Justia Civil Rights Opinion Summaries

Law enforcement responded to the defendant's home after his ex-girlfriend reported that he had threatened suicide during a phone call. The officers, aware of his history of alcohol abuse and mental health issues, entered his home without a warrant after he failed to respond to their attempts to contact him. Inside, an officer shot the defendant, believing he was armed. The defendant was charged with Assault on a Peace Officer.The District Court of the Third Judicial District denied the defendant's pretrial motions to dismiss and suppress evidence obtained from the warrantless entry. The court also denied his motion for a new trial based on an alleged Brady violation, where the defendant claimed the State failed to disclose that the officer who shot him had been shot at in a prior incident. The jury found the defendant guilty.The Supreme Court of Montana reviewed the case and affirmed the lower court's decisions. The court held that the officers' warrantless entry was justified under the community caretaker doctrine, given the exigent circumstances of a potential suicide. The court also found no Brady violation, as the undisclosed evidence about the officer's prior incident would not have changed the trial's outcome. The court concluded that the officers acted reasonably in their entry and subsequent actions, and the defendant's conviction was upheld. View "State v. Case" on Justia Law

A juvenile was indicted as a youthful offender for unarmed carjacking, unarmed assault with intent to rob, and assault and battery on an elder. The charges stemmed from an incident where the juvenile, after escaping from a secure facility, attacked an elderly man and stole his car. The juvenile pleaded guilty and was sentenced to two years in a house of correction followed by five years of probation.The Juvenile Court initially sentenced the juvenile to a house of correction, but after multiple probation violations, including missing appointments and being involved in new offenses, the court sentenced him to State prison. The juvenile appealed the sentence, arguing it was unlawful and that the judge did not adequately consider his well-being and the impact of recent literature on juvenile brain development.The Supreme Judicial Court of Massachusetts reviewed the case. The court found that the juvenile's sentence was lawful under G. L. c. 119, § 58, which allows for adult sentences, including State prison, for youthful offenders. The court determined that the Juvenile Court judge had appropriately considered the juvenile's criminal history, noncompliance with probation, and the need for public safety. The court also concluded that the judge did not need to make specific written findings on the impact of juvenile brain development literature.Additionally, the Supreme Judicial Court held that the Appellate Division of the Superior Court is authorized to review sentences to State prison imposed by the Juvenile Court on youthful offenders. This ensures that youthful offenders have the same procedural safeguards as adult criminal defendants. The court affirmed the juvenile's sentence and allowed for the appeal to the Appellate Division. View "Commonwealth v. Y." on Justia Law

Arthur Lee Burton was convicted of capital murder and sentenced to death in June 1998 for kidnapping, sexually assaulting, and strangling a woman in Houston, Texas. His conviction was affirmed by the Texas Court of Criminal Appeals, but his sentence was vacated and remanded for a new trial on punishment. Upon retrial, he was again sentenced to death, and this sentence was affirmed. Burton pursued state and federal habeas relief, which were all denied.Burton recently filed three challenges to his scheduled execution in Texas state court, including motions to withdraw his execution order and a habeas petition alleging constitutional violations. These challenges were rejected by the Texas Court of Criminal Appeals. Subsequently, Burton sought authorization from the United States Court of Appeals for the Fifth Circuit to file a successive federal habeas petition under 28 U.S.C. § 2244(b) and moved to stay his execution.The United States Court of Appeals for the Fifth Circuit denied both motions. The court held that Burton's petition was untimely, as it was filed well beyond the one-year limitation period prescribed by § 2244(d). Burton's reliance on Atkins v. Virginia and Moore v. Texas was insufficient to excuse the delay, as both cases were decided long before his current motion. The court also rejected Burton's arguments for equitable tolling and actual innocence, finding that he had not pursued his rights diligently and that his claims were not supported by extraordinary circumstances. Consequently, the court concluded that Burton failed to meet the requirements of § 2244 and denied his motion to stay execution. View "In re Burton" on Justia Law

Carl Langston was convicted of possessing a firearm in violation of 18 U.S.C. § 922(g)(1), the felon-in-possession statute. Langston argued that this statute is unconstitutional under the Second Amendment as applied to him, given his prior convictions for theft and drug trafficking under Maine law. He also challenged the district court's denial of his motion to suppress evidence obtained during a police stop and several sentencing decisions.The United States District Court for the District of Maine denied Langston's motion to suppress, finding that the police stop was based on reasonable suspicion. Langston then entered a conditional guilty plea, reserving the right to appeal the suppression ruling. At sentencing, the district court applied a four-level enhancement for possessing a firearm during a felony assault on an officer and denied Langston a reduction for acceptance of responsibility, citing his conduct during pretrial release.The United States Court of Appeals for the First Circuit reviewed Langston's claims. The court held that Langston's Second Amendment challenge failed under the plain-error standard because it was not "clear" or "obvious" that § 922(g)(1) is unconstitutional as applied to him. The court noted that the Supreme Court has consistently referred to felon-in-possession laws as "presumptively lawful."The court also upheld the district court's denial of the motion to suppress, agreeing that the totality of the circumstances gave rise to reasonable suspicion for the police stop. Additionally, the court found no plain error in the application of the sentencing enhancement for felony assault on an officer and ruled that the district court did not abuse its discretion in relying on hearsay evidence to conclude that Langston violated his pretrial release conditions. Finally, the court affirmed the denial of the acceptance-of-responsibility credit, noting the similarities between Langston's conduct at the time of his arrest and during his pretrial release.The First Circuit affirmed Langston's conviction and sentence. View "US v. Langston" on Justia Law

