Justia Civil Rights Opinion Summaries

The petitioner was convicted of capital murder and sentenced to death in Texas in 2010 for the killing of his fiancée’s thirteen-month-old daughter. The prosecution’s case relied heavily on DNA evidence and forensic testimony. Over the years, the petitioner pursued multiple avenues of postconviction relief, including direct appeal, state habeas petitions, and federal habeas petitions, all of which were denied. In 2024, he sought access to additional electronic DNA data from the Southwestern Institute of Forensic Sciences, arguing that this information was necessary to evaluate the reliability of the forensic evidence used at trial. After being denied access by the district attorney and the convicting court, he filed a lawsuit under 42 U.S.C. § 1983, claiming that Texas’ postconviction relief procedures violated his due process rights by giving prosecutors unreviewable discretion to withhold evidence.The United States District Court for the Eastern District of Texas dismissed the § 1983 complaint for failure to state a claim, finding that the petitioner had not sufficiently alleged a due process violation and that his request for an injunction resembled an improper petition for a writ of mandamus. The district court also denied his motion for discovery. The petitioner appealed and, in the interim, sought a stay of execution and authorization to file a successive habeas petition based on new evidence and scientific developments.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s dismissal, holding that Texas’ postconviction relief procedures do not violate due process, as they provide adequate opportunities for discovery and judicial review in habeas proceedings. The court also denied the motions for a stay of execution and for authorization to file a successive habeas petition, finding that the petitioner failed to meet the stringent requirements for such relief. The court granted leave to file a motion in excess of the word limit. View "In Re: Milam" on Justia Law

In this case, the appellant was convicted of simple assault with a bias enhancement after an incident at a Metro station. The government’s evidence showed that the appellant approached a group, made derogatory remarks about their sexual orientation, and physically assaulted one of them multiple times. The assailant was later apprehended at a different Metro station and identified as the appellant. The charges were eventually narrowed to simple assault with a bias enhancement, and the appellant was found guilty by a jury.Prior to trial in the Superior Court of the District of Columbia, the appellant objected to the composition of the jury venire, arguing that it did not reflect a fair cross-section of the community, as only three of fifty-four potential jurors appeared to be African American. The trial judge denied the motion to strike the panel, finding that the appellant had not shown systematic exclusion of a group from the jury selection process. The judge also denied a subsequent, untimely request for access to jury selection records, reasoning that the request came only after the motion to strike had been denied and that no prior efforts had been made to obtain such records.On appeal, the District of Columbia Court of Appeals reviewed the sufficiency of the evidence and the fair cross-section claim. The court held that there was sufficient evidence for a reasonable juror to find the appellant guilty beyond a reasonable doubt, based on the testimony of the arresting officer and the circumstances of the arrest. The court also held that the trial court did not err in denying the motion to strike the jury panel or the belated request for jury selection records, finding that the denial was based on the untimeliness of the request rather than an improper threshold requirement. The judgment of the Superior Court was affirmed. View "Brown v. United States" on Justia Law

A Black defendant was convicted of multiple felonies, including attempted premeditated murder, torture, and assault, after a series of violent incidents. The most serious event occurred at a hotel, where the defendant attacked a night manager with a boxcutter, stabbed him, and then continued to assault him with a pen and by biting and headbutting him. The defendant also assaulted correctional officers on two separate occasions while in jail. At trial, the defense did not dispute the violent conduct but argued that the defendant lacked the specific intent required for the most serious charges, emphasizing his impulsive behavior and likening his actions to those of an animal.The case was tried in the San Mateo County Superior Court, where the jury found the defendant guilty on all charges presented. The court imposed consecutive sentences for attempted murder and torture, finding that the crimes involved separate acts of violence and objectives. The court also described the defendant’s conduct as “animalistic” at sentencing. The defendant appealed, arguing that his counsel’s and the court’s animal comparisons violated the California Racial Justice Act of 2020 (RJA), that the court erred in evidentiary rulings and sentencing, and that cumulative error deprived him of a fair trial.The California Court of Appeal, First Appellate District, Division Two, held that the defendant was procedurally barred from raising RJA claims based on his counsel’s animal comparisons because those statements were part of a deliberate defense strategy, invoking the doctrine of invited error. The court also found that the RJA claim regarding the trial court’s comment was forfeited due to lack of objection. The court rejected the defendant’s other claims, finding no evidentiary or sentencing error, and affirmed the judgment. View "People v. Midell" on Justia Law

