Justia Civil Rights Opinion Summaries

The defendant, Freddy Rivera Corbi, was bullied by gang members in his community for years. In July 2019, he was seriously injured by a gang member. A month later, Corbi encountered another gang member, Lazaro Orozco, and fatally shot him after an argument. At trial, the main issue was whether the shooting was in self-defense or an act of revenge. The jury convicted Corbi of second-degree murder.The Superior Court of San Diego County reviewed the case. Corbi argued that the trial court abused its discretion by allowing the prosecution’s gang expert to offer certain opinions and that the prosecutor violated the California Racial Justice Act of 2020 during closing arguments. He also claimed the court erred in considering whether to dismiss a firearm enhancement at sentencing. The trial court imposed a sentence of 15 years to life for the murder, plus 10 years for a reduced firearm enhancement.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. The court found no reversible error regarding the expert testimony, determining that the gang expert’s opinions were not speculative and did not prejudice the jury’s decision. The court also held that Corbi forfeited his Racial Justice Act claim by failing to raise it in the trial court. Finally, the court concluded that the trial court properly imposed the firearm enhancement, as it had discretion to impose or dismiss the enhancement and had considered the relevant mitigating factors. The judgment was affirmed. View "P. v. Corbi" on Justia Law

Khyle Armando Briscoe, at age 21, participated in a robbery during which his accomplice, Shaun P., was fatally shot by the victim, Ben P. Briscoe was convicted of first-degree murder, robbery, and burglary, with a special circumstance finding under Penal Code section 190.2, subdivision (d), which led to a life without parole sentence. This special circumstance applies to non-killer participants in felonies who act with reckless indifference to human life.The trial court sentenced Briscoe to life without parole, and the conviction was affirmed on appeal. Briscoe later sought a parole hearing under Penal Code section 3051, which allows certain youth offenders to seek parole but excludes those sentenced to life without parole for special circumstance murder. The trial court denied his motion, and Briscoe appealed.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court noted that section 3051 was intended to provide youth offenders with a meaningful opportunity for release based on demonstrated growth and rehabilitation. However, the statute excludes youth offenders sentenced to life without parole for special circumstance murder. Briscoe argued that this exclusion violated equal protection, particularly because section 190.2, subdivision (d) employs the same standard of liability as section 189, subdivision (e)(3), which does not exclude youth offenders from parole consideration.The Court of Appeal agreed with Briscoe, finding that the exclusion of youth offenders sentenced under section 190.2, subdivision (d) from parole consideration under section 3051 violated equal protection. The court reversed the trial court's order and remanded the case for a parole hearing and related proceedings. View "P. v. Briscoe" on Justia Law

Enrique Sanchez, the petitioner, sought a writ of mandate to vacate a trial court order directing the San Bernardino County Public Defender to assign a new attorney to represent him. This order was issued after evidence suggested that the deputy public defender currently assigned to Sanchez's case made racially charged remarks during plea negotiations, potentially violating the Racial Justice Act (RJA). Sanchez argued that the trial court's decision was an abuse of discretion.The trial court received a motion from the prosecutor to disclose exculpatory evidence and evaluate the deputy public defender's conflict of interest. The motion included a declaration from the prosecutor detailing the deputy public defender's remarks, which implied racial bias. During a closed hearing, the trial court read the prosecutor's declaration to Sanchez and asked if he wanted the current public defender to continue representing him. Sanchez expressed his desire to retain his current counsel. However, the trial court later ordered the public defender's office to assign a new attorney, citing potential RJA issues and the risk of ineffective assistance of counsel.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court concluded that the trial court did not abuse its discretion in removing the deputy public defender. The appellate court noted that the RJA's provisions and the potential for implicit bias created an actual conflict of interest that the deputy public defender could not objectively investigate. Additionally, the trial court's decision to prevent potential future RJA claims and ensure adequate representation was within its discretion. The petition for writ of mandate was denied, and the stay on trial court proceedings was vacated. View "Sanchez v. Superior Court" on Justia Law

Two defendants, Fredi Analberto Lopez-Flores and Christian Alejandro May Quintero, were convicted of multiple sex crimes, including forcible rape, sodomy, and oral copulation in concert, after they abducted an inebriated woman, Jane Doe, from the streets of San Francisco, drove her 50 miles away, and assaulted her. The prosecution used terms like "monsters" and "predators" during closing arguments, which the defendants later claimed violated the California Racial Justice Act (RJA) and constituted prosecutorial misconduct.In the lower court, the jury found both defendants guilty on all counts. Lopez-Flores was also found to have a prior conviction, which was considered during sentencing. The trial court imposed consecutive sentences under section 667.6, subdivision (d), finding that the offenses occurred on separate occasions. The court also stated that even if this finding was incorrect, it would impose consecutive sentences under section 667.6, subdivision (c), based on the nature of the crimes and aggravating factors.The California Court of Appeal, First Appellate District, reviewed the case. The court concluded that the prosecution's use of the terms "monsters" and "predators" did not violate the RJA, as these terms were race-neutral and based on the defendants' conduct. The court also found no prosecutorial misconduct, determining that the comments were within the permissible range of descriptive commentary based on the evidence. The court held that the trial court did not err in imposing consecutive sentences under section 667.6, subdivision (c), and any potential error under subdivision (d) was harmless because the court provided adequate reasons for its discretionary decision. The judgments were affirmed. View "P. v. Quintero" on Justia Law

