Justia Civil Rights Opinion Summaries

The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions based on ineffective assistance of counsel, holding that errors in the proceedings below did not prejudice Defendant.In vacating Defendant's convictions the court of appeals concluded that trial counsel had been ineffective by failing to object to introduction and use of evidence about Defendant's silence while being arrested and by not objecting to the manslaughter jury instruction. The court ultimately concluded that Defendant was prejudiced by these instances of deficient performance. The Supreme Court reversed and reinstated the convictions vacated by the court of appeals, holding (1) trial counsel performed deficiently in failing to object to a certain jury instruction; and (2) assuming counsel was also deficient for not objecting to the State's use of Defendant's post-arrest, pre-Miranda silence against Defendant, Defendant failed to establish that there was a reasonable probability that the outcome of the trial would have been different without these errors. View "State v. Bonds" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court judge denying Defendant's motion to enforce a plea bargain, holding that the plea offer did not violate Defendant's rights to due process.Defendant was indicted along with two codefendants on two counts of murder in the first degree. Defendant was offered a "package deal" plea bargain under which he would have been able to plead guilty to manslaughter if his codefendant also agreed to the same plea. Defendant's codefendant refused the terms of the agreement. Defendant and his codefendant were tried and convicted of all charges. Defendant later filed a motion to vacate his convictions and to accept pleas to manslaughter, as the Commonwealth had originally offered, arguing that the condition attached to the plea offer violated his right to decide whether to accept the plea or go to trial. A superior court judge denied the motion. The Supreme Judicial Court affirmed, holding that the superior court did not err in denying Defendant's motion to enforce the plea bargain. View "Commonwealth v. DiBenedetto" on Justia Law

The Supreme Judicial Court remanded this matter to the county court for entry of an order dismissing the Commonwealth's gatekeeper petition filed under Mass. Gen. Laws ch. 278, 33E challenging the decision of the superior court judge granting Defendant's motion for postconviction relief and reducing his conviction, holding that the petition was untimely.Defendant served forty-four years in prison for his conviction of murder in the first degree. In 2020, Defendant filed a postconviction motion to reduce the verdict from murder in the first degree to murder in the second degree on the grounds that the Commonwealth's 1978 package plea offer violated his right to due process. The motion judge granted the motion and, in 2021, reduced the verdict to murder in the second degree. The Commonwealth filed a notice of appeal but did not file the gatekeeper petition until five and one-half months later, exceeding the thirty-day time limit set out in Mains v. Commonwealth, 433 Mass. 30, 36 n.10 (2000). After a remand, the single justice allowed the petition. The Supreme Judicial Court remanded the matter for entry of an order dismissing the Commonwealth's gatekeeper petition, holding that, with respect to filing deadlines, the Commonwealth is subject to the limitations established in Mains. View "Commonwealth v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction relief (PCR) court determining that Appellant raised a colorable claim for ineffective assistance of trial counsel and ordering him to disclose certain materials, holding that the PCR court did not err in ordering the disclosure of the records.Appellant was found guilty of two counts of first degree murder and sentenced to death. In these PCR proceedings, the PCR court determined that Appellant's ineffective assistance of counsel claim in III(A)-III(E) of the PCR petition was colorable. The court then ordered Appellant to disclose materials associated with trial counsel's interviews of three of Appellant's family members who did not testify during the penalty phase of trial. Appellant filed a petition for special action, claiming that he should not have to disclose the records at issue. The Supreme Court affirmed, holding that there was good cause for the disclosure of materials associated with the interviews under Ariz. R. Crim. P. 32.6(b)(2). View "Naranjo v. Honorable Sukenic" on Justia Law

The Supreme Judicial Court affirmed the judgment of the motion judge allowing Defendant's motion for a new trial after the trial court convicted him of murder in the first degree, holding that the motion judge did not abuse her discretion in concluding that counsel's assistance was constitutionally ineffective.During the proceedings, counsel was informed of a proffer indicating that someone other than Defendant had gone to the victim's home on the evening of the killing and carrying the same caliber firearm as was used in the killing. In his motion for a new trial, Defendant argued that his counsel provided ineffective assistance by failing to investigate the exculpatory evidence provided by the Commonwealth. The motion judge allowed the motion. The Supreme Judicial Court affirmed, holding (1) use of the proffer evidence could have raised a reasonable doubt as to whether Defendant murdered the victim; and (2) therefore, the motion judge's denial of Defendant's motion for a new trial was an abuse of discretion. View "Commonwealth v. Tavares" on Justia Law

