Justia Civil Rights Opinion Summaries

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

The Supreme Court approved the decision of the court of appeal affirming the trial court's denial of Defendant's motion to suppress eyewitness identifications resulting from an out-of-court police procedure, holding that the proper standard of review is abuse of discretion review and that the court of appeal correctly analyzed the merits under that standard.In denying Defendant's motion to suppress, the court of appeal applied the abuse of discretion standard of review to the trial court's ruling on the out-of-court identification by the eyewitness. On appeal, the court of appeal affirmed "[d]ue to the abuse of discretion standard of review." The Supreme Court approved the decision below, holding (1) abuse of discretion review is the proper standard; and (2) the trial court did not abuse its discretion in admitting the out-of-court identification. View "Alahad v. State" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder in the first degree on the theory of deliberate premeditation but vacated his conviction of murder in the first degree on a theory of felony-murder, holding that the felony-murder conviction was improper.Defendant was convicted of murder in the first degree on theories of deliberate premeditation and felony-murder, with aggravated kidnapping as the predicate felony. In this appeal, consolidated with the appeal of his motions for a new trial and for reconsideration, Defendant argued, and the Commonwealth conceded, that the conviction of murder in the first degree on a theory of felony-murder was improper because the predicate felony of aggravated kidnapping did not exist at the time of the killing. The Supreme Court vacated Defendant's felony-murder conviction and otherwise affirmed, holding (1) Defendant's conviction of felony-murder lacked sufficient evidence to support it; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "Commonwealth v. Samia" on Justia Law

In this criminal case, the Supreme Court held that the Due Process Clause of the United States Constitution does not require a court to pre-screen eyewitness identification testimony before the eyewitness can be permitted to make an identification of the defendant for the first time in open court.Defendant was indicted on four counts of robbery and four counts of use of a firearm in the commission of a felony for robbing a bank. After a jury trial, Defendant was convicted and sentenced to forty-five years' imprisonment. The Supreme Court affirmed, holding (1) due process did not compel the circuit court to pre-screen the identification at issue when that identification was made for the first time in court; (2) the circuit court did not abuse its discretion in ruling that Defendant's identification was more probative than prejudicial; and (3) Defendant was properly convicted of a second or subsequent offense of use of a firearm in the commission of a felony. View "Walker v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and reversed the judgment of the district court convicting Defendant of aggravated burglary and obstructing a police officer and sentencing him to forty years for aggravated burglary and six months for obstructing a peace officer, holding that the case must be remanded for resentencing.Specifically, the Supreme Court held (1) Defendant's constitutional right to a speedy trial was not violated; (2) Defendant's claim of instructional error not warrant plain error review because he failed to show how he was prejudiced; (3) Defendant's ineffective assistance of counsel claim must fail because Defendant he to show any prejudice; and (4) Defendant was entitled to resentencing because the district court relied on incorrect information when it imposed the sentence. View "State v. Kirn" on Justia Law

Michigan’s 1994 Sex Offender Registration Act (SORA) (amended in 2006 and 2011) imposed registration requirements, restrictions on living and working in a school zone, and reporting requirements. Michigan retroactively imposed these obligations, including those contained in the amendments, on offenders convicted before 2006 and 2011. In another suit, the Sixth Circuit held, in 2016, that the retroactive application of SORA amendments violated the Ex Post Facto Clause. While an interim order was in effect, in another suit, Michigan passed a fourth version of SORA, effective on March 24, 2021, removing or modifying provisions that had been declared unconstitutional.In 2021, five Michigan sex offenders filed suit, seeking damages under 42 U.S.C. 1983. They alleged that the Michigan State Police enforced unconstitutional provisions of SORA from 2006 onwards, including after the previous cases were decided. They alleged that state officials, whom they purported to sue “in their individual capacities,” knew that the invalidated provisions were unconstitutional, but failed to stop their subordinates from enforcing them, noting the governors’ duty under the Michigan Constitution to ensure the faithful execution of federal and state law. The district court dismissed the complaint on various grounds, including sovereign immunity. The Sixth Circuit affirmed on different grounds. The plaintiffs fail to state a claim of supervisory liability. They do not plausibly allege that the defendants authorized, approved, or knowingly acquiesced in any unconstitutional conduct. View "Does 1-5 v. Whitmer" on Justia Law

The Supreme Judicial Court affirmed the judgment of the county court denying the Commonwealth's petition filed under Mass. Gen. Laws ch. 211, 3 seeking relief from a superior court judge's denial of the Commonwealth's motion to disqualify Rosemary Scapicchio, Defendant's appellate counsel, on the ground that she had a conflict of interest, holding that the single justice did not err or abuse his discretion in denying the motion.Defendant was convicted of murder in the first degree. Later, represented by Scapicchio, Defendant filed a motion for a new trial alleging ineffective of counsel. Thereafter, Scapicchio represented Michael Barros at a hearing in an unrelated criminal case. The Commonwealth moved to disqualify Scapicchio on the grounds that her representation of both Defendant and Barros gave rise to a conflict of interest. The superior court denied the motion. The Commonwealth then filed the petition at issue. The single justice denied relief without reaching its merits. The Supreme Judicial Court affirmed, holding that the single justice neither erred nor abused his discretion by denying the petition. View "Commonwealth v. Monteiro" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's petition for postconviction relief from his conviction for first-degree felony murder under an aiding and abetting theory of criminal liability, holding that Appellant's arguments did not entitle him to relief.In his petition for postconviction relief, Appellant claimed in part that he received ineffective assistance of trial counsel because counsel did not communicate an Alford plea deal to him. The district court denied the petition, concluding that Appellant failed to prove his claim by a preponderance of the evidence. The Supreme Court affirmed, holding that the evidence established beyond a reasonable doubt that Appellant committed first-degree felony murder under an aiding and abetting theory of criminal liability. View "State v. King" on Justia Law