Justia Civil Rights Opinion Summaries

The First Circuit affirmed the judgment of the district court ruling that the underlying suit was time barred as to all defendants in this action brought by Plaintiff under 42 U.S.C. 1983 on behalf of her late son's estate on the six-year anniversary of his death, holding that the lawsuit was time barred.Plaintiff sued jail staff and a medical contractor (collectively, Defendants), alleging that while her son was detained in the Somerset County Jail, Defendants failed to recognize his serious mental illness, thus leading to his death following a suicide attempt. Defendants moved to dismiss the suit as time barred. The district court granted the motion. The First Circuit affirmed, holding that Plaintiff was not entitled to relief on her allegations of error. View "Martin v. Somerset County" on Justia Law

Trammel was sentenced to 12 years in prison: the upper term of eight years for kidnapping, a consecutive 16 months for burglary, a consecutive eight months for making criminal threats, and a consecutive two years for a June 2017 domestic violence conviction (one year for the conviction plus a year on an attached arming enhancement). The court imposed concurrent three-year terms for two remaining domestic violence convictions and concurrent time-served sentences for misdemeanors.The court of appeal concluded that the court erred by imposing separate punishment for both domestic violence and simple assault, based on the same incident. The trial court conducted a full resentencing, noting that new sentencing laws (effective January 2022) applied. The court reviewed a mitigation assessment and resentenced Trammel to 12 years and four months–eight years for kidnapping; a consecutive 16 months for burglary; a consecutive two years for a 2017 domestic violence conviction–one year for the conviction plus a year on the attached arming enhancement; and consecutive one-year terms on the remaining domestic violence counts. The court stayed the punishment for criminal threats and misdemeanors. The court found that the lower term or middle term would be inappropriate because Trammel showed no remorse.The court of appeal again remanded. The imposition of a longer sentence on remand violates the California Constitution’s prohibition against double jeopardy. The court rejected Trammel’s request for another full resentencing hearing before a different judge, finding no showing of vindictiveness. View "People v. Trammel" on Justia Law

The Court of Appeals reversed the judgment of the appellate division affirming Defendant's conviction on two counts of murder in the second degree and one count of robbery in the second degree, holding that the warrantless entry into Defendant's home was not based on consent, and therefore, the suppression court erred in denying Defendant's motion to suppress.Defendant was indicted on several charges including kidnapping, robbery, and felony murder. Defendant filed a motion to suppress, arguing that the warrantless, nonconsensual entry into his home was unlawful. The suppression court denied the motion. The appellate division affirmed. The Court of Appeals reversed, holding that the warrantless entry into the apartment in which Defendant was found by police officers and arrested violated Defendant's rights under the New York and United States Constitutions. View "People v. Cuencas" on Justia Law

The Court of Appeals reversed the order of the appellate division affirming Defendant's conviction, holding Supreme Court should have suppressed a gun as the product of an impermissible stop because the police officers lacked reasonable suspicion of criminal activity or probable cause that Defendant had violated the rules of the road while riding his bicycle.Defendant was riding his bicycle down a road when police officers drove alongside him and asked him to stop. Defendant stopped and, in response to an officer's question, admitted that he was carrying a gun. Defendant pleaded guilty to a weapons charge. The appellate division affirmed. The Court of Appeals reversed, holding (1) police interference with a bicyclist is a seizure requiring reasonable suspicion of a criminal offense or probable cause of a Vehicle and Traffic Law violation; and (2) the officers in this case violated the New York and United States Constitutions when they stopped Defendant, and therefore, the indictment against Defendant must be dismissed. View "People v. Rodriguez" on Justia Law

The Court of Appeals reversed Defendant's conviction for one count of criminal possession of a weapon in the second degree, holding that the record did not support the trial court's conclusion that Defendant was not in custody for purposes of Miranda v. Arizona, 384 US 436 (1966), when he was handcuffed and questioned by law enforcement officers.On appeal, Defendant argued that Supreme Court erred in denying his motion to suppress statements he made to police while handcuffed and the physical evidence found in his vehicle because the officers failed to read him his Miranda rights prior to questioning him and because he never voluntarily consented to a search of the vehicle. The Court of Appeals reversed Defendant's conviction, holding (1) Defendant was in custody and had not received Miranda warnings when he answered questions by the police officers and therefore, Supreme Court erred in denying Defendant's motion to suppress his responses to the officers' questions; and (2) the Miranda violation when Defendant was stopped and handcuffed did not render his later written consent to search his vehicle involuntary. View "People v. Cabrera" on Justia Law

