Justia Civil Rights Opinion Summaries

In 1993, Fields, having spent the day drinking alcohol and smoking marijuana, fought with Burton, who lived in a duplex owned by Horton. That night, Burton was locked outside. Fields appeared, with a knife, and broke a window in the duplex. Fields and Burton fled before police arrived, having been called by a neighbor. Officers found Fields in Horton’s residence, a block away, in possession of Horton’s jewelry, saying that he had killed Horton, who was dead in her bedroom. At his second trial, the prosecution argued that Fields broke into Horton’s residence through a storm window, murdered her, and started burglarizing the residence before police arrived. To test that theory, the jury conducted an experiment using a flat-tipped knife submitted into evidence to remove a cabinet door in the jury room (in place of the storm window). Satisfied with the outcome, the jurors convicted Fields of intentional murder and sentenced him to death.In 2022, the Sixth Circuit granted Fields conditional habeas corpus relief. On rehearing, en banc, the court affirmed the denial of relief. The Supreme Court has not addressed when jury experiments of this type violate state or federal law. Under the Antiterrorism and Effective Death Penalty Act habeas relief is unavailable unless a state court has unreasonably applied “clearly established Federal law, as determined by the Supreme Court,” 28 U.S.C. 2254(d)(1). View "Fields v. Jordan" on Justia Law

The First Circuit affirmed the judgment of the district court denying Petitioner's petition seeking habeas relief on ineffective assistance of counsel claims, holding that there was no error in the proceedings below.Petitioner was convicted in a Massachusetts state court of three counts each of rape, rape of a child, and assault and battery with a dangerous weapon. The appeals court affirmed the trial court's denial of Petitioner's petition for a new trial. Petitioner then sought habeas relief in a federal district court, claiming that he was denied the constitutionally affective assistance of counsel. The district court denied relief. The First Circuit affirmed upon applying the deference required by the Antiterrorism and Effective Death Penalty Act, holding that Petitioner failed to establish that he was entitled to habeas relief. View "Quintanilla v. Marchilli" on Justia Law

The Supreme Judicial Court vacated the judgment of the trial court denying Petitioner's petition for post-conviction review (PCR) arguing that her trial counsel provided ineffective assistance, holding that Petitioner's conviction of domestic violence assault against her daughter must be vacated.In her PCR petition, Petitioner argued that trial counsel's representation was ineffective by opening the door during opening statements to prejudicial evidence about her parenting practices and because he did not object to prosecutorial error at trial. The PCR denied relief. The Supreme Judicial Court vacated the judgment below, holding that trial counsel's decision to open the door to evidence regarding Petitioner's parenting practices and his failure to object at trial to the prosecutorial error made his conviction unreliable and unworthy of confidence. View "Pratt v. State" on Justia Law

In 2019, the Alabama Legislature passed -- and Governor Kay Ivey signed -- House Bill 380 ("H.B. 380"), which became Act No. 2019-393, Ala. Acts 2019. As enacted, H.B. 380 amended various Code provisions, including § 15-22-21(a), Ala. Code 1975, creating the position of director of the Alabama Bureau of Pardons and Paroles ("the Bureau"), and § 15-22-20(b), Ala. Code 1975, addressing the nomination and appointment processes for the members of the Alabama Board of Pardons and Paroles ("the Board"). After H.B. 380 was enacted, Governor Ivey appointed Leigh Gwathney as chair of the Board pursuant to the new procedures set forth in § 15-22-20(b). In November 2020, the three-member Board convened and held a parole-consideration hearing for Angela Turner, an inmate who was serving a life sentence for murder. Following a review of Turner's file, the Board unanimously denied Turner's parole request. Around that same time, Governor Ivey appointed Cam Ward as the new director of the Bureau. In response to the Board's denial of parole, Turner filed suit against Governor Ivey, Ward, Gwathney, and the other members of the Parole Board, in which she sought a judgment declaring that Governor Ivey's appointment of Ward and Gwathney to their respective positions pursuant to the changes created by H.B. 380 violated the Alabama Constitution of 1901. She also, on behalf of the State of Alabama, petitioned for writs of quo warranto pursuant to § 6-6-591, Ala. Code 1975, alleging that Ward and Gwathney unlawfully held their respective positions. Finally, she alleged a 42 U.S.C. § 1983 claim against all the defendants on the basis that she had been denied due process during her parole-consideration hearing. The circuit court dismissed Turner's claims with prejudice. Finding no reversible error in the circuit court's order, the Alabama Supreme Court affirmed. View "Turner and the State of Alabama ex rel. Angela Turner v. Ivey, et al." on Justia Law

