Justia Civil Rights Opinion Summaries

Alyssa was visiting her friend when Lundy, intoxicated forced his way into the house. A neighbor called 911 after hearing “a woman crying” and someone “being thrown around.” Lundy left before officers arrived. The women stated that Lundy left in a red Pontiac. Officers, looking for Lundy, received another call. Lundy had returned with a gun. Officer Martin returned to the house in about two minutes, activated his bodycam, and recorded the women saying that Lundy pointed the gun at them, loaded it, and threatened to kill them in front of Alyssa and Lundy’s young children. Officer Brown found Lundy near the house and looked through the window of the red Pontiac. A loaded pistol sat on the passenger’s seat. During booking, Lundy stated that he’d take the gun charge because “it’s mine.”Lundy was convicted of possessing a firearm as a felon, 18 U.S.C. 922(g)(1), 924(a)(2). The prosecution introduced Martin’s bodycam footage and Martin’s testimony about that conversation. Lundy argued that because Alyssa did not testify, her out-of-court statement was barred. The Sixth Circuit upheld the admission of that evidence. The excited-utterance exception applied because there was an event startling enough to cause nervous excitement, the statement was made before there was time to contrive or misrepresent, and the statement was made while Alyssa was under the stress of the excitement caused by the event. The statement was nontestimonial, and the Confrontation Clause does not apply. View "United States v. Lundy" on Justia Law

The Supreme Court affirmed Defendant's conviction for interference with a peace officer, holding that the district court did not violate Defendant's due process rights by conducting a hearing under Asch v. State, 62 P.3d 945 (Wyo. 2003), in Defendant's absence after he refused to attend the hearing.Defendant, who was serving three consecutive life sentences at the Wyoming State Penitentiary, was charged with interference with a peace officer. Before the scheduled trial date, the State moved to require Defendant to be restrained during trial. The district court conducted an Asch hearing without Defendant and decided to impose restraints at trial. Defendant was convicted of one count of felony interference with a peace officer. The Supreme Court affirmed, holding that Defendant waived any right he had to be present at the Asch hearing by knowingly and voluntarily failing to appear at the hearing due to circumstances within his control. View "Castellanos v. State" on Justia Law

In this case concerning how an Ohio prisoner is to enforce his constitutional right to a speedy trial on an untried indictment the Supreme Court held that a prisoner satisfies the "causes to be delivered" requirement of Ohio Rev. Code 2941.401 when he delivers the written notice and the request to the warden where he is imprisoned, even if the warden fails to deliver the notice and the request to the prosecuting attorney or the appropriate court.Appellant, who was indicted on counts of aggravated robbery and robbery, moved to dismiss the indictment on speedy-trial grounds. The trial court granted the motion, concluding that Appellant had strictly complied with section 2941.401 when he provided written notice of his place of imprisonment and a request for a final disposition and that the 180-day speedy trial time was not tolled by the warden's failure to comply with his duty to send out Appellant's written notices and requests to the prosecuting attorney or the appropriate court. The court of appeals reversed, concluding that Appellant had not strictly complied with the requirements of the statute. The Supreme Court reversed, holding that Appellant caused to be delivered his written notice and request for final disposition under the statute when he provided them to the warden. View "State v. Williams" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant to seventy years in Montana State Prison for deliberate homicide, a felony, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's claim that his trial attorney provided ineffective assistance when he advised Defendant and the court that mitigated deliberate homicide was not a lesser-included offense of deliberate homicide was more appropriate for postconviction relief; and (2) the district court did not err when it concluded that the State's offer of proof provided sufficient evidence to accept Defendant's Alford plea. View "State v. Bristow" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of rape, one count of aggravated assault, and two counts of domestic violence in the presence of a child, holding that Defendant was not entitled to relief on his multiple claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in not withholding from jury deliberations a video exhibit of Defendant's police interview; (2) Defendant failed to show that he was prejudiced by the alleged deficient performance of his trial counsel; and (3) the district court did not err in denying Defendant's motions for a mistrial and a new trial arising out of a child witness's breakdown on the witness stand. View "State v. Centeno" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of second-degree murder and sentencing him to forty years in prison, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) as concerning the prosecutor's effort to conceal the State's involvement in Defendant's transfer proceedings, the circuit court properly exercised its discretion to neutralize any error; (2) the circuit court acted within its discretion to denying Defendant's motion for mistrial; (3) viewed in their entirety, the instructions given to the jury correctly stated the applicable law; (4) the exercise of the circuit court's discretion did not contravene Defendant's right to present a complete defense; and (5) Defendant's sentence could not be described as grossly disproportionate to his crime. View "State v. Black Cloud" on Justia Law

