Justia Civil Rights Opinion Summaries

The defendant, Dwane Estwick, was convicted of first-degree and second-degree robbery following a jury trial and was sentenced to 12 years in prison, followed by five years of post-release supervision. The defendant claimed that the prosecution failed to provide a race-neutral explanation for its peremptory strike of a prospective juror, K.S., an African-American female. The defendant argued that this failure constituted a violation of the Batson framework, which prohibits racial discrimination in jury selection, and thus, he was entitled to a new trial.The Appellate Division affirmed the conviction (208 AD3d 799 [2d Dept 2022]). A Judge of the Court of Appeals granted leave to appeal (39 NY3d 1078 [2023]). The defendant reiterated his claim that the prosecution failed to provide a race-neutral explanation for its peremptory strike of K.S., thus violating the Batson framework.The Court of Appeals of New York agreed with the defendant. It found that the defendant had established a prima facie case of discrimination regarding the prosecution's peremptory challenge against K.S. The burden then shifted to the prosecution to provide a race-neutral basis for its peremptory strike, which it failed to do. Instead, the trial court stepped in to provide an explanation, speculating that the prosecution had gotten a "bad vibe" from K.S. The court ruled that the prosecution had "given a legitimate race-neutral reason" for the strike. The Court of Appeals held that this was a serious departure from the Batson framework and constituted an error of the highest order. The court's speculation as to the prosecution's basis for the strike was irrelevant and deprived the defendant of any meaningful way to demonstrate pretext in the face of the prosecution's silence. As a result, the Court of Appeals reversed the Appellate Division order and ordered a new trial. View "People v Estwick" on Justia Law

The case revolves around Quasim Hastings, a prisoner convicted of second-degree murder in 2004 and eligible for parole consideration. Hastings, diagnosed with a mental disability, is entitled to a parole hearing that provides him with protections under the Massachusetts Constitution and Federal and State statutes prohibiting discrimination based on disability. Prior to a 2023 parole hearing, Hastings' counsel filed a motion for funds to retain a forensic psychologist and a social services advocate to assist with preparing a prerelease plan. While the motion for a forensic psychologist was approved, the request for a social services advocate was denied by a different Superior Court judge, who reasoned that the indigency statute limits his authority to approve funds to pending proceedings or appeals in any court.The judge's denial of the motion for funds was reported to the Appeals Court, and Hastings's application for direct appellate review was granted by the Supreme Judicial Court. The Supreme Judicial Court concluded that Hastings's motion for funds to retain a social services advocate implicates his State constitutional right to reasonable disability accommodations. Therefore, the constitutionally mandated exception to the indigency statute applies, and the order denying Hastings's motion for funds was reversed. The court held that a judge has the discretion to allow a motion for funds to pay for expert assistance as reasonably necessary to safeguard the indigent prisoner's constitutional rights prohibiting discrimination on the basis of disability. View "Commonwealth v. Hastings" on Justia Law

The case involves Brian Dewayne Darden-Mosby, who was convicted of two federal drug-dealing offenses. During the investigation, Drug Enforcement Agency (DEA) agents executed a search warrant for Darden-Mosby’s house and car, discovering an unregistered firearm, a money counter, drug ledgers, marijuana, and a backpack containing cocaine. They also seized $112,690 in cash found in various locations in his bedroom. After the search, police pulled over one of Darden-Mosby’s cocaine suppliers and found Darden-Mosby in the passenger seat with a bank envelope containing $2,500 in cash and two cashier’s checks totaling nearly $150,000.The United States prosecuted Darden-Mosby for various crimes based on the drugs and guns found in his house. As part of the prosecution, the government initiated criminal-forfeiture proceedings against the cash from Darden-Mosby’s bedroom, the two cashier’s checks, and the $2,500 found in Darden-Mosby’s pocket. Darden-Mosby sought to suppress the cashier’s checks and $2,500, arguing the detective’s search violated the Fourth Amendment. The district court denied the motion. The government ultimately opted not to introduce that evidence at trial, and it dismissed the criminal forfeiture claims against the two checks.A jury convicted Darden-Mosby of two drug-dealing offenses. The government declined to prosecute the forfeiture of the $2,500 in cash from the traffic stop any further but continued to pursue criminal forfeiture of the $112,690 from Darden-Mosby’s house. After a hearing and additional briefing, the court concluded the cash was connected to Darden-Mosby’s drug dealing and ordered the criminal forfeiture of the money.Separate from the government’s criminal-forfeiture actions, the DEA commenced administrative-forfeiture proceedings against the two cashier’s checks and the $2,500. These proceedings resulted in the administrative forfeiture of all three assets.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed in part and reversed in part. The court affirmed the district court’s criminal-forfeiture order with respect to the $92,470 found in the safe and shoebox at Darden-Mosby’s house but reversed with respect to the $20,220 found in and on the dresser. The court found that Darden-Mosby offered credible evidence that the $20,220 found on and in the dresser had legal sources and purposes. However, the court found that Darden-Mosby’s evidence was considerably weaker when it came to the $92,470 in the safe and shoebox. View "United States v. Darden-Mosby" on Justia Law

