Justia Civil Rights Opinion Summaries

McCall, who pleaded guilty to a conspiracy charge involving heroin possession and distribution in 2015 and was sentenced to 235 months’ imprisonment, moved for compassionate release. He cited as“extraordinary and compelling circumstances” warranting his release: the COVID-19 pandemic, his rehabilitation efforts, and the Sixth Circuit’s 2019 decision, “Havis” that “attempted” controlled substance offenses do not qualify as predicate offenses for the purpose of the Sentencing Guidelines’ career-offender enhancement and a subsequent holding applying the decision to convictions for conspiracy to distribute controlled substances. He argued that his prior convictions for drug trafficking and assault no longer qualify as predicate offenses for career-offender status, that he has rehabilitated himself, and that the 18 U.S.C. 3553(a) factors favored granting compassionate release. The government argued that McCall raised “generalized fears of contracting COVID-19, without more,” that post-sentence legal developments are not extraordinary, and that McCall poses a danger to the community.The district court denied McCall’s motion in a form order. The Sixth Circuit reversed. The district court suggested that it thought itself unable to rely on nonretroactive changes in sentencing law and abused its discretion by not considering the disparity in McCall’s sentence post-Havis along with his efforts at rehabilitation and the presence of COVID-19. View "United States v. McCall" on Justia Law

The Supreme Court reversed the opinion of the court of appeals that vacated Defendant's conviction and remanded the case to the trial court for entry of a judgment of acquittal, holding that remand was required for a new trial.Defendant was convicted of "knowingly and willfully" threatening to kill a court officer. The court of appeals reversed, concluding that Defendant's conviction violated the Free Speech Clause of the First Amendment. At issue on appeal was whether the First Amendment protected Defendant from being convicted for publishing messages contained in his Facebook posts. The Supreme Court held that Defendant's messages were shielded by the First Amendment and that, because there remained questions for a properly instructed jury, the matter must be remanded for a new trial. View "State v. Taylor" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the decision of the district court dismissing as untimely and successive Defendant's motion filed under Kan. Stat. Ann. 60-1507, holding that the court was correct to dismiss the motion as untimely.Defendant was convicted in 2000 of premeditated murder, aggravated robbery, and aggravated burglary for acts he committed when he was fourteen years old. The district court sentenced Defendant to two concurrent life sentences without the possibility of parole for fifty years. Defendant later filed his section 60-1507 motion, arguing that the scheme under which he was sentenced violated the Eighth Amendment. The district court dismissed the motion. The court of appeals reversed, concluding that Defendant's motion was subject to an exception to the prohibition on successive motions. The Supreme Court reversed, holding that Defendant's sentencing scheme satisfied the constitutional requirements of Miller v. Alabama, 567 U.S. 460 (2012), and therefore, it was unnecessary to consider Defendant's motion to prevent manifest injustice. View "Williams v. State" on Justia Law

DEA obtained a search warrant for Perryman’s Indianapolis home. Agents arrived at the property, read Perryman his Miranda rights, then searched the home. In the master suite, they found fentanyl, baggies, a digital scale, and a loaded AR-15 rifle, three to four steps away from the fentanyl, along with men’s shoes and clothes. Perryman’s girlfriend, Moore, lived elsewhere but had signed the lease for the home. Moore said that the drugs, money, and gun were not hers. The agents read Perryman his Miranda rights for a second time. He agreed to talk. He admitted that the drugs were his, then provided the agents with the name of his drug supplier but said the rifle “belonged to a girlfriend.”Perryman was indicted for possessing fentanyl with intent to distribute, 21 U.S.C. 841(a)(1), possessing a firearm in furtherance of a drug trafficking crime, 18 U.S.C. 924(c)(1), and possessing a firearm while a convicted felon, 922(g)(1). The court excluded questioning concerning the disciplinary record of Sergeant Jones, who participated in the search of Perryman’s home. Jones’ 15-year-old disciplinary offense resulted in a reprimand and stemmed from an unrelated investigation. The Seventh Circuit affirmed Perryman’s convictions, rejecting challenges to the sufficiency of the evidence and, under the Confrontation Clause, to the exclusion of evidence relating to Jones’ disciplinary record. View "United States v. Perryman" on Justia Law

The Supreme Court affirmed in its entirety the judgment of the trial court convicting Defendant of first-degree murder and sentencing him to death, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not commit reversible error when it denied Defendant's request for self-representation under Faretta v. California, 422 U.S. 806 (1975) because the motion was untimely; (2) it was not reasonably probable that the jury would have reached a result more favorable to Defendant but for one improper question posed by the prosecutor to a witness; (3) the trial court did not err when it denied Defendant's motion for a mistrial; (4) admission of certain evidence did not violate Defendant's right to due process or render his trial fundamentally unfair; (5) there was no merit to Defendant's allegations of instructional error; and (6) Defendant's challenges to the death penalty law were unavailing. View "People v. Wright" on Justia Law

