Justia Civil Rights Opinion Summaries

In 2012, three people were shot and killed outside a nightclub in Houston, Texas. Feanyichi E. Uvukansi was identified by an eyewitness, Jeresano, who picked him out of a photo array. Uvukansi was convicted of capital murder and sentenced to life without parole. At trial, Jeresano testified that he had no agreement with prosecutors regarding his testimony, but it was later revealed that he did have an agreement that could reduce his federal drug sentence in exchange for his testimony.Uvukansi did not raise the issue of false testimony on direct appeal but did so in state habeas proceedings. The state district court found that Jeresano's testimony was false but deemed it immaterial because the jury was aware of parts of the agreement through other testimony. The Texas Court of Criminal Appeals denied Uvukansi’s application without a written order. Uvukansi then filed a Section 2254 application in federal district court, which was dismissed on the grounds that the state court's decision was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the state district court applied the correct "reasonable likelihood" standard for materiality and did not impose a higher burden of proof on Uvukansi. The court also found that the state district court did not err in considering the false testimony's impact on Jeresano's credibility rather than the identification itself. The Fifth Circuit concluded that the state court's decision was not contrary to, or an unreasonable application of, clearly established Supreme Court precedent and affirmed the dismissal of Uvukansi's Section 2254 application. View "Uvukansi v. Guerrero" on Justia Law

Jorge Rivera-Guadalupe was living in a rooming house in Harrisburg, Pennsylvania, when he was mugged and robbed. His friend, Christopher Valkosak, came to stay with him for protection. The next evening, Valkosak was shot by a stranger in the hallway outside Rivera-Guadalupe’s room. Detective Jacob Pierce investigated the incident, interviewed a neighbor who described the shooter as a tall Black male, and obtained a search warrant for Rivera-Guadalupe’s room. The search yielded marijuana, a knife, and IDs but no gun. Rivera-Guadalupe was arrested and charged with multiple offenses, including attempted homicide and possession of marijuana. He was acquitted of all charges after being incarcerated for over eighteen months.The United States District Court for the Middle District of Pennsylvania dismissed claims against other defendants but allowed the malicious prosecution claim against Det. Pierce to proceed. Det. Pierce sought dismissal based on qualified immunity, arguing that probable cause for some charges precluded a malicious prosecution claim. The District Court, referencing Johnson v. Knorr, held that probable cause for one charge does not insulate officers from liability for malicious prosecution on other charges lacking probable cause. Det. Pierce’s motion for judgment on the pleadings was denied, and he appealed.The United States Court of Appeals for the Third Circuit reviewed the case. The court concluded that the right to be prosecuted only on charges supported by probable cause was not clearly established at the time of Rivera-Guadalupe’s prosecution due to conflicting precedents within the circuit and among other circuits. The court reversed the District Court’s denial of qualified immunity for Det. Pierce and remanded the case with instructions to dismiss on that basis. The court clarified that the any-crime rule applies to false arrest claims but not to malicious prosecution claims. View "Rivera-Guadalupe v. Pierce" on Justia Law

Johnnie Franklin Wills, a state prisoner, filed a habeas petition challenging his life sentence under West Virginia’s recidivist statute. He argued that the judicially crafted test for determining whether a recidivist life sentence is proportional to the crime is unconstitutionally vague. Wills was convicted of grand larceny and conspiracy to commit grand larceny in 2016, and due to his prior eight felony convictions, he was sentenced to life imprisonment with parole eligibility after fifteen years under the recidivist statute.The West Virginia courts denied Wills relief, stating that the void-for-vagueness doctrine does not apply to their proportionality test. The Supreme Court of Appeals of West Virginia affirmed this decision, distinguishing Wills’s case from the U.S. Supreme Court’s decisions in Johnson v. United States and Sessions v. Dimaya, which invalidated certain statutory provisions as unconstitutionally vague. The state court maintained that the proportionality test was clear and did not fall under the same scrutiny as the statutes in Johnson and Dimaya.Wills then filed a federal habeas petition under 28 U.S.C. § 2254, which the United States District Court for the Northern District of West Virginia also denied. The district court found that the state court’s decision was not contrary to or an unreasonable application of clearly established federal law. The court noted that the proportionality test serves as a judicial limitation on the recidivist statute, unlike the statutory mandates in Johnson and Dimaya.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The court held that the state court’s ruling was not an unreasonable application of clearly established federal law, as the U.S. Supreme Court has not extended the void-for-vagueness doctrine to judicially crafted proportionality tests. Therefore, Wills’s habeas petition was denied. View "Wills v. Pszczolkowski" on Justia Law

