Justia Civil Rights Opinion Summaries

A criminal complaint was filed against Appellant. On May 20, 2009, a certificate of mental disease or defect and dangerousness issued pursuant to 18 U.S.C. Section 4246. Appellant’s mental condition improved with treatment. The district court ordered his conditional discharge. Appellant returned home and lived with his mother after conditional discharge. The district court revoked the term and recommitted him. This appeal presents two consequential questions. Both relate to the continued involuntary commitment of those afflicted with a mental illness. A commitment wrongly perpetuated is an unwarranted restraint of liberty; a commitment errantly discontinued poses a danger to the committee and the public.   The Fourth Circuit vacated the district court’s order and remanded for further proceedings. The court explained that the record is unclear whether the district court’s findings were made by a preponderance of the evidence. It also appears from the record that the district court collapsed both inquiries of Section 4246(f) into a single question, focusing only on whether Appellant violated the conditions of his release and not explaining why “in light of” those violations his continued release created a substantial risk to other persons or property. Additionally, the record would benefit from further development respecting the violations alleged and the available, recent records from the facility. Further, the court wrote that the government should take note of its evidentiary burden, develop evidence on the point, and provide the district court a sound basis for making reasoned findings on the matter of dangerousness for that particular alleged violation. View "US v. Christopher Perkins" on Justia Law

The Supreme Court affirmed the order of the circuit court summarily denying Appellant's sixth successive motion for post-conviction relief under Fla. R. Crim. P. 3.851, holding that the circuit court did not err in summarily denying the motion.Appellant was convicted of first-degree felony murder and armed robbery and was sentenced to death. Decades later, Appellant filed the sixth successive post-conviction motion at issue on appeal, arguing that two pieces of allegedly newly discovered evidence required extending the rationale in Roper v. Simmons, 543 U.S. 551 (2005), for barring the execution of defendants under the age of eighteen at the time of the offense to bar the execution of defendants under the age of twenty-one. The circuit court summarily denied relief. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant's claim was untimely and that his request to extend Roper was meritless. View "Melton v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Trumbell Correctional Institution, where Appellant was serving a forty-year prison sentence, holding that there was no error.Appellant was serving his prison sentence for nine convictions for felonious assault, in violation of Ohio Rev. Code 2903.11(B)(3). Appellant filed a petition for a writ of habeas corpus arguing, inter alia, that section 2903.11(B)(3) violates the Equal Protection Clauses of the Ohio and United States Constitution. The court of appeals dismissed the petition for failure to state a valid claim for habeas relief. The Supreme Court affirmed, holding that habeas corpus did not lie for Appellant's nonjurisdictional claims. View "Christian v. Davis" on Justia Law

Courtney was sentenced to three years in state prison followed by one year of supervised release for violating an earlier term of parole by failing to register as a sex offender. Courtney’s supervised release was revoked before he left prison. The stated reason was not that he had acted wrongly but that he had no arrangements for a place to live that state officials deemed suitable. Courtney spent his year of supervised release in prison.Courtney brought suit under 42 U.S.C. 1983, alleging that the defendants failed to investigate his proposed living arrangements and ignored his grievances and that his release was revoked without evidence that he violated any terms of release and without adequate procedural protections. The district court dismissed Courtney’s claims as barred by the Supreme Court’s 1994 “Heck” decision, which forecloses civil litigation that would call into question the validity of a state criminal conviction or sentence that has not been set aside or that would call into question the validity of parole revocation, at least when the revocation is based on the parolee’s wrongdoing.The Seventh Circuit affirmed in part but remanded the claims based on the defendants’ failure to do their jobs. Courtney’s claims that the defendants, after his parole revocation, ignored his grievances and communications regarding possible host sites, if substantiated, would not necessarily imply that the Prison Review Board’s decision to revoke his parole was invalid. Courtney’s claims concerning the defendants’ inaction before that date are similar to seeking a writ of mandamus, not like seeking habeas corpus relief, and would not “necessarily demonstrate the invalidity of confinement or its duration.” View "Courtney v. Butler" on Justia Law

