Justia Civil Rights Opinion Summaries

The defendant, Phillip Romero, was charged with multiple offenses, including assault and false imprisonment, after threatening and attacking his romantic partner. During jury selection, the prosecution used a peremptory strike to excuse Prospective Juror F, one of two Hispanic jurors in the pool. Romero raised a Batson challenge, arguing that the strike was racially motivated. The prosecution explained that the juror appeared disinterested and unfocused. The trial court denied the Batson challenge, finding the prosecution's reason credible and race-neutral.The Colorado Court of Appeals reviewed the case and reversed the trial court's decision, concluding that the trial court had clearly erred in denying the Batson challenge. The appellate court held that the prosecution's reason lacked specific factual justification and objective evidence, and thus, the trial court should not have credited it. The appellate court ordered a new trial for Romero.The Supreme Court of Colorado reviewed the appellate court's decision. The Supreme Court held that the appellate court misapplied the clear error standard of review by not deferring to the trial court's credibility determinations. The Supreme Court emphasized that the trial court is in the best position to assess demeanor and credibility. It found that the trial court had implicitly found the prosecution's reason credible and that the record supported this finding. The Supreme Court reversed the appellate court's decision and remanded the case for consideration of other issues raised by Romero on appeal. View "People v. Romero" on Justia Law

Police officers questioned Terrence Kenneth Eugene about his involvement in a road-rage incident without informing him of his Miranda rights. During the encounter, Eugene admitted to pushing the other driver but denied using a weapon. His statements were used at trial, leading to his conviction for second and third-degree assault.The trial court denied Eugene's motion to suppress his statements, finding he was not in custody for Miranda purposes. The court noted that Eugene's movement was not restricted, the officers did not use coercive tactics, and Eugene was not formally arrested. A jury subsequently convicted Eugene.On appeal, the Colorado Court of Appeals reversed the convictions, concluding that Eugene was in custody during the interrogation and that the trial court erred in not suppressing his statements. The appellate court found that the circumstances of the interrogation, including the officers' tone and the duration of the encounter, indicated a custodial situation.The Supreme Court of Colorado reviewed the case and reversed the appellate court's decision. The court held that Eugene was not in custody for Miranda purposes, emphasizing the public and non-coercive nature of the encounter. The court noted that Eugene was questioned outside his apartment in broad daylight, was not physically restrained, and the officers did not use force or threats. Consequently, the court reinstated the trial court's suppression ruling and remanded the case to the court of appeals for further proceedings. View "People v. Eugene" on Justia Law

The case involves the defendant, who was indicted for unlawful possession of a firearm and related offenses after Boston police officers monitored his Snapchat account and observed him brandishing firearms in several videos. The police used an undercover Snapchat account to send a friend request to the defendant, who accepted it, allowing the officers to view his posts. The defendant was arrested twice, once in January 2018 and again in May 2018, each time after posting videos showing him with firearms.In the Superior Court, the defendant filed multiple discovery motions seeking information about the Boston Police Department's (BPD) use of undercover social media monitoring, arguing that it was relevant to an equal protection claim of discriminatory enforcement. The court granted these motions, ordering the Commonwealth to disclose various pieces of information, including the usernames and profile images used by undercover officers. The Commonwealth refused to comply, citing concerns about compromising ongoing investigations and endangering informants.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Commonwealth did not properly assert a privilege to withhold the requested information, as it failed to demonstrate a legitimate need to protect ongoing investigations or the safety of informants. The court also affirmed the lower court's application of the equal protection standard from Commonwealth v. Long, which applies to claims of discriminatory law enforcement practices beyond traffic stops.The court concluded that the Superior Court judge did not abuse his discretion in dismissing the indictments with prejudice as a sanction for the Commonwealth's deliberate non-compliance with the discovery order. The dismissal was deemed appropriate because the Commonwealth's refusal to provide the requested discovery denied the defendant the opportunity to develop his equal protection claim, thus preventing a fair trial. View "Commonwealth v. Dilworth" on Justia Law

In September 8, 2018, Michael Holmes attended a public fair in Belle Chasse, Louisiana, to test a new camera lens. While taking photos, Holmes was approached by Deputy Sheriff Corbett Reddoch, who asked for his identification. Holmes questioned the request, leading to a physical altercation where Reddoch arrested Holmes, claiming he was taking pictures of children. Holmes was charged only with resisting arrest.Holmes filed a lawsuit in the United States District Court for the Eastern District of Louisiana, asserting claims under 42 U.S.C. § 1983 and Louisiana state law. The jury found in favor of Holmes on his Fourth Amendment unlawful arrest claim but granted qualified immunity to Reddoch for the investigatory stop. The jury also found for Holmes on state-law claims of battery, false imprisonment, and malicious prosecution. Reddoch's post-verdict motions for judgment as a matter of law and a new trial were denied by the district court.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's denial of Reddoch's motions, holding that there was sufficient evidence for the jury to conclude that Reddoch did not have probable cause to arrest Holmes. The court also found that Reddoch forfeited his qualified immunity defense for the false arrest claim by not raising it in his Rule 50 motion. Additionally, the court held that the jury's verdicts on the investigatory stop and arrest were not inconsistent, as they involved different legal standards. The court also upheld the jury's award of punitive damages, finding that Reddoch's actions demonstrated reckless or callous indifference to Holmes's constitutional rights. The judgment of the district court was affirmed. View "Holmes v. Reddoch" on Justia Law

