Justia Civil Rights Opinion Summaries

In 1994, Keith and his uncle were charged with cocaine trafficking based on information provided by Chatman, a confidential informant. Weeks later, someone shot six of Chatman’s relatives, killing three of them. A survivor identified Keith as his attacker. An Ohio jury convicted Keith of triple homicide and sentenced him to death.Keith has filed four federal habeas petitions; three have claimed “Brady” violations. This petition was filed after Keith received the personnel file for Yezzo, a forensic expert who testified at Keith’s trial that she could confirm that the perpetrator’s car had left a partial license plate imprint of the numbers “043” in the snow, matching the license plate on an Oldsmobile driven by Keith’s girlfriend (Davison) and that the tire tracks matched the tires Davison’s grandfather had purchased for the Oldsmobile—though they did not match the tires actually installed on it when the car was found. Yezzo’s file showed that Yezzo’s supervisors, colleagues, and union representatives had expressed concerns about the reliability of her work, even stating that Yezzo would “stretch the truth.” Keith submitted a new forensic analysis that concluded that the snow impressions were not consistent with the Oldsmobile. Ohio state courts again denied relief.The Sixth Circuit affirmed the denial of relief. Keith cannot show that no reasonable juror today would convict him in light of the “evidence as a whole.” The full record contains significant additional evidence of Keith’s guilt. View "Keith v. Hill" on Justia Law

In 2013, Coleman was convicted of conspiring to distribute crack cocaine, 21 U.S.C. 841(a)(1), (b)(1)(A), 846. Coleman was sentenced to the then-mandatory term of life imprisonment based on having at least two prior convictions for a “felony drug offense,” section 841(b)(1)(A). The Seventh Circuit affirmed.Coleman’s pro se motion to vacate his sentence, 28 U.S.C. 2255, asserted that his appointed counsel, Vaupel, was ineffective for failing to inform him of the government’s pretrial 21 U.S.C. 851 Notice of Enhancement, indicating its intention to seek life imprisonment based on his prior Illinois cocaine-related convictions. According to Coleman, had Vaupel shown him this notice, he never would have agreed to go to trial. Vaupel responded that he had repeatedly informed Coleman that he faced a mandatory life sentence and that the government was unwilling to waive the enhancement. Coleman moved to amend his petition to argue that Vaupel was ineffective by failing to argue that Coleman’s convictions did not qualify as “felony drug offenses” because Illinois defined “cocaine” more broadly than federal law. The district court denied Coleman’s section 2255 motion, and his motion to amend as not relating back to his initial pleading and untimely.The Seventh Circuit reversed. The district court must determine whether Vaupel considered a possible categorical challenge to Coleman’s predicate offenses and, if he did consider it, his reasons for not raising it. Coleman has established that he was prejudiced by counsel’s purportedly deficient performance. View "Coleman v. United States" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant, following a jury trial, of various firearm and controlled substance offenses, holding that none of Defendant's challenges on appeal had merit.Specifically, the First Circuit held (1) the district court correctly concluded that the search warrant leading to Defendant's arrest was clearly supported by probable cause, and therefore, there was no error in the denial of Defendant's motion to suppress; (2) the district court did not err in concluding that the evidence was sufficient to support Defendant's convictions on the firearm charges; and (3) the district court's seventy-two-month sentence on count one was substantively reasonable. View "United States v. Sylvestre" on Justia Law

Plaintiff was arrested for murder and held for almost four years before the charges against him were dismissed, months after another person confessed to the crime. Years later, Plaintiff then sued the County of Riverside and various County officials under 42 U.S.C. Section 1983, claiming that they had violated his due process rights under Brady v. Maryland, 373 U.S. 83 (1963), by suppressing the separate confession. The district court denied a motion for judgment on the pleadings on the Brady claim.   The Ninth Circuit reversed and remanded, without prejudice to Parker, asserting a different due process claim. A Brady violation requires that the withheld evidence have a reasonable probability of affecting a judicial proceeding, and no such proceeding was affected here. The panel held that Plaintiff could not show prejudice from the nondisclosure of the confession. A Brady violation requires that the withheld evidence have a reasonable probability of affecting a judicial proceeding. Plaintiff did not state a Brady claim because he did not assert the nondisclosure would have changed the result of any proceeding in his criminal case. The panel rejected Plaintiff’s contention that the prejudice inquiry should be whether the withheld evidence had a reasonable probability of affecting counsel’s strategy. The panel noted that no court has adopted Plaintiff’s proposed rule, and most other courts require a conviction to establish prejudice. Moreover, here, the cause of Plaintiff’s continued detention was not the suppression of the confession, but the District Attorney’s continued prosecution even after receiving the confession. View "ROGER PARKER V. COUNTY OF RIVERSIDE, ET AL" on Justia Law

