Justia Civil Rights Opinion Summaries

Articles Posted in Criminal Law
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Isaiah Hammett was killed during the St. Louis Metropolitan Police Department’s (SLMPD) execution of a search warrant at his grandfather’s home. Hammett’s surviving mother and grandfather, Gina Torres and Dennis Torres (Dennis), brought Fourth Amendment excessive force and unlawful seizure claims under 42 U.S.C. § 1983, conspiracy claims under 42 U.S.C. §§ 1983 and 1985, and state law wrongful death and infliction of emotional distress claims against the City of St. Louis and multiple SLMPD officers.The district court denied the City and defendant officers’ motion for summary judgment on these claims, and they appealed. The Eighth Circuit determined it lacked jurisdiction to review the denial of qualified immunity "if at the heart of the argument is a dispute of fact." The Court found that in their essence, defendants' arguments were related to the of the sufficiency of the evidence, and whether certain opinion testimony presented at trial created a genuine issue of fact. To the extent that defendants asserted arguments beyond the scope of the Court's jurisdiction, the Eighth Circuit dismissed their appeal. On the few arguments that remained, the Court reversed the district court's denial of the defendant officers' qualified immunity claims: Dennis was not seized for purposes of the Fourth Amendment; (2) the City could not have conspired with itself through the defendant officers acting within the scope of their employment; and (3) the intracorporate conspiracy doctrine did not apply to § 1983 conspiracy claims. Judgment was dismissed in part, reversed in part, and remanded for further proceedings. View "Torres v. Coats" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of a panel of the court of appeals affirming Defendant's conviction of possession of more than 3.5 grams of methamphetamine with intent to distribute, possession of a firearm within ten years of a prior felony conviction, and two counts of drug paraphernalia possession, holding that insufficient evidence supported Defendant's firearm possession conviction.On appeal, Defendant raised six allegations of error. The Supreme Court reversed in part, holding (1) the panel erred when it refused to consider for the first time on appeal the legal appropriateness of an intent-to-distribute instruction and the instruction's permissive inference was legally inappropriate, but this error was not prejudicial; (2) Defendant's constitutional challenges failed; (3) there was insufficient evidence to support Defendant's firearm conviction; and (4) Defendant was not entitled to relief on his remaining claims of error. View "State v. Valdez" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the decision of the circuit court convicting Defendant on the charge of first-degree intentional homicide with use of a dangerous weapon and being a felon in possession of a firearm, holding that Defendant's Sixth Amendment right to counsel was not violated.At issue was whether Defendant's constitutional right to counsel was violated when a jail inmate secretly recorded conversations with Defendant and when the State admitted those recordings into evidence. The court of appeals reversed on grounds of ineffective assistance of counsel, concluding that trial counsel's failure to seek suppression of the recording fell below an objective standard of reasonableness. The Supreme Court reversed, holding that Defendant's Sixth Amendment right to counsel was not violated because Defendant was not acting as a State agent when he recorded his conversations with Defendant. View "State v. Arrington" on Justia Law

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The Supreme Court affirmed the judgment the district court denying postconviction relief sought by Defendant without conducting an evidentiary hearing, holding that the district court did not abuse its discretion by failing to hold an evidentiary hearing on Defendant's claims.Defendant was convicted of three counts of first-degree murder and sentenced to death on each murder conviction. Defendant later filed what the district court referred to as his fifth postconviction motion, alleging (1) after the Legislature passed L.B. 268 abolishing the death penalty and when L.B. 268 was subsequently repeated by public referendum, his constitutional rights were violated; and (2) he was constitutionally ineligible for imposition of the death penalty under Atkins v. Virginia, 536 U.S. 304 (2002). The court summarily denied relief on both claims. The Supreme Court affirmed, holding (1) the district court properly found that Defendant's Atkins claim was both procedurally barred and time barred; and (2) Defendant's L.B. 268 claim was meritless. View "State v. Lotter" on Justia Law

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The Court of Appeal affirmed the judgment of the trial court convicting Defendant of the involuntary manslaughter of his girlfriend, holding that no violation of Brady v. Maryland, 373 U.S. 83 (1963), occurred in this case.During trial, the county medical examiner opined that the victim had been beaten to death, and the district court relied on that testimony in arguing that Defendant beat his girlfriend to death, thereby committing first-degree murder. On appeal, Defendant challenged the trial court's failure to disclose certain portions of redacted memoranda written by the office of the district attorney as material relevant to impeachment of the medical examiner's trial testimony. The Court of Appeal affirmed, holding that, although portions of the redacted memoranda qualified as impeachment material under Brady, the failure to disclose them was not material to the outcome at trial. View "People v. Deleoz" on Justia Law

