Justia Civil Rights Opinion Summaries

Dennis Christopher Howard sued Spotsylvania County Sheriff Roger L. Harris and Deputy David Setlock for injuries from a self-inflicted gunshot wound while detained in a law enforcement vehicle. Howard claimed Harris was responsible for Setlock’s actions, which he argued constituted gross negligence. The incident began when Howard, a convicted felon, was found with a suicide note and missing shotgun. After being detained and searched, Howard maneuvered his handcuffs, accessed a handgun left in the vehicle, and shot himself.The Circuit Court of Spotsylvania County granted summary judgment for the defendants, ruling that Howard’s gross negligence claim failed as a matter of law and that the defense of illegality barred his claims. The court found that Setlock’s actions did not amount to gross negligence and that Howard’s injuries resulted from his illegal act of possessing a firearm as a convicted felon.The Court of Appeals of Virginia reversed the circuit court’s decision, holding that Howard had stated a viable gross negligence claim and that his claim was not barred by the illegality defense. The appellate court found that there was a genuine dispute of material fact regarding Howard’s mental state and whether it negated the mens rea required for the illegal possession of a firearm.The Supreme Court of Virginia reviewed the case and concluded that Howard’s claim was barred by the defense of illegality. The court held that Howard’s violation of Code § 18.2-308.2, which prohibits convicted felons from possessing firearms, was a proximate cause of his injuries. The court reversed the judgment of the Court of Appeals and entered final judgment for the defendants, finding that Howard’s allegation of an “unsound mind” did not negate the strict liability offense of possessing a firearm as a convicted felon. View "Harris v. Howard" on Justia Law

John A. Poole was convicted in 2002 of first-degree murder, being a felon in possession of a firearm, and possession of a firearm during the commission of a felony. He was 18 years old at the time of the crime and was sentenced to life imprisonment without the possibility of parole. The Michigan Court of Appeals affirmed his convictions, and the Michigan Supreme Court denied his application for leave to appeal. Poole filed multiple motions for relief from judgment, which were denied.Following the U.S. Supreme Court's decisions in Miller v. Alabama and Montgomery v. Louisiana, which addressed mandatory life sentences for juveniles, Poole sought relief again. The Michigan Supreme Court remanded the case to the Court of Appeals to determine if Poole was entitled to relief under the state constitution's prohibition on cruel or unusual punishment, as extended to 18-year-olds in People v. Parks. The Court of Appeals held that Parks applied retroactively and vacated Poole's sentence, remanding for resentencing.The Michigan Supreme Court reviewed whether Parks should apply retroactively to cases where the period for direct review had expired. The court held that Parks, which extended Miller's protections to 18-year-olds under the Michigan Constitution, announced a substantive rule and should be applied retroactively. The court overruled the state retroactivity analysis in People v. Carp to the extent it survived Montgomery. The court affirmed the Court of Appeals' decision to vacate Poole's sentence and remanded the case for resentencing under MCL 769.25a. View "People Of Michigan v. Poole" on Justia Law

Kalel Martínez-Bristol was indicted on June 24, 2021, for being a felon in possession of a firearm and ammunition, and for possession of a machinegun. At the time, he was on federal supervised release for a 2011 drug conspiracy conviction. He pled guilty to the felon-in-possession charge on September 9, 2022. The presentence report identified the firearm as a pistol with a machinegun conversion device. Martínez did not object to the report. On February 6, 2023, he was sentenced to 46 months' imprisonment for the felon-in-possession conviction.The District Court for the District of Puerto Rico also addressed the supervised release violation. The government argued it was a Grade A violation due to the machinegun, while Martínez argued for a Grade B violation. The court initially granted a continuance for further evidence. At the continued hearing, the government presented evidence that the firearm was a machinegun, which Martínez did not cross-examine. The court determined it was a Grade A violation and sentenced Martínez to 15 months' imprisonment, consecutive to his other sentence.The United States Court of Appeals for the First Circuit reviewed the case. Martínez waived any appeal regarding his felon-in-possession conviction and sentence by not briefing those issues. He argued that his due process and confrontation rights were violated in the revocation hearing, but the court found no error. The court noted that Martínez had the evidence months before the hearing and did not object. The court affirmed the judgments, finding the government's evidence sufficient to establish the firearm as a machinegun. View "United States v. Martinez-Bristol" on Justia Law

