Justia Civil Rights Opinion Summaries

The appellant, Jordon J. Miller, was convicted and sentenced for second degree murder following a plea agreement. The charge stemmed from an incident when shots were fired at a passing vehicle, resulting in the death of Jade Lea. Miller appealed, claiming that the district court erred in overruling his motion to withdraw his plea, that his statutory right to a speedy trial was violated, that the court imposed an excessive sentence, and that he received ineffective assistance of trial counsel. The Nebraska Supreme Court found no abuse of discretion in the overruling of Miller's motion to withdraw his plea, noting that a defendant’s change of mind alone is not a fair and just reason to withdraw a guilty or no contest plea. The court also found that the record on appeal was not sufficient to review Miller's claims of ineffective assistance of trial counsel. Finally, the court found no abuse of discretion in Miller's sentencing. As such, the court affirmed Miller’s conviction and sentence. View "State v. Miller" on Justia Law

The case involves Jeremiah Paul, who was convicted of possession of a firearm with a prior violent conviction. Paul had pleaded no contest following the denial of his motion to suppress evidence of a firearm by the trial court, pursuant to Penal Code section 1538.5. He contended that the evidence of the firearm should have been excluded because law enforcement officers discovered it only after they unlawfully detained him to verify his parole status. The Court of Appeal of the State of California Second Appellate District Division Five found that the initial encounter between Paul and the officers was indeed an unlawful detention. The court pointed to several factors leading to this conclusion such as the positioning of the officers that blocked Paul from leaving, the officers approaching Paul from both sides of his car and shining their flashlights into his car, and the fact that the officers approached Paul while he was on his phone in a legally parked vehicle. The court held that these factors would lead a reasonable person to believe they are not free to leave, thus constituting a detention. Therefore, the court reversed the trial court’s judgment and vacated its order denying Paul's motion to suppress evidence. The court concluded that the officers would not have obtained Paul's parole status if they had not first unlawfully detained him and thus, the firearm was not lawfully obtained and should be suppressed. View "P. v. Paul" on Justia Law

The case involves a defendant, Tommy Bonds, who was stopped by Officer Ryan Cameron of the San Diego Police Department (SDPD) leading to his arrest for a misdemeanor concealed firearm violation. Bonds claimed he was stopped because he was Black and filed a motion for relief under the California Racial Justice Act of 2020, alleging racial bias in his stop. The Superior Court of San Diego County denied the motion, accepting the officer's testimony that race played no role in his decision to stop the vehicle as he could not determine the race of the occupants from outside. The court did not consider the possibility of implicit bias, i.e., unconscious bias that could be influencing the officer's decisions.On appeal, the Court of Appeal, Fourth Appellate District Division One State of California, held that the trial court applied the wrong legal standard by focusing on whether the officer intended to discriminate on the basis of race, rather than considering the possibility of implicit bias. The Court of Appeal stated that the Racial Justice Act addresses both intentional and unintentional racial bias. The court remanded the case back to the trial court to conduct a new hearing, considering whether the officer's actions exhibited implicit bias on the basis of race.The appellate court also commented on the admissibility of statistical evidence regarding police practices, stating that according to the Racial Justice Act, such evidence is admissible for determining whether a violation of the Act has occurred. View "In re H.D." on Justia Law

