Justia Civil Rights Opinion Summaries

When he was seventeen years old, Appellant committed the crime of first-degree robbery. Appellant was sentenced to a term of imprisonment not to exceed twenty-five years. Appellant was sentenced under a statute that required him to serve at least seventy percent of his sentence before he was eligible for parole. Appellant appealed, arguing that his sentence constituted cruel and unusual punishment. The Supreme Court vacated the sentence and remanded to the district court for resentencing, holding that, for the reasons express in State v. Lyle, filed on this same date, the mandatory sentence violated the prohibition against cruel and unusual punishment under the Iowa Constitution. View "State v. Taylor" on Justia Law

Appellant was a seventeen-year-old high school student when he took a small plastic bag containing marijuana from a fellow student outside the high school. After a jury trial, Appellant was convicted of robbery in the second degree. Appellant was prosecuted as an adult and was sentenced under a statute that required the imposition of a mandatory seven-year minimum sentence of imprisonment. Appellant appealed, arguing that the mandatory minimum was unconstitutional as applied to him. During the pendency of the appeal, the United States decided Miller v. Alabama. The court of appeals affirmed the sentence. The Supreme Court granted review to consider whether Appellant’s sentence was constitutional in light of the cases the Court handed down subsequent to Miller. The Supreme Court vacated the sentence and remanded for resentencing, holding that a statute mandating a sentence of incarceration in a prison for juvenile offenders with no opportunity for parole until a minimum period of time has been served is unconstitutional under the Iowa Constitution. View "State v. Lyle" on Justia Law

Bingham, then in her late teens, committed aggressive acts toward adults and children, including grabbing and kissing. She was declared a sexually dangerous person under the Sexually Dangerous Persons Act, 725 ILCS 205/1.01. The Director of the Illinois Department of Corrections was appointed as her guardian. She was to remain committed “until or unless [she] is recovered and released.” The appellate court reversed. The Illinois Supreme Court affirmed. The limited evidence was insufficient to establish that it was substantially probable that Bingham would commit future sex offenses. A single incident, in which she attempted to grab a woman’s breast area through her shirt, was insufficient to establish that substantial probability. Another incident, involving Bingham touching the buttocks of 17-year-old Katie C, was not clearly intentional; Katie C. acknowledged that Bingham only touched her one time and stopped as soon as Katie C. asked her to do so. There was no evidence that the incident was done as a result of “arousal or gratification of sexual needs or desires.” Without evidence of either an act of sexual assault or acts of child molestation, the state failed to prove propensities toward acts of sexual assault or sexual molestation of children.View "People v. Bingham" on Justia Law

In 2001, the Bryan family’s adopted son, J.O., repeatedly raped and molested his younger foster brother, K.B., in the room the boys shared. After weeks of abuse, K.B. told his foster parents, who contacted the Erie County Office of Children and Youth (ECOCY), which had facilitated J.O.’s adoption, and had J.O. removed from their home. The Bryans blamed ECOCY for K.B.’s ordeal, claiming that ECOCY employees concealed J.O.’s history of violent behavior and sexual misconduct. The Bryans sued ECOCY and seven employees under 42 U.S.C. 1983 on a theory that permits recovery from state actors when “the state’s own actions create the very danger that causes the plaintiff’s injury.” During trial, the parties agreed to a high-low settlement. Regardless of the verdict, the Bryan family was to receive at least $900,000 and defendants were to pay no more than $2.7 million. The jury returned an $8.6 million verdict; the defendants tendered $2.7 million. The Bryans claimed breach of the settlement agreement’s confidentiality clause, rendering the deal unenforceable. The district court concluded that it lacked subject matter jurisdiction to decide whether to enforce those terms or the verdict. The Third Circuit remanded. The case was not dismissed, nor was the verdict satisfied. A district court’s jurisdiction does not terminate at the moment jury deliberations do. View "Bryan v. Erie Cnty. Office of Children & Youth" on Justia Law

Defendants in these cases were both seventeen-year-old offenders who were convicted of special circumstance murder and sentenced to life imprisonment without the possibility of parole under Cal. Penal Code 190.5(b). After Defendants were sentenced, the U.S. Supreme Court decided Miller v. Alabama. On review, the California Supreme Court held (1) section 190.5(b), properly construed, confers discretion upon a trial court to sentence a juvenile convicted of special circumstance murder to life without parole, with no presumption in favor of life without parole; (2) Miller requires a trial court, in exercising its sentencing discretion, to consider the distinctive attributes of youth before imposing life without parole on a juvenile offender; (3) section 190.5(b) does not violate the Eighth Amendment to the U.S. Constitution because it authorizes and requires consideration of the distinctive attributes of youth highlighted in Miller, once the statute is understood not to impose a presumption in favor of life without parole; and (4) because the trial courts in these cases sentenced Defendants without awareness of the full scope of their discretion conferred by section 190.5(b) and without the guidance set forth in Miller, the cases must be remanded for resentencing. View "People v. Gutierrez" on Justia Law

