Justia Civil Rights Opinion Summaries

In 1991, Jackson was wrongfully convicted of murder. In 2016, the Innocence Project requested from the Cleveland Police documents relating to the investigation, pursuant to the Ohio Public Records Act. Receiving no response, Innocence Project sent a request to the Cuyahoga County Prosecutor’s Office. Assistant Prosecuting Attorney Marburger produced a heavily redacted file. The Act exempts “investigatory work product” and “[t]rial preparation record[s]” from production as public records. Months later, the Ohio Supreme Court held that the investigatory-work-product exception did not extend beyond the conclusion of a trial. Cleveland then produced the unredacted file, which included significant exculpatory evidence. The Cuyahoga County Prosecutor’s Office also produced an unredacted file. A state-court judge vacated Jackson’s conviction. In 2019, he was finally exonerated. Jackson filed suit under 42 U.S.C. 1983. Against Marburger, Jackson alleged denial of access to courts.The Sixth Circuit held that Marburger is not entitled to absolute immunity. Responding to a records request after the conclusion of a trial and appeal is not an action that is an inherent part of a prosecutor’s adversarial function. The court reversed the denial of qualified immunity. Jackson plausibly stated a claim that Marburger violated his right of access to the courts when she removed exculpatory information from the file and effectively prevented him from filing for postconviction relief but in 2016 it was not clearly established that redacting exculpatory information from a response to a public-records request effectively covered-up evidence. View "Jackson v. City of Cleveland" on Justia Law

A gambling dispute incited a fistfight between gang subsets. Witnesses later testified that after they thought the fight was over, they saw Ferrell shoot a gun, then saw Rawlings, lying on the ground, bloodied. Ferrell dropped the gun and fled. Ferrell later claimed he had only shot once, into the air. The juvenile court transferred Ferrell, age 17, to a court of criminal jurisdiction, where he was charged with murder, with alleged sentencing enhancements for use of a firearm.The Court of Appeal affirmed Ferrell’s second-degree murder conviction and 40-year sentence. The California Supreme Court granted Ferrell habeas relief. The jury instructions erroneously permitted the conviction based on a felony-murder theory invalidated in 2009. The unadorned guilty verdict does not show that the jury avoided that theory. The court rejected an argument that the jury’s additional finding — that Ferrell intentionally discharged a firearm and caused death in committing his offense — along with other evidence, establish that any rational jury would have found Ferrell guilty under a valid theory of second-degree murder, implied malice. Even in light of the entire record, the jury’s additional finding fails to establish the mental component of implied malice, which requires a defendant to act with a conscious disregard for life, knowing his act endangers another’s life. The jury could have, consistent with its finding, concluded Ferrell shot Rawlings while trying to stop a fight without believing he was shooting toward any person. View "In re Ferrell" on Justia Law

In July 2013, Koger began serving a 300-day sentence in Cook County Jail. While incarcerated, he received 42 books by mail. Per Jail policy, contained in the Inmate Information Handbook, inmates can keep no more than three books or magazines (excluding religious texts) in their cell at any time. Koger received a copy of the Handbook. Inmates with excess books can mail them out of the Jail using supplies available at the Jail commissary, can have someone outside the Jail pick up personal property, and are free to donate their books to other inmates. The policy was not strictly enforced during Koger’s stay.In October 2013, Jail administrators warned Koger they would soon search cells and take excess books. On October 5, officers searched the cells and took all but three books from Koger’s cell. Koger did not file a grievance. The Jail acknowledges the search but disputes whether any books were taken and what became of them. The Jail has no policy for dealing with confiscated books. The Jail released Koger on October 24, 2013; he died in 2020.Koger’s suit under 42 U.S.C. 1983 has twice previously been before the Seventh Circuit, which affirmed the district court’s summary judgment rejection of Koger’s claim that the county deprived him of his books without due process. Koger received constitutionally sufficient due process surrounding any property deprivation, and presented insufficient evidence to hold the county liable under “Monell.” View "Orozco v. Dart" on Justia Law

