Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for postconviction relief without holding an evidentiary hearing, holding that the district court did not err in determining that all of Defendant's claims were either insufficiently pled or affirmatively refuted by the record.Defendant, in inmate who was serving consecutive sentences for three convictions, including a life sentence for first degree murder, brought this motion alleging ineffective assistance of counsel both at trial and on direct appeal. The district court denied the motion after determining that all of Defendant's claims were either insufficiently pled or affirmatively refuted by the record. The Supreme Court affirmed, holding that none of Defendant's claims warranted an evidentiary hearing and that the district court properly overruled Defendant's motions to add exhibits and to appoint counsel. View "State v. Cox" on Justia Law

Plaintiff is a Florida death-row prisoner who is scheduled to be executed on May 3, 2023, at 6:00 p.m. Barwick brought an action under 42 U.S.C. Section 1983, arguing that the Governor of Florida and several other state officials violated his constitutional right to due process because they did not adequately consider his candidacy for executive clemency. He also moved for an emergency stay of execution. The district court denied Plaintiff’s motion for a stay. Plaintiff then moved in this Court for a stay of execution pending appeal.   The Eleventh Circuit denied Plaintiff’s motion for a stay. The court explained that here Plaintiff argued that the State violated his due-process rights because it did not provide any standards that would govern the clemency decision. But under the Eleventh Circuit’s binding precedent, the court wrote it cannot agree that the Due Process Clause requires the State to provide any such standards. An initial problem with Plaintiff’s argument about the State’s lack of standards is that it runs counter to Supreme Court authority. Further, the court held that it cannot agree with Plaintiff’s argument that his clemency proceeding was arbitrary because the Commission allegedly “provided false guidance” when it said it was not concerned with his guilt but then “myopically focused on [his] crime.” Accordingly, the court held that Plaintiff’s due-process claim does not have a substantial likelihood of success on the merits. View "Darryl Barwick v. Governor of Florida, et al" on Justia Law

Diaz was convicted of conspiracy to distribute and possess with intent to distribute heroin and cocaine and was sentenced to 33 months’ incarceration followed by 36 months’ supervised release. During that period of supervised release, Scranton Police Officers responded to a report of a physical, domestic incident involving Diaz’s then-girlfriend, Fernandez. Other violations of supervised release included possessing and using marijuana. During a probable cause and detention hearing, Magistrate Saporito heard testimony from Fernandez that she was not scared of Diaz. Saporito imposed a no-contact condition. Fernandez's testimony in the detention hearing was proven false. Diaz had called Fernandez and persuaded her to recant her statements to the police. Saporito ordered Diaz to be detained until his final revocation hearing.At the final supervised release violation hearing, Judge Mannion sentenced Diaz to the statutory maximum of 24 months’ incarceration followed by another two years’ supervised release. Mannion reimposed the no-contact order to apply during Diaz’s incarceration and his new term of supervised release. The Third Circuit vacated in part. The district court lacked either statutory or inherent authority to impose the custodial no-contact order. The court upheld the condition of Diaz’s second period of supervised release as narrowly tailored and sufficiently connected to the 18 U.S.C. 3553(a) factors. View "United States v. Santos Diaz" on Justia Law

Police released the footage of a bank robbery to the media. Several tipsters identified Garcia as the robber. Garcia was arrested without a warrant. Two days later Detective Spano submitted a “Probable Cause Statement and Judicial Determination” (CR-215) form to a court commissioner (essentially a magistrate) to establish a basis for Garcia’s continued detention. The form references the Fourth Amendment and Wisconsin Statute 970.01, “Initial Appearance Before a Judge.” Spano indicated that he had “probable cause to believe that [Garcia] committed” bank robbery and violated his parole," citing a description of the surveillance footage and the tips. The commissioner checked a box stating: “I find probable cause to believe that the arrested person committed the offense(s),” and set bail at $50,000. Garcia, in jail, was not present for the CR-215 determination.Hours after the probable cause finding—without counsel for Garcia—the police conducted an in-person lineup with two tellers. Three days later, Wisconsin prosecutors charged Garcia with bank robbery. Garcia appeared in court that day represented by a public defender; 10 days later Garcia appeared at a preliminary hearing; the court ordered him detained pending trial.The Wisconsin Court of Appeals affirmed Garcia’s conviction, determining that the right to counsel had not attached at the time of the lineup. The Seventh Circuit affirmed a grant of habeas corpus relief (28 U.S.C. 2254). The state court's resolution of Garcia’s Sixth Amendment right-to-counsel claim was objectively unreasonable, even applying "vast deference" under 2254(d)(1). The court cited the “Supreme Court’s long line of cases on the attachment of the right to counsel.” The judicial machinery of the state’s adversarial process necessarily began to turn against Garcia after the commissioner executed the CR-215 form. View "Garcia v. Hepp" on Justia Law

Under the Gun Control Act “it shall be unlawful for any person to transfer or possess a machinegun,” 18 U.S.C. 922(o)(1). The Act incorporates the definition from the National Firearms Act: “machinegun” means any weapon which shoots, is designed to shoot, or can be readily restored to shoot, automatically more than one shot, without manual reloading, by a single function of the trigger. The term shall also include the frame or receiver of any such weapon, any part designed and intended solely and exclusively, or combination of parts designed and intended, for use in converting a weapon into a machinegun, and any combination of parts from which a machinegun can be assembled if such parts are in the possession or under the control of a person, 26 U.S.C. 5845(b).The ATF, which administers both statutes, previously maintained that a bump stock, which drastically increases a gun’s rate of fire, is not a machinegun part. In 2018, after a Las Vegas gunman used bump stocks attached to semiautomatic rifles to kill 58 people and injure roughly 500 in approximately 10 minutes, the ATF reversed its position by promulgating the Rule, giving possessors of bump stocks 90 days to destroy or abandon their bump stocks.Hardin challenged the Rule as exceeding the ATF’s statutory authority. The Sixth Circuit reversed a judgment upholding the Rule, noting the rule of lenity in criminal cases and that Congress could resolve the ambiguity. View "Hardin v. Bureau of Alcohol, Tobacco, Firearms and Explosives" on Justia Law

