Justia Civil Rights Opinion Summaries

The Supreme Court vacated the orders of the superior court granting Defendants' motions to suppress evidence of approximately ninety-four pounds of marijuana seized from one defendant's vehicle during a traffic stop, holding that the trial justice erred in granting Defendants' motions to suppress.Junjie Li was operating a vehicle and Zhong Kuang was in the passenger seat when a law enforcement officer initiated a traffic stop. While conversing with Li, the officer noticed Li began to exhibit nervous behavior and detected an order of marijuana coming from inside Kuang's vehicle. After a dog sniff, officers discovered marijuana. Li and Kuang moved, individually to suppress the marijuana. The trial justice granted the motions to suppress, holding that the extension of the traffic stop beyond its original scope was unreasonable because the officer did not have independent reasonable suspicion to prolong the stop. The Supreme Court vacated the superior court's orders, holding that the trial justice erred in concluding that the officer did not possess reasonable suspicion to prolong the stop based on the totality of the circumstances. View "State v. Li" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of unlawful trafficking in scheduled drugs and falsifying physical evidence, entered after a jury trial, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress evidence seized as the result of what Defendant argued was an unlawful arrest; (2) there was no obvious error in the admission of lay opinion testimony by law enforcement officers on certain matters; (3) the record evidence was sufficient to justify the trial court's giving a permissible-inference instruction; and (4) there was no error or abuse of discretion in the denial of Defendant's motion for new trial and for judgment of acquittal. View "State v. Abdullahi" on Justia Law

Booker was convicted of first-degree murder and received a 55-year sentence of 55. After unsuccessfully appealing his conviction, he tried a petition for postconviction relief. At the latter stage, he was represented by Illinois Assistant Appellate Defender Reyna. Booker wanted Reyna to argue that his trial counsel was constitutionally ineffective. Reyna declined. Booker filed a pro se supplemental brief raising the ineffective assistance of trial counsel claim. The Illinois Appellate Court rejected Booker’s pro se brief because of the state’s rule against hybrid representation.Booker then filed a federal habeas petition, 28 U.S.C. 2254, arguing that his trial counsel was ineffective. The district court held that the claim was procedurally defaulted, reasoning that Illinois courts did not violate any federal rule when they denied his attempt to raise the issue in a pro se supplemental brief. The court also held that Booker’s default could not be excused on actual innocence grounds. The Seventh Circuit affirmed. Booker must bear the consequences of his decision. Even if Reyna’s advice was not entirely accurate regarding his chances of success, Booker had proceeded pro se in the past and knew that he could do so again to ensure that his preferred arguments were raised, or he could hope that the court would make an exception to the rule against hybrid representation. View "Booker v. Baker" on Justia Law

The Supreme Court held that indefinite sentencing under the "Reagan Tokes Law," which became effective in March 2019 and requires that for certain felony offenses a sentencing court impose on the offender an indefinite sentence consisting of a minimum and a maximum prison term, is not unconstitutional.The two appellants in this case - Christopher Hacker and Danan Simmons - were both subject to sentencing under the Reagan Tokes Law. On appeal, Appellants argued that Ohio Rev. Code 2967.271, which allows the Ohio Department of Rehabilitation and Correction to maintain an offender's incarceration beyond the minimum prison term imposed by a trial court, violates the separation of powers doctrine, procedural due process, and the right to a jury trial. The Supreme Court disagreed and affirmed, holding that Appellants failed to rebut the Reagan Tokes Law's presumption of constitutionality in their facial challenge. View "State v. Hacker" on Justia Law

The Supreme Judicial Court affirmed Defendant's convictions other than his unlawful possession conviction, which the Court vacated in light of its recent opinion in Commonwealth v. Guardado, 491 Mass. 666 (2023), holding that Defendant's rights under the Second Amendment and his due process rights were violated as to this conviction because the jury was not instructed that licensure was an essential element of the crime.Specifically, the Supreme Judicial Court held (1) the trial court did not err in denying Defendant's motion to suppress his statement at the police station on the grounds that police officers impermissibly recorded it without his express consent and that he was not informed promptly of his right to make a telephone call; (2) the prosecutor did not improperly refer to omissions in Defendant's statement to police officers; (3) there was no reason to reduce the degree of guilt or order a new trial; and (4) in light of this Court's recent opinion in Guardado, Defendant's unlawful possession of a firearm conviction must be vacated. View "Commonwealth v. Morris" on Justia Law

In 2001, G.A. was charged with lewd acts with a child, sexual battery by restraint, and false imprisonment. Finding G.A. incompetent to stand trial, the court committed G.A. to the Redwood Regional Center. G.A. never regained competency but was released and received services through the Center until 2008. In 2010, G.A. was charged with kidnapping with the intent to sexually assault, rape, annoy, or molest a child under the age of 10 and sexual intercourse or sodomy with a child under the age of 10. Finding G.A. incompetent to stand trial, the court again committed him.A 2021 petition to extend G.A.’s commitment alleged that G.A. suffers from developmental disabilities and that he represents a danger to himself or to others. A psychologist, who evaluated G.A. several times, calculated G.A.’s I.Q. at 42 and testified that G.A. poses a danger to himself and to others, particularly children. The court continued the commitment.The court of appeal dismissed an appeal because the commitment order has expired. The court found that Welfare and Institutions Code 6500 does not violate due process by dispensing with the need for proof of a recent overt act of dangerousness but that substantial evidence did not support the finding of G.A.’s danger to others--it was based on the testimony of an expert witness who relied on unsupported assumptions of fact about G.A.’s offenses. The court noted significant ambiguity as to the meaning of “danger to self.” View "People v. G.A." on Justia Law

