Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the district court summarily denying Defendant's second petition for postconviction relief, holding that the district court did not abuse its discretion in denying the petition without holding an evidentiary hearing.After a jury trial, Defendant was found guilty of first-degree felony murder and attempted first-degree premeditated murder, among other crimes. Defendant later filed the postconviction petition at issue, asserting that he was denied his Sixth Amendment right to a trial before an impartial jury and that his trial counsel and appellate counsel provided ineffective assistance. The district court summarily denied the petition as time barred and procedurally barred. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it summarily denied Defendant's second postconviction petition as untimely. View "White v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of first-degree sexual assault, holding that there was no error in the proceedings below.After a jury trial, Defendant was found guilty of sexual assault in the first degree and sentenced to imprisonment for less than ten nor more than fifteen years. On appeal, Defendant argued, among other things, that the district court violated his Sixth Amendment right to a public trial by partially closing the courtroom in light of the COVID-19 pandemic. The Supreme Court affirmed, holding (1) the district court did not violate Defendant's right to a public trial, and Defendant waived his right to a public trial; (2) Defendant waived any appellate argument regarding the admissibility of certain evidence; and (3) Defendant failed to prove that he was prejudiced by his trial counsel's alleged errors. View "Tarpey v. State" on Justia Law

Indiana Department of Correction (IDOC) Officers found Smallwood unresponsive in his prison cell. When he awoke, Smallwood assured a nurse that he had not taken any drugs, and reminded her that he is diabetic. Smallwood consented to a urinalysis and the results were negative. Dr. Talbot nonetheless ordered blood tests. Smallwood asked for a form to refuse the blood draw. Prison guards stated that he could not refuse, twisted his hands and wrists, placed him in a headlock, and held a taser to his chest while placing him in restraints. They held him down while a lab technician drew his blood. The blood test results revealed no illegal drugs. Smallwood alleges that the officers took him to an observation cell where they subjected him to physical and sexual abuse, then placed him in segregation. Smallwood filed a grievance but did not properly follow IDOC grievance procedures, which require that a prisoner first attempt to informally resolve the problem: a grievant need not seek informal resolution for allegations of sexual abuse. Smallwood filed a timely formal grievance, alleging sexual abuse. Smallwood’s grievance was rejected for failing to show that he had tried to informally resolve his complaint. Smallwood expressed an inability to understand the grievance process. A year later, Smallwood's attempt at informal resolution was rejected as untimely.Smallwood sued, 42 U.S.C. 1983. The district court granted the defendants summary judgment. The Seventh Circuit vacated, finding unresolved, material factual questions regarding Smallwood’s ability to make use of the grievance procedure. View "Smallwood v. Williams" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion to suppress evidence that he possessed an AR-15 assault rifle and many rounds of ammunition, holding that the district court correctly found that Defendant had no objectively reasonable expectation of privacy in the evidence at issue.At issue was whether Defendant showed an objectively reasonable privacy interest in the items seized from a case he had left in the home of his former domestic partner and their minor son. Law enforcement officers retrieved the case after responding to Defendant's former partner's domestic disturbance call when Defendant entered the residence, assaulted her, and left her and the child wounded. Defendant filed a motion to suppress, arguing that he had a subjective and objectively reasonable expectation of privacy in the case. The district court denied the motion. The First Circuit affirmed, holding that Defendant did not have an objectively reasonable expectation of privacy. View "United States v. John" on Justia Law

The Supreme Court affirmed Defendant's conviction of taking a controlled substance into a jail, a felony, and misdemeanor possession of a controlled substance, holding that there was no error in the convictions but remand was required for the limited purpose of correcting the written judgment and sentence.Specifically, the Supreme Court held (1) the evidence was sufficient for the jury to convict Defendant of voluntarily taking a controlled substance into a jail; (2) the evidence was sufficient for the jury to convict Defendant of knowingly possessing a controlled substance; and (3) this Court will not consider Defendant's constitutional claim because it was unpreserved and was not supported by relevant authority or cogent argument. View "Borja v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for voluntary manslaughter, holding that the circuit court committed no instructional error or constitutional violation in the underlying proceedings.On appeal, Defendant argued, among other things, that the district court erred in instructing the jury on a "stand your ground" defense, which confused the jury about his actual justification defense. The Supreme Court affirmed, holding (1) Defendant was not entitled to relief on his argument that the stand-your-ground defense wasn't in play, and thus that the stand-your-ground instruction was erroneously given; and (2) including the term "illegal activity" in the instructions did not violate Defendant's right to due process. View "State v. Ellison" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of first-degree rape and two counts of sexual contact with a child under the age of sixteen, holding that Defendant was not entitled to relief on his claims of error.After a jury trial, Defendant was found guilty of rape and sexual contact with a minor and sentenced to two consecutive sixty-year terms of imprisonment on the rape convictions. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant's motion for judgment of acquittal on the two rape charges; (2) the submission of the sexual contact charges to the jury did not violate the prohibition against double jeopardy; (3) there was no improper bolstering of witnesses at trial by either the circuit court or the prosecution; (4) the circuit court did not abuse its discretion by denying Defendant's motion for a new trial; (5) Defendant's sentence neither violated the constitutional prohibition against cruel and unusual punishment, nor did it constitute an abuse of discretion; and (6) no other prejudicial error occurred. View "State v. Manning" on Justia Law