Jose Villegas, a 39-year-old inmate at Lake Correctional Institution (LCI) in Florida, died following a physical confrontation with correctional officers. The incident began when officers found Villegas unconscious in his cell. Upon regaining consciousness, Villegas resisted the officers' attempts to restrain him. The officers eventually subdued Villegas and transported him to a medical unit, but he was pronounced dead upon arrival. The autopsy reported that Villegas died from restraint asphyxia, with excited delirium as a contributing factor, and noted the presence of synthetic cannabinoids in his system.Douglas B. Stalley, representing Villegas's estate and his minor children, filed a lawsuit against the officers, their supervisors, and the Florida Department of Corrections (FDOC) for negligence, wrongful death, excessive force, deliberate indifference, and supervisory liability. The United States District Court for the Middle District of Florida granted summary judgment in favor of the defendants on the constitutional claims and declined to exercise jurisdiction over the state-law wrongful death claim, remanding it to state court.The United States Court of Appeals for the Eleventh Circuit reviewed the case. Stalley appealed the district court's decision regarding the deliberate indifference and supervisory liability claims. The Eleventh Circuit affirmed the district court's ruling, holding that the officers were entitled to qualified immunity. The court found that the officers' decision to transport Villegas to a medical unit rather than provide on-scene care did not violate any clearly established constitutional right. Consequently, the supervisory liability claim also failed, as it was contingent on the underlying constitutional violation. View "Stalley v. Lake Correctional Institution Warden" on Justia Law

A Black man, known for his career in the NFL, was accused by an intellectually disabled woman of raping her at gunpoint during a babysitting job interview at his home. The jury found him guilty of forcible rape, forcible oral copulation, and false imprisonment, with firearm use in the first two offenses. He was sentenced to 15 years to life in prison. The prosecution argued that the police did not search his house due to his fame and race, suggesting a search would have caused controversy.The trial began in March 2020 but was paused due to the COVID-19 pandemic, resuming three months later. The jury acquitted him on two counts related to the victim's incapacity to consent. The trial court sentenced him in October 2020. The defendant appealed, arguing that the prosecution's statements violated the California Racial Justice Act of 2020 by appealing to racial bias.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found that the prosecution violated the Racial Justice Act by explicitly asserting that the defendant's race influenced the police's decision not to search his house, implying he gained an undeserved advantage at trial because he was Black. The court concluded that the prosecution's statements constituted racially discriminatory language under Penal Code section 745, subdivision (a)(2). The court held that Penal Code section 745, subdivision (e)(2)(A) precludes harmless error analysis and mandates vacating the conviction and sentence. Consequently, the court reversed the judgment, vacated the conviction and sentence, and remanded for new proceedings consistent with the Racial Justice Act. View "P. v. Stubblefield" on Justia Law

Steven Catlin, a California state prisoner, appealed the district court’s denial of his 28 U.S.C. § 2254 habeas corpus petition challenging his 1990 conviction for the murders of his fourth wife, Joyce Catlin, and his adoptive mother, Martha Catlin, as well as his death sentence. Catlin was convicted of murdering three family members with paraquat, a poisonous herbicide. The habeas petition in this case relates to his convictions for the murders of Joyce and Martha and the death sentence for Martha’s murder.The California Supreme Court (CSC) summarily denied Catlin’s first state habeas petition on the merits in 2007 and rejected his second state habeas petition in 2013 as procedurally barred. The district court denied Catlin’s federal habeas petition and his motion for discovery and evidentiary development in 2019, granting a certificate of appealability on several claims.The United States Court of Appeals for the Ninth Circuit reviewed Catlin’s claims under the deferential standard set forth in the Antiterrorism and Effective Death Penalty Act (AEDPA). The court affirmed the district court’s denial of Catlin’s habeas petition, concluding that the CSC reasonably rejected Catlin’s claims. The court held that the CSC acted reasonably in rejecting Catlin’s claims of error arising from the state trial judge’s ex parte discussion with a juror, concluding that there was no ineffective assistance of counsel at both the guilt and penalty phases of Catlin’s trial, and determining that there was no violation of due process rights under Brady v. Maryland and Napue v. Illinois.The Ninth Circuit also declined to issue a certificate of appealability for Catlin’s uncertified claim that the state violated his due process rights by withholding exculpatory evidence and presenting false evidence. The court found that no reasonable jurist could debate the district court’s resolution of this claim. View "CATLIN V. BROOMFIELD" on Justia Law

