Justia Civil Rights Opinion Summaries

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

The case concerned Everett Maynard, a police officer in West Virginia, who was convicted of deprivation of rights under color of law. This conviction was based on his use of excessive force against an arrestee, Robert Wilfong, which resulted in Wilfong being hospitalized with a broken nose and lacerations on his upper head. During the trial, witnesses were required to wear face masks due to the COVID-19 pandemic. Maynard appealed his conviction, arguing that the mask requirement violated his Sixth Amendment rights, and that the district court erred in applying sentencing enhancements for obstruction of justice and for causing "serious bodily injury."The United States Court of Appeals for the Fourth Circuit affirmed the conviction and sentence. It held that the mask requirement did not violate Maynard's Sixth Amendment right, as the protection against the spread of COVID-19 is an important public policy interest and the reliability of the witnesses’ testimony was assured. This was because the witnesses were under oath, cross-examined, and the jury could observe their demeanor. The court also found no error in the application of sentencing enhancements. The court agreed with the district court's finding that the injuries inflicted on Wilfong constituted "serious bodily injury," and affirmed the application of the obstruction of justice enhancement, finding that a defendant's perjurious testimony at trial is relevant to sentencing because it reflects on a defendant’s criminal history, willingness to obey the law, and general character. View "US v. Maynard" on Justia Law

In the case from the Court of Appeal of the State of California, First Appellate District, Division Five, the 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, appealed his conviction on the grounds that his trial counsel exhibited racial bias towards him in violation of the California Racial Justice Act of 2020. He argued that his counsel's advice to testify in his natural linguistic style, which included the use of slang terms and a certain accent, displayed racial bias or animus. The court disagreed, ruling that advising a defendant to testify in an authentic and genuine manner did not indicate racial bias or animus and did not violate the Racial Justice Act. The defendant also argued that the trial court erred in imposing two sentence enhancements and a parole revocation restitution fine. The court agreed that the parole revocation restitution fine should be stricken, as the defendant was sentenced to life without the possibility of parole. The judgment was thus modified to remove the parole revocation restitution fine, but otherwise affirmed. View "People v. Coleman" on Justia Law

This case concerns Johnnie Wesley, who was brought in for questioning by Wisconsin police in connection with a murder investigation. Wesley invoked his right to remain silent during the initial interrogation, and the interrogation ceased. However, he was interrogated two more times, during which he made incriminating statements implicating himself in the murder. Wesley was subsequently charged with felony murder. He moved to suppress the incriminating statements on two grounds: (1) the officers did not honor his initial invocation of his right to remain silent, and (2) he unequivocally invoked his right to remain silent during the third interrogation. The motion was denied and Wesley was convicted. He then petitioned for a writ of habeas corpus in the Eastern District of Wisconsin, which was dismissed.On appeal to the United States Court of Appeals for the Seventh Circuit, the court affirmed the lower court's decisions. It held that the Wisconsin Court of Appeals reasonably applied Supreme Court precedent to Wesley’s case. The court determined that Wesley's right to remain silent was "scrupulously honored" after he invoked it during the first interrogation, and that he did not unequivocally invoke his right to remain silent during the third interrogation. The court reasoned that Wesley's statements during the third interrogation could reasonably be interpreted as exculpatory, rather than as an invocation of silence. View "Wesley v. Hepp" on Justia Law

In a case before the Supreme Court of the State of Wyoming, appellant Darrell Leonardo Alexander claimed that the district court erred in denying his motion to suppress evidence obtained by law enforcement after they entered his apartment without a warrant or his consent. The case revolved around the question of warrantless entry and consent.The court held that the warrantless entry into Alexander's apartment did not violate the Fourth Amendment. This was because the officers reasonably believed that Alexander's girlfriend, identified as E.B., had the apparent authority to consent to their entry. E.B. had called the police to report domestic violence, and when the officers arrived, she opened the door to the apartment and stepped inside, holding the door open for the officers. This action was seen as an invitation for the officers to enter the apartment.The court also found that E.B. had given implied consent for the officers to enter the apartment based on her nonverbal gestures and actions, such as opening the door and stepping inside when asked about the location of her boyfriend. Considering the totality of the circumstances, the court ruled that the officers' reliance on E.B.'s apparent authority to consent to their entry was reasonable. As such, the district court's decision to deny Alexander's motion to suppress the evidence was affirmed. View "Alexander v. The State of Wyoming" on Justia Law

The court case in question involves James McCray, a violent offender with mental health disorders (OMHD), who has been committed to the State Department of State Hospitals (DSH) since 2005. McCray appealed a 2022 order recommitting him for another one-year term, arguing that there was insufficient evidence to prove he represented a substantial danger to others due to his severe mental health disorder, that he voluntarily absented himself from his recommitment trial, and that the trial court did not obtain a knowing and intelligent waiver of his right to a jury from him before the trial.The Court of Appeal of the State of California First Appellate District Division Four dismissed McCray's appeal as moot since the recommitment order he appealed from had expired and he had been recommitted for another year. However, the court addressed his claim that the trial court failed to ensure he knowingly and intelligently waived his right to a jury trial, given its recurring importance.Upon review, the court found that the trial court relied entirely on McCray's counsel's brief questioning about his understanding of the right to a jury trial and did not take any steps to ensure McCray fully understood the significance of a jury trial and the difference between a bench trial and a jury trial. The court concluded that McCray did not make a knowing and intelligent waiver of his right to a jury trial, and highlighted the importance of the court directly informing an OMHD defendant about the right being waived to ensure a meaningful record of the defendant's understanding of a jury waiver. View "P. v. McCray" on Justia Law