Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of twelve counts of possession of matter portraying a sexual performance by a minor and other sex-related offenses and his total sentence of seventy years in prison, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err by denying Defendant's motion to suppress evidence obtained from the seizure of his cellphone and password because Defendant voluntary consented to the search; and (2) the trial court did not erroneously instruct the jury as to the effect of Ky. Rev. Stat. 532.110(1)(d) on the jury's discretion to recommend consecutive and concurrent sentences. View "Payne v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and reversed in part the opinion of the court of appeals affirming Defendant's conviction for possession of heroin, holding that the court of appeals erred by affirming the trial court's admission of certain evidence and by affirming the trial court's decision allowing a certain witness to testify.Here, the Supreme Court adopted the reasonable test for determining whether the warrantless search of a parolee's vehicle is constitutionally permissible under the Fourth Amendment, as announced in Samson v. California, 547 U.S. 843 (2006), and overruled its decision in Bratcher v. Commonwealth, 424 S.W.3d 411 (Ky. 2014) to the extent it held that the conditions of parole imposed by state law are immaterial to the Fourth Amendment analysis. The Court also held that the court of appeals (1) did not err in affirming the trial court's denial of Defendant's motion to suppress evidence obtained from a warrantless search of his truck; (2) erred by affirming the trial court's admission of evidence of methamphetamine for which Defendant had been acquitted and evidence of marijuana for which he had been found guilty; and (3) erred in affirming the trial court's decision to allow a witness to testify regarding events he did not perceive in real-time. View "Gasaway v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of trafficking in a controlled substance in the first degree, second or greater offense and its sentence of twenty-seven years in prison, holding that any error was harmless beyond a reasonable doubt.On appeal, Defendant argued that the trial court violated his constitutional right to confront witnesses against him by permitting three witnesses to testify via Zoom and erred by permitting the Commonwealth to join three indictments for trial. The Supreme Court disagreed and affirmed, holding that the trial court (1) did not err when it joined the three indictments for trial; and (2) erred when it permitted three witnesses to testify remotely, but the error was harmless beyond a reasonable doubt. View "Spalding v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the appellate court reversing the decision of the circuit court finding that the Fifth Amendment privilege against self-incrimination prevented the State from compelling Defendant to provide the passcode for his cell phone, holding that the foregone conclusion doctrine applied as an exception to the Fifth Amendment privilege in this case.Defendant was charged with two counts of forgery stemming from the discovery of two false paychecks made payable to him. The police applied for and obtained a warrant to search Defendant's cell phone but could not execute the warrant because the phone was passcode protected. The State then filed a motion to compel production of the passcode. The circuit court denied the motion, concluding that compelling Defendant to provide the passcode would constitute compelling incriminating testimonial communication and that the foregone conclusion did not apply as an exception to the Fifth Amendment privilege. The appellate court reversed. The Supreme Court affirmed, holding that the foregone conclusion applied in this case. View "People v. Sneed" on Justia Law

Student H.P.-B. resides with her adult cousin Q.T. within the geographical boundaries of Pottsgrove. H.P.-B. enrolled in Pottsgrove during the 2014–2015 school year. Q.T. does not have legal custody of H.P.-B—an August 2008 order grants primary physical and legal custody to H.P.-B.’s grandmother, E.E. Q.T. filed an IDEA due process complaint on H.P.-B’s behalf. The district court held that a straightforward application of C.F.R. 34 Section 300.30 (b)(2) “dictates that Q.T. does not qualify as H.P.-B.’s ‘parent’ for purposes of the IDEA.” Q.T., E.E., and F.P. appealed the district court’s order. Appellants argued that the district court erred by holding that Q.T. does not qualify as H.P.-B.’s parent for purposes of the IDEA and, thus that Q.T. is unable to file a due process complaint on H.P.-B.’s behalf.   The Third Circuit reversed and remanded. The court explained the district court erred in finding that Q.T. did not qualify as H.P.-B.’s parent and thus lacked standing to file a due process complaint on H.P.-B.’s behalf. The court reversed the district court’s decision and remanded with instructions to vacate the hearing officer’s order dismissing Q.T.’s due process complaint. The court explained there is ample evidence in the record that Q.T. was acting in the place of H.P.-B.’s natural parent, satisfying the third definition of “parent.” The record shows Q.T. affirmed that she was supporting H.P.- B. assumed all personal obligations related to school requirements for H.P.-B. and intended to keep and support H.P.-B. continuously, and not merely through the school year. View "Q. T. v. Pottsgrove School District" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license and his sentence of eighteen months in a house of correction, holding that the Commonwealth did not demonstrate beyond a reasonable doubt that Defendant knowingly, intelligently, and voluntarily waived his Miranda rights, and Defendant did not waive this issue.In a pretrial motion, Defendant filed a motion to suppress based on the alleged inadequacy of the Miranda warnings provided to him in Spanish. The motion judge denied the motion after finding that Defendant was given "the full complement of Miranda warnings" in English and in Spanish. After he was convicted and the convictions were affirmed on appeal Defendant filed a postconviction motion for a new trial, which the motion judge denied following a hearing. The appeals court affirmed. The Supreme Judicial Court vacated the conviction, holding (1) Defendant did not waive the issue of whether Miranda warnings were properly given to him in Spanish; and (2) the admission of Defendant's post arrest statements was error. View "Commonwealth v. Delossantos" on Justia Law

