Justia Civil Rights Opinion Summaries

In 2005, a jury convicted Lopez and three others of Gomez’s first-degree premeditated murder and found true the gang-murder special circumstance and the criminal street gang sentencing enhancement. Lopez was sentenced to life imprisonment without the possibility of parole. The Court of Appeal affirmed. Lopez sought habeas relief, alleging his jury had been instructed on the natural and probable consequences theory of aiding and abetting first-degree murder, found invalid in the California Supreme Court's 2014 "Chiu" decision. In 2019, the Court of Appeal held that the Chiu error was harmless beyond a reasonable doubt based on the gang-murder special circumstance, which required the jury to find that an aider and abettor acted with intent to kill, and the “overwhelming” evidence against Lopez generally. The court discounted the prosecutor’s discussion of the natural and probable consequences theory in his closing argument and found a jury note referencing that theory inconsequential under the circumstances.The California Supreme Court reversed. The gang-murder special circumstance here does not necessarily render the Chiu error harmless beyond a reasonable doubt but indications that the jury may have relied on an invalid theory, such as a prosecutor’s closing argument or a jury note, do not preclude a finding of harmlessness. The court must rigorously review the evidence to determine whether any rational juror who found the defendant guilty based on an invalid theory and made the factual findings reflected in the verdict, would necessarily have found the defendant guilty based on a valid theory. View "In re Lopez" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree, holding that Defendant was not entitled to relief on his allegations of error.In 2019, police charged Defendant with murder in the first degree for a murder committed in 1979. The charges were based on the results of a DNA test that was performed on a drinking straw that the police retrieved from an eating establishment where Defendant had eaten. A jury found Defendant guilty and sentenced him to prison. The Supreme Court affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress evidence about DNA that police found on the straw that Defendant discarded or to analyze DNA attached to the straw; (2) the district court did not abuse its discretion by declining to give an instruction regarding federal sentencing law; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Burns" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction for two counts each of second-degree sexual assault and second-degree sexual assault of a child and also reversing the circuit court's order denying Defendant's motion for postconviction relief, holding that Defendant was not entitled to postconviction relief.In his motion for postconviction relief, Defendant argued that the prosecutor at his trial violated his Fifth Amendment right against self-incrimination by adversely commenting on his decision not to testify. The court of appeals reversed, concluding that the prosecutor's argument that the evidence was "uncontroverted" was improper, thus violating Defendant's Fifth Amendment right not to testify at trial. The Supreme Court reversed, holding that the prosecutor did not comment on Defendant's silence, and therefore, the circuit court properly denied Defendant's motion for postconviction relief. View "State v. Hoyle" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's plea-based convictions, holding that the court of appeals erred in concluding that the record as a whole demonstrated that his pleas were entered voluntarily and intelligently.Defendant was charged with eleven felonies. Pursuant to a plea agreement, Defendant entered a plea of no contest to three charges. Defendant appealed, arguing, among other things, that his no contest pleas were not entered freely, intelligently, voluntarily, understandingly, and knowingly. The court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in finding that Defendant's no contest pleas were voluntarily and intelligently entered because the record did not affirmatively show that Defendant understood his rights or that he expressly waived them. View "State v. Mead" on Justia Law

