Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's convictions for first-degree rape, first-degree sexual abuse, intimidating a participant in a legal process, and being a first-degree persistent felony offender and his sentence of twenty years' imprisonment, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the Commonwealth did not improperly comment on Defendant's right to remain silence during voir dire or deprive him of an impartial jury by making a burden-shifting argument to the venire should Defendant have chosen to testify; (2) the trial court did not err by denying Defendant's motion to strike two jurors for cause; and (3) no cumulative error occurred because no prejudicial error occurred. View "Finch v. Commonwealth" on Justia Law

The Supreme Court reversed Defendant's convictions for arson and attempted arson and otherwise affirmed, holding that the trial court erred in failing to grant a directed verdict in Defendant's favor as to the counts for arson in the first degree and attempted arson.Specifically, the Supreme Court held (1) hearsay statements regarding the victims' fear of Defendant were admissible under Ky. R. Evid. 803(3)'s state-of-mind exception; (2) the trial court did not err in permitting witnesses to invoke their Fifth Amendment privilege against self-incrimination; (3) the trial court properly precluded Defendant from presenting an aaltperp defense; (4) the trial court properly admitted physical evidence; (5) Defendant was entitled to a directed verdict on the charges of first-degree arson and attempted first-degree arson; (6) Defendant was not entitled to a directed verdict on the charges for murder; (7) Defendant's burglary convictions did not violate double jeopardy protections; and (8) reversal was not required on grounds of cumulative error. View "Martin v. Commonwealth" on Justia Law

The Court of Appeals affirmed the order of the appellate division affirming the judgment of Supreme Court denying Defendant's motion to suppress the firearm found in the vehicle he was driving, holding that the People sustained their burden of demonstrating that the inventory search protocol in this case met "the constitutional minimum."Two New York Police Department officers observed Defendant commit multiple traffic infractions while driving, stopped him, and arrested him for carrying a gravity knife in his pocket. At the precinct, the officers conducted an inventory search of the vehicle and recovered a firearm from the truck. Defendant filed a motion to suppress the firearm on the grounds that the NYPD's inventory search protocol was unconstitutional. The motion was denied, and Defendant pled guilty to criminal possession of a firearm. The Court of Appeals affirmed, holding that Defendant failed to overcome the People's proof establishing a valid inventory search protocol. View "People v. Douglas" on Justia Law

Zakhari, in a program to become a cardiothoracic surgeon, engaged in online sexually explicit conversations with a profile (boredcrbgirl) created by a detective, claiming to be a 15-year-old girl. He received an image of an officer. Zakhari sent an Uber to take boredcrbgirl to his apartment for sex. The officer arrived at Zakhari’s residence in the Uber. Zakhari was arrested. The detective interrogated him after giving the Miranda warnings. Zakhari said, “I can answer some questions and then maybe call.” After responding to basic questions, he said: My sister’s an attorney. Asked if he wanted to call her, Zakhari said “yeah,” then paused. The detective interjected that such a call would end the questioning. Zakhari continued to answer questions and made incriminating statements.Zakhari was convicted of attempting to persuade a minor to engage in illegal sexual activity, 18 U.S.C. 2422(b), attempting to transmit an obscene image to a minor, section 1470, and attempting to produce child pornography sections 2251(a)(e). Zakhari unsuccessfully moved to suppress his statements. The court declined to strike the third charge on grounds of prosecutorial vindictiveness.The Sixth Circuit vacated the convictions. The suppression motion should have been granted. The factual context shows Zakhari had “lawyerly assistance” in mind in wanting to call his sister and the invocation was not ambiguous. The court abused its discretion in failing to require the government to substantiate its explanations concerning Count 3. Zakhari showed enough to presume vindictiveness. View "United States v. Zakhari" on Justia Law

Castro-White died from a drug overdose. Detective Sivert noticed that Castro-White’s phone had many missed calls from Karaplis, who implicated others but lied to Sivert by denying any involvement. Later, after admitting his involvement, Karaplis described the drug dealer, “Red,” Red’s car, Red’s phone number, and, using Google Maps, the specific home where he bought drugs from Red. Sivert traveled to this home and spotted a nearby car p that fit Karaplis’s description and was registered to “Russell Davis,” called “Big Red.” Karaplis identified Davis’s picture with “100 percent” confidence. Sivert had Karaplis set up a phone call with Davis to discuss Castro-White’s death. Sivert then obtained a warrant to search Davis’s Garden Avenue home. During the search, police found the phone and illegal drugs. Davis unsuccessfully moved to suppress the evidence and was given a mandatory life sentence.The Sixth Circuit remanded for an evidentiary hearing about what Sivert told the magistrate in person. Although the magistrate described his general practice, he lacked a “specific recollection” of Davis’s case. Sivert was “sure” that he had conveyed the many facts connecting Davis to the home. The court again denied Davis’s motion, despite finding that the affidavit failed to establish a probable-cause nexus between Davis and the home. The Sixth Circuit affirmed. Sivert uncovered overwhelming evidence tying Davis to the home and the magistrate (not Sivert) bore any blame for failing to transcribe the additional oral testimony. View "United States v. Davis" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's denial of Defendant's motion to suppress and finding no error in her criminal trial, holding that the search for evidence in this case violated the Fourth Amendment and that remand was required.Defendant was convicted of trafficking in methamphetamine, possession with intent o manufacture, sell, or deliver methamphetamine, and possession of methamphetamine. The court of appeals affirmed. The Supreme Court reversed, holding (1) the search and subsequent seizure of contraband did not comport with the Fourth Amendment; and (2) remand was required for the trial court to determine if the evidence should be suppressed pursuant to the exclusionary rule. View "State v. Julius" on Justia Law

