Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree murder and his sentence of death, holding that Defendant failed to demonstrate any reversible error.Defendant pleaded guilty to first-degree murder and was sentenced to death. Defendant appealed, raising ten allegations of error. The Supreme Court affirmed, holding (1) the trial court did not err in allowing Defendant to represent himself during trial; (2) the trial court did not err in accepting Defendant's guilty plea; (3) the trial properly renewed the offer of counsel at all critical stages of the proceedings; (4) there was no reversible error in the trial court's findings on the statutory aggravators alleged by the State and on certain statutory and non statutory mitigators; (5) any error in the trial court's inclusion of a sentencing recommendation in the presentence investigation report did not rise to the level of fundamental error; and (6) Defendant was not entitled to relief on his remaining allegations of error. View "Woodbury v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's postconviction petition filed under Ark. R. Crim. P. 37, holding that the circuit court did not err.Defendant was convicted of four counts of rape and one count of terroristic threatening. The Supreme Court affirmed. Thereafter, Defendant filed amended petition under Rule 37 alleging six grounds for relief. The circuit court denied the petition. The Supreme Court affirmed, holding (1) the circuit court did not clearly err in finding that trial counsel provided constitutionally effective assistance of counsel; and (2) the circuit court did not abuse its discretion in striking the testimony of Defendant's expert witness. View "Joyner v. State" on Justia Law

The Supreme Court dismissed this interlocutory appeal brought by the State pursuant to Ark. R. App. P.-Crim. 3 arguing that the circuit court erred in granting Defendant's motion to suppress medical records obtained through a prosecutor's subpoena, holding that the appeal was not a proper State appeal under Rule 3.The State charged Defendant with one count of negligent homicide after he rear-ended a vehicle, causing an accident that killed a minor. Defendant filed a motion to suppress the results of a urine sample collected at the hospital and medical records that were obtained by the State, which included the results of a blood test taken as part of Defendant's medical treatment. The circuit court granted the motion to suppress, and the State appealed. The Supreme Court dismissed the appeal, holding that the State did not have a proper basis to appeal. View "State v. Kirchner" on Justia Law

During a routine traffic stop, officers ran a name check on Bass, a passenger, which returned an investigative alert issued by the Chicago Police Department for an alleged sexual assault. Bass was arrested and made incriminating statements to investigators. The court denied a motion to suppress those statements and found him guilty of criminal sexual assault. The appellate court reversed, holding that the traffic stop violated the Fourth Amendment because it was unlawfully prolonged, that Illinois Constitution article I, section 6, provides greater protections than the Fourth Amendment, and that arrests based on investigative alerts, even those supported by probable cause, violate the Illinois Constitution.The Illinois Supreme Court affirmed the reversal of Bass’s conviction, relying solely on the Fourth Amendment, without addressing investigatory alerts or the state constitution. The state failed to meet its burden of showing that the stop was not unlawfully prolonged. Officers cannot lawfully pursue unrelated investigations after quickly completing the mission by claiming that the overall duration of the stop (here, about eight minutes) remained reasonable, nor by waiting to resolve the mission (by writing a ticket or giving a verbal warning) until unrelated inquiries are completed. The name check was unrelated to resolving the red light violation; the officers resolved the traffic violation and then waited to issue the verbal warning so that they could engage in on-scene investigations into other crimes by checking names until they found something worth investigating. View "People v. Bass" on Justia Law

The Supreme Judicial Court affirmed the judgment of the single justice denying Petitioner's petition filed 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 trafficking in heroin, operating a motor vehicle with a suspended license, and two civil motor vehicle infractions. Petitioner filed a motion to suppress, which was denied. Petitioner subsequently filed a motion for leave to file a renewed motion to suppress, as well as a motion for recusal of the district court judge. The judge denied both motions. Petitioner then filed his Mass. Gen. Laws ch. 211, 3 petition arguing that the trial judge made multiple decisions that were unfairly prejudicial to him. The single justice denied relief. The Supreme Judicial Court affirmed, holding that there was nothing exceptional about Petitioner's case that warranted the exercise of this Court's extraordinary power. View "Torres v. Commonwealth" on Justia Law

The Ninth Circuit granted a petition for review of the Commission's decision concluding that petitioner failed to prove a prima facie case of discrimination under Section 105(c) of the Mine Safety and Health Act. Petitioner, a dredge operator, claimed that his former employer, CalPortland, discriminated against him for engaging in protected activities related to safety issues.The panel concluded that Section 105(c)'s unambiguous text requires a miner asserting a discrimination claim under Section 105(c) to prove but-for causation. Therefore, the panel rejected the Pasula-Robinette framework and concluded that the Commission applied this wrong causation standard. The panel explained that the Supreme Court has instructed multiple times that the word "because" in a statutory cause of action requires a but-for causation analysis unless the text or context indicates otherwise. Section 105(c) contains no such indication. The panel remanded for further proceedings. View "Thomas v. CalPortland Co." on Justia Law

