Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of capital murder and sentence of life imprisonment without parole, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the trial court's failure to instruct the jury with the model verdict form on dispute accomplice status was reversible error under the third and fourth exceptions enumerated in Wicks v. State, 606 S.W.2d 366 (Ark. 1980). The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence obtained during a search of his property; and (2) neither Wicks exception to the objection requirement applied under the circumstances of this case. View "Nowell v. State" on Justia Law

Addison was convicted, in absentia, of unlawful possession of a motor vehicle, unlawful possession of a converted motor vehicle, forgery, and two counts of theft, arising out of his alleged use of counterfeit money to purchase a motorcycle, and was sentenced to 15 years’ imprisonment. Having failed to appear for trial, he was subsequently arrested.Addison’s appellate counsel did not file a brief and determined that there are no meritorious issues, except concerning credit that should be applied toward the prison sentences. Addison filed a postconviction petition, contending that trial and appellate counsel were deficient. Appointed postconviction counsel filed an amended petition, alleging trial counsel was ineffective for failing to file a motion to suppress based on improper Miranda warnings, for failing to object to expert testimony regarding counterfeit currency when no expert was disclosed, and for failing to argue sufficiency of the evidence where there were discrepancies; and that the court erred in giving an accountability instruction. The petition did not assert ineffective assistance of appellate counsel. The trial court dismissed the petition.Addison appealed, arguing that postconviction counsel rendered unreasonable assistance in failing to argue ineffective assistance of appellate counsel. The Illinois Supreme Court agreed. Addison did not forfeit collateral review of his conviction by failing to appear at trial. While any postconviction claims that could have been raised on direct appeal are generally forfeited that forfeiture could have been overcome by framing the issues as ineffective assistance of appellate counsel for failing to raise the issues on direct appeal. The appellate court properly remanded for compliance with Illinois Supreme Court Rule 651(c) without considering the merits. View "People v. Addison" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of possession with intent to distribute a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress drug evidence.Defendant was a passenger in a single-vehicle car accident on the Maine Turnpike. Suspicion that the vehicle and/or its occupants were transporting drugs Maine police officers searched Defendant's bag and discovered narcotics. Defendant filed a motion to suppress, arguing that the evidence was obtain in violation of her Fourth Amendment rights. The district court denied the motion, after which Defendant conditionally pleaded guilty. The First Circuit affirmed, holding that Defendant's arguments for suppression failed. View "United States v. Howard" on Justia Law

Convicted of the 1996 strangulation murder of Stites, Reed was sentenced to death. The Texas Court of Criminal Appeals affirmed. Reed’s state and federal habeas petitions were unsuccessful. In 2014, Reed sought DNA testing of the evidence. The prosecutor refused to test most of the evidence. The court denied Reed’s motion; the Texas Court of Criminal Appeals affirmed, citing chain of custody issues.Reed filed suit, 42 U.S.C. 1983, asserting that Texas’s stringent chain-of-custody requirement was unconstitutional and effectively foreclosed DNA testing for individuals convicted before the promulgation of rules governing the handling and storage of evidence. The Fifth Circuit affirmed the dismissal of the suit, finding that the two-year statute of limitations began to run when the Texas trial court denied Reed’s motion, not when the Texas Court of Criminal Appeals denied rehearing.The Supreme Court reversed. The statute of limitations began to run at the end of the state-court litigation. Establishing a procedural due process violation requires proof of deprivation by state action of a protected interest in life, liberty, or property, and inadequate state process. The claim is not complete when the deprivation occurs but only when the state fails to provide due process. Texas’s alleged failure to provide Reed with a fundamentally fair process was complete when the state litigation ended and deprived Reed of his asserted liberty interest in DNA testing. If the statute of limitations began to run after a state trial court’s denial of the motion, the prisoner would likely continue to pursue state court relief while filing a federal section 1983 suit. That parallel litigation would run counter to principles of federalism, comity, consistency, and judicial economy. If any due process flaws lurk in the DNA testing law, the state appellate process may cure those flaws, rendering a federal suit unnecessary. View "Reed v. Goertz" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of being an accessory before the fact to kidnapping and the order denying his motion for postconviction relief, holding that Defendant was not entitled to relief on his claims of error.Defendant, a police officer, provided several specific items to James Feeney, his drug supplier, at Feeney's request, including information about the victim as well as Defendant's police badge, gun holster, and handcuffs. Feeney provided the information and items to Scott Morrison and Alfred Ricci, who convinced the victim they were at his house to complete a mandatory drug test. The pair kidnapped him, and Feeney murdered him. Defendant was convicted of being an accessory before the fact to kidnapping. The Supreme Judicial Court affirmed the convictions and the denial of Defendant's postconviction motion, holding (1) the evidence was sufficient for a jury to find beyond a reasonable doubt that Defendant shared Feeney's intent that the kidnapping take place; (2) the trial judge's instructions to the jury were without error; and (3) there was no error in the trial judge's evidentiary rulings. View "Commonwealth v. Schoener" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of gross sexual assault and two counts of unlawful sexual contact, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the district court did not abuse its discretion in denying Defendant's motion for a continuance; (2) there was no constitutional error in the trial court's ruling requiring that participants in Defendant's trial be masked; (3) there was no prosecutorial error in either the State's opening or closing argument or in the State's rebuttal argument; and (4) Defendant's claims of evidentiary error were unavailing. View "State v. Hunt" on Justia Law

