Justia Civil Rights Opinion Summaries

Roldan was convicted of criminal sexual assault. Roldan, then 21, allegedly had sex with an intoxicated 16-year-old noncitizen. The Illinois Appellate Court later reversed the conviction, concluding that the state did not prove that Roldan knew the victim was too intoxicated to consent.Drawing upon information he learned after trial, Roldan sued Cicero, Illinois police officers under 42 U.S.C. 1983, alleging that the officers failed to disclose an agreement to help the victim apply for an immigration benefit—a U visa—in exchange for her testimony. The officers moved to dismiss the complaint based on qualified immunity. The district court denied the motion on grounds that the Supreme Court’s 1972 “Giglio” decision and related cases clearly established the officers’ duty to disclose the agreement. The Seventh Circuit affirmed that immunity is inappropriate at this early stage but for a different reason. Qualified immunity hinges on a fact that Roldan did not flesh out in his complaint: whether the police officers informed the prosecution about the U-visa agreement with the victim. If the police did, they cannot be liable, for the ultimate disclosure obligation would have rested with the prosecutors. View "Roldan v. Stroud" on Justia Law

Shaw’s pro se complaint alleged that three times in 2018 he needed to use the handicapped bathroom but was unable to because nondisabled prisoners occupied it. Shaw is confined to a wheelchair and incontinent. Each instance ended with Shaw defecating on himself. Shaw alerted prison staff, who asserted that they could not control what toilets other inmates used or reserve the handicapped stall solely for his use. Shaw’s complaint alleged violations of the Americans with Disabilities Act (ADA), the Rehabilitation Act, and constitutional rights.Before allowing the defendants to be served and fulfilling the screening obligation imposed by 28 U.S.C. 1915A(a), the district court addressed the ADA and Rehabilitation Act claims and concluded that Shaw, while unquestionably a qualified person with a disability, failed to allege a denial of access to any prison service and instead complained only about an “inconvenience” of prison life. The Seventh Circuit reversed. Shaw’s allegations suffice to state claims under the ADA and Rehabilitation Act; he will still need to prove his claim and show deliberate indifference. View "Shaw v. Kemper" on Justia Law

The Court of Appeals affirmed the judgment of the court of special appeals reversing the decision of the post-conviction court determining that Appellant's trial counsel provided ineffective assistance by failing to object to certain incomplete or missing jury instructions, holding that defense counsel's failure to object to a "CSI effect" voir dire question did not render her performance constitutionally deficient.In 2007, Appellant was convicted by a jury of murder. In 2010 and 2011, the Court of Appeals held in three cases that a CSI effect message from the bench constituted reversible error. In 2014, Appellant filed a pro se petition for post-conviction relief arguing that he received ineffective assistance of counsel based on his counsel's failure to object to the trial court's CSI effect voir dire question. In 2020, the post-conviction court granted the petition for post-conviction relief and ordered a new trial. The court of special appeals reversed. The Court of Appeals affirmed, holding that under the professional norms that existed at the time of Appellant's trial, defense counsel's failure to object to a CSI-effect voir dire question did not render her performance constitutionally deficient. View "McGhee v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for habeas corpus, holding that the circuit court did not err in denying the petition after holding an evidentiary hearing.Appellant was convicted of three counts of first-degree rape and one count of sexual contact with a child under sixteen for raping and having sexual contact with his four-year-old autistic daughter. The conviction was affirmed on appeal. Appellant later filed a petition for habeas corpus alleging several instances of ineffective assistance of counsel. After a hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish that his trial counsel provided ineffective assistance. View "Spaniol v. Young" on Justia Law

