Justia Civil Rights Opinion Summaries

Thomas Eugene Creech, sentenced to death in 1995, faced a failed execution attempt in early 2024 due to the inability to establish reliable intravenous access. Following this, Creech filed a petition for post-conviction relief, arguing that any further attempt to execute him would violate his constitutional rights under the Fifth Amendment’s Double Jeopardy Clause and the Eighth Amendment’s prohibition against cruel and unusual punishment.The District Court of the Fourth Judicial District of Idaho dismissed Creech’s petition, construing his Eighth Amendment argument as a challenge to the method of execution, which it determined could not be litigated in a post-conviction action. The court suggested that Creech could pursue his Eighth Amendment challenge through other legal avenues, such as a 42 U.S.C. § 1983 action. The court also addressed the merits, finding that a second execution attempt did not violate the Fifth Amendment as it did not impose more punishment than authorized, nor did it violate the Eighth Amendment as the failed attempt did not involve intentional or malicious infliction of unnecessary pain.The Supreme Court of Idaho affirmed the district court’s dismissal. It held that Creech’s claims were properly raised under Idaho Code section 19-2719 but found no genuine issue of material fact warranting an evidentiary hearing. The court determined that the failed execution did not constitute cruel and unusual punishment under the Eighth Amendment, as the psychological strain and pain experienced were inherent in any execution method. Additionally, the court ruled that a second execution attempt did not violate the Double Jeopardy Clause, as the initial attempt did not complete the punishment authorized by the legislature. Creech’s state constitutional claims were not considered as they were not adequately preserved for appeal. View "Creech v. State" on Justia Law

In this case, Tyler Reece Rambo was convicted on three counts of aggravated assault upon a peace officer following an incident with police at a city park in Idaho. Rambo appealed his conviction, challenging several of the district court’s evidentiary rulings concerning the admission of evidence at his trial. Rambo argued that the court erred in excluding evidence of a civil lawsuit against the Coeur d’Alene Police Department, admitting body camera footage of his gun discharging, excluding body camera footage of officers returning fire, prohibiting him from testifying about the trajectory of a bullet, and prohibiting him from showing the jury his bullet scars. The Supreme Court of the State of Idaho affirmed the majority of the district court’s rulings and determined that the district court's one erroneous relevancy determination regarding the exclusion of body cam footage indicating that Rambo’s gun did not discharge a second time, was harmless. Therefore, the Supreme Court affirmed Rambo’s judgment of conviction. View "State v. Rambo" on Justia Law