Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction and sentence on one count of assault in the second degree and one count of negligent child abuse, holding that Defendant was not entitled to relief on her claims of error.Specifically, the Supreme Court held (1) Defendant's claims of ineffective assistance of counsel were unavailing; (2) Defendant failed to preserve for appellate review his argument that the trial court erred by excepting from its sequestration order an eyewitness to the crimes who was the wife of one victim and mother of the other; (3) the trial court did not err by refusing to give a self-defense instruction; and (4) the trial court did not abuse its discretion in determining that Defendant was not a suitable candidate for probation. View "State v. Johnson" on Justia Law

Williams was a key facilitator in a years-long cocaine trafficking scheme. In 2001, he was convicted of federal drug and conspiracy charges, 18 U.S.C. 841(a)(1), 846 and given life sentences. Williams appealed the denial of his 18 U.S.C. 3582(c)(1)(A) motion for a reduced sentence, arguing that the district court erred in holding that it was not permitted to consider whether Williams’s unconstitutionally imposed mandatory life sentence contributed to “extraordinary and compelling reasons” for the reduction of his sentence.The Seventh Circuit affirmed, declining to reconsider its 2021 "Thacker" decision, stating it would make no difference to Williams’s case. The district court held in the alternative that even if Williams was eligible for a reduction in his sentence, this relief was not warranted in light of 18 U.S.C. 3553(a)'s factors. The court acknowledged different approaches among the circuits regarding the bounds of court discretion to find extraordinary and compelling reasons for early release— specifically, whether the two-step process employed by the Seventh Circuit is correct or if a more holistic approach is called for. The court noted that the U.S. Sentencing Commission is in the process of studying the issue, and recently has proposed defining “extraordinary and compelling reasons” to include circumstances in which “[t]he defendant is serving a sentence that is inequitable in light of changes in the law.” View "United States v. Williams" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of death, holding that Defendant was not entitled to relief on any of his claims of error.Defendant pleaded guilty to first degree murder. After a penalty-phase trial, the court concluded that the aggravating circumstances far outweighed the mitigating circumstances, warranting a sentence of death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in declining to grant Defendant's motion to continue; (2) the trial court did not err in rejecting two statutory mitigating circumstances; (3) Defendant failed to establish a constitutional defect with Florida's death-penalty statute; (4) Defendant's guilty plea was knowingly, intelligently, and voluntarily given; and (5) Defendant's remaining arguments were without merit. View "Wells v. State" on Justia Law

The First Circuit affirmed the judgment of the district court denying Appellant's challenge to his sentence under 28 U.S.C. 2255, holding that Appellant did not meet his burden of showing that his counsel's performance during the underlying criminal trial was deficient.Appellant pleaded guilty to two counts of conspiracy to distribute a substance containing cocaine base and one count of malicious damage or destruction of property by fire. At sentencing, the trial court determined that Appellant was a career offender in part because his prior Maine state court conviction for unlawful trafficking in scheduled drugs qualified as a "controlled substance offense" under the U.S. Sentencing Guidelines. In this collateral challenge to his sentence, Appellant argued that he received constitutionally ineffective assistance of counsel during his sentencing hearing based on his counsel's failure to object to the use of the Maine drug conviction as a predicate offense for the career offender enhancement. The First Circuit denied relief, holding that Appellant's ineffective assistance claim failed. View "Thompson v. United States" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of employing a minor in an obscene performance in violation of Conn. Gen. Stat. 53a-196a, sexual assault in the first degree, and other offenses, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying Defendant's motion to sever the sexual offenses with the nonsexual offenses and in joining the informations for trial; (2) the obscene performance statute was not unconstitutionally vague as applied to Defendant's conduct, and the First Amendment did not require the Court to undertake an independent appellate review of that conviction; (3) the trial court's potentially incorrect rulings, including those relating to the excludion from evidence video recordings of forensic interviews of the victim, were harmless error beyond a reasonable doubt; and (4) the evidence was sufficient to support Defendant's convictions of assault in the third degree, criminal violation of a protective order, and stalking in the first degree. View "State v. Michael R." on Justia Law