The Supreme Court affirmed Defendant's conviction on twenty-one counts related to his sexual abuse of his daughter AF, holding that Defendant was not entitled to relief on his allegations of error.At issue was whether the district court abused its discretion in admitting a sexually explicit photograph of AF's mother, Mrs. Freer, and a pornographic father-daughter incest video under Wyo. R. Evid. 404(b). The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting the sexually explicit photograph of Mrs. Freer and the pornographic incest video; (2) Defendant failed to demonstrate that alleged prosecutorial misconduct denied him his right to a fair trial. View "Freer v. Wyoming" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction on charges of domestic violence aggravated assault and domestic violence assault and the trial court's finding of guilty on a charge of violating a condition of release, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued, among other things, that the trial court violated his constitutional right to a representative jury by using the absolute disparity test to determine the racial makeup of the jury venire. The Supreme Judicial Court disagreed and affirmed, holding that the trial court (1) appropriately determined the 1.01% absolute disparity in Defendant's jury venire was insufficient to show underrepresentation; and (2) did not abuse its discretion in denying Defendant's motion to subpoena the grand jurors. View "State v. Footman" on Justia Law

The First Circuit affirmed the judgment of the district court denying Plaintiff's request for preliminary injunctive relief challenging the restraint procedures used by the Massachusetts Department of Correction (DOC) under the Eighth Amendment and Title II of the Americans with Disabilities Act of 1990 (ADA), holding that the district court did not err in denying relief.Plaintiff, an inmate who suffered from severe arthritis in his shoulder joints, challenged the restraint procedures used on him by the DOC, including "rear cuffing" with a single standard handcuff, then later rear cuffing using "double cuffs," and still later using custom modified handcuffs. In this action, Plaintiff argued that the unnecessary pain caused by these restraint procedures violated his constitutional and statutory rights and sought an order requiring the DOC to adopt his own proposed restraint procedure. The district court denied Plaintiff's request for preliminary relief. The First Circuit affirmed, holding that the district court properly determined that DOC did not respondent with deliberate indifference to Plaintiff's medical needs and that Plaintiff was unlikely to prevail on the merits of his ADA claim. View "Sosa v. Mass. Dep't of Correction" on Justia Law

Defendant asserts that he is required by his religious faith to abstain from psychiatric medication. Because he is not competent to stand trial, though, the government requested to involuntarily medicate him, and the district court granted the motion.   The Fifth Circuit held that the district court did not err in concluding that the government had satisfied the conditions for involuntary medication set out in Sell v. United States, 539 U.S. 166, 180–81 (2003). However, the court wrote that the district court should also have analyzed whether any statutory religious-freedom protections apply to Defendant. The court vacated and remanded for the district court to consider that issue. The court held that the government psychiatrist’s medical opinion is sufficient evidence that involuntary medication will “significantly further” the government’s interest. And “whatever the strength of that evidence,” Defendant “provides no reason to question its accuracy.” Thus, the court agreed with the district court that the government has provided enough evidence to satisfy the second prong. View "USA v. Harris" on Justia Law

Gunter and Grommet participated in a conspiracy to deliver methamphetamine, including a controlled purchase of actual methamphetamine from Gunter by law enforcement agents. A September 17, 2019 indictment charged Gunter and Grommet of conspiring to distribute and possessing with intent to distribute at least 50 grams of methamphetamine, 21 U.S.C. 841(a)(1), (b)(1)(A), 846. Gunter was arrested on July 2, 2020. The court set an initial trial date of August 31, 2020. Over the next 23 months, the trial was repeatedly rescheduled. Gunter first requested continuances; later continuances were at the request of Grommet, who was evaluated for competency and whose lawyer subsequently died. When Gunter eventually (unsuccessfully) sought severance, he did not cite Speedy Trial Grounds.Days before trial, Gunter unsuccessfully moved to dismiss the indictment alleging a violation of his Sixth Amendment speedy trial rights. The Seventh Circuit affirmed Gunter’s conviction after considering the length of and reasons for the delay, whether the defendant asserted his right to a speedy trial, and any prejudice the defendant suffered. Although Gunter first moved to dismiss the indictment on the basis of his right to a speedy trial immediately before trial, he opposed motions for continuances and asserted his desire for a speedy trial numerous times. The delays could not be attributed to the government. Gunter made no argument that he experienced any prejudice from the delay, and no strong showing of prejudice is obvious in the record. View "United States v. Gunter" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of assault and battery by means of a dangerous weapon, holding that portions of the victim's then-girlfriend's grand jury testimony were properly admitted in accordance with the hearsay exemption for prior inconsistent statements.Prior to trial, the victim's then-girlfriend Shyla Bizarro identified Defendant as the victim's attacker from surveillance video footage and testified to her identification before the grand jury. Prior to her testimony, however, Bizarro revealed that she wished to recant her statements to police and her grand jury testimony. The trial judge admitted substantively the recanted portions of Bizarro's grand jury testimony, including her prior statements of identification. The Supreme Judicial Court affirmed the conviction, holding (1) the portions of Bizarro's grand jury testimony were properly admitted as prior inconsistent statements; (2) portions of Bizarro's grand jury testimony identifying Defendant in the video independently satisfied the hearsay exemption for statements of identification; and (3) there was no merit to Defendant's remaining arguments. View "Commonwealth v. Brum" on Justia Law