Justia Civil Rights Opinion Summaries

In 2000, Adnan Syed was convicted of the murder of Hae Min Lee and sentenced to life in prison plus 30 years. In 2022, the State’s Attorney for Baltimore City moved to vacate Syed’s conviction, citing new evidence and alleged Brady violations. Young Lee, the victim’s brother, was given less than one business day’s notice of the vacatur hearing, which he attended remotely. The court granted the motion to vacate and ordered the State to either retry Syed or enter a nolle prosequi (nol pros) within 30 days. The State later entered a nol pros, effectively dismissing the charges against Syed.Young Lee appealed the vacatur order, arguing that his rights as a victim’s representative were violated due to insufficient notice and the inability to attend the hearing in person. The Appellate Court of Maryland vacated the circuit court’s order, reinstated Syed’s convictions, and remanded for a new hearing, holding that the nol pros did not moot Lee’s appeal and that Lee had the right to reasonable notice and to attend the hearing in person.The Supreme Court of Maryland affirmed the Appellate Court’s decision, holding that the entry of the nol pros did not moot Lee’s appeal. The court ruled that a victim has the right to be heard at a vacatur hearing under CP § 11-403, which includes hearings where the alteration of a sentence is considered. The court also held that Lee’s rights were violated due to insufficient notice and the inability to attend the hearing in person. The case was remanded to the Circuit Court for Baltimore City for further proceedings, starting from the point immediately after the State’s Attorney filed the motion to vacate. View "Syed v. Lee" on Justia Law

In 1987, Michael Hill was convicted of two murders and sentenced to death. Hill maintained that the murders were committed by Michael McCray, whose statements to the police incriminated both himself and Hill. McCray did not testify at trial, invoking his privilege against self-incrimination, but his statements were admitted under the hearsay rule. Decades later, Hill discovered that the prosecution had failed to disclose a promise not to prosecute McCray for his involvement in the case. Hill filed a habeas corpus petition alleging violations of Brady v. Maryland and Napue v. Illinois.The trial court dismissed Hill’s claims, finding he failed to establish a prima facie case. The court concluded that the evidence against Hill was overwhelming and that the failure to disclose the non-prosecution agreement did not undermine confidence in the verdict. The court also found that Hill did not plead that false evidence was presented to the jury, as required under Napue.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court found that Hill established a prima facie case for both Brady and Napue violations. The court noted that McCray’s testimony at the preliminary hearing was misleading and that the prosecution’s suppression of the non-prosecution agreement allowed McCray to assert his privilege against self-incrimination, leading to the admission of his statements without cross-examination. The court concluded that the suppressed evidence was material and could have affected the jury’s verdict. The court reversed the trial court’s order and remanded the case for further proceedings, directing the trial court to issue an order to show cause. View "In re Hill" on Justia Law

Michael Harvel, a county official, was convicted by a jury for sexually assaulting seven women he supervised, violating their constitutional rights under 18 U.S.C. § 242. Harvel appealed, raising issues about the timeliness of the charges, the indictment's sufficiency, and the admission of certain evidence.The United States District Court for the Middle District of Tennessee initially handled the case. Harvel argued that the most serious charges were not brought within the five-year statute of limitations under 18 U.S.C. § 3282(a). However, the court found that these charges were "punishable by death" under 18 U.S.C. § 3281, thus not subject to the five-year limit. Harvel also claimed that the introduction of "other crimes" evidence violated the Due Process Clause and Federal Rule of Evidence 403. The district court allowed this evidence, finding it relevant and not overly prejudicial.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's rulings, holding that the charges were timely under § 3281 because the crimes included kidnapping and aggravated sexual abuse, which are punishable by death under § 242. The court also rejected Harvel's due process challenge to Rule 413, which allows the admission of other sexual assaults to show propensity, and found no abuse of discretion in the district court's Rule 403 balancing. Additionally, the court upheld the denial of Harvel's motion for a mistrial, concluding that the district court's limiting instructions were sufficient to mitigate any potential prejudice from the inadmissible testimony.In conclusion, the Sixth Circuit affirmed Harvel's convictions and the 204-month sentence, finding no merit in his arguments regarding the statute of limitations, the indictment's sufficiency, or the evidentiary rulings. View "United States v. Harvel" on Justia Law

