Justia Civil Rights Opinion Summaries

The First Circuit affirmed the judgment of the district court convicting Defendant of all counts in a 41-count indictment charging him with sexual exploitation of a child and possessing, promoting, and distributing child pornography and sentencing him to a term of eighty years' imprisonment, holding that Defendant's arguments on appeal were unavailing.On appeal, Defendant argued that the total length of his term-of-hears sentence violated the constitutional prohibition on cruel and unusual punishment contained in the Eighth Amendment to the United States Constitution. The First Circuit affirmed, holding that Defendant's eighty-year sentence for dozens of child pornography offenses did not reach the level of gross disproportionality. View "United States v. Raiche" on Justia Law

S.B., age 13, lived with his mother in Michigan and visited relatives in Indiana. S.B.’s uncle, Hinkle, isolated and molested S.B. during two visits. By the time he was 17, S.B. used opiates and marijuana regularly and had experimented with heroin. During a family meeting to address his drug use, S.B. admitted his drug use and that Hinkle had molested him.Hinkle was charged with child molesting, sexual misconduct with a minor, and being a repeat sexual offender. Hinkle’s counsel opposed a motion to exclude evidence of S.B.’s drug use, arguing the evidence was relevant to show S.B.’s motive to fabricate allegations. The court ruled that it would not allow evidence of S.B.’s drug use except to show that it interfered with his ability to recall relevant events. At trial, Hinkle’s counsel unsuccessfully argued (outside the jury’s presence) that S.B. had falsely accused Hinkle to avoid facing consequences when his family confronted him for using narcotics. The jury heard evidence that S.B. “ha[d] a habit of playing family members against each other,” and was “really good at lying.” S.B. testified that he had convictions for credit card fraud, auto theft, and retail fraud.Hinkle was convicted and sentenced to 42 years in prison. The Seventh Circuit affirmed the denial of his habeas petition. The Court of Appeals of Indiana did not unreasonably apply federal constitutional law in upholding the exclusion of evidence of S.B.’s drug use. View "Hinkle v. Neal" on Justia Law

The Supreme Court approved of the decision of the First District Court of Appeal affirming Defendant's conviction for sexual battery in violation of Fla. Stat. 794.011(5)(b), holding that subsection 5(b) is not facially unconstitutional because it does not remove the State's burden to prove the defendant's general intent to engage in the act that constitutes the offense under the statute.On appeal, Defendant argued that subsection 5(b) was facially unconstitutional or must be read to include a requirement that the State prove that a criminal defendant knew or should have known the victim did not consent to sexual intercourse. The First District affirmed, disagreeing with Defendant that section 794.011(5)(b) was unconstitutional because it does not require the State to prove a defendant's mens rea. The Supreme Court affirmed, holding that the Legislature's reach did not approach the extent of its constitutional grasp where the statute makes sexual battery a crime of general intent not a strict liability offense. View "Statler v. State" on Justia Law

The Supreme Court reversed the judgment of the court of appeals determining that the evidence should have been suppressed in the underlying criminal case based on a statutory violation, holding that there was no violation of Defendant's Fourth Amendment rights in this case.While Defendant was serving community control, his probation officer conducted a random home-check on Defendant, searched his cell phone, and discovered child pornography. Defendant moved to suppress the uncovered evidence on the grounds that the suspicion-less search violated the Fourth Amendment. The district court denied the suppression motion. The court of appeals reversed, concluding that the search violated Ohio Rev Code 2951.02(A)'s requirement that a probation officer may conduct a search only when there are "reasonable grounds to believe" that a probationer is violating the law or conditions of control. The Supreme Court reversed, holding (1) the probation officer exceeded the scope of her authority when she searched Defendant's cell phone without reasonable grounds to believe that he had violated the law or the conditions of probation; and (2) because there was no constitutional violation, there was no basis to exclude the evidence obtained as a result of the search. View "State v. Campbell" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of incest, holding that Defendant was not entitled to reversal of his convictions based on any of his allegations of error.Specifically, the Supreme Court held (1) the district court did not err in finding that Defendant had not demonstrated that the victim's allegations against other male relatives were false and thus inadmissible under the Rape Shield statute; (2) Defendant's ineffective assistance of counsel claim was inappropriate for review on direct appeal; and (3) this Court declines to exercise plain error review to consider whether Defendant received a fundamentally fair trial when the district court did not sua sponte exclude testimony of false reporting statistics. View "State v. McCaulou" on Justia Law

