Justia Civil Rights Opinion Summaries

On January 9, 2021, Xzavier D. Hill, an 18-year-old, was shot and killed by Virginia State Troopers Seth W. Layton and Benjamin I. Bone. Hill's estate, represented by his mother, LaToya K. Benton, filed a lawsuit in the United States District Court for the Eastern District of Virginia, alleging that the troopers used excessive force in violation of 42 U.S.C. § 1983 and committed state law torts. The troopers moved for summary judgment, claiming qualified immunity. The district court granted the motion, finding that the troopers' actions were objectively reasonable and that no clearly established law indicated their conduct was unconstitutional.The district court found that the troopers were entitled to qualified immunity on both the constitutional and clearly established prongs. The court determined that the troopers reasonably believed Hill posed a danger by disobeying commands and reaching towards what they perceived to be a handgun. The court also concluded that there was no precedent clearly establishing that the troopers' actions were unlawful. Consequently, the court dismissed the state law tort claims, as they were dependent on the success of the federal excessive force claim.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the troopers were entitled to qualified immunity. The court found that all three Graham factors—severity of the crime, immediate threat to officers, and resisting arrest or evading arrest by flight—favored the troopers. The court also determined that there was no Supreme Court or Fourth Circuit precedent that clearly established the troopers' conduct as unconstitutional. Therefore, the judgment of the district court was affirmed. View "Benton v. Layton" on Justia Law

Lawrence Ray was convicted in the United States District Court for the Southern District of New York for multiple crimes, including racketeering conspiracy, extortion, sex trafficking, forced labor, money laundering, tax evasion, and committing a violent crime in aid of a racketeering enterprise. These convictions stemmed from Ray's operation of a criminal enterprise that targeted young adults, primarily his daughter's college roommates, for indoctrination and exploitation, including sex trafficking and forced labor in Pinehurst, North Carolina.The district court sentenced Ray to 720 months of imprisonment, followed by a lifetime term of supervised release. Ray appealed his conviction, arguing insufficient evidence to support his convictions, the unconstitutionality of the racketeering statutes, improper admission of expert testimony, and the substantive unreasonableness of his sentence.The United States Court of Appeals for the Second Circuit reviewed Ray's appeal. The court found sufficient evidence to support Ray's convictions, including the existence of an enterprise, the commission of violent crimes to maintain or increase his position in the enterprise, and the coercion of victims into sex trafficking and forced labor. The court also rejected Ray's constitutional challenge to the racketeering statutes, noting that such challenges have been consistently rejected in the past.Regarding the expert testimony, the court held that the district court did not abuse its discretion in admitting the testimony of Dr. Hughes, a clinical and forensic psychologist, who provided general background on coercive control tactics without directly linking her testimony to Ray or his victims. The court also found that the district court properly balanced the probative value of the testimony against its potential prejudicial effect.Finally, the court concluded that Ray's 720-month sentence was substantively reasonable, given the gravity of his crimes and the need for deterrence, incapacitation, and just punishment. The court affirmed the judgment of the district court. View "United States v. Ray" on Justia Law

Robert Schneider, charged with murder, filed a discovery motion under Pitchess v. Superior Court and Brady v. Maryland, seeking Brady information from the confidential personnel records of six deputies with the Los Angeles County Sheriff’s Department (LASD). The trial court found good cause for an in camera review and determined that four of the six deputies' files contained Brady material. However, the court only ordered the disclosure of the names, addresses, and phone numbers of individuals who had witnessed or complained about the conduct, not the Brady material itself.Schneider petitioned for a writ of mandate, challenging the limited disclosure. The Court of Appeal of the State of California, Second Appellate District, Division Seven, reviewed the case. The court concluded that the trial court should have ordered LASD to disclose all Brady material in the four deputies’ personnel files, including documents and any audio-video materials.The Court of Appeal held that while the Pitchess procedures must be followed to obtain Brady information in officers’ confidential personnel files, the limitations on disclosure under Pitchess do not apply to Brady material. The court emphasized that Brady material must be fully disclosed, including any relevant complaints, reports, or audio-visual evidence, to ensure the defendant's right to a fair trial. The petition was granted, directing the trial court to vacate its previous order and conduct a further in camera review to identify and produce all Brady material to Schneider’s counsel. View "Schneider v. Superior Court" on Justia Law