A law enforcement agency in the District of Columbia, responsible for supervising individuals on supervised release, imposed GPS monitoring on a supervisee without judicial or Parole Commission authorization. The agency’s internal regulations permitted its officers to unilaterally require GPS monitoring as an administrative sanction, and this practice had been applied to thousands of supervisees over two decades. In this instance, the supervisee was placed on GPS monitoring twice, first for a positive drug test and then for submitting questionable urine samples. Subsequently, police investigating an armed robbery used the agency’s GPS data to identify and locate the supervisee, leading to his arrest and the recovery of stolen property and a firearm.The Superior Court of the District of Columbia reviewed the supervisee’s motion to suppress the GPS evidence and its fruits, following the District of Columbia Court of Appeals’ recent decision in Davis v. United States, 306 A.3d 89 (D.C. 2023), which held that the agency lacked statutory authority to impose GPS monitoring absent judicial or Parole Commission approval, rendering such searches unconstitutional. The government conceded the constitutional violation but argued that the good faith exception to the exclusionary rule should apply, as the agency reasonably relied on its own regulations. The trial court rejected this argument and granted the suppression motion.On appeal, the District of Columbia Court of Appeals affirmed the trial court’s ruling. The court held that the exclusionary rule applies because the agency is a law enforcement entity, not a neutral third party like a judge or legislature, and thus should feel the deterrent effect of suppression. The good faith exception does not apply when a law enforcement agency unilaterally authorizes unconstitutional searches based on its own mistaken interpretation of its authority. The court concluded that suppression is warranted to deter systemic constitutional violations. View "United States v. Wells" on Justia Law

In this case, the defendant was shot five times in his apartment parking lot and, in the chaos, dropped his black iPhone and a satchel. His girlfriend took the satchel but left the phone, which was later recovered by police near some shrubs. The police also seized a different (white) iPhone from the defendant at the hospital. The black iPhone remained in police evidence for over two years, until it became relevant in a separate federal drug investigation. The government ultimately used data from the black iPhone, along with other evidence, to charge the defendant with drug trafficking, firearm offenses, and money laundering.The United States District Court for the District of Oregon presided over the trial. Before trial, the defendant moved to suppress evidence from the black iPhone, arguing that he retained a privacy interest in the device and its data, and also sought recusal of the district judge due to her prior service as U.S. Attorney when he was prosecuted for unrelated charges over fifteen years earlier. The district court denied both motions, finding that the defendant had abandoned the black iPhone and thus lacked standing to challenge its search, and that recusal was not warranted.The United States Court of Appeals for the Ninth Circuit reviewed the case. The Ninth Circuit disagreed with the district court’s finding that the defendant had abandoned his privacy interest in the black iPhone, holding that the circumstances—dropping the phone while fleeing after being shot—did not show intent to abandon the device or its data. However, the Ninth Circuit affirmed the denial of the suppression motion because federal agents obtained a warrant and searched the phone within a reasonable period. The court also affirmed the denial of the recusal motion, concluding that a reasonable person would not question the judge’s impartiality under these facts. The conviction and sentence were affirmed. View "USA V. HUNT" on Justia Law

