Justia Civil Rights Opinion Summaries

Articles Posted in Criminal Law
by
The case involves Joseph A. Jakuttis, a former officer and detective in the Dracut Police Department, who also served as a Task Force Officer for the federal Drug Enforcement Administration's Cross Borders Initiative. Jakuttis brought multiple federal and state claims against the Town of Dracut, certain Dracut police officers, and members of the federal law-enforcement task force. He alleged that he was demoted and faced retaliation after reporting serious criminal activities implicating two Dracut police officers, which he learned from a confidential drug informant.The United States Court of Appeals for the First Circuit affirmed the dismissal of Jakuttis's Bivens claims against Michael V. O'Hanlon and Richard P. Poirier, Jr., and his §1983 claim against the Town of Dracut, David J. Chartrand Jr., and Demetri Mellonakos. The court ruled that the defendants are entitled to qualified immunity, as they could have reasonably thought that Jakuttis was speaking as part of his official duties rather than as a private citizen when he reported the misconduct, thus not clearly violating his First Amendment rights.The court also affirmed the dismissal of Jakuttis's state-law tort claims against Poirier, as Poirier was deemed to be acting within the scope of his federal employment during the relevant times. However, the court remanded the Massachusetts Whistleblower Act claim against the Town of Dracut and the Intentional Interference with Advantageous Economic Relationship claim against Chartrand and Mellonakos to the District Court. The court reasoned that these state-law claims should be resolved by a state court due to reasons of comity. View "Jakuttis v. Town of Dracut" on Justia Law

by
This case pertains to Jeremiah Paul, a parolee, who was convicted of possession of a firearm due to his prior violent conviction, after police officers discovered a firearm in his vehicle. The discovery occurred after the officers asked him about his parole status during an encounter, which he contends was an unlawful detention that led to the discovery of the firearm. Paul argued that the evidence of the firearm should have been suppressed as it was only discovered following his unlawful detention.The Court of Appeal of the State of California, Second Appellate District, Division Five, disagreed with the trial court's ruling that the initial encounter between Paul and the police officers was consensual. The appellate court highlighted several factors such as the positioning of the police officers, their use of flashlights on Paul, the fact that Paul was engaged in a phone conversation when the officers approached, and the opening of the vehicle's door, which would have led a reasonable person to believe that they were not free to leave. This, they concluded, constituted an unlawful detention.Consequently, the appellate court reversed the trial court's ruling stating the initial encounter was consensual. The court held that Paul's motion to suppress the evidence of the firearm, which was discovered as a result of the unlawful detention, should have been granted. The court reversed the judgment, vacated the conviction, and remanded the case to the trial court with instructions to grant Paul's motion to suppress the evidence of the firearm. View "People v. Paul" on Justia Law

by
The case revolves around Lawrence Weber, who was arrested for driving under the influence of alcohol (DUI). Weber's driving privileges were suspended for 180 days by a North Dakota Department of Transportation hearing officer following his refusal to take a chemical breath test after his arrest. Weber argued that he was not provided with a reasonable opportunity to contact an attorney, which he claimed invalidated the authority of the North Dakota Department of Transportation to revoke his driving privileges.On February 26, 2023, Weber was arrested after an onsite screening test showed a blood alcohol content of .152 percent. Following his arrest, when asked to take a chemical breath test, Weber invoked his Fifth Amendment rights and requested an attorney. Despite being given access to his phone to contact his attorney, Weber made a call to an individual who refused to help him contact his attorney. Weber did not attempt to make further calls or ask for additional time to contact his attorney.The hearing officer found that Weber refused to take the chemical breath test and had a reasonable opportunity to call an attorney. The officer's findings were upheld by the district court. Weber appealed the decision, maintaining that he was not provided with a reasonable opportunity to contact an attorney.The Supreme Court of North Dakota affirmed the judgment of the district court. The court concluded that Weber was provided with a reasonable opportunity to contact an attorney and his right to counsel was satisfied. Weber's claim that he was denied the opportunity to contact an attorney was not supported by the evidence. The court found that the hearing officer's findings were supported by a preponderance of the evidence, and her conclusion that Weber was not deprived of his right to consult counsel was in accordance with the law. View "Weber v. NDDOT" on Justia Law

