Justia Civil Rights Opinion Summaries

David Dajuanta Wallace was convicted of felony murder and a firearm offense related to the shooting death of Darius Bottoms. Wallace argued that the evidence was insufficient, that his due process rights were violated by being required to wear a leg iron and prison clothing during the trial, and that he received ineffective assistance of counsel.A Fulton County grand jury indicted Wallace and two co-defendants for various crimes, including felony murder and gang activity. Wallace pled guilty to some charges and went to trial on others. The jury found him guilty of felony murder and a firearm offense. The trial court sentenced him to life in prison with the possibility of parole for felony murder and an additional five years for the firearm charge. Wallace's motion for a new trial was denied by the trial court.The Supreme Court of Georgia reviewed the case and found that the evidence was sufficient to support Wallace's convictions. The court held that the testimony of an accomplice was corroborated by other evidence, satisfying Georgia statutory law. Constitutionally, the evidence allowed the jury to find Wallace guilty as a party to the crimes rather than merely an accessory after the fact. The court also determined that any error related to Wallace wearing a leg iron was harmless beyond a reasonable doubt, given that the jury could not see the leg iron, Wallace used it strategically, and the strong evidence of his guilt.Regarding ineffective assistance of counsel, the court concluded that Wallace failed to show either deficiency or prejudice. The court affirmed Wallace's convictions and the trial court's rulings. View "WALLACE v. THE STATE" on Justia Law

The Texas Department of Public Safety detained and arrested the appellant for criminal trespassing as part of Operation Lone Star in Maverick County. Unlike the appellant, the two women in his group were transferred to the custody of the U.S. Border Patrol. The appellant claimed selective arrest and prosecution based on his sex and sought relief through pretrial habeas proceedings.The trial court held a hearing and heard testimony from various witnesses, including DPS officers and a client advocate. The court found that the appellant, along with other adult males, was arrested for criminal trespass while the women were transferred to federal custody due to jail capacity issues. The trial court denied the appellant's pretrial writ and motion to dismiss, concluding there was no sex discrimination.The Fourth Court of Appeals, sitting en banc, held that the appellant's claim was cognizable on pretrial habeas and found that he had demonstrated a prima facie case of sex discrimination. The appellate court reversed the trial court's ruling and remanded the case to allow the State to rebut the presumption of sex discrimination under strict scrutiny.The Court of Criminal Appeals of Texas reviewed the case and agreed that the appellant's claim was cognizable. However, the court found that the appellant failed to meet the demanding burden of showing a prima facie case of selective enforcement or prosecution. The court noted that the evidence suggested the discriminatory effect was due to logistical issues during an ongoing state of emergency, rather than intentional sex discrimination. The court reversed the appellate court's decision and affirmed the trial court's denial of relief. View "EX PARTE APARICIO" on Justia Law

In this case, the defendant was charged with possessing a stolen firearm and receiving a firearm while under felony indictment. Law enforcement found the stolen firearm in a vehicle owned by another individual, who later revealed that the defendant had left the gun in his car. The defendant admitted to touching the gun and knowing it was stolen. He was under felony indictment for other firearms offenses at the time.The United States District Court for the Southern District of Ohio denied the defendant's motion to dismiss the indictment, which argued that the statutes under which he was charged violated the Second Amendment. During jury selection, the defendant raised a Batson challenge against the prosecutor's peremptory strike of the last black juror on the panel. The district court found the prosecutor's reasons for the strike to be race-neutral and allowed it. The jury convicted the defendant on both counts, and he was sentenced to 18 months' imprisonment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court upheld the district court's denial of the motion to dismiss, finding that the statutes in question were consistent with historical firearm regulations and did not violate the Second Amendment. The court also affirmed the district court's rejection of the Batson challenge, concluding that the prosecutor's race-neutral explanation for the peremptory strike was credible and not pretextual. The Sixth Circuit affirmed the defendant's conviction and sentence. View "United States v. Gore" on Justia Law

