Justia Civil Rights Opinion Summaries

The Supreme Court reversed the judgment of the district court granting Defendant's motion to dismiss the charge against him for violation of his due process rights, holding that Defendant's due process rights were violated, but the district court abused its discretion in granting the extreme remedy of dismissal under the facts of this case.After Defendant was charged with sexual assault the district court found him to be incompetent to stand trial and ordered him remanded to a psychiatric hospital for competency restoration treatment. After a delay of over 160 days during which he remained in jail, Defendant was transferred to the hospital. Defendant moved to dismiss the complaint on the ground that his continued detention in jail violated his due process rights. The district court granted the motion to dismiss. The Supreme Court reversed, holding (1) this Court's precedent did not support the district court's conclusion that aggravated circumstances warranted dismissing the complaint against Defendant with prejudice; and (2) the district court neglected to balance the deterrent objectives of dismissal against society's interest in prosecuting criminal acts. View "State v. Gonzalez" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in admitting certain testimony pursuant to the constancy of accusation doctrine; (2) the trial court did not err in excluding impeachment evidence of pending criminal charges against the State's key witness; and (3) the first degree of sexual assault charge was not ambiguous and therefore did not violate Defendant's right to jury unanimity under the Sixth Amendment. View "State v. Velasquez-Mattos" on Justia Law

Conner was convicted in Indiana state court for three counts of felony drug dealing and maintaining a common nuisance. Conner qualified as a habitual offender and was sentenced to an aggregate term of 72 years in prison. He had remained in custody pre-trial, but there was a delay of 1,029 days from the charging date (1,034 days from his arrest). Conner’s attorney never made a Sixth Amendment objection to the pretrial delays and Conner’s own objections were rejected because he was represented by counsel. State courts rejected his post-trial Sixth Amendment and ineffective assistance claims. Conner was advised by his postconviction counsel to postpone filing his federal habeas petition until the U.S. Supreme Court ruled on the petition for a writ of certiorari filed after his state postconviction proceedings. Conner relied on that advice, to his detriment. The one-year period in which to file the habeas petition continued to run while the certiorari petition was pending.The district court dismissed his subsequent habeas petition as untimely, 28 U.S.C. 2244(d)(1)(A) & (d)(2). The Seventh Circuit affirmed, acknowledging that the postconviction lawyer’s mistake was particularly grave but holding that Supreme Court and circuit precedent j foreclose equitably tolling the deadline. View "Conner v. Reagle" on Justia Law

Three men joined in a shootout, but only Rogers was convicted of murdering a bystander caught in their crossfire. At his trial, Rogers’s attorney did not object while the trial judge admonished a trial witness (Singleton) about perjury after that witness gave testimony favorable to Rogers. The attorney offered no arguments when Singleton changed his testimony and did not cross-examine Singleton about the change. The Third Circuit reversed the denial of habeas relief. Counsel’s failure to object to the trial judge’s admonishment, conduct he “did not think” was problematic, fell below an objective standard of reasonableness under “Strickland” as did counsel’s later failure to cross-examine Singleton regarding his changed testimony. Counsel characterized Singleton as “a liar, trying to help his buddy out,” whose testimony would not be “determinative of the outcome of this case,” but Singleton was the only witness to ever claim Rogers shot first—the ultimate issue in the case. Had Rogers’s counsel objected to the trial judge’s admonishment of Singleton and cross-examined Singleton about his changed testimony, “a reasonable probability” exists that “the result of the proceeding would have been different.” Without Singleton’s testimony against Rogers, the prosecution’s remaining evidence was negligible. View "Rogers v. Superintendent Greene SCI" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant postconviction relief by ordering a substantive sentencing hearing, holding that, under the circumstances of this case, it would be manifestly unfair for the district court not to hold a substantive sentencing hearing in accordance with State v. Warren, 592 N.W.2d 440 (Minn. 1999).After a jury trial, Defendant was convicted of two counts of first-degree murder. Defendant was seventeen years old when he committed the offenses. The district court sentenced Defendant to two consecutive sentences of life in prison without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, the district court resentenced Defendant to two consecutive sentences of life in prison with the possibility of release after thirty years. The Supreme Court affirmed. Defendant subsequently filed his postconviction petition requesting a substantive hearing to consider whether, pursuant to the test articulated in Warren, his modified sentences should be served concurrently rather than consecutively. The district court granted the petition. The Supreme Court affirmed, holding that the unique circumstances of this case warranted the exercise of this Court's inherent supervisory powers to direct that the district court hold a substantive sentencing hearing in accordance with Warren. View "State v. Thompson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of felony domestic assault-harm under Minn. Stat. 609.2242, subds. 1(2), 4, holding that there was no error in the proceedings below and that the evidence was sufficient to support the conviction.On appeal, the court of appeals concluded that the district court erred by instructing the jury that Defendant could use reasonable force to resist an "assault against the person" rather than to resist any "offense against the person" but that the error was not plain and that sufficient evidence supported the conviction. The Supreme Court affirmed, holding (1) use of nonlethal self-defense under section 609.06, subd. 1(3) requires a person to resist an offense carrying the threat of bodily harm; (2) the district court's use of the phrase "assault against the person" in the jury instruction at issue was not error; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Lampkin" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying Appellant's petition for postconviction relief without an evidentiary hearing, holding that Appellant was conclusively entitled to no relief on his claims even if the facts alleged were proven by a preponderance of the evidence.Appellant, who was imprisoned for first-degree premeditated murder, filed a petition seeking postconviction relief and an evidentiary hearing, arguing that he was deprived of his Sixth Amendment right to effective assistance of appellate counsel in his direct appeal. The district court summarily denied relief. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the postconviction petition without an evidentiary hearing. View "Woodard v. State" on Justia Law

