Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of two counts of first degree murder, two counts of attempted murder, and possession of a firearm by a felon, holding that there was no reversible error.Specifically, the Supreme Court held (1) the prosecutor's use of a peremptory strike during jury selection prior to the guilt phase did not violate Batson v. Kentucky, 476 U.S. 79 (1986), or People v. Wheeler, 22 Cal. 3d 258 (1978); (2) the trial court did not err in denying Defendant's motion to suppress the gun discovered during a traffic stop; (3) the trial court did not err in admitting hearsay evidence that was the basis for the gang enhancement; (4) there was sufficient evidence to support Defendant's gang enhancement conviction; and (5) the court erred in admitting evidence of the victim's cancer diagnoses during the penalty phase, but there was no reasonable possibility that the victim impact testimony affected the verdict. View "People v. McDaniel" on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief to petitioner in an action where petitioner was found guilty of two first-degree murder counts. Although the Missouri Court of Appeals' conclusion that petitioner's counsel performed effectively relied on unreasonable determinations of fact, petitioner failed to show how the error was prejudicial. In this case, the trial court's ruling to deny severance was reasonable and did not amount to an abuse of discretion. Furthermore, even if petitioner could show a substantial probability of severance on appeal, he cannot show an overall reasonable probability of a different outcome in the case. In this case, the evidence against petitioner was convincingly incriminating on both murders and he has not met his burden of showing a reasonable probability of a different outcome in either case even if there was a severance of the cases. View "Donelson v. Steele" on Justia Law

The Supreme Court affirmed the order of the postconviction court denying Gary Hilton's motion to vacate his conviction of first-degree murder and sentence of death and denied Hilton's petition for a writ of habeas corpus, holding that Hilton was not entitled to relief.Specifically, the Supreme Court held (1) as to Hilton's claims of ineffective assistance of counsel, Defendant's allegations of deficient performance were insufficient to satisfy Strickland, and the postconviction court did not err in denying Hilton's claim that he was entitled to relief under Hurst v. Florida, 577 U.S. 92 (2016), and Hurst v. State, 202 So. 3d 40 (Fla. 2016); and (2) as to Hilton's petition for writ of habeas corpus, some claims were procedurally barred and, as to his remaining claims, Hilton was not entitled to relief. View "Hilton v. State" on Justia Law

Plaintiffs Horn and Jackson filed civil rights actions against the City of New Haven and law enforcement officials under 42 U.S.C. 1983. Plaintiffs each served more than 17 years in prison for a robbery and murder that they did not commit. Plaintiffs alleged that a police forensic examiner violated their due process rights under the Fourteenth Amendment by withholding exculpatory ballistics reports in contravention of Brady v. Maryland.The Second Circuit affirmed the district court's denial of the examiner's motion to dismiss both actions, concluding that he cannot make out a defense of either qualified immunity or absolute immunity. In this case, the examiner is not entitled to qualified immunity where it was clearly established that a police forensic examiner, whether an analyst or technician fulfilling any of the roles associated with forensic analysis, in 1999 reasonably would have understood that he or she was required to turn over exculpatory information to the prosecutor. Furthermore, the examiner is not entitled to absolute immunity where, even if the court concluded that adjusting the margin of error in a General Rifling Characteristics (GRC) Report constituted prosecutorial advocacy, the complaint nowhere alleges that the examiner was asked or instructed to create a new GRC Report using a larger margin of error. View "Horn v. Stephenson" on Justia Law

The Second Circuit affirmed the district court's denial of plaintiff's motion for a preliminary injunction against defendants for alleged violations of the federal Freedom of Access to Clinic Entrances Act (FACE), the New York State Clinic Access Act (State Act), and the New York City Access to Reproductive Health Care Facilities Act (City Act).The court held that the district court did not abuse its considerable discretion in denying a preliminary injunction. At this stage and as to the violations the district court found, the district court concluded that the Attorney General had not demonstrated irreparable harm. In this case, many of the issues are close ones and the court cannot say that the district court abused its considerable discretion in denying a preliminary injunction. Because the court did not disrupt the district court's determination that a preliminary injunction should not issue at this time, the court did not reach defendants' cross-appeal challenging the Attorney General's standing under the City Act or their constitutional challenges to FACE, the State Act, and the City Act. View "New York ex rel. James v. Griepp" on Justia Law

