Justia Civil Rights Opinion Summaries

The Bail Project, a nonprofit organization, advocates for the abolition of cash bail and pays cash bail for thousands of individuals across the country to show that conditioning a pretrial defendant’s release upon the payment of money is not necessary to secure appearances at future court dates. Indiana House Enrolled Act 1300 requires charitable bail organizations to register with the state and limits for whom such organizations can pay cash bail.The Project sought to enjoin Indiana’s Department of Insurance from enforcing the law, arguing that HEA 1300 (which had not yet gone into effect) would violate its First Amendment right to free speech and its Fourteenth Amendment right to equal protection. The district court held that The Project had not shown a likelihood of success on the merits. The Seventh Circuit affirmed. The payment of cash bail is not protected by the First Amendment. Although The Project pays bail with the intent to communicate its message and to further its advocacy, a reasonable observer would not understand the conduct itself as communicating any message without additional explanatory speech. HEA 1300 does not violate the Equal Protection Clause because it is rationally related to Indiana’s legitimate interest in regulating the pretrial detention of criminal defendants. View "The Bail Project, Inc. v. Commissioner, Indiana Department of Insurance" on Justia Law

In this murder case, the Supreme Court established a standard a defendant must satisfy to compel extraction of GPS data by a defendant's third-party agent from a crime victim's automobile for the trial court's in camera inspection and held that remand was required in the instant case.Defendant was charged with the second-degree murder of Grant Draper, making his brother Lane Draper a victim by virtue of Ariz. Rev. Stat. 13-4401(12), a statute that implements the Arizona Constitution's Victims' Bill of Rights. During plea negotiations and without notice to Lane, Defendant obtained a court order to access GPS data to support his third-party defense identifying Lane as the possible killer and for cross-examination regarding the time Defendant argued he was asleep. The trial court allowed the data to be extracted for a limited in camera interview. Lane filed a petition for special action, which the court of appeals denied. The Supreme Court held (1) a defendant is entitled to discovery from a victim if the defendant seeks evidence of a constitutional dimension and the defendant establishes that the requested discovery is very likely to contain such evidence; and (2) remand was required in this case. View "Draper v. Honorable Gentry" on Justia Law

The Supreme Court affirmed Defendant's conviction of ten sex crimes against two sisters, A.S. and T.S., holding that Defendant was not entitled to relief on his allegations of error.The State charged Defendant with a total of twenty-two crimes against A.S. and T.S. The jury convicted him of ten of the charges, and the district court sentenced him to seventy-one to eighty-five years in prison. The Supreme Court affirmed, holding (1) Defendant failed to establish that the State violated his right to due process of law under Brady or Giglio; (2) Defendant did not show that his counsel performed deficiently or that his defense was prejudiced by counsel's actions at trial; and (3) the State presented sufficient evidence to support Defendant's convictions for the first-degree sexual assault against T.S. View "Mills v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court denying Defendant's motion for a new trial following his successful motion for postconviction forensic and deoxyribonucleic acid (DNA) analysis pursuant to Mass. Gen. Laws ch. 278A, 2, holding that there was no error in the denial of Defendant's motion for a new trial.A jury convicted Defendant of murder in the first degree on a theory of extreme cruelty or atrocity, and the Supreme Court affirmed. Following multiple pro se motions, Defendant filed the instant motion for postconviction DNA analysis, which the court allowed. Defendant then filed a motion for a new trial. The motion judge denied the motion, concluding that the new evidence did not case real doubt on the justice of Defendant's conviction. Defendant then filed a petition pursuant to Mass. Gen. Laws ch. 278, 33E for leave to appeal. A single justice granted the petition. The Supreme Judicial Court affirmed the denial of Defendant's motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error. View "Commonwealth v. Duguay" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Defendant's motion for a new trial, holding that the record was insufficient to determine whether Defendant's right to a public trial was violated due to restrictions put in place by the district court arising from the COVID-19 pandemic.In December 2019, Defendant was charged with first-degree aggravated robbery. Because of the restrictions placed on trials due to the pandemic the county submitted a trial plan that excluded all spectators from the courtroom but included a one-way video feed that would broadcast the trial in an adjacent courtroom. The trial court overruled Defendant's objection, and the trial proceeded. After Defendant was convicted he moved for a new trial. The court of appeals denied the motion. The Supreme Court reversed, holding that additional findings were required on the decision to close the courtroom before it could be determined whether Defendant's public trial right was violated. View "State v. Bell" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress statements recorded on a body-worn camera, holding that the district court did not abuse its discretion in determining that the statements should be suppressed.In response to a domestic disturbance 911 call law enforcement officers found A.H. locked out of her apartment while Defendant was inside, and A.H. told the officers that Defendant had assaulted her both in the present and in the past. These statements were recorded by an officer's body-worn camera. Defendant was subsequently charged with one count of misdemeanor domestic assault. The district court granted Defendant's motion to suppress the body-worn camera recording on the grounds that their admission would violate Defendant's constitutional right to confrontation. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in determining that A.H.'s statements did not qualify as excited utterances under Minn. R. Evid. 802(2); and (2) properly suppressed the statements as inadmissible hearsay. View "State v. Tapper" on Justia Law

