Justia Civil Rights Opinion Summaries

The Court of Appeals reversed the conclusion of the appellate division that the Sex Offender Registration Act (SORA) court acted within its discretion by upwardly departing to level three in determining Defendant's risk level classification, holding that the SORA court deprived Defendant of basic due process protections of notice and an opportunity to be heard.Defendant's convictions required him to register under SORA. At the SORA hearing, the court noted that Defendant would normally be required to register as a level two sex offender but upwardly departed to level three due to Defendant's "extensive prior disciplinary history." The appellate division affirmed. The Court of Appeals reversed, holding that the proceeding failed to comport with due process because Defendant was provided no notice or meaningful opportunity to be heard in response to the District Attorney's request for an upward departure. View "People v. Worley" on Justia Law

Smith was indicted in the Northern District of Florida for theft of trade secrets from StrikeLines’ website. Smith moved to dismiss the indictment, citing the Constitution’s Venue Clause and the Vicinage Clause. Smith argued that he had accessed the website from his Alabama home and that the servers storing StrikeLines’ data were in Orlando, Florida. The Eleventh Circuit determined that venue was improper and vacated Smith’s conviction, but held that a trial in an improper venue did not bar reprosecution.The Supreme Court affirmed. The Constitution permits the retrial of a defendant following a trial in an improper venue conducted before a jury drawn from the wrong district. Except as prohibited by the Double Jeopardy Clause, when a defendant obtains a reversal of a prior, unsatisfied conviction, he may be retried. Nothing in the Venue Clause suggests that a new trial in the proper venue is not an adequate remedy for its violation. The Vicinage Clause—which guarantees the right to “an impartial jury of the State and district wherein the crime shall have been committed,” concerns jury composition, not the place where a trial may be held, and concerns the district where the crime was committed, rather than the state. The vicinage right is one aspect of the Sixth Amendment’s jury-trial rights and retrials are the appropriate remedy for violations of other jury-trial rights.The Double Jeopardy Clause is not implicated by retrial in a proper venue. A judicial decision on venue is fundamentally different from a jury’s verdict of acquittal. Culpability is the touchstone; when a trial terminates with a finding that the defendant’s criminal culpability had not been established, retrial is prohibited. Retrial is permissible when a trial terminates on a basis unrelated to factual guilt. The reversal of a conviction based on a violation of the Venue or Vicinage Clauses, even when called a “judgment of acquittal,” does not resolve the question of criminal culpability. View "Smith v. United States" on Justia Law

The Supreme Court affirmed Defendant's conviction of twelve counts of possession of matter portraying a sexual performance by a minor and other sex-related offenses and his total sentence of seventy years in prison, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err by denying Defendant's motion to suppress evidence obtained from the seizure of his cellphone and password because Defendant voluntary consented to the search; and (2) the trial court did not erroneously instruct the jury as to the effect of Ky. Rev. Stat. 532.110(1)(d) on the jury's discretion to recommend consecutive and concurrent sentences. View "Payne v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and reversed in part the opinion of the court of appeals affirming Defendant's conviction for possession of heroin, holding that the court of appeals erred by affirming the trial court's admission of certain evidence and by affirming the trial court's decision allowing a certain witness to testify.Here, the Supreme Court adopted the reasonable test for determining whether the warrantless search of a parolee's vehicle is constitutionally permissible under the Fourth Amendment, as announced in Samson v. California, 547 U.S. 843 (2006), and overruled its decision in Bratcher v. Commonwealth, 424 S.W.3d 411 (Ky. 2014) to the extent it held that the conditions of parole imposed by state law are immaterial to the Fourth Amendment analysis. The Court also held that the court of appeals (1) did not err in affirming the trial court's denial of Defendant's motion to suppress evidence obtained from a warrantless search of his truck; (2) erred by affirming the trial court's admission of evidence of methamphetamine for which Defendant had been acquitted and evidence of marijuana for which he had been found guilty; and (3) erred in affirming the trial court's decision to allow a witness to testify regarding events he did not perceive in real-time. View "Gasaway v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of trafficking in a controlled substance in the first degree, second or greater offense and its sentence of twenty-seven years in prison, holding that any error was harmless beyond a reasonable doubt.On appeal, Defendant argued that the trial court violated his constitutional right to confront witnesses against him by permitting three witnesses to testify via Zoom and erred by permitting the Commonwealth to join three indictments for trial. The Supreme Court disagreed and affirmed, holding that the trial court (1) did not err when it joined the three indictments for trial; and (2) erred when it permitted three witnesses to testify remotely, but the error was harmless beyond a reasonable doubt. View "Spalding v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the appellate court reversing the decision of the circuit court finding that the Fifth Amendment privilege against self-incrimination prevented the State from compelling Defendant to provide the passcode for his cell phone, holding that the foregone conclusion doctrine applied as an exception to the Fifth Amendment privilege in this case.Defendant was charged with two counts of forgery stemming from the discovery of two false paychecks made payable to him. The police applied for and obtained a warrant to search Defendant's cell phone but could not execute the warrant because the phone was passcode protected. The State then filed a motion to compel production of the passcode. The circuit court denied the motion, concluding that compelling Defendant to provide the passcode would constitute compelling incriminating testimonial communication and that the foregone conclusion did not apply as an exception to the Fifth Amendment privilege. The appellate court reversed. The Supreme Court affirmed, holding that the foregone conclusion applied in this case. View "People v. Sneed" on Justia Law

