Justia Civil Rights Opinion Summaries

Harris went to the store, argued with a clerk, left the store, and entered the laundromat next door where his friend, Henderson, worked. Harris asserts that while he was between the buildings, the clerk came out, pointed a gun, and taunted him with racial slurs. Following Harris’s 911 call, four officers arrived. As shown on bodycams, they expressed disbelief in Harris’s report. The store clerk denied having a gun. The store had at least three surveillance cameras but the officers watched footage from only the front door, although Harris had reported that the incident occurred near the back door. Harris wanted to move forward with his report, believing the footage would corroborate his account. The officers indicated that the video revealed Harris had lied and arrested Harris. No officer took Henderson’s statement. Detective Busch reviewed the police report and passed it to the prosecutor for charging.Harris spent 18 days in jail before being released on bond. Weeks later, the state dropped Harris’s false felony report charge; the store clerks failed to appear. Harris sued the City of Saginaw, the officers, and Busch. The Sixth Circuit affirmed the denial of qualified immunity summary judgment to the officers, the grant of qualified immunity to Busch, and the dismissal of Harris’s failure-to-train and failure-to-supervise claims against the city. There is a genuine dispute of material fact regarding whether the officers arrested Harris without probable cause. View "Harris v. City of Saginaw, Michigan" on Justia Law

The Supreme Court reversed the opinion of the court of appeals reversing Defendant's convictions for driving after cancellation-inimical to public safety (DAC-IPS) based on the conclusion that Minn. Stat. 171.24, subd. 5 is unenforceable on private property, holding that the statute is enforceable on private property.Defendant, whose license was cancelled as inimical to public safety, was charged with DAC-IPS after a law enforcement officer observed him drive a motor vehicle down a private driveway. Defendant filed a motion to suppress and to dismiss the complaint for lack of probable cause. The district court denied the motions. The district court subsequently found Defendant guilty. The court of appeals reversed, ruling that the DAC-IPS requires a license only when a vehicle is operated on a street or highway. The Supreme Court reversed, holding (1) the DAC-IPS statute is enforceable in private property; and (2) the district court properly denied Defendant's motions to suppress and dismiss, resulting in restatement of Defendant's convictions. View "State v. Velisek" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the petition for a writ of prohibition filed by the State prohibiting the district court from enforcing a "taint team" order, holding that the district court erred in concluding that the Sixth Amendment right to counsel was implicated in this case.Appellant, a juvenile at the time of his offense, was convicted of first-degree premeditated murder and sentenced to two consecutive sentences of life without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, Appellant was granted resentencing. At issue during the hearing was copies of recorded calls made by Appellant while he was incarcerated. The district court ordered the State to use a taint team to review the recorded calls for attorney-client communications on the ground that Appellant's the constitutional right to counsel was implicated. The court of appeals granted the State's petition for a writ prohibiting the court from enforcing the taint team order. The Supreme Court affirmed, holding that relief was not warranted because (1) the Sixth Amendment was not implicated here; and (2) the State would be injured and without any adequate remedy to correct the unauthorized action of the court. View "State v. Flowers" on Justia Law

Moss purchased cocaine from a DEA informant and was charged with possession with intent to deliver 1,000 or more grams of cocaine and possession of a firearm during the commission of a felony. Moss’s first attorney moved for an entrapment hearing. Steingold then began representing Moss. At the entrapment hearing, 10 days later, Steingold attested to minimal pre-trial preparation. Moss was the only witness he presented. Steingold requested a continuance to contact witnesses he learned about during Moss’s direct and cross-examination. The court permitted Steingold to contact one witness but denied a continuance. The prosecution presented five witnesses and multiple exhibits. The court denied Moss’s motion to dismiss based on entrapment.At trial, Steingold waived his opening argument, presented no witnesses, and stipulated to the admission of the transcript from the entrapment hearing as substantive evidence. For one of the government’s two witnesses, Steingold did not object during his testimony or conduct any cross-examination. Steingold waived his closing argument. On appeal, Moss unsuccessfully argued that Steingold provided constitutionally ineffective assistance by waiving Moss’s right to a jury trial and stipulating to the admission of the evidence from the entrapment hearing.The Sixth Circuit reversed the district court’s order of habeas relief. The state court’s denial of Moss’s ineffective assistance claims under Strickland was not contrary to nor an unreasonable application of clearly established federal law. View "Moss v. Miniard" on Justia Law

Freeman was convicted, along with Miller and Collier, of second-degree murder. The jury had heard the confession of Miller, a non-testifying codefendant, with redactions that replaced the names of Collier and Freeman, with the substitutes “the first guy” and “the second guy.” The court gave a limiting instruction that the statement was to be considered only as to Miller, not as to the other defendants, in order to protect Freeman’s Sixth Amendment right to confront a witness against him. Freeman’s objection was overruled and rejected on appeal in state court.The district court concluded that a “Bruton” violation occurred and that the violation was not harmless, and granted Freeman habeas relief. The Third Circuit reversed. A Bruton violation occurred. When a statement is redacted— whether by substituting the codefendant’s name with a neutral pronoun, a blank space, or a symbol—in such a manner that “[a] juror … need only lift his eyes to [the codefendant], sitting at counsel table” to understand who is being implicated, the introduction of that statement is a Sixth Amendment violation. However, there was ample other evidence against Freeman, and the violative statement was largely duplicative of other evidence; there is no “grave doubt about whether [the error] had substantial and injurious effect or influence in determining the jury’s verdict.” The error was harmless. View "Freeman v. Superintendent Fayette SCI" on Justia Law