In 1999, Agpawa pleaded guilty to federal felony mail fraud. In 2002, he completed his sentence. Agpawa ran for mayor of the City of Markham in 2017. There were no preelection challenges to Agpawa’s nominating petitions, but Cook County State’s Attorney Foxx sent Agpawa a letter stating that he was ineligible to serve as mayor because of his felony conviction. Agpawa won the election. Foxx filed a complaint, alleging that Agpawa had been convicted of an “infamous crime” and was prohibited from holding municipal office unless he received a presidential pardon under the Election Code. 10 ILCS 5/29-15. The appellate court affirmed judgment for Foxx.Agpawa sought relief from then-Governor Rauner, who issued a document that purported to be a “RESTORATION OF RIGHTS OF CITIZENSHIP ROGER AGPAWA.” Agpawa took the oath of office as Markham's mayor. The court vacated its earlier order. No appeal was taken. In 2020, Agpawa sought reelection. Opponents objected. The Markham Municipal Officers Electoral Board ruled in favor of Agpawa. The appellate court reversed. A subsequent amendment to the Election Code specifically refers to a restoration of rights by the governor.The Illinois Supreme Court reinstated the Board ruling. While the governor has no constitutional authority to pardon a federal conviction, the governor has statutory authority to mitigate the collateral electoral consequences of such a conviction by issuing a restoration of rights. Governor Rauner’s untitled document restored Agpawa’s Illinois rights of citizenship, including the right to hold municipal office. The court rejected arguments that the Illinois legislature had no authority to alter the effect of a federal conviction and that the statutory amendment violated the special legislation clause, was “void for vagueness,” should not be applied retroactively, and violated first amendment rights, the equal protection clause, and separation of powers principles. View "Walker v. Agpawa" on Justia Law

The Supreme Court affirmed the decision of the court of appeals ruling that the Post-Conviction Remedies Act (PCRA), Utah Code 78B-9-101-110, barred Appellant's claims because they "could have been" brought on appeal, holding that Appellant's claims failed because trial counsel was not ineffective.Appellant was convicted of sexually molesting his daughter. The convictions were affirmed on appeal. Appellant later filed a petition for post-conviction relief, arguing that his trial counsel was ineffective and that his appellate counsel was ineffective for failing to raise ineffectiveness claims on direct appeal. The reviewing court denied relief. The court of appeals affirmed, ruling that the PCRA barred Appellant's claims. The Supreme Court affirmed, holding (1) the PCRA barred Appellant's direct claims against his trial counsel; and (2) appellate counsel was not ineffective. View "McCloud v. State" on Justia Law

In 1899, the Barnard E. Bee chapter of the United Daughters of the Confederacy erected a monument of a Confederate soldier in a San Antonio Park, also placing a time capsule beneath the statue. In 1932, the Albert Sidney Johnston (ASJ) chapter of the United Daughters of the Confederacy formed, and that chapter functionally took the place of the Bee chapter when the Bee chapter dissolved in 1972. Over a century after the monument was erected, the City of San Antonio removed both the monument and time capsule. The ASJ chapter filed suit, claiming violations of the First and Fourteenth Amendments.The Fifth Circuit affirmed the district court's dismissal of the complaint based on lack of standing, agreeing with the district court that the ASJ chapter had no property right in the monument, time capsule, or land at the center of the park. The court rejected ASJ's contention that it possesses an easement or license to use the land. Rather, the land was generally inalienable and unassignable. Furthermore, any permission to use the land was limited. Even assuming arguendo that the 1899 document created an easement or irrevocable license, however, it transferred only to the Bee chapter and terminated with its dissolution in 1972. Therefore, the ASJ chapter's failure to establish a particularized injury undermines both of its claims. View "Albert Sidney Johnston Chapter v. City of San Antonio" on Justia Law

Plaintiff filed suit against her former employer, WTW, alleging civil conspiracy under Texas law, a hostile work environment under Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act of 1990 (ADA), disability discrimination under the ADA, racial discrimination, and wrongful termination.The Fifth Circuit affirmed the district court's grant of WTW's motion for summary judgment. The court concluded that, while plaintiff did exhaust her disability discrimination and failure-to-accommodate claims, she failed to exhaust her claims of race discrimination and a hostile work environment. The court also concluded that plaintiff has not raised a genuine issue of material fact as to her failure-to-accommodate and disability discrimination claims, and WTW is entitled to judgment as a matter of law. The court further concluded that the district court did not abuse its discretion in denying plaintiff's motion to alter or amend the judgment and plaintiff has not shown that the district court abused its discretion in taxing costs against her. View "Jennings v. Towers Watson" on Justia Law

In 2002, Hayes, age 20, violently attacked his 60-year-old neighbor without provocation or apparent motive, causing her to lapse into a coma. Hayes was later seen burning items in his backyard. Clothing recovered from the burn pile contained the victim’s blood. Charged with attempted first-degree murder with a deadly weapon and armed trespassing, Hayes was found incompetent to proceed and transferred to a state mental health facility. After months of treatment, the psychology department and two court-appointed psychiatrists concluded that Hayes was competent to proceed Counsel filed a notice of intent to rely on an insanity defense and renewed his objection to the competence finding but never obtained an expert opinion regarding Hayes’ sanity at the time of the attack. On the first day of trial, defense counsel withdrew the insanity defense, allegedly at Hayes' request. Defense counsel did not call witnesses but attempted to present a misidentification defense through cross-examination. At sentencing, new defense counsel presented extensive evidence of Hayes’ mental illnesses. The court called Hayes “mentally disturbed” but sentenced him to life imprisonment.Hayes argued that trial counsel was ineffective for abandoning the insanity defense. The Eleventh Circuit reversed a grant of federal habeas relief. To establish prejudice, Hayes must show “that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. The district court instead relied on a prejudice test that was rejected by the Supreme Court. Under the clear and convincing standard required by Florida law, Hayes cannot show a reasonable probability that his insanity defense would have been successful if presented to the jury View "Hayes v. Secretary, Florida Department of Corrections" on Justia Law