Robert Arthur McIntosh, a Black man, sought the appointment of counsel to assist him in prosecuting a petition for writ of habeas corpus in superior court, raising claims under the California Racial Justice Act (RJA). He alleged that the San Diego District Attorney’s Office charged gang and firearm enhancements more frequently against Black individuals and imposed longer sentences on them compared to similarly situated individuals of other races. McIntosh supported his claims with statistical data and reports. The trial court denied his request for counsel, stating he had not made the prima facie showing required for an order to show cause (OSC).The trial court ruled that section 1473(e) of the Penal Code required a prima facie showing of a violation for the appointment of counsel and issuance of an OSC. McIntosh then petitioned the California Court of Appeal, Fourth Appellate District, Division One, for a writ of habeas corpus. The appellate court issued an OSC limited to whether McIntosh was entitled to appointed counsel under section 1473(e).The California Court of Appeal, Fourth Appellate District, Division One, held that section 1473(e) imposes a duty on trial courts to assess the adequacy of the factual allegations in the habeas petition to determine if an indigent petitioner is entitled to appointed counsel, independent of the prima facie showing required for an OSC. The court found that the trial court erred by conflating these two inquiries. The appellate court exercised its discretion to construe McIntosh’s petition for writ of habeas corpus as a petition for writ of mandate and issued a writ directing the trial court to conduct the required inquiry to determine if McIntosh is entitled to appointed counsel. View "McIntosh v. Super. Ct." on Justia Law

On October 21, 2021, Officers Nicholas Stevens and Jason Purkapile of the Sioux Falls Police Department stopped a vehicle with an inoperable brake light. The driver, Lee Martin Holy, provided a North Dakota driver’s license but no proof of insurance. Officer Stevens returned to his patrol car to run routine checks and issue a warning ticket. Meanwhile, Officer Purkapile engaged in conversation with Holy’s grandfather, the passenger, and initiated a warrant check on him. When Officer Stevens returned to Holy’s vehicle, he asked about contraband and requested to search the car. Holy admitted to having marijuana and a medical cannabis card. A subsequent search revealed a methamphetamine pipe and methamphetamine, leading to Holy’s arrest.The Circuit Court of the Second Judicial Circuit in Minnehaha County denied Holy’s motion to suppress the evidence, concluding that the stop was not unreasonably extended by the interdiction questions. The court found that the duration of the stop was not unduly prolonged and that the warrant check on Holy’s grandfather was still pending when Holy admitted to possessing marijuana. Holy was found guilty of possession of a controlled substance and drug paraphernalia based on stipulated facts and was sentenced to supervised probation and court costs.The Supreme Court of the State of South Dakota reviewed the case and affirmed the circuit court’s decision. The court held that the interdiction questions did not extend the length of the stop beyond the time necessary to complete the mission, as the warrant check on the passenger was still pending. The court did not address whether a routine warrant check for a passenger is permissible under the Fourth Amendment, leaving that determination for another case. View "State v. Holy" on Justia Law

Texas Game Warden Dustin Delgado arrested Joshua McClain for driving while intoxicated after observing his truck swerve and conducting field sobriety tests. McClain later sued Delgado for false arrest. The district court denied Delgado qualified immunity. However, because McClain did not carry his burden to show Delgado violated his constitutional rights, the United States Court of Appeals for the Fifth Circuit reversed the district court's decision.The United States District Court for the Western District of Texas initially reviewed the case. Delgado moved for summary judgment on both the false arrest and malicious prosecution claims, arguing that he was entitled to qualified immunity. The district court granted the motion for the malicious prosecution claim but denied it for the false arrest claim. Delgado appealed the denial of qualified immunity for the false arrest claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Delgado had reasonable suspicion to stop McClain based on his swerving and probable cause to arrest him after observing clues of intoxication during field sobriety tests. The court found that McClain did not establish a genuine dispute of material fact regarding whether Delgado's conduct violated the Fourth Amendment. Consequently, the court reversed the district court's denial of Delgado's motion for summary judgment, granting Delgado qualified immunity. View "McClain v. Delgado" on Justia Law

Frederick Marsalia Rosenau was convicted of felony murder and a violation of the Street Gang Terrorism and Prevention Act in connection with the shooting death of Quincy Suggs. Suggs was shot and killed on September 16, 2014. Rosenau, along with co-defendants Lavarr Pierce, Khadijah Jenkins, and Julius Lofton, was charged with multiple offenses, including malice murder, felony murder, aggravated assault, arson, and gang-related activities. Lofton pled guilty to voluntary manslaughter and testified against the others. Rosenau, Pierce, and Jenkins were tried together, and the jury found Rosenau guilty of felony murder, aggravated assault, and a gang act violation. He was sentenced to life in prison without parole for felony murder and an additional 15 years for the gang act violation.Rosenau filed a motion for a new trial, which was denied by the trial court. He then appealed to the Supreme Court of Georgia, arguing that the evidence was insufficient to support his gang act conviction, that the trial court erred in denying his motion for mistrial after the prosecutor commented on his silence, and that his trial counsel was ineffective for not retaining a gang expert and for not objecting to certain testimony.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Rosenau's gang act conviction. The court held that the trial evidence established the existence of a criminal street gang, Rosenau's association with the gang, and that the aggravated assault of Suggs was intended to further the gang's interests. The court also found that the trial court did not abuse its discretion in denying Rosenau's motion for mistrial, as the curative instruction given to the jury was sufficient. Lastly, the court concluded that Rosenau's trial counsel was not ineffective, as the decisions made were reasonable trial strategies. The Supreme Court of Georgia affirmed Rosenau's convictions. View "Rosenau v. State" on Justia Law