Correctional officers at an Illinois state prison brutally beat inmate Larry Earvin, who later died from his injuries. Todd Sheffler and two others were charged with various federal crimes related to the killing and its cover-up. After a mistrial, Sheffler was retried and found guilty by a jury.In the United States District Court for the Central District of Illinois, Sheffler was convicted on five counts, including conspiracy to deprive civil rights, deprivation of civil rights, conspiracy to engage in misleading conduct, obstruction-falsification of documents, and obstruction-misleading conduct. Sheffler argued that there was no reasonable likelihood that his incident report and interview with state police would reach federal officials, challenging his convictions under 18 U.S.C. § 1512 and § 1519. He also contended that the district court erred in ruling he breached a proffer agreement and allowed a biased juror to sit on his trial. Additionally, he claimed prosecutorial misconduct during the rebuttal closing argument.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that sufficient evidence supported Sheffler’s convictions, as it was reasonably likely that his false statements would reach federal officials, given the severity of the crime and the cooperation between state and federal authorities. The court also found no clear error in the district court’s conclusion that Sheffler breached the proffer agreement by making false statements during FBI interviews. Furthermore, the court determined that the district court did not abuse its discretion in handling the juror bias issue or in denying Sheffler’s motion for a new trial based on alleged prosecutorial misconduct.The Seventh Circuit affirmed the district court’s denial of Sheffler’s motion for a new trial and upheld his convictions. View "USA v Sheffler" on Justia Law

The case involves Benjamin D. Rieker, a Lincoln Police Department officer, who was working off-duty as a security guard at a hospital. On October 31, 2020, Jan Noch, a patient, became disruptive and was asked to leave the hospital. Rieker encountered Noch in a hallway and instructed him to leave through the ambulance bay exit, but Noch insisted on leaving through the main lobby. Rieker claimed Noch threatened him and made aggressive movements, prompting Rieker to push Noch, causing him to fall. Security footage and eyewitnesses provided conflicting accounts of the incident.The county court for Lancaster County convicted Rieker of third-degree assault and false reporting after a bench trial. Rieker was sentenced to 18 months’ probation for each conviction, to be served concurrently. Rieker appealed to the district court, arguing that the evidence was insufficient to support his convictions and that his motion to suppress certain statements should have been granted. The district court affirmed the convictions and sentences.The Nebraska Supreme Court reviewed the case, focusing on whether the evidence was sufficient to support the convictions. The court found that the evidence, including security footage and eyewitness testimony, supported the conclusion that Rieker’s use of force was not justified under the defense of property statute. The court also found that Rieker knowingly provided false information in his reports and during an interview with law enforcement, intending to impede the investigation of an actual criminal matter.The Nebraska Supreme Court affirmed Rieker’s convictions and sentences, concluding that the evidence was sufficient to support both the assault and false reporting convictions. The court did not find it necessary to address the suppression issue, as any potential error in admitting the ACI form was deemed harmless given the other competent evidence supporting the convictions. View "State v. Rieker" on Justia Law

In 2010, Juan Nuno was prosecuted and later pleaded no contest to attempted murder, admitting to several sentence-related allegations. He was sentenced to 30 years in prison. In 2022, Nuno filed a petition to vacate his conviction under Penal Code section 1172.6, which the trial court found made a prima facie case for an evidentiary hearing. Nuno then filed a motion for discovery of peace officer personnel records, seeking exculpatory evidence under Brady v. Maryland and through Pitchess procedures. The trial court ordered limited disclosure of personnel information after an in-camera review but later denied Nuno’s petition after the evidentiary hearing.Nuno appealed, requesting the appellate court to review the trial court’s application of Pitchess standards. The Attorney General did not initially object to this request. The appellate court sought supplemental briefing on whether the trial court’s review should include Brady principles and whether Brady obligations apply in section 1172.6 proceedings. Both parties agreed that Nuno’s request encompassed Brady principles.The California Court of Appeal, Sixth Appellate District, decided that a petitioner may obtain disclosure of peace officer personnel information under Brady principles through Pitchess procedures in advance of a section 1172.6 evidentiary hearing. The court found that the trial court did not abuse its discretion under Pitchess principles but did not clearly consider Brady principles. Consequently, the appellate court conditionally reversed the trial court’s order denying Nuno’s petition and remanded for further proceedings to ensure compliance with Brady principles. If additional information is found to be discoverable under Brady, the trial court must allow Nuno to demonstrate prejudice and potentially order a new evidentiary hearing. View "People v. Nuno" on Justia Law