The Supreme Judicial Court vacated Defendant's conviction of carrying a firearm without a license and his sentence of eighteen months in a house of correction, holding that the Commonwealth did not demonstrate beyond a reasonable doubt that Defendant knowingly, intelligently, and voluntarily waived his Miranda rights, and Defendant did not waive this issue.In a pretrial motion, Defendant filed a motion to suppress based on the alleged inadequacy of the Miranda warnings provided to him in Spanish. The motion judge denied the motion after finding that Defendant was given "the full complement of Miranda warnings" in English and in Spanish. After he was convicted and the convictions were affirmed on appeal Defendant filed a postconviction motion for a new trial, which the motion judge denied following a hearing. The appeals court affirmed. The Supreme Judicial Court vacated the conviction, holding (1) Defendant did not waive the issue of whether Miranda warnings were properly given to him in Spanish; and (2) the admission of Defendant's post arrest statements was error. View "Commonwealth v. Delossantos" on Justia Law

The Supreme Court affirmed the order of the district court requiring Broadwater County to provide to Helena Independent Record (IR) or other interested persons redacted videographer and documentation records pertaining to Jason Ellsworth's May 2021 stop by and encounter with a Montana Highway Patrol officer, holding that there was no error.Ellsworth pleaded guilty to an obstructing a peace officer. Thereafter, a reporter with the IR requested from Broadwater County a copy of Ellsworth's investigative file. Petitioner, a county attorney, determined that the file contained confidential criminal justice information and filed a petition seeking a declaratory ruling to clarify and enforce the rights of recovery to redacted confidential criminal justice information (CCJI) contained in the file. Petitioner also filed a separate motion for leave to deposit the investigative file under seal. The district court (1) concluded that Ellsworth's criminal case had been completed and that the declaratory action was ripe for decision; and (2) held that Ellsworth's privacy rights outweighed the public's right to know regarding certain information irrelevant to the charge. The Supreme Court affirmed, holding that Ellsworth was given a proper opportunity to participate, and his due process right was not infringed regarding the release of the CCJI. View "Broadwater Co. v. Release of Confidential Criminal Justice Information" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree statutory sodomy, incest, first-degree child molestation, and one count of first-degree attempted rape, holding that the circuit court's jury instructions did not violate Defendant's constitutional right to a unanimous verdict.On appeal, Defendant argued that the evidence presented at trial included multiple allegations of abuse related to each count of sexual misconduct and that five separate verdict directors violated his constitutional right to a unanimous jury verdict. The Supreme Court affirmed, holding that the jury instructions violated Defendant's right to a unanimous verdict. View "State v. Hamby" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of possessing a controlled substance, in violation of Mo. Rev. Stat. 579.015.1, and unlawfully using a weapon while in possession of a controlled substance, in violation of Mo. Rev. Stat. 571.030.1, holding that Defendant's convictions did not infringe upon his right to be free from double jeopardy.On appeal, Defendant argued that his convictions violated double jeopardy protections because they arose from the same conduct. The Supreme Court reversed, holding that no double jeopardy violation existed because the plain language of the states combined with fundamental principles of statutory interpretation clearly demonstrated the legislature's intent to authorize multiple punishments under sections 579.015 and 571.030.1(11). View "State v. Onyejiaka" on Justia Law