Justia Civil Rights Opinion Summaries

The Supreme Court dismissed the order of the circuit court denying Appellant's motion for new trial based on allegations of juror misconduct, holding that the motion was clearly untimely, and therefore, the circuit court did not have authority to act on Appellant's motion when it entered orders in this action.In 2004, Appellant was convicted of first-degree murder and sentenced to life imprisonment. In 2018, Appellant filed a petition for writ of habeas corpus and motion for new trial alleging juror misconduct. The trial judge dismissed the habeas petition without prejudice and denied the motion for new trial. The Supreme Court dismissed the appeal, holding that Appellant's motion for new trial was untimely, and the circuit court lacked jurisdiction to consider the motion. View "Herron v. Ark. Department of Corrections" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court to deny Appellant's petition for postconviction relief, holding that, under the circumstances of this case, the court abused its discretion in denying Appellant's petition for postconviction relief.In 2016, Appellant was found guilty of aggravated murder, gross abuse of a corpse, and tampering with evidence. The trial court sentenced Appellant to life in prison without the possibility of parole for the aggravated murder. Appellant later filed a petition for postconviction relief arguing that her trial counsel provided ineffective assistance in failing to present evidence about neonaticide, as it is currently understood, as a mitigating factor. The trial court denied the petition, and the court of appeals affirmed. The Supreme Court reversed, holding that the trial court's decision denying Appellant's postconviction petition was unreasonable and arbitrary and not based on competent and credible evidence. View "State v. Weaver" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding that decision of the trial court to deny Defendant's motion to suppress evidence discovered after a traffic stop, holding that there was no error.After executing the traffic stop at issue, a law enforcement officer ordered Defendant to step out of the car and opened the door for him to do so. Another officer later looked through the open door and spotted a marijuana cigarette on the floor. A subsequent search of the car led to the discovery of a pistol. Defendant pleaded no contest to firearm-related charges. On appeal, Defendant challenged the denial of his motion to suppress. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the officers did not violate the Fourth Amendment by ordering Defendant to exit the car; (2) opening the door was not a search; (3) the second officer did not conduct a search; and (4) under the automobile exception to the warrant requirement, the discovery of the marijuana cigarette in plain view allowed the officers to search the car. View "State v. Jackson" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, with robbery in the third degree as the predicate felony and carrying a pistol or revolver without a permit, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the prosecutor committed improprieties during closing argument by arguing facts that were not in evidence and by making inferences that were unsupported by the evidence. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the conviction of felony murder with the predicate felony of third-degree robbery; and (2) the prosecutor did not engage in improprieties during closing argument that deprived Defendant of his due process right to a fair trial. View "State v. Brown" on Justia Law

The Supreme Judicial Court affirmed Defendant's conviction of, among other charges, seventeen counts of sexual exploitation of a minor under the age of twelve, holding that a search of Defendant's smartphone did not violate Defendant's rights under the Fourth Amendment.On appeal, Defendant argued that the trial court abused its discretion when it declined to reach its argument that the warrant supporting the search of his cellphone was overbroad and violated the particularity requirement of the Fourth Amendment. The Supreme Judicial Court disagreed and affirmed, holding (1) the district court did not err by denying Defendant's motion to suppress; and (2) Defendant's remaining arguments on appeal were without merit. View "Maine v. Jandreaud" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court dismissing rape charges against Defendant due to prejudicial preindictment delay, holding that Defendant failed to demonstrate actual prejudice. In 2017, Defendant was indicted on a multiple-count indictment alleging that Defendant had raped the complaining witness in 2005. The trial court dismissed the charges. The court of appeals affirmed, concluding that Defendant had demonstrated actual prejudice. The Supreme Court affirmed reversed after clarifying that, in determining whether unconstitutional preindictment delay has occurred in a rape case in which consent is at issue, the relevant inquiry is whether the defendant has shown actual prejudice, holding that Defendant failed to show actual prejudice under the standard set forth in State v. Jones, 69 N.E.3d 688 (Ohio 2016). View "State v. Bourn" on Justia Law