In 1993, Darrin Rick pleaded guilty to criminal sexual conduct involving four developmentally disabled girls and one seven-year-old boy. After failing to complete sex-offender treatment programs in prison, Hennepin County petitioned to civilly commit him as a "sexually dangerous person." Three psychologists, including two appointed by a Minnesota district court, agreed that Rick met the criteria for commitment. Consequently, he was committed to the Minnesota Sex Offender Program. In 2007, the Minnesota Supreme Court declined further review of his case. Years later, new expert reports suggested that the actuarial tools used to justify his commitment had overestimated his risk of recidivism.Rick filed a federal habeas petition, arguing that the new evidence showed he was "actually innocent" of being a sexually dangerous person. The United States District Court for the District of Minnesota entertained the petition under the actual-innocence exception, finding that the reliance on outdated expert reports and actuarial data violated his due-process rights. The court granted habeas relief, allowing Rick to bypass the one-year statute of limitations for filing the petition.The United States Court of Appeals for the Eighth Circuit reviewed the case and focused on whether the actual-innocence exception could apply to civil commitments. The court concluded that the exception, traditionally used in criminal cases to address wrongful convictions, does not extend to civil commitments. The court emphasized that the exception is meant for cases involving criminal guilt or innocence, not predictions of future dangerousness. Consequently, the Eighth Circuit reversed the district court's grant of habeas relief and remanded the case for denial of Rick's petition. View "Rick v. Harpstead" on Justia Law

Luke LeFever was involved in a series of criminal activities following a roadside encounter with Deputy Castellanos of the Dawson County Sheriff’s Department. LeFever lunged at the deputy, was tased twice, and fled the scene. He attempted to steal multiple vehicles, broke into a home, assaulted a resident, and led officers on a high-speed chase, driving recklessly and endangering public safety. The chase ended when officers fired 60 to 70 rounds at LeFever’s vehicle, resulting in serious injuries.The United States District Court for the District of Nebraska denied LeFever’s requests for appointed counsel and granted summary judgment in favor of the defendants. The court found that Deputy Castellanos had probable cause for the initial arrest and that the use of force, including the tasings and the shot fired at the utility vehicle’s wheel, was reasonable. The court also found that the report of “shots fired” by Deputy Castellanos did not rise to the level of a constitutional violation. Additionally, the court ruled that the actions of the other officers during the chase and subsequent shooting were reasonable under the circumstances and that qualified immunity applied.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court agreed that the use of force by Deputy Castellanos and the other officers was reasonable and that qualified immunity protected the officers from liability. The court also found no abuse of discretion in the district court’s denial of LeFever’s requests for appointed counsel, noting that the facts and legal issues were clear and uncomplicated, and that the district court had provided adequate assistance to LeFever in managing his case. View "LeFever v. Castellanos" on Justia Law

Four condemned inmates challenged the constitutionality of a South Carolina statute that provides three methods of execution: electrocution, lethal injection, and firing squad. They argued that the statute violates the South Carolina Constitution's prohibition against cruel, corporal, or unusual punishment.The Richland County Circuit Court ruled in favor of the inmates, declaring the statute unconstitutional. The court found that electrocution and firing squad methods violate the state constitution's prohibition on cruel, corporal, or unusual punishment. It also found the statute's provision allowing inmates to choose their method of execution unconstitutionally vague and an improper delegation of authority. The court further ruled that the retroactive application of the amended statute violated ex post facto prohibitions.The South Carolina Supreme Court reversed the lower court's decision. The court held that the statute does not violate the South Carolina Constitution. It found that electrocution is not unconstitutionally cruel, corporal, or unusual, noting that the inmates did not meet their burden of proving that electrocution causes unnecessary and excessive pain. The court also held that lethal injection, as conceded by the inmates, is constitutional if properly administered. Regarding the firing squad, the court found it to be a relatively quick and painless method of execution, thus not cruel or unusual.The court also addressed the inmates' claims about the statute's vagueness and improper delegation of authority, finding that the term "available" is not unconstitutionally vague and that the statute does not unlawfully delegate authority to the Director of the Department of Corrections. The court emphasized that the statute's provision allowing inmates to choose their method of execution is a constitutional innovation aimed at making the death penalty less inhumane. The court concluded that the statute is constitutional in its entirety. View "Owens v. Stirling" on Justia Law

