Justia Civil Rights Opinion Summaries

The Supreme Judicial Court held that the single justice of the county court neither erred nor abused his discretion by denying, without a hearing, Petitioner's petition for relief under Mass. Gen. Laws ch. 211, 3, holding that the single justice neither erred nor abused his discretion by denying extraordinary relief.In 1985, Petitioner was convicted of aggravated rape and other offenses. In 2005, the Sex Offender Registration Board issued a decision ordering Petitioner to register as a level three sex offender, thereafter denying Petitioner's motion for relief from the registration requirement. In this petition, Petitioner brought, among other claims, constitutional challenges to both federal and state sex offender registration laws. The single justice denied relief. The Supreme Judicial Court affirmed, holding that the single justice did not abuse his discretion in finding that no exceptional circumstances were present in this case warranting extraordinary relief. View "Rancourt v. Attorney General" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing Defendant's conviction following her conditional plea of nolo contendere to the charge of possession of narcotics with intent to sell, holding that the appellate court incorrectly determined that the trial court erred by denying Defendant's motion to suppress.On appeal, Defendant argued that the trial court erred in denying her motion to suppress evidence seized by the police following a warrantless entry into her apartment on the grounds that the exigent circumstances and emergency aid doctrines supported the warrantless search of her apartment. The appellate court agreed and reversed. The Supreme Court reversed, holding (1) the warrantless entry was supported by the exigent circumstances doctrine; and (2) the evidence supported an objectively reasonable belief that someone inside Defendant's apartment was in need of emergency medical aid. View "State v. Curet" on Justia Law

Plaintiff-Appellant Elsa Palacios, personal representative of the estate of the deceased, Bernardo Palacios Carbajal, filed suit pursuant to 42 U.S.C. § 1983 against Defendants-Appellees Salt Lake City Police Officers Neil Iversen and Kevin Fortuna in their individual capacities, as well as Salt Lake City Corporation. Plaintiff alleged the officers violated Palacios’ Fourth Amendment rights when he was fatally shot during a police pursuit. The district court granted summary judgment on the basis of qualified immunity in favor of Defendants, finding a lack of a constitutional violation and that Plaintiff failed to show a violation of clearly established law. On appeal, Plaintiff contended that disputes about material and historical facts precluded summary judgment. According to Plaintiff, the district court erred by not making reasonable factual inferences in Plaintiff’s favor, primarily that: (1) Palacios may have been unaware he was being pursued by police because officers did not verbally identify themselves, because he was severely intoxicated, and he did not match the full description of the robbery suspect; (2) once Palacios fell onto his side during the shooting and did not point his gun at officers, he was effectively subdued; and (3) Palacios’ conduct showed he was attempting to avoid confrontation, not evade arrest. Plaintiff also contended that officers exaggerated the seriousness of the offenses that precipitated the pursuit and that officers should have used less intrusive means of apprehension because Palacios did not pose an imminent threat. Finding no reversible error, the Tenth Circuit Court of Appeals affirmed the district court's dismissal of Plaintiff's case. View "Palacios v. Fortuna, et al." on Justia Law