In 2013, Sergeant Robert Motyka, a Denver police officer, shot Michael Valdez, who was lying unarmed on the ground and surrendering. In the ensuing lawsuit brought under 42 U.S.C. § 1983, a jury awarded Valdez $131,000 from Sergeant Motyka for excessive force in violation of the Fourth Amendment1 and $2,400,000 from the City and County of Denver (“Denver”) for failure to train its officers. The district court awarded $1,132,327.40 in attorney fees and $18,199.60 in costs to Valdez’s lawyers. The Tenth Circuit addressed three appeals arising from this litigation. Denver challenged the district court's: (1) denial of its motion for summary judgment; (2) reversal of a discovery order and permission for Valdez to present additional municipal liability theories; and (3) jury instructions on municipal liability. Valdez cross-appealed the district court's grant of qualified immunity to Lieutenant John Macdonald, another Denver police officer who shot at him. And Sergeant Motyka and Denver contend that the district court abused its discretion in awarding attorney fees and costs. The Tenth Circuit: (1) affirmed the judgment against Denver; (2) affirmed qualified immunity because Valdez did not show the court erred in this respect; and (3) affirmed the attorney fee award but reversed costs, finding the district court did not explain its award after finding Valdez had not substantiated them. The case was remanded for the district court to reexamine whether costs should be awarded. View "Valdez v. City and County of Denver" on Justia Law

The National Center for Missing and Exploited Children (NCMEC) forwarded to the Knoxville Police a CyberTip from Facebook reporting that a 43-year-old male appeared to be using Facebook private messages to entice a 15-year-old female (M.D.) to produce and send child-exploitation images and engage in sexual activity. The CyberTip suggested that they had already engaged in sexual activity and included information matching Tywan Sykes.Charged with enticing a minor to engage in sexual activity, 18 U.S.C. 2422(b); enticing a minor to engage in sexually explicit conduct for the purpose of producing any visual depiction of such conduct, section 2251; committing felony offenses involving a minor while required by Tennessee law to register as a sex offender, section 2260A; and knowingly possessing child pornography section 2252A, Sykes filed unsuccessful motions to suppress evidence retrieved from his Facebook account and cell phone. He argued that NCMEC is a government entity and that Facebook had become NCMEC's agent by searching his account and forwarding messages to NCMEC and that the month-and-a-half delay between the seizure of his phone and the execution of the search warrant was unreasonable. The court also partially denied a motion to exclude evidence of his prior sex offenses.The Sixth Circuit affirmed Sykes’s convictions and 45-year sentence, rejecting arguments that the district court erred in denying his motion to suppress and erroneously admitted evidence of a past sex-offense conviction; that there was insufficient evidence to convict on all charges; and that his sentence was procedurally unreasonable. View "United States v. Sykes" on Justia Law

Police discovered a loaded firearm, cocaine, and more than 800 methamphetamine pills on Jones’s person and in his car during a traffic stop. Federal charges followed. Counsel declined to make frivolous challenges to the court’s jurisdiction at Jones’s request. Jones sought to represent himself. Magistrate Long conducted an extensive Faretta colloquy, covering Jones’s education, mental health, and prior legal experiences. Jones confirmed his understanding of the charges and agreed to follow the Federal Rules of Evidence and Criminal Procedure. He claimed that he understood the perils of self-representation, which Long explained in detail. The court allowed Jones to represent himself and appointed his public defender as standby counsel. Jones spent months before trial challenging the court’s jurisdiction in frivolous filings, advancing “sovereign-citizen” arguments.Concerned with the incoherence of the filings, the government requested a second Faretta colloquy. District Judge Mihm conducted the colloquy. Jones insisted he did not “consent” to jurisdiction and would not participate in his trial. While he acknowledged understanding the “letter” of the charges against him, he also expressed confusion about whether the proceedings were criminal, civil, administrative, or even “statutory maritime.” Mihm concluded that Jones’s waiver of counsel remained valid. Jones did not deliver opening or closing statements, cross-examine witnesses, or lodge any objections. His testimony had no bearing on the charges against him. The Seventh Circuit affirmed his conviction and 138-month sentence. Jones knowingly and voluntarily waived his right to counsel. View "United States v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual abuse in the third degree, holding that Defendant was not entitled to reversal of his convictions on his allegations of error.The court of appeals affirmed Defendant's convictions but concluded that the trial court lacked jurisdiction to enter a nunc pro tunc order attempting to correct Defendant's sentence and remanding the case for the district court to correct the sentence. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to support the jury's finding that Defendant was previously convicted of an act of sexual abuse for purposes of the sentencing enhancement; (2) the district court did not err in overruling Defendant's challenge brought under Batson v. Kentucky, 476 U.S. 79 (1986); and (3) any error in the court's decision to excuse a juror for cause did not prejudice Defendant. View "State v. Booker" on Justia Law

The Supreme Court affirmed the judgment of the superior court in granting summary judgment in favor of Defendants, Rhode Island College and related individuals, on the grounds of qualified immunity, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff brought this action seeking equitable relief and damages under 42 U.S.C. 1983 and 1988 on the grounds that Defendants' conduct toward him during his Master of Social Work program violated his First and Fourteenth Rights. The superior court concluded that Defendants were entitled to qualified immunity and granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal were unavailing. View "Felkner v. R.I. College" on Justia Law