A New York State Police trooper stopped Daniel Delgado for erratic driving and discovered that his license was suspended. During an inventory search of his vehicle, the trooper found a loaded “ghost gun” and ammunition, which Delgado admitted belonged to him. Delgado had several prior convictions, including a felony conviction for attempted second-degree murder in Florida, where he had shot a man in the back. Delgado was indicted for possessing ammunition after a felony conviction, in violation of 18 U.S.C. § 922(g)(1), and pleaded guilty without a plea agreement.The United States District Court for the Southern District of New York denied Delgado’s motion to withdraw his guilty plea and to dismiss the indictment, finding that § 922(g)(1) did not violate the Second Amendment. At sentencing, the court determined that Delgado’s prior Florida conviction for attempted second-degree murder was a “crime of violence” under U.S.S.G. § 2K2.1(a), resulting in a higher base offense level. Delgado was sentenced to thirty months’ imprisonment and three years of supervised release. He timely appealed, challenging both the constitutionality of § 922(g)(1) and the classification of his prior conviction.The United States Court of Appeals for the Second Circuit reviewed the case. It held that Delgado’s constitutional challenge to § 922(g)(1) was foreclosed by its recent decision in Zherka v. Bondi, which reaffirmed the statute’s constitutionality after New York State Rifle & Pistol Ass’n v. Bruen. The court also held that Florida’s offense of attempted second-degree murder is categorically a crime of violence under the Sentencing Guidelines, as it requires an intentional act imminently dangerous to another and demonstrating a depraved mind. The Second Circuit affirmed the judgment of the district court. View "United States v. Delgado" on Justia Law

A man was accused of picking up a woman in El Paso, Texas, under the pretense of giving her a ride, then driving her across state lines to his home in Anthony, New Mexico, where he violently sexually assaulted her. The woman testified that she was handcuffed, physically assaulted, and raped multiple times before escaping at a stoplight in El Paso and seeking help. The defendant’s adopted daughter also testified that he had sexually assaulted her repeatedly when she was a minor and again as an adult.A federal grand jury in the United States District Court for the District of New Mexico indicted the defendant for kidnapping and transporting an individual across state lines with intent to engage in illegal sexual activity. At trial, the defendant argued that the encounter with the woman was consensual and related to commercial sex, and he sought to introduce evidence of her prior prostitution to support his consent defense. The district court excluded this evidence under Federal Rule of Evidence 412, finding it irrelevant to consent. The court also allowed the adopted daughter’s testimony under Rule 413, concluding that her allegations of prior sexual assault by the defendant were admissible and not unduly prejudicial under Rule 403. The jury convicted the defendant on both counts.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s evidentiary rulings. The court held that excluding evidence of the victim’s prior prostitution did not violate the defendant’s constitutional rights, as such evidence is not probative of consent under established precedent. The court also affirmed the admission of the adopted daughter’s testimony, holding that Rule 413 applies based on the conduct underlying the charges, not the statutory elements, and that the district court did not abuse its discretion under Rule 403. The court further found that the defendant had waived arguments regarding limitations on cross-examination of the adopted daughter. The convictions were affirmed. View "United States v. Clay" on Justia Law

Two individuals, both members of a San Francisco gang known as Mac Block, were involved in a shootout at a funeral reception that resulted in the death of a man named Simmons and injuries to several bystanders. The government alleged that the defendants, after a confrontation with Simmons, retrieved firearms and returned to the scene, where a gunfight ensued. One defendant was accused of aiding and abetting the murder, while the other was alleged to have directly participated in the shooting. Both were charged with murder in aid of racketeering under the VICAR statute and with being felons in possession of firearms.The United States District Court for the Northern District of California presided over the trial. Before trial, the court considered, but ultimately denied, a motion to bifurcate the trial so that the jury would first decide whether the defendants committed murder, and only if so, then consider the racketeering elements. The court concluded that Ninth Circuit precedent, specifically United States v. Barker, precluded such bifurcation. The court also addressed a Batson challenge to the government’s peremptory strike of a Black juror, finding the government’s race-neutral explanation sufficient and not pretextual. The jury convicted both defendants on all counts, and the court denied post-trial motions for acquittal and a new trial.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the convictions. The court held that Barker forecloses bifurcation of the elements of a single VICAR murder charge, reasoning that such bifurcation would impermissibly alter the structure of the offense as defined by Congress. The court also upheld the district court’s rejection of the Batson challenge, finding no clear error in the determination that the government’s strike was not racially motivated. The convictions were affirmed. View "USA V. MANNING" on Justia Law

