Justia Civil Rights Opinion Summaries

Darrell J. Robinson was convicted of four counts of first-degree murder and sentenced to death. Robinson appealed to the Supreme Court of Louisiana, arguing that the state suppressed material evidence that violated his due process rights. The evidence in question included undisclosed deals with jailhouse informant Leroy Goodspeed, serology reports and notes, other forensic evidence, and eyewitness accounts inconsistent with trial testimony.The court found that the state did suppress evidence and this evidence was favorable to the defense. The court further found that the undisclosed evidence was material and its suppression undermined confidence in the verdict. Consequently, the court decided that Robinson did not receive a fair trial, resulting in a verdict unworthy of confidence. The court reversed Robinson's conviction, vacated his sentence, and remanded the case for a new trial. View "STATE EX REL. ROBINSON VS. VANNOY" on Justia Law

The case involves Michael Earl Mosby III, an African-American man charged with multiple murders, including a drive-by shooting, by the Riverside County District Attorney's Office in California. The District Attorney sought the death penalty in Mosby's case. Mosby filed a motion claiming that the decision to seek the death penalty violated the California Racial Justice Act of 2020, which prohibits the state from seeking or obtaining a criminal conviction or sentence on the basis of race. The motion was denied by the trial court, which ruled that Mosby had failed to make a prima facie showing of a violation as required under the Act.Mosby then petitioned the Court of Appeal of the State of California, Fourth Appellate District, Division Two, for a writ of mandate directing the superior court to vacate its order denying his request for a hearing on his Racial Justice Act claim and to enter a new order granting an evidentiary hearing. The appellate court agreed in part with the trial court that Mosby was required to present not only statistical evidence of racial disparity in the charging of the death penalty by the District Attorney 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.However, based on the evidence presented in this case, which included factual examples of nonminority defendants who committed murder but were not charged with the death penalty in cases involving similar conduct and who were similarly situated, e.g., had prior records or committed multiple murders, and statistical evidence that there was a history of racial disparity in charging the death penalty by the District Attorney, the appellate court concluded that Mosby met his burden of establishing a prima facie case under section 745, subdivision (a)(3). Therefore, the appellate court granted the writ petition and directed the trial court to conduct an evidentiary hearing. View "Mosby v. Super. Ct." on Justia Law

A sex offender, who was convicted in the 1980s and had lived a law-abiding life for 37 subsequent years, petitioned the trial court to be removed from California’s registry of sex offenders. The People opposed the petition, arguing that one of the offender’s sex crimes would render him ineligible for removal from the registry if prosecuted today under a statute enacted 21 years after his conviction. The court had to decide whether a petition for removal from the sex offender registry could be denied on the grounds that the offender's underlying sex crime also constitutes a different, later-enacted sex crime that requires lifetime registration. The Court of Appeal of the State of California Second Appellate District Division Two held that the trial court erred in giving controlling weight to the nature of the underlying sex offenses and ignoring the defendant's lack of reoffending over the years. The court's decision was reversed, and the defendant was ruled eligible for removal from the registry. View "People v. Franco" on Justia Law

In a case before the Supreme Judicial Court of Massachusetts, the defendant, Denzel McFarlane, convicted of unlawful possession of a firearm and other related charges, appealed for a new trial. He based his appeal on the fact that a police officer who had arrested and testified against him was found civilly liable for false arrest and false imprisonment in an unrelated lawsuit. McFarlane argued that the existence of the civil lawsuit against the officer was exculpatory information that the prosecution should have disclosed to the defense but failed to do so.The primary legal issue was whether the existence of a pending civil lawsuit against a police officer must be disclosed by a prosecutor as exculpatory evidence. The court held that the existence of a pending civil lawsuit against a police officer does not need to be disclosed by a prosecutor as exculpatory evidence. The court reasoned that until a finding of liability has been made, a pending civil lawsuit constitutes an unsubstantiated allegation of police misconduct that does not tend to negate the guilt of the defendant. Therefore, the court affirmed the denial of McFarlane's motion for a new trial.In addition, the court established that while a prosecutor has no duty to inquire into pending civil lawsuits against a prosecution team member, the duty of inquiry does require that prosecutors inquire about the existence of any findings of civil liability related to the performance of a police officer's duties. In other words, if a police officer has been found liable in a civil lawsuit, the prosecution has a duty to discover that information and potentially disclose it to the defense. View "Commonwealth v. Mcfarlane" on Justia Law

In this case, six plaintiffs -- two criminal defense organizations, two defense attorneys, and two former criminal defendants -- filed a petition against the District Attorney's Office for the Hampden District in Massachusetts. The plaintiffs alleged multiple failures by the District Attorney's Office, primarily stemming from its handling of evidence of misconduct within the Springfield Police Department (the department). The U.S. Department of Justice had previously conducted an investigation and found that officers in the department, particularly those within the narcotics bureau, routinely falsified police reports and engaged in a pattern of excessive force.The Supreme Judicial Court of Massachusetts found that the District Attorney's Office, through certain discovery policies, committed a breach of both the duty to disclose evidence that tends to exculpate defendants and the duty to investigate or inquire about such evidence. Specifically, the court identified three problematic practices: 1) disclosing adverse credibility findings made about the department's officers only on a discretionary basis; 2) withholding instances of officer misconduct from disclosure where a specific bad act cannot be clearly attributed to a particular officer; and 3) failing to gain access to all documents known to have been reviewed by the Department of Justice (DOJ).To rectify these breaches, the court ordered the District Attorney's Office to obtain access to all categories of documents known to have been reviewed by the DOJ and disclose them to the plaintiffs. From there, case-by-case adjudication can begin to address the claims of individual defendants affected by the department's misconduct. In issuing this order, the court emphasized the importance of a prosecutor's dual duties -- to disclose and to investigate -- in upholding the integrity of the criminal justice system. View "Graham v. District Attorney for the Hampden District" on Justia Law