The Supreme Court affirmed the order of the district court requiring Broadwater County to provide to Helena Independent Record (IR) or other interested persons redacted videographer and documentation records pertaining to Jason Ellsworth's May 2021 stop by and encounter with a Montana Highway Patrol officer, holding that there was no error.Ellsworth pleaded guilty to an obstructing a peace officer. Thereafter, a reporter with the IR requested from Broadwater County a copy of Ellsworth's investigative file. Petitioner, a county attorney, determined that the file contained confidential criminal justice information and filed a petition seeking a declaratory ruling to clarify and enforce the rights of recovery to redacted confidential criminal justice information (CCJI) contained in the file. Petitioner also filed a separate motion for leave to deposit the investigative file under seal. The district court (1) concluded that Ellsworth's criminal case had been completed and that the declaratory action was ripe for decision; and (2) held that Ellsworth's privacy rights outweighed the public's right to know regarding certain information irrelevant to the charge. The Supreme Court affirmed, holding that Ellsworth was given a proper opportunity to participate, and his due process right was not infringed regarding the release of the CCJI. View "Broadwater Co. v. Release of Confidential Criminal Justice Information" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree statutory sodomy, incest, first-degree child molestation, and one count of first-degree attempted rape, holding that the circuit court's jury instructions did not violate Defendant's constitutional right to a unanimous verdict.On appeal, Defendant argued that the evidence presented at trial included multiple allegations of abuse related to each count of sexual misconduct and that five separate verdict directors violated his constitutional right to a unanimous jury verdict. The Supreme Court affirmed, holding that the jury instructions violated Defendant's right to a unanimous verdict. View "State v. Hamby" on Justia Law

The Supreme Court affirmed the order of the circuit court overruling Appellants' motion to vacate the court's order appointing a receiver for Appellants, holding that the petition filed by Patriots Bank seeking the appointment of a receiver pursuant to the Missouri Commercial Receivership Act (MCRA), Mo. Rev. Stat. 515.500-515.665, did not violate due process.Bank entered into lending relationships with Appellants, all of which defaulted. Bank filed a petition seeking the appointment of a receiver for Appellants. The circuit court entered the receiver order. The Supreme Court affirmed, holding (1) the Bank complied with the plain language of the MCRA's notice requirement; (2) the application of the MCRA to Appellants' case did not violate the due process protections under either the state or federal constitutions; (3) the circuit court did not abuse its discretion in overruling Appellants' motion to vacate the receiver order; and (4) the receiver order did not violate the MCRA. View "Black River Motel, LLC v. Patriots Bank" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of possessing a controlled substance, in violation of Mo. Rev. Stat. 579.015.1, and unlawfully using a weapon while in possession of a controlled substance, in violation of Mo. Rev. Stat. 571.030.1, holding that Defendant's convictions did not infringe upon his right to be free from double jeopardy.On appeal, Defendant argued that his convictions violated double jeopardy protections because they arose from the same conduct. The Supreme Court reversed, holding that no double jeopardy violation existed because the plain language of the states combined with fundamental principles of statutory interpretation clearly demonstrated the legislature's intent to authorize multiple punishments under sections 579.015 and 571.030.1(11). View "State v. Onyejiaka" on Justia Law