Charles Warner was convicted in federal district court in New Mexico for being a felon in possession of a firearm and dealing in firearms without a license. Warner appealed his conviction on four grounds: he argued that he was not prohibited from owning firearms under 18 U.S.C. § 922(g), that his suppression challenge regarding evidence seized at his house was improperly denied, that the evidence was insufficient to convict him of dealing in firearms without a license, and that the number of firearms in his possession was improperly counted.The United States District Court for the District of New Mexico denied Warner's pre-trial motion to dismiss the felon-in-possession charge and his motion to suppress evidence seized from his computers. At trial, Warner testified that he knew he was a convicted felon but did not know he was prohibited from possessing firearms under federal law. The jury convicted Warner on both counts. At sentencing, the district court applied a sentencing enhancement for possessing between 25 and 99 firearms, based on expert testimony, and sentenced Warner to 33 months' imprisonment.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that Warner is a "prohibited person" under § 922(g) because he has two prior state-law felony convictions for which he could have been sentenced to more than one year of imprisonment and has not had all of his civil rights restored. The court also rejected Warner's constitutional challenge to § 922(g), holding that it is foreclosed by recent Tenth Circuit precedent. The court found that any alleged error in the denial of Warner's suppression motion was harmless because none of the evidence Warner sought to suppress was used in the prosecution's case-in-chief. The court also held that the evidence was sufficient to convict Warner of dealing in firearms without a license and affirmed the district court's application of the sentencing enhancement for possessing between 25 and 99 firearms. Accordingly, the Tenth Circuit affirmed Warner's conviction and sentence. View "United States v. Warner" on Justia Law

Abelardo Rodriguez-Arvizu was arrested by U.S. Border Patrol agents on November 18, 2019, for a suspected immigration violation. During processing, an outstanding arrest warrant related to his involvement in a marijuana "rip crew" was discovered. He was subsequently arrested by FBI agents, who did not inform him of the specific charges. During the ride to the FBI office, Rodriguez-Arvizu made incriminating statements. At the FBI office, he was read his Miranda rights, and he made further statements after waiving his rights.The United States District Court for the District of Arizona denied Rodriguez-Arvizu's motion to suppress his statements. The court found that although the FBI agents violated Fed. R. Crim. P. 4(c)(3)(A) by not informing him of the charges, suppression was not warranted. The court also found no violation of his Fifth Amendment right to counsel, as he did not unambiguously invoke this right. Additionally, the court determined that he validly waived his Sixth Amendment right to counsel despite not knowing the specific charges. Finally, the court ruled that his confession was within the safe harbor period of 18 U.S.C. § 3501(c) and did not violate the McNabb-Mallory rule.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The Ninth Circuit held that suppression was not warranted for the Rule 4(c)(3)(A) violation, as the agents' conduct was not sufficiently deliberate or culpable. The court also agreed that Rodriguez-Arvizu did not unambiguously invoke his Fifth Amendment right to counsel and that he validly waived his Sixth Amendment right. The court further held that the safe harbor period began with his FBI arrest, making his confession admissible. View "USA V. RODRIGUEZ-ARVIZU" on Justia Law

In 2001, Morris Mullins, then seventeen, killed a seventy-eight-year-old widow, Amy Davis, in her home. He was charged as an adult with rape and aggravated murder. Mullins pled guilty to aggravated murder in exchange for the State dropping the rape charge and not seeking the death penalty. He was sentenced to life without parole (LWOP). At sentencing, the court considered evidence of Mullins's dysfunctional upbringing and psychological evaluations but ultimately imposed a juvenile life without parole (JLWOP) sentence.Mullins later challenged his sentence as unconstitutional, citing the Eighth Amendment and the Utah Constitution. In 2013, he filed a pro se motion to correct an illegal sentence under rule 22(e) of the Utah Rules of Criminal Procedure, arguing that his sentence was unconstitutional under Miller v. Alabama, which held that mandatory JLWOP for juveniles violated the Eighth Amendment. The district court denied his motion in 2016, and Mullins's appeal was delayed until 2020 due to ineffective assistance of counsel.The Utah Supreme Court reviewed the case, focusing on whether Mullins's JLWOP sentence was constitutional. The court held that the sentencing judge's comments suggested ambiguity about Mullins's capacity for change, which undermined confidence in the appropriateness of the JLWOP sentence. The court vacated Mullins's sentence and remanded for resentencing, emphasizing the need to consider Mullins's youth and potential for rehabilitation in light of Miller and its progeny. The court did not find the sentencing statute unconstitutionally vague or the JLWOP categorically unconstitutional but required a more thorough consideration of Mullins's youth and potential for change. View "State v. Mullins" on Justia Law