The defendant, Freddy Rivera Corbi, was bullied by gang members in his community for years. In July 2019, he was seriously injured by a gang member. A month later, Corbi encountered another gang member, Lazaro Orozco, and fatally shot him after an argument. At trial, the main issue was whether the shooting was in self-defense or an act of revenge. The jury convicted Corbi of second-degree murder.The Superior Court of San Diego County reviewed the case. Corbi argued that the trial court abused its discretion by allowing the prosecution’s gang expert to offer certain opinions and that the prosecutor violated the California Racial Justice Act of 2020 during closing arguments. He also claimed the court erred in considering whether to dismiss a firearm enhancement at sentencing. The trial court imposed a sentence of 15 years to life for the murder, plus 10 years for a reduced firearm enhancement.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court found no reversible error regarding the expert testimony, determining that the gang expert’s opinions were not speculative and did not prejudice the jury’s decision. The court also held that Corbi forfeited his Racial Justice Act claim by failing to raise it in the trial court. Finally, the court concluded that the trial court properly imposed the firearm enhancement, as it had discretion to impose or dismiss the enhancement and had considered the relevant mitigating factors. The judgment was affirmed. View "P. v. Corbi" on Justia Law

Khyle Armando Briscoe, at age 21, participated in a robbery during which his accomplice, Shaun P., was fatally shot by the victim, Ben P. Briscoe was convicted of first-degree murder, robbery, and burglary, with a special circumstance finding under Penal Code section 190.2, subdivision (d), which led to a life without parole sentence. This special circumstance applies to non-killer participants in felonies who act with reckless indifference to human life.The trial court sentenced Briscoe to life without parole, and the conviction was affirmed on appeal. Briscoe later sought a parole hearing under Penal Code section 3051, which allows certain youth offenders to seek parole but excludes those sentenced to life without parole for special circumstance murder. The trial court denied his motion, and Briscoe appealed.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court noted that section 3051 was intended to provide youth offenders with a meaningful opportunity for release based on demonstrated growth and rehabilitation. However, the statute excludes youth offenders sentenced to life without parole for special circumstance murder. Briscoe argued that this exclusion violated equal protection, particularly because section 190.2, subdivision (d) employs the same standard of liability as section 189, subdivision (e)(3), which does not exclude youth offenders from parole consideration.The Court of Appeal agreed with Briscoe, finding that the exclusion of youth offenders sentenced under section 190.2, subdivision (d) from parole consideration under section 3051 violated equal protection. The court reversed the trial court's order and remanded the case for a parole hearing and related proceedings. View "P. v. Briscoe" on Justia Law

Enrique Sanchez, the petitioner, sought a writ of mandate to vacate a trial court order directing the San Bernardino County Public Defender to assign a new attorney to represent him. This order was issued after evidence suggested that the deputy public defender currently assigned to Sanchez's case made racially charged remarks during plea negotiations, potentially violating the Racial Justice Act (RJA). Sanchez argued that the trial court's decision was an abuse of discretion.The trial court received a motion from the prosecutor to disclose exculpatory evidence and evaluate the deputy public defender's conflict of interest. The motion included a declaration from the prosecutor detailing the deputy public defender's remarks, which implied racial bias. During a closed hearing, the trial court read the prosecutor's declaration to Sanchez and asked if he wanted the current public defender to continue representing him. Sanchez expressed his desire to retain his current counsel. However, the trial court later ordered the public defender's office to assign a new attorney, citing potential RJA issues and the risk of ineffective assistance of counsel.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court concluded that the trial court did not abuse its discretion in removing the deputy public defender. The appellate court noted that the RJA's provisions and the potential for implicit bias created an actual conflict of interest that the deputy public defender could not objectively investigate. Additionally, the trial court's decision to prevent potential future RJA claims and ensure adequate representation was within its discretion. The petition for writ of mandate was denied, and the stay on trial court proceedings was vacated. View "Sanchez v. Superior Court" on Justia Law

Two defendants, Fredi Analberto Lopez-Flores and Christian Alejandro May Quintero, were convicted of multiple sex crimes, including forcible rape, sodomy, and oral copulation in concert, after they abducted an inebriated woman, Jane Doe, from the streets of San Francisco, drove her 50 miles away, and assaulted her. The prosecution used terms like "monsters" and "predators" during closing arguments, which the defendants later claimed violated the California Racial Justice Act (RJA) and constituted prosecutorial misconduct.In the lower court, the jury found both defendants guilty on all counts. Lopez-Flores was also found to have a prior conviction, which was considered during sentencing. The trial court imposed consecutive sentences under section 667.6, subdivision (d), finding that the offenses occurred on separate occasions. The court also stated that even if this finding was incorrect, it would impose consecutive sentences under section 667.6, subdivision (c), based on the nature of the crimes and aggravating factors.The California Court of Appeal, First Appellate District, reviewed the case. The court concluded that the prosecution's use of the terms "monsters" and "predators" did not violate the RJA, as these terms were race-neutral and based on the defendants' conduct. The court also found no prosecutorial misconduct, determining that the comments were within the permissible range of descriptive commentary based on the evidence. The court held that the trial court did not err in imposing consecutive sentences under section 667.6, subdivision (c), and any potential error under subdivision (d) was harmless because the court provided adequate reasons for its discretionary decision. The judgments were affirmed. View "P. v. Quintero" on Justia Law