Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission denying Appellant's claim for benefits from the Second Injury Fund, holding that the Commission did not abuse its discretion and that the Commission's findings were supported by substantial evidence.On appeal, Appellant challenged the Commission's decision to overrule his motion to conduct additional discovery and submit additional evidence after the Supreme Court's decision in Cosby v. Treasurer of Missouri, 579 S.W.3d 202 (Mo. banc 2019) interpreting Mo. Rev. Stat. 287.220 and the Commission's finding that Appellant failed to show any medically documented qualifying preexisting disabilities that qualified him for benefits. The Supreme Court affirmed, holding (1) the Commission did not abuse its discretion in overruling Appellant's motion to conduct additional discovery and submit additional evidence; and (2) the Commission's findings were supported by substantial and competent evidence. View "Dubuc v. Treasurer of State of Missouri Custodian of Second Injury Fund" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of conspiracy to commit export violations, visa fraud, making false statements to federal agents, money laundering, and smuggling, holding that the search of Defendant's laptop and cellular phone was a constitutional search.Defendant, a Chinese national, was stopped by Customs and Border Patrol agents upon his arrival to the United States after a trip to China. Agents seized Defendant's electronic devices for a further search. Defendant was indicted based on evidence during the warrantless search of his devices. The First Circuit affirmed, holding that neither probable cause nor a warrant was required for the search in this case to be lawful. View "United States v. Qin" on Justia Law

Philadelphia officers Kling and Nestel stopped Gallman for running a stop sign and recovered a firearm from Gallman’s passenger. Officer Rosinski moved Gallman to the patrol car. Kling discovered a firearm near Gallman's driver’s seat. Gallman, previously convicted of first-degree robbery, was charged with possession of a firearm by a felon, and unsuccessfully moved to suppress the evidence. During the hearing, the government informed the court that there was an open Internal Affairs Division (IAD) investigation about Rosinski’s failure to call a supervisor to a traffic stop. The government also supplied an IAD memorandum regarding a racial profiling complaint against Rosinski and Stout, who was also present at the Gallman stop. That matter was closed before Gallman’s arrest; the allegation was unfounded.Following COVID-19 protocol, Gallman's trial was conducted in one courtroom and video-streamed to another where the public and Gallman’s family were seated. Outside the presence of the jury, the court asked Gallman whether he wanted to stipulate his prior conviction and discussed the pending Rosinski IAD investigation.The Third Circuit affirmed Gallman’s conviction. Closing the video stream during the sessions away from the jury did not constitute reversible error; it was not “clear under current law” that the Sixth Amendment public-trial right applied to those proceedings. The closures here were brief and resulted from pandemic protocol challenges rather than any substantive decision. Some of the topics discussed were also discussed in open court. Nor did the court abuse its discretion in admitting evidence of Gallman’s prior conviction. View "United States v. Gallman" on Justia Law

Detective Kopchak, investigating drug trafficking, observed Rivers leaving a house, driving a red Nissan Ultima to sell drugs to an informant, and returning to the same house. After days of surveillance, investigators determined that Rivers lived at the house, and executed a search warrant. Kopchak again observed the Nissan, looked through its window, and allegedly observed a cigar wrapper, a piece of paper in the center console, and a small plastic bag that he identified as “a bag of dope.” Lieutenant DiPenti verbally indicated that he also saw the “bag of dope.” Officers found Loines and others in Rivers’ residence and read them their Miranda rights. Loines volunteered that car keys, belonging to the Nissan, were his. The car was towed for an inventory search. Officers took a picture of the car’s center console, showing a small plastic bag underneath a cigar wrapper, with a lottery ticket beside it. Officers searched the vehicle and found a firearm, two bags of suspected narcotics, and a scale. Police did not obtain a warrant to search the automobile.Loines, charged with drug crimes under 21 U.S.C. 846, 841(a)(1), 841(b)(1)(C), and a firearm offense, 18 U.S.C. 924(c)(1)(A), unsuccessfully moved to suppress the evidence seized from his vehicle. The Sixth Circuit reversed; the “bag of dope” was not in plain view, there was no probable cause to search the vehicle, and the government did not satisfy the automobile exception to the warrant requirement. View "United States v. Loines" on Justia Law

Around 11:14 a.m., Deanna called 911, claiming that she feared for her life because her husband was “threatening [her] with guns,” was on “new medication from the doctor,” and had “tremendous guns” in their house. Deputy Swick arrived knowing that Puskas had weapons and observed stuff scattered across the lawn and Puskas holding a rifle. Puskas put the rifle down. Swick told Puskas multiple times to get on the ground. Puskas walked toward the house instead. He stopped, picked up a bag, and pulled out a shotgun, and told Swick to “run.” From his vehicle, Swick reported that Puskas had a shotgun. Puskas dropped the shotgun. Sunbury Police Officers arrived, tried to verbally engage Puskas, and requested a negotiator. Deputy Gibson arrived, with a canine, Cash. Puskas ignored the officers and continued meandering around the yard, tossing a shirt at the officers. Gibson released Cash. Puskas ran toward the house. Cash initially targeted the shirt. Gibson refocused Cash. The officers followed Cash with their guns drawn. Puskas darted behind a tree and picked up a pistol case. Someone yelled, “he’s got a pistol.” Puskas pulled out a revolver. The officers shot him at 11:38 a.m. Puskas died at the hospital.Deanna sued under 42 U.S.C. 1983, alleging excessive force in deploying Cash and shooting Puskas. The Sixth Circuit affirmed summary judgment in favor of the officers. Body camera footage confirms that their actions were reasonable under the circumstances. View "Puskas v. Delaware County., Ohio" on Justia Law