The case involves David Arias, who was convicted of two counts of sexual abuse against a minor. During the trial, the defense challenged the prosecutor's use of a peremptory strike against a prospective Black female juror. The trial court ruled that a prima facie case of discrimination was established, but accepted the prosecutor's reasons for the strike without further discussion. Arias was convicted and sentenced to 15 years to life in prison.The trial court's decision was appealed to the Court of Appeal of the State of California, First Appellate District. The appellate court found that the trial court's denial of the defense's challenge to the prosecutor's peremptory strike was improper. The prosecutor's reasons for the strike did not withstand scrutiny. The appellate court concluded that the record lacked sufficient evidence on which the trial court could have reasonably relied to accept the prosecutor's reasons for striking the juror without further probing and explanation. As a result, the appellate court reversed the trial court's decision. View "P. v. Arias" on Justia Law

The case involves Jesse Calvin Gilbert, who was pulled over by a law enforcement deputy due to a non-operating license plate light. Gilbert was arrested on an active warrant, and the deputy conducted a warrantless search of the vehicle. During the search, the deputy found a handgun under the driver's seat. Gilbert, an ex-felon, was charged with possession of a firearm and moved to suppress the evidence, arguing that the search was not a true inventory search but a ruse to conduct an investigatory search.The district court denied Gilbert's motion, finding that the deputy appropriately impounded the vehicle and the inventory search was reasonable. Gilbert appealed his subsequent conviction based on the search and the unsuppressed evidence.The Supreme Court of Nevada affirmed the district court's decision. The court clarified that an investigatory motive does not necessarily invalidate an inventory search as long as the search that occurred is the same as the inventory-based search that would have happened absent any such motivation. The court also stated that a court deciding a suppression motion must determine the search's reasonableness under the totality of the circumstances by evaluating the extent to which law enforcement departed from the standardized procedures, whether the scope of the search was as expected in light of the underlying justifications for inventory searches, and whether the inventory produced served the purposes of an inventory search. The court concluded that the search was reasonable and denied Gilbert's motion to suppress. View "GILBERT VS. STATE" on Justia Law

The case revolves around Mr. Lyndell Daniels, who was detained by law enforcement officers who linked him to a stolen Glock firearm based on his name. Daniels was charged with being a felon in possession of a firearm. Daniels moved to suppress his name as the fruit of an unlawful investigative detention, arguing that the officers had no reasonable suspicion to detain him. The district court agreed with Daniels and granted his motion. The government appealed this decision, arguing that the district court erred because there was reasonable suspicion to detain Daniels.The case originated from a near-anonymous call to the Aurora Police Department, expressing concern about three Black men, wearing dark hoodies and jeans, intermittently taking guns in and out of their pockets and getting in and out of a dark SUV. The caller believed they were “getting ready to do something,” but reported no illegality. The police arrived at the scene and detained Daniels, who was standing near the SUV. The officers did not observe any illegal activity or firearms when they arrived.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court found that the totality of the circumstances known to the officer when he detained Daniels did not amount to reasonable suspicion. The court noted that the 911 call, the presence and actions of the SUV, the time of the encounter, and the location of the encounter were not sufficient to establish reasonable suspicion. The court concluded that Daniels' detention was unreasonable under the Fourth Amendment, and the district court's grant of Daniels' motion to suppress was proper. View "United States v. Daniels" on Justia Law

The case revolves around an incident involving Corey Fisherman, an inmate at Minnesota’s maximum-security prison, and David Launderville, a prison guard. Fisherman was being transferred to a more restrictive area after a shank was found in his cell. During the transfer process, Fisherman initially refused to undergo a strip search, leading to the intervention of the A-Team, a group of guards trained to handle noncompliant inmates, which included Launderville. After the search, Fisherman objected to kneeling and placing his hands through a small opening in his cell door. Once he complied, he was handcuffed. Fisherman alleges that Launderville kneed him six times, three times each in the face and body, while another guard kneeled on his legs. Launderville, however, claims he struck Fisherman twice in the leg because he was resisting.The case was initially heard in the United States District Court for the District of Minnesota. The magistrate judge identified a potential jury issue: whether Launderville struck a restrained inmate six times in the face and body or a partially unrestrained one just twice in the leg. The district court adopted the report and recommendation, leading to an appeal to the United States Court of Appeals for the Eighth Circuit.The Court of Appeals affirmed the district court's decision, denying Launderville's claim of qualified immunity. The court found that a reasonable jury could conclude that the repeated blows to Fisherman's head and body were "malicious and sadistic." The court also determined that the law was clearly established that repeatedly striking a fully restrained inmate violates the Eighth Amendment. Therefore, the court concluded that every reasonable official in Launderville's position would have understood that kneeing a restrained inmate several times in the face and body violated that right. View "Fisherman v. Launderville" on Justia Law

