Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction for aggravated murder and his sentence of death, holding that, while error occurred in this case in the form of repetitive crime scene photos, the prosecutor's misstatements, and sentencing opinion errors, none of the errors resulted in prejudicial error.After a jury trial, Defendant was found guilty of the aggravated murders of his four-year-old daughter, C.D., and her mother, Nicole Duckson, with accompanying death-penalty specifications. The court sentenced Defendant according to the jury's recommendation of a sentence of death for the aggravated murder of C.D. The court then sentenced Defendant to life without parole for the aggravated murder of Nicole. The Supreme Court affirmed but remanded the case, holding (1) Defendant received a fair trial, and none of the errors in this case, when considered either individually or cumulatively, resulted in prejudicial error; (2) the overwhelming evidence established Defendant's guilt; and (3) the case must be remanded for the trial court to issue a nunc pro tunc entering confirming the September 14, 2019 judgment entry and the September 16, 2019 entry to the sentence that was imposed at the sentencing hearing. View "State v. Garrett" on Justia Law

During a traffic stop, a detective and a police officer worked in tandem to search Colbert’s vehicle and frisk him, uncovering on his person a brick-shaped package later confirmed to contain a controlled substance. Colbert moved to suppress this evidence, arguing that the frisk violated his constitutional rights. The district court denied the motion. Colbert entered a conditional guilty plea to possession with intent to distribute 40 grams or more of a mixture containing a detectable amount of fentanyl, 21 U.S.C. 841(a).The Seventh Circuit affirmed. The officers had reasonable suspicion to frisk him based on two officers observing the smell of marijuana coming from the vehicle, Colbert’s erratic driving, evasive and nervous behavior, a bulge in his pocket, and unwillingness to follow directions. Colbert had read and signed a form, giving the officer permission to search his vehicle. View "United States v. Colbert" on Justia Law

In 2010, Cannon pled guilty to assault with intent to commit rape and dissuading a witness. Cannon was sentenced to a term of seven years. In 2016, the district attorney filed a petition to commit Cannon under the Sexually Violent Predator Act (SVPA) (Welf. & Inst. Code, 6600). Cannon’s SVPA trial was continued several times. Updated evaluations were prepared in 2018, revealing a split in opinion among the experts as to whether Cannon qualified as an SVP. At a pretrial conference unattended by Cannon, his counsel waived his right to a jury trial. Cannon’s bench trial began in 2020. There was testimony that Cannon suffered a traumatic injury to the prefrontal lobes of his brain and subsequently became obsessed with sex and began consuming large amounts of pornography. He was aggressive toward teenage girls. Family members became overwhelmed with Cannon’s sexual disinhibition.The court of appeal remanded the resulting commitment order for a determination of whether Cannon’s constitutional right to equal protection was violated by the court’s failure to advise him of his right to a jury trial and to obtain his personal waiver of that right. The court otherwise affirmed, rejecting challenges to the sufficiency of the evidence and to expert witness testimony that included case-specific hearsay. View "People v. Cannon" on Justia Law

The Supreme Court affirmed the judgment of the superior convicting Defendant, following a jury trial, of first degree murder and sentencing him to death, holding that Defendant failed to demonstrate that alleged errors occurring at the guilt phase of trial cumulated in his not having received a "fair trial on the issue of his mental state at the time of the shooting."Specifically, the Supreme Court held (1) the trial court committed error under state law by ordering that Defendant submit to an examination by the prosecution expert and allowing the jury to learn of Defendant's refusal to be examined, but these errors were not prejudicial; (2) the prosecutor's comments regarding the ethics of forensic psychiatry did not infect the trial with unfairness that rose to the level of prejudicial error; (3) the trial court erred in admitting a law enforcement officer's statement under People v. Sanchez, 63 Cal.4th 665 (2016), but the error did not contribute to the jury's verdict; (4) the guilt phase errors were not cumulatively prejudicial; (5) the trial court did not err in excusing a prospective juror for cause because of her views on the death penalty; and (6) no other prejudicial error occurred during the penalty phase of the trial. View "People v. Camacho" on Justia Law

Clark, a JTVCC inmate, was treated for schizophrenia and bipolar disorder at the prison for at least 10 years, a fact of which the prison officials were aware. Despite having few disciplinary “points” on his record and no security classification meriting solitary confinement, Clark remained in the unit for seven months, alone in his cell except for three one-hour intervals per week. Clark was not allowed to work or participate in educational or religious services. He was permitted only four phone calls and four visitors per month. Inmates must “earn their way out” of solitary confinement; while in isolation, Clark would “yell and bang on the door." Prison officials considered these outbursts to be disciplinary incidents. When Clark questioned his confinement, he was put in the “naked room,” an isolation cell where he had only an open smock. Clark's mental illness caused behavior that was punished by conditions that furthered his deterioration. Clark experienced “increased hallucinations, paranoia, self-mutilation, sleeplessness, and nightmares.”Officials failed to abide by a policy requirement to consider his mental illness. Clark alleges they knew of the American Correctional Association study on the effects of solitary confinement on seriously mentally ill inmates. The study singled out JTVCC’s Warden, stating that he is not “open to change in regards to restrictive housing" regarding the mentally ill. The Third Circuit reversed the qualified immunity dismissal of Clark’s 42 U.S.C. 1983 suit. His allegations trigger established Eighth Amendment protection. View "Clark v. Coupe" on Justia Law