Christopher Skaggs was released on parole in 2019 after serving a prison sentence for felony violations of the Vehicle Code. In December 2020, the Mendocino County District Attorney filed a petition to revoke his parole, alleging new criminal conduct, and also filed a related criminal complaint. Skaggs failed to appear for hearings, resulting in bench warrants. He was later arrested in Lake County on these warrants and new charges, convicted, and sentenced to additional prison time. While incarcerated, Skaggs repeatedly requested to resolve the Mendocino County parole revocation and criminal matters. The criminal complaint was dismissed under Penal Code section 1381, but the court declined to dismiss the parole revocation petition, finding section 1381 inapplicable.Skaggs subsequently filed a nonstatutory motion to dismiss the parole revocation petition on constitutional due process grounds, arguing that delays prejudiced him by preventing concurrent sentencing and prolonging his custody. The Mendocino County Superior Court construed his motion as a Penal Code section 1385 motion and denied it, reasoning that section 1385 does not apply to parole revocation proceedings. The court then held a contested revocation hearing, found Skaggs violated parole, sentenced him to 90 days in jail, and ordered his parole terminated upon release. Skaggs appealed the denial of his motion and the parole revocation.The California Court of Appeal, First Appellate District, Division Three, determined that Skaggs’s appeal was moot because his parole had already been terminated and no effective relief could be granted. However, the court exercised its discretion to address the trial court’s error, holding that the trial court improperly construed Skaggs’s constitutional due process motion as a section 1385 motion and incorrectly concluded it lacked authority to consider the motion. The appellate court clarified that trial courts have jurisdiction to entertain nonstatutory motions to dismiss parole revocation petitions on constitutional due process grounds. The appeal was dismissed as moot. View "People v. Skaggs" on Justia Law

The petitioner was convicted by an Arizona jury of child molestation after he helped bathe young girls who were in his and his wife’s care through the foster system. The relevant Arizona statute defined child molestation as any direct or indirect touching of a child’s private parts, and, at the time, allowed a defendant to raise an affirmative defense by proving he was not motivated by sexual interest. The petitioner admitted to the touching but argued he lacked sexual motivation.After his first trial ended in a mistrial, the Arizona Supreme Court decided State v. Holle, which held that sexual motivation was not an element of the crime and that the lack of sexual interest was an affirmative defense the defendant must prove by a preponderance of the evidence. At the petitioner’s second trial, the court instructed the jury accordingly, and he was convicted on some counts. The Arizona Court of Appeals affirmed, relying on Holle, and the Arizona Supreme Court denied review. The United States Supreme Court also denied certiorari. The petitioner then sought federal habeas relief in the United States District Court for the District of Arizona, arguing that the statutory scheme unconstitutionally shifted the burden of disproving an essential element of the crime to him. The district court denied relief, finding the state courts’ application of federal law was not objectively unreasonable.The United States Court of Appeals for the Ninth Circuit reversed. It held that Arizona’s statutory scheme violated the Due Process Clause of the Fourteenth Amendment by shifting to the defendant the burden of disproving sexual motivation, which is the critical fact distinguishing criminal from innocent conduct. The court concluded that the Arizona Court of Appeals’ decision upholding the conviction was an objectively unreasonable application of clearly established Supreme Court precedent. The Ninth Circuit ordered the district court to grant the writ of habeas corpus. View "BIEGANSKI V. SHINN" on Justia Law