A woman from North Carolina was found raped and murdered in a Washington, D.C. apartment in March 2017. The victim’s body was discovered bound and stabbed, with evidence of sexual assault. Surveillance footage and ATM records showed her car and credit cards being used in the days following her death. The investigation led to the arrest of El Hadji A. Toure, whose DNA was found at the crime scene and on items used to bind the victim. Video evidence placed Toure near the victim’s apartment shortly before the crime, and he was later seen using her credit and debit cards, always entering the correct PIN. After the murder, Toure’s financial situation improved markedly, as he paid cash for a hotel stay and a car.A jury in the Superior Court of the District of Columbia convicted Toure of multiple offenses, including first-degree murder, sexual abuse, kidnapping, and related charges. He was sentenced to life without release. While his appeal was pending, Toure moved for a new trial, arguing that the government failed to timely disclose disciplinary records (QCARs) for forensic witnesses, in violation of Brady v. Maryland. The Superior Court denied the motion, finding that, even assuming suppression of favorable evidence, there was no reasonable probability the outcome would have been different given the strength of the other evidence.The District of Columbia Court of Appeals reviewed both the convictions and the denial of a new trial. The court held that, although the government failed to timely disclose impeachment evidence, the suppressed material was not material under Brady because the remaining evidence against Toure was overwhelming. The court also found that the prosecutor’s conduct in eliciting certain testimony violated Toure’s confrontation and due process rights, but concluded that any error was harmless beyond a reasonable doubt. The convictions and denial of a new trial were affirmed, with a remand for merger and resentencing as necessary. View "Toure v. United States" on Justia Law

Carey Jackson was found guilty by a DeKalb County jury of felony murder, aggravated assault, first-degree criminal damage to property, and a violation of the Street Gang Terrorism and Prevention Act in connection with the shooting death of Arnold Leslie and the assaults of seven other individuals. The crimes occurred on April 6, 2020, and Jackson was indicted on December 1, 2020. The jury found Jackson not guilty of malice murder and possession of a firearm during the commission of a felony but guilty of the remaining counts. Jackson was sentenced to life in prison with the possibility of parole for felony murder, along with additional consecutive and concurrent prison terms for the other charges.Jackson filed a motion for a new trial on January 18, 2022, which was amended through new counsel on April 9, 2024. The trial court denied the motion on June 26, 2024. Jackson then filed a notice of appeal on July 16, 2024, and the case was docketed in the Supreme Court of Georgia for the term beginning in December 2024.The Supreme Court of Georgia reviewed Jackson's claim that his trial counsel was ineffective for failing to object to a jury instruction related to the Street Gang Act. Jackson argued that the instruction created a constitutionally impermissible mandatory presumption. The court found that the instruction did not create a mandatory presumption or shift the burden of proof to the defendant. Instead, it explained the meaning of the phrase "further the interests of the gang" and required the jury to find beyond a reasonable doubt that the crime committed was the sort of crime the gang engaged in. Consequently, the court held that Jackson's trial counsel was not deficient for failing to object to the instruction and affirmed the trial court's decision. View "JACKSON v. THE STATE" on Justia Law

The defendant was pulled over by deputies in Des Moines County after they responded to a reckless-driver complaint and observed her driving erratically. The deputies noted symptoms of intoxication and conducted field sobriety tests, which the defendant failed to complete. She requested an attorney when asked to submit to a preliminary breath test and was arrested. At the jail, she was given her phone and informed of her rights, including the right to contact an attorney, but she did not make any attempt to do so.The defendant was charged with operating a motor vehicle while intoxicated (OWI), first offense. She filed a motion to suppress evidence, claiming her rights were violated under Iowa Code section 804.20 when the deputies did not permit her to call an attorney. The Iowa District Court for Des Moines County denied her motion, and the case proceeded to a jury trial. The district court also denied her motion in limine to suppress alleged hearsay evidence. The jury found the defendant guilty, and she appealed the decision, challenging the sufficiency of the evidence and the denial of her motions.The Iowa Court of Appeals affirmed the district court's decisions. The Iowa Supreme Court granted further review but adopted the court of appeals' opinion for all claims except the motion to suppress issue concerning Iowa Code section 804.20. The Supreme Court determined that Iowa Code section 804.20 was not violated, as the defendant was given a reasonable opportunity to contact an attorney without unnecessary delay. The decision of the court of appeals and the district court judgment were affirmed. View "State of Iowa v. Clark" on Justia Law

The State of Nevada charged Matthew Desavio with a felony for making threats or conveying false information concerning an act of terrorism. Desavio was found incompetent to stand trial and was ordered to be transferred for competency restoration treatment. However, the State failed to transfer him, leading to a nearly 90-day delay. Desavio moved to dismiss the charge due to this delay, and the district court initially held the Nevada Division of Public and Behavioral Health in contempt and fined them, but eventually dismissed the criminal complaint without prejudice.The Eighth Judicial District Court in Clark County reviewed the case and dismissed the criminal complaint without prejudice due to the State's failure to transfer Desavio for competency restoration treatment. The State appealed, arguing that the district court lacked a legal basis to dismiss the case under the competency statutes and the recent decision in State v. Gonzalez. The district court found that the delay violated Desavio's due process rights, which constituted ongoing prejudice.The Supreme Court of Nevada reviewed the case and affirmed the district court's decision. The court held that the dismissal without prejudice was appropriate to remedy the ongoing prejudice to Desavio's due process rights. The court noted that the district court had tried lesser sanctions, such as holding the Division in contempt and imposing fines, but these measures proved ineffective. The Supreme Court concluded that the district court did not abuse its discretion in dismissing the charge without prejudice, as it was a necessary step to address the violation of Desavio's due process rights. View "State v. Desavio" on Justia Law

