Justia Civil Rights Opinion Summaries

David Wood was convicted of capital murder and sentenced to death in 1992 for the brutal murders of six females in 1987. The victims were found buried near El Paso, and evidence indicated that Wood had sexually assaulted them before killing them. Wood's conviction and sentence were affirmed by the Texas Court of Criminal Appeals (CCA). Over the years, Wood pursued extensive litigation in state and federal courts, including multiple motions for post-conviction DNA testing under Chapter 64 of the Texas Code of Criminal Procedure. The trial court granted some of his motions, but the results did not exonerate him. Subsequent motions were denied, and the CCA affirmed these denials, concluding that Wood had engaged in a pattern of piecemeal litigation and delay.Wood then filed a 42 U.S.C. § 1983 suit in the United States District Court for the Western District of Texas, alleging that the CCA's construction of Chapter 64 violated his procedural due process rights. He claimed that the CCA's consistent denial of DNA testing rendered the state-created testing right illusory and that the CCA's interpretation of the statute's unreasonable-delay provision was novel and unforeseeable. The district court dismissed Wood's complaint and denied his motion to stay his execution.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that Wood lacked standing for his first claim because a favorable ruling would not substantially likely lead to DNA testing. For his second claim, the court found it meritless, as the CCA's interpretation of the unreasonable-delay provision was neither novel nor unforeseeable. Consequently, the Fifth Circuit affirmed the district court's order and judgment and denied Wood's renewed motion to stay his execution. View "Wood v. Patton" on Justia Law

In 1995, Garr Keith Hardin and Jeffrey Clark were convicted of murdering Rhonda Sue Warford based on forensic evidence and witness testimonies. Robert Thurman, a forensic serologist, testified that a hair found at the crime scene was similar to Hardin’s hair. After over two decades in prison, DNA testing revealed that the hair did not belong to Hardin, leading a state court to vacate their convictions. Hardin and Clark then sued Thurman under 42 U.S.C. § 1983, alleging that he failed to disclose observation notes that suggested the hair might not have matched Hardin’s hair sample, violating his obligations under Brady v. Maryland.The United States District Court for the Western District of Kentucky denied Thurman’s qualified-immunity defense for Hardin’s Brady claim but granted summary judgment on other claims. The court found that a reasonable jury could determine that Thurman should have recognized the exculpatory value of his notes and that the notes were material to Hardin’s defense. The court also held that Thurman could not invoke qualified immunity because Hardin’s Brady rights were clearly established before 1992.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s decision in part and dismissed in part for lack of jurisdiction. The Sixth Circuit held that it lacked jurisdiction to review Thurman’s arguments that the notes were not exculpatory or material, as these were mixed questions of law and fact. However, the court rejected Thurman’s argument that the law in the mid-1990s did not clearly establish that Brady’s duty of disclosure applied to forensic scientists, affirming that such duties were clearly established and applicable to Thurman. View "Clark v. Louisville-Jefferson County Metro Government" on Justia Law

Defendant-Appellant Kenston Harry was convicted of possessing controlled substances with intent to distribute and conspiracy to distribute the same. The case centers on the use of a stationary pole camera by the Drug Enforcement Administration (DEA) to monitor the exterior of Harry's business, Action Audio, for approximately 50 days without a warrant. The camera captured footage of the business's exterior, parking lot, and occasionally the interior when the garage door was open. Harry was arrested after investigators found narcotics and firearms at Action Audio and his residence.The United States District Court for the District of Connecticut denied Harry's motion to suppress the pole-camera evidence, which was introduced at trial. The jury convicted Harry, and the district court sentenced him to ten years for the fentanyl- and cocaine-related charges, including conspiracy, and five years for the marijuana charge, to run concurrently. The court also denied Harry's request for safety-valve relief from the mandatory minimum sentence under 18 U.S.C. § 3553(f).The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the use of the stationary pole camera did not constitute a Fourth Amendment search, as Harry did not have a reasonable expectation of privacy in the publicly visible areas of his business. The court also found that the district court did not err in denying Harry safety-valve relief, as he failed to prove that the firearms found were not connected to his drug-trafficking activities. The Second Circuit affirmed the judgment of the district court. View "United States v. Harry" on Justia Law

Triston Harris Steinman was stopped by Nevada State Trooper William Boyer for speeding. During the stop, Boyer observed an ammunition box in Steinman's car and learned that Steinman had a felony conviction. Boyer asked Steinman to exit the vehicle and sit in the patrol car while he ran a criminal history check. Steinman admitted to having ammunition but denied having firearms. Boyer eventually seized the car and obtained a search warrant, leading to the discovery of firearms, ammunition, and other contraband.The District Court for the District of Nevada suppressed the evidence, ruling that Boyer unlawfully prolonged the traffic stop without reasonable suspicion and lacked probable cause to seize the vehicle. The court also found the search warrant overbroad and invalid.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that Boyer did not unlawfully prolong the stop, as his actions were within the scope of the traffic stop's mission and did not measurably extend its duration. The court also found that Boyer had reasonable suspicion of an independent offense after learning of Steinman's felony conviction. Additionally, the court ruled that Boyer had probable cause to seize the vehicle based on evidence of federal and state law violations. The court concluded that the search of the vehicle was permissible under the automobile exception to the Fourth Amendment's warrant requirement, despite the overbroad warrant. Thus, the suppression of the evidence was reversed. View "USA V. STEINMAN" on Justia Law