The Supreme Court affirmed the judgment of the trial court in this action seeking to confiscate money under Indiana's civil forfeiture statute, holding that the right to a jury trial applies in such an action.The State filed a complaint to forfeit $2,435 in cash that police officers recovered after stopping Alucious Kizer for a traffic violation, alleging that the money had been "furnished or intended to be furnished" in exchange for a crime, that it had been "used to facilitate" a crime, or that it was "traceable as proceeds" of a crime. Kizer requested a jury trial. The State moved to strike the demand, arguing that no such right existed under either the Indiana or United States Constitution. The court of appeals reversed, concluding that Kizer was not entitled to trial by jury. The Supreme Court vacated the court of appeals' opinion and affirmed the trial court, holding (1) Ind. Const. Art. I, 20 protects the right to a jury trial for in rem civil forfeitures; and (2) therefore, Kizer had a constitutional right to trial by jury. View "State v. $2,435 in U.S. Currency" on Justia Law

Jones was convicted of robbery in Indiana, Kentucky, and federal courts. Jones’s Kentucky plea deal agreed to a commencement date for Jones’s accrual of time-served credits, not when officers actually took Jones into custody, as would ordinarily be the case, but on an earlier date. The sentencing court failed to adopt the plea agreement and ordered the Department of Corrections to calculate Jones’s time-served credit in accordance with “this judgment,” which made no mention of the negotiated agreement, and “the law.” The court did not provide Jones the opportunity to withdraw his plea. Jones did not appeal or seek correction of his sentence. Jones unsuccessfully asked prison administrators to honor the plea agreement’s time-served provision; doing so would have violated the judgment of conviction. Jones asked the sentencing court for clarification. The court ratified the administrators’ calculations. Jones did not appeal. The court subsequently instructed that Jones be given credit in accordance with the agreement. Jones was then released.Jones filed suit, alleging that Kentucky prison administrators violated his Eighth and Fourteenth Amendment rights through their alleged deliberate indifference to the prospect of incarcerating him beyond the length of his sentence. The Sixth Circuit reversed the denial of the defendants’ qualified immunity motions. The defendants—state corrections officials—neither caused nor contributed to Jones’s over-incarceration nor could they unilaterally remedy the matter, which was dictated by court orders. View "Jones v. Bottom" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Petitioner to ten to twenty-five years' imprisonment after he pleaded guilty to second-degree sexual assault, holding that the circuit court's failure to explicitly discuss the mandatory mitigating circumstances listed in W. Va. Code 61-11-23(c) before ordering the final sentence was not prejudicial.On appeal, Petitioner argued that the circuit court failed to consider the "mitigating circumstances" set forth in section 61-11-23(c) and that his sentence was constitutionally disproportionate. The Supreme Court affirmed the sentence, holding (1) Petitioner's substantial rights were not affected by the circuit court's failure to acknowledge and consider the statutory mitigating circumstances; and (2) Petitioner's argument that his sentence was constitutionally disproportionate due to his age and mental capacity was unavailing. View "State v. Hall" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendants' motions to dismiss the underlying lawsuit seeking money damages pursuant Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971) for alleged unconstitutional searches and seizures, holding that the district court did not err.Plaintiffs claimed three Bivens causes of action for money damages related to the searches and seizures. The district court dismissed the complaint, determining that the claims arose within a new Bivens context and that special factors counseled toward denying relief. The First Circuit affirmed, holding that Plaintiffs' claims arose in a new factual scenario of Bivens and involved special factors. View "Quinones-Pimentel v. Cannon" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to correct an illegal sentence, holding that the district court did not err in ruling that res judicata barred Defendant's motion to correct an illegal sentence.Defendant was convicted of second-degree abuse of a minor and soliciting a minor to engage in sexual relations and sentenced to twenty years as to the sexual abuse conviction and to four to five years on the solicitation conviction, to be served consecutively. Defendant later filed a pro se motion to correct an illegal sentence, arguing that the acts underlying his conviction were one continuous act and that his consecutive sentences violated double jeopardy protections. The district court denied relief ruling that res judicata barred the motion. The Supreme Court affirmed, holding (1) a motion to correct an illegal sentence can be subject to res judicata; and (2) the interests of res judictata in finality and avoiding repetitive litigation were served in this case. View "Peterson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's complaint against the Nebraska Department of Correctional Services (DCS) and three of its officials regarding computation of Plaintiff's tentative mandatory release date (TRD), holding that there was no error.Plaintiff, an inmate, filed an action for declaratory judgment alleging that DCS was responsible for actions infringing on her constitutional rights under the Eighth Amendment and the due process clause of the Fourteenth Amendment by concluding that her TRD was consistent with Nebraska statutes and case law. The district court dismissed the case for failing to state a claim upon which relief could be granted. The Supreme Court affirmed, holding (1) Plaintiff did not state a claim upon which relief could be granted under 42 U.S.C. 1983; and (2) the trial court lacked jurisdiction under Neb. Rev. Stat. 84-911 for Plaintiff's claims against DCS. View "Williams v. Frakes" on Justia Law