In a previous decision involving a reporter’s request for information concerning an investigation involving Sanford, the South Dakota Supreme Court held that SDCL 23A-35-4.1 permits a circuit court to “seal the contents of an affidavit in support of a search warrant upon a showing of reasonable cause, but only until the investigation is terminated or an indictment or information is filed.” The court may not prohibit the public disclosure of other specific records nor of the fact that a search warrant affidavit has been filed.” Certain personally identifying information within court records must be redacted as a matter of course.Following the completion of the state’s criminal investigation, the circuit court unsealed the search warrant affidavits related to the investigation. Sanford challenged the denial of his request to inspect and participate in redacting the affidavits before the records were unsealed. The South Dakota Supreme Court affirmed. The circuit court properly applied the provisions of SDCL 15-15A-13 and 23A-35-4.1 and thoroughly considered the statutory and constitutional grounds asserted by Sanford with respect to information that could conceivably be contained in the affidavits. The court appropriately exercised its discretion to “decide whether there [were] sufficient grounds to prohibit access” to the contents of the affidavits. View "Matter Of Implicated Individual" on Justia Law

In 2015, Nijmeddin was sentenced to an indeterminate life term, consecutive to a determinate term, for murder, attempted voluntary manslaughter, assault with a deadly weapon, and possession of narcotics. In 2023, the Department of Corrections recommended that the court recall Nijmeddin’s sentence under the new compassionate release provisions, Penal Code 1172.2, that apply to defendants who have “serious and advanced illness with an end-of-life trajectory,” creating a “presumption favoring recall and resentencing . . . which may only be overcome if a court finds the defendant is an unreasonable risk of danger to public safety.”Nijmeddin has advanced incurable pancreatic cancer, biliary adenocarcinoma, and other medical conditions. Nijmeddin is foregoing chemotherapy treatment. Nijmeddin, 65 years old, has committed prison rules violations, including fighting and violent threats. Nijmeddin’s doctor testified Nijmeddin “is barely able to get out of" his wheelchair and estimated Nijmeddin has three-six months to live. Nijmeddin’s brother, an attorney, is willing to be Nijmeddin’s caregiver. The court observed, “Nijmeddin looks quite good. … the doctors may say that he is terminally ill, he is not on that far end.” The court characterized Nijmeddin as “able to use his mental capacity to commit offenses” and declined to recall Nijmeddin’s sentence, finding that he poses an unreasonable risk to public safety.The Attorney General conceded that the court erred and that Nijmeddin is entitled to relief. The court of appeal issued a peremptory writ of mandate commanding the trial court to immediately enter an order recalling Nijmeddin’s sentence. View "Nijmeddin v. Superior Court of Monterey County" on Justia Law

A fight erupted during a house party; someone fired multiple shots into the bedroom through the door, striking and killing Walker. Police obtained statements from more than 25 individuals. Eyewitness descriptions identified the shooter as a black male who used his right hand, but descriptions were otherwise very inconsistent. After the party, rumors circulated on Facebook accusing Smyth of the shooting. The police later turned their attention to Harris and, ultimately, to Mull, who was identified as the shooter by several witnesses. At Mull’s jury trial, the prosecution presented multiple witnesses. The defense did not call any witnesses. Convicted of first-degree reckless homicide, Mull was sentenced to 25 years' confinement.The Wisconsin Supreme Court reversed an order granting Mull a new trial, rejecting Mull’s argument that his attorney was ineffective for "failing to file a third-party perpetrator motion regarding any one of the viable alternate suspects.” Counsel testified he thought a reasonable doubt defense was preferable to a third-party perpetrator defense because it was difficult to locate witnesses, even using an investigator, and that there were credibility issues and inconsistent accounts. Counsel objected to a line of questioning relative to out-of-court messages and attempted to discredit that testimony on cross-examination; he did not move to strike a statement made during cross-examination because he did not want "too much attention." The court concluded that the controversy was fully tried, and it is not probable that justice has miscarried. View "State v. Mull" on Justia Law