In this case, the issue at hand revolves around the California Racial Justice Act (CRJA). The petitioner, Michael Earl Mosby III, was charged with the drive-by shooting of Darryl King-Divens, along with a gun enhancement and three special circumstances, including having committed multiple murders. The District Attorney sought the death penalty for Mosby, who had been previously convicted in Los Angeles County of two additional murders and attempted murder. Mosby filed a motion claiming that the District Attorney's decision to seek the death penalty violated the CRJA, which prohibits seeking or obtaining a criminal conviction on the basis of race. The trial court denied Mosby's motion, ruling that he had failed to make a prima facie showing of racial discrimination under the CRJA.The Court of Appeal of the State of California Fourth Appellate District granted the writ petition and directed the trial court to conduct an evidentiary hearing. The court held that under the CRJA, a defendant must present not only statistical evidence of racial disparity in the charging of the death penalty but also evidence of nonminority defendants who were engaged in similar conduct and were similarly situated but charged with lesser offenses, to establish a prima facie case. The court found that Mosby had met his burden of establishing a prima facie case under the CRJA. Therefore, the trial court should have ordered an evidentiary hearing at which the District Attorney could produce evidence of the relevant factors that were used to determine the charges against the nonminority defendants who were involved in similar conduct, and who were similarly situated to Mosby; and to provide any race-neutral reasons that it considered in deciding to charge Mosby with the death penalty. View "Mosby v. Superior Court" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit considered an appeal by several Missouri public officials who were denied qualified immunity by a lower court regarding five claims arising from a murder prosecution. The murder case, involving Donald Nash who was eventually convicted for the murder of Judy Spencer, was reopened in 2007, 25 years after the crime occurred. The officials based their case on a theory that DNA evidence found under Spencer's fingernails belonged to Nash, which they asserted could not have remained present if Spencer had washed her hair after their last encounter.Nash was convicted and spent 11 years in prison until the Missouri Supreme Court set aside his conviction in 2020. The charges were dismissed after DNA testing on the shoelace used to strangle Spencer supported Nash’s noninvolvement. Nash and his wife filed a lawsuit against the officials, claiming violations of rights including unlawful arrest and detention, fabrication of evidence, failure to investigate, violations of rights of access to courts, and violation of the right to familial and marital associations.The Eighth Circuit affirmed in part, reversed in part, and dismissed in part the appeals on the denial of qualified immunity. The court held that the officials were not entitled to qualified immunity on the claim of unlawful arrest and detention, finding that the omission of certain exculpatory facts from the probable cause affidavit negated probable cause for Nash's arrest. However, the court reversed the denial of qualified immunity for the claim alleging violation of the right to familial and marital associations, as this was not a clearly established constitutional right in 2008. The court dismissed the officials' appeal on the remaining claims due to lack of jurisdiction, as these involved genuine disputes of material fact to be resolved by a jury. View "Estate of Nash v. Folsom" on Justia Law

In this case from the Supreme Court of Arkansas, defendant Robert J. Williams, Jr. appealed his conviction for capital murder and aggravated assault. Williams argued that the trial court erred in granting the State's motion for continuance, violated his rights to a speedy trial, and improperly denied his Batson challenge during jury selection. The Supreme Court of Arkansas disagreed and affirmed the lower court's decision.On the issue of the continuance, the court held that the trial court did not abuse its discretion in granting the State's motion for continuance. The court found that the State acted with due diligence and the affidavit submitted by the State substantially complied with the requirements set forth by law.On the issue of speedy trial, the court conducted a de novo review to determine whether specific periods of time were excludable under the speedy-trial rules. The court found that Williams was brought to trial within the twelve-month period required by the rules. Therefore, the court held that Williams's right to a speedy trial was not violated.Finally, on the issue of the Batson challenge, the court held that the trial court properly allowed the State to strike a juror based on a race-neutral reason, that is, the juror's lack of involvement in the judicial process. The court deferred to the trial court's ability to gauge the State's demeanor and credibility, finding no error in the denial of the Batson challenge.Therefore, the court affirmed the decisions of the lower court, finding no prejudicial error. View "Williams v. State" on Justia Law

In 2003, Terry Harper and Emmanuel Ruiz were convicted by a jury of murder and related charges connected to the shooting deaths of Joe Luhrman, David Carty, and Tracy Glover in 2001. Harper appealed his conviction, arguing that his right to due process was violated due to the almost 20-year delay between his conviction and his direct appeal, that the trial court abused its discretion in denying his motion for mistrial after the State referenced a response he gave to police questioning that he contends was previously excluded and prejudicial, and that he was denied effective assistance of counsel when his trial attorneys failed to obtain and introduce evidence that he was suffering a severe injury to his dominant hand at the time of the shootings.The Supreme Court of Georgia affirmed the trial court's decision. The court applied the four-part balancing test from Barker v. Wingo to Harper's claim of a due process violation due to the delayed appeal. Although the court found that the delay was lengthy and Harper consistently asserted his right to appeal, it ultimately held that Harper failed to show actual prejudice from the delay. Regarding the mistrial motion, the court found that the trial court did not abuse its discretion in denying the motion as the jury was given prompt curative instructions, and the prosecutor acted in good faith. Lastly, the court denied Harper's ineffective assistance of counsel claim, as he failed to show a reasonable probability that the result of his trial would have been different if his medical records were introduced into evidence. View "HARPER v. STATE" on Justia Law