In 1993, Clark entered Catlin's Galesburg apartment to commit robbery. Clark was 24 years old; Catlin was 89. Clark killed Catlin by cutting her throat, then robbed the apartment. Clark pled guilty but mentally ill to first-degree murder and robbery. Clark suffered from antisocial personality disorder, borderline personality disorder, and fetal alcohol syndrome. He had an IQ of 79 and the intellectual ability of a 13-14-year-old; he had been severely abused as a child and had an extensive criminal history. Clark was sentenced to 90 years of imprisonment for the murder, with a consecutive 15-year prison sentence for the robbery. The appellate court affirmed. In 2001 and 2012 Clark filed unsuccessful post-conviction petitions.In a 2018 motion for leave to file a successive postconviction petition, Clark challenged the constitutionality of his sentence as inconsistent with the Illinois Constitution's proportionate penalties clause. Clark argued that his sentence was the functional equivalent of a life sentence and that the circuit court failed to give sufficient weight to the characteristics of his intellectual disabilities and his young age as mitigation factors. The appellate court and Illinois Supreme Court affirmed the denial of relief.The proportionate penalties clause requires penalties to be determined with the objective of restoring the offender to useful citizenship and provides a limitation on penalties beyond those afforded by the eighth amendment. Precedent does not establish “cause” for relaxing the res judicata doctrine with respect to the issues Clark raised, which were decided on direct appeal. Clark also cannot establish prejudice under the cause-and-prejudice test by advancing a challenge to his sentence as it relates to his intellectual disabilities. “Neurological development was not a prospect for” Clark. View "People v. Clark" on Justia Law

A North Carolina social services department received a tip that Michael had engaged in inappropriate sexual contact with his four-year-old stepdaughter. Michael and his family subsequently moved to Kentucky, where Family Services told detectives that Michael was possibly sexually abusing the children. All three children were placed into foster care.Before each interview, Michael received and waived his Miranda rights. He admitted to touching “between [Dorothy’s] legs and in her vagina area.” The detectives later said: “You’re going to continue to not have any contact with your children just until you admit to everything.” Michael said that he’d “like to talk to a therapist or something other than social services.” The detectives continued, saying: “You’re going to continue the rest your [sic] life without seeing your children because you want to bottle this up.” During a second interview, Michael admitted to multiple acts of sexual abuse that he had previously denied.Michael unsuccessfully moved to suppress the incriminating statements as coerced under “Miranda.” The Kentucky Supreme Court found that four of the officers’ statements “were delivered in a threatening manner” but noted that Michael had already admitted to three instances of sexual abuse. That court, the federal district court, and the Sixth Circuit affirmed the denial of the motion to suppress. The Kentucky Supreme Court’s decision did not involve an unreasonable determination of the facts or an unreasonable application of clearly established federal law. View "Michael v. Butts" on Justia Law

While investigating a heroin distribution network involving Triplett and Collins, investigators obtained court-authorized wiretaps on 12 phones, 18 U.S.C. 2510. In copying files containing the recordings onto optical discs and sealing those discs, the government made mistakes, failing to seal the Phone 5 recordings and those from nine days on Phone 9. The government searched Collins's stash house, and recovered heroin, cutting agents, packaging, and 10 firearms.After the government disclosed its Phone 9 mistake, Collins moved to suppress those recordings and all subsequent recordings which relied on the improperly sealed disks to obtain additional authorizations. The government committed not to use at trial any Phone 9 recordings from the nine-day unsealed period. The district court denied the motion, finding that no later wiretap applications relied on unsealed recordings.The government later discovered and disclosed the Phone 5 error. Collins filed another motion to suppress. The government agreed not to use any Phone 5 recordings at trial but opposed the suppression of recordings from other phones. The district court denied the motion, finding that the government had not yet failed to immediately seal Phone 5 when it applied for another wiretap, that the government’s explanation concerning mechanical error was satisfactory, and that the applications for additional wiretaps did not rely on the recordings. Collins pleaded guilty to conspiracy, firearm, and money laundering offenses.The Seventh Circuit affirmed. The government’s voluntary suppression of the unsealed recordings indicated that they were not central to the case, which supported the government’s explanation. View "United States v. Collins" on Justia Law