Based on allegations that he sexually abused his grandson, J.M., McKown was charged with three counts of predatory criminal sexual assault of a child (720 ILCS 5/11-1.40(a)(1)), three counts of aggravated criminal sexual abuse (11-1.60(c)(1)(i)), and one count of child pornography (11- 20.1(a)(1)(ii)). There were inconsistencies in J.M.’s testimony. An officer testified that McKown had consented to a search of his basement, where the officer saw “multiple cutout pictures of young female children’s faces that had slits cut into the mouths and cutout images of male penises inserted into those slits.”The appellate court and Illinois Supreme Court affirmed McKown’s convictions. The pictures of young children that McKown modified to depict sexual conduct constitute child pornography under section 11-20.1 and section 11-20.1 is consistent with the First Amendment to the U.S. Constitution. McKown possessed images of actual, identifiable children that he altered to depict sexual conduct. Sufficient corroboration existed to satisfy the corpus delicti rule as to McKown’s convictions for various sexual offenses. View "People v. McKown" on Justia Law

Pingelton was charged with criminal sexual assault on victims who were 16 years old. The emergency medicine physicians who examined the victims testified that they had no opinion as to whether either victim was sexually assaulted. The appellate court affirmed his convictions. Pingelton pro se filed a postconviction petition alleging ineffective assistance of both trial and appellate counsel, citing failure to object to the presentation of improper expert testimony by the physicians. The prosecution’s motion to dismiss was served on Pingelton’s appointed counsel. Almost two years later, postconviction counsel moved to withdraw, arguing that Pingelton’s claims could not be supported as a matter of law and that the record revealed no other meritorious issues. Pingelton requested that the court allow him to amend his petition and proceed. At a “status” hearing, the state and postconviction counsel appeared personally. Pingelton appeared via telephone. The court granted counsel’s motion to withdraw and dismissed, finding that none of Pingelton’s allegations indicated that he had received “unreasonable” assistance from his attorneys.The Appellate Court affirmed. The Illinois Supreme Court affirmed. Pingelton’s right to procedural due process was violated when the court dismissed his postconviction petition without affording him adequate notice and a meaningful opportunity to be heard. However, Pingelton’s claims lack merit, so he did not present a substantial showing of a constitutional deprivation at trial or on direct appeal. View "People v. Pingelton" on Justia Law

Moran was convicted of attempted murder and aggravated battery with a firearm for a 2006 Calumet City, Illinois shooting. After the trial, the prosecution learned that exculpatory evidence, including a ballistics report linking the gun used in the Calumet City shooting to a different shooting, had not been turned over to the defense as required by Brady v. Maryland. Moran sought postconviction relief. A state court vacated his conviction. Moran was retried and acquitted in 2017.Moran then filed a federal suit (42 U.S.C. 1983) against the city, two detectives who investigated the shooting, and a crime scene technician who mishandled the ballistics report, seeking redress for the decade he spent incarcerated. The district court granted the defendants summary judgment, noting that Moran’s allegation that an Assistant States Attorney knew about the report was a judicial admission that negated an essential element of the claim; prosecutorial knowledge of exculpatory evidence blocks civil liability for police officers. The court stated that even without that judicial admission, the record could not allow a reasonable jury to find that the evidence had been suppressed. Moran moved for leave to amend his complaint. The Seventh Circuit affirmed the denial of that motion. Moran unduly delayed seeking to amend his complaint; he should have known that his complaint contained factual errors at the outset. View "Moran v. Calumet City, Illinois" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming both Defendant's judgment of conviction and the circuit court's denial of his motion to suppress evidence, holding that police officers' warrantless entry in Defendant's fenced-in back yard was not a valid "knock and talk" investigation and that the entry was not permissible under the exigency of hot pursuit.On appeal, Defendant argued that the police officers lacked an implicit license to enter his backyard, and therefore, the entry violated the Fourth Amendment. The Supreme Court agreed and reversed the decision of the court of appeals, holding (1) the "knock and talk" investigation was not valid because the officers did not have an implicit license to enter Defendant's backyard; and (2) because the officers did not immediately or continuously pursue Defendant from the scene of the crime, the officers' entry into Defendant's backyard was not permissible under the exigency of hot pursuit and therefore violated the Fourth Amendment. View "State v. Wilson" on Justia Law

The Supreme Court affirmed Defendant's conviction of operating while intoxicated (OWI) sixth offense, in violation of Wis. Stat. 346.63(1)(a), holding that Defendant's constitutional right to be free from abusive governmental searches was satisfied in this case, and therefore, the circuit court did not err in denying Defendant's motion to suppress.On appeal, Defendant argued that the warrant compelling him to submit to a blood draw was constitutionally defective because, when the affiant signed the affidavit that accompanied the warrant petition, the affiant was not placed under oath or affirmation. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the affidavit fulfilled the oath or affirmation requirement under the state and federal Constitutions; and (2) therefore the circuit court did not err in denying Defendant's motion to suppress. View "State v. Moeser" on Justia Law