Brian Jones, a Wisconsin prisoner, sued several correctional officers under 42 U.S.C. § 1983, alleging violations of his Eighth Amendment rights. The claims arose from an incident where Jones caused a disturbance in the prison dayroom, refused to return to his cell, and was subsequently placed in a restraint chair and transported to a restrictive-housing cell. Jones alleged that the officers used excessive force, conducted an unlawful strip search, and confined him in a dirty cell.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the officers on all claims. Jones, who represented himself during the lower court proceedings, argued on appeal that the magistrate judge should have granted his request for pro bono counsel under 28 U.S.C. § 1915(e)(1). The magistrate judge had denied this request, concluding that Jones was competent to litigate the straightforward case on his own.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the magistrate judge applied the correct legal standard and reasonably concluded that Jones was capable of handling the case himself. The court also determined that the video evidence conclusively showed that Jones's claims lacked merit. The video demonstrated that the officers used only minimal force, conducted the strip search in a professional manner, and that Jones's cell conditions did not amount to a constitutional violation. Consequently, the Seventh Circuit affirmed the district court's judgment, holding that the denial of pro bono counsel was appropriate and that the officers did not violate Jones's Eighth Amendment rights. View "Jones v. Anderson" on Justia Law

In 2017, a minor admitted to two counts of assault with intent to commit rape and was initially placed in a Level B program. Due to multiple probation violations, the juvenile court later committed him to the Division of Juvenile Justice (DJJ) in 2019. After being discharged from DJJ in April 2023, the juvenile court imposed a probation condition requiring the minor to register as a sex offender under Penal Code section 290.008. The minor appealed, arguing that this requirement violated his equal protection rights because it treated him differently from minors who committed similar offenses after the juvenile justice realignment, which closed DJJ and transferred responsibilities to county facilities.The Superior Court of Sacramento County upheld the probation condition, rejecting the minor's equal protection argument. The court found that the sex offender registration requirement did not involve a loss of liberty and thus did not implicate a fundamental right, applying the rational basis standard of review. The court reasoned that the Legislature could have determined that minors in county facilities have a lower risk of recidivism due to more effective treatment, justifying the differential treatment.The California Court of Appeal, Third Appellate District, reviewed the case de novo and affirmed the lower court's decision. The court held that the rational basis standard applied because the sex offender registration requirement did not involve a fundamental right or suspect classification. The court found that a rational basis existed for the differential treatment, as the Legislature could have reasonably concluded that minors already in DJJ custody posed a higher risk of recidivism and required continued registration to protect public safety. Thus, the court found no equal protection violation and affirmed the dispositional order. View "People v. I.B." on Justia Law

A high-school administrator, Justin Schimandle, forcibly restrained a student, C.G., at school. Following an investigation, Detective Josh Duehning of the Dekalb County Sheriff’s Office submitted affidavits to support an arrest warrant for Schimandle on battery charges. An Illinois state magistrate judge issued the warrant, and Schimandle turned himself in. The criminal case proceeded to a bench trial, where Schimandle was found not guilty after the prosecution rested.Schimandle then sued the Dekalb County Sheriff’s Office and Duehning, alleging false arrest. The defendants moved for judgment on the pleadings, and the United States District Court for the Northern District of Illinois granted the motion, dismissing Schimandle’s claims. The court found that there was probable cause to arrest Schimandle and that Duehning was entitled to qualified immunity.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that arguable probable cause supported Schimandle’s arrest, meaning a reasonable officer could have believed probable cause existed based on the circumstances. The court also found that Duehning was entitled to qualified immunity, protecting him from liability for the false arrest claim. Additionally, the court noted that the magistrate judge’s issuance of the arrest warrant further supported the reasonableness of Duehning’s actions. Consequently, the court affirmed the dismissal of Schimandle’s complaint. View "Schimandle v. DeKalb County Sheriff's Office" on Justia Law

In 1997, the defendant was convicted of second-degree murder with a firearm enhancement and sentenced to 15 years to life, plus an additional 10 years. In January 2020, he filed a petition under former section 1170.95, which was summarily denied. In January 2023, he filed a motion for relief under section 745 of the California Racial Justice Act (RJA), claiming racial bias in his conviction and sentence. The trial court denied the motion, citing improper service and failure to state a violation of the RJA.The defendant appealed, arguing that he made a prima facie case for a hearing under section 745 and that the denial violated his equal protection rights. The People contended that the trial court lacked jurisdiction to consider the motion and that the denial was not erroneous. The defendant countered that his motion was authorized under section 745, subdivision (b).The California Court of Appeal, Fifth Appellate District, reviewed the case and concluded that the defendant's motion was prematurely filed under the RJA’s phased-in retroactivity provisions. Specifically, the court noted that the defendant's case fell within the last phase of eligibility for relief, commencing January 1, 2026. As a result, the trial court lacked fundamental jurisdiction to consider the motion, rendering its order void. The appellate court vacated the trial court's order and dismissed the appeal. View "People v. Vigil" on Justia Law

