Justia Civil Rights Opinion Summaries

Articles Posted in Kentucky Supreme Court
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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

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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

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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

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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

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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

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After a jury trial, Appellant was found guilty of robbery in the first degree and of being a persistent felony offender in the first degree for robbing a cashier clerk at a convenience store at knifepoint. The Supreme Court affirmed, holding that the trial court (1) did not err by allowing three witnesses to identify Appellant as the perpetrator on the store surveillance video and in still shot photos; (2) did not err or violate Appellant’s due process rights by denying Appellant’s motion for a continuance of trial; and (3) did not err by denying Appellant’s motion for a directed verdict of acquittal. View "Morgan v. Commonwealth" on Justia Law

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After a jury trial, Appellant was found guilty of first-degree manslaughter, tampering with physical evidence, alcohol intoxication, and criminal trespass. For his crimes, Appellant received a twenty-five-year prison sentence. The Supreme Court affirmed Appellant’s conviction and corresponding sentence, holding that the trial court did not err by (1) denying Appellant’s motion to suppress statements he made during his interrogation at police headquarters; (2) failing to suppress the evidence of subsequent statements made during Appellant’s hospitalization; (3) denying Appellant’s motion to suppress evidence of hair comparisons; and (4) finding Appellant in criminal contempt of court. View "Meskimen v. Commonwealth" on Justia Law

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Appellant entered a conditional guilty plea to manufacturing methamphetamine and second-degree persistent felony offender status. On appeal, Appellant argued that the trial court erred by denying his motion to suppress the drug-related evidence seized by a state police officer and a parole officer during a warrantless search of his residence while he was a parolee. Specifically, Appellant argued that the warrantless search was unreasonable under the Fourth Amendment because the parole officers did not have reasonable suspicion that he was engaged in criminal activity. The Supreme Court affirmed the trial court’s denial of Appellant’s motion to suppress, holding that because the Fourth Amendment does not prohibit a police officer from conducting a suspicionless search of a parolee, Appellant had no basis for application of the exclusionary rule. View "Bratcher v. Commonwealth" on Justia Law

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Appellant entered a conditional guilty plea to possession of a controlled substance and carrying a concealed deadly weapon. Appellant appealed the district court’s denial of his motion to suppress evidence seized upon his arrest. The circuit court and court of appeals both affirmed the district court’s ruling. The Supreme Court affirmed the district court’s denial of Appellant’s motion to suppress, holding that police officers’ search and ultimate seizure of a gun and controlled substances found on Appellant’s person was supported by sufficient cause and thus was a valid search incident to arrest. View "Vega v. Commonwealth" on Justia Law

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After a jury trial, Appellant was found guilty of robbery, burglary, unlawful imprisonment, receiving stolen property, and being a persistent felony offender (PFO). Appellant was sentenced to thirty years’ imprisonment. The Supreme Court reversed Appellant’s convictions and remanded the case for further proceedings, holding (1) the trial court erred when it misinformed Appellant that he could not proceed to trial with a hybrid form of representation and therefore denied Appellant his right to represent himself for one pretrial motion while still retaining the services of counsel for the remainder of the proceedings; and (2) because the trial judge misstated the law, reversal and a new trial were necessary. View "Mitchell v. Commonwealth" on Justia Law