Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the order of the trial court denying and dismissing Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that Appellant failed to demonstrate that his sentences were illegal.After a jury trial, Appellant was convicted of second-degree murder and sentenced as a habitual offender to eighty years' imprisonment. In his petition to correct an illegal sentence, Appellant asserted that the application of Ark. Code Ann. 5-4-501(c) to enhance his sentence was illegal and that the enhanced sentence violated the prohibition against the ex post facto application of criminal statutes. The trial court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate that his enhanced sentence was an illegal sentence pursuant to section 16-90-111. View "Rainer v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court concluding that it lacked jurisdiction to reduce Defendant's sentence, holding that there was no error.In 1993, Defendant pleaded guilty to first-degree murder and was sentenced to a term of life in prison. Defendant was nineteen years old when he committed the murder. At issue was Defendant's postconviction motion to reduce his sentence, in which Defendant argued that Arkansas courts should expand their interpretation of the Eighth Amendment as it relates to sentencing young adults. The Supreme Court affirmed the circuit court's denial of the motion, holding that the circuit court did not err in concluding that no Arkansas law gave it jurisdiction to modify Defendant's sentence under the circumstances of this case. View "Robinson v. State" on Justia Law

In 1993, Kastman was charged with misdemeanor offenses based on acts of public indecency involving children and disorderly conduct. The state’s attorney initiated a civil commitment proceeding against Kastman under the Sexually Dangerous Persons Act (725 ILCS 205/0.01). Evidence indicated that Kastman suffered from pedophilia, antisocial personality disorder, exhibitionism, and alcohol dependency. Kastman was found to be a sexually dangerous person, and the circuit court granted the petition. In 2016, Kastman was granted conditional release from institutional care.In 2020, he sought financial assistance. Kastman asserted that he was unemployed, disabled, and could not afford his $300 monthly treatment costs and the $1800 monthly rent for housing that complied with the Sex Offender Registration Act. The circuit court of Lake County ordered the Department of Corrections to pay a portion of Kastman’s monthly expenses. The appellate court and Illinois Supreme Court affirmed. The statutes indicate that a sex offender’s ability to pay is a relevant consideration in deciding who should bear the expense of treatment costs; without a clear statutory directive, the legislature is not presumed to have intended that only financially stable individuals are eligible for conditional release. Financial instability and the need for supervision to protect the public are not the same things. View "People v. Kastman" on Justia Law

Jackson was convicted of first-degree murder and attempted armed robbery. After the jury returned its signed verdict forms in open court, Jackson’s attorney asked the court to poll the jury. The circuit court then asked 11 of the 12 jurors whether the verdicts reflected on the verdict forms were their verdicts. All of the 11 jurors who were questioned confirmed that the signed verdict forms accurately reflected their verdicts. The circuit court dismissed the jury without polling the twelfth juror. Jackson’s attorney failed to object to the error and did not include the error in a posttrial motion.Jackson raised the error for the first time on direct appeal. The appellate court held that the error in polling the jury constituted structural error that called into question the integrity of the judicial process, excused the forfeiture under the second prong of Illinois’s plain error rule, and reversed the conviction. The Illinois Supreme Court reinstated the conviction. A procedure that is not required in every criminal jury trial cannot be logically categorized as an essential element of every criminal jury trial on par with the jury trial oath; no U.S. Supreme Court precedent suggests that a criminal defendant is denied the fundamental right to juror unanimity when jury polling does not take place or when there is an error in the jury polling process. View "People v. Jackson" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to twenty years' imprisonment for his convictions of two counts of manslaughter in the second degree, driving under the influence of controlled substances first offense, and persistent felony offender first degree, holding that Defendant's claims of error did not warrant reversal.Specifically, the Supreme Court held (1) the trial court was correct in declining to suppress Defendant's statements statements he made at the accident scene, and suppression of Defendant's blood test was not required in this case; (2) the trial court did not err in excusing a prospective juror for cause; and (3) while certain statements were not properly admissible during the Commonwealth's examination of detective Brandon McPherson, they did not rise to the level of palpable error resulting in manifest injustice. View "Simpson v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court in this criminal case, holding that the case must be remanded for the trial court to consider whether Defendant's consent to a blood draw was voluntary under the totality of the circumstances.Defendant entered a conditional plea to one count of manslaughter in the first degree and one count of manslaughter in the second degree. The Supreme Court affirmed in part and vacated in part, holding that the trial court (1) did not err by failing to suppress Defendant's statements obtained without a Miranda warning; (2) erred in suppressing the results of Defendant's blood draw without determining whether her consent was voluntary where she received a warning that if she refused the blood test and were convicted of DUI, her mandatory minimum jail sentence would be doubled; and (3) did not err by failing to dismiss the case due to alleged abuse of the grand jury process. View "Haney v. Commonwealth" on Justia Law

