Justia Civil Rights Opinion Summaries

The Supreme Court reversed the decision of the court of criminal appeals reversing Defendant's convictions and reinstated the judgments of the trial court, holding that the intermediate court erred when it stated that an involuntary confession claim is "inextricably linked" to a Miranda waiver claim such that the two inquiries can be considered together.Defendant, a juvenile at the time of the offenses, was convicted of aggravated robbery, premeditated first-degree murder, two counts of first-degree felony murder, and theft of property valued at over $10,000. Defendant was sentenced to life in prison for the murder conviction. On appeal, the court of criminal appeals reversed the denial of Defendant's motion to suppress pretrial statement to detectives, concluding that the statement was not voluntary. The Supreme Court reversed, holding (1) Defendant's overall statement was voluntary, and his Miranda waiver was both knowing and voluntary; and (2) the evidence presented by the State was sufficient to support Defendant's conviction for premeditated first-degree murder. View "State v. McKinney" on Justia Law

The Supreme Court reversed the order of the circuit court suppressing statements made by Defendant during the execution of a search warrant, holding that the circuit court erred in concluding that Defendant's statements to a law enforcement officer during the execution of a search warrant were involuntarily made.Defendant was indicted for one count each of rape in the third degree and sexual contact with a person incapable of consenting. Defendant filed a motion to suppress the statements he made to law enforcement, arguing that his statements were obtained in violation of Miranda v. Arizona, 384 U.S. 436 (1996). The circuit court granted the motion, concluding that Defendant's statements were involuntarily made under the Due Process Clause. The Supreme Court reversed, holding that, based on a review of the totality of the circumstances, the circuit court erred in concluding that Defendant's statements to law enforcement were involuntarily made. View "State v. Ghebre" on Justia Law

Howard was charged as a felon in possession of a weapon. Before his trial, the government struck the only three Black jurors on the 39-person venire panel. The judge had admonished the jurors that they could not use the internet for any purpose related to or surrounding the case and asked the jurors to “[r]aise your number if you don’t use the internet.” Jurors 9, 13, and 24 each raised their numbers. Jurors 9 and 24 were two of the three Blacks. The prosecutor struck each of them, explaining: “I do not believe people when they say they don’t use the Internet.” In response to the defendant’s subsequent Batson challenge, the court applied the three steps of the Batson inquiry. At the third step—that the defendant established purposeful discrimination by the government—the court summarized Howard’s counsel’s argument, stating: “Your sole justification and your persuasiveness is that the government attorney, who does happen to be African-American, has struck every single African-American on the panel.”The Seventh Circuit affirmed Howard’s conviction, rejecting arguments that the district court erred by injecting the prosecutor’s race into the Batson inquiry, improperly evaluating the peremptory strike, and failing to make required demeanor findings. The prosecutor’s theory was not so “implausible or fantastic” as to require a conclusion that the justification was “pretext[] for purposeful discrimination.” View "United States v. Howard" on Justia Law

Plaintiff Jeffrey Helvie appealed a district court’s decision to grant Defendant Chad Jenkins, an Adams County, Colorado, deputy sheriff, qualified immunity on Helvie’s claim that the deputy used excessive force against Helvie during a traffic stop. On August 23, 2018, at approximately 11:45 p.m., Deputy Jenkins observed Plaintiff make several traffic infractions while driving a Nissan pickup truck. The vehicle window was partially down when Deputy Jenkins approached. According to Deputy Jenkins, he could smell the strong odor of burnt marijuana coming out of the window, though Plaintiff disputed having smoked marijuana that day. Plaintiff handed his driver’s license and registration to Deputy Jenkins, but had difficulty providing his proof of insurance (which was on his phone) due to either poor cellular reception or Plaintiff's inability to correctly enter a passcode. According to Deputy Jenkins, he believed that Plaintiff was operating a vehicle while under the influence and wanted to conduct further investigation. When Plaintiff did not get out of the vehicle, Deputy Jenkins grabbed Plaintiff's arm and ordered him out of the vehicle. According to Deputy Jenkins, Plaintiff pulled away. Deputy Jenkins then grabbed Plaintiff's leg and pulled him out of the vehicle, causing Plaintiff to land on his back. As Deputy Jenkins was pulling Plaintiff out of the vehicle, he observed a handgun in the pocket of the driver’s side door. After review of Plaintiff's complaint, the Tenth Circuit determined he failed to show that Deputy Jenkins violated his constitutional rights and, necessarily flowing from that holding, Plaintiff failed to show that his constitutional rights allegedly violated were clearly established. View "Helvie v. Jenkins" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony possession of methamphetamine, holding that the district court did not err in denying Defendant's multiple motions to suppress challenging the validity of the warrant and supporting affidavit police obtained to search his residence.On appeal, Defendant argued that Officer Andy Lucas of the Gillette Police Department knowingly, or with reckless disregard, omitted facts from the search warrant affidavit and that the warrant was not sufficiently particular to remain valid under the Fourth Amendment. The Supreme Court disagreed, holding (1) the district court did not clearly err in finding Officer Lucas had not recklessly omitted information from the affidavit; and (2) the search warrant contained sufficient information to allow Officer Lucas to identify the place to be searched with reasonable effort. View "Herdt v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of fifth-degree possession of a controlled substance, holding that the search of Defendant's purse was constitutional under the automobile exception to the Fourth Amendment's search warrant requirement.Defendant, a passenger in a vehicle searched by law enforcement without a warrant, removed her purse from the car as she got out, but an officer directed her to leave the purse on the car. The officer's ensuing search of the purse revealed a controlled substance. Defendant filed a motion to suppress, arguing that the automobile exception did not apply because the purse was an extension of her person, not a container within the car. The district court denied the motion. The court of appeals affirmed the denial, concluding that the warrantless search of Defendant's purse was constitutional. The Supreme Court affirmed, holding that (1) the purse was a container that was inside the car at the time probable cause arose; and (2) because the purse could have contained marijuana, the officer was permitted to search it under the automobile exception. View "State v. Barrow" on Justia Law