Based on a tip from foreign law enforcement, Kentucky Detective Gatson and federal agents went to Lewis’s home. Lewis invited them inside and signed a form, consenting to “a complete search of the premises, property or vehicle” and electronic devices. A forensic examiner arrived and generated a preview of Lewis’s laptop, which revealed file names indicative of child pornography; on Lewis’s cell phone, he found thumbnail images of Lewis’s cousin’s children bathing naked. Lewis reportedly stated that he did not know that it was illegal to look at child pornography, then invoked his Miranda rights but did not say that he was revoking his consent to search. Gatson obtained a warrant. A forensic search of the seized devices revealed evidence of child pornography on Lewis’s laptop, cell phone, and USB thumb drive.The district court found that the search warrant failed to establish probable cause but that suppression was inappropriate because officers had relied on the warrant in good faith. Lewis conditionally pleaded guilty to producing child pornography, 18 U.S.C. 2251(a). The Sixth Circuit vacated. Lewis consented to the initial search of his laptop and cell phone and the officers’ account of that search and the preview generated were validly obtained and are admissible. All other evidence taken from Lewis’s electronic devices was obtained through searches and seizures that were not supported by a valid warrant. The warrant affidavit stated only Gatson’s conclusory belief that a suspect committed a crime and could not establish probable cause, which precludes the application of the good-faith exception to the exclusionary rule. View "United States v. Lewis" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's second-degree murder conviction, holding that the evidence was sufficient to support a jury finding that Defendant was the aggressor when she shot and killed the victim, and therefore, the trial court did not err in giving an instruction on the aggressor doctrine.At issue was the proper application of North Carolina's castle doctrine statute. See N.C. Gen. Stat. 14-51.2(b). Defendant and the victim in this case had a tumultuous relationship, and on the day of the murder Defendant had warned the victim not to come to her residence. The victim came anyway and was shot and killed. Defendant was convicted of second-degree murder. The court of appeals remanded the case for a new trial, holding that the trial court improperly instructed the jury on the aggressor doctrine. The Supreme Court reversed, holding that the trial court properly instructed the jury that if it found that Defendant was the aggressor, the presumption in section 14-51.2 was no longer available for her. View "State v. Hicks" on Justia Law

The Supreme Court affirmed the jury verdict that Defendant was guilty of the first-degree murder of a young child as well as of first-degree kidnapping, sexual offense with a child and felony child abuse inflicting serious injury, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to disqualify the trial judge; (2) the trial court erroneously admitted at trial a full-body photograph of the victim during certain testimony, but the error was not prejudicial; (3) the trial court may have improperly allowed certain witnesses to testify about their emotional reactions to seeing the victim's injuries, but the evidence was not prejudicial; (4) the trial court erred in denying Defendant's second motion to suppress a statement he made to law enforcement officers at a hospital, but there was no prejudice; (5) there was no cumulative prejudice; (6) there was no error in the trial court's rulings related to Defendant's attempt to establish a prima facie case of racial or gender-based discrimination; (7) North Carolina's death sentence system is constitutional; and (8) Defendant received a fair trial and capital sentencing proceeding. View "State v. Richardson" on Justia Law