Michigan State Police (MSP) detectives, assigned to investigate the 2011 Bates killing, learned that on the night of her murder, Bates was in her home with Jones and both of their boyfriends. Reed, Jones’s boyfriend, was charged. Jones said she did not want to testify and that “they” would kill her if she did. An assistant prosecutor saw Brown (Reed’s mother) following Jones as Jones cried, yelling that she “couldn’t go testify and she better not go in there.” Brown was arrested for witness intimidation. Brown was in jail for approximately 96 hours and was not brought before a judge for a probable cause hearing. MSP never requested a warrant for her arrest or took any other action relating to her detention.Brown sued the MSP defendants for violating her Fourth Amendment rights. The district court held that the defendants were not entitled to qualified immunity but, because of the “complicated factual scenario” did not determine at the summary judgment stage which defendants bore legal responsibility for violating her rights. The Sixth Circuit affirmed in part. Under the totality of the circumstances, there was probable cause to arrest Brown. The defendants are entitled to qualified immunity on that claim. It was clearly established at the time of Brown’s arrest that her arresting officers had a duty to take her before a magistrate for a probable cause hearing; they are not entitled to qualified immunity on that claim. View "Brown v. Knapp" on Justia Law

Plaintiffs were arrested by Sheriff’s deputies for stashing their client’s cell phone in a bag only minutes before the police executed a search warrant for child pornography on that phone.  Plaintiffs alleged that District Attorney and Assistant District Attorney ordered the arrest. Following the arrest, the DA, in a statement to the press, and ADA, on the courthouse steps, publicly accused Plaintiffs of concealing evidence of a crime and knowingly possessing child pornography. After Plaintiffs were acquitted they filed this federal lawsuit for unlawful arrest. The district court entered judgment against the Deputies and denied the DA’s and ADA’s motion for summary judgment on the false arrest claim. The district court also denied the district attorneys’ motion for summary judgment on Plaintiffs’ defamation claims.   The Eleventh Circuit affirmed in part and reversed in part and remanded to the district court with instructions to enter judgment for Defendants on Plaintiffs’ false arrest claims. The court wrote that on remand, the district court should determine whether to exercise pendent jurisdiction over the defamation claims. The court held that Defendants are entitled to qualified immunity because they had arguable probable cause to arrest Plaintiffs. The court explained it believes “a reasonable officer, looking at the entire legal landscape at the time of the arrests, could have interpreted the law as permitting the arrests here.” However, even if Defendants made their allegedly defamatory statements as part of their official duties, the Supreme Court of Alabama has held that state-agent immunity does not protect against intentional defamation. View "Megan Garcia, et al v. Pamela Casey, et al" on Justia Law

Kelsey Carpenter gave birth to a baby girl at home, alone, after deciding that she would not risk having her child removed from her custody as had happened with her two older children when they tested positive for drugs after being delivered at the hospital. She again used drugs during her pregnancy. After Carpenter’s daughter was born, the baby struggled to breathe, and Carpenter attempted to provide her with CPR. Carpenter also cut the baby’s umbilical cord but did not clamp it, and the umbilical stump continued to bleed. Carpenter bathed, diapered, clothed, and attempted to breastfeed the baby before seemingly passing out. When she woke up, her newborn daughter was dead. Before Health & Saf. Code, § 123467(a) was effective, the State charged Carpenter with implied malice murder and felony child endangerment, contending that Carpenter intentionally chose an unattended at-home delivery, despite being warned of the dangers, in an effort to evade child welfare services and at the risk of her daughter’s life. According to the State, Carpenter’s acts and omissions, including her failure to seek medical assistance after realizing her baby was in distress, caused the baby to bleed to death. Carpenter challenged the superior court’s order denying her motion to set aside the information for lack of probable cause under Penal Code section 995. She contended she was immune from prosecution based on the new law, which went into effect after the preliminary hearing, but before the superior court ruled on her section 995 motion. While the Court of Appeal agreed that Carpenter could not be prosecuted for her decision to have an unattended home birth or any effect that her alleged drug use or lack of prenatal care during pregnancy may have had on her baby, the law did not preclude the State's prosecution for her acts and omissions after her daughter was born alive. The Court therefore denied Carpenter's petition. View "Carpenter v. Super. Ct." on Justia Law

After a New Year’s Eve hit-and-run left one person dead and another injured, Jones became a suspect and turned himself in. During a recorded interrogation at 1:18 a.m., an officer read Jones his Miranda rights and fully explained those rights. Jones asked what penalty he was potentially facing. The officer refused to answer, asking multiple times if Jones wanted to proceed with questioning. The officer stated that others had placed him at the scene of the accident, police knew Jones fled because he was scared, Jones did the right thing coming in, and it was important for Jones to get his side of the story on record. After saying he felt horrible, Jones asked, “So y’all can get a public pretender right now?” After some laughter, a detective responded, “You said it right, pretender … they’re called public defenders.” After more chuckling, the detective said: “Obviously due to the time right now, we can’t.” At one point the detective stated that he believed the maximum punishment was 15 years. Jones then told the detectives what happened, implicating himself.The Wisconsin trial court denied his motion to suppress, concluding that Jones's joking reference to a “public pretender” cannot constitute a genuine request. A state appellate court affirmed. The Seventh Circuit affirmed the denial of habeas relief. Jones’s question about a lawyer, whether earnest or in jest, was too ambiguous to invoke his right to counsel under Supreme Court law. View "Jones v. Cromwell" on Justia Law