Yathomas Riley was convicted of malice murder and other crimes related to the shooting death of his wife, Dr. Lisa Marie Riley, in the presence of their infant son. The crimes occurred on June 14 and July 9, 2015. Riley was indicted on multiple counts, including malice murder, felony murder, and aggravated assault. After a jury trial, Riley was found guilty on all counts and sentenced to life in prison without parole, along with additional consecutive and concurrent prison terms for other charges.Riley filed a motion for a new trial, which was denied by the trial court. He then appealed to the Court of Appeals, which transferred the case to the Supreme Court of Georgia. The Supreme Court remanded the case to the trial court to determine if Riley knowingly and voluntarily chose to represent himself on appeal. The trial court confirmed this, and the case was resubmitted to the Supreme Court.The Supreme Court of Georgia reviewed Riley's claims, including the trial court's decision to allow the lead investigator to remain in the courtroom, the presentation of allegedly false evidence, and claims of ineffective assistance of counsel. The court found no abuse of discretion in allowing the investigator to stay, as he was the State's chief investigative agent. Riley's claims about false evidence and perjured testimony were either not preserved for appeal or lacked supporting evidence. The court also found that Riley failed to demonstrate that his trial counsel's performance was deficient or that any alleged deficiencies prejudiced his defense.Riley's claim that his trial counsel conceded guilt in violation of McCoy v. Louisiana was also rejected. The court concluded that counsel did not concede guilt but rather argued alternative theories to support acquittal, which did not violate Riley's Sixth Amendment rights. The Supreme Court of Georgia affirmed Riley's convictions and sentences. View "RILEY v. THE STATE" on Justia Law

Elijah Jackson, a Black man, was charged with carrying a loaded firearm after police found a handgun during a search of the car he was driving. Jackson filed a motion under the California Racial Justice Act of 2020, arguing that the police stopped and searched his car due to racial bias. The superior court denied his motion, stating that Jackson failed to establish a prima facie violation under the Racial Justice Act.The superior court found that the police officers were conducting a saturation patrol in a high-crime area and stopped Jackson for having illegally tinted windows. The officers observed Jackson and his brother, who were wearing clothing associated with gang members, and conducted a traffic stop. During the stop, the officers found a baseball bat in the car and, after a search, discovered an unregistered loaded firearm. Jackson argued that the stop and search were racially motivated, supported by statistical evidence showing racial disparities in traffic stops and searches by the San Diego Police Department (SDPD).The Court of Appeal, Fourth Appellate District, reviewed the case and concluded that Jackson had produced facts that, if true, established a substantial likelihood of a violation of the Racial Justice Act. The court noted the statistical evidence showing racial disparities in SDPD's traffic stops and searches, as well as Jackson's and his brother's repeated stops for the same tinted windows without receiving citations. The court also considered the officers' focus on Jackson's and his brother's appearance and the neighborhood they were in, which suggested implicit bias.The Court of Appeal issued a writ of mandate directing the superior court to grant an evidentiary hearing to consider Jackson's motion under the Racial Justice Act. The court emphasized the importance of addressing implicit bias in the criminal justice system and ensuring that race does not play a role in seeking or obtaining convictions. View "Jackson v. Super. Ct." on Justia Law

Breion Woodson was convicted in Wisconsin state court on charges of firearm and drug possession and sentenced to 19 years in prison. During sentencing, the government presented a video from social media showing men with guns and drugs, which the judge used to assess Woodson's character and danger to the community. Woodson argued that he was misidentified in the video, but the judge denied his motion for a new sentencing hearing. The Wisconsin Court of Appeals affirmed, stating Woodson failed to prove he was not the man in the video.Woodson then filed a federal habeas corpus petition in the Eastern District of Wisconsin, introducing booking photos from the time of his sentencing that suggested he was not the man in the video. However, the district court ruled it could not consider the photos since they were not presented in state court and denied his petition, finding the state appellate court's decision reasonable based on the evidence it had.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that under the Antiterrorism and Effective Death Penalty Act (AEDPA), habeas relief is unavailable unless the state court's decision was contrary to or an unreasonable application of federal law or based on an unreasonable determination of facts. The court found that Woodson's claim was not procedurally defaulted and that the actual innocence exception did not apply to his case. The court also ruled that it could not consider the new evidence (booking photos) under AEDPA's strict limitations. Consequently, the Seventh Circuit affirmed the district court's denial of Woodson's habeas petition. View "Woodson v Mlodzik" on Justia Law