Officer Staffer saw Jefferson traveling at high speed with his car alarm blaring. Staffer, suspecting the vehicle was stolen, attempted a traffic stop. Jefferson was driving with an open container of alcohol. Fearing a probation violation, Jefferson did not stop. Officer Lias joined the pursuit after hearing radio dispatches, only aware that Jefferson was driving a possibly stolen vehicle. Although other officers observed Jefferson traveling at high speeds, running red lights, ignoring police signals to pull over, and driving close to other vehicles, Lias did not personally witness Jefferson doing so. Jefferson hit a fire hydrant. Officers surrounded Jefferson’s vehicle. Jefferson reversed, striking a police vehicle before backing into an intersection. Lias arrived as Jefferson was driving away. Lias claims that he discharged his firearm because he feared for his own safety and others around him. Jefferson was struck in his forearm, fracturing his bones, but drove away. Jefferson later pled guilty to second-degree eluding.The district court rejected Jefferson’s 42 U.S.C. 1983 suit, finding Lias entitled to qualified immunity. The Third Circuit reversed. A jury should make factual determinations regarding Lias’s decision to employ deadly force against Jefferson. Video footage makes clear that neither Lias nor anyone else was in danger of being struck by Jefferson. It is clearly established that an otherwise non-threatening individual engaged in vehicular flight is entitled to be free from being subjected to deadly force if it is unreasonable for an officer to believe his or others’ lives are in immediate jeopardy. Jefferson’s second-degree eluding conviction does not preclude his excessive force claim. View "Jefferson v. Lias" on Justia Law

Plaintiffs Irvin and Bates filed 42 U.S.C. 1983 actions against police officers, the police chief, and the city, alleging violations of their Fourth Amendment rights and claims under Iowa law when Officers Richardson and Jupin stopped Irvin and Bates while responding to a 911 call.The Eighth Circuit consolidated the appeals and affirmed the district court's grant of summary judgment dismissing Irvin's claims, as well as Bates's parallel state and federal claims. However, the court reversed the district court's grant of summary judgment dismissing Bates's federal and state law claims of false arrest after the initial encounter. The court concluded that the district court did not err by concluding that Officer Richardson had reasonable suspicion to stop and detain Irvin and Bates to determine whether they were involved in an unlawful firearm display during a public disturbance minutes earlier at a location they were walking away from. Because the officers had, at a minimum, arguable reasonable suspicion, they are entitled to qualified immunity on the investigative stop claims. The court affirmed the district court's grant of qualified immunity dismissing the Fourth Amendment claims where, under the circumstances, the force used by the officers did not turn the lawful Terry stop into an arrest. The court's conclusion that plaintiffs were not arrested defeats the false arrest claims.However, the court concluded that under Iowa law the district court erred in granting defendants summary judgment on Bates's claim regarding his subsequent arrest for interference with official acts. Likewise, summary judgment was not appropriate as to Bates's section 1983 false arrest claim where the relevant facts are too confused and contested to conclude, as a matter of law, that Officer Richardson is entitled to qualified immunity. Finally, the court declined to resolve these Monell issues as a matter of law on this summary judgment record and therefore included these issues in reversing the grant of summary judgment dismissing Bates's separate false arrest claims. View "Irvin v. Richardson" on Justia Law

Jones was a juvenile in 2000 when he pled guilty to first-degree murder and was sentenced to 50 years in prison pursuant to a fully negotiated plea agreement. After unsuccessfully petitioning for postconviction relief, Jones sought leave to file a successive postconviction petition alleging his sentence violated the eighth amendment protections in the Supreme Court’s “Miller v. Alabama” decision.The appellate court affirmed the denial of his motion, finding that Jones’ claims did not invoke the protections provided to juveniles in Miller. The Illinois Supreme Court affirmed. Miller’s additional protections for juvenile offenders apply only when a trial court lacks or refuses to use discretion in sentencing a juvenile offender to life, or to a de facto life, sentence. The mandatory sentencing scheme that applied in Illinois at the time he was sentenced was never applied to Jones. By entering a plea agreement, a defendant forecloses any claim of error. A voluntary guilty plea waives all non-jurisdictional errors or irregularities, including constitutional ones. Jones has not claimed that the state engaged in any misrepresentation or committed any misconduct. View "People v. Jones" on Justia Law

Chicago police officer Luzadder and his partner were on patrol at 11:36 p.m. when they received a dispatch stating that an anonymous person reported that two white females were walking with a white male wearing a black hoodie, who “was swinging at the females” and “has a gun” near a particular intersection. A second call reported that the group had moved north. Minutes later, at the second location, Luzadder saw Carter, a white male, wearing the described clothing, holding his waistband. Luzadder did not see two women nor did he see Carter violate any laws. Luzadder believed that Carter was attempting to conceal a firearm. Luzadder, with a hand on his service weapon, ordered Carter to raise his hands, patted down Carter over his clothes, and felt what he thought was the handle of a handgun. He lifted Carter’s shirt and recovered a revolver from Carter’s waistband. Luzadder arrested Carter, who was charged with being an armed habitual criminal, aggravated unlawful use of a weapon, and unlawful use or possession of a weapon by a felon.The circuit court denied his motion to suppress. The appellate court affirmed the denial of Carter’s motion and his nine-year sentence. The Illinois Supreme Court affirmed in part. The officers had the necessary reasonable suspicion for an investigatory stop. The court otherwise vacated. The state failed to prove Carter guilty beyond a reasonable doubt of armed habitual criminal; the other convictions were merged into that conviction. View "People v. Carter" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress evidence of cocaine discovered after a dog sniff of the vehicle in which Defendant was a passenger, holding that the stop was extended, and that extension was not justified by reasonable, articulable suspicion.Defendant was charged with first-degree possession of cocaine. He pled not guilty and filed a motion to dismiss, claiming that he was illegally detained and that the police did not have reasonable, articulable suspicion to call the dog. The trial court determined that it was a valid stop and that the evidence should not be suppressed. The Supreme Court affirmed, holding (1) the traffic stop was extended; (2) the Commonwealth failed to establish simultaneous missions that permitted the seizure; and (3) the Commonwealth did not meet its burden of establishing reasonable, articulable suspicion. View "Commonwealth v. Clayborne" on Justia Law