Justia Civil Rights Opinion Summaries

At a barbecue at Brown's home. K.M. and Brown became inebriated and had a physical altercation. K.M.’s wife, Rebecca, got K.M. to his car, in front of Brown’s house. According to Rebecca, K.M. was standing in the street when Brown approached and swung a knife at K.M.. K.M. swung back with a piece of wood that Brown had thrown at K.M. earlier. Brown claims K.M. came up the driveway toward him holding pieces of wood and raised his hands as if to strike Brown, so Brown picked up a knife from the grill and swung it. He did not realize he had stabbed K.M. until K.M. collapsed in the street. Brown did not call 911 but made statements such as “that will teach him.” In recorded telephone calls from the jail, Brown made statements attributing the stabbing to anger rather than fear. K.M.’was struck three times; the knife’s blade penetrated his skull and passed through the brain. K.M. survived but has cognitive and physical impairments and will require care for the remainder of his life.Brown was convicted of first-degree reckless injury. The Seventh Circuit affirmed the denial of Brown’s habeas petition. Even if he was deprived of due process when the trial court refused to instruct the jury on the “castle doctrine” as part of his self-defense theory, any error was harmless. It is unlikely that a properly instructed jury would have accepted Brown’s factual account. View "Brown v. Eplett" on Justia Law

Barney’s wife got a restraining order against him and temporary custody of their son. She was subsequently found dead near their son’s daycare, her throat cut open. Barney was charged with murder. Barney had a rocky relationship with his defense lawyer, Riley, and claims that he told Riley of his plan to represent himself on July 14, 2005, then wrote the judge a letter. Though Barney had dated the letter July 21, the judge did not get it until August 10, the day before the trial began. In court, the judge held up the letter, explained that he had not read it, and handed it to Riley. Riley promised Barney that he would “deal with” Barney’s request. He never did.After a two-week trial, Barney was convicted of first-degree murder. His conviction was affirmed. In habeas proceedings, the New Jersey Superior Court found that Barney did not “clearly and unequivocally” tell the court or Riley that he wanted to represent himself. The Third Circuit affirmed the denial of federal habeas relief. The state court ruling was not “contrary to, or involved an unreasonable application of, clearly established” Supreme Court precedent, 28 U.S.C. 2254(d). Barney did not establish prejudice in his ineffective assistance claim; the trial court did not get Barney’s request until the eve of jury selection. View "Barney v. Administrator New Jersey State Prisons" on Justia Law

The Supreme Court reversed Defendant's conviction of murder and criminal possession of a firearm in connection with the death of his wife, holding that the prosecutor improperly commented on Defendant's invocation of his right to remain silent following his arrest and advisement of rights pursuant to Miranda v. Arizona, 384 U.S. 436, 384 U.S. 436 (1966).On appeal, Defendant argued that the evidence was insufficient to establish his identity as the perpetrator of the crimes of conviction and that the prosecutor improperly commented on his post-Miranda silence. The Supreme Court reversed his convictions, holding (1) the evidence was sufficient to support the conviction; but (2) the prosecutor's remarks impermissibly used Defendant's post-Miranda silence against him, in violation of Doyle v. Ohio, 426 U.S. 610 (1976), rendering the trial "fundamentally unfair," and the error was not harmless. View "State v. Patrick M." on Justia Law

In 2011 Sanders drove a truck into his sister and her boyfriend. He was charged with two counts of attempted first-degree intentional homicide. Sanders suffered from schizophrenia and was not taking his medication. Sanders was initially found to lack the capacity to proceed or to assist in his defense. Sanders received treatment, was reevaluated, and a second report suggested he was “malingering.” Sanders entered into a plea agreement, stating he had read and understood the criminal complaint and understood the consequences of pleading guilty. Sanders’s cognitive abilities and educational level were considered, as was whether Sanders could have pleaded not guilty by reason of mental disease or defect.The day after receiving a seven-year sentence, Sanders gave notice of his intent to pursue postconviction relief and was appointed new counsel. The Wisconsin Court of Appeals rejected that attorney’s no-merit report but dismissed the appeal, reasoning that Sanders relied on facts outside the record. On remand, Sanders moved to withdraw his guilty pleas, asserting that he did not understand the offenses to which he pleaded and that his attorney was ineffective. The court denied both motions, making extensive findings that Sanders’s trial counsel was credible and Sanders was generally not credible but was intelligent and understood the proceedings and issues. The Court of Appeals affirmed the denial of relief. The Seventh Circuit affirmed. Sanders’s claim for ineffective assistance of counsel is procedurally defaulted. It plainly appears from Sanders’s petition and attached exhibits that he is not entitled to relief on his claim that his pleas were not knowing and voluntary. View "Sanders v. Radtke" on Justia Law

