Justia Civil Rights Opinion Summaries

Samia, Hunter, and Stillwell were tried jointly for the murder-for-hire of Lee, a real estate broker. The prosecution argued that Hunter had hired Samia and Stillwell to pose as buyers and visit properties with Lee. The court admitted Stillwell’s confession that he was in the van in which Lee was killed, but he claimed that Samia had shot Lee. Since Stillwell would not be testifying and the full confession implicated Samia, the prosecution introduced the testimony of a DEA agent, who described Stillwell’s confession in a way that eliminated Samia’s name while avoiding obvious indications of redaction. Before that testimony and again before deliberations, the court instructed the jury that the testimony about Stillwell’s confession was admissible only as to Stillwell and should not be considered as to Samia or Hunter. All three were convicted. The Second Circuit held that the admission of Stillwell’s confession did not violate Samia’s Confrontation Clause rights.The Supreme Court affirmed. The Confrontation Clause was not violated by the admission of a non-testifying codefendant’s confession that did not directly inculpate the defendant and was subject to a proper limiting instruction. The Sixth Amendment’s Confrontation Clause forbids the introduction of out-of-court “testimonial” statements unless the witness is unavailable and the defendant has had the chance to cross-examine the witness previously but applies only to witnesses “against the accused.” Ordinarily, a witness at a joint trial is not considered a witness ‘against’ a defendant if the jury is instructed to consider that testimony only against a codefendant. This rule is consistent with the Clause’s text, historical practice, and the law’s reliance on limiting instructions in other contexts. To mandate severance whenever the prosecution wishes to introduce the confession of a non-testifying codefendant in a joint trial would be “too high” a price to pay. View "Samia v. United States" on Justia Law

Hansen promised hundreds of noncitizens a path to U.S. citizenship through “adult adoption,” earning nearly $2 million from his fraudulent scheme. The government charged Hansen under 8 U.S.C. 1324(a)(1)(A)(iv), which forbids “encourag[ing] or induc[ing] an alien to come to, enter, or reside in the United States, knowing or in reckless disregard of the fact that such [activity] is or will be in violation of law.” The Ninth Circuit found Clause (iv) unconstitutionally overbroad, in violation of the First Amendment.The Supreme Court reversed. Because 1324(a)(1)(A)(iv) forbids only the purposeful solicitation and facilitation of specific acts known to violate federal law, the clause is not unconstitutionally overbroad. A statute is facially invalid under the overbreadth doctrine if it “prohibits a substantial amount of protected speech” relative to its “plainly legitimate sweep.” Here, Congress used “encourage” and “induce” as terms of art referring to criminal solicitation and facilitation (capturing only a narrow band of speech) not as those terms are used in ordinary conversation. Criminal solicitation is the intentional encouragement of an unlawful act, and facilitation—i.e., aiding and abetting—is the provision of assistance to a wrongdoer with the intent to further an offense’s commission. Neither requires lending physical aid; both require an intent to bring about a particular unlawful act. The context of these words and statutory history indicate that Congress intended to refer to their well-established legal meanings. Section 1324(a)(1)(A)(iv) reaches no further than the purposeful solicitation and facilitation of specific acts known to violate federal law and does not “prohibi[t] a substantial amount of protected speech” relative to its “plainly legitimate sweep.” View "United States v. Hansen" on Justia Law

Amaya was convicted of conspiracy to travel in interstate commerce with intent to commit murder, 18 U.S.C. 1958; using a firearm during and in relation to a crime of violence causing death, sections 924(c), (j); and conspiracy to possess with intent to distribute five or more kilograms of cocaine, 21 U.S.C. 846. The district court imposed a sentence of life imprisonment for each count, to be served concurrently, and ordered Amaya to pay a statutorily required “special assessment” of $100 per count of conviction, section 3013(a)(2). The Sixth Circuit affirmed.Years later, Amaya filed a pro se 28 U.S.C. 2255 motion to vacate his conviction and sentence on count two, arguing that after the Supreme Court’s 2019 “Davis” holding, his murder conspiracy charge was no longer a valid predicate crime of violence for his 924(c) conviction. The district court invoked the “concurrent sentence doctrine” and denied relief. The Sixth Circuit affirmed; 28 U.S.C. 2255 limits its reach to “prisoner[s] in custody ... claiming the right to be released.” Only prisoners who claim a right to be released from custody may challenge their sentences. Even if his motion were successful, Amaya would still be in custody on the two unchallenged life sentences and the $100 special assessment attached to Amaya’s challenged conviction did not warrant section 2255 review. View "Amaya v. United States" on Justia Law