In 2001, Respondent was found guilty of first-degree murder while committing or attempting to commit criminal sexual conduct and first-degree premeditated murder. Respondent was a juvenile when he committed the crime. The district court sentenced Respondent to life without the possibility of release (LWOR) under the mandatory sentencing scheme in Minn. Stat. 609.106(2)(1). After the U.S. Supreme Court decided Miller v. Alabama in 2012, Respondent filed a petition for postconviction relief, arguing that his sentence violated the Eighth Amendment. The postconviction court granted Respondent’s petition and resentenced him to life in prison with the possibility of release after thirty years. The Minnesota Supreme Court subsequently issued its decision in Chambers v. State, which held that the Miller rule does not apply retroactively to a juvenile whose sentence of LWOR under section 609.106(2)(1) became final before the Miller rule was announced. Thereafter, in the instant case, the Supreme Court reversed the postconviction court’s order and reinstated the original sentence of LWOR, holding that the postconviction court’s legal conclusion was in direct conflict with Chambers, and the circumstances of this case did not warrant granting relief to Respondent under the Court’s supervisory powers to ensure the fair administration of justice. View "Roman Nose v. State" on Justia Law

In 1990, defendant, then 14 years old, was arrested for two fatal shootings. Following a discretionary hearing under the Juvenile Court Act, the court allowed defendant to be prosecuted under the criminal laws. He was convicted of two first degree murders, attempted first degree murders of two others, and home invasion. Because defendant was convicted of murdering more than one victim, the Unified Code of Corrections, 730 ILCS 5/5-8-1(a)(1)(c), required a term of natural life imprisonment, with parole not available. He was also sentenced to 30 years for each attempted murder and home invasion, all to run concurrently. The appellate court affirmed. In 1996-1998 defendant filed three post-conviction petitions. All were dismissed; the appellate court affirmed the dismissals. In 2002, defendant filed another petition, arguing that the natural life sentence was unconstitutional because defendant did not actually participate in the act of killing; that the sentence violated the Eighth Amendment; and that the statute requiring a mandatory life sentence violated the Illinois Constitution as applied to a 14-year-old. The circuit court dismissed, noting that defendant carried a weapon and actually entered the abode where the murders occurred. The appellate court affirmed. Defendant another petition in 2011, arguing violation of the Eighth Amendment in light of the Supreme Court’s 2010 decision, Graham v. Florida, and ineffective assistance because counsel failed to interview an eyewitness before the juvenile hearing. The court denied the petition. While appeal was pending, the Supreme Court decided in Miller v. Alabama (2012), that “mandatory life without parole for those under the age of 18 at the time of their crimes violates the Eighth Amendment’s prohibition on ‘cruel and unusual punishments.’ ” The appellate court concluded that Miller applies retroactively on post-conviction review and remanded for a new sentencing hearing, but upheld denial of the ineffective assistance claim. The Illinois Supreme Court affirmed. View "People v. Davis" on Justia Law

Appellant was charged with several offenses stemming from two separate shootings. Appellant was age seventeen when the offenses were committed. After a jury trial, Appellant was convicted of two counts of aggravated murder and sentenced to consecutive terms of life imprisonment without parole. On appeal, Appellant contended that his sentence amounted to cruel and unusual punishment. The court of appeals affirmed, holding (1) Appellant’s sentence was proper under Miller v. Alabama because the sentence imposed in this case was not mandatory but, rather, an exercise of the trial court’s discretion; and (2) the trial court did not violate the Eighth Amendment by failing to consider Appellant’s youth as a mitigating factor in sentencing Appellant. The Supreme Court reversed, holding (1) the Eighth Amendment requires trial courts to consider youth as a mitigating factor when sentencing a child to life without parole for homicide, and the record must reflect that the court specifically considered the juvenile offender’s youth as a mitigating factor at sentencing when a prison term of life without parole is imposed; and (2) because Appellant might not have been given the benefit of the consideration of youth as a mitigating factor, his sentence did not comport with the procedural strictures of Miller. View "State v. Long" on Justia Law

I.T., who admitted to conduct that would be a Class B felony child molesting if committed by an adult, was ordered by the trial court to undergo therapeutic polygraph examinations. During one of those exams, I.T. admitted to molesting two other children. Based on those statements, the State filed a new delinquency petition. I.T. moved to dismiss the petition, arguing that the Juvenile Mental Health Statute, which bars a child’s statement to a mental health evaluator from being admitted into evidence to prove delinquency, barred the State’s evidence. The trial court granted the motion. The State appealed. The Supreme Court affirmed, holding (1) the State may appeal a juvenile court order that suppresses evidence if doing so terminates the proceeding; and (2) the Statute’s limited immunity prohibits both use and derivative use of a juvenile’s statements to prove delinquency. View "State v. I.T." on Justia Law

Defendant was convicted of first degree murder and sentenced to life imprisonment for a murder he committed when he was sixteen years old. More than fifteen years later, Defendant filed an amended postconviction motion challenging his life imprisonment sentence. The district court denied the motion. After Defendant appealed, the U.S. Supreme Court decided Miller v. Alabama, which held that the Eighth Amendment forbids a state sentencing scheme that mandates life in prison without the possibility of parole for a juvenile offender convicted of homicide. The Supreme Court reversed in this case, holding (1) the rule announced in Miller applied retroactively to Defendant; and (2) Defendant’s sentence was unconstitutional under Miller, and therefore, Defendant was entitled to be resentenced. Remanded. View "State v. Mantich" on Justia Law