David Gaddie was charged with four counts of gross sexual imposition for allegedly sexually abusing a child. In a separate case, he was charged with three counts of gross sexual imposition for allegedly abusing the child's mother, but those charges were dismissed. The case involving the child proceeded to trial, and Gaddie was found guilty on all counts. On direct appeal, one conviction was reversed due to an issue with jury instructions.Gaddie then filed an application for postconviction relief, claiming ineffective assistance of counsel and prosecutorial misconduct. The State moved for partial summary dismissal, arguing that Gaddie should have raised the prosecutorial misconduct claim on direct appeal. The district court reserved ruling on this motion and held a hearing. During the hearing, it was revealed that the State had introduced a video containing statements about Gaddie abusing the child's mother, which Gaddie’s attorney had objected to during the trial. The district court denied the State's motion for partial summary dismissal but ultimately denied Gaddie’s application for postconviction relief, reasoning that the situation was a misunderstanding rather than intentional misconduct.The North Dakota Supreme Court reviewed the case and found that prosecutorial misconduct had occurred because the State introduced inadmissible prior bad act evidence without providing the required notice under N.D.R.Ev. 404(b). The Court held that this misconduct prejudiced Gaddie’s right to a fair trial. Consequently, the Supreme Court reversed the district court's judgment denying postconviction relief and remanded the case with instructions to vacate the criminal judgment and enter any supplementary orders required by law. View "Gaddie v. State" on Justia Law

Curtis Terrell, after consuming a significant amount of alcohol, pain pills, and methamphetamine, began running erratically in a residential neighborhood. His wife, Angela Terrell, called 911, requesting an ambulance. Officer Jason Allgrunn arrived and arrested Mr. Terrell. When Mrs. Terrell began filming the incident, she was also arrested. The Terrells filed multiple federal and state claims against Allgrunn and other officers involved.The United States District Court for the Western District of Louisiana denied summary judgment to the defendants on all claims, rejecting their qualified immunity defense. The defendants appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court reversed the district court's denial of summary judgment for the defendants on the Terrells' false arrest claims, finding that Officer Allgrunn had probable cause to arrest both Mr. and Mrs. Terrell. The court also reversed the denial of summary judgment on Mrs. Terrell's excessive force claim, concluding that there was no clearly established law prohibiting the officer's conduct. However, the court dismissed the appeal regarding Mr. Terrell's excessive force claim for lack of jurisdiction, as there were genuine disputes of material fact about what occurred when Mr. Terrell was out of the video frame.Additionally, the court reversed the denial of summary judgment on the Terrells' malicious prosecution and First Amendment retaliation claims, citing the presence of probable cause. The court also reversed the denial of summary judgment for Officers Henderson and Banta on the failure-to-intervene claims, as there were no violations of clearly established constitutional law.Finally, the court vacated the district court's denial of summary judgment on the Louisiana state law claims and remanded for reconsideration in light of the appellate court's opinion. View "Terrell v. Allgrunn" on Justia Law

Jermaine Randy Howard was convicted of second-degree murder after shooting a man at an unlicensed nightclub in San Jose. Howard claimed he acted in self-defense, but the jury rejected this defense. Before sentencing, Howard filed a motion alleging the prosecutor violated the California Racial Justice Act (RJA) by questioning him about his connection to East Palo Alto, which he argued was racially biased. The trial court denied the motion, finding Howard failed to make a prima facie showing of an RJA violation, and sentenced him to 19 years to life in prison.Howard appealed, arguing the trial court erred in denying his RJA motion and that the prosecutor's cross-examination and closing arguments violated the RJA and his due process rights. He also contended that the jury instructions misstated the law regarding murder, imperfect self-defense, and heat of passion, cumulatively prejudicing his defense.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found that the trial court erred in concluding Howard had not made a prima facie showing of an RJA violation regarding the prosecutor's cross-examination about East Palo Alto. The appellate court conditionally reversed the judgment and remanded the case for further proceedings on Howard's RJA motion. The court rejected Howard's claims of instructional error, finding the jury instructions correctly stated the law and did not mislead the jury about the prosecution's burden of proof.The appellate court's main holding was that Howard made a prima facie showing of an RJA violation, warranting a hearing on his motion. The court conditionally reversed the judgment and remanded for further proceedings, affirming the conviction and sentence otherwise. If the trial court denies relief on remand, the judgment will be reinstated; if relief is granted, further proceedings will follow. View "People v. Howard" on Justia Law