Justia Civil Rights Opinion Summaries

This case involves a federal habeas corpus petition by Darnell Dixon, who was convicted of home invasion and murder by an Illinois state court and sentenced to life imprisonment. Dixon's habeas petition primarily focused on claims of actual innocence and prosecutorial misconduct. The United States Court of Appeals for the Seventh Circuit affirmed the denial of his habeas petition by the United States District Court for the Northern District of Illinois.The case involved a series of events including a drug-related robbery and subsequent murders. Dixon and Eugene Langston were implicated in the murders, with Langston identified in a police lineup by a witness, Horace Chandler. However, Chandler later recanted this identification. The state's case against Dixon relied heavily on a confession that Dixon later claimed was false. Dixon's confession and Chandler's identification of Langston were central to the state's theory of accomplice liability, arguing that Dixon was accountable for Langston's acts.In his habeas petition, Dixon argued that he was denied due process when the trial court excluded evidence that charges against his alleged accomplice, Langston, were dismissed. He also asserted that his trial counsel was ineffective for failing to object to the exclusion of that evidence. Furthermore, Dixon claimed that the state committed prosecutorial misconduct by presenting conflicting positions regarding Langston's involvement in the murders at trial and during post-conviction proceedings.However, the Seventh Circuit found that Dixon's claim of actual innocence, based on the state's post-conviction contention that Langston's involvement was irrelevant and evidence of abusive and perjurious conduct by the case's police detective, did not meet the high standard required to conclusively prove his innocence. The Seventh Circuit also rejected Dixon's arguments of prosecutorial misconduct and ineffective assistance of counsel, finding no clear error in the district court's factual findings on these issues. View "Darnell Dixon v. Tarry Williams" on Justia Law

In November 2018, Joseph Hoskins was stopped by a Utah state trooper, Jared Withers, because his Illinois license plate was partially obscured. The situation escalated when Trooper Withers conducted a dog sniff of the car, which led him to search the car and find a large amount of cash. Mr. Hoskins was arrested, and his DNA was collected. Mr. Hoskins sued Trooper Withers and Jess Anderson, Commissioner of the Utah Department of Public Safety, alleging violations of the First and Fourth Amendments and state law.The United States Court of Appeals for the Tenth Circuit held that Trooper Withers had reasonable suspicion to conduct the traffic stop because Utah law requires license plates to be legible, and this applies to out-of-state plates. The court also found that the dog sniff did not unlawfully prolong the traffic stop, as Mr. Hoskins was searching for his proof of insurance at the time. The court ruled that the trooper's protective measures, including pointing a gun at Mr. Hoskins, handcuffing him, and conducting a patdown, did not elevate the stop into an arrest due to Mr. Hoskins's confrontational behavior.The court further held that the dog's reaction to the car created arguable probable cause to search the car and that the discovery of a large amount of cash provided arguable probable cause to arrest Mr. Hoskins. The court found that Trooper Withers did not violate any clearly established constitutional rights by pointing a gun at Mr. Hoskins in retaliation for protected speech or as excessive force. Lastly, the court found no violation of Mr. Hoskins's due process rights related to the handling of his DNA sample, as neither the Due Process Clause nor state law created a protected interest in a procedure to ensure the destruction of his DNA sample. View "Hoskins v. Withers" on Justia Law

In the case of People v. Ramirez, Fernando Ramirez, the defendant, was convicted of causing a three-car collision while intoxicated, resulting in one death and four serious injuries. During the trial, which took place amidst the COVID-19 pandemic, safety protocols such as social distancing and mask-wearing were implemented. The defendant objected to these measures, claiming they impeded his ability to fully observe the facial expressions of prospective jurors, thereby infringing on his rights to be present at all material stages of his trial and to meaningfully contribute to his defense. The New York Court of Appeals disagreed, stating that neither a defendant's right to be present during jury selection nor due process requires that a defendant have a simultaneous, unobstructed view of the entirety of every prospective juror's face during jury selection. The Court affirmed that the safety protocols did not violate the defendant's right to be present and observe the jury selection process, and there was no violation of due process.The defendant also requested a mistrial after observing the deceased victim's surviving spouse crying in the courtroom. He argued that this could induce undue sympathy from the jury. However, the trial court denied the motion, as the crying was not conspicuous and there was no indication the jury was aware of it. The court further offered a curative instruction to prevent sympathy, which the defense counsel declined. The New York Court of Appeals upheld the trial court's decision, affirming that there were no grounds for a mistrial. View "People v Ramirez" on Justia Law

This case involves an appeal from the United States District Court for the District of South Dakota filed by the defendant, Nathaniel Crawford. Crawford was involved in a domestic dispute with his ex-girlfriend at an apartment complex, which led to concerned residents calling 911, reporting that Crawford was threatening to shoot a person or burn the complex. After officers arrived at the scene, Crawford fled but returned later to threaten his ex-girlfriend with a firearm. He fled again before officers could arrive; however, they found him and his vehicle in a nearby parking lot. Officers identified a wooden object protruding from the vehicle's center console, which they inferred to be a firearm. Crawford was subsequently charged with being a prohibited person in possession of a firearm due to his prior felony and misdemeanor domestic violence convictions.Crawford moved to suppress the firearm, arguing that officers lacked probable cause to search his vehicle. The district court denied his motion, leading to Crawford's appeal. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision, agreeing that the 911 calls, the ex-girlfriend's statements, and the wooden object established probable cause for the vehicle search. The court ruled that the officers' search was supported by probable cause based on the combination of these factors, establishing probable cause to search Crawford's vehicle for a firearm. The court also rejected Crawford's arguments that the search was unreasonable due to the officers' original investigation of him for a different crime and their lack of knowledge about his status as a prohibited person under federal law. The court maintained that the government can search for evidence of one crime and charge the suspect with a different crime based on what it later learns. The court concluded that the "fruit of the poisonous tree" was admissible because the tree in this case was not poisonous. View "United States v. Crawford" on Justia Law

In this case, the Supreme Court of the State of Illinois affirmed the lower courts' decisions denying Darrell Fair's claim of torture. Fair, who had been convicted of a felony, appealed the circuit court’s denial of his claim of torture under the Illinois Torture Inquiry and Relief Commission Act. The Supreme Court held that a court analyzing a claim of torture under the Act must consider the totality of the circumstances, including any allegations of constitutional violations that would not by themselves support a freestanding claim of torture under the Act. However, the court ultimately concluded that the circuit court’s determination that Fair failed to prove his claim of torture was not manifestly erroneous. The court found that Fair had not shown by a preponderance of the evidence that under the totality of the circumstances, the combination of acts alleged were sufficiently severe to constitute torture. The court emphasized the circuit court’s credibility determinations as the fact finder at the evidentiary hearing, where it found Fair to be a "wholly incredible witness," while another witness was "extremely" credible. View "People v. Fair" on Justia Law

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