The Supreme Judicial Court affirmed the judgment of the trial court convicting Defendant of two counts of two counts of murder in the first degree on the theory of premeditation as to Mark Greenlaw and Jennifer O'Connor and on the theory of extreme atrocity or cruelty as to O'Connor, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Judicial Court held (1) the trial judge did not abuse his discretion in denying Defendant's motion for a mistrial regarding the victim's fear of rape; (2) the prosecutor's statement during closing argument impermissibly appeal to the jury's sympathy, but the statement did not create a substantial likelihood of a miscarriage of justice; (3) the trial judge erred in failing to instruct the jury that it could consider voluntary ingestion of drugs in determining extreme atrocity or cruelty, but the error did not create a substantial likelihood of a miscarriage of justice; (4) the judge did not err in excusing juror number fifteen; (5) the indictment charging attempted burning of a dwelling was not defective; and (6) there was no error warranting relief under Mass. Gen. Laws ch. 278, § 33E. View "Commonwealth v. Doughty" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count of kidnapping in the first degree and one count of committing violence against an employee of the Department of Corrections, holding that there was no plain error in the proceedings below.On appeal, Defendant argued that the circuit court erred in failing to conduct a sufficient Faretta hearing to ensure his waiver of counsel was knowing, intelligent, and voluntary and in ordering his sentence to consecutively to his prior sentence, in violation of his plea agreement with the State. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the circuit court plainly erred in sustaining Defendant's request to represent himself; and (2) the circuit court did not err in ordering Defendant's sentences to run consecutively. View "State v. Teter" on Justia Law

Howell received medical screenings from nurses employed by NaphCare, which contracts with the Jail to provide medical services. Nurses noted his sickle cell disease diagnosis. Howell returned to the medical unit after he started a fight. Video shows Howell repeatedly falling in the hallway. Officers placed Howell in a wheelchair. At the medical sallyport, Howell complained loudly of pain and stated that he could not feel his legs. Howell slid out of the wheelchair and was eventually left on the floor. Nurse Jordan reviewed Howell’s medical chart. Medical staff had previously sent Howell to a hospital for sickle cell pain. Jordan concluded Howell was in pain but was experiencing a psychiatric issue. Around 5:40 p.m., officers placed Howell in a restraint chair, transported Howell to the mental health unit, and placed him in a cell with a small window on its door. At 6:06 p.m., Nurse Arthur checked on Howell, who was still yelling. but decided that he did not need further medical treatment. No NaphCare employee checked on Howell again. Officers checked Howell approximately every 20 minutes by looking through the window, seeing only a side profile. Officers falsified log entries and failed to comply with regulations concerning removal, rotating Howell’s limbs, or providing water or the restroom. At 9:45 p.m., Officers went to remove Howell and found him dead. The coroner determined that Howell died from sickle cell crisis.In a suit under 42 U.S.C. 1983, the district court granted the defendants summary judgment. The Seventh Circuit reversed as to Nurse Jordan and Deputy Erwin on deliberate indifference claims; a reasonable jury could find that they recklessly failed to act to mitigate an unjustifiably high risk of harm to Howell that a reasonable official would have recognized. Erwin was not entitled to qualified immunity. View "Howell v. NaphCare, Inc." on Justia Law

The Supreme Court held that, within the particular facts and overall context of this criminal case, the trial court did not violate either the United States Constitution or the North Carolina General Statutes by declining to conduct further inquiry into Defendant's capacity to proceed following his apparent suicide attempt on the morning of the sixth day of trial.Defendant's suicide attempt occurred before the jury was given its instructions but after the jury had heard closing arguments from both sides. To determine whether Defendant had forfeited his right to be present for the trial's ongoing proceedings the trial court received evidence concerning his medical history and state of mind at the time of his apparent suicide attempt. The court ultimately concluded that Defendant's injuries were entirely caused by his own voluntary actions, and therefore, Defendant had voluntarily absented himself from the trial proceedings. The trial was continued in his absence, and the trial court entered judgments against Defendant. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not erroneously decline to make further inquiry into Defendant's capacity to proceed during the trial proceedings. View "State v. Flow" on Justia Law

The Supreme Court reversed the final order and judgment of the trial court in this case involving challenges to N.C. Gen. Stat. 13-1, the statute setting forth the criteria that felons must satisfy to be eligible for re-enfranchisement, holding that the trial court erred in entering an order allowing all felons not in jail or prison to register and vote.Nearly fifty years after the legislature rewrote section 13-1 to make re-enfranchisement automatic for all eligible felons Plaintiffs brought this action challenging the requirement that felons complete their probation, parole, or post-release supervision before they regain their voting rights. Plaintiffs alleged that this requirement was intended to discriminate African Americans. The trial court ruled for Plaintiffs. The Supreme Court reversed, holding (1) there was insufficient evidence to prove that legislators intended their reforms to section 13-1 to disadvantage African Americans; and (2) Plaintiffs were not entitled to relief on their other constitutional claims. View "Community Success Initiative v. Moore" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, selling sexual relations, and two counts of felony theft, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant argued that the district court erred in determining that her incriminating statements made to law enforcement confessing to the murder were made voluntarily. Among other things, Defendant contended that sleep deprivation and drug use tainted her interview and that her confinement in the interview room was coercive. The Supreme Court affirmed, holding (1) the district court correctly held that Defendant's statements were freely, voluntarily, and knowingly given and admissible at trial; and (2) ample evidence supported the jury's finding of premeditation. View "State v. Spencer" on Justia Law