A police chase ended when the fleeing armed robber crashed into Plaintiff Thaer Mahdi’s tailor shop. Officers fired scores of bullets at the driver, and many hit the shop. The shop was badly damaged, and Mahdi was psychologically traumatized. Mahdi filed suit under 42 U.S.C. § 1983 against the Salt Lake City Police Department (SLCPD); the Unified Police Department (UPD); and four officers of the Utah Highway Patrol (UHP)—Superintendent Michael Rapich, Sergeant Chris Shelby, and Troopers Jed Miller and Jon Thompson. Plaintiff alleged: (1) the responding officers used excessive force in violation of his right to substantive due process under the Fourteenth Amendment; and (2) that the officers’ unconstitutional use of force resulted from Superintendent Rapich’s failure to train and supervise his subordinates and from the defendant law-enforcement agencies’ policies and customs, including their failure to properly train or supervise their employees. Defendants moved to dismiss Mahdi’s first amended complaint for failure to state any claims. In response, Mahdi moved for leave to file a second amended complaint. The United States District Court for the District of Utah denied the motion as futile and granted the defendants’ motions to dismiss. The court held that Mahdi had not adequately alleged that any officers violated his constitutional right to substantive due process and that in the absence of any such violation the police agencies also could not be liable under § 1983. Mahdi appealed, challenging the dismissal of his claims and denial of his motion for leave to file his second amended complaint. Finding no reversible error in the district court's judgment, the Tenth Circuit affirmed dismissal of plaintiffs claims and denial of his motion. View "Mahdi v. Salt Lake Police Department, et al." on Justia Law

The Supreme Court affirmed the decision of the court of appeal upholding the trial court's finding that trial may continue in Defendant's absence under Cal. Penal Code 1043(b)(2) because the absence was voluntary, holding that the trial court did not violate Defendant's constitutional rights by finding him to be voluntarily absent without conducting an evidentiary hearing regarding the circumstances of his absence.On appeal, the court of appeal concluded that substantial evidence supported the trial court's finding that Defendant voluntarily absented himself from trial and that the court's decision to proceed with trial rather than grant defense counsel's motion for a one-day continuance constituted harmless error. The Supreme Court affirmed, holding that substantial evidence supported the trial court's finding of voluntary absence under the circumstances of this case. View "People v. Ramirez" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the the trial court's decision ordering $1,615 in restitution for lost wages of the victim after Defendant pleaded guilty to two fifth-degree felony charges, holding that unless the loss of wages is directly and proximately caused by the offense, lost wages are not compensable as restitution.During the restitution hearing the victim testified that she was seeking restitution for lost wages relating to the wages she lost as a result of attending hearings for the criminal cases. The trial court ultimately ordered restitution for the lost wages of the victim. The court of appeals reversed. The Supreme Court affirmed, holding that the statutory meaning of restitution was not altered or expanded by Ohio Const. art. I, 10a, otherwise known as Marsy's Law, and that crime victims should receive restitution from those whose crimes that have directly and proximately caused them to suffer economic loss or detriment. View "State v. Yerkey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions and sentence for three counts of aggravated murder, six counts of aggravated robbery and other crimes and his sentence of life in prison, holding that a trial court errs in its evaluation of a defendant's lack of remorse when it considers that defendant's decision to waive allocution and remain silent at sentencing if the defendant exercised his right to a jury trial.Specifically, the Supreme Court held (1) the lower courts did not err in determining that Defendant did not waive his attorney-client privilege with regard to direct communications with his attorney; (2) even if this case presented circumstances in which the attorney-client privilege yielded to Defendant's right to confrontation, any error was not prejudicial; and (3) while the trial court erred in considering Defendant's decision to waive allocution and remain silent in determining whether he lacked remorse, the error was not prejudicial. View "State v. Brunson" on Justia Law