Carlos Martinez, a former federal prison guard, was convicted of multiple charges related to the repeated rape of an inmate, referred to as "Maria," at the Metropolitan Detention Center in Brooklyn, New York. Maria testified that Martinez raped her on five occasions, using both physical force and threats to coerce her. The jury found Martinez guilty of several counts, including sexual abuse by threats or fear, deprivation of civil rights, and aggravated sexual abuse for one of the rapes.The United States District Court for the Eastern District of New York sentenced Martinez to ten years in prison. Martinez challenged the sufficiency of the evidence for two counts, arguing that the jury's acquittals on other counts indicated they did not believe Maria's testimony. The government cross-appealed, arguing that the ten-year sentence was procedurally and substantively unreasonable.The United States Court of Appeals for the Second Circuit reviewed the case. The court rejected Martinez's sufficiency challenge, affirming that the jury was entitled to credit Maria's testimony that Martinez physically restrained her during one of the rapes. The court also noted that inconsistent verdicts do not undermine a conviction.The court found the district court's sentence procedurally unreasonable due to several errors: relying on clearly erroneous factual findings, misapprehending the law, and failing to sentence Martinez based on all his convictions. The district court had improperly treated the convictions for sexual abuse by threats or fear as equivalent to sexual abuse of a ward, and it had given undue weight to its doubts about the jury's guilty verdicts.The Second Circuit held that the ten-year sentence was also substantively unreasonable because it did not adequately reflect the seriousness of Martinez's offenses. The court affirmed the judgment of conviction, ordered that a specific paragraph in the Presentence Investigation Report be stricken, and remanded the case for resentencing consistent with its opinion. View "United States v. Martinez" on Justia Law

Jamal L. Smith was convicted of first-degree intentional murder while committing a drive-by shooting, among other charges, for the fatal shooting of Jay Boughton during a road rage incident. Smith was driving a rented Chevrolet Suburban with two passengers from Chicago to Minnesota. During the trip, Smith brandished a pistol in a video, and later, the Suburban was involved in a road rage incident where Smith allegedly pointed a gun at another driver. On the night of the murder, Smith's Suburban paced Boughton's truck on the highway before a single .45-caliber bullet was fired from the Suburban, striking Boughton in the neck and causing his death.The Hennepin County District Court denied Smith's motion to dismiss the indictment based on the racial composition of the grand jury and admitted evidence of Smith's prior bad acts under the immediate episode exception. A jury found Smith guilty, and he was sentenced to life with the possibility of release for the murder charge and a concurrent sentence for possession of ammunition or a firearm after being convicted of a crime of violence. Smith appealed, arguing judicial bias, ineffective assistance of counsel, improper jury pool composition, erroneous admission of prior bad acts, and insufficient evidence to prove he fired the fatal shot.The Minnesota Supreme Court reviewed the case and found that Smith failed to demonstrate judicial bias or ineffective assistance of counsel. The court also held that Smith did not show that Black persons were underrepresented in the jury pool or that any underrepresentation resulted from systematic exclusion. The court ruled that the district court did not abuse its discretion in admitting evidence of Smith's prior bad acts, as it was admissible under the Spreigl exception or as direct or corroborative evidence of a charged crime. Finally, the court concluded that the only reasonable inference from the circumstances proved was that Smith fired the fatal shot. The court affirmed the judgment of convictions. View "State v. Smith" on Justia Law

Harry Malbry, who was convicted in 1991 for committing lewd acts on a child, sought to terminate his obligation to register as a sex offender. His offenses involved daily sexual abuse of a five-year-old girl over three years. After serving a six-year prison term, he was released and required to register annually as a sex offender. In 2022, Malbry petitioned the trial court to end his registration duty, citing his crime-free record since 1991 as evidence that he no longer posed a danger to the community.The Superior Court of Los Angeles County denied Malbry’s petition, emphasizing that community safety would be significantly enhanced by his continued registration. The court highlighted the persistence and severity of his offenses, his lack of insight into his actions, and his exploitation of a trusting child. The court also noted that Malbry had not sought any professional help or therapy to address his behavior.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case and affirmed the lower court’s decision. The appellate court considered several factors, including the nature and facts of the offense, the age of the victim, and Malbry’s lack of participation in a certified sex offender treatment program. The court also noted that legislative changes, such as the enactment of section 288.7, which mandates lifetime registration for similar offenses, underscored the heightened danger posed by Malbry’s conduct. The court concluded that continuing Malbry’s registration as a sex offender significantly enhances community safety, given the severity and persistence of his past offenses and his lack of demonstrated rehabilitation. View "People v. Malbry" on Justia Law