David Paul Planchard was convicted by a jury of stalking Debra Doe and violating a protective order. Planchard and Doe had a relationship from 1997 to 2000 and had a son together in 2006. Despite a restraining order issued in 2020, Planchard continued to harass Doe through public Facebook posts from 2016 to 2023. These posts included threats, derogatory comments, and references to Doe's past trauma. Planchard also showed up at Doe's house in May 2023, violating the protective order.The Superior Court of Sacramento County found Planchard guilty of stalking and violating a protective order. The jury determined that Planchard's actions, including his Facebook posts and visit to Doe's house, constituted a credible threat and harassment. The court sentenced him to five years for stalking and a stayed term of six months for violating the protective order.The California Court of Appeal, Third Appellate District, reviewed the case. Planchard argued that his Facebook posts did not constitute direct contact and thus could not be considered harassment under the stalking statute. The court disagreed, citing precedent that indirect threats and harassment through third parties or public posts can still meet the statutory requirements for stalking. The court found sufficient evidence to support the jury's verdict, noting that the posts were intended to harass and threaten Doe, and it was reasonably foreseeable that she would see them.The court also addressed Planchard's claims of ineffective assistance of counsel, finding no merit in his arguments. The court concluded that the Facebook posts were relevant and admissible, and that any failure to object by his counsel did not constitute ineffective assistance. The judgment of the Superior Court was affirmed. View "P. v. Planchard" on Justia Law

Christopher Kee was convicted of assault with a dangerous weapon in Indian country following an altercation with his then-girlfriend, Candace Chinchillas, in April 2020. The couple had a tumultuous relationship marked by excessive drinking and mutual accusations of abuse. Kee claimed that the stabbing incident was an act of self-defense, while Chinchillas described it as a violent attack. Kee was acquitted of three other counts of assault, which had more corroborative evidence, but was convicted on Count 2, which relied heavily on the conflicting testimonies of Kee and Chinchillas.The United States District Court for the District of New Mexico presided over Kee's trial. Kee did not object during the trial to the prosecution's use of his post-Miranda silence to impeach his testimony. After being convicted and sentenced, Kee filed a timely appeal, arguing that his due process rights were violated under Doyle v. Ohio, which prohibits the use of a defendant's post-Miranda silence for impeachment purposes.The United States Court of Appeals for the Tenth Circuit reviewed Kee's appeal. The court agreed with Kee that the prosecution's repeated references to his post-Miranda silence constituted a clear violation of Doyle. The court applied the plain error review standard, which requires showing that the error was plain, affected substantial rights, and seriously affected the fairness, integrity, or public reputation of judicial proceedings. The court found that the Doyle violation affected Kee's substantial rights because the case hinged on the credibility of Kee and Chinchillas, and the improper impeachment could have influenced the jury's verdict.The Tenth Circuit vacated Kee's conviction and sentence and remanded the case for further proceedings consistent with its opinion. View "United States v. Kee" on Justia Law

In the early morning of October 23, 2013, Colleen Ritzer, a Danvers High School math teacher, was found dead in the woods outside the high school. She had been raped, strangled, and stabbed. The defendant, a fourteen-year-old student in her class, was convicted by a Superior Court jury of first-degree murder, aggravated rape, and armed robbery. The primary issue at trial was whether the defendant lacked criminal responsibility due to mental illness.The defendant appealed, arguing that the trial judge impeded his ability to present his defense. He raised several issues: the exclusion of expert testimony on brain scans, limitations on expert testimony regarding his statements, improper cross-examination of defense experts, forced disclosure of psychological test data, the use of suppressed statements by the Commonwealth's expert, the denial of a jury instruction on adolescent brain development, insufficient evidence for the aggravated rape and armed robbery convictions, the denial of a motion to suppress evidence, improper prosecutorial conduct in closing arguments, the denial of a change of venue due to pretrial publicity, and the proportionality of his sentence under the Massachusetts Declaration of Rights.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the convictions. The court held that the exclusion of the brain scan evidence was within the judge's discretion due to its limited probative value and potential for unfair prejudice. The limitations on expert testimony were also upheld, since the defendant was able to present sufficient evidence of his mental state. The court found no abuse of discretion in the cross-examination of defense experts or the disclosure of psychological test data. The use of the suppressed statements by the Commonwealth's expert did not warrant exclusion of the testimony. The court also found no error in the denial of the jury instruction on adolescent brain development, the sufficiency of the evidence for the aggravated rape and armed robbery convictions, the denial of the motion to suppress, or the prosecutor's closing arguments. The court concluded that the defendant was not entitled to a change of venue and that his sentence was not disproportionate under the Massachusetts Declaration of Rights. View "Commonwealth v. Chism" on Justia Law