In 1988, Kerins was convicted of sodomy with a person under 18, a Sexually Violent Predator (SVP) qualifying offense. In 1998, Kerins pleaded guilty to two counts of annoying or molesting a child under 18. The trial court sentenced him to 13 years in prison. Before Kerins’s scheduled release date in 2006, two psychologists concluded Kerins met the SVP criteria, Welfare and Institutions Code section 6600(a). After his probable cause hearing there were multiple continuances, reevaluations, and substitutions of attorney. In November 2020. Kerins filed a habeas corpus petition, arguing that the People did not bring him to trial in a timely manner and that he was denied effective assistance of counsel.The trial court denied the petition in November 2021, describing the delay as “considerable,” but finding that the “overwhelming reason” for the delay was that Kerins’s counsel sought “continuance after continuance.” The court further observed that Kerins did not assert his right to a speedy trial until 2019 and that nothing indicated Kerins’s defense had been impaired. The court of appeal upheld the decision. The court’s findings about the reasons for the delays and concerning prejudice were supported by substantial evidence. Kerins offered no evidence to rebut the presumption that his attorneys provided reasonable assistance. View "In re Kerins" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder with the use of a deadly weapon, holding that a district court's invocation of general, as opposed to case-specific, concerns related to the COVID-19 pandemic does not justify dispensing with a defendant's right to in-person confrontation.Appellant fatally shot his girlfriend in a car in which two children were present. During the jury trial, the district court permitted two witnesses to testify remotely via video. On appeal, Defendant argued that his constitutional right to confrontation was violated because the witnesses' convenience did not justify permitting remote testimony and that the district court should have made case-specific findings before summarily ordering that the witnesses may appear remotely. The Supreme Court agreed, holding that because the court did not make the required findings of necessity before allowing the two witnesses to testify remotely Defendant's right to confrontation was violated, but the constitutional error was harmless beyond a reasonable doubt. View "Newson v. State" on Justia Law

The Supreme Judicial Court vacated the judgment of the post-conviction review (PCR) court denying Appellant's PCR petitions, holding that the PCR court misconstrued aspects of the relevant law.In his speedy trial petitions, Defendant argued that his rights to a speedy trial had been violated and that his trial counsel provided ineffective assistance by failing to raise his speedy trial claims. The PCR court denied the petition. Thereafter, Defendant sought a certificate of probable cause. The Supreme Judicial Court vacated the judgment below, holding (1) the PCR court utilized a faulty analysis in concluding that there was no merit to Defendant's speedy trial claim; and (2) because the PCR court did not analyze counsel's strategy in failing to assert Defendant's right to a speedy trial the case must be remanded. View "Winchester v. State" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of one count of aggravated trafficking in scheduled drugs and two counts of criminal forfeiture, holding that the trial court did not err in denying either Defendant's motion to suppress or his motion for discovery.On appeal, Defendant argued that the trial court erred when it denied his motion to suppress and his request for additional discovery relating to the State's cooperating defendant. The Supreme Judicial Court affirmed, holding (1) law enforcement agents had probable cause to support their stop of Defendant, and therefore, the trial court did not err when it denied Defendant's motion to suppress; and (2) the trial court did not abuse its discretion in denying Defendant's discovery motion. View "State v. Lepenn" on Justia Law

The Supreme Court affirmed the judgment of the circuit court admitting two 911 calls reporting a shooting and a dash cam video containing statements from an eyewitness during Defendant's criminal trial, holding that any error was harmless.After a jury trial, Defendant was convicted of first-degree murder, first-degree battery, and other crimes. After he was sentenced to life imprisonment plus fifteen years, Defendant filed a motion for a mistrial, which was deemed denied. The Supreme Court affirmed, holding (1) the circuit court properly ruled that the statements from the 911 calls were nontestimonial and thus admissible; (2) the circuit court erred in admitting the dash cam video, but the error was harmless beyond a reasonable doubt; and (3) Defendant's final two arguments were not preserved for appellate review. View "McNeil-Lewis v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of stalking his ex-wife, holding that Defendant was not denied his right to a speedy trial and that the trial court did not commit prejudicial error in instructing the jury.After a jury trial, Defendant was found guilty of one count of felony stalking and sentenced to four to six years in prison. The Supreme Court affirmed, holding (1) Defendant was not denied his right to a speedy trial under either Wyo. R. Crim. P. 48 or the Sixth Amendment to the United States Constitution; and (2) the district court abused its discretion by giving instruction number fourteen because it described stalking as a general intent crime when it, in fact, is a specific intent crime, but Appellant did not meet his burden to demonstrate prejudice. View "Person v. State" on Justia Law