In 2017, Corridore was convicted of sexually abusing his granddaughter. He was sentenced to 19 months to 15 years in prison and became subject to mandatory lifetime electronic monitoring (LEM) via a permanent ankle bracelet and sex offender registration under Michigan’s Sex Offenders Registration Act (SORA). By the time he filed a habeas petition in federal district court, he had been released from prison and discharged from parole. The district court dismissed the petition, explaining that Corridore was no longer in custody and therefore could not meet the requirements of 28 U.S.C. 2254.The Sixth Circuit affirmed, rejecting Corridore’s arguments that he is subject to lifetime sex-offender registration and electronic monitoring—requirements that he says satisfy the custody requirement. The collateral consequences of a conviction are not sufficient to render an individual “in custody” for the purposes of a habeas attack. The issue is whether a petitioner’s movement is limited because of direct government control and therefore amounts to a severe restraint on liberty. The LEM and SORA requirements, even combined, do not qualify. View "Corridore v. Washington" on Justia Law

In 2000, Jones was convicted on two counts of unlawful possession of a firearm by a felon, 18 U.S.C. 922(g)(1). The Eighth Circuit affirmed Jones’ convictions and sentence. Jones’ subsequent 28 U.S.C. 2255 motion resulted in the vacatur of one of his concurrent sentences. Years later, the Supreme Court held (Rehaif) that a defendant’s knowledge of the status that disqualifies him from owning a firearm is an element of a 922(g) conviction, abrogating contrary Eighth Circuit precedent. Jones filed a 28 U.S.C. 2241 motion in the district of his imprisonment.The Eighth Circuit and the Supreme Court affirmed the dismissal of the petition. Section 2255(e) does not allow a prisoner asserting an intervening change in interpretation of a criminal statute to circumvent the Antiterrorism and Effective Death Penalty Act (AEDPA) restrictions on second or successive 2255 motions by filing a 2241 habeas petition.Under section 2255, federal prisoners can collaterally attack their sentences in the sentencing court, rather than by a 2241 habeas corpus petition in the district of confinement. The purpose of 2255 was to address problems created by district courts collaterally reviewing one another’s proceedings and by the concentration of federal prisoners in certain districts. Congress generally barred federal prisoners “authorized” to file a 2255 motion from filing a 2241 petition but preserved access to 2241 in cases where “the remedy by motion is inadequate or ineffective to test the legality" of the detention (Saving Clause). AEDPA subsequently barred second or successive 2255 motions unless based on either newly discovered evidence or “a new rule of constitutional law.” The inability of a prisoner with a statutory claim to satisfy section 2255(h) does not mean that the prisoner may bring a 2241 petition. Section 2255 is not necessarily “inadequate or ineffective” if the 2255 court fails to apply the correct substantive law. The Saving Clause is concerned with the adequacy or effectiveness of the remedial vehicle, not asserted errors of law. Due process does not guarantee the opportunity to have legal issues redetermined in successive collateral attacks. AEDPA embodies a balance between finality and error correction; there is nothing incongruous about a system in which the application of a since-rejected statutory interpretation cannot be remedied after final judgment. View "Jones v. Hendrix" on Justia Law

