Justia Civil Rights Opinion Summaries

Joseph Corcoran was convicted of four murders by an Allen County jury, and the judge sentenced him to death as recommended by the jury. Corcoran has been involved in extensive litigation over the past 25 years, including multiple decisions from the Indiana Supreme Court and the United States Supreme Court, regarding the constitutionality of his execution. Corcoran has expressed his desire to accept his conviction and sentence, stating that he does not wish to pursue further legal challenges.The Allen Superior Court initially sentenced Corcoran to death, and the Indiana Supreme Court remanded for resentencing due to the consideration of non-statutory aggravating factors. Upon resentencing, the death sentence was reimposed and affirmed by the Indiana Supreme Court. Corcoran chose not to pursue post-conviction relief, leading to competency proceedings initiated by the State Public Defender, who argued that Corcoran was incompetent to waive post-conviction remedies. The trial court and the Indiana Supreme Court found Corcoran competent. Corcoran later filed an untimely petition for post-conviction relief, which was dismissed.The Indiana Supreme Court reviewed the case and denied the State Public Defender's motions to file successive petitions for post-conviction relief and to stay the execution. The court held that Corcoran is competent to waive post-conviction remedies and that the State Public Defender lacks standing to file the petitions without Corcoran's authorization. Additionally, the court found no reasonable possibility that Corcoran is entitled to relief, as the claims presented were procedurally defaulted and previously addressed. The court concluded that Corcoran has a rational understanding of his execution and the reasons for it, and thus, denied the motions for a stay of execution. View "Corcoran v. State" on Justia Law

Andre Louis Keller drove to a permanent immigration checkpoint where a Customs & Border Protection (CBP) canine alerted to his vehicle. Upon searching, agents found an alien unlawfully present in the United States concealed under luggage. Keller conditionally pleaded guilty and appealed the district court’s denial of his motion to suppress the evidence found in the vehicle.The United States District Court for the Southern District of Texas held a hearing on Keller’s motion to suppress. Testimonies were provided by CBP Agent Jesse Sandoval, Matthew B. Devaney from CBP’s Canine Academy, and Andre Falco Jimenez, a private police dog trainer. The district court denied Keller’s motion, leading to his conditional guilty plea. Keller was sentenced to 20 months in prison and 3 years of supervised release. He then appealed the suppression ruling.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that stopping a vehicle for brief questioning at a permanent immigration checkpoint is not a Fourth Amendment search and does not require probable cause. The court found that the canine’s alert provided probable cause to search Keller’s vehicle. The court also concluded that the canine’s actions did not constitute an unlawful search and that the district court did not err in its ruling. The Fifth Circuit affirmed the district court’s denial of Keller’s motion to suppress. View "United States v. Keller" on Justia Law

C.H., an eleven-year-old, was sexually exploited by a stranger on Omegle.com, an online platform that connects users in video chatrooms. The stranger, referred to as John Doe, threatened C.H. into creating child pornography. C.H.'s parents sued Omegle.com LLC, alleging violations of 18 U.S.C. § 2255 (Masha’s Law) for knowingly possessing child pornography and the Trafficking Victims Protection Reauthorization Act for knowingly benefiting from a sex trafficking venture.The United States District Court for the Middle District of Florida dismissed the claims, citing section 230 of the Communications Decency Act, which protects providers of interactive computer services from being treated as the publisher or speaker of user-provided information. The court also found that the sex trafficking claim did not meet the Fight Online Sex Trafficking Act (FOSTA) exception to section 230 because C.H.'s parents did not allege that Omegle.com had actual knowledge of benefiting from sex trafficking.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that C.H.'s parents did not state a claim under Masha’s Law because they failed to allege that Omegle.com knowingly possessed or accessed child pornography. The court also held that the FOSTA exception to section 230 requires actual knowledge of sex trafficking, not just constructive knowledge. Since C.H.'s parents did not plausibly allege that Omegle.com had actual knowledge of the sex trafficking incident involving C.H., the court affirmed the district court's dismissal of the claims. View "M.H., et al. v. Omegle.com LLC" on Justia Law

