Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the superior court convicting Defendant of three counts of first-degree sexual assault, following a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme eCourt held that the trial justice (1) did not violate Defendant's constitutional right to present a defense by excluding the proposed expert testimony of Dr. Patricia R. Recupero as not relevant under Rule 401 of the Rhode Island Rules of Evidence; (2) did not err in instructing the jury that there was no need for certain testimony to be corroborated in order to support a guilty verdict; and (3) did not abuse his discretion in limiting the redirect examination of Defendant about his preparation for trial. View "State v. Robinson" on Justia Law

In this case regarding the removal of a prospective juror based solely on his or her gender the Supreme Court held that when a party objecting to a peremptory challenge offers a bare allegation of gender discrimination without offering other relevant circumstances to support an inference of gender discrimination, that party fails to establish a prima facie case of purposeful gender discrimination.After a jury trial, Defendant was found guilty of the crime of sexual imposition. On appeal, Defendant argued that the prosecutor sought to exclude male jurors because they would tend to sympathize with him. The court of appeals reversed, holding that Defendant established a prima facie case of purposeful discrimination when the state exercised its peremptory challenge on a prospective juror and did not provide a gender-neutral explanation for its challenge. The Supreme Court reversed, holding that the trial court erred when it failed to recognize that Batson v. Kentucky, 476 U.S. 79 (1986), applied to Defendant's objections to the state's peremptory challenges, but the error was immaterial because Defendant failed to establish a prima facie case of discrimination. View "State v. Stalder" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing this action in mandamus brought by Appellant, an inmate at the London Correctional Institution, against Ohio Attorney General Dave Yost asking Yost to provide him with names of Ohio Department of Rehabilitation and Correction (ODRC) employees who worked on a case Appellant had previously filed against the ODRC, holding that there was no error.In 2016, Appellant filed a pro se lawsuit alleging excessive force during an altercation with ODRC staff. After the parties settled, Appellant unsuccessfully requested from the attorney general's (AG) office the name of the ODRC employee who communicated with the attorney general's office during settlement negotiations. Appellant then filed the current action requesting an order requiring the AG to provide the ODRC employees' who made decisions regarding his settlement. The attorney general dismissed the action for failure to state a claim. The Supreme Court affirmed, holding that Appellant failed to show that he had a clear legal right to the requested information or that the AG had a clear legal duty to provide that information. View "State ex rel. Russell v. Yost" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions for deliberately premeditated murder in the first degree and unlawful possession of a firearm and declined to exercise its authority to grant extraordinary relief, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the trial judge erred in excluding evidence that law enforcement officers found illegal narcotics in a vehicle occupied by the victim and in the victim's clothing and that the judge's ruling "deprived the defense of the plausible alternative theory that rival drug dealers committed the murder." The Supreme Judicial Court disagreed and affirmed, holding (1) there was no evidentiary error in the proceedings below; (2) as to the firearm conviction, the trial court's failure to instruct the jury on licensure requirements was harmless beyond a reasonable doubt; and (3) the verdict of murder in the first degree was consonant with justice and should stand. View "Commonwealth v. Bookman" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of burglary in the second degree, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's constitutional rights to confrontation, to present a defense, and to a fair trial under the Sixth and Fourteenth Amendments to the federal constitution were not violated during the underlying proceedings; and (2) assuming, without deciding, that the trial court abused its discretion when it limited defense counsel's cross-examination of the victim on the ground that the proffered line of questioning was speculative, Defendant failed to satisfy his burden of proving harm. View "State v. Lanier" on Justia Law

Marvin’s mother called the police to perform a wellness check; she thought Marvin, age 21, was suicidal. St. Joseph County Sheriff’s Deputies arrived at Marvin’s home and found his mother in the driveway with a bleeding lip. She stated that Marvin had hit her with a chair. The officers approached the house to speak with Marvin, who declined to exit the house. During the confrontation, the deputies saw Marvin’s father remove a box cutter from Marvin’s pocket. They pulled him from the doorway and wrestled him to the ground. While he resisted, they tased him twice and struck him several times. Marvin sued the deputies for unlawful entry and excessive force. Marvin admitted that he was uncooperative but claimed he was not threatening or violent and that he suffered a concussion and a broken toe.Marvin brought claims under 42 U.S.C. 1983 against the deputies for unlawful entry and excessive force, in violation of his Fourth Amendment rights. The Seventh Circuit affirmed the dismissal of the unlawful entry claims against Officer Corban, who had not helped pull Marvin from his house, and the excessive force claims against Officer Lawson-Rulli, who was not involved in tasing or hitting Marvin. Corban and Holcomb’s use of force was reasonable as a matter of law. The court also affirmed a defense verdict on Marvin’s unlawful entry claims against Holcomb and Lawson-Rulli. View "Marvin v. Holcomb" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Hamilton County Common Pleas Court Judge Tom Heekin for failure to file an affidavit of prior civil actions as required by Ohio Rev. Code 2969.25(A), holding that Appellant filed the required affidavit.Appellant, an inmate, filed a petition for a writ of mandamus seeking an order compelling Judge Heekin to vacate a judgment entry dismissing a malpractice case Appellant had filed against his criminal defense attorney. The court of appeals sua sponte dismissed the petition based on Appellant's purported failure to comply with section 2969.25(A). The Supreme Court reversed, holding that the affidavit Appellant filed with his petition supported his claim that he complied with section 2969.25(A). View "State ex rel. Woods v. Heekin" on Justia Law