The defendant was convicted of sexual offenses against his granddaughter and sentenced to state prison followed by five years of supervised probation. The probation conditions included GPS monitoring and a requirement to stay away from the victim and her family. After his release, the defendant moved to vacate the GPS condition, arguing it was unconstitutional without an individualized determination of its reasonableness, as required by a recent court decision.The Superior Court judge denied the motion, finding the GPS condition reasonable and added exclusion zones for the cities of Framingham and Marlborough, which were not specified in the original sentence. The defendant appealed, arguing that the GPS condition was unreasonable and that adding exclusion zones violated double jeopardy principles.The Supreme Judicial Court of Massachusetts reviewed the case. It held that the addition of exclusion zones did not violate double jeopardy because the original sentence contemplated such zones. However, the court found that the scope of the exclusion zones, covering entire cities, was overly broad and increased the severity of the defendant's sentence. The court affirmed the GPS condition as reasonable, given the seriousness of the offense and the defendant's moderate risk of reoffense, but remanded for revision of the exclusion zones to be consistent with statutory and probationary goals.The court also directed the probation department to remove GPS monitors from defendants who had not received a reasonableness hearing and to refrain from attaching monitors until such hearings are held, ensuring compliance with constitutional requirements. View "Commonwealth v. Rodriguez" on Justia Law

In 1990, the petitioner was convicted of murder, largely based on two cross-racial eyewitness identifications. Both witnesses initially identified another person as the shooter but later identified the petitioner, who was the only Black man at the defense table during a probable cause hearing. The petitioner challenged the identification procedures and jury instructions on appeal, but the Connecticut Supreme Court upheld his conviction.The petitioner filed a habeas petition in 2016, claiming that the admission of unduly suggestive and unreliable eyewitness identification evidence violated his due process rights. He also argued that advances in the science of eyewitness identification since his conviction called into question the validity of his conviction. The habeas court dismissed these claims, concluding they were barred by res judicata and that the decisions in State v. Guilbert and State v. Dickson did not apply retroactively. The court also dismissed and denied other claims of ineffective assistance of counsel.The Connecticut Supreme Court reviewed the case and concluded that the principles set forth in Dickson, which addressed the suggestiveness of first-time, in-court identifications, must apply retroactively on collateral review. The court reasoned that the rule in Dickson was a result of scientific developments that significantly improve the accuracy of convictions and that the petitioner had raised similar claims in his direct appeal. The court reversed the Appellate Court's decision and remanded the case for a trial on the petitioner's due process and actual innocence claims, directing the lower court to apply the holding of Dickson retroactively. View "Tatum v. Commissioner of Correction" on Justia Law

Derrick Patterson pleaded guilty to one count of Hobbs Act robbery and one count of identity theft. Patterson met his victim through Grindr, a dating application, and during their encounter, he took the victim’s phone and used it to withdraw money from the victim’s bank accounts.The United States District Court for the Central District of California sentenced Patterson to 111 months in prison, including a three-level enhancement for hate crime motivation under U.S.S.G. § 3A1.1. The district court rejected Patterson’s argument that the enhancement required a finding that he was motivated by hate. Patterson appealed the sentence.The United States Court of Appeals for the Ninth Circuit reviewed the case and agreed with Patterson that the language of the enhancement was ambiguous. The court held that the enhancement requires a finding beyond a reasonable doubt that the defendant was motivated by hate or animus. The court concluded that the district court erred by imposing the enhancement without such a finding. Consequently, the Ninth Circuit vacated Patterson’s sentence and remanded the case for resentencing. View "USA V. PATTERSON" on Justia Law

Brian Watson was convicted in 2017 by a jury for the felony sale of a controlled drug (fentanyl) resulting in death. The prosecution's evidence included testimony from Dr. Daniel Isenschmid, a forensic toxicologist, who discussed toxicology tests conducted by his colleagues, revealing fentanyl and its metabolites in the victim's blood. Watson appealed, arguing that the trial court erred by allowing Dr. Isenschmid to testify about tests he did not perform. The New Hampshire Supreme Court affirmed the conviction, finding that Dr. Isenschmid's involvement in the case was sufficient to satisfy the Confrontation Clause.Watson then filed a habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the District of New Hampshire, claiming that his Confrontation Clause rights were violated by Dr. Isenschmid's testimony. The warden moved for summary judgment, which the district court granted, concluding that the state court's decision was neither contrary to nor an unreasonable application of Supreme Court precedent.The United States Court of Appeals for the First Circuit reviewed the case and upheld the district court's decision. The court found that Watson did not provide clear and convincing evidence to show that the state court's factual findings were incorrect. The court also determined that the state court's decision was not contrary to or an unreasonable application of clearly established federal law. The First Circuit noted that Dr. Isenschmid had personally reviewed all relevant documentation, data, and test results, and had issued and signed the toxicology report, making his testimony permissible under the Confrontation Clause. The court affirmed the district court's grant of summary judgment in favor of the warden. View "Watson v. Edmark" on Justia Law

