Justia Civil Rights Opinion Summaries

Articles Posted in North Carolina Supreme Court
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The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for second-degree murder, holding that the court of appeals erred in concluding that the trial court erred by denying Defendant's motion to suppress evidence generated from his blood but that the error was not prejudicial.In denying Defendant's suppression motion the court of appeals held that the trial court erred by not excluding Defendant's blood test results but that Defendant failed to carry his burden to show that the denial of his motion to suppress resulted in prejudicial error. The Supreme Court reversed, holding that the court of appeals applied the incorrect standard for determining prejudice resulting from the violation of Defendant's rights under the United States Constitution. View "State v. Scott" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals vacating Defendants' convictions of second-degree murder and ordering a new trial, holding that the trial court committed prejudicial error in excluding evidence that was highly relevant as to Defendants' self-defense claims.Defendants, Thomas Martens and his daughter, Molly Corbett, were found guilty of murdering Molly's husband, Jason Corbett. During trial, Defendants maintained that they had lawfully used deadly force to defend themselves while under a reasonable apprehension that they were facing an imminent threat of deadly harm during an interaction initiated by Jason. The Supreme Court remanded the case to the trial court for a new trial, holding that the trial court erroneously excluded certain evidence, thus depriving Defendants of their ability to present a full and meaningful defense. View "State v. Corbett" on Justia Law

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The Supreme Court reversed the trial court's denial of Defendant's motion for appropriately relief filed after he was convicted of two counts of first-degree murder, holding that certain undisclosed evidence was material and that it was reasonably probable that, had it been disclosed to Defendant prior to trial, the outcome would have been different.Defendant was convicted of first-degree burglary, first-degree rape, robbery with a dangerous weapon, and two counts of first-degree murder and sentenced to death. The convictions were affirmed on direct appeal. In postconviction proceedings, it became clear that the State failed to produce certain pieces of evidence to Defendant prior to his trial. Later that year, postconviction counsel uncovered additional evidence. Defendant then filed a motion for appropriate relief, arguing that the State failed to disclose exculpatory evidence in violation of his due process right pursuant to Brady v. Maryland, 373 U.S. 83 (1963). The trial court denied the motion. The Supreme Court reversed and remanded this case with instruction to grant the motion and order a new trial, holding that the failure to disclose the exculpatory evidence prejudiced Defendant's ability to present a defense. View "State v. Best" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals affirming Defendant's convictions, holding that the trial court abused its discretion when it "flatly prohibited questioning as to issues of race and implicit bias during voir dire" and that the trial court's improper restrictions on Defendant's questioning during voir dire prejudiced Defendant.Defendant was convicted of several crimes, including robbery with a dangerous weapon and second-degree kidnapping. On appeal, Defendant challenged the trial court's refusal to allow him to pursue during voir dire certain lines of inquiry relating to racial bias and police-officer shootings of black civilians. The court of appeals rejected Defendant's claims and found no error in the trial court's judgment. The Supreme Court reversed, holding that the trial court abused its discretion and prejudiced Defendant by restricting all inquiry into prospective jurors' racial biases and opinions regarding police officer shootings of black men. View "State v. Crump" on Justia Law

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The Supreme Court held that the scheduling and procedural circumstances existent in this case did not constitute an infringement upon Defendant's constitutional right to a speedy trial.After a jury trial, Defendant was convicted of first-degree sex offense with a child and indecent liberties with a child. On appeal, Defendant argued that the trial court erred by denying his motion to dismiss the charges against him because the State violated his constitutional right to a speedy trial by failing to calendar his trial date for approximately five years following the issuance of the indictments against him. The court of appeals affirmed, holding that here was no speedy trial violation. The Supreme Court affirmed after weighing the factors set forth in Barker v. Wingo, 407 U.S. 514 (1972), as they applied to the circumstances of this case, holding that Defendant's constitutional right to a speedy trial was not violated. View "State v. Farmer" on Justia Law

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The Supreme Court reversed the decision of the court of appeals concluding that Defendant received ineffective assistance of appellate counsel, holding that Defendant failed to prove that his appellate counsel's representation fell below an objective standard of reasonableness.After a jury trial, Defendant was found guilty of possession of a firearm by a felon and being a habitual felon. The court of appeals affirmed. Defendant subsequently filed a motion for appropriate relief alleging ineffective assistance of appellate counsel. Specifically, Defendant asserted that appellate counsel's failure to cite State v. Pakulski, 356 S.E.2d 319 (N.C. 1987), amounted to ineffective assistance. After a successful appeal and remand, the trial court granted the motion. The court of appeals affirmed, holding that Defendant's appellate counsel was constitutionally ineffective for failing to make arguments under Pakulski. The Supreme Court reversed, holding the precedent established in Pakulski did not govern the instant case and that appellate counsel's failure to rely on Pakulski was objectively reasonable. View "State v. Collington" on Justia Law

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The Supreme Court vacated the order of the trial court dismissing Defendant's motion for appropriate relief (MAR) in which Defendant asserted claims under the Racial Justice Act (RJA), holding that the retroactive application of the 2012 amended RJA and the 2013 repeal of the RJA violates the constitutional prohibitions against ex post facto laws.The trial court dismissed Defendant's MAR, concluding that it was voided by the repeal of the RJA. The Supreme Court vacated the trial court's order and remanded the case for the reinstatement of Defendant's sentence of life imprisonment without parole, holding (1) the retroactivity provision of the RJA repeal violated the double jeopardy protections of the North Carolina Constitution; (2) the judgment sentencing Defendant to life imprisonment without the possibility of parole was a final judgment, and therefore, double jeopardy barred further review; and (3) the retroactive application of the RJA repeal violates the prohibitions against ex post facto laws contained in the state and federal constitutions. View "State v. Augustine" on Justia Law

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The Supreme Court held that the retroactivity provision of the Racial Justice Act (RJA) Repeal violated the double jeopardy protections of the North Carolina Constitution.Defendant was convicted of first-degree murder and sentenced to death. After the North Carolina General Assembly enacted the RJA, Defendant filed a motion for appropriate relief pursuant to the RJA. After a hearing, the trial court concluded that race was a significant factor in the decisions of prosecutors to exercise peremptory challenges to strike African-American jurors and resentenced Defendant to life imprisonment without the possibility of parole. After three more defendants showed that their death sentences were sought or imposed on the basis of race the General Assembly repealed the RJA. The trial court concluded that the RJA Repeal retroactively voided the defendants' claims and dismissed each of the defendants' motions for appropriate relief. The Supreme Court vacated the trial court's order, holding that the retroactivