Justia Civil Rights Opinion Summaries

The Supreme Judicial Court affirmed Defendant's conviction of, among other charges, seventeen counts of sexual exploitation of a minor under the age of twelve, holding that a search of Defendant's smartphone did not violate Defendant's rights under the Fourth Amendment.On appeal, Defendant argued that the trial court abused its discretion when it declined to reach its argument that the warrant supporting the search of his cellphone was overbroad and violated the particularity requirement of the Fourth Amendment. The Supreme Judicial Court disagreed and affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress; and (2) Defendant's remaining arguments on appeal were without merit. View "Maine v. Jandreaud" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court dismissing rape charges against Defendant due to prejudicial preindictment delay, holding that Defendant failed to demonstrate actual prejudice. In 2017, Defendant was indicted on a multiple-count indictment alleging that Defendant had raped the complaining witness in 2005. The trial court dismissed the charges. The court of appeals affirmed, concluding that Defendant had demonstrated actual prejudice. The Supreme Court affirmed reversed after clarifying that, in determining whether unconstitutional preindictment delay has occurred in a rape case in which consent is at issue, the relevant inquiry is whether the defendant has shown actual prejudice, holding that Defendant failed to show actual prejudice under the standard set forth in State v. Jones, 69 N.E.3d 688 (Ohio 2016). View "State v. Bourn" on Justia Law

A police chase ended when the fleeing armed robber crashed into Plaintiff Thaer Mahdi’s tailor shop. Officers fired scores of bullets at the driver, and many hit the shop. The shop was badly damaged, and Mahdi was psychologically traumatized. Mahdi filed suit under 42 U.S.C. § 1983 against the Salt Lake City Police Department (SLCPD); the Unified Police Department (UPD); and four officers of the Utah Highway Patrol (UHP)—Superintendent Michael Rapich, Sergeant Chris Shelby, and Troopers Jed Miller and Jon Thompson. Plaintiff alleged: (1) the responding officers used excessive force in violation of his right to substantive due process under the Fourteenth Amendment; and (2) that the officers’ unconstitutional use of force resulted from Superintendent Rapich’s failure to train and supervise his subordinates and from the defendant law-enforcement agencies’ policies and customs, including their failure to properly train or supervise their employees. Defendants moved to dismiss Mahdi’s first amended complaint for failure to state any claims. In response, Mahdi moved for leave to file a second amended complaint. The United States District Court for the District of Utah denied the motion as futile and granted the defendants’ motions to dismiss. The court held that Mahdi had not adequately alleged that any officers violated his constitutional right to substantive due process and that in the absence of any such violation the police agencies also could not be liable under § 1983. Mahdi appealed, challenging the dismissal of his claims and denial of his motion for leave to file his second amended complaint. Finding no reversible error in the district court's judgment, the Tenth Circuit affirmed dismissal of plaintiffs claims and denial of his motion. View "Mahdi v. Salt Lake Police Department, et al." on Justia Law

The Supreme Court affirmed the decision of the court of appeal upholding the trial court's finding that trial may continue in Defendant's absence under Cal. Penal Code 1043(b)(2) because the absence was voluntary, holding that the trial court did not violate Defendant's constitutional rights by finding him to be voluntarily absent without conducting an evidentiary hearing regarding the circumstances of his absence.On appeal, the court of appeal concluded that substantial evidence supported the trial court's finding that Defendant voluntarily absented himself from trial and that the court's decision to proceed with trial rather than grant defense counsel's motion for a one-day continuance constituted harmless error. The Supreme Court affirmed, holding that substantial evidence supported the trial court's finding of voluntary absence under the circumstances of this case. View "People v. Ramirez" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the the trial court's decision ordering $1,615 in restitution for lost wages of the victim after Defendant pleaded guilty to two fifth-degree felony charges, holding that unless the loss of wages is directly and proximately caused by the offense, lost wages are not compensable as restitution.During the restitution hearing the victim testified that she was seeking restitution for lost wages relating to the wages she lost as a result of attending hearings for the criminal cases. The trial court ultimately ordered restitution for the lost wages of the victim. The court of appeals reversed. The Supreme Court affirmed, holding that the statutory meaning of restitution was not altered or expanded by Ohio Const. art. I, 10a, otherwise known as Marsy's Law, and that crime victims should receive restitution from those whose crimes that have directly and proximately caused them to suffer economic loss or detriment. View "State v. Yerkey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions and sentence for three counts of aggravated murder, six counts of aggravated robbery and other crimes and his sentence of life in prison, holding that a trial court errs in its evaluation of a defendant's lack of remorse when it considers that defendant's decision to waive allocution and remain silent at sentencing if the defendant exercised his right to a jury trial.Specifically, the Supreme Court held (1) the lower courts did not err in determining that Defendant did not waive his attorney-client privilege with regard to direct communications with his attorney; (2) even if this case presented circumstances in which the attorney-client privilege yielded to Defendant's right to confrontation, any error was not prejudicial; and (3) while the trial court erred in considering Defendant's decision to waive allocution and remain silent in determining whether he lacked remorse, the error was not prejudicial. View "State v. Brunson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for possession of a controlled substance with intent to deliver, holding that Iowa R. Evid. 5.106 and the common law doctrine of completeness cannot trump Iowa R. Evid. 5.402.Specifically, the Supreme Court held (1) Defendant's right to a jury drawn from a fair cross section of the community under Iowa Const. art. I, 10 was not violated; (2) Defendant's claims of ineffective assistance of counsel were not properly before the Court and must be raised in the first instance on postconviction review; (3) the district court did not abuse its discretion in excluding certain documents proffered by Defendant as a discovery sanction; (4) the district court did not abuse its discretion in showing the jury an abbreviated version of a law enforcement officer's bodycam video; and (5) the evidence was sufficient to support the convictions. View "State v. Tucker" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the juvenile court to transfer Appellant to adult court, holding that that court's decision to transfer Appellant to adult court was not supported by a preponderance of the evidence and that the juvenile court abused its discretion by relinquishing jurisdiction.After the juvenile court transferred jurisdiction over Appellant to the general division a jury found Appellant guilty of aggravated murder and murder for a killing that occurred when he was fourteen years old. The court of appeals affirmed the conviction, concluding that the juvenile court did not violate Appellant's constitutional right to due process by transferring his case to the adult court. The Supreme Court reversed, holding (1) the standard of proof applicable to discretionary-bindover proceedings is a preponderance of the evidence, and the state need not produce affirmative evidence of nonamenability; (2) a juvenile court need not consider all potential juvenile dispositions when balancing the factors weighing in favor of and against transfer; and (3) the juvenile court improperly relinquished jurisdiction in this case. View "State v. Nicholas" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion for postconviction relief without an evidentiary hearing and without first giving him an opportunity to respond to the State's reply, holding that the district court did not err in denying Defendant's motion for postconviction relief.Defendant was convicted of first degree murder, use of a weapon to commit a felony, and possession of a deadly weapon by a prohibited person. The Supreme Court affirmed. Thereafter, Defendant brought his motion for postconviction relief, raising several allegations of error. The district court rejected Defendant's claims without holding an evidentiary hearing. The Supreme Court affirmed, holding that there was no merit to Defendant's assignments of error. View "State v. Jennings" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant, following a jury trial, of disturbing the peace, holding that the district court did not err by reviewing his appeal only for plain error and that the record was insufficient to reach Defendant's argument that trial counsel was ineffective for failing to file a statement of errors.Defendant's counsel timely appealed Defendant's county court conviction and later filed a bill of exceptions but did not file a statement of errors within ten days of filing the bill of exceptions. Consequently, the district court reviewed the appeal only for plain error and affirmed the judgment below. The Supreme Court affirmed, holding (1) the district court did not err by limiting its review to plain error; and (2) the record was insufficient to reach Defendant's remaining argument. View "State v. Warren" on Justia Law