by
In 2002, Michael David Carruth was convicted and sentenced to death for four counts of first-degree murder, one count of attempted murder, first-degree burglary, and first-degree robbery in Alabama. Carruth appealed the denial of his habeas corpus petition, which raised six main issues. These included allegations of ineffective trial counsel for failing to investigate and present mitigating evidence during the penalty phase of his trial, and ineffective appellate counsel for failing to notify him of further available appellate proceedings and to argue that the prosecution engaged in prosecutorial misconduct. Carruth also argued that he was deprived of his right to an impartial jury and due process of law due to premature jury deliberations.The United States Court of Appeals for the Eleventh Circuit examined all the issues and affirmed the district court's denial of Carruth's habeas corpus petition. The circuit court determined that Carruth's claims did not survive deference under the Antiterrorism and Effective Death Penalty Act, as the state court's adjudications were not contrary to federal law, nor did they involve an unreasonable determination of the facts. The court also held that Carruth's claim of ineffective assistance of counsel was procedurally barred because it was not properly raised and preserved at the state level. The circuit court concluded that the nature of the crimes and the strength of the evidence against Carruth outweighed any potential mitigating evidence that may have been presented. View "Michael David Carruth v. Commissioner, Alabama Department of Corrections" on Justia Law

by
In this case before the United States Court of Appeals for the Sixth Circuit, the defendant, Charles O’Neill, appealed the judgment of the district court. O’Neill was charged with sexually exploiting a minor and receiving or distributing child pornography. He pleaded guilty to both charges but reserved the right to appeal the district court’s denial of his motion to suppress evidence obtained from his home and a barn he owned. The evidence included large numbers of photographs of nude and partially nude minor boys on O’Neill’s phone and iPad, and a computer, camcorder, camera, digital storage devices, miscellaneous clothing, and a vibrator found in the barn.The district court found that although the affidavits from the police officers used to obtain search warrants contained false statements and lacked probable cause, the officers had not knowingly or recklessly misled the issuing magistrate, and their reliance on the warrants was objectively reasonable under the good-faith exception in United States v. Leon.On appeal, the Sixth Circuit affirmed the district court's decision, agreeing that none of the exceptions to the good-faith exception applied. The court found that the officers' errors in the affidavits were negligent rather than reckless, the affidavits weren't "bare bones" as they contained more than conclusory claims and were far from devoid of factual support, and the warrants weren't facially deficient. The court noted that the officers' reliance on the search warrants was objectively reasonable, and therefore the fruits of their searches shouldn't be suppressed. The court also noted that even if it shared the dissenting judge's view on the officers' state of mind, it would likely conclude that the district court's denial of the suppression motion was proper because the remaining content of the affidavit would likely establish probable cause. View "United States v. O'Neill" on Justia Law

by
This case concerned an appeal by Matthew Ware, a former correctional officer, against the substantive reasonableness of his sentence. Ware was convicted by a jury of two counts of deprivation of rights under color of law and was sentenced to concurrent terms of 46 months of imprisonment. The United States Court of Appeals for the Tenth Circuit affirmed this sentence.Ware was a correctional officer at the Kay County Detention Center in Oklahoma. The charges against him arose from two incidents where he was found to have abused his power and caused harm to inmates. In one incident, Ware ordered the transfer of two inmates to a different level of the detention center, despite knowing that this would likely result in a fight, which it did. In another incident, Ware ordered a detainee to be handcuffed in a painful position for an extended period of time.Ware appealed his sentence, arguing that the court did not give adequate weight to his personal history and lack of criminal record. However, the Court of Appeals found that the district court had thoroughly weighed each of the sentencing factors and detailed its reasoning. The Court of Appeals held that the district court did not abuse its discretion in sentencing Ware to 46 months of imprisonment, and affirmed the sentence. View "United States v. Ware" on Justia Law

by
In a case before the United States Court of Appeals for the Fifth Circuit, Ivan Cantu, who was convicted of capital murder and sentenced to death in 2001, sought to authorize the district court to consider a successive petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2244. He claimed a violation of the Due Process Clause of the Fourteenth Amendment and suppression of evidence by the state in violation of Brady v. Maryland. The Fifth Circuit denied his motion for authorization, holding that Cantu had failed to meet the requirements of 28 U.S.C. § 2244(b)(2)(B).The court found that Cantu failed to exercise due diligence to discover the evidence he was now relying on and that he failed to provide clear and convincing evidence that no reasonable factfinder would have found him guilty. The court also noted that Cantu's last-minute filing was an attempt at manipulation and did not serve the public interest or the interest of the victims in the timely enforcement of the sentence. Consequently, the court denied Cantu's motion for a stay of execution. View "In Re: Ivan Cantu" on Justia Law

