Justia Civil Rights Opinion Summaries

Defendant Hector Valdez-Mendoza pleaded guilty to one count of sexual assault. After the district court granted Defendant's request for new counsel, Defendant filed a motion to withdraw plea of guilty, asserting in part that he had good cause to withdraw his guilty plea because his previous defense counsel convinced him he could not get a fair trial. The district court denied Valdez-Mendoza's motion. The Supreme Court reversed Defendant's conviction, holding that Defendant had good cause to withdraw his guilty plea because his previous defense counsel shared her belief with Defendant that he could not get a fair trial and made no attempt to assuage Defendant's fear of an unfair trial. Remanded.

After a jury trial, Richard Edwards was found guilty of deliberate homicide. The Supreme Court affirmed the judgment of the district court, holding (1) the district court did not err when it permitted Edwards' wife's testimony because (a) her observations of Edwards' actions did not constitute spousal communications and therefore were not privileged, and (b) Edwards' marital communications regarding the murder that were accompanied by threats were not privileged because they were not communicated in reliance on the confidence of the marital relationship; (2) Edwards was not denied effective assistance of counsel because he failed to show he was prejudiced by defense counsel's admission of lack of preparation for cross-examination; and (3) while it was error for the district court not to inquire into Edwards' post-trial motion for new counsel, reversal in this case was not required because Edwards did not allege a conflict that resulted in a total lack of communication, nor did he claim that his attorneys were unable or unwilling to represent him at the sentencing hearing.

Rosina Spaulding pleaded guilty in district court to misdemeanor DUI per se. Spaudling reserved the right to appeal the district court's denial of her motion to suppress. On appeal, the Supreme Court affirmed, holding the district court correctly denied Spaulding's motion to suppress as (1) although Spaulding was temporarily seized when a deputy sheriff pulled her vehicle over, made contact with her, and inquired as to her and her passengers' well-being, (2) the warrantless seizure was constitutionally reasonable because it met the criteria of the community caretaker doctrine, which allows a government official to stop and investigate a citizen without a warrant when there are objective, specific, and articulable facts from which an experienced officer would suspect that citizen is in need of help or is in peril.

John Chaussee was charged with driving under the influence of alcohol. The offense was alleged to be Chaussee's fourth DUI conviction, making it a felony. Chaussee filed a motion to dismiss, arguing that two of his prior DUI convictions were constitutionally invalid. The district court denied the motion. Chaussee pleaded guilty, reserving his right to appeal the denial of his motion. At issue on appeal was whether Chaussee sufficiently demonstrated that his prior convictions were constitutionally infirm. The Supreme Court affirmed the district court's denial of Chaussee's motion to dismiss, holding that Chaussee failed in his burdens of production and persuasion to demonstrate that his prior convictions were constitutionally invalid.

A jury convicted John Hartsoe of aggravated assault and violation of an order of protection. On appeal, the Supreme Court affirmed in part and remanded in part, holding (1) the district court erred by by permitting Hartsoe to be shackled in a chair and brought into the courtroom during voir dire, but because the record was insufficiently developed to enable the Court to conduct a harmless error analysis, the matter was remanded to the district court to determine whether the violation was harmless in light of the interests that the right to remain free of physical restraints was designed to protect; and (2) the district court did not err in granting Hartsoe's request to represent himself as Hartsoe voluntarily, knowingly, and intelligently elected to proceed pro se.

A jury found Robert DaSilva guilty of failure to provide notice of address change as a sex offender, a felony, and resisting arrest, a misdemeanor. On appeal, the Supreme Court affirmed, holding (1) the district court did not violate DaSilva's due process rights by instructing the jury as a matter of law that DaSilva's previous Washington conviction of second degree assault with sexual motivation was a "sexual offense" under Montana law; and (2) the district court did not act arbitrarily or err in granting a continuance of trial that was requested by the State to permit an amendment to the information.

Montana resident Robin Jordan petitioned for a temporary protective order in a Montana county court against Ohio resident Mark Kalin. The court issued the temporary protective order, and Kalin appealed. In the district court, Kalin moved to dismiss for lack of jurisdiction. The district court did not rule on the motion but found it had jurisdiction in its findings issued after the substantive hearing. The district court then adopted a permanent order of protection prohibiting Kalin from having any contact with Jordan or her husband. Kalin appealed. The Supreme Court affirmed, holding (1) the district court did not err in failing to grant Kalin's motion to dismiss as the allegations of the petition were sufficient to confer jurisdiction on the district court; (2) the evidence was sufficient for the district court to issue a permanent order of protection; and (3) the district court's order of protection did not punish Kalin for exercising his constitutional right to defend himself in court.

Following a jury trial, James Main Jr. was convicted of deliberate homicide and felony murder. Main appealed, arguing that (1) the district court erred in denying his motion to suppress statements he made to two police officers while he was being driven to the police station and while at the police station; (2) the district court erred by denying Main's motion to dismiss for insufficient evidence at the close of the state's case-in-chief; and (3) Main was denied effective assistance of counsel. The Supreme Court affirmed, holding that (1) Main voluntarily, knowingly, and intelligently waived his Miranda rights; (2) the evidence was sufficient to permit the jury to find the elements of the crime had been committed beyond a reasonable doubt; and (3) Main's ineffective assistance of counsel claims should be addressed in a postconviction proceeding.