McMullen was convicted under Indiana law of possession of cocaine and marijuana. In preparation for sentencing, McMullen’s attorney, Lewis, said he “really didn’t do anything independently to develop any mitigation” and “just relied” on the PSR although he knew McMullen “came from a seriously troubled background.” Lewis did not consider having a mental health professional evaluate McMullen, who was given a 50-year sentence, largely based on his criminal history. State courts rejected his claim of ineffective assistance. The district court denied his petition for federal habeas relief under 28 U.S.C. 2254.The Seventh Circuit vacated. Although in 2021, an Indiana trial court modified McMullen’s sentence and placed him on probation, the issue was not moot. The Indiana Court of Appeals' decision was contrary to “Strickland.” Given that the state was asking for the statutory maximum prison term, Lewis’s investigation should have gone beyond reliance on the PSR, and talking to a relative. The state appellate court failed to evaluate the totality of the available mitigation evidence, which is significant and compelling. On remand, the district court must consider evidence and argument as to whether Lewis had any strategic reasons for the limits of his investigation into McMullen’s mental health and background and the presentation of mitigating circumstances. View "McMullen v. Dalton" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions for felony charges stemming from an inventory search of an impounded truck that Defendant was driving when he was pulled over by a law enforcement officer, holding that the search was reasonable and lawful under the Fourth Amendment.Law enforcement performed an inventory search as to the truck at issue and found a handgun in the truck's right door panel. After Defendant unsuccessfully moved to suppress the evidence of the gun the trial court found him guilty. The court of appeals reversed, holding that the search was not reasonable under the Fourth Amendment because the state's evidence was insufficient. The Supreme Court reversed, holding that the inventory search was lawful. View "State v. Toran" on Justia Law

The Supreme Court dismissed this appeal brought by the State of an order and judgment dismissing with prejudice criminal charges against Defendant, holding that there was no final, appealable judgment, and therefore, the State lacked statutory authority to appeal pursuant to Mo. Rev. Stat. 547.200.Defendant, who was charged with second-degree murder, first-degree robbery, and armed criminal action, filed a motion to dismiss the indictment. The circuit court sustained the motion in part and dismissed the murder and robbery charges with prejudice, concluding that the Double Jeopardy Clause precluded those charges. The State appealed. The Supreme Court dismissed the appeal, holding that this was an improper appeal. View "State v. Harris" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment in favor of the Hocking County Common Pleas Court and Judge Dale Crawford in Appellant's action for writs of mandamus and prohibition, holding that the court of appeals correctly determined that the doctrine of res judicata barred Appellant's claims.Appellant was found guilty of assaulting a peace officer. The court of appeals affirmed. About seven years later, Appellant filed a complaint for writs of mandamus and prohibition alleging that the trial court deprived her of her constitutional right to counsel and lacked jurisdiction to hold the sentencing hearing. The court of appeals concluded that the doctrine of res judicata barred Appellant's claims. The Supreme Court affirmed, holding that the court of appeals correctly determined that res judicata barred this mandamus and prohibition action. View "State ex rel. Ogle v. Hocking County Common Pleas Court" on Justia Law