One night, Officer Devosie Jones of the City of Remerton Police Department attempted to stop a black Cadillac with one headlight. The car did not stop, leading to a high-speed chase that ended when the Cadillac crashed into a tree. Quinton Simmons was found trying to exit the car and was arrested. Officers found narcotics and a firearm in the vehicle. Simmons was charged with possession of methamphetamine with intent to distribute, possession of a firearm by a convicted felon, and possession of a firearm in furtherance of a drug trafficking crime. He pleaded not guilty, claiming he was kidnapped and framed by a gang member who fled the scene.The United States District Court for the Middle District of Georgia denied Simmons's Batson challenge, accepting the government's race-neutral reasons for striking three black jurors. During the trial, the court allowed the government to play a brief segment of a body camera video but denied Simmons's request to play additional clips during closing arguments, as they had not been shown during the evidence phase. The jury found Simmons guilty on all counts.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the district court did not abuse its discretion in limiting the scope of closing arguments, as Simmons had the opportunity to present the video clips during the trial but chose not to. The court also found no error in the district court's denial of the Batson challenge, as Simmons failed to make a prima facie case of racial discrimination, and the government's race-neutral explanations were credible. The Eleventh Circuit affirmed the district court's judgment. View "United States v. Simmons" on Justia Law

Wayne Lozier, Jr., a licensed bounty hunter in Louisiana, traveled to Missouri to detain a fugitive, R.C., who had failed to appear for her court date in Louisiana. Lozier entered a residence in Missouri, handcuffed R.C., and transported her towards Mississippi. During this time, the residence owner alerted law enforcement, leading to an investigation by Officer Jeffrey Atkins. Lozier was found to have violated Missouri laws by not being licensed in Missouri and failing to notify local law enforcement before apprehending R.C.A federal grand jury indicted Lozier for kidnapping and conspiracy to kidnap. Lozier moved to dismiss the indictment, arguing his actions were lawful as an agent of a bail bondsman. The United States District Court for the Eastern District of Missouri denied these motions, stating Lozier's arguments were factual challenges. At trial, Lozier admitted to the Missouri law violations but contended his actions were standard fugitive apprehension. He objected to a jury instruction that he claimed deprived the jury of deciding whether his actions were unlawful. The jury found Lozier guilty on both counts, and he was sentenced to 120 months on each count, to run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the jury instruction (Instruction 16) created a conclusive presumption that Lozier acted unlawfully by violating Missouri law, thus removing the jury's ability to consider justification or excuse. This violated Lozier's due process rights. The court held that this error was not harmless and vacated Lozier's convictions, remanding the case for a new trial. View "United States v. Lozier" on Justia Law

Tam Steven Nguyen committed various crimes at the age of 22 and was convicted in 2003 of attempted murder, kidnapping, and assault with a firearm. He was sentenced to a determinate term of 14 years, an indeterminate term of 25 years to life, and a life term with the possibility of parole. While incarcerated, Nguyen earned various credits, including good conduct and educational merit credits. These credits were applied to his minimum eligible parole date (MEPD) and youth parole eligible date (YPED), respectively.Nguyen petitioned the trial court for a writ of habeas corpus in 2022, arguing that he should be able to use all types of credits to advance his YPED, not just educational merit credit. The trial court denied his petition. Nguyen then petitioned the California Court of Appeal, which summarily denied the petition. The California Supreme Court granted review, ordered the appellate court to vacate its order, and issued an order to show cause.The California Court of Appeal reviewed the case and held that Nguyen's right to equal protection was not violated. The court found that youth and nonyouth offenders are not similarly situated for the purposes of the challenged regulations, as youth offenders have two parole eligibility dates (MEPD and YPED) while nonyouth offenders have only one (MEPD). The court also determined that there is a rational basis for the regulation that limits the types of credits that can advance a youth offender's YPED, as it aligns with the legislative intent to provide a fixed and relatively stable parole eligibility date for youth offenders. Consequently, the court denied Nguyen's petition for writ of habeas corpus. View "In re Nguyen" on Justia Law

In 2005, Delano Hale was sentenced to death by an Ohio court for the murder of Douglas Green. Green was found dead in a motel room, wrapped in plastic bags, and had been shot multiple times. Hale was arrested driving Green's stolen vehicle and later admitted to the shooting, claiming it was in self-defense against Green's sexual advances. Hale was convicted of aggravated murder and other charges, and the jury recommended the death penalty.Hale's conviction and sentence were affirmed by the Ohio Supreme Court and the Ohio Court of Appeals. Hale filed for post-conviction relief, which was denied by the trial court and affirmed by the appellate court. He then sought federal habeas relief, raising multiple claims, including ineffective assistance of counsel and sentencing errors under Blakely v. Washington.The United States Court of Appeals for the Sixth Circuit reviewed Hale's habeas petition. The court denied Hale's claim of ineffective assistance of counsel, finding that his trial counsel's decision not to call a forensic expert was a reasonable strategic choice. The court noted that Hale's counsel had considered hiring an expert but ultimately chose a different strategy, which did not constitute deficient performance under Strickland v. Washington.The court also denied Hale's claim regarding his noncapital sentences, which were enhanced based on judicial factfinding in violation of Blakely. The Ohio Supreme Court had reviewed this claim for plain error and found no prejudice, concluding that a jury would have reached the same sentencing conclusions. The Sixth Circuit found this determination reasonable and upheld the Ohio Supreme Court's decision.The Sixth Circuit affirmed the district court's denial of Hale's habeas petition, concluding that Hale's claims did not warrant relief under the deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA). View "Hale v. Cool" on Justia Law

