Justia Civil Rights Opinion Summaries

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

The Supreme Court affirmed the judgment of the intermediate court of appeals (ICA) affirming the judgment of the circuit court granting the State's motion for revocation of probation and resentencing Defendant to five years of imprisonment with credit for time served, holding that there was no error.After probation officers conducted a warrantless search of Defendant's home and recovered a firearm and ammunition, the circuit court revoked Defendant's probation. At issue on appeal was whether the circuit court abused its discretion by imposing a probation condition allowing warrantless searches by a probation officer for contraband. The ICA affirmed. The Supreme Court affirmed, holding that because Defendant was prohibited from owning or possessing firearms and ammunition and because he had notice that the term "contraband" would include such items, the circuit court did not abuse its discretion by imposing the special condition. View "State v. Talo" on Justia Law

The Supreme Court vacated the decision of the intermediate court of appeals (ICA) affirming order of the circuit court denying Defendant's motion to dismiss indictment against him, the court's judgment of conviction and sentence, and the later order of restitution, holding that the circuit court abused its discretion by denying Defendant's motion to dismiss the indictment.In his motion to dismiss the indictment against him, Defendant argued that the prosecutor committed prosecutorial misconduct by before the grand jury by improperly eliciting testimony that he had invoked his right to remain silent. The circuit court denied the motion to dismiss, and Defendant entered a no-contest plea to assault in the first degree. The ICA affirmed. The Supreme Court vacated the lower courts' decisions, holding (1) the prosecutor violated Defendant's due process right to a fair and impartial grand jury hearing by eliciting testimony that Defendant invoked his right to remain silent; and (2) the circuit court erred by ordering Defendant to pay $1,461,444 in restitution. View "State v. Borge" on Justia Law

Williams sought compassionate release under 18 U.S.C. 3582(c)(1), citing as “extraordinary and compelling” circumstances the fact that a district court treated him as having a prior conviction for unlawful drug delivery, which increased his minimum sentence, 21 U.S.C. 841(b)(1)(B), while his Illinois conviction for delivery of cocaine did not satisfy the criteria of a “serious drug felony.”The Seventh Circuit rejected that argument, noting its own precedent. Section 3582(c)(1) addresses 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 with distinct requirements, such as the time limits in 28 U.S.C. 2255(f) or the need for a declaration by the Sentencing Commission that a revision to a Guideline applies retroactively. There is nothing “extraordinary” about a legal error and the law provides methods other than compassionate release for dealing with those claims.Williams also argued that he has a spotless conduct record in prison, has completed educational programs that will allow him to participate in society, and has a greater risk of contracting COVID-19 and other diseases in prison. The court rejected those claims for failure to exhaust administrative remedies by presenting them to the Bureau of Prisons. View "United States v. Williams" on Justia Law

The Supreme Court affirmed the judgment of the trial court deciding to grant Defendant's request to represent himself and denying his motion for a new trial, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that his waiver of his right to the assistance of counsel was not valid and that the trial justice erred when she denied his motion for a new trial. The Supreme Judicial Court affirmed, holding (1) there was no error in the trial justice's decision allowing Defendant to discharge his attorney when and as he did; and (2) the record established that Defendant made a voluntary, knowing, and intelligent waiver of his right to the assistance of counsel; and (3) the trial justice did not err in denying Defendant's motion for a new trial. View "State v. Delossantos" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence of a 108-month term of immurement for attempted possession with intent to distribute 400 grams or more of fentanyl, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the First Circuit held (1) Defendant waived his claim that the district court erred by denying his motion to suppress on the grounds that his arrest and the subsequent search of his person were unreasonable; (2) the district court did not plainly error in allowing the testimony of a detective; (3) the evidence was sufficient to support the conviction; and (4) Defendant's sentence was substantively reasonable. View "United States v. Concepcion-Guliam" on Justia Law

The First Circuit affirmed the judgment of the district court concluding that the government had shown by a preponderance of the evidence that Appellant had violated the conditions of his supervised release and sentencing him to a two-year term of imprisonment, holding that there was no error.On appeal, Appellant challenged the district court's determination that the government proved, by a preponderance of the evidence, that he possessed a firearm in violation of the conditions of his supervised release. The First Circuit affirmed, holding (1) a releasee does not have a Sixth Amendment right to confront adverse witnesses during revocation proceedings, and Appellant's remaining constitutional challenge was waived; (2) the district court erred in failing to make the explicit balancing determination contemplated by Fed. R. Civ. P. 32.1(b)(2)(C), but the error was harmless; and (3) the district court's factual findings were not clearly erroneous. View "United States v. Teixeira" on Justia Law

Scott was suspected of shooting and killing Bishop. Scott claims he asked for an attorney during his arrest, but no questioning occurred at that time. Approximately four hours later, Scott was taken for an interview. After the detectives read Scott his Miranda rights, he admitted in a recorded interview to murdering Bishop. Four attorneys worked on Scott’s case before trial; one moved to exclude Scott’s confession on the basis of intoxication. The judge denied the motion, doubting Scott’s testimony. The jury heard the confession and convicted Scott.In a postconviction motion, Scott unsuccessfully alleged that his attorney was ineffective for not moving to suppress his confession on the theory that, because he requested an attorney during his arrest, his confession was obtained in violation of the Fifth Amendment. Scott's second unsuccessful postconviction motion claimed his first postconviction counsel deficiently pleaded his claim by failing to marshal facts showing he informed his trial counsel of his request for an attorney.The Seventh Circuit affirmed the denial of his federal habeas petition, in which he claimed both his trial and first postconviction attorneys were ineffective. The Wisconsin appellate court’s decision was not contrary to or an unreasonable application of Supreme Court precedent, which has never extended Miranda beyond the context of custodial interrogation to permit an accused to request an attorney at the time of his arrest so as to cut off questioning before any attempt at questioning. View "Scott v. Hepp" on Justia Law

Perry died from gunshot wounds sustained during a fight with Shirley. In 2008, Shirley was convicted of first-degree reckless homicide. Shirley uses a prosthetic device below his knee. Although he can walk, during his trial Shirley was in a wheelchair with his legs shackled. To prevent the jury from observing the shackles, fabric was draped over both counsel tables. During voir dire, Juror 34 stated, if he’s in cuffs, "he did something.” Juror 34 separately confirmed he had seen the restraints, had not mentioned them to other jurors, and that his observations did not bias him. Shirley and his counsel said they were satisfied with those responses and did not request accommodations to muffle the noise of the shackles while Shirley was on the witness stand.The Wisconsin Court of Appeals rejected claims that his presumption of innocence was violated because Juror 34 noticed his restraints, that being shackled inhibited his right to present a complete defense because it limited his ability to approach exhibits, make demonstrations and show the jury which leg his prosthesis was on. The court could not locate an explanation in for the restraint decision but found Shirley “had little difficulty communicating” in an “intelligent and articulate” manner from the witness stand. The Seventh Circuit affirmed the denial of Shirley’s petition for habeas relief. No Supreme Court case clearly establishes that the decision to shackle a criminal defendant while testifying violates the defendant’s constitutional rights. View "Shirley v. Tegels" on Justia Law