The Supreme Court answered a certified question of law concerning the applicability of Conn. Gen. Stat. 53-37 to this case, concluding that section 53-37 did not apply because Plaintiff's complaint did not allege any speech constituting an "advertisement."Plaintiff brought this reenforcement action challenging 53-37, which provides that "[a]ny person who, by his advertisement, ridicules or holds up to contempt any person or class of persons, on account of the creed, religion, color, denomination, nationality or race of such person or class of persons, shall be guilty of a class D misdemeanor." Plaintiff alleged that the statue violated his right to free speech under the First and Fourteenth Amendments to the United States Constitution and sought declaratory and injunctive relief seeking permanently to enjoin the enforcement of the statute. Defendants filed a motion to dismiss for lack of subject matter jurisdiction, arguing that Plaintiff lacked standing to bring the action because he had failed to allege an injury in fact. The Supreme Court answered a certified question regarding the issue by answering that the uncontroverted evidence demonstrated that section 53-37 was not intended to encompass the type of personal, noncommercial speech alleged in Plaintiff's complaint. View "Cerame v. Lamont" on Justia Law

Gilbert, on parole for a state conviction, was arrested for printing false identifications and credit cards and was returned to the custody of the Michigan Department of Corrections. Federal authorities charged Gilbert with identity theft crimes. Wolf was Gilbert's appointed counsel. Gilbert consented to federal detention pending trial. Gilbert pleaded guilty under 18 U.S.C. 1029(a)(4) and 1028A(a)(1). After reviewing Gilbert’s PSR, Wolf realized that he had mistakenly led Gilbert to believe that the time Gilbert had spent in federal detention would be credited against his federal sentence. Wolf acknowledged the error. The court offered Gilbert the opportunity to withdraw his plea but Gilbert decided to continue with sentencing. The court sentenced Gilbert to 15 months on Count 1, concurrent to the undischarged Michigan term, and 24 months on Count 2, “consecutive to Count 1 and all other terms of imprisonment.”Gilbert filed a habeas motion. Wolf admitted that he gave Gilbert erroneous advice and that because of his incorrect understanding of the law he did not expedite Gilbert’s guilty plea and sentence; did not seek a downward adjustment under USSG 5G1.3; and did not object when the court ruled that the aggravated identity theft sentence had to run consecutive to all other undischarged sentences. The Sixth Circuit affirmed the denial of relief. Even if Gilbert could demonstrate that counsel’s performance—initial error followed by correction—was deficient, he failed to present evidence of prejudice. Sentences imposed under the aggravated identity theft statute must run consecutive to all other (including state) sentences and are not subject to USSG 5G1.3 adjustments. View "Gilbert v. United States" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendants' motion to withdraw his guilty plea under Kan. Stat. Ann. 22-3210 and his subsequent motion under Kan. Stat. Ann. 60-1507 alleging ineffective assistance of counsel and involuntariness when he entered the plea, holding that the district court did not err.On appeal, the Supreme Court noted that Defendant did not preserve any issue on appeal as it related to his section 60-1507 motion and that Defendant made new arguments that were inappropriately raised for the first time on appeal. As to the denial of Defendant's motion to withdraw his plea under Kan. Stat. Ann. 22-3210(d)(2), the Supreme Court held that the district court did not abuse its discretion in denying Defendant's motion to withdraw plea. View "Shelton-Jenkins v. State" on Justia Law

Several defendants were charged by indictment in separate cases with various offenses arising from their alleged participation in the Capitol riot on January 6, 2021. Among other charges, the government also charged each Defendant with one count of Obstruction of an Official Proceeding under 18 U.S.C. Section 1512(c)(2). The district court granted each Defendant’s motion to dismiss. The government filed a motion to reconsider, which the district court denied. At issue on consolidated appeal is whether individuals who allegedly assaulted law enforcement officers while participating in the Capitol riot can be charged with corruptly obstructing, influencing, or impeding an official proceeding, in violation of 18 U.S.C. Section 1512(c)(2). The DC Circuit reversed. The court held that the district court erred in dismissing the counts under 18 U.S.C. Section 1512(c)(2). The court wrote that Defendants’ alleged conduct falls comfortably within the plain meaning of “corruptly . . . obstruct[ing], influenc[ing], or imped[ing] [an] official proceeding, or attempt[ing] to do so.” The alternative interpretations of Section 1512(c)(2) proffered by the district court and Defendants failed to convince the court to depart from the natural reading of the statute’s unambiguous text. View "USA v. Joseph Fischer" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of possession of a controlled substance with intent to deliver and two counts of failure to possess a tax stamp, holding that the district court did not err in denying Defendant's motion to suppress.Officers entered Defendant's apartment without a warrant over the objections of the occupants. They then obtained a search warrant, finding evidence resulting in criminal charges. Defendant filed a motion to suppress, arguing that the initial warrantless entry was unconstitutional. The district court denied the motion, concluding that the search was justified under the emergency aid doctrine. The Supreme Court affirmed, holding that the emergency aid doctrine permitted the police officers' entry into the residents to render emergency aid to a possible shooting victim hidden inside. View "State v. Youm" on Justia Law