Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction for the first degree murder of Rafael Noriega and his sentence of death, holding that there was no reversible error in the proceedings below.A jury convicted Defendant of first degree murder and found true the special circumstance allegation that the murder was committed while Defendant was engaged in the commission of a robbery. The jury also found true the special circumstance allegation that Defendant was previously convicted of murder. The jury returned a verdict of death, and the trial court denied Defendant's ensuing motion for modification of his sentence. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant's right to self-representation in its rulings regarding Defendant's funding requests; (2) there was no error or abuse of discretion in the district court's evidentiary rulings; (3) Defendant's challenges to the special service allegations were unavailing; (4) there was no error in the jury instructions; (5) there was no error or abuse of discretion during the penalty phase; and (6) Defendant's challenges to the constitutionality of California's death penalty law failed. View "People v. Thomas" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Petitioner's petition for writ of habeas corpus, holding that Petitioner's statutory and constitutional claims did not raise jurisdictional issues that entitled him to habeas relief.Petitioner was convicted of capital murder and first-degree battery and sentenced to a life sentence plus consecutive twenty-four sentences. The Supreme Court affirmed on direct appeal. Petitioner later brought this petition alleging that he was not named in the body of the criminal information and that he was not identified in the document, and therefore, the trial court lacked jurisdiction over him. The circuit court denied the habeas corpus petition. The Supreme Court affirmed, holding that the trial court had personal and subject-matter jurisdiction over Petitioner. View "Lee v. Payne" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction for operating under the influence, entered upon Defendant's conditional guilty plea after the trial court denied his motion to suppress evidence obtained through a police officer's interactions with him in a convenience store parking lot, holding that the trial court did not err in denying Defendant's motion to suppress.Defendant moved on multiple grounds to suppress evidence obtained as a result of his interactions with the police officer, arguing that he was unlawfully seized based on an unreliable anonymous tip and was directed to perform field sobriety testing without given a chance to decline. The court denied the motion to suppress. Defendant then entered a conditional guilty plea to operating under the influence. The Supreme Judicial Court affirmed, holding that the officer did not violate the United States Constitution by conducting field sobriety tests under the circumstances of this case. View "State v. Wilcox" on Justia Law

In 2000, Von Vader pled guilty to distributing methamphetamine in Wisconsin and was sentenced to 270 months’ imprisonment; the court concluded he was a “career offender.” He did not appeal. Von Vader later pled guilty to possessing heroin in prison (in Kansas) and received an additional ten-year sentence. In a 2017 petition (28 U.S.C. 2255) Von Vader argued that intervening Supreme Court precedent indicated that one or more of his previous convictions should not have been counted toward career offender classification. Von Vader’s petition was dismissed as untimely.He then unsuccessfully applied for compassionate release (18 U.S.C. 3582(c)(1)), contending that the 2000 sentencing error was an “extraordinary and compelling” reason for his release. The Seventh Circuit first held that the fact that Von Vader’s 2000 sentence has expired did not render the application moot because relief would be possible, The court then rejected his claims on the merits. A challenge to a sentence must be resolved by direct appeal or motion under 2255, not by seeking compassionate release. Judicial decisions, even those announcing new law, cannot alone amount to an extraordinary and compelling circumstance, which, under 3582(c)(1), is some new fact about an inmate’s health or family status, or an equivalent post-conviction development, not a purely legal contention for which statutes specify other avenues of relief. Even if the Sentencing Commission’s staff erred in distributing information concerning Van Vader’s right to file a 2255 motion, prisoners do not have a right to legal assistance in initiating collateral relief requests. View "United States v. Von Vader" on Justia Law

Williams was shot and killed in 2009, and two other men were injured. A Wisconsin jury found beyond a reasonable doubt that Wilson was the gunman. After exhausting state remedies, he appealed the district court’s denial of his habeas petition under 28 U.S.C. 2254, claiming that he received constitutionally ineffective assistance from his trial and postconviction counsel.The Seventh Circuit declined to reach the merits of Wilson’s claims, finding both procedurally defaulted. Wisconsin state courts disposed of Wilson’s ineffective assistance of trial counsel claim on adequate and independent state procedural grounds. Wilson failed to present his ineffective assistance of postconviction counsel claim for one complete round of state court review. If a petitioner’s claims are procedurally defaulted, federal habeas review is precluded unless the prisoner demonstrates either “cause for the default and actual prejudice as a result of the alleged violation of federal law,” or that failure to consider the claims will result in a fundamental miscarriage of justice.” The miscarriage of justice exception ‘applies only in the rare case where the petitioner can prove that he is actually innocent. Wilson does not allege cause and prejudice and did not make a sufficient showing of actual innocence. View "Wilson v. Cromwell" on Justia Law