Illinois’s Sexually Dangerous Persons Act authorizes the commitment and indefinite detention of individuals who are charged with a crime and found to suffer from a mental disorder "coupled with criminal propensities to the commission of sex offenses.” The Act requires care and treatment for the committed person, "designed to effect recovery.” Once detainees are deemed “no longer dangerous,” the state must discharge them. The Supreme Court held, in 1986, that the Act, on its face, complies with the Due Process Clause, noting the lack of punitive intent, the availability of treatment, and the realistic possibility of release.Every Big Muddy River Program detainee participates in a weekly core therapy group. Only detainees who have acknowledged their prior sexual misconduct participate in offense-specific and didactic groups. Big Muddy does not provide individual therapy. Therapists evaluate detainees semiannually and provide them with copies of their evaluations and treatment plans. Detainees may discuss their evaluations with the therapists only in group therapy, not one-on-one. The state contracts with Wexford to evaluate detainees for release. The plaintiffs alleged that Big Muddy’s treatment program was run in a constitutionally deficient manner.The district court concluded that the disparity between Big Muddy’s treatment program and professional standards amounted to a constitutional violation and issued an injunction, requiring that Big Muddy provide the plaintiffs a minimum of 7.5 hours of core group therapy per week; reinstate inactive groups; and use independent evaluators for discharge evaluations.The Seventh Circuit reversed, acknowledging concern about whether Illinois is complying with its Fourteenth Amendment obligations. Detainees receive minimal treatment, raising serious questions about whether rehabilitation and release are realistically available. The district court, however, issued too broad an injunction under the Prison Litigation Reform Act, 18 U.S.C. 3626(a)(1)(A), which requires the least intrusive means available to correct the constitutional violation. View "Howe v. Hughes" on Justia Law

Plaintiffs sued police officers under Sec. 1983 after the officers made warrantless entry into their apartment. The district court granted summary judgment to Plaintiffs and Defendants appealed.On appeal, the Eighth Circuit reversed. While warrantless searches are presumptively unreasonable, there is an exception when officers act with probable cause to believe that a crime has been committed and an objectively reasonable basis to believe that exigent circumstances exist.Here, the officers were dispatched to the scene in response to a report of domestic violence. The report received by the officers explained that the 911 call came from a neighbor who thought “abuse” was occurring and heard a “verbal argument,” “someone being thrown around,” and “yelling and screaming” in the upstairs apartment. The neighbor stated that a woman, her boyfriend, and a child lived in the apartment. This created anm exigency, justifying warrantless entry. View "Benedda Cotten v. Ryan Miller" on Justia Law

Johnsonburg, Pennsylvania Officer Cuneo learned that the St. Marys Police Department had a search warrant to obtain a DNA sample from Perez. Cuneo knew Perez, a local with a history of illegal drug use. A log entry instructed officers who saw Perez to “hold” him and call St. Marys. Cuneo knew that Perez’s DNA had been found at the scene of a recent drug house burglary. Cuneo inferred—mistakenly—that a “body” warrant also had been issued. Later, sitting in his cruiser, Cuneo spotted Perez. The men stood on the sidewalk, having a “friendly conversation.” When Cuneo mentioned the DNA warrant and told Perez he needed to take him into custody. Perez said he was going home and sprinted away.Cuneo pursued Perez. Perez says he was tased from behind without warning. Cuneo says he warned Perez to stop before tasing him. Perez fell forward, breaking his nose. Cuneo radioed for backup and medical assistance. Perez recovered; a physical altercation ensued. Cuneo repeatedly tased and struck Perez with his baton, then shot Perez in the back.In a suit under 42 U.S.C. 1983, Cuneo asserted qualified immunity in defense. The court denied Cuneo’s summary judgment motion as to his use of his firearm and the unlawful seizure claim. The Third Circuit reversed in part. Cuneo did not seize Perez during their initial encounter. The court remanded so Perez’s excessive force claim for Cuneo’s use of his firearm can proceed. View "Perez v. Borough of Johnsonburg" on Justia Law

When police responded to a shooting outside a casino, the victim was dead. They found Grady’s cell phone, which they used, along with surveillance video, to track him down and arrest him. They searched Grady’s apartment and discovered a gun. An expert witness later testified that it was the weapon that was used in the shooting. Grady and his roommate, Bronson, gave different accounts of what happened that night.A state-court jury convicted Grady of first-degree murder. In response to a special verdict form, the jury found that the prosecution had not proved that Grady was the triggerman. Bronson was sentenced to 24 years, Grady to 60 years. Grady’s direct appeal focused on his sentence. The Illinois Appellate Court affirmed the dismissal of his ineffective assistance post-conviction petition, concluding that the evidence presented against Grady was “overwhelming” and Grady could not demonstrate the necessary prejudice under Strickland.Contending that the special-verdict finding negated the prosecution’s sole theory of guilt, Grady sought a writ of habeas corpus under 28 U.S.C. 2254(a), alleging ineffective assistance of counsel, because his direct-appeal lawyer raised only two issues on appeal, both of which Grady regards as significantly weaker than the inconsistent-verdict argument. The Seventh Circuit affirmed the denial of relief. The state court’s rejection of this contention was not an unreasonable application of Strickland. View "Grady v. Truitt" on Justia Law