In consolidated proceedings, Petitioners each sought a writ requiring the Superior Court to dismiss their cases for violating their speedy trial rights under Penal Code section 1382.2. Petitioners argued there was no good cause to continue their cases past the statutory deadline because the Superior Court can no longer rely on the “exceptional circumstances” resulting from the COVID-19 pandemic.The court of appeal denied the petitions. The pandemic and its adverse impacts on the courts did not end when the courts reopened; courts had to address both the backlog that had developed during the closure of the courts and new cases. Although the courts reopened, the pandemic continued to wreak havoc, with 36 judicial officers, court staff, sheriff’s deputies, attorneys, defendants, and jurors contracting COVID-19, being required to quarantine due to exposure, or having to care for family members. The persistence of a backlog during the period at issue was principally the result of continuing consequences of the pandemic. Not only the pandemic, itself, but its length, seriousness, and continuing effects were unexpected and unanticipated and resulted in exceptional and extraordinary circumstances. The Superior Court did not, in these cases, abuse its discretion in concluding that exceptional circumstances justified the continuance of Petitioners’ trials past their statutory last days. View "Estrada v. Superior Court of the City and County of San Francisco" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of murder but vacated his sentence, holding that a criminal defendant's decision to exercise his constitutional right to a trial by jury may not be considered at sentencing.After a seven-day trial at which Defendant did not testify, the jury returned a verdict of guilty to murder. After a sentencing hearing, the court found that there were no mitigating circumstances and imposed a thirty-two-year sentence. The Supreme Judicial Court vacated Defendant's sentence, holding that the trial court (1) did not err when it denied Defendant's request to provide him with access to the grand jury transcript; but (2) abused its discretion by referencing Defendant's demand for a jury trial in determining the genuineness of Defendant's claim of personal reform and contrition. View "State v. Moore" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court's order dismissing Appellant's appeal from the district court absent a conviction as required by Ark. R. Crim. P. 36(a), holding that the district court illegally imposed court costs and probation in violation of Appellant's state and federal constitutional due process rights and his federal and state constitutional right to a trial.Appellant pled guilty to carrying a weapon in a publicly owned building. The district court ordered Appellant to pay court costs of $140 and told Appellant if there were no further charges within thirty days the charge would be dismissed. The court dismissed the case at the end of thirty days for lack of jurisdiction on the grounds that there was no underlying conviction. The Supreme Court reversed in part, holding that the court had jurisdiction to hear Appellant's challenge to the legality of his de facto sentence, and Appellant should have been heard on the merits. View "Gillette v. City of Fort Smith" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's convictions based on ineffective assistance of counsel, holding that errors in the proceedings below did not prejudice Defendant.In vacating Defendant's convictions the court of appeals concluded that trial counsel had been ineffective by failing to object to introduction and use of evidence about Defendant's silence while being arrested and by not objecting to the manslaughter jury instruction. The court ultimately concluded that Defendant was prejudiced by these instances of deficient performance. The Supreme Court reversed and reinstated the convictions vacated by the court of appeals, holding (1) trial counsel performed deficiently in failing to object to a certain jury instruction; and (2) assuming counsel was also deficient for not objecting to the State's use of Defendant's post-arrest, pre-Miranda silence against Defendant, Defendant failed to establish that there was a reasonable probability that the outcome of the trial would have been different without these errors. View "State v. Bonds" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court judge denying Defendant's motion to enforce a plea bargain, holding that the plea offer did not violate Defendant's rights to due process.Defendant was indicted along with two codefendants on two counts of murder in the first degree. Defendant was offered a "package deal" plea bargain under which he would have been able to plead guilty to manslaughter if his codefendant also agreed to the same plea. Defendant's codefendant refused the terms of the agreement. Defendant and his codefendant were tried and convicted of all charges. Defendant later filed a motion to vacate his convictions and to accept pleas to manslaughter, as the Commonwealth had originally offered, arguing that the condition attached to the plea offer violated his right to decide whether to accept the plea or go to trial. A superior court judge denied the motion. The Supreme Judicial Court affirmed, holding that the superior court did not err in denying Defendant's motion to enforce the plea bargain. View "Commonwealth v. DiBenedetto" on Justia Law

The Supreme Judicial Court remanded this matter to the county court for entry of an order dismissing the Commonwealth's gatekeeper petition filed under Mass. Gen. Laws ch. 278, 33E challenging the decision of the superior court judge granting Defendant's motion for postconviction relief and reducing his conviction, holding that the petition was untimely.Defendant served forty-four years in prison for his conviction of murder in the first degree. In 2020, Defendant filed a postconviction motion to reduce the verdict from murder in the first degree to murder in the second degree on the grounds that the Commonwealth's 1978 package plea offer violated his right to due process. The motion judge granted the motion and, in 2021, reduced the verdict to murder in the second degree. The Commonwealth filed a notice of appeal but did not file the gatekeeper petition until five and one-half months later, exceeding the thirty-day time limit set out in Mains v. Commonwealth, 433 Mass. 30, 36 n.10 (2000). After a remand, the single justice allowed the petition. The Supreme Judicial Court remanded the matter for entry of an order dismissing the Commonwealth's gatekeeper petition, holding that, with respect to filing deadlines, the Commonwealth is subject to the limitations established in Mains. View "Commonwealth v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the post-conviction relief (PCR) court determining that Appellant raised a colorable claim for ineffective assistance of trial counsel and ordering him to disclose certain materials, holding that the PCR court did not err in ordering the disclosure of the records.Appellant was found guilty of two counts of first degree murder and sentenced to death. In these PCR proceedings, the PCR court determined that Appellant's ineffective assistance of counsel claim in III(A)-III(E) of the PCR petition was colorable. The court then ordered Appellant to disclose materials associated with trial counsel's interviews of three of Appellant's family members who did not testify during the penalty phase of trial. Appellant filed a petition for special action, claiming that he should not have to disclose the records at issue. The Supreme Court affirmed, holding that there was good cause for the disclosure of materials associated with the interviews under Ariz. R. Crim. P. 32.6(b)(2). View "Naranjo v. Honorable Sukenic" on Justia Law