The Court of Appeals vacated the judgment of the court of special appeals concluding that Appellant had waived his right to appeal the denial of his motion to suppress, holding that Appellant did not waive his right to appeal the suppression ruling.After he had been convicted of a crime of violence Appellant was indicted on charges of possessing a regulated firearm. Appellant filed a motion to suppress the gun and the loaded magazine recovered by law enforcement officers while conducting a warrantless search of his hotel room. Thereafter, the State filed a superseding indictment under a new case number to add additional charges. Appellant subsequently renewed his motion to suppress in the new case. The trial court denied the motion, and Appellant was convicted of first-degree assault and other crimes. The court of appeals affirmed, ruling that Appellant waived his challenge to the denial o this motion to suppress. The Court of Appeals remanded the case for further consideration, holding that defense counsel did not waive Appellant's right to appellate review of the denial of his motion to suppress. View "Huggins v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree arson stemming from a fire that occurred in Defendant's home, for which she submitted a claim to her insurer seeking to recover for the damage to her home, holding that Defendant was not entitled to relief on her claims of error.On appeal, Defendant argued that the circuit court erred in denying her motion for judgment of acquittal and that she was denied her fundamental right to due process. The Supreme Court affirmed, holding (1) the circuit court's factual findings were legally sufficient to support a conviction of second-degree arson; (2) the circuit court did not err when it denied Defendant's motion for judgment of acquittal; and (3) Defendant was not denied her constitutional right to due process and a fair trial. View "State v. Krouse" on Justia Law

The Supreme Court reversed the judgment of the postconviction court partially granting Defendant's motion to vacate his first-degree murder convictions and sentences of death pursuant to Fla. R. Crim. P. 3.851, holding that the postconviction court erred in granting a new penalty phase.Defendant pleaded guilty to two counts of first-degree murder and one count of attempted first-degree murder. After waiving a penalty-phase jury, Defendant was sentenced to death. Defendant later filed a postconviction motion under Fla. R. Crim. P. 3.851. The postconviction court summarily denied Defendant's four purely legal claims but granted a new penalty phase, ruling that counsel was deficient in investigating and presenting mitigating evidence, which prejudiced Defendant. The Supreme Court reversed, holding that Defendant failed to establish deficient performance in any respect. View "State v. Mullens" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and carrying a dangerous weapon, holding that there was no deprivation of Defendant's due process right to a fair trial in this case.On appeal, Defendant argued that the prosecutor committed two instances of impropriety during the State's closing and rebuttal arguments, neither of which the defense objected to at trial. The Supreme Court upheld Defendant's convictions, holding (1) the first challenged argument did not exceed the bounds of permissible argument; and (2) as to the prosecutor's second challenged argument, even if the prosecutor's remarks were improper, there was no possibility that they deprived Defendant of a fair trial. View "State v. Hinds" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of robbery in the first degree following the entry of his conditional plea of nolo contendere, holding that the prosecution of Defendant was time barred by the five-year statute of limitations set forth in Conn. Gen. Stat. 54-193(b).The robbery in this place took place on November 29, 2013. The next day, Defendant confessed to a detective as to his involvement in the robbery. On December 6, 2018, Defendant was transported to the superior court, where he was served with an arrest warrant. Defendant filed a motion to dismiss, arguing that the prosecution was barred under section 54-193(b). The trial court denied the motion to dismiss, finding that the State made at least some effort to execute the warrant on or before November 29, 2018. After Defendant entered his nolo contendere plea he appealed the denial of his motion to dismiss. The appellate court affirmed. The Supreme Court reversed, holding that the State did not meet its burden to demonstrate that the warrant for Defendant's arrest was executed without unreasonable delay. View "State v. Freeman" on Justia Law

The Supreme Court reversed Defendant's convictions for several drug-related offenses, holding that the trial court abused its discretion by admitting evidence obtained during a search of Defendant's home.Officer Cody Scott was investigating a robbery when he detained Defendant for an outstanding warrant for his arrest. The officer asked Defendant if he would escort him inside the house, and Defendant agreed to the request. After Officer Scott observed possible narcotics in the residence he obtained a search warrant, the execution of which revealed various drug paraphernalia. The court of appeals affirmed Defendant's convictions, holding that the trial court did not abuse its discretion by denying Defendant's motion to suppress. The Supreme Court reversed, holding that Defendant's protections under Pirtle v. State, 323 N.E.2d 634 (Ind. 1975), were violated in this case, and therefore, the trial court abused its discretion by admitting evidence obtained during the search. View "McCoy v. State" on Justia Law