The Supreme Court reversed Defendant's conviction for three counts of first degree murder and several other crimes, holding that the trial judge erred when he granted Defendant's request to represent himself after a different judge had previously denied the request.Before trial, Defendant filed a motion to exercise his right of self-representation under Faretta v. California, 422 U.S. 806 (1975). Judge Zumwalt denied the motion, concluding that Defendant had a mental disorder that prevented him from appreciating the ramifications of waiving counsel. More than one year later, Defendant filed a second Faretta motion before Judge Boyle. Without considering Judge Zumwalt's denial of the first Faretta motion or the evidence on which it was based, Judge Boyle granted the motion. The Supreme Court reversed, holding that Judge Boyle abused his discretion by overturning Judge Zumwalt's Faretta denial while intentionally ignoring the bases for the decision or relevant evidence and that the decision was not harmless. View "People v. Waldon" on Justia Law

In 2011, police officers stopped Villareal while he was driving a car the officers believed had been involved in a neighborhood shooting. During the traffic stop, officers searched the car and recovered a fully loaded handgun. Villareal was charged with several offenses related to the firearm. Villareal pleaded guilty to unlawful possession of a firearm by a gang member (720 ILCS 5/24-1.8(a)(1). The circuit court sentenced Villareal to four years in prison. Villareal subsequently filed a petition, arguing his sentence was improperly increased by mandatory supervised release.The circuit court dismissed the petition. On appeal, Villareal challenged section 24-1.8(a)(1) as facially unconstitutional under the Eighth Amendment because it impermissibly criminalized his status as a gang member. He also argued that it violated substantive due process. The appellate court rejected Villareal’s Eighth Amendment challenge and declined to address the due process claim, as it was raised for the first time in Villareal’s supplemental brief.The Illinois Supreme Court affirmed. The statute is rationally related to a legitimate state interest in curbing gang violence in public places and is not unconstitutionally vague. The court noted plain language explaining when a person is an active gang member. Villareal did not allege or show all gang membership is involuntary. View "People v. Villareal" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress statements he had made during two separately recorded interrogations of him by police officers, holding that the trial court properly denied Defendant's motion to suppress.The two interrogations at issue occurred on the same day. As to the first interrogation, Defendant claimed that the police failed to advise him of his rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further claimed that the second interrogation was tainted by the alleged illegality of the first interrogation. The trial court denied the motion to suppress and, following a jury trial, convicted Defendant of manslaughter in the first degree with a firearm. The Supreme Court affirmed, holding (1) Miranda warnings were not required for the first interrogation because it was not custodial; and (2) the failure to provide the warnings did not taint the second interrogation. View "State v. Brandon" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner failed to establish that he was entitled to relief.Petitioner was convicted of manslaughter in the first degree with a firearm, assault in the first degree, and criminal possession of a firearm. In his habeas petition, Petitioner argued that his trial counsel's concession of Petitioner's guilt to the manslaughter charge without Petitioner's prior approval violated his rights to effective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984), and personal autonomy under McCoy v. Louisiana, __ U.S. __ (2018). The habeas court denied the petition, finding Petitioner's claims to be without merit. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Petitioner's right to autonomy was not implicated under the facts of this case; and (2) Petitioner's second claim on appeal was unpreserved. View "Grant v. Commissioner of Correction" on Justia Law

Defendant kidnapped Doe, then age twelve, and drove her from California to Nevada knowing that she would engage in prostitution. The defendant entered into a written plea agreement pursuant to which, in exchange for the government’s promise to drop five serious criminal charges, he would plead guilty to two lesser crimes (interstate travel in aid of unlawful activity, in violation of 18 U.S.C. Section 1952(a)(3)(A)) and would pay Doe restitution. The district court nonetheless concluded that it lacked statutory authority to order Defendant to pay restitution to Doe.   The panel filed (1) an order amending its opinion, denying a petition for panel rehearing, and denying on behalf of the court a petition for rehearing en banc; and (2) an amended opinion granting Jane Doe’s petition for a writ of mandamus pursuant to 18 U.S.C. Section 3771(d)(3), a provision of the Crime Victims’ Rights Act. The panel published the opinion to reiterate what this court held in two cases decided three decades ago: 18 U.S.C. Section 3663(a)(3) grants statutory authority to district courts to award restitution whenever a defendant agrees in a plea agreement to pay restitution.   The panel held that the district court’s holding that it lacked statutory authority to order restitution was legal error. The panel granted the mandamus petition and instructed the district court to address, in the first instance, Defendant’s evidentiary challenges and other arguments concerning the appropriate amount of restitution. View "JANE DOE V. USDC-NVL" on Justia Law