The Supreme Court held that, for double jeopardy purposes, the unit of prosecution for a violation of Minn. Stat. 243.166, subd. 3(a), which requires a predatory offender to register "with the corrections agent as soon as the agent is assigned to the person," is the assignment of a corrections agent, thus affirming in part and reversing in part the decision of the court of appeals.Defendant was convicted and sentenced on seven separate occasions between 2004 and 2018 for failing to register under subdivision 3(a). In August 2019, Defendant refused to sign required paperwork presented by his new corrections agent. In September 2019, Defendant again refused to sign the paperwork presented by a special agent of the Minnesota Bureau of Criminal Apprehension assigned by Defendant's corrections agent. The State charged Defendant with two counts of failing to register under subdivision 3(a). Defendant moved to dismiss the charges on double jeopardy grounds. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Defendant's earlier convictions did not bar prosecution of the August 2019 offense; but (2) the September 2019 offense was barred. View "State v. Larson" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony shoplifting after a jury trial, holding that the district court did not err or abuse its discretion.On appeal, Defendant argued that his right to a speedy trial was violated and that the district court abused its discretion by allowing a juror who inadvertently saw a video about the trial on social media to remain on the jury. The Supreme Court disagreed and affirmed, holding (1) Defendant was not denied his right to a speedy trial under Wyo. R. Crim. P. 48 or the Sixth Amendment; and (2) Defendant waived any claim related to alleged juror impropriety by not objecting before the return of the verdict. View "Vlahos v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder with death specifications and her sentence of death, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant raised sixteen propositions of law. The Supreme Court rejected each proposition of law, holding, among other things, that (1) there was no prejudicial error in the trial court's evidentiary rulings; (2) Defendant was not entitled to relief on his ineffective assistance of counsel claims; (3) although significant mitigating factors existed, the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt; and (4) the death sentence was appropriate and proportionate. View "State v. Drain" on Justia Law

Gussie was charged with fraud. Virgin Islands prosecutors later learned one of the grand jurors might have been a victim of Gussie’s scheme. The government obtained a superseding indictment from a new grand jury about a year later. A jury convicted Gussie, who was sentenced to 45 months in prison.The Third Circuit affirmed. The superseding indictment cured any potential defect, making any error harmless. Gussie suffered no prejudice facing charges under the validly returned superseding indictment. The court rejected Gussie’s arguments that allowing an alleged victim to sit on the grand jury considering an indictment against her was “so prejudicial” that it caused the grand jury “no longer to be a grand jury,” requiring dismissal with prejudice and that the superseding indictment exceeded the statute of limitations because the original indictment was not validly pending when the superseding indictment returned. While Gussie claimed the government knew the juror was a possible victim and permitted the juror’s participation, the district court found no supporting facts for that assertion. View "United States v. Gussie" on Justia Law

Rodriguez was arrested for domestic violence. He gave the police his brother’s name and date of birth. He was convicted and sentenced to probation. Although the court had learned Rodriguez’s real name, the judgment of conviction listed “Ely M. Martinez” as an alias for Rodriguez and listed Martinez’s date of birth. Rodriguez failed to report for probation. An arrest warrant was issued with the same information as the judgment. Years later, police arrested Martinez for an unrelated offense and booked him in the Milwaukee County Jail on a Wednesday. The next day, the district attorney decided not to press charges but a warrant check revealed the outstanding warrant for Rodriguez. Although jail officials made efforts to positively identify the detainee, he was not released until Tuesday morning.Martinez sued under 42 U.S.C. 1983, claiming due process violations. The district court entered summary judgment for the defendants, concluding that Martinez’s detention was relatively brief and Martinez could not show that the defendants failed to investigate or ignored evidence of his innocence. The Seventh Circuit affirmed. Although the defendants could have improved aspects of their investigation, Martinez has not provided evidence showing that they were deliberately indifferent to his claims of mistaken identity. View "Martinez v. Santiago" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to modify his sentence under Kan. Stat. Ann. 21-6628(c), which requires courts to modify sentences if certain sentencing provisions are found to be unconstitutional, holding that Appellant was not entitled to a sentencing modification.In 1999, Appellant was convicted of first-degree premeditated murder and sentenced to a hard forty sentence. After a retrial in 2005, Appellant was again convicted of premeditated first-degree murder. Before sentencing, Appellant filed a motion arguing that the hard forty sentencing scheme violated his Sixth Amendment right to a jury trial. The sentencing court denied the motion and again imposed a hard forty life sentence. In 2016, after the Supreme Court decided State v. Soto, 322 P.3d 344 (Kan. 2014), Appellant filed a motion for a sentencing modification under section 21-6628(c). The district court denied the motion. The Supreme Court affirmed, holding that the district court correctly denied the motion. View "State v. Albright" on Justia Law