by
The case concerns an appeal by Brandon Cade against a ruling by the United States District Court for the Northern District of Illinois, Eastern Division, before the United States Court of Appeals For the Seventh Circuit. Cade was arrested by Chicago police officers who noticed an open bottle of alcohol in a sedan next to which Cade and another individual were standing. During a search of the car, officers found an unlicensed firearm and Cade admitted it was his. He was charged with possession of a firearm by a felon. Cade argued to suppress evidence of the gun and his incriminating statements, but the district court denied his motion. Cade pleaded guilty but reserved his right to appeal the suppression ruling. He argued that his initial encounter with the officers was an unlawful seizure and that his incriminating statements should be suppressed because the officers did not have reasonable suspicion to seize him.The Court of Appeals affirmed the lower court's ruling. The court found that the initial encounter with the officers was consensual and did not constitute a seizure. The court also ruled that even if there was an unlawful seizure, Cade's incriminating statements were sufficiently attenuated from any allegedly unlawful conduct. The presence of the open alcohol bottle provided probable cause for the search, which led to the discovery of the firearm, and Cade's admission to owning the firearm occurred after he was read his Miranda rights. The court concluded that there was no evidence of bad faith by the officers, and that an evidentiary hearing was not needed as there were no material factual disputes. View "United States v. Cade" on Justia Law

by
In the case of Commonwealth v. Rashad Shepherd, the Supreme Judicial Court of Massachusetts affirmed the defendant’s conviction of murder in the first degree on the theory of felony-murder, with attempted unarmed robbery as the predicate felony. The case centered around a failed robbery attempt that ended in the shooting and death of the intended victim. The defendant, along with two co-conspirators, hatched a plan to rob the victim, who was known to sell marijuana from his apartment. However, when the plan was put into motion, the victim resisted, and in the ensuing altercation, was shot and killed. The prosecution's theory was that the defendant was the shooter.In his appeal, the defendant argued that the court’s decision in a prior case, Commonwealth v. Brown, which abolished felony-murder as an independent theory of liability for murder in the first and second degrees, should be applied to his case retroactively. He maintained that not doing so violated equal protection principles as more Black individuals were serving life sentences without parole for felony-murder than white individuals. However, the court rejected this argument, noting that the decision in Brown was applied to all equally, regardless of race or ethnicity.The defendant also claimed errors in jury instructions and conduct by the trial judge, but the court determined that there was no reversible error. Lastly, the defendant argued that he received ineffective assistance of counsel, but the court found that the decisions by the defense were not manifestly unreasonable. View "Commonwealth v. Shepherd" on Justia Law

by
In this case, the defendant, June Wolverine, was charged with six misdemeanor traffic violations, including a third offense of Driving Under the Influence of Alcohol (DUI). Wolverine was unable to attend her trial due to being in federal custody. The State of Montana moved to continue the trial, but did not provide information on when Wolverine would be released from federal custody. Wolverine subsequently filed a motion to dismiss the charges due to a lack of a speedy trial, as required by Montana law. The Justice Court denied Wolverine's motion, and she pleaded guilty to the DUI charge while reserving her right to appeal the speedy trial issue. The District Court affirmed the Justice Court's denial of the motion to dismiss, ruling that Wolverine's federal incarceration had a clear causal impact on the trial delay.The Supreme Court of the State of Montana reversed the decision of the District Court. The Supreme Court held that the State had failed to demonstrate good cause for the delay in Wolverine's trial. The State knew Wolverine was in federal custody and had ample time to ask for Wolverine’s temporary release for trial or to notify the Justice Court about the looming deadline for a speedy trial. Yet, the State did nothing as the deadline passed. The Supreme Court concluded that the State did not fulfill its obligation to try the defendant in a timely manner, thus violating Wolverine's right to a speedy trial. The court reversed the District Court's decision and ruled in favor of Wolverine. View "State v. Wolverine" on Justia Law