Matthew Fuller was convicted of possessing more than two ounces but less than one-half pound of marijuana, a felony, and was placed on supervised probation. After two subsequent arrests, the State petitioned to revoke his probation. The court appointed two attorneys for Fuller, both of whom withdrew. The court did not appoint a third attorney and conducted the revocation hearing with Fuller representing himself. Fuller was found to have violated his probation and was sentenced to a previously suspended two-year prison term.The Circuit Court of the Third Judicial Circuit in Codington County, South Dakota, initially handled the case. Fuller was arrested following a traffic stop and charged with marijuana possession. He was released on bond and represented by multiple attorneys who withdrew. Fuller pled guilty to a lesser charge, and the court imposed a suspended sentence with probation. After his subsequent arrests, the court ordered him held without bond pending the revocation hearing. Fuller’s attorneys withdrew due to a breakdown in the attorney-client relationship, and the court did not appoint new counsel.The Supreme Court of the State of South Dakota reviewed the case. The court held that while Fuller was entitled to appointed counsel under state law, he did not demonstrate that the lack of counsel prejudiced the outcome of the revocation hearing. The court found sufficient evidence to support the probation violation, including Fuller’s use of methamphetamine. The court also rejected Fuller’s claims of judicial bias and due process violations, affirming the lower court’s decision to revoke his probation and execute the suspended sentence. View "State V. Fuller" on Justia Law

In 2021, a 14-year-old named Emanuel Ochoa was convicted of aggravated sexual assault of a child under 6, injury to a child causing serious mental injury, and kidnapping, all related to the sexual assault of a five-year-old girl. The key issue in this case was whether Ochoa's statements to law enforcement were made voluntarily. The court concluded that they were not.The trial court denied Ochoa's motion to suppress his statements, ruling that they were voluntary. The Second Court of Appeals upheld this decision, finding that Ochoa was not in custody during the pre-warnings portion of the interview and that his post-warnings statements were voluntary. The court noted that Ochoa and his mother went to the interview voluntarily, he was told he could leave at any time, and his freedom of movement was not restricted. The court also found that the statements made by the magistrate and the Texas Ranger did not render Ochoa's confession involuntary.The Court of Criminal Appeals of Texas reviewed the case and reversed the court of appeals' judgment. The court held that Ochoa's confession was involuntary under due process principles. The court emphasized that Ochoa's youth, lack of maturity, and inexperience with the legal system made him particularly vulnerable to coercive interrogation tactics. The court found that the combined effect of the Texas Ranger's misleading statements and the magistrate's incorrect information about Ochoa's rights overbore his will and rendered his confession involuntary. The case was remanded to the court of appeals for a harm analysis. View "OCHOA v. STATE OF TEXAS" on Justia Law

Anthony Lemicy was convicted by a jury on four counts of sexual exploitation of a minor under 18 U.S.C. § 2251(a), (e). The district court sentenced him to consecutive 30-year terms for each count, totaling 120 years. Lemicy appealed, raising several claims including improper waiver of his right to counsel, violation of his right to a fair trial due to appearing in an orange jumpsuit and restraints, improper jury instructions, insufficient evidence, incorrect calculation of criminal history points, and an unreasonable sentence.The United States District Court for the Eastern District of Missouri initially appointed a federal public defender for Lemicy, but after conflicts, he chose to represent himself with standby counsel. The court repeatedly informed him of the risks and limitations of self-representation, which he acknowledged. During the trial, Lemicy appeared in jail-issued clothing by choice, despite the court offering him the opportunity to change. The jury was instructed to disregard his appearance.The United States Court of Appeals for the Eighth Circuit reviewed the case. It found that Lemicy knowingly and voluntarily waived his right to counsel, and the district court did not err in its handling of standby counsel. The court also determined that Lemicy was not compelled to wear the orange jumpsuit and any error was invited by him. The jury instructions were deemed appropriate, and the evidence was sufficient to support the convictions. The court upheld the calculation of criminal history points and found the sentence reasonable, given the severity of the offenses and the involvement of multiple victims.The Eighth Circuit affirmed the district court’s judgment, concluding that there were no violations of Lemicy’s constitutional rights and that the sentence imposed was within the court’s discretion. View "United States v. Lemicy" on Justia Law