Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's sentence of death, following resentencing, in connection with his convictions of first degree murder, two counts of forcible rape, and enhancements for personal use of a firearm, holding that any error in the resentencing was harmless beyond a reasonable doubt.When Defendant was convicted in 2000 the jury found true special circumstances for committing murder during a kidnapping and intentional infliction of torture and set the penalty at death. The Supreme Court upheld the guilt judgment but reversed the penalty verdict on the grounds that the trial court erroneously dismissed a juror during penalty phase deliberations. After a retrial, Defendant was again sentenced to death. The Supreme Court affirmed, holding (1) double jeopardy principles did not bar Defendant's penalty retrial; (2) the penalty retrial did not violate due process; (3) Defendant's challenges to the constitutionality of California's death penalty statute were unavailing; and (4) any error brought about by retroactive application of Senate Bill 1437 was harmless beyond a reasonable doubt. View "People v. Wilson" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court denying Defendant's motion to suppress the seizure of his cell phone and its refusal to suppress evidence of child pornography, holding that the warrant authorizing the search of Defendant's electronic devices containing the child-pornography evidence was unsupported by probable cause.On appeal, Defendant argued that the police exceeded the scope of the first warrant by seizing his phone from his wife and that the application for the second warrant did not contain sufficient detail such that a neutral magistrate could determine whether there was probable cause that the alleged objects of the search were pornographic. The First Circuit remanded the case for further proceedings, holding (1) there was no violation of Defendant's constitutional rights in the seizure of his phone under the first warrant; (2) fatal deficiencies in the second affidavit supporting the second warrant resulted in the second search warrant being issued without the required showing of probable cause; and (3) the good-faith exception did not apply, requiring suppression of the evidence. View "United States v. Sheehan" on Justia Law

Two sisters accused Bell, a family friend, of sexually assaulting them. There was no physical evidence. Bell did not testify. Bell’s attorney sought to undermine the sisters’ credibility, suggesting that the girls had motives to lie, highlighting the younger sister’s admission that she had been drunk and had lied to police about her inebriation, and noting that the older sister’s account had changed. In closing arguments, the prosecutor stated that jurors who voted to acquit would “have to believe” that the sisters were lying and that if someone lies, “they’re going to have a reason.” The judge instructed the jury that the state had the burden to prove guilt beyond a reasonable doubt; the attorneys’ arguments were not evidence; and the jury should disregard any arguments suggesting facts not in evidence.The jury convicted Bell. Because of his prior sexual-assault convictions, the court sentenced him to life in prison without parole. On appeal, Wisconsin courts rejected Bell’s argument that the prosecutor’s comments during closing arguments shifted the burden of proof. The Seventh Circuit affirmed the denial of Bell’s federal habeas corpus petition, 28 U.S.C. 2254(d), stating that under de novo review, "the prosecutor’s comments might give us significant pause,” but under the Antiterrorism and Effective Death Penalty Act’s deferential standard, the Supreme Court of Wisconsin’s decision was neither contrary to nor an unreasonable application of clearly established federal law as determined by the U.S. Supreme Court. View "Bell v. Hepp" on Justia Law

The Supreme Court affirmed the judgments of the district courts denying Appellants' separate motions to suppress, holding that the Wyoming Constitution does not require that an exterior canine sniff of a vehicle be supported by probable cause.Appellants in these cases were both subjected to an extended investigative detention, and both Appellants were arrested after a canine sniff of their vehicles. On appeal, Appellants argued that the canine sniffs had to be supported by probable cause under Wyo. Const. art. I, 4. The Supreme Court disagreed, holding (1) the Wyoming Constitution does not require probable cause for an exterior canine sniff of a vehicle; and (2) Appellants were not entitled to relief on their remaining allegations of error. View "Tarzia v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that a trial court can properly consider conduct related to a charge of which a criminal defendant was acquitted when the court sentences the defendant on other charges of which the defendant was convicted but that courts should be extremely cautious in relying on such conduct in sentencing.Defendant was convicted and sentenced for robbery in the first degree and other offenses. Defendant later filed his motion to correct an illegal sentence arguing that the sentencing court violated his constitutional rights by considering conduct underlying a charge for which he was acquitted - assault. The trial court denied the motion. The Supreme Court affirmed, holding (1) a sentencing judge may consider a broad range of conduct so long as the sentence falls within the statutory range and the conduct does not serve as grounds to enhance the sentence; and (2) the sentencing court in this case did not violate Defendant's right to trial by jury under the Sixth Amendment or his right to due process under the Fourteenth Amendment by considering the conduct underlying his assault charge. View "State v. Langston" on Justia Law

