Justia Civil Rights Opinion Summaries

The Court of Appeals held that Defendant had a reasonable expectation of privacy in data contained on his hard drive and that the government conducted an unreasonable search by examining data without any authority to do so either by a warrant or an exception to the warrant requirement.At issue was whether the consensual creation of a copy of the hard drive of Defendant's seized laptop computer permanently eliminated Defendant's privacy interest in the hard drive. The circuit court denied Defendant's motion to suppress and ultimately convicted him of three counts of distribution of child pornography. The appellate court reversed, concluding that individuals have a legitimate expectation of privacy in the digital data within their computer and that Defendant's revocation of his consent to examine the data from his laptop precluded a forensic examination of the mirror-image copy of its hard drive without a warrant. The Court of Appeals affirmed, holding that the search in this case was unreasonable after Defendant withdrew his consent. View "State v. McDonnell" on Justia Law

A kitchen supervisor directed Balle, an Illinois state prisoner, to carry near-boiling water across a wet, damaged floor in a plastic five-gallon bucket. His foot caught in a hole, and he fell down. The water splashed on him and caused severe burns. Balle sued several prison officials, claiming they violated the Eighth Amendment by being deliberately indifferent to the dangerous kitchen conditions. The district court dismissed some of Balle’s claims at the pleading stage and granted summary judgment on the others.The Seventh Circuit affirmed in part. The record lacks sufficient evidence to create a genuine dispute as to the subjective knowledge of two defendants. Viewing the record in the light most favorable to Balle, a reasonable jury could conclude that the kitchen conditions represented an objectively serious danger to inmates, but gaps in the record prevent a jury from inferring that the two actually knew about the conditions that made the kitchen seriously dangerous–that inmates had to carry scalding water across the damaged floor. The court reversed in part, reinstating the claim against the kitchen supervisor, who required the inmates to carry the scalding water. The court affirmed the denial of a motion to recruit counsel. View "Balle v. Kennedy" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellants' joint motion to suppress more than 300 pounds of marijuana law enforcement discovered during a traffic stop on Interstate 80 in Wyoming, holding that the district court did not err when it denied Appellants' motion to suppress evidence.Appellants - Cristian Ramirez and Hector Zapien-Galvan - were pulled over by state troopers for an expired registration. Appellants refused to consent to a search of the car, after which a certified canine alerted to packages containing 320.6 pounds of marijuana. Appellants moved to suppress the evidence, arguing that the officer's conduct in pursuing their vehicle without reasonable suspicion negated the subsequent probable cause for the search. The district court denied the motion. The Supreme Court affirmed, holding that the district court properly denied Appellants' motion to suppress because the underlying traffic stop was both objectively justified and reasonable at its inception and did not violate Wyo. Const. art. I, 4 or the Fourth Amendment. View "Zapien-Galvan v. State" on Justia Law

The Supreme Court affirmed the order of the district court reversing its order suppressing evidence found in the car that Defendant was driving on two separate occasions where law enforcement discovered drugs and other contraband, holding that the district court did not abuse its discretion in reversing its suppression order but erred in admitting prior drug use.Defendant was convicted by a jury of two counts of possessing methamphetamine and four counts of possessing drug paraphernalia with intent to use to distribute. The court of appeals reversed and remanded for a new trial on the ground that the district court erroneously allowed the State to introduce evidence relating to Defendant's prior convictions for similar crimes. The Supreme Court affirmed, holding (1) the district court erred in admitting prior drug crime evidence, and the error was not harmless; and (2) the district court did not abuse its discretion in granting the State's motion to reconsider its erroneous suppression ruling. View "State v. Campbell" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to dismiss the indictment against him on double jeopardy grounds after the district court declared a mistrial based on complications brought about by the pandemic, holding that that there was no error.Defendant was charged with transmitting a threatening communication in interstate commerce. During trial, the government's main witness and a case agent took a test that came back positive for COVID-19. The court ultimately ordered a mistrial and dismissed the jurors. Thereafter, Defendant filed a motion to dismiss on double jeopardy grounds. The district court denied the motion. The Supreme Court affirmed, holding that the steps taken by the district court leading to its declaration of a mistrial were within its discretion. View "United States v. Dennison" on Justia Law

In 2006, Mervilus, age 22, supported his mother, a cancer patient, and two younger siblings. Abreu accused Mervilus of robbing and stabbing him. Mervilus agreed to take a polygraph examination. Earlier that year, officers dismissed drug charges after a polygraph exam indicated he truthfully denied responsibility. New Jersey permitted polygraph results to be admitted at trial. The Union County Police Department’s only certified polygraph examiner, Kaminskas, conducted the exam. Kaminskas used the “Arther Method,” an “outlier in the polygraph world,” not accredited by the American Polygraph Association. The Method relies on subjective observations and assumptions, such as that certain ethnic groups do not experience any guilt when they lie. Kaminskas concluded Mervilus was deceptive. The only relevant question where Mervilus’s physiological responses signaled deception was a question for which Kaminskas insisted Mervilus change his answer. At trial Abreu failed to identify Mervilus, pointing to a different Black man. The court admitted the polygraph exam. Mervilus was convicted. In 2011, the conviction was overturned on the ground that Kaminskas’s testimony was improper and prejudicial.Mervilus sued Kaminskas, Chief Vaniska, and Union County, 42 U.S.C. 1983. The Third Circuit reversed the summary judgment rejection of those claims. Mervilus introduced sufficient evidence to try his fabrication-of-evidence claim against Kaminskas. His Monell claim against Union County is viable even if Kaminskas did not fabricate evidence; a jury might not render an inconsistent verdict if it found the County liable but Kaminskas not culpable. View "Mervilus v. Union County" on Justia Law

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