Justia Civil Rights Opinion Summaries

The Court of Appeals affirmed the decision of the court of special appeals affirming the judgment of the circuit court denying Appellant's motion to correct an illegal sentence, holding that Appellant's sentencing proceeding complied with the constitutional protections recognized in recent decisions of the Supreme Court.In 2010, Petitioner was convicted of first-degree felony murder and other crimes for his involvement in a burglary at the age of sixteen that resulted in a murder. Petitioner was sentenced to life in prison with all but sixty years suspended for the murder conviction and will be eligible for parole at the time he is forty-two years old. In 2017, Petitioner filed a motion to correct an illegal sentence, arguing that his sentence violated the Eighth Amendment, as interpreted in recent decisions of this Court and the Supreme Court. The circuit court denied the motion, and the court of special appeals affirmed. The Supreme Court affirmed, holding that Petitioner's sentence did not amount to a de facto sentence of life without parole, and his sentence was not grossly disproportionate. View "Jedlicka v. State" on Justia Law

The Court of Appeals held that ambiguity in a sentencing court's remarks about a juvenile offender's post-offense conduct and character, when made before the Supreme Court issued its decisions governing the sentencing of a juvenile offender to life without the possibility of parole, requires that the offender receive a new sentencing hearing for purposes of the Eighth Amendment.Petitioner was seventeen years old when he committed a series of murders. In Maryland, Petitioner pled guilty to six counts of first-degree murder. The sentencing court sentenced him to the maximum sentence of six terms of life in prison without the possibility of parole. After the Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Petitioner filed a motion to correct an illegal sentence. The circuit court denied the motion. The Supreme Court remanded the case, holding that because opposing inferences could be drawn as to whether the sentencing judge determined that Petitioner was not "the rare juvenile offender whose crimes reflects irreparable corruption" for whom the Eighth Amendment allows a sentence of life without parole. View "Malvo v. State" on Justia Law

Plaintiff claimed that his Fourth Amendment rights were violated because he was detained without probable cause for driving while intoxicated. He brought suit under Section 1983, seeking damages from the officers who submitted an affidavit and incident reports to a magistrate to support his pretrial detention. The defendants moved for summary judgment, asserting the defense of qualified immunity. The district court determined that fact issues precluded summary judgment, specifically, whether the officers made false statements that Plaintiff was “operating a motor vehicle” in violation of Texas law.The Fifth Circuit reversed. Under Texas law, the inquiry when determining whether a person caused a vehicle to move must take into account “the totality of the circumstances [regarding whether] the defendant took action to affect the functioning of his vehicle in a manner that would enable the vehicle’s use.” The court explained that the officers' allegedly false statements pertained to how far the vehicle moved rather than whether it moved at all. Even if a vehicle only moved six inches, that may be sufficient to establish the operation element. View "Garcia v. Orta" on Justia Law

The Supreme Court affirmed Defendant's convictions and life sentences for first-degree murder, robbery, kidnapping, carjacking, and drug-related offenses, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant was not entitled to relief on his claims of error during jury selection; (2) the trial judge was neither biased nor prejudiced against Defendant nor his counsel during voir dire; (3) as to Defendant's claims of error during the guilt phase of his trial, he failed to establish that the trial court committed prejudicial error in its evidentiary rulings; (4) the prosecutor did not commit misconduct rendering Defendant's trial fundamentally unfair; and (5) as to the penalty phase issues raised by Defendant, there was no prejudicial error. View "People v. Ramirez" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of aggravated trafficking of scheduled drugs, holding that the trial court did not err in denying Defendant's motion to suppress, and Defendant's remaining allegations of error were unavailing.Specifically, the Supreme Judicial Court held (1) because law enforcement had probable cause to arrest Defendant, the court did not err in denying Defendant's motion to suppress; (2) the trial court did not err in determining that there was no violation of the court's sequestration order; (3) there was no obvious error in the instructions given to the jury; and (4) there was no illegality in the sentence or in the court's procedure. View "State v. Rosario" on Justia Law

The Supreme Court affirmed the decision of the postconviction court denying Defendant's motion to vacate his convictions and sentences, including three convictions for first-degree murder and three sentences of death, holding that Defendant was entitled to neither postconviction relief nor a writ of habeas corpus.In 2014, Defendant pleaded guilty to murdering his girlfriend and her two children. The trial court sentenced Defendant to death for each murder. Defendant later filed a motion for postconviction relief, which the trial court denied. Defendant appealed the court's decision and filed a petition for a writ of habeas corpus, raising two claims. The Supreme Court denied relief, holding (1) as to Defendant's petition for postconviction relief, Defendant failed to demonstrate error, deficiency, or prejudice as to any of his claims; and (2) as to Defendant's habeas corpus petition, Defendant was not entitled to relief on his claims. View "Covington v. State" on Justia Law