In August 2009, Kennedy and his father were arrested by Philadelphia police during an armed home invasion. In October 2013, after numerous delays, they went on trial. Both were convicted. Kennedy was sentenced to 10-15 years of imprisonment. After failing to obtain redress under the Pennsylvania Post-Conviction Relief Act, Kennedy’s appeal was rejected by the Pennsylvania Superior Court. In July 2019, Kennedy filed a pro se federal habeas petition, arguing that his right to a speedy trial had been violated. The district court denied Kennedy’s petition on grounds of procedural default and adopted the state-court finding that only 16 days of the 50-month delay in bringing Kennedy to trial were attributable to the Commonwealth. The court additionally held his petition to be “without merit."The Third Circuit reversed, concluding that Kennedy’s procedural default was excused and that his Sixth Amendment Speedy Trial Right was violated. The Commonwealth had, in the interim, conceded that Kennedy’s Sixth Amendment claim was exhausted. The court noted that a 50-month delay is exceptional and that the Commonwealth did not overcome the presumptive prejudice of a four-year delay, despite the strength of its case at trial. Kennedy has also identified prejudice stemming from loss of employment, anxiety, and incarceration. View "Kennedy v. Superintendent Dallas SCI" on Justia Law

The Supreme Court affirmed the denial of Appellant's petition for postconviction relief arguing that the district court committed reversible error by denying his pretrial motion to suppress his statements to law enforcement officers, holding that the district court did not abuse its discretion by denying Appellant's request for postconviction relief.Appellant was convicted of second-degree murder and first-degree arson and sentenced to a total of 528 months in prison. Appellant later filed for postconviction relief, asserting that the district court committed reversible error by denying his pretrial motion to suppress statements he made to law enforcement officers. The district court denied relief on the grounds that Appellant was not subjected to custodial interrogation at the time he made his statements. The court of appeals affirmed on different grounds. The Supreme Court affirmed on the grounds cited by the district court, holding that Defendant could not invoke his Fifth Amendment right to counsel because no custodial interrogation took place. View "Charette v. State" on Justia Law

The Supreme Court vacated the judgment of the intermediate court of appeals (ICA) in this criminal case, holding that because the information omitted the crime of forgery in the second degree's states of mind, it failed to state an offense as to counts 4-7 and violated Defendant's right to due process.Defendant was charged via information with four counts of forgery in the second decree. Defendant filed a pretrial motion to dismiss counts 4-7 charging him with forgery in the second degree because the information omitted forgery's states of mind. In response, the State argued that intent to defraud is an element, understandable to the common person, and gave notice to Defendant of forgery's state of mind. The circuit court granted Defendant's motion to dismiss. The ICA reversed. The Supreme Court reversed, holding (1) Defendant's information did not identify forgery's states of mind, intentionally and knowingly; and (2) therefore, counts 4-7 failed to state an offense and violated Defendant's right to due process. View "State v. Garcia" on Justia Law

The Supreme Court vacated the adjudicatory and dispositional orders of the circuit court in this termination of parental rights case, holding that the circuit court erred when it terminated Father's parental rights because Father did not receive proper notice of the hearing at which he was purportedly adjudicated.The circuit court terminated Father's parental rights for allegedly abandoning his infant son. Father proposed two assignments of error claiming that he was denied an adjudicatory hearing for a determination whether the child had been abuse and/or neglected as alleged. The Supreme Court vacated the circuit court's order, holding (1) Father did not receive proper notice that the hearing at issue was an adjudicatory hearing from him, and without such notice, Father was not provided due process; and (2) without first holding an adjudicatory hearing, the circuit court could not lawfully proceed to disposition and termination of Father's parental rights. View "In re A.G." on Justia Law

Meyers was one of seven men convicted of the 1989 gang-related murders of Williams and Kaufman in Chicago. In 1995, after Meyers’ conviction was affirmed on direct appeal, he filed a pro se petition for post-conviction, arguing that his trial counsel, Nichols, was ineffective for failing to investigate the scene of the shooting and to establish that a witness, Wilson, would not have been able to see the shooters from his second-floor vantage point. Pointing to Wilson’s post-trial recantation, Meyers added that he was wrongfully convicted based on Wilson’s perjured trial testimony and the prosecution’s subornation to commit perjury. Meyers also argued that his trial counsel, Nichols, was ineffective in failing to interview and present the alibi testimony of Parker. The Illinois appellate court rejected his claims.The Seventh Circuit affirmed the denial of his federal habeas corpus petition. The Illinois Appellate Court did not unreasonably apply “Strickland” in rejecting his claim that Nichols was ineffective for failing to interview and present Parker’s alibi testimony. The risk that the defense would have taken by pursuing that alibi, which contradicted statements made by Nichols after his arrest, is obvious. The state court reasonably determined that his conviction was not based on the knowing use of perjured testimony. View "Meyers v. Gomez" on Justia Law