In 1999, a Virginia state court jury convicted Askari Lumumba of second-degree murder and other related charges, sentencing him to fifty-eight years in prison. While serving his sentence, Lumumba engaged in communications that led to disciplinary action. He spoke on the phone about organizing inmates and sent emails discussing potential group actions within the prison. As a result, he was charged with attempting to garner support for a group demonstration, violating Disciplinary Offense Code 128, which prohibits participating in or encouraging work stoppages or group demonstrations.Lumumba's disciplinary hearing concluded with a finding of guilt, resulting in 30 days of disciplinary segregation and a loss of 180 days of good-conduct sentence credits. His appeals to the Warden and Regional Director were denied. He then petitioned for a writ of habeas corpus in the Supreme Court of Virginia, which was denied on jurisdictional grounds. Subsequently, Lumumba filed a federal habeas corpus petition under 28 U.S.C. § 2254, arguing that Offense Code 128 was void for vagueness and violated the First Amendment. The district court dismissed his petition, finding the regulation clear and reasonably related to legitimate penological interests.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that Offense Code 128 is not facially unconstitutional under the First Amendment, as it reasonably relates to maintaining order and security in prisons. The court also found that the regulation is not void for vagueness, as it provides sufficient notice of prohibited conduct and does not invite arbitrary enforcement. Consequently, the Fourth Circuit affirmed the district court's dismissal of Lumumba's petition. View "Lumumba v. Kiser" on Justia Law

Kyle J. Rodney was convicted in Nevada state court of multiple charges, including burglary while in possession of a deadly weapon, conspiracy to commit murder, robbery with use of a deadly weapon, attempted murder with use of a deadly weapon, and battery with use of a deadly weapon resulting in substantial bodily harm. The convictions stemmed from an incident where Rodney and an accomplice attacked and severely injured Ralph Monko after Monko won a significant amount of money at a casino. Monko's injuries were severe, including head trauma and long-term physical and cognitive impairments.Rodney's convictions were affirmed by the Nevada Supreme Court. He then filed a pro se post-conviction petition for a writ of habeas corpus in state court, which was denied without the appointment of counsel or an evidentiary hearing. A second post-conviction petition was also denied on procedural grounds. Rodney subsequently filed a federal habeas corpus petition under 28 U.S.C. § 2254, raising several ineffective-assistance-of-counsel (IAC) claims. The federal district court found these claims procedurally defaulted. On appeal, the Ninth Circuit vacated and remanded for the district court to determine if the procedural default could be excused under Martinez v. Ryan, which allows for such an excuse if the IAC claims are substantial.The United States District Court for the District of Nevada, on remand, initially allowed new evidence and discovery but later ruled that it could not consider new evidence due to the Supreme Court's decision in Shinn v. Ramirez. The district court concluded that Rodney's IAC claims were not substantial based on the state-court record alone and denied relief.The Ninth Circuit Court of Appeals affirmed the district court's decision. The court held that Rodney did not fail to develop the state-court record within the meaning of 28 U.S.C. § 2254(e)(2) and that the district court erred in limiting its analysis to the state-court record. However, the Ninth Circuit found that even considering the new evidence, Rodney's IAC claims were not substantial. The court concluded that there was no reasonable probability that the outcome of Rodney's trial or sentencing would have been different but for counsel's alleged errors. Thus, the procedural default of Rodney's claims could not be excused, and the denial of his habeas petition was affirmed. View "RODNEY V. GARRETT" on Justia Law

Three retired New Hampshire State Police troopers challenged their inclusion on the Exculpatory Evidence Schedule (EES), claiming their placement was based on outdated and misinterpreted conduct. Approximately twenty years ago, the troopers inflated traffic stop records in their activity logs to meet mandated quotas. An internal investigation led to their discipline but not termination. Initially placed on the "Laurie List," their names were later removed, only to be reinstated on the EES over a decade later.The Superior Court dismissed the troopers' complaint, finding their conduct potentially exculpatory and their placement on the EES appropriate. The court also ruled that the troopers had received adequate due process. The troopers appealed, arguing that their conduct was not fraudulent and that the age of the conduct diminished its relevance.The Supreme Court of New Hampshire reviewed the case, focusing on whether the troopers' conduct was "potentially exculpatory" under RSA 105:13-d. The court noted that "potentially exculpatory evidence" includes evidence that could be material to guilt or punishment, including impeachment evidence. The court emphasized that factors such as the age and nature of the conduct should be considered in determining its relevance.The court concluded that the limited record did not establish whether the troopers' conduct was potentially exculpatory, as it could have been a result of a mistaken interpretation of reporting requirements rather than dishonesty. Therefore, the court reversed the Superior Court's dismissal and remanded the case for further proceedings to determine the potential exculpatory nature of the conduct, considering its admissibility and relevance in future criminal cases. View "Doe v. N.H. Attorney Gen." on Justia Law