The Supreme Judicial Court affirmed the decision of the juvenile court judge denying Juvenile's motion to suppress evidence of a seized firearm on the grounds that police did not have reasonable suspicion to stop her, holding that the juvenile court did not err.As a result of a report about kids displaying a firearm outside a housing complex four police officers were dispatched to the complex. One officer noticed Juvenile walking along the street who kept adjusting the waistband of her pants. The officers stopped her, conducted a patfrisk, and discovered a loaded firearm in Juvenile's waistband. After her motion to suppress was denied Juvenile entered a conditional guilty plea to four firearms-related offenses. The Supreme Judicial Court affirmed, holding that the officers had reasonable suspicion that Juvenile was carrying an illegal firearm in her waistband, and therefore, the stop and pat frisk of Juvenile comported with constitutional requirements. View "Commonwealth v. Karen K." on Justia Law

The Supreme Court affirmed Defendant's conviction for the first-degree premediated murder of her estranged husband, holding that Defendant was not entitled to reversal on her claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion or violate Defendant's right to confrontation under the Sixth Amendment by placing limits on cross-examination; (2) the district court did not err by denying Defendant's motion for judgment of acquittal at the close of the State's evidence because the State presented sufficient evidence to establish a prima facie case of first-degree premeditated murder against Defendant; and (3) sufficient evidence supported Defendant's conviction for first-degree premeditated murder. View "State v. Frantz " on Justia Law

Indicted in Florida and Connecticut, Villa cooperated with prosecutors. Meanwhile, Villa was indicted in Kentucky. Villa was unaware of those charges when he pled guilty (represented by Perez) in the other cases. Those courts sentenced him to concurrent terms of 140 and 98 months. The Kentucky prosecutor, Judd, emailed Meier (Villa’s attorney) a proposed plea agreement, which assumed no further cooperation but stated that if Villa were willing to cooperate further, Judd would consider recommending a concurrent sentence. Later, Villa spoke to Meier and Perez in a three-way phone call. Meier allegedly did not mention Judd’s offer. Villa met with Judd, an FBI agent, and an investigator. Judd told Villa that the government wanted him to testify against a co-defendant but did not mention the possibility of a cooperation agreement. Villa pled guilty without an agreement and was sentenced to 77 months, consecutive to his other sentences.Villa moved to set aside his sentence, citing ineffective assistance of counsel. When Meier provided the case file, Villa allegedly discovered that Judd had mentioned a cooperation agreement and a concurrent sentence. Villa moved to amend his 28 U.S.C. 2255 motion, attaching an affidavit in which he said that Meier never told him about Judd’s offer and that he would have accepted it, plus an affidavit from Perez. The government submitted an affidavit from Meier, asserting that he told Villa about Judd’s offer.The district court denied Villa's motion, reasoning that Judd’s wanting Villa to testify against Rodriguez-Hernandez should have put Villa on notice of a potential agreement. The Sixth Circuit vacated and remanded for an evidentiary hearing. The district court expected too much of an uncounseled defendant conversing in his second language with a federal prosecutor. Nothing about Villa’s meeting with Judd resolved the factual dispute presented by the affidavits. View "Villa v. United States" on Justia Law

O’Connor is the parent of John. When John was 14 years old, O’Connor allegedly “supplied excessive amounts of alcohol to her son and his minor friends to the point where minors would vomit, be unable to stand, and fall unconscious. When these minors were extremely intoxicated from the alcohol, she encouraged them to engage in sexual activity with each other, facilitated sexual encounters, and watched some of these sexual encounters.” O’Connor also helped the minors leave their homes at night without their parents’ knowledge, communicating with them via Snapchat or text message and picking them up down the street from their homes.O’Connor is currently held in pretrial custody on charges of 39 offenses involving 15 minor victims. The trial court denied release on bail due to the seriousness of the charged offenses, which include 12 counts of felony child endangerment (Penal Code 273a(a)), along with evidence showing that less restrictive conditions of release on bail would not protect the public or the minor victims. O’Connor filed a habeas petition, contending that she was entitled to bail as a matter of law. On remand from the California Supreme Court, the court of appeal again denied the petition, concluding that O’Connor was charged with qualifying felony offenses involving an act of violence on another person within the meaning of California Constitution, article I, section 12(b). View "In re O'Connor" on Justia Law

The Supreme Court held that a law enforcement officer's act of shining a spotlight for illumination does not ipso facto constitute a detention under the Fourth Amendment, but rather, the proper inquiry requires consideration of the totality of the circumstances, including the use of the spotlight.Defendant was charged with drug offenses after a law enforcement officer conducted a search of the car he was driving. At issue was whether the officer engaged in a consensual encounter when he pulled behind Defendant's car and turned on his spotlight. The court of appeal concluded that spotlight illumination and approach on foot did not "manifest a sufficient show of police authority to constitute a detention." The Supreme Court agreed, holding (1) under the totality of the circumstances, Defendant was not detained by the officer's use of a spotlight; and (2) remand was appropriate for a new factual finding as to whether the officer's detention of the vehicle's female passenger effectuated a detention of Defendant. View "People v. Tacardon" on Justia Law