The plaintiff, John Deaton, was arrested and charged with assault, battery, and disorderly conduct following an altercation at a youth football game. Although the charges were later dismissed, Deaton filed state and federal claims against the Town of Barrington and several individuals, including police officers and the town manager. The case was removed from state court to the United States District Court for the District of Rhode Island. The district court granted summary judgment in favor of the defendants on most counts and remanded three counts to the state court for resolution. Deaton appealed, arguing that the district court improperly found that probable cause to arrest him existed, improperly denied his post-judgment motion, and should have abstained and remanded to state court to allow the state claims to be resolved.The district court had granted summary judgment in favor of the defendants, finding that there was probable cause for Deaton's arrest. The court also denied Deaton's post-judgment motion for relief. Deaton appealed these decisions, arguing that the district court had improperly found probable cause for his arrest, improperly denied his post-judgment motion, and should have abstained from hearing the case and remanded it to state court.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that the district court had correctly determined that there was probable cause for Deaton's arrest. The court also found that the district court had not erred in denying Deaton's post-judgment motion for relief. Finally, the court determined that abstention was not appropriate in this case, as resolution of the state law question would not avoid the need to resolve a significant federal constitutional question. View "Deaton v. Town of Barrington" on Justia Law

The case involves a defendant who was convicted of first-degree murder with special circumstances and an enhancement for personally and intentionally discharging a firearm causing great bodily injury or death. The defendant appealed his conviction, arguing that his trial counsel exhibited racial bias towards him in violation of the California Racial Justice Act of 2020 (RJA) by advising him to use Ebonics and slang when he testified. He also contended that the trial court erred in imposing two sentence enhancements and a parole revocation restitution fine after sentencing him to life without the possibility of parole.The Court of Appeal of the State of California, First Appellate District, Division Five, found that the defendant's trial counsel did not exhibit racial bias. The court noted that the counsel's advice to the defendant to "speak how you speak" when testifying was a valid tactical decision aimed at ensuring the defendant appeared authentic and genuine before the jury. The court also found that the defendant had not demonstrated by a preponderance of the evidence that his counsel's advice indicated racial animus or bias towards him. Therefore, the court concluded that there was no violation of the RJA.The court also found that the defendant's claim that his enhancements should have been stricken was forfeited for failure to request that the trial court strike the enhancements under section 1385. However, the court agreed with the defendant and the People that the trial court improperly imposed a parole revocation restitution fine. The court modified the judgment to strike the parole revocation restitution fine and affirmed the judgment in all other respects. View "P. v. Coleman" on Justia Law

In May 2019, police officers detained Marlon Flores in a Los Angeles neighborhood known for narcotics and gang activity. The officers observed Flores standing alone near a parked car, ducking behind it as they approached. The officers suspected Flores was involved in narcotics activity due to his behavior and the area's reputation. During a pat-down search, the officers found a drug pipe in Flores's car and methamphetamine in his wallet. Flores was subsequently charged with carrying a loaded firearm and armed possession of methamphetamine.The trial court denied Flores's motion to suppress the evidence, reasoning that his behavior was suspicious enough to warrant detention and subsequent questioning. Flores pleaded no contest to the firearm charge, and the methamphetamine charge was dismissed. He was sentenced to three years' probation. The Court of Appeal affirmed the judgment, concluding that Flores was not detained until he was ordered to stand and put his hands behind his head, and that reasonable suspicion justified the detention.The Supreme Court of California reversed the lower courts' decisions. The court held that the officers' observations of Flores's behavior, combined with his presence in a high crime area at night, did not provide a particularized and objective basis for suspecting that Flores was engaged in illegal activity. The court emphasized that a person's mere presence in a high crime area cannot transform them into a suspect. The court concluded that the officers lacked reasonable suspicion to detain Flores, and thus, the evidence obtained during the pat-down search should have been suppressed. The case was remanded to the trial court to allow Flores to withdraw his no contest plea and for the court to grant Flores's suppression motion. View "P. v. Flores" on Justia Law