Ali Tuckett sought damages from the State of New York under Court of Claims Act § 8-b, claiming unjust conviction and imprisonment. Tuckett's 2011 conviction for sexually abusing his minor cousin, N.M., was vacated after N.M. recanted his testimony in 2013, admitting he had lied. Tuckett then filed a claim for damages, asserting his innocence and that he did not cause his conviction.The Court of Claims dismissed Tuckett's claim, concluding he did not prove his innocence by clear and convincing evidence. The court excluded polygraph evidence Tuckett wanted to present and found N.M.'s recantation not credible, relying on testimony from the original investigation and trial. The Appellate Division affirmed the dismissal, agreeing that any reliance on hearsay was harmless and that the court's findings were supported by the record. Two justices dissented, believing the court improperly relied on evidence outside the record and hearsay.The New York Court of Appeals reviewed the case and affirmed the Appellate Division's decision. The court found that any potential hearsay error was harmless given the substantial non-hearsay evidence supporting the Court of Claims' decision. The court also determined that the findings of fact were supported by the record and that the Court of Claims did not improperly rely on evidence outside the record. Additionally, the court rejected Tuckett's argument that the Court of Claims applied an incorrect presumption regarding the reliability of recantation testimony, noting that the court provided specific reasons for finding N.M.'s recantation not credible.The Court of Appeals held that Tuckett failed to prove his innocence by clear and convincing evidence and affirmed the dismissal of his claim. View "Tuckett v State of New York" on Justia Law

Lawrence Davonn Foye was placed on court-supervised parole after being convicted of fleeing in a vehicle with reckless indifference. His parole conditions included not violating any laws, avoiding disreputable persons, and abstaining from drug use. In January 2023, his probation officer filed a petition to revoke his parole, alleging three violations: using marijuana, being charged with first-degree murder, and associating with a disreputable person. Following a hearing, the Circuit Court of Kanawha County revoked his parole and imposed the underlying sentence.The Circuit Court found that the State presented sufficient evidence to support the parole violations. Detective Adkins testified about the murder investigation, corroborating information from a cooperating witness with cell phone data and video footage. The court also noted that Foye did not contest the allegations of drug use and associating with a disreputable person. The court applied the "reasonable cause" standard from West Virginia Code § 62-12-10(a)(1) to revoke Foye's parole.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the Circuit Court's decision. The court clarified that the standard of proof for a final parole or probation revocation hearing under West Virginia Code § 62-12-10(a)(1) is proof by a preponderance of the evidence. The court found that the State met this standard by presenting sufficient evidence of all three parole violations. The court also addressed the procedural due process requirements, ensuring that Foye's rights were protected during the revocation process. View "State v. Foye" on Justia Law

Petitioner Jayden Demarko McDaniel, a Black individual, was charged with multiple felonies, including attempted first-degree murder and gang-related offenses. McDaniel alleged that he was disparately charged with gang enhancements due to his race, in violation of the California Racial Justice Act of 2020 (RJA). He sought discovery of evidence from the prosecution to support his claim, arguing that statistical evidence indicated a racial disparity in the application of gang enhancements in San Mateo County.The San Mateo County Superior Court denied McDaniel's motion for discovery, concluding that he failed to demonstrate "good cause" as required by the RJA. The court found that McDaniel's statistical evidence lacked context and did not provide specific facts about his case or other similar cases involving non-Black defendants. McDaniel then filed a petition for writ of mandate with the Court of Appeal, which was initially denied without prejudice. He subsequently refiled his petition, which was again denied by the superior court.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and concluded that McDaniel had met the low threshold for demonstrating good cause for discovery under the RJA. The court held that McDaniel's county-specific statistical evidence, supported by an expert declaration, presented a plausible factual foundation for his claim of racial bias in charging decisions. The court emphasized that the RJA's discovery standard is intended to be broad and flexible, allowing for various types of evidence, including statistical data, to support a claim of racial disparity.The Court of Appeal vacated the trial court's order and remanded the case for a new hearing to reconsider McDaniel's discovery motion, directing the trial court to weigh the potential probative value of the requested information against the burdens of gathering it. View "McDaniel v. Superior Court" on Justia Law