In 2012, Horton was convicted of multiple drug trafficking and firearm crimes. Horton had been convicted of four prior state drug felonies. The court imposed three concurrent life sentences. Horton’s direct appeal and collateral relief motion under 28 U.S.C. 2255, failed. Under 2255(h) a successive motion is permitted only if it contains “newly discovered evidence” of innocence or is based on a “new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court.” Horton filed a habeas petition under 28 U.S.C. 2241, citing the “saving clause,” 28 U.S.C. 2255(e); a 2241 motion “shall not be entertained” unless the remedy by motion under 2255 “is inadequate or ineffective to test the legality of his detention.”The Seventh Circuit previously held (Davenport) that 2255 is “inadequate or ineffective”— and 2241 is available—when the limits on successive 2255 motions bar relief and the prisoner’s claim is based on a new interpretation of a criminal statute that was previously foreclosed by circuit precedent. Horton's Davenport claim challenged his sentences based on the Supreme Court’s 2016 Mathis decision.In the interim, the Supreme Court decided Jones v. Hendrix, (2022): The inability of a prisoner with a statutory claim to satisfy 2255’s conditions does not mean that he can bring his claim in a habeas petition under the saving clause. It means that he cannot bring it at all." The Seventh Circuit affirmed the denial of relief, abrogating Davenport. View "Horton v. Lovett" on Justia Law

Sanders was convicted in 2006 of firearms offenses. The court imposed an enhanced sentence under the Armed Career Criminal Act, based on three prior convictions, including one for Illinois residential burglary. His direct appeal and 28 U.S.C. 2255 motion for collateral relief failed. Sanders has three times unsuccessfully sought permission to file a successive 2255 motion. A successive motion is permitted only if it contains “newly discovered evidence” of innocence or is based on a “new rule of constitutional law, made retroactive to cases on collateral review by the Supreme Court.”Sanders filed a 28 U.S.C. 2241 habeas petition, citing the “saving clause.” 28 U.S.C. 2255(e); A federal prisoner’s 2241 motion “shall not be entertained” unless the remedy by motion under 2255 “is inadequate or ineffective to test the legality of his detention.” Seventh Circuit precedent (Davenport) applied the saving-clause gateway to habeas claims premised on a new interpretation of a criminal statute that was previously foreclosed by circuit precedent. Sanders’s Davenport claim challenged his ACCA-enhanced sentence based on the Supreme Court’s 2016 Mathis decision.The district judge denied relief. The Supreme Court held, in Jones v. Hendrix, (2022): The inability of a prisoner with a statutory claim to satisfy the 2255 conditions does not mean that he can bring his claim in a habeas petition under the saving clause. It means that he cannot bring it at all. The Seventh Circuit affirmed the denial of relief, abrogating Davenport. View "Sanders v. Joseph" on Justia Law

The Court of Appeals affirmed the judgment of the appellate court reversing the decision of the circuit circuit court that examination of data contained on Defendant's hard drive was not a search in violation of the Fourth Amendment, holding that the government violated Defendant's Fourth Amendment rights in this case.Defendant voluntarily consented to government agents seizing his laptop computer, creating a copy of its hard drive, and searching the data on it. After the copy was made but before the government examined the data Defendant withdrew his consent. Defendant moved to suppress the evidence from the forensic examination of the copy of his laptop's hard drive. The circuit court denied the motion. On appeal, Defendant asserted that he had a legitimate expectation of privacy in the mirror-image copy of his laptop hard drive. The appellate court agreed and reversed. The Court of Appeals affirmed, holding (1) Defendant had a reasonable expectation of privacy in the data contained on his hard drive; (2) because the government did not examine the data before Defendant withdrew his consent Defendant did not lose his reasonable expectation of privacy in the data; and (3) the government conducted an unreasonable search by examining the data without any authority to do so. View "State v. McDonnell" on Justia Law