In 2015, Eddie Williams was prosecuted in Pennsylvania for crimes related to a dispute over illegal drug profits, resulting in one death and one serious injury. Williams, along with Rick Cannon and Akeita Harden, was implicated in the incident. Cannon pleaded guilty to multiple charges, including homicide, and Williams was tried jointly with Harden. During the trial, the judge read Cannon's Criminal Information, which included charges naming Williams as a co-conspirator, to the jury. Williams was found guilty on all counts and sentenced to life imprisonment plus additional years.Williams filed a Post-Conviction Relief Act (PCRA) petition in 2017, arguing ineffective assistance of counsel due to his attorney's failure to object to the reading of Cannon's Criminal Information. The PCRA court denied the petition, and the Pennsylvania Superior Court affirmed. The Pennsylvania Supreme Court denied further appeal. Williams then filed a habeas corpus petition in the United States District Court for the Middle District of Pennsylvania, which granted relief, finding a violation of the Confrontation Clause and ineffective assistance of counsel.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the reading of Cannon's Criminal Information, which included testimonial statements implicating Williams, violated the Confrontation Clause. The court also found that Williams's counsel was ineffective for failing to object to the reading, which prejudiced Williams's defense. The Third Circuit affirmed the District Court's decision to grant habeas relief, concluding that the errors had a substantial and injurious effect on the jury's verdict. The case was remanded for the District Court to issue a writ of habeas corpus. View "Williams v. District Attorney Lebanon County" on Justia Law

In 2007, Mohamed Musaid was arrested for the murder of a relative and confessed to the crime. However, his trial was delayed for over eight years due to repeated findings of incompetence to stand trial, attributed to his long history of mental illness. Musaid was found incompetent on ten occasions and competent on five, with his competency dependent on his compliance with antipsychotic medication. Each time he was found competent and transferred to Rikers Island, he would refuse medication and regress to incompetence.The trial court eventually allowed Musaid's trial to proceed nearly ten months after a final finding of competency, without re-evaluating his mental state. During the trial, Musaid exhibited erratic behavior, raising questions about his competency. Despite this, the trial court did not conduct a further inquiry into his mental state. Musaid was convicted and sentenced to 25 years to life for second-degree murder and five years for criminal possession of a weapon.Musaid appealed, arguing that the trial court's failure to reassess his competency before trial violated his due process rights. The Appellate Division affirmed the conviction, stating there was no indication that Musaid was unable to understand the proceedings or assist in his defense. Musaid then sought habeas corpus relief in the United States District Court for the Southern District of New York, which was denied.The United States Court of Appeals for the Second Circuit reviewed the case and found that the trial court's failure to conduct a minimal inquiry into Musaid's competency just before trial was objectively unreasonable, given his history of mental illness and the time elapsed since the last competency evaluation. The court reversed the district court's decision and remanded with instructions to grant a conditional writ of habeas corpus, allowing the state courts to determine whether it is possible to reconstruct Musaid's competency at the time of trial based on evidence proximate to the trial. View "Musaid v. Kirkpatrick" on Justia Law

Joshua Allen Baldwin was arrested by Officer Daniel Beasley on July 22, 2021, at Lucky Lil’s Casino in Anaconda, Montana, for allegedly violating his pre-release conditions by being in a casino. Beasley confirmed with dispatch that Baldwin was under court conditions prohibiting him from being in such establishments. After Baldwin was arrested, officers observed suspicious items in his car, including a butane refill bottle, burnt pliers, and a Ziploc baggie with a white crystalline substance. A subsequent search of Baldwin’s car, conducted after obtaining a warrant, revealed methamphetamine and drug paraphernalia.The Third Judicial District Court, Anaconda-Deer Lodge County, denied Baldwin’s motion to suppress the evidence obtained from the search, ruling that the arrest was lawful. Baldwin then pleaded guilty to felony drug possession while reserving his right to appeal the suppression ruling. The misdemeanor charge for drug paraphernalia was dismissed.The Supreme Court of the State of Montana reviewed the case and reversed the lower court’s decision. The court held that Beasley did not have probable cause to arrest Baldwin for contempt of court based on the alleged violation of pre-release conditions. The court determined that pre-release conditions do not constitute an independent mandate of the court under Montana law, and thus, Baldwin’s arrest was unlawful. Consequently, the evidence obtained from the search of Baldwin’s car, which was conducted as a result of the unlawful arrest, should have been suppressed. The court found no applicable exceptions to the exclusionary rule, such as good faith or independent source exceptions, and concluded that the evidence was directly tied to the unlawful arrest. View "State v. Baldwin" on Justia Law