Officer Layne pulled VanPelt over for driving a car with an illegal window tint and called for backup. When Officer Bennett responded, Layne informed him that “the plate doesn’t come back to the car” and the “car smells like weed.” While patting VanPelt down, Layne found several baggies of marijuana and one baggie of crack cocaine. With VanPelt in handcuffs, Layne led him toward the police car. VanPelt took off running. Four seconds later, Layne tackled VanPelt to the ground, then stood and attempted to pull VanPelt to his feet, briefly grabbing VanPelt’s hair. VanPelt replied that he could not stand because his hip was broken. Layne released his grip. VanPelt fell back to the ground.VanPelt sued Layne for using excessive force and Detroit for failing to adequately train and supervise Layne, 42 U.S.C. 1983. The Sixth Circuit affirmed summary judgment in favor of the defendants, citing qualified immunity. Layne’s tackle and subsequent attempt to lift VanPelt did not violate the Fourth Amendment. Layne’s use of force throughout the encounter was objectively reasonable under the circumstances, even assuming Layne could have stopped VanPelt using a less severe technique. When Layne attempted to lift VanPelt, a reasonable officer would not have known that VanPelt was injured. The record and video did not establish any indication of excessive force nor evidence that Layne had “evil intentions.” View "VanPelt v. City of Detroit" on Justia Law

In 1995, Range pleaded guilty to making false statements about his income to obtain $2,458 of food stamp assistance. His conviction was classified as a misdemeanor punishable by up to five years’ imprisonment. Range was sentenced to three years’ probation. Three years later, Range attempted to purchase a firearm but was rejected by the instant background check system. Range’s wife subsequently bought him a deer-hunting rifle. Years later Range learned that he was barred from purchasing and possessing firearms because of his welfare fraud conviction. He sold his rifle to a firearms dealer and sought a declaratory judgment that 18 U.S.C. 922(g) violated the Second Amendment as applied to him. The section prohibits firearm ownership by any person who has been convicted of a crime punishable by imprisonment for a term exceeding one year—the federal definition of a felony.In 2022, the Third Circuit affirmed the rejection of the suit, reasoning that “the people” constitutionally entitled to bear arms are “law-abiding, responsible citizens,” and that even if Range fell within “the people,” the government demonstrated that its prohibition is consistent with historical tradition.On rehearing, en banc, the Third Circuit reversed. Despite his false statement conviction, Range remains among “the people” protected by the Second Amendment. The government did not carry its burden of showing that the Nation’s history and tradition of firearm regulation support disarming Range. View "Range v. Attorney General United States" on Justia Law

The Supreme Court held that felony resisting arrest constitutes a single unified offense, thus affirming the judgment of the trial court convicting Defendant of felony resisting arrest and other offenses and sentencing him accordingly.On appeal, Defendant argued that the trial court's instruction regarding the elements of resisting arrest under Ariz. Rev. Stat. 13-2508(A)(2) improperly conflated subsections (A)(1) and (A)(2). The court of appeals rejected the argument and affirmed. The Supreme Court affirmed, holding (1) section 13-2508 is ambiguous because it may be reasonably read as setting forth a single unified offense or distinct crimes, and this Court concludes that subsections (A)(1) and (A)(2) are alternative means of committing one offense; (2) this Court's interpretation of section 13-2508 comports with the Sixth Amendment; and (3) because the two subsections set forth a single unified offense the jury instruction regarding this crime did not constitute error. View "State v. Luviano" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the circuit court's denial of Defendant's petition for postconviction relief, holding that any error during the underlying proceedings that may have violated Defendant's right to confrontation was harmless.Defendant was convicted, after a jury trial, of delivering more than fifty grams of methamphetamine. In his postconviction petition, Defendant argued that the admission of certain testimony was hearsay, and therefore, his right to confrontation under the Sixth Amendment was violated. The circuit court denied relief. The court of appeals affirmed, concluding that if any error occurred it was harmless. The Supreme Court affirmed, holding that, assuming without deciding that Defendant's confrontation right was violated, the error was harmless. View "State v. Barnes" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on theories of both deliberate premeditation and extreme atrocity or cruelty, holding that there was no error in the underlying proceedings or in the verdict.On appeal, Defendant argued, among other things, that the district court erred in denying his motion to suppress the evidence recovered pursuant to a search warrant following a police trooper's examination of Defendant's vehicle, which was visibly parked in the driveway leading up to his house. The Supreme Judicial Court affirmed, holding (1) because Defendant's vehicle was not parked within the curtilage of his home the trooper's observations of the vehicle did not constitute a search for constitutional purposes; and (2) there was no reason for this Court to exercise its authority under Mass. Gen. Laws ch. 278, 33E to reduce the verdict or order a new trial. View "Commonwealth v. Wittey" on Justia Law