Pierner-Lytge, a Second Amendment supporter, walked to a public park near Walker Elementary School that contains a playground and a baseball field. Many children and families were reportedly present that evening. Pierner-Lytge carried a rifle with a spike bayonet bolted to the end of the barrel, a holstered semi-automatic handgun, plus a duty belt containing pepper spray, a baton, and handcuffs. Milwaukee County officers responded to reports. Pierner-Lytge stated that she was exercising her Second Amendment rights and confirmed that she had a concealed carry weapon license but did not have it with her. Pierner-Lytge had previously resisted arrest and threatened officers and had been the subject of six mental health detention proceedings. Officers arrested Pierner-Lytge for disorderly conduct. She complied with instructions. Officers confiscated her rifle, bayonet, handgun, and duty belt. Pierner-Lytge was released from custody and was not charged. The seized property was returned.Pierner-Lytge sued. 42 U.S.C. 1983, alleging that the officers violated her Fourth Amendment rights by arresting her without probable cause. The Seventh Circuit affirmed summary judgment based on qualified immunity. While a reasonable officer should have known in 2020 that simply carrying a firearm in public does not constitute disorderly conduct, more is required to show that the legality of Pierner-Lytge’s conduct was “beyond debate.” To the extent the officers misjudged whether probable cause existed to arrest Pierner-Lytge, it was a reasonable decision given the Wisconsin disorderly conduct statute at the time View "Pierner-Lytge v. Hobbs" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse her discretion in denying relief.Petitioner was convicted of several crimes, including armed assault with intent to murder. The firearm leading to the charges was recovered during a motor vehicle search that led to charges in a separate case against a different individual, Danilo Depina, who successfully moved to suppress the firearm on the basis that it had been illegally seized. Petitioner later filed the underlying petition, which the county court treated as a petition pursuant to Mass. Gen. Laws ch. 211, 3, arguing that he had stand to petition the district attorney's office that had prosecuted Petitioner to produce evidence related to the firearm. A single justice denied the petition. The Supreme Judicial Court appealed, holding that there was no abuse of discretion in the denial of the appeal. View "Pina v. Commonwealth" on Justia Law

Cruz, convicted of capital murder and sentenced to death, argued that under the Supreme Court’s “Simmons” decision, he should have been allowed to inform the jury that a life sentence in Arizona would be without parole. The Arizona Supreme Court held that Arizona’s capital sentencing scheme did not trigger Simmons. The Supreme Court subsequently held ("Lynch" (2016)), that it was fundamental error to conclude that Simmons “did not apply” in Arizona.Cruz sought to raise the Simmons issue under Arizona Rule of Criminal Procedure 32.1(g), which permits a successive post-conviction petition if “there has been a significant change in the law that, if applicable ... would probably overturn the defendant’s judgment or sentence.” The Arizona Supreme Court denied relief, reasoning that a significant change in the application of a law is not a significant change in the law itself, focusing on whether Lynch was a significant change in federal law.The U.S. Supreme Court vacated. A state procedural ruling that is “firmly established and regularly followed” ordinarily forecloses review of a federal claim but the Arizona ruling rests on such a novel and unforeseeable interpretation of a state-court procedural rule that it is not adequate to foreclose review of the federal claim. Although Lynch did not change the Supreme Court’s interpretation of Simmons, it did change the operation of Simmons by Arizona courts in a way that matters for Rule 32.1(g). The analytic focus of Arizona courts applying Rule 32.1(g) has always been on the impact on Arizona law. View "Cruz v. Arizona" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing this lawsuit brought by Appellants seeking a declaration "that individuals are restored to civil rights and possess the fundamental right to vote guaranteed by [Minn. Const. art. VII] by virtue of being released or excused from incarceration following a felony," holding that there was no error.At issue before the Supreme Court was (1) whether Minn. Const. art. VII, 1 requires that a person convicted of a felony be restored to the right to vote upon being released or excused from incarceration; and (2) whether Minn. Stat. 609.165 is contrary to the fundamental right to vote or to equal protection protections under the state Constitution. The Supreme Court held (1) under article VII, section 1, a person convicted of a felony cannot vote in Minnesota unless his or her right to vote is restored in accordance with an affirmative act or governmental mechanism restoring the person's right to vote; and (2) section 609.165 does not violate the fundamental right to vote, and there was insufficient evidence to prove that the statute violates the Minnesota Constitution's equal protection principle. View "Schroeder v. Simon" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for first-degree intentional homicide, first-degree sexual assault, and false imprisonment, holding that Defendant was not entitled to relief on his allegations of error.The Supreme Court accepted for review the issues of (1) whether Defendant's confession of sexual assault was corroborated by a significant fact; and (2) whether the cross-examination of Defendant's expert witness through the use of a Wisconsin Crime Lab report that was not entered into evidence and whose author did not testify violated Defendant's constitutional right to confrontation. The Supreme Court affirmed, holding (1) the State sufficiently corroborated Defendant's confession of sexual assault; and (2) the State improperly used the report's content for its truth during closing arguments, but the circuit court's error in permitting this argument was harmless beyond a reasonable doubt. View "State v. Thomas" on Justia Law