The Court of Appeals affirmed Defendant's convictions of two counts of murder in the first degree and two counts of murder in the second degree, holding that the admission of two autopsy reports through an expert witness who did not perform the autopsies, combined with that witness's testimony, violated Defendant's constitutional right to confrontation, but the error was harmless.Defendant was convicted of murdering the two young children in her care by repeatedly stabbing them. The Court of Appeals affirmed the convictions, holding (1) People v. Freycinet, 11 NY3d 38 (NY 2008), should no longer be followed because it is inconsistent with the demands of the Confrontation Clause as recently articulated by the Supreme Court; and (2) Defendant's constitutional right to confrontation was violated by the admission of the autopsy reports and the testimony of the witness at issue, but the error was harmless beyond a reasonable doubt. View "People v. Ortega" on Justia Law

The Court of Appeals reversed the decision of the appellate division affirming Defendant's convictions for second degree robbery and petit larceny, holding that admission of a criminalist's testimony and underlying exhibits was error, and the error was not harmless, thus entitling Defendant to a new trial.On appeal, the appellate division ruled that Defendant's constitutional right to confrontation was not violated when the criminalist performed his own analysis about the creation of DNA profiles. The Court of Appeals disagreed and reversed, holding that because the record failed to establish that the testifying analyst had the requisite involvement with the DNA profiles the admission of the criminalist's testimony and underlying exhibits was erroneous, and the People did not establish that there was no reasonable possibility that the error might have contributed to Defendant's conviction. View "People v. Jordan" on Justia Law

The Supreme Court affirmed Defendant's conviction for operating while intoxicated (OWI) and eluding, holding that the district court did not abuse its discretion in admitting evidence about a preliminary breath test (PBT) and that the evidence was sufficient to support the convictions.During the underlying jury trial, the district court admitted a portion of an officer body cam video showing Defendant agreeing to a PBT, after which the edited video jumped to Defendant's arrest for OWI. The Supreme Court held (1) this juxtaposition of the PBT and arrest violated Iowa R. Evid. 5.403 because it had minimal probative value while strongly implying that Defendant had failed the PBT, but the error was harmless; and (2) there was sufficient evidence to sustain Defendant's eluding conviction. View "State v. Amisi" on Justia Law

The Supreme Court held that the district court and court of appeals did not err in finding that Defendant was not seized before the law enforcement officer who eventually arrested him discovered his probable intoxication and that Defendant was lawfully detained on grounds of probable intoxication.In his motion to suppress, Defendant argued that he had been seized when the officers partially blocked him in while he was parked in a parking lot, trained a spotlight on him, and shined flashlights into his car from both sides. The trial court concluded that Defendant had not been "seized" before the police discovered his intoxication. The court of appeals affirmed, concluding that the officers' actions were not "sufficiently coercive" to constitute a seizure. The Supreme Court affirmed, holding that Defendant was lawfully detained because the officers did not seize him before his intoxication was observed. View "State v. Wittenberg" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to suppress and convicting him of firearm violations, holding that the law enforcement officer who arrested Defendant did not unlawfully seize Defendant.After a woman called the police to report a suspicion car parked in front of her home an officer responded in a patrol car and pulled alongside the parked car. The officer walked over to talk to the driver, smelled a strong odor of burnt marijuana, and searched Defendant and the car. In his suppression motion, Defendant argued that the officer did not unlawfully seize him. The court of appeals concluded that the trial court did not err in denying the motion to suppress. The Supreme Court affirmed, holding that the officer's conduct in this case did not constitute a seizure, and once the officer detected the odor of burnt marijuana he had a lawful ground to detain and search Defendant and the car. View "State v. Cyrus" on Justia Law