Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was convicted of first-degree sexual abuse and first-degree sodomy. Appellant was sentenced to imprisonment for twenty years. The two jury instructions under which Appellant was convicted directed the jury not to consider a specific event but broadly referred to a five-month period. The Supreme Court vacated the judgment and remanded for a new trial, holding that, upon application of Johnson v. Commonwealth, Appellant’s constitutional right to a unanimous verdict was violated because (1) at trial, the instructions given to the jury contained no distinguishing descriptions that would fairly apprise the jury of exactly which criminal episode it was charged to consider; and (2) the error was jurisprudentially intolerable. View "Ruiz v. Commonwealth" on Justia Law

Appellant was convicted of possession of a handgun by a convicted felon and of being a second-degree persistent felony offender. Appellant was sentenced to twenty years in prison. On appeal, Appellant argued that that his incriminating utterance to police during his arrest should have been suppressed as the fruit of an unlawful search, seizure, and arrest because the policy unlawfully located and identified him during the course of a protective sweep at a Louisville residence, which led to his unlawful arrest and incriminating statement. The Supreme Court affirmed, holding that suppression of Appellant’s spontaneous utterance was not required because the police officers’ initial entry into the residence was consensual, the scope of the protective sweep was reasonable, the seizure of Appellant was lawful, and Appellant’s incriminating statement was spontaneous and not the product of custodial interrogation. View "Simpson v. Commonwealth" on Justia Law

After a jury trial, Appellee was found guilty of second-degree arson, second-degree burglary, and of being a first-degree persistent felony offender. The trial court erred in its peremptory strike allocation during voir dire, but Appellee’s counsel failed to preserve the issue for appeal. Appellee subsequently filed a motion pursuant to RCr 11.42 to vacate his sentence due to ineffective assistance of counsel, arguing that he would have used the two additional peremptory strikes denied to him by the trial court in striking two jurors. The trial court denied the motion, concluding that Appellee’s allegations were not credible. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred in relying on Shane v. Commonwealth in reversing the decision of the trial court; and (2) Appellee failed to demonstrate how he was prejudiced by not being able to strike the two jurors. View "Commonwealth v. Lawson" on Justia Law

After a jury trial, Appellant was convicted of the use of a weapon of mass destruction in the second degree for and attempted murder for installing a pipe bomb in a car. Appellant was sentenced to forty years in prison. The Supreme Court affirmed, holding (1) Appellant’s conviction did not violate double jeopardy principles; (2) the trial court did not err in finding that serious physical injury occurred to the victim and in sentencing Appellant as a violent offender; (3) the trial court’s refusal to allow the jurors to use their notes during deliberations was not reversible error; and (4) Appellant was not wrongly denied his motion for directed verdict. View "Biederman v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of manufacturing methamphetamine while in possession of a firearm, of being a convicted felon in possession of a hand gun, and possession of marijuana. The trial court sentenced Appellant as a persistent felony offender to thirty-four years’ imprisonment. The Supreme Court affirmed, holding that the trial court (1) did not err by not instructing the jury on unlawful possession of a methamphetamine precursor as a lesser-included offense of manufacturing methamphetamine; and (2) did not err in denying, without an evidentiary hearing, Appellant’s motion to suppress items seized from his home, as the search was done pursuant to a valid search warrant. View "Rawls v. Commonwealth" on Justia Law

Appellee was an inmate when he was allegedly involved in a riot. During an interview with an investigating officer, Appellee requested that three witnesses be questioned who could corroborate his version of events, but the witnesses were not interviewed. After a disciplinary hearing, at which Appellee did not call witnesses or present evidence in his defense, Appellee was disciplined for his participation in the riot. Appellee subsequently filed a petition for declaration of rights in the circuit court, arguing that Appellants violated his due process rights by failing to interview the three purported witnesses and by denying him the right to call witnesses and present evidence in his defense. The trial court dismissed the complaint, concluding that the hearing complied with the minimal requirements of procedural due process as outlined in Wolff v. McDonnell. The court of appeals reversed. The Supreme Court affirmed, holding (1) the interviewing officer’s failure to interview the requested witnesses did not deprive Appellant of procedural due process as outlined in Wolff; but (2) while Appellee did not have had the right to remain silent or the right to an attorney during his disciplinary hearing, he deserved a new disciplinary hearing because he was erroneously informed that he enjoyed the rights espoused in Miranda. View "White v. Boards-Bey" on Justia Law

After a prison disciplinary hearing, Appellant, a prisoner, was found guilty of committing physical action against another inmate resulting in death or serious physical injury. Appellant subsequently filed a declaration of rights action in circuit court appealing the finding of guilt, contending that his due process rights were violated because the prison’s disciplinary hearing officer refused to allow him to call the victim of the assault and declined to view surveillance camera footage of the incident. The circuit court denied the petition. The court of appeals affirmed. The Supreme Court reversed, holding (1) if a prison challenges the denial of a prisoner’s request for a particular witness in a disciplinary proceeding by appealing the discipline imposed, the adjustment officer (AO) must provide for the record on review the AO’s reason for denying the witness; (2) if requested by the prisoner in a disciplinary proceeding an AO must review surveillance footage or similar documentary evidence; and (3) Appellant was found guilty and subject to prison discipline as a result of a process that failed to comport with the minimum requirements of due process. Remanded. View "Ramirez v. Nietzel" on Justia Law

After a jury trial, Appellant was found guilty of one count of complicity to murder and one count of first-degree complicity to robbery. Appellant was sentenced to life imprisonment on the murder count and to twenty years on the robbery count. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) the trial court did not err by denying Appellant’s motions for mistrial after the Commonwealth referenced two of the three co-indictees’ guilty pleas in the presence of the jury; (2) the trial court did not err by admitting eighteen jail letters written by Appellant and her co-indictee into evidence; and (3) the trial court did not err by denying Appellant’s motion for a mistrial after the jury briefly accessed inadmissible evidence during deliberations. View "Mayse v. Commonwealth" on Justia Law

The City of Lebanon sought to annex several hundred acres of nearby property. The owners of the property subject to the annexation, including Appellees, filed a lawsuit against the City to invalidate the annexation ordinance. The trial court granted Appellees’ motion for summary judgment, concluding that the City, by intentionally manipulating the annexation boundaries to guarantee a successful annexation, violated Appellees’ constitutional rights. The court of appeals affirmed, holding that the boundaries of territory to be annexed must be “natural or regular” and that the boundaries of the proposed annexation in this case did not meet this standard. The Supreme Court reversed and declared the annexation valid, holding (1) the court of appeals erred in applying a “natural or regular” standard; and (2) the City’s annexation fully complied the the statutory requirements and did not violate Appellees’ constitutional rights. View "City of Lebanon v. Goodin" on Justia Law

Appellant’s charges in this case stemmed from a search of his residence by his parole officers and local sheriff’s deputies. Appellant entered a conditional guilty plea to manufacturing methamphetamine and being a second-degree persistent felony offender and was sentenced to fifty years’ imprisonment. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Appellant’s motion to suppress the products of the search of his home, as Appellant consented to the search and there was no indication that the consent was invalid; and (2) denying Appellant’s motion to suppress the results of lab testing on the products of the search, as the lab results were clearly admissible. View "Helphenstine v. Commonwealth" on Justia Law