Plaintiff, on behalf of her son, sued District Attorney, Sheriffs, and Clay County under Section 1983 alleging that Defendants violated her son’s Fourteenth Amendment due process rights by unlawfully detaining him for years. The complaint also contends that, at one point, the Sheriff held Defendant down and forced him to take unwanted medication. As to Clay County, Plaintiff argued that Sheriffs were final policymakers, making the county liable under Monell. Defendants sought summary judgment; Plaintiff responded with a motion for partial summary judgment.   After summary judgment, the following claims remained: the detention claim against the Sheriffs and Clay County; the forced medication claim against Clay County alone. The Sheriffs and Clay County appealed. The Fifth Circuit, in treating the petition for rehearing en banc as a petition for panel rehearing, granted the petition for panel rehearing. The court dismissed Clay County’s appeal for lack of jurisdiction and affirmed the district court’s denial of summary judgment as to the Sheriffs.   The court explained that this is not a case about jailers following court orders that turned out to be unconstitutional. These Sheriffs held Plaintiff’s son in violation of a court order that followed Jackson’s commit-or-release rule. The court wrote that it cannot be that the initial detention order in a case overrides subsequent release orders and allows jailers to indefinitely hold defendants without consequence. Thus, taking the evidence in Plaintiff’s favor, the Sheriffs violated Plaintiff’s due process right by detaining him for six years in violation of the commit-or-release rule and qualified immunity thus does not protect the Sheriffs. View "Harris v. Clay County, MS" on Justia Law

The Supreme Judicial Court vacated the order of the trial court denying Defendant's motion for a new trial, holding that Defendant received constitutionally ineffective assistance of counsel during trial and that remand to the superior court was required for Defendant to receive a new trial.After a jury trial, Defendant was convicted of murder in the first degree and firearm offenses. During the trial, defense counsel disclosed confidential information to the Commonwealth regarding the location of "key incriminating evidence." Defendant filed a motion for a new trial, alleging that he had received constitutionally ineffective assistance of counsel because he had not given his counsel his informed consent to disclose the information. The superior court denied the motion. The Supreme Judicial Court vacated the superior court's judgment, holding (1) because defense counsel did not present Defendant with any other option than disclosing the existence of the incriminating evidence Defendant's purported consent to the disclosure was neither adequately informed nor voluntary; and (2) because trial counsel mistakenly believed he had a duty to disclose the incriminating evidence and did not obtain Defendant's prior consent to making that disclosure, an actual conflict of interest existed rendering the representation constitutionally ineffective. View "Commonwealth v. Tate" on Justia Law

On November 17, 1997, an Ashtabula Police dispatcher advised officers that Jones, who had outstanding felony warrants, had been spotted. Days earlier, Jones had told his cousin that he “was facing a lot of time” and “was going to shoot at the police if they ever tried to arrest him.” Officer Glover found Jones, who pulled a revolver from his pocket and fired several shots at Glover. Jones kicked Glover in the chest, then fled the scene. Officers apprehended Jones and recovered the weapon, which used hollow-point bullets. Officer Glover died the following morning.Jones was convicted of murder. During the penalty phase, Jones’s counsel presented testimony from a clinical psychologist who diagnosed Jones with Antisocial Personality Disorder and testified that Black men with this disorder (including Jones) would commit more murders—he claimed that about one in four “African-American urban males” suffered from the disorder, and the only treatment was to “throw them away, lock them up.” The jury recommended and the court imposed the death penalty. The district court denied Jones’s petition for habeas relief. The Sixth Circuit reversed. The issue of whether Jones received ineffective assistance of counsel during the penalty phase because his attorneys failed to prepare expert witnesses properly, as shown by the psychologist’s racialized testimony, was not procedurally defaulted. On de novo review of the merits, the court held trial counsel performed ineffectively and Jones is entitled to a new sentencing. View "Jones v. Bradshaw" on Justia Law

After the prosecutor used peremptory strikes against three Hispanic women during jury selection, Petitioner raised an objection pursuant to Batson v. Kentucky, 476 U.S. 79 (1986). The trial court denied the challenge, and the California Court of Appeal affirmed on direct appeal. The California Supreme Court summarily denied review.   The Ninth Circuit affirmed the district court’s denial of a California state prisoner’s habeas corpus petition raising a Batson challenge to a jury conviction. The panel held that, even if a combined race and gender class such as Hispanic women is a cognizable group for purposes of Batson, that new rule would not apply to Petitioner’s case. The panel concluded that, under circuit precedent in Cooperwood v. Cambra, 245 F.3d 1042 (9th Cir. 2001), and Turner v. Marshall, 63 F.3d 807 (9th Cir. 1995), the recognition of a mixed race and gender class would be a new rule. Teague v. Lane, 489 U.S. 288 (1989), bars the application of new constitutional rules of criminal procedure to cases that were final before the new rule was announced.   The panel further held that Petitioner did not establish a prima facie case of discrimination based on race alone because the totality of the circumstances, including a comparison between the prospective jurors the prosecutor struck and those he did not, did not raise an inference that race motivated the prosecutor to exercise a strike. Accordingly, the California Court of Appeal’s decision on Batson step one was not contrary to or an unreasonable application of clearly established federal law or an unreasonable determination of facts. View "GIANG NGUYEN V. SCOTT FRAUENHEIM" on Justia Law