In 1987, a Michigan jury convicted Burton of first-degree murder and a firearm charge. He was sentenced to life in prison without the possibility of parole. In 2019, Burton was released from prison and his conviction was vacated on the prosecutor’s motion after key witnesses recanted and details of witness manipulation and intimidation were revealed. Detective Sanders’s investigative tactics allegedly included threats and physical violence against witnesses, including minors. In 2020,Burton filed claims under 42 U.S.C. 1983 and 1988 against Sanders and Detroit for Brady violations, malicious prosecution, and fabrication of evidence. The district court dismissed Burton’s claims as barred by Detroit’s Chapter 9 bankruptcy which occurred after Burton’s claims arose. Burton’s claims against Sanders remain pending. Burton’s sons then filed suit against Sanders and the city, alleging that the wrongful conviction and incarceration of their father throughout their childhood and into adulthood violated their constitutional right to family integrity. The district court dismissed, finding no cognizable due process right for “interference with family integrity” when a party is indirectly harmed by a constitutional tort against a family member. The Sixth Circuit affirmed; the plaintiffs have not alleged that the defendants acted with a culpable state of mind, directed toward them or their family unit. View "Chambers v. Sanders" on Justia Law

In 2005, a jury convicted Lopez and three others of Gomez’s first-degree premeditated murder and found true the gang-murder special circumstance and the criminal street gang sentencing enhancement. Lopez was sentenced to life imprisonment without the possibility of parole. The Court of Appeal affirmed. Lopez sought habeas relief, alleging his jury had been instructed on the natural and probable consequences theory of aiding and abetting first-degree murder, found invalid in the California Supreme Court's 2014 "Chiu" decision. In 2019, the Court of Appeal held that the Chiu error was harmless beyond a reasonable doubt based on the gang-murder special circumstance, which required the jury to find that an aider and abettor acted with intent to kill, and the “overwhelming” evidence against Lopez generally. The court discounted the prosecutor’s discussion of the natural and probable consequences theory in his closing argument and found a jury note referencing that theory inconsequential under the circumstances.The California Supreme Court reversed. The gang-murder special circumstance here does not necessarily render the Chiu error harmless beyond a reasonable doubt but indications that the jury may have relied on an invalid theory, such as a prosecutor’s closing argument or a jury note, do not preclude a finding of harmlessness. The court must rigorously review the evidence to determine whether any rational juror who found the defendant guilty based on an invalid theory and made the factual findings reflected in the verdict, would necessarily have found the defendant guilty based on a valid theory. View "In re Lopez" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree, holding that Defendant was not entitled to relief on his allegations of error.In 2019, police charged Defendant with murder in the first degree for a murder committed in 1979. The charges were based on the results of a DNA test that was performed on a drinking straw that the police retrieved from an eating establishment where Defendant had eaten. A jury found Defendant guilty and sentenced him to prison. The Supreme Court affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress evidence about DNA that police found on the straw that Defendant discarded or to analyze DNA attached to the straw; (2) the district court did not abuse its discretion by declining to give an instruction regarding federal sentencing law; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Burns" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction for two counts each of second-degree sexual assault and second-degree sexual assault of a child and also reversing the circuit court's order denying Defendant's motion for postconviction relief, holding that Defendant was not entitled to postconviction relief.In his motion for postconviction relief, Defendant argued that the prosecutor at his trial violated his Fifth Amendment right against self-incrimination by adversely commenting on his decision not to testify. The court of appeals reversed, concluding that the prosecutor's argument that the evidence was "uncontroverted" was improper, thus violating Defendant's Fifth Amendment right not to testify at trial. The Supreme Court reversed, holding that the prosecutor did not comment on Defendant's silence, and therefore, the circuit court properly denied Defendant's motion for postconviction relief. View "State v. Hoyle" on Justia Law