In 2010, Keller and others broke into a Shelby County house occupied by Morrow and Jones and two minor children. Keller threatened the occupants with a gun while demanding money. One assailant repeatedly struck Morrow in the head. All the assailants ransacked the house. One child hid and called 911. After his conviction Keller sought a new trial, raising several challenges to his convictions and sentence; he did not raise a double-jeopardy claim. For the first time, on appeal to the Tennessee Court of Criminal Appeals, Keller argued his convictions violated the Double Jeopardy Clause, in that his convictions for attempted especially aggravated robbery and aggravated assault of Morrow were for the same offense, and that all of his convictions should have merged into a single conviction for aggravated robbery of Morrow. The Tennessee Court of Criminal Appeal found that Keller waived his double-jeopardy claim by not raising it in his motion for a new trial as required by Tennessee’s procedural rules. Keller had acknowledged the waiver. Considering Keller’s double-jeopardy claim under plain-error review, the court held that the double-jeopardy claim failed.After unsuccessfully seeking post-conviction relief in state court, Keller filed a federal habeas petition. The Sixth Circuit affirmed the denial of his federal 28 U.S.C. 2254 habeas petition on the double jeopardy claim. Keller, by his own concession, procedurally defaulted his double-jeopardy claim. View "Keller v. Genovese" on Justia Law

The Supreme Court reversed Defendant's conviction for misdemeanor interference with a peace officer stemming from his act of resisting when police officers entered his home without a warrant to arrest him for a misdemeanor crime, holding that, under the circumstances of this case, Defendant's conviction could not stand.On appeal, Defendant argued that the officers' warrantless entry into his home was unlawful, and therefore, the trial court erred in denying his motion to suppress. The Supreme Court reversed, holding (1) the officers in this case were not "engaged in the lawful performance" of their official duties when they entered Defendant's home without a warrant, as required to convict him under Wyo. Stat. Ann. 6-5-204(a); and (2) because the officers' warrantless entry into Defendant's home was per se unreasonable, the warrantless entry into Defendant's home to execute a warrantless arrest violated Defendant's rights under the Fourth Amendment. View "Woods v. State" on Justia Law

During a routine traffic stop, Houston Police Officer fatally shot a man. Plaintiffs, including the parents and estate of the victim, brought multiple claims against the officer who fatally shot the man, two other police officers, and the city. The individual defendants claimed qualified immunity. The district court, in ruling on a motion to dismiss in response to Plaintiffs’ complaint, dismissed Plaintiffs' claims. Plaintiffs appealed the dismissal and requested reassignment to a different district judge. The Fifth Circuit agreed with Plaintiffs that the dismissal of the Section 1983 claims against Defendant for excessive force, denial of medical care, and unlawful arrest was an error. The court reversed and remanded those claims. The court explained that taking as true that Defendant had no reason to believe the man was armed and that the shooting officer knew the man was seriously injured and likely could not move, a police officer would know, under these precedents, that to handcuff the man was an arrest without probable cause under clearly established law. The court affirmed the dismissal of Plaintiffs’ remaining claims is affirmed. The court denied, as moot, Plaintiffs’ request for reassignment to a new judge. View "Allen v. Hays" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of possessing firearms by a felon and one count of possessing methamphetamine with intent to distribute but reversed his conviction of one count of driving with a suspended license, holding that the evidence did not support the suspended license conviction.Specifically, the Supreme Court held (1) the district court did not err in finding that Defendant's statements during an interrogation were voluntary and admissible at trial; (2) the district court's failure to obtain a jury trial waiver before an elemental stipulation was not structural, and the error did not affect the trial's outcome; (3) the lower courts did not err in holding that trial counsel was not ineffective in pursuing a guilt-based defense; (4) there was no clear error in the jury instructions; and (5) the State failed to present evidence of a necessary element of the crime of driving while Defendant's license was suspended. View "State v. Bentley" on Justia Law