The Supreme Court affirmed the judgment of the district court overruling Defendant's motion to suppress and convicting her of possession of methamphetamine and drug paraphernalia following a stipulated bench trial, holding that the district court did not err when it overruled Defendant's motion to suppress.In denying Defendant's suppression motion, the trial court concluded that Defendant consented to a search of her vehicle, in which certain illegal items were found, and that a subsequent search of Defendant's person occurred incident to a valid arrest. The Supreme Court affirmed, holding (1) probable cause existed to arrest Defendant, and the subsequent search of her person occurred incident to a valid arrest; and (2) Defendant was not entitled to relief on her remaining allegations of error. View "State v. Hammond" on Justia Law

Fieste was charged with threatening to assault and murder two federal judges, three former U.S. presidents, and the current President. She is currently incompetent to stand trial. Fieste's mental illness causes her to experience delusions. In custody, Fieste refused the antipsychotic medication that experts believe will restore her competence. The government obtained permission to involuntarily medicate her to render her competent to stand trial. The order was stayed pending appeal.The Seventh Circuit affirmed but remanded. Fieste’s pretrial detention is insufficient to overcome the government’s interest in prosecution although Fieste’s anticipated Guidelines range is 12-18 months and she will “likely face a sentence of time served” if convicted. The district court properly conducted a holistic assessment to conclude that the proposed treatment plan is substantially likely to render Fieste competent and that the side effects are substantially unlikely to significantly interfere with her ability to participate in the proceedings. The order permitted Fieste to be medicated with “long-acting injectable anti-psychotic medication, along with other medications” suggesting impermissible flexibility to administer unspecified medications. The district court must provide a dosage range based on the expert’s recommendation or some other appropriate evidence, whether directly in its order or by incorporating a sufficiently detailed treatment plan. View "United States v. Fieste" on Justia Law

Lighthart had dated both Buchanan and the victim, who was known to have access to large amounts of money. Lighthart drove the victim to a residence, knowing that Buchanan was there intending to rob the victim. Buchanan beat the victim, demanding money, and eventually shot him to death. Lighthart then injected the victim with a solution that contained Drano or attempted to do so. After cleaning the scene, they disposed of the body by setting it on fire inside the victim’s Jeep in a rural field. In 2004, Lighthart, then 23, entered a partially negotiated plea of guilty to first-degree murder, in exchange for the dismissal of other charges and a sentencing cap of 35 years. Lighthart filed a motion to reduce her 35-year sentence and, subsequently, an untimely pro se motion to withdraw her plea, asserting that she was the victim of domestic violence and ineffective assistance of counsel. After an 11-½ year delay following remand and changes in counsel, the appellate court affirmed the dismissal of her 725 ILCS 5/122-1 post-conviction petition as untimely.The Illinois Supreme Court reversed. An ineffective notice of appeal from a negotiated guilty plea, which is dismissed for lack of appellate jurisdiction due to failure to follow procedural requirements (Illinois Supreme Court Rule 604(d)) triggers a six-month limitations period for bringing a postconviction petition. However, under the circumstances, Lighthart could not have been culpably negligent in the untimely filing of her petition. View "People v. Lighthart" on Justia Law

In 2012, Givens, Dudley, and Strong burglarized a store and attempted to escape by backing a van out of a closed garage door, striking a police officer. Chicago police officers fired their weapons at the van, resulting in Strong’s death and injuries to Dudley and Givens, who were convicted of felony murder, aggravated battery to a peace officer, and possession of a stolen motor vehicle.Dudley, Givens, and Strong’s estate sued the City, alleging the use of excessive force. With respect to Dudley and Givens, the circuit court granted Chicago summary judgment based on the collateral estoppel effect of their prior criminal proceedings. The estate’s lawsuit resulted in a partial verdict for the estate. The circuit court granted Chicago’s motion for judgment notwithstanding the verdict (JNOV) based on the jury’s answers to special interrogatories. The appellate court reversed, holding that collateral estoppel did not bar Dudley and Givens from litigating their claims and the circuit court erred in vacating the verdict.The Illinois Supreme Court agreed that collateral estoppel did not bar the suit by Dudley and Givens. Chicago did not establish with “clarity and certainty” that the identical question was decided in the earlier proceeding The court reinstated the JNOV. The circuit court properly held that the jury’s special finding related to an ultimate issue of fact upon which the rights of the parties depended and was clearly and absolutely irreconcilable with the verdict returned. View "Givens v. City of Chicago" on Justia Law