Justia Civil Rights Opinion Summaries

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

The Supreme Court affirmed the judgment of the district court convicting Defendant, after a jury trial, of sexual assault in the first degree, holding that the district court did not abuse its discretion in prohibiting Defendant from questioning the complaining witness, J.K., about her prior allegation against a doctor.On appeal, Defendant argued that the district court erred by prohibiting from asking J.K. about an allegation she made against her prenatal doctor regarding inappropriate touching during the course of a prenatal examination. The Supreme Court affirmed, holding that the district court's decision to exclude the evidence did not violate Defendant's constitutional right to confront his accuser. View "State v. Ali" on Justia Law

The Supreme Judicial Court affirmed the judgment of a single justice of the court denying Petitioner's petition pursuant to Mass. Gen. Laws ch. 211, 3, holding that the single justice did not err or abuse his discretion in denying relief.Petitioner was charged with assault and battery on a family or household member, malicious destruction of property, and intimidation of a witness. After Petitioner unsuccessfully filed several motions to dismiss he filed his Mass. Gen. Laws ch. 211, 3 arguing that the complaint had not been signed by the correct police officer and proceeding to trial on the basis of a nonconforming criminal complaint would violate his due process rights. The previously unsigned complaint was subsequently signed and sworn in open court. Thereafter, the single justice denied Petitioner's Mass. Gen. Laws ch. 211, 3 petition. The Supreme Judicial Court affirmed, holding that there was no reason Petitioner could not obtain his desired relief in a direct appeal. View "Schajnovitz v. Commonwealth" on Justia Law

In August, 1993, Fields, having spent the day drinking alcohol and smoking marijuana, got into a fight with Burton. Burton lived in a duplex owned by Horton. That night, Burton found that she was locked outside. Fields appeared, with a knife, and broke a window in the duplex. Both Fields and Burton fled before police arrived, having been called by a neighbor. Officers found Fields in Horton’s residence, a block away, in possession of Horton’s jewelry, saying that he had killed Horton, who was dead in her bedroom. At his second trial, the prosecution argued that Fields broke into Horton’s residence through a storm window, murdered her in the bedroom, and started burglarizing the residence shortly before police arrived. To test the plausibility of that theory, the jury conducted an experiment using a flat-tipped knife submitted into evidence to remove a cabinet door in the jury room (in place of the storm window). Satisfied with the outcome, the jurors convicted Fields of intentional murder and sentenced him to death.The Sixth Circuit granted Fields conditional habeas corpus relief. The jury improperly considered extrinsic evidence in violation of the Fifth and Sixth Amendments. Given the centrality of the issue, the inherently prejudicial nature of the experiment, and the lack of overwhelming evidence of guilt, the jury experiment had a “substantial and injurious effect or influence in determining the jury’s verdict.” View "Fields v. Jordan" on Justia Law

On three occasions, Harrison sold methamphetamine to B.B., a confidential informant who recorded the transactions on video. Police arrested Harrison. B.B. died before trial and was unable to testify about the controlled buys. As a substitute, the government played B.B.’s videos of the transactions for the jury, over Harrison’s objection. Recordings of statements from B.B. to law-enforcement personnel were excluded on Sixth Amendment grounds.The jury convicted Harrison on multiple drug counts and being a felon in possession of a firearm. The district court found that Harrison’s prior conviction for complicity to commit murder was a serious violent felony and that Harrison was subject to a sentencing enhancement, raising his mandatory minimum on the possession-with-intent-to-sell count from 10 years to 15. 21 U.S.C. 841. Harrison was sentenced to 15 years’ imprisonment. The Sixth Circuit affirmed, rejecting arguments that the introduction of B.B.’s videos violated his Sixth Amendment right to confront his accusers and the district court improperly characterized his prior conviction as a violent felony at sentencing. B.B.’s statements in the videos were not offered for their truth and were not hearsay. Complicity to commit murder always requires the use of physical force, because murder always requires the use of physical force. View "United States v. Harrison" on Justia Law

Investigating drug trafficking based on the report of a confidential informant, the police entered the homes of both Alexander and his girlfriend, without search warrants. Officers entered Alexander’s home and secured the premises, then waited to conduct a search until a warrant was issued. At Alexander’s girlfriend’s home, they secured the premises and were applying for a warrant, which was all but certain to issue, when they received what they understood as consent to a search. Alexander was charged with possession with intent to distribute 28 grams or more of cocaine base, 21 U.S.C. 841(a)(1), (b)(1)(B); possession with intent to distribute cocaine; possession of a firearm in furtherance of a drug trafficking crime, 18 U.S.C. 924(c)(1)(A)(i); and possession of a firearm by a prohibited person, 18 U.S.C. 922(g)(1), 924(a)(2).The Third Circuit affirmed the denial of Alexander’s motion to suppress, citing the inevitable discovery exception to the exclusionary rule. There was probable cause to believe Alexander had cocaine and drug-dealing paraphernalia in both houses. Officers had reason to believe that Alexander had been tipped off so that evidence of drug dealing would be imminently destroyed. Exigent circumstances justified the officers entering without a warrant; the search of Alexander’s residence was valid because a warrant was properly issued. View "United States v. Alexander" on Justia Law

In July 2017, Cross was charged with murder. He remained in custody through trial. At a preliminary hearing, the court ordered Cross to respond to the state’s motion for pretrial discovery within 30 days, with written notice of any defenses. The court granted Cross six continuances, attributing each delay to Cross for purposes of the 120-day statutory speedy-trial term. On July 16, 2018, the defense indicated "ready for trial" and demanded a speedy trial. Trial was set for September 24, 2018; the 70-day period after July 16 would be attributable to the state. On August 21, Cross first raised an alibi defense. The state argued that the alibi would have been known to Cross for a year, that the late disclosure would require further investigation, and that the time from July 16 to September 24 should be attributable to Cross The court attributed the 36-day period before August 21 to the state but attributed the subsequent 34-day period to Cross. The court set a new trial date of November 6; the delay after September 24 was attributed to the state. Defense counsel did not object to a statement that the speedy-trial term would run on November 29.On appeal following his conviction, Cross first argued that his statutory speedy-trial rights were violated. The appellate court and Illinois Supreme Court rejected his argument that there is no delay unless a trial date is postponed. Cross received effective assistance of counsel. View "People v. Cross" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder and his sentence of death, holding that, while error occurred in this case in the form of repetitive crime scene photos, the prosecutor's misstatements, and sentencing opinion errors, none of the errors resulted in prejudicial error.After a jury trial, Defendant was found guilty of the aggravated murders of his four-year-old daughter, C.D., and her mother, Nicole Duckson, with accompanying death-penalty specifications. The court sentenced Defendant according to the jury's recommendation of a sentence of death for the aggravated murder of C.D. The court then sentenced Defendant to life without parole for the aggravated murder of Nicole. The Supreme Court affirmed but remanded the case, holding (1) Defendant received a fair trial, and none of the errors in this case, when considered either individually or cumulatively, resulted in prejudicial error; (2) the overwhelming evidence established Defendant's guilt; and (3) the case must be remanded for the trial court to issue a nunc pro tunc entering confirming the September 14, 2019 judgment entry and the September 16, 2019 entry to the sentence that was imposed at the sentencing hearing. View "State v. Garrett" on Justia Law