In a 1999 incident, Hale told Lewis to kill Rogers. Lewis handed his revolver to Mays, who shot Rogers multiple times, fatally. Lewis, Hale, and Mays collected drugs and money and fled. Lewis, represented by Attorney Raff, refused to consider plea offers. Lewis was convicted. At sentencing. the court found no mitigating circumstances—none being asserted by the defense—and sentenced Lewis to the maximum aggregate sentence of 130 years' imprisonment. Lewis’s appeal was unsuccessful.In post‐conviction proceedings, the state conceded that Raff “basically did not do any advocacy" at sentencing but argued that he could not have made a difference. Other witnesses at the post‐conviction hearing spoke about a diagnosis of bipolar disorder, associated substance abuse, physical abuse by Lewis's mother’s boyfriends, mental disorders in other family members, and attempted suicide. The state appellate court concluded that Lewis was not prejudiced by the deficient performance of counsel.The Seventh Circuit reversed the denial of habeas relief. The decision of the last responsible state court was contrary to Supreme Court precedent, in holding that “Strickland,” not “Cronic,” furnished the applicable rule, While the Indiana Court of Appeals was not unreasonable in finding that Lewis had not been prejudiced by his attorney’s substandard performance, prejudice need not be shown. Raff gave up on Lewis and left him entirely without the assistance of counsel at the sentencing stage of a felony murder case. View "Lewis v. Zatecky" on Justia Law

In 1995, firefighters responded to a fire at a house where Brown, age 17, lived with family members. Three firefighters died when a staircase collapsed. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) opened an arson investigation and offered a $15,000 reward. Wright’s testimony undermined Brown’s alibi. Abdullah testified that Brown later confessed that he had started the fire. The prosecution’s witnesses denied receiving payment or having been promised payment in exchange for their testimony. The state court jury convicted Brown, who was sentenced to three consecutive terms of life imprisonment.Brown filed unsuccessful post-sentence motions concerning payment to witnesses. In 2001, Brown unsuccessfully sought federal habeas relief. Years later, Brown filed a petition under Pennsylvania’s Post Conviction Relief Act (PCRA), alleging newly-discovered evidence based on an expert opinion about the cause of the fire. In response to an FOIA request, ATF provided canceled checks showing it had made payments of $5,000 and $10,000 in 1998 relating to the fire. Abdullah acknowledged receiving $5,000 from ATF after Brown’s trial; Wright acknowledged receiving $10,000. The PCRA court found that Brown’s claims about the prosecution’s nondisclosure of the witnesses’ rewards satisfied exceptions to the PCRA’s time-bar and granted Brown a new trial.Meanwhile, a federal grand jury indicted Brown for the destruction of property by fire resulting in death, 18 U.S.C. 844(i). The state court dismissed the state charges. The Third Circuit affirmed the denial of a motion to dismiss the federal indictment. Retrying a defendant because the conviction was reversed for trial error is not second jeopardy. The court declined to consider an exception to the dual sovereignty doctrine, under which a state crime is not “the same offense” as a federal crime, even if for the same conduct. View "United States v. Brown" on Justia Law

Ohio H.B. 214, signed into law in 2017, prohibits any person from purposefully performing or inducing or attempting to perform or induce an abortion if the person has knowledge that the pregnant woman is seeking the abortion, in whole or in part, because of a test result indicating or a prenatal diagnosis of Down Syndrome in an unborn child or “any other reason to believe” that an unborn child has Down Syndrome, Ohio Rev. Code 2919.10(B). Violations constitute fourth-degree felonies. The law requires the state medical board to revoke the license of a physician who violates it and makes that physician liable for damages. The performing physician must attest in writing that he is not aware that fetal Down Syndrome is a reason for the woman’s decision to terminate.The Sixth Circuit initially affirmed the entry of a preliminary injunction but, on rehearing, en banc, reversed, reasoning that the restrictions imposed, or burdens created, by H.B. 214 do not create a substantial obstacle to a woman’s ability to choose or obtain an abortion. The restrictions are reasonably related to, and further, Ohio’s legitimate interests. The right to an abortion, even before viability, is not absolute. The “right” actually implicated or affected here is not the woman’s right merely to obtain an abortion; the court focused on the doctor’s “knowing” participation in the Down-syndrome stigmatic decision-making. View "Preterm-Cleveland v. McCloud" on Justia Law

After Joseph Hutcheson died as a result of police officers restraining him at the Dallas County Jail, Hutcheson's wife and mother filed suit against the county and four individual officers, bringing an excessive force claim against the officers and failure-to-train and wrongful-death claims against the county. Hutcheson died from a combination of the narcotics in his system and the stress from his struggle with and restraint by the officers. The district court dismissed or granted summary judgment on all claims.The Fifth Circuit affirmed the district court's grant of summary judgment on the excessive force claim, concluding that plaintiffs failed to raise a dispute of material fact regarding whether the officers used unreasonable force to restrain a resisting suspect. The court also concluded that the district court did not abuse its discretion by denying the motion for limited discovery on the issue of qualified immunity. The court further concluded that the district court properly dismissed the failure-to-train claim where plaintiffs failed to allege that the county provided no training, so they cannot show that the county was deliberately indifferent. Finally, the court concluded that the district court did not abuse its discretion in denying leave to file a second amendment. Accordingly, the court affirmed the district court's judgment in its entirety. View "Hutcheson v. Dallas County" on Justia Law