In 2015, Brennan R. Trass was charged with first-degree felony murder and criminal possession of a firearm after killing Jose Morales during a drug deal. Trass admitted to the shooting, claiming self-defense. Before trial, the district court appointed multiple attorneys for Trass due to conflicts, causing significant delays. Two weeks before the trial in 2019, the court allowed Trass' attorneys to withdraw due to a conflict and ordered Trass to represent himself with standby counsel. During the trial, Trass was removed from the courtroom for refusing to participate, and his standby counsel took over. The jury convicted Trass.The Reno District Court initially handled the case, where Trass faced multiple attorney changes and delays. Trass filed a direct appeal, and the Kansas Supreme Court remanded the case to the district court to determine the feasibility of a retrospective competency hearing. The district court found Trass competent before and during his 2019 trial. Trass raised several issues on appeal, including violations of his right to counsel, speedy trial rights, and sufficiency of evidence.The Kansas Supreme Court reviewed the case and found that the district court violated Trass' Sixth Amendment right to counsel by forcing him to represent himself without proper advisories or warnings about the dangers of self-representation. The court concluded that Trass did not waive his right to counsel knowingly and intelligently, nor did he forfeit it through egregious misconduct. The violation of Trass' right to counsel constituted structural error, requiring automatic reversal of his convictions. The court also found no violation of Trass' statutory right to a speedy trial and sufficient evidence to support his felony-murder conviction. The case was reversed and remanded for a new trial before a different judge. View "State v. Trass" on Justia Law

Lucas Montel Howard, while detained in the Madison County jail, directed his friend Alissia Washington to purchase crack cocaine from a dealer. Law enforcement monitored their phone calls, and when Washington returned with the drugs, she was pulled over and instructed by Howard to hide the cocaine in her vagina. The drugs were later discovered during a search at the police department, leading to Howard and Washington’s indictment on felony drug charges. Washington entered a best-interest plea, while Howard went to trial and was found guilty of possession of cocaine with intent to sell and conspiracy to possess cocaine with intent to sell.The Madison County Circuit Court sentenced Howard as a nonviolent habitual offender and subsequent drug offender to sixty years for possession with intent to sell and twenty years for conspiracy, to run concurrently. Howard appealed, arguing insufficient evidence of intent to sell, a Confrontation Clause violation, double jeopardy, improper admission of Washington’s guilty plea, prosecutorial misconduct, ineffective assistance of counsel, and a sleeping juror issue.The Supreme Court of Mississippi reviewed the case and found that the evidence, including Howard’s phone calls and prior convictions, sufficiently supported the jury’s findings of intent to sell and conspiracy. The court held that the trial court did not abuse its discretion in limiting cross-examination or in handling the sleeping juror issue. The court also found no merit in Howard’s claims of double jeopardy, prosecutorial misconduct, or ineffective assistance of counsel. The cumulative error doctrine was deemed inapplicable as no errors were identified. Consequently, the Supreme Court of Mississippi affirmed Howard’s convictions and sentences. View "Howard v. State of Mississippi" on Justia Law

In 1998, Khyle Armando Briscoe, then 21, participated in a robbery with Shaun P. During the robbery, Briscoe and Shaun P. both had guns. A struggle ensued, resulting in Ben P., the robbery victim, fatally shooting Shaun P. Briscoe was charged with first-degree murder, robbery, and burglary, with firearm-use enhancements and a special circumstance of murder during a robbery and burglary. A jury convicted Briscoe on all counts, and he was sentenced to life without parole.Briscoe filed a motion in 2022 for a parole hearing under Penal Code section 3051, which allows certain youth offenders to seek parole but excludes those sentenced to life without parole for special circumstance murder. He argued that this exclusion violated equal protection under the California and U.S. Constitutions. The trial court denied his motion, adhering to the majority view that section 3051 did not violate equal protection. Briscoe appealed.The California Court of Appeal, First Appellate District, reviewed the case. The court noted that section 3051’s exclusion of youth offenders sentenced to life without parole for special circumstance murder was previously upheld in People v. Hardin. However, Briscoe raised a narrower challenge, arguing that excluding youth offenders sentenced under section 190.2, subdivision (d) for special circumstance murder, while including those convicted of first-degree felony murder under section 189, subdivision (e)(3), violated equal protection. The court agreed, finding no rational basis for treating these equally culpable offenders differently.The court reversed the trial court’s order and remanded the case for a Franklin proceeding and a section 3051 parole hearing, holding that section 3051’s exclusion of youth offenders sentenced under section 190.2, subdivision (d) for murder during a robbery or burglary violated equal protection. View "People v. Briscoe" on Justia Law