The case involves Lori Ann Wiley, who, along with Charles Wallace Hanson, engaged in a verbal altercation at a Kern High School District (KHSD) high school. The incident began when a school employee blocked a handicap parking spot they intended to use. Wiley later submitted a written complaint about the incident to the school. Subsequently, KHSD police officer Michael Whiting recommended various misdemeanor charges against Wiley, leading to her being cited and a prosecutor filing a criminal complaint with three misdemeanor charges. After a mistrial, the court dismissed Wiley’s charges in the interest of justice.Wiley sued KHSD police officers Edward Komin, Michael Whiting, Luis Peña, and Steven Alvidrez, alleging violations of her First Amendment rights, malicious prosecution, and abuse of process. She brought causes of action under 42 U.S.C. section 1983, the Bane Act, and common law torts for intentional infliction of emotional distress and negligence. The trial court sustained the defendants’ demurrer to Wiley’s causes of action in the second amended complaint on multiple grounds without leave to amend and granted a motion to strike Wiley’s punitive damages allegations without leave to amend.The California Court of Appeal, Fifth Appellate District, reviewed the case. The court affirmed the trial court’s decision in part and reversed it in part. The appellate court held that Wiley failed to adequately plead her claims under section 1983 for malicious/retaliatory prosecution and abuse of process, as well as her claims under the Bane Act. The court also found that the defendants were entitled to qualified immunity and that Wiley did not sufficiently allege facts to support her claims for intentional infliction of emotional distress and negligence. However, the court granted Wiley leave to amend her section 1983 claim but denied leave to amend her other causes of action. The court affirmed the trial court’s order granting the motion to strike without leave to amend. View "Wiley v. Kern High School District" on Justia Law

The appellant, Shawn Lee Perrot, was convicted in 2004 of multiple sexual offenses involving minors, including forcible rape, lewd acts on a child, and distribution of lewd material to a minor. After serving over 16 years of a 21-year sentence, he was paroled with specific conditions. Perrot violated three parole conditions: accessing and using computer devices, associating with known sex offenders, and possessing sexually stimulating devices. He challenged these conditions as unconstitutionally vague and overbroad.Upon his release, Perrot refused to sign parole conditions, leading to civil commitment proceedings, which were later dismissed. He was evaluated as high risk for reoffending. Perrot signed parole conditions, including prohibitions on computer access, associating with sex offenders, and possessing sexually stimulating devices. He filed grievances and a habeas corpus petition challenging these conditions, which were largely denied, though he was temporarily allowed limited computer use for legal research.The Department of Adult Parole Operations filed a petition for parole revocation, alleging Perrot violated the conditions. Evidence showed he possessed multiple unauthorized devices, operated a business assisting sex offenders, and had sexually stimulating devices. The court found probable cause and revoked his parole, sentencing him to a 60-day jail term, followed by reinstatement to parole.The California Court of Appeal, First Appellate District, reviewed the case. The court rejected Perrot's claims, holding that the parole conditions were not unconstitutionally vague or overbroad. The court found the conditions were sufficiently precise and narrowly tailored to address the state's compelling interest in preventing Perrot from reoffending. The order revoking Perrot's parole was affirmed. View "P. v. Perrot" on Justia Law

Nathaniel Pryor was stopped by police in Aurora, Illinois, after officers received a tip about drug activity linked to a van. Pryor exited the van quickly, and an officer ordered him to the ground, took him down, struck him twice, and searched him. No drugs were found, and Pryor was charged with obstructing/resisting a police officer, but the charge was later dropped. Pryor then sued several officers and the City of Aurora, alleging multiple federal and state law claims, including under 42 U.S.C. § 1983.The United States District Court for the Northern District of Illinois granted in part the defendants' motion for summary judgment, dismissing some claims and allowing others to proceed to trial. At trial, the jury found in favor of the defendants on the remaining claims. Pryor appealed, arguing that the district court erred in its summary judgment decision and in various evidentiary and procedural rulings during the trial.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment on Pryor’s false arrest claim, finding that the officers had probable cause to arrest him for obstruction of justice and resisting arrest. The court also upheld the district court’s decision to grant qualified immunity to the officer for the leg sweep and tackle, as Pryor failed to show that the use of force was clearly established as excessive under the circumstances. Additionally, the court found that the searches conducted by the officer were proper incidents to Pryor’s arrest and were not extreme or patently abusive.The Seventh Circuit also affirmed the district court’s evidentiary and procedural rulings, including the admission of drug surveillance evidence, the exclusion of certain testimony by Pryor, and the handling of jury instructions. The court concluded that the district court did not abuse its discretion in these decisions and that any errors were harmless. The judgment of the district court was affirmed in full. View "Pryor v. Corrigan" on Justia Law