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The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions on the grounds that his counsel had been ineffective, holding that errors on the part of trial counsel did not prejudice Defendant.Defendant was convicted of murder and several related charges. The court of appeals vacated the convictions, determining that trial counsel was ineffective in failing to object to the use of evidence about Defendant's silence while being arrested and in not objecting to the manslaughter jury instruction, prejudicing Defendant. The Supreme Court reversed, holding (1) defense counsel was ineffective for not objecting to the manslaughter jury instruction, which incorrectly shifted the burden of proof for imperfect self-defense, but the error was not prejudicial; and (2) assuming that defense counsel was ineffective for failing to object to commentary by the prosecution in Defendant's silence after arrest, the error was not prejudicial. View "State v. Bonds" on Justia Law

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The Supreme Court quashed the decision of the Third District Court of Appeal affirming Defendant's convictions of driving under the influence (DUI) causing damage to property or person and DUI causing serious bodily injury, holding that Defendant's dual convictions violated double jeopardy.On appeal, Defendant argued that his dual convictions arising from a single episode violated double jeopardy. The Third District affirmed, holding that principles of double jeopardy did not prohibit dual convictions and sentences for DUI property damages/bodily injury and DUI serious bodily injury arising from the commission of a single act. The Supreme Court reversed, holding (1) the criminal offenses of DUI causing damage to property or person and DUI causing bodily injury are degree variants of the same offense under Fla. Stat. 775.021(4)(b)2; and (2) Defendant's dual convictions for both offenses as to the same victim arising from a single episode violated the prohibition against double jeopardy. View "Velazco v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying the guilt-phase claims Kim Jackson raised in his motion for postconviction relief filed under Fla. R. Crim. P. 3.851 and denied Jackson's petition for a writ of habeas corpus, holding that Jackson was not entitled to relief.After a jury trial, Jackson was found guilty of first-degree murder and sentenced to death. The Supreme Court affirmed. Jackson subsequently filed a postcondition motion raising more than twenty claims for relief. The circuit court vacated Jackson's death sentence under Hurst v. State, 202 So. 3d 40 (Fla. 2016), and otherwise affirmed. The Supreme Court affirmed and denied habeas corpus relief, holding (1) a due process claim for preindictment delay requires a showing of substantial prejudice to the defendant and bad faith on the part of the State; (2) as to two of Jackson's claims of ineffective assistance of counsel this Court assumed deficient performance but found no prejudice; and (3) Jackson was not entitled to a writ of habeas corpus. View "Jackson v. State" on Justia Law

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After a three-and-a-half-year delay, a jury convicted Appellant of conspiring to launder the proceeds generated by a network of Brooklyn medical clinics. Appellant appealed his conviction and sentence. He argued that the district court erred when it denied his motions to dismiss based on violations of the Speedy Trial Act, 18 U.S.C. Section 3161 et seq. Specifically, Appellant claimed that the district court improperly excluded time based on the complexity of the case without determining, on the record, why the case was complex or that such exclusions outweighed the best interest of the public and the defendant in a speedy trial. He contended that the excessive pre-trial delay, to which he objected, arose not from the supposed complexity of the prosecution but rather because the Government delayed production of certain documents possessed by state and federal agencies that had participated in the joint investigation and prosecution of Appellant.   The Second Circuit reversed the district court’s judgment of conviction, vacated Appellant’s conviction and sentence, and remanded to the district court. The court held that the district court’s exclusion of time during at least two long periods of delay was insufficient under the Speedy Trial Act.   The court explained that the Speedy Trial Act was designed to enforce the Sixth Amendment’s guarantee that the accused shall enjoy the right to a speedy trial. Here, the district court failed in this responsibility. It neither held the Government accountable for its discovery obligations nor appropriately considered the causes and implications of the extraordinary delays introduced by the Government’s dilatory conduct of discovery. View "United States v. Pikus" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder arising from events in 1990 after his fourth trial, held almost thirty years after the crime, holding that Defendant was not entitled to relief on any of his claims of error.On appeal, Defendant argued that his conviction must be reversed due to juror misconduct, the improper admission of certain testimony, the erroneous exclusion of hearsay evidence, and a violation of due process. The Supreme Court disagreed and affirmed his conviction, holding that none of Defendant's allegations of error warranted reversal of his convictions. View "State v. Liggins" on Justia Law