In 1999, Riley was shot and killed in Chicago. Coleman made a statement to police that she saw Blalock, whom she knew from grammar school, with his hand out a car window, shooting in Riley’s direction. Coleman stated that no threats or promises had been made to her and that she had been allowed to make corrections to her statement. Blalock gave a handwritten statement confessing to the shooting. Before trial, defense counsel filed a motion to suppress, alleging that Blalock's statement was the result of physical coercion by detectives, who slapped and yelled at him, threatened him, and cut or sliced his fingernails. At trial, Coleman recanted her statement, claiming that police had struck her with pens and her statement had not been freely given.Convicted of first-degree murder, Blalock was sentenced to 40 years’ imprisonment. In 2016, Blalock sought leave to file a second successive postconviction petition, claiming that newly discovered evidence showed that the officers who interrogated him had engaged in a pattern and practice of police brutality. The appellate court and Illinois Supreme Court affirmed the denial of that petition. Blalock failed to establish prejudice by showing that the claim not raised during the initial proceeding so infected the trial that the resulting conviction or sentence violated due process, 725 ILCS 5/122-1(f). Blalock’s trial testimony indicated that he fabricated his statement to appease the detectives and assistant state’s attorney, not because of physical abuse, which contradicts the abuse allegations contained in the post-conviction petition. View "People v. Blalock" on Justia Law

In 2013, Craig (age 49) executed an Illinois statutory short-form health care power of attorney, appointing his mother as his agent. In 2016, Craig was hospitalized at McFarland after being charged with burglary and found unfit to stand trial. In 2018, a McFarland psychiatrist sought to involuntarily administer psychotropic medications to Craig under the Mental Health Code, 405 ILCS 5/2-107. Craig alleged that decisions on his medical treatment rested with his agent. A psychiatrist testified that Craig was diagnosed with schizoaffective disorder, bipolar type, when he was 25 years old and had been experiencing hallucinations with symptoms of paranoia, inability to sleep, poor impulse control, hypersexuality, physical aggression, and psychomotor agitation; Craig had no understanding of his mental illness and lacked the capacity to make rational treatment decisions. She opined that the benefits of the medications outweighed the potential risks. Without treatment, Craig was unable to live outside a hospital. Craig’s 82-year-old mother declined to consent, believing that the medications caused brain damage, made Craig “like a zombie,” and made him look “like a man without a head.”The trial court granted the petition for involuntary administration of psychotropic medication for a period not to exceed 90 days. The appellate court and Illinois Supreme Court affirmed. The Mental Health Code, which includes strict standards for an order permitting involuntary administration of psychotropic medications, provides a narrow exception to an agent’s authority to make a principal’s health care decisions. View "In re Craig H." on Justia Law

The First Circuit affirmed the convictions of Appellants Edilio Benjamin-Hernandez (Benjamin) and Johanni Balbuena-Hernandez (Balbuena) on multiple charges stemming from a conspiracy to transport cocaine from the Dominican Republic to Puerto Rico, holding that Appellants were not entitled to relief on their claims of error.On appeal, Appellants challenged the district court's denial of their motion to dismiss and argued that the evidence presented at trial was insufficient to support the convictions. Benjamin also raised two evidentiary challenges. The First Circuit affirmed, holding (1) there was no violation of the Speedy Trial Act's seventy-day limit; (2) no Sixth Amendment violation occurred in this case; and (3) there was sufficient evidence supporting Appellants' convictions. View "United States v. Benjamin-Hernandez" on Justia Law

In 2010, a jury convicted Mammone of the aggravated murder of his two children and his former mother-in-law, aggravated burglary, violation of a protective order, and attempted arson. Mammone’s mother, his father, and a psychologist testified on his behalf at sentencing, and Mammone gave a five-hour unsworn statement. The jury recommended and the court imposed three death sentences plus 27 years of consecutive imprisonment for his noncapital offenses. The Ohio Supreme Court affirmed.The Sixth Circuit affirmed the denial of his habeas corpus petition, 28 U.S.C. 2254. The court rejected Mammone’s arguments that pretrial publicity was so prejudicial that he did not receive a fair trial; that the jurors unconstitutionally prayed before penalty-phase deliberations; and that trial counsel and appellate counsel were ineffective. The Ohio Supreme Court held that it could not conclude that pretrial publicity rendered Mammone’s trial a “hollow formality.” That decision was not an objectively unreasonable application of Supreme Court precedent. Mammone cites no Supreme Court precedent holding that prayer by jurors amounts to the influence of extraneous information. Mammone’s underlying claim that trial counsel should have pursued a defense of not guilty by reason of insanity is not substantial because he cannot overcome the presumption that the decision was strategic. View "Mammone v. Jenkins" on Justia Law