Officer Sandoval encountered inmate Hacker, who is almost totally deaf, and ordered him to return to his bed. Hacker, unable to hear, did not comply. Sandoval shoved Hacker, who awoke handcuffed to a bed. He filed an administrative grievance and received notice that it had been referred to the Office of Professional Responsibility and the Divisional Superintendent, with a form allowing Hacker to appeal within 15 days. Neither document gave any timeline for OPR’s disposition of Hacker’s grievance. More than three months later, an OPR investigator concluded he could not substantiate Hacker’s claims; his superior officer signed the memorandum to approve the closure of the referral. The document does not state that the grievance process as a whole had ended, nor mention an appeals process. Hacker apparently received no communication from the Superintendent.Hacker had already filed suit. The district court granted the defendants summary judgment, citing failure to exhaust claims under the Prison Litigation Reform Act and to comply with other PLRA requirements, 42 U.S.C. 1997e(a). The Seventh Circuit vacated. The jail’s grievance procedures became unavailable to Hacker after the jail involved OPR; various communications forced Hacker to “go beyond the established system and guess” what he needed to do. One of Hacker’s claims under the ADA and Rehabilitation Act failed because his grievance did not give fair notice that he was requesting a personal listening device; his other claim, concerning missing medications, was not tied to a physical injury as required to recover damages under the PLRA. View "Hacker v. Cook County, Illinois" on Justia Law

The Court of Appeals reversed the decision of the appellate division affirming the judgment of the trial court convicting Defendant of rape in the first degree, holding that Defendant's constitutional right to prompt prosecution under the due process clause of the New York Constitution was violated in this case.The complainant reported to the police that she had been raped a few hours earlier by Defendant, whom she identified. The complainant submitted to a sexual assault examination, but Defendant, who was questioned by the police the same day, but refused to provide a DNA sample. Years later, a sample of Defendant's DNA sample was obtained via a buccal swab, which disproved Defendant's claim that he and the complainant had not had sex. More than four years after the complainant reported the assault, the People filed an indictment against Defendant. Defendant moved to dismiss the indictment on the grounds that the excessive preindictment delay violated his due process right to prompt prosecution. County Court denied the motion, and Defendant was convicted. The appellate division affirmed. The Court of Appeals reversed and dismissed the indictment, holding that the delay of the police and prosecutors violated Defendant's constitutional right to a prompt prosecution. View "People v. Regan" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Appellant of first-degree murder and other crimes and sentencing him to an aggregate term of two life sentences plus 835 years' imprisonment, holding that the State failed to demonstrate that Appellant was brought to trial within the twelve-month period required by Ark. R. Crim. P. 28.1(b).At issue on appeal was whether Appellant's constitutional right to a speedy trial, as embodied in Ark. R. Crim. P. 28.1, was violated when the State failed to bring him to trial within twelve months of the date of his arrest. The Supreme Court concluded that Appellant's right was indeed violated because he was held for a total of 405 days during which the speedy trial was not tolled, a total that exceeded the requisite 365-day period. View "Parker v. State" on Justia Law

In this criminal case, the Supreme Court held that the district court and intermediate court of appeals (ICA) erred in ruling that Defendant was not entitled to the requisite Miranda warnings when she was questioned by law enforcement officers, holding that "if a person is unable to leave a place of interrogation due to circumstances incident to medical treatment, determining whether the person is 'in custody' under a totality of circumstances requires an inquiry into whether the person was at liberty to terminate the interrogation and cause the officer to leave."State v. Ketchum, 34 P.3d 1006 (Haw. 2001), articulated that a person is "in custody" for constitutional purposes if the totality of the circumstances reflects that the point of arrest has arrived because probable cause to arrest has developed. State v. Sagapolutele-Silva, 511 P.3d 782 (Haw. 2002), overruled Ketchum's bright-line rule and said that the existence of probable cause was only a factor in determining whether someone was entitled to Miranda warnings under the totality of the circumstances. Here, the Supreme Court expressly overruled Sagapolutele-Silva's abrogation of the Ketchum rule and held that the Ketchum rule remained in effect. The Court then held that, based on the totality of the circumstances, Defendant was in custody well before probable cause developed, and therefore, the lower courts erred by holding that Miranda warnings were not required. View "State v. Hewitt" on Justia Law

The Supreme Court affirmed Defendants' convictions for attempted murder in the second degree, kidnapping, and other crimes but remanded the case for a new extended term sentencing hearing and resentencing, holding that that extended term sentencing instructions and special interrogatories were prejudicially erroneous and misleading.The jury selection process in the underlying proceedings identified prospective jurors by a number, not name. On appeal, Defendants argued that the circuit court's jury selection method violated their constitutional right to a presumption of innocence and an impartial jury. The Supreme Court disagreed and affirmed the convictions, holding that there was no constitutional violation. The Court, however, held that Defendants' life without the possibility of parole sentences for attempted murder could stand because the circuit court's extended term sentencing jury instructions and special interrogatories were prejudicially erroneous and misleading. View "State v. Lafoga" on Justia Law