Plaintiff’s criminal history included a 1998 guilty plea to felony mail fraud. After maintaining an otherwise clean record for 24 years, he decided he wanted a gun. But 18 U.S.C. Section 922(g)(1) bars gun possession for anyone who, like Plaintiff, has a conviction for “a crime punishable by imprisonment for a term exceeding one year.” So he brought this suit under 18 U.S.C. Section 925A to challenge the constitutionality of Section 922(g)(1) as the law applied to him. Relying on pre-Bruen framework, The district court granted a motion from the government and dismissed the case.   The Seventh Circuit remanded to allow the district court to undertake the Bruen analysis. The court explained the parties may be unable altogether to find answers to certain questions, may find incomplete information in response to others, and perhaps in some instances, may identify substantial historical information pertinent to one or another dimension of the required inquiry. In the end, the district court will have to give the best answer available to whether the government has carried its burden of “affirmatively proving that its firearms regulation is part of the historical tradition that delimits the outer bounds of the right to keep and bear arms.” View "Patrick Atkinson v Merrick B. Garland" on Justia Law

The Supreme Court affirmed the judgments of the superior court convicting Defendant following a jury trial for larceny of an automobile and adjudicating him a probation violator, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued, among other things, that the trial court erred in denying his motion to suppress certain evidence collected as a result of a warrantless search of his real-time cell-site location information (CSLI). The Supreme Court disagreed and affirmed, holding (1) the acquisition of real-time CSLI qualifies as a search under the Fourth Amendment for which a warrant is required; (2) any error in the trial justice's determination that the exigent circumstances exception to the warrant requirement applied to the facts of this case was harmless; (3) the trial justice did not abuse his discretion in denying Defendant's motion to exclude certain testimony, and any error in allowing other testimony to be admitted at trial was harmless; and (4) Defendant waived his last argument for appeal. View "State v. Sinapi" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the decision of the circuit court to suppress the results of a search of Defendant, holding that the law enforcement officers had probable cause to arrest Defendant, and therefore, the underlying search was a lawful search incident to arrest.A police officer executed a traffic stop of Defendant for speeding and, during her initial contact with Defendant, "detected an odor of raw marijuana." The officer called for back-up, and two officers escorted Defendant out of the vehicle. The officers proceeded to search Defendant based on the odor of marijuana and found two baggies containing cocaine and fentanyl. Defendant filed a motion to suppress on the grounds that the State lacked probable cause to arrest and search him. The circuit court granted the motion, and the court of appeals affirmed. The Supreme Court reversed, holding that, under the totality of the circumstances, the officers had probable cause to arrest Defendant on the belief that he was committing or had committed a crime, and therefore, there was no Fourth Amendment violation. View "State v. Moore" on Justia Law

Believing that two men were about to engage in the armed robbery of a gas station, defendant police officers ("Defendants") approached the Plaintiff's’ vehicle with guns pointed and forcibly removed him. The district court denied the Defendants' claim to qualified immunity, and the Defendants appealed.On appeal, the Ninth Circuit reversed. First, it was not clearly established that the officers lacked an objectively reasonable belief that criminal activity was about to occur. Second, clearly established law did not prevent the officers from suspecting Plaintiff might be armed. Here, Defendants believed Plaintiff was about to commit and armed robbery, which is a crime typically involving the use of a weapon. Nothing gave the panel any reason to second guess the officer's "on the ground" determination.The court also rejected Plainitff's claim that it was a violation of a clearly established right to point a firearm at the Plaintiff and demand he exits his vehicle without first identifying themselves as law enforcement. View "DEJUAN HOPSON V. JACOB ALEXANDER, ET AL" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence of drugs and entering judgment on Defendant's plea of guilty to possession of cocaine with intent to distribute, holding that there was no error or abuse of discretion.Defendant was pulled over by a New Hampshire police officer, Stephen DiChiara, following a suspected drug buy. DiChiara was asked to conduct the stop by a United States Drug Enforcement Agency (DEA) task force officer, DiChiara stoped and seized the car Defendant was driving. A subsequent search of the car revealed uncovered roughly one kilogram of cocaine. Defendant moved to suppress evidence of the drugs, arguing that DiChiara could not act solely on the DEA officer's probable cause. The Supreme Court affirmed, holding that the directive given to DiChiara was sufficient to attribute the DEA officer's probable cause to DiChiara. View "United States v. Balser" on Justia Law