In 2011, Daniel Santillanes was convicted of a felony charge for facilitating the sale or transportation of marijuana in Arizona. In 2020, Arizona voters passed Proposition 207, which permitted the expungement of certain marijuana-related offenses. Following this, Santillanes sought to have his felony marijuana conviction expunged and his civil rights restored, including his right to possess a firearm. The trial court granted his request. The state then appealed the decision, questioning whether they had the right to do so.The main issue under consideration by the Supreme Court of the State of Arizona was whether the state had the right to appeal the trial court's decision to expunge Santillanes's record and restore his civil rights. The court concluded that the state did indeed have the right to appeal this expungement order under A.R.S. § 13-4032(4). The court found that an order expunging records of a felony conviction affects the substantial rights of the state, and therefore, the state has the right to appeal such a decision.The Supreme Court vacated parts of the lower court's opinion and remanded the case back to the trial court for further proceedings, consistent with the remainder of the appellate court's opinion. View "STATE OF ARIZONA v SANTILLANES" on Justia Law

In this case, the defendant, James McCray, appealed from a 2022 order that recommitted him for another one-year term under a statutory scheme governing violent offenders with mental health disorders. McCray argued that there was insufficient evidence that he represented a substantial danger of physical harm to others due to a severe mental health disorder, that he voluntarily absented himself from his recommitment trial, and that the trial court failed to obtain from him a knowing and intelligent waiver of his right to a jury. The California Court of Appeal, First Appellate District, Division Four, found that McCray's appeal was moot due to his subsequent recommitment in 2023. However, the court decided to address the trial court's failure to engage in a robust enough oral colloquy with McCray to establish that he knowingly and intelligently waived his right to a jury trial. The court concluded that the record is insufficient to support the determination that McCray made a valid waiver of his right to a jury. Therefore, the court dismissed the appeal as moot but found that McCray's waiver of his right to a jury trial was not knowing and intelligent. View "People v. McCray" on Justia Law

In this case, the Supreme Court of Iowa addressed whether the district court erred in ordering the placement of a sexually violent predator in a transitional release program over the State’s objection. The State argued that the offender was ineligible for that program without a relapse prevention plan (RPP) accepted by his treatment provider at the Civil Commitment Unit for Sexual Offenders (CCUSO) as required by Iowa Code section 229A.8A(2)(d) (2022). The district court determined that the offender’s plan, approved by the offender’s expert, satisfied that statutory requirement. The State appealed, asserting that the court erred by substituting its judgment for that of CCUSO’s staff.The Supreme Court of Iowa held that a writ of certiorari is the proper form of appellate review, and granted the petition. On the merits, the court held that the district court erred by substituting its judgment for that of CCUSO’s staff. The court agreed with the State that the offender was ineligible for placement in the transitional release program because his treatment provider at CCUSO had not accepted his proposed RPP. The court also rejected the offender's substantive due process claims. Consequently, the court sustained the writ and vacated the district court’s ruling. View "In Re Detention of Schuman" on Justia Law

The case concerns Tia Deyon Pugh, who was charged with impeding law enforcement during a civil disorder in violation of 18 U.S.C. § 231(a)(3) during a protest in Mobile, Alabama. She smashed a police car window with a baseball bat, thus obstructing law enforcement officers in their official duties during the civil disorder. Pugh challenged the constitutionality of Section 231(a)(3) on four grounds, arguing that it: (1) exceeds Congress’s power to legislate under the Commerce Clause, (2) is a substantially overbroad regulation of activities protected by the First Amendment, (3) is a content-based restriction of expressive activities in violation of the First Amendment, and (4) is vague in violation of the Fifth Amendment’s Due Process Clause. The district court rejected these arguments, and Pugh was found guilty by a jury.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed Pugh’s conviction. The court held that Section 231(a)(3) does not exceed Congress's power under the Commerce Clause as the statute's jurisdictional element is sufficient to limit its scope to constitutional applications. The court also found that the statute does not violate the First Amendment as it does not broadly prohibit protected speech and expressive conduct. Furthermore, the court ruled that the statute is not a content-based restriction and does not violate the Fifth Amendment's Due Process Clause due to vagueness. The court concluded that the statute constitutionally applies to Pugh's conduct, and she may not challenge the statute on vagueness grounds based on its application to others. View "USA v. Pugh" on Justia Law

Valentino Bagola, serving a life sentence for two counts of first-degree murder, was required to pay $9,000 in restitution through monthly installment payments during his incarceration. When Bagola received funds as part of a federal COVID-related stimulus payment, the government filed a motion to release these funds to apply towards his restitution obligations. Bagola objected, arguing that the funds were not garnishable. However, the United States District Court for the District of North Dakota ruled in favor of the government, ordering the turnover of $924.60 from Bagola's trust account towards his restitution obligations. The court concluded that the funds were not exempt under 18 U.S.C. § 3613(a)(1) and there was a valid lien against these funds. Bagola appealed the decision.The United States Court of Appeals for the Eighth Circuit upheld the district court's decision. The appellate court found that the district court did not err in determining that the stimulus funds constituted "substantial resources" under § 3664(n). Bagola’s contention that applying stimulus funds to restitution was improper and threatened prison security by negatively impacting inmate morale was raised for the first time on appeal and did not meet the plain error standard for review. The court also found that the amount of the funds, over $900, could be considered substantial relative to Bagola's usual monthly installment amounts. Therefore, the court affirmed the district court's judgment, ruling that the stimulus payment funds were subject to turnover towards Bagola's restitution obligations. View "United States v. Bagola" on Justia Law