Former inmate Morgan, a devout Muslim, sued Michigan prison officials for allegedly violating his free exercise rights by failing to provide him with meals consistent with his religion after he was transferred to a prison that lacked the capacity to produce compliant meals. Morgan filed a grievance with the prison five days after he arrived. The district court granted the defendants summary judgment based on Morgan’s failure to exhaust administrative remedies under the Prison Litigation Reform Act of 1995, 42 U.S.C. 1997e, which requires prisoners to follow a prison’s grievance procedures before challenging prison conditions in court. The district court held that Morgan’s grievance only covered the failure to provide meals up until the date of the grievance, so Morgan should have filed further grievances as to the alleged free exercise violation.The Sixth Circuit reversed. Morgan already put the prison officials on notice of unconstitutional conduct; requiring repeat grievances for the same course of conduct would exceed the requirements of the Act. At issue here is Morgan’s free exercise claim, which he raised by prison grievance. The facts Morgan has pled along with this claim, including staff laughing at him, are sufficiently ancillary to require no further exhaustion of his claim. View "Morgan v. Trierweiler" on Justia Law

Nucera was charged with committing a hate crime, depriving another of his civil rights, and making false statements to the FBI, arising from actions he took as a police officer arresting Stroye. His jury engaged in heated deliberations with racial tensions playing a major role. Credibility determinations were crucial, and jurors were deeply divided over whom and what to believe.The Third Circuit rejected Nucera’s claims of jury misconduct. Nucera offers only post-verdict affidavits from jurors who say they experienced racial vitriol, intimidation, and other misconduct that occurred during the jury deliberations. When parties challenge a verdict, Federal Rule of Evidence 606(b) bars a court from considering a juror’s statement or affidavit unless it satisfies either an exception in the Rule or a constitutional exception created by the Supreme Court (Peña-Rodriguez, 2017), for evidence of racial bias. The latter exception is narrow and specific: it requires a clear statement that a juror voted for a conviction based on racial animus toward, or stereotypes about, the defendant. None of Nucera’s evidence satisfies the Rule 606(b) exceptions nor does it fit the Peña-Rodriguez exception. The court also affirmed a ruling that limited Nucera’s use of the victim’s out-of-court statement and the court’s jury instructions about unanimity. The court vacated Nucera’s sentence; the district court erred in applying the Sentencing Guidelines. View "United States v. Nucera" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant for possession with intent to distribute marijuana and failure to affix a tax stamp, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held that the district court (1) did not err by denying Defendant's motion to suppress evidence of marijuana found when law enforcement conducted a warrantless search of a duffel bag and suitcase on a passenger trial; (2) did not err in failing to suppress certain testimony at trial; (3) did not abuse its discretion in denying Defendant's motion for a mistrial; and (4) did not abuse its wide discretion in sentencing Defendant to four to six years of imprisonment for possession with intent to distribute marijuana. View "State v. Vaughn" on Justia Law

Ingram contends that, while confined in the Terre Haute Penitentiary, he was attacked and beaten by guards, after which the medical staff denied him necessary care. A magistrate concluded that Ingram failed to exhaust his administrative remedies, as required by 42 U.S.C.1997e(a), and granted the defendants summary judgment.The Seventh Circuit affirmed in part. Ingram filed three substantive grievances. Two he did not pursue to a conclusion; one. asserting that members of the staff failed to protect him from harm, was rejected because it lacked required attachments and Ingram did not resubmit a grievance or appeal. A second grievance asserted that staff retaliated against him by withholding necessary medical care. The prison rejected this grievance because Ingram had not attempted an informal resolution. An inmate cannot short-circuit the grievance process by filing in court while that process is ongoing.The court remanded in part. Ingram alleged that he never got a written decision on his remaining substantive grievance, complaining about the attack itself. If an appeal was blocked by the need to attach a document that the prisoner did not have, then that appeal is not “available” to the prisoner, and the statute allows the prisoner to turn to court. The district court should have held a hearing and taken testimony on subjects such as whether the Warden refused to provide the statement to Ingram or whether there was just a bureaucratic delay in handing it over. View "Ingram v. Watson" on Justia Law