Court affirmed, holding that the statutory meaning of restitution was not altered or expanded by Ohio Const. art. I, 10a, otherwise known as Marsy's Law, and that crime victims should receive restitution from those whose crimes that have directly and proximately caused them to suffer economic loss or detriment. View "State v. Yerkey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions and sentence for three counts of aggravated murder, six counts of aggravated robbery and other crimes and his sentence of life in prison, holding that a trial court errs in its evaluation of a defendant's lack of remorse when it considers that defendant's decision to waive allocution and remain silent at sentencing if the defendant exercised his right to a jury trial.Specifically, the Supreme Court held (1) the lower courts did not err in determining that Defendant did not waive his attorney-client privilege with regard to direct communications with his attorney; (2) even if this case presented circumstances in which the attorney-client privilege yielded to Defendant's right to confrontation, any error was not prejudicial; and (3) while the trial court erred in considering Defendant's decision to waive allocution and remain silent in determining whether he lacked remorse, the error was not prejudicial. View "State v. Brunson" on Justia Law

Detroit prohibits street vendors from selling their goods within 300 feet of sports arenas or stadiums. After the completion of Little Caesar’s Arena in 2017, the new home of the Red Wings and Pistons, Detroit refused to renew three vendor licenses for locations that fell within the 300-foot exclusion zone. The licenses had been in place since 2008. The displaced vendors sued, claiming due process violations.The Sixth Circuit affirmed summary judgment in favor of Detroit. The ordinance does not create a property interest in a vendor’s license; it never says that applicants will receive licenses for the places they choose but requires that they apply “for an approved location,” and warns that the city may “terminate[] or eliminate[]” a vendor location. Detroit retains the discretion to deny or suspend licenses to prevent a violation of the rules or to protect public safety. Even a protected property interest would not suffice to defeat Detroit’s decision. Detroit had rational reasons for denying these vendor applications: its interest in preventing congestion on its sidewalks, ensuring sidewalk safety, eliminating blight and litter, and protecting arena operators from competition. A 300-foot buffer zone around arenas is a rational way to advance Detroit’s interest in preventing congestion. View "Williams v. City of Detroit" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for possession of a controlled substance with intent to deliver, holding that Iowa R. Evid. 5.106 and the common law doctrine of completeness cannot trump Iowa R. Evid. 5.402.Specifically, the Supreme Court held (1) Defendant's right to a jury drawn from a fair cross section of the community under Iowa Const. art. I, 10 was not violated; (2) Defendant's claims of ineffective assistance of counsel were not properly before the Court and must be raised in the first instance on postconviction review; (3) the district court did not abuse its discretion in excluding certain documents proffered by Defendant as a discovery sanction; (4) the district court did not abuse its discretion in showing the jury an abbreviated version of a law enforcement officer's bodycam video; and (5) the evidence was sufficient to support the convictions. View "State v. Tucker" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the juvenile court to transfer Appellant to adult court, holding that that court's decision to transfer Appellant to adult court was not supported by a preponderance of the evidence and that the juvenile court abused its discretion by relinquishing jurisdiction.After the juvenile court transferred jurisdiction over Appellant to the general division a jury found Appellant guilty of aggravated murder and murder for a killing that occurred when he was fourteen years old. The court of appeals affirmed the conviction, concluding that the juvenile court did not violate Appellant's constitutional right to due process by transferring his case to the adult court. The Supreme Court reversed, holding (1) the standard of proof applicable to discretionary-bindover proceedings is a preponderance of the evidence, and the state need not produce affirmative evidence of nonamenability; (2) a juvenile court need not consider all potential juvenile dispositions when balancing the factors weighing in favor of and against transfer; and (3) the juvenile court improperly relinquished jurisdiction in this case. View "State v. Nicholas" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for postconviction relief without an evidentiary hearing and without first giving him an opportunity to respond to the State's reply, holding that the district court did not err in denying Defendant's motion for postconviction relief.Defendant was convicted of first degree murder, use of a weapon to commit a felony, and possession of a deadly weapon by a prohibited person. The Supreme Court affirmed. Thereafter, Defendant brought his motion for postconviction relief, raising several allegations of error. The district court rejected Defendant's claims without holding an evidentiary hearing. The Supreme Court affirmed, holding that there was no merit to Defendant's assignments of error. View "State v. Jennings" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of disturbing the peace, holding that the district court did not err by reviewing his appeal only for plain error and that the record was insufficient to reach Defendant's argument that trial counsel was ineffective for failing to file a statement of errors.Defendant's counsel timely appealed Defendant's county court conviction and later filed a bill of exceptions but did not file a statement of errors within ten days of filing the bill of exceptions. Consequently, the district court reviewed the appeal only for plain error and affirmed the judgment below. The Supreme Court affirmed, holding (1) the district court did not err by limiting its review to plain error; and (2) the record was insufficient to reach Defendant's remaining argument. View "State v. Warren" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, after a jury trial, of sexual assault in the first degree, holding that the district court did not abuse its discretion in prohibiting Defendant from questioning the complaining witness, J.K., about her prior allegation against a doctor.On appeal, Defendant argued that the district court erred by prohibiting from asking J.K. about an allegation she made against her prenatal doctor regarding inappropriate touching during the course of a prenatal examination. The Supreme Court affirmed, holding that the district court's decision to exclude the evidence did not violate Defendant's constitutional right to confront his accuser. View "State v. Ali" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was charged with assault and battery on a family or household member, malicious destruction of property, and intimidation of a witness. After Petitioner unsuccessfully filed several motions to dismiss he filed his Mass. Gen. Laws ch. 211, 3 arguing that the complaint had not been signed by the correct police officer and proceeding to trial on the basis of a nonconforming criminal complaint would violate his due process rights. The previously unsigned complaint was subsequently signed and sworn in open court. Thereafter, the single justice denied Petitioner's Mass. Gen. Laws ch. 211, 3 petition. The Supreme Judicial Court affirmed, holding that there was no reason Petitioner could not obtain his desired relief in a direct appeal. View "Schajnovitz v. Commonwealth" on Justia Law

In August, 1993, Fields, having spent the day drinking alcohol and smoking marijuana, got into a fight with Burton. Burton lived in a duplex owned by Horton. That night, Burton found that she was locked outside. Fields appeared, with a knife, and broke a window in the duplex. Both Fields and Burton fled before police arrived, having been called by a neighbor. Officers found Fields in Horton’s residence, a block away, in possession of Horton’s jewelry, saying that he had killed Horton, who was dead in her bedroom. At his second trial, the prosecution argued that Fields broke into Horton’s residence through a storm window, murdered her in the bedroom, and started burglarizing the residence shortly before police arrived. To test the plausibility of that theory, the jury conducted an experiment using a flat-tipped knife submitted into evidence to remove a cabinet door in the jury room (in place of the storm window). Satisfied with the outcome, the jurors convicted Fields of intentional murder and sentenced him to death.The Sixth Circuit granted Fields conditional habeas corpus relief. The jury improperly considered extrinsic evidence in violation of the Fifth and Sixth Amendments. Given the centrality of the issue, the inherently prejudicial nature of the experiment, and the lack of overwhelming evidence of guilt, the jury experiment had a “substantial and injurious effect or influence in determining the jury’s verdict.” View "Fields v. Jordan" on Justia Law