In 2019, the California Supreme Court ruled that the defendant, Oscar Manuel Vaquera, did not receive fair notice of the sentence that the prosecution was seeking in his case, which violated his right to due process. Vaquera was charged with two counts of a sex offense covered by California's "One Strike" law and was convicted on both counts. In the habeas corpus proceeding, Vaquera challenged the 25-year-to-life sentence the trial court imposed for the second count.The prosecution had initially requested a sentence of 15 years to life for the second count, but later argued for a 25-year-to-life sentence under a different provision of the One Strike law. Vaquera contended that the imposition of the 25-year-to-life sentence violated due process because he did not receive fair notice that the prosecution intended to seek that sentence. The California Supreme Court agreed with Vaquera and ordered the trial court to resentence him to 15 years to life for the second count.The Court ruled that the One Strike allegation in Vaquera's case did not provide him with fair notice that the prosecution was seeking a 25-year-to-life sentence under the specific provision of the law based on the victim's age. The Court held that due process requires an accusatory pleading to inform the defendant of the particular One Strike sentence the prosecution is seeking and of the factual basis it intends to prove to support that sentence. In this case, the prosecution did not provide fair notice of its intent to seek the longer One Strike sentence, which violated Vaquera's due process rights. View "In re Vaquera" on Justia Law

In the state of Montana, William James Rupnow Jr., a licensed bail bondsman, was accused of criminal offenses after he tried to apprehend a client, Victorianne Dahl, who had violated her bail conditions. Dahl had consistently been late with payments and had violated other conditions of her release. Rupnow resorted to using pepper spray in his attempt to detain Dahl, leading to the State charging him with felony assault with a weapon and aggravated assault. Rupnow was ultimately acquitted on the aggravated assault charge, but the jury could not reach a verdict on the assault with a weapon charge. In response, Rupnow filed a lawsuit against the Montana State Auditor and Commissioner of Insurance, Mike Winsor, Jennifer Hudson, and XYZ government subdivision, alleging malicious prosecution, abuse of process, and violation of his rights under the Montana Constitution. The defendants requested the case be dismissed based on prosecutorial immunity, a motion which the District Court granted. Rupnow appealed the decision, arguing that as a bail bondsman, he had the authority to arrest Dahl without a warrant.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision to dismiss Rupnow's case. The Court found that Montana's statutory scheme for pre-trial release, or bail, did not provide bail bondsmen with an unfettered right to remit a bail bond client to jail without an outstanding warrant. The Court reasoned that the legislature did not intend to grant bail bondsmen arrest authority that far exceeded that of law enforcement officers. Therefore, Rupnow did not have the authority to arrest Dahl without a warrant, meaning there was probable cause to charge Rupnow with the crimes he was accused of. The Court concluded that Rupnow's claims of malicious prosecution and abuse of process failed as a matter of law. View "Rupnow v. State Auditor" on Justia Law

In the case at hand, the plaintiff, Benjamin Adams, an inmate at Indiana’s Plainfield Correctional Facility, sued the current and former commissioners of the Indiana Department of Corrections and various other officials pursuant to 42 U.S.C. § 1983, alleging that they violated his First and Eighth Amendment rights, as well as his Fourteenth Amendment rights to due process and equal protection. Adams was sentenced to a prison term of 30 years for attempted murder and a consecutive term of four years for involuntary manslaughter. He was assigned to work in the prison kitchen, but that assignment was rescinded due to concerns that he might use the assignment to smuggle drugs into the prison. He was later charged with offense A-100 for engaging in criminal gang activity related to an assault in the prison. Disciplinary Hearing Officer J. Peltier found Adams guilty of that offense on March 16. He was ordered to spend one year in disciplinary segregation, 365 days of his earned good time credits were revoked, and he was demoted from credit-earning class 1 to class 3.The United States Court of Appeals for the Seventh Circuit affirmed the district court's grant of summary judgment in favor of the defendants. The appellate court concluded that Adams' claim of First Amendment retaliation lacked sufficient evidence to suggest that the defendants were motivated by a retaliatory intent to pursue the assault charge against him. The court also held that Adams was not deprived of his Fourteenth Amendment due process rights, as prison disciplinary hearings require only informal due process, which leaves substantial flexibility in the hands of prison administrators. Regarding the Equal Protection claim, the court found no evidence that Adams was treated differently based on his race. Lastly, the court concluded that the defendants could not be held liable for violating Adams' Eighth Amendment rights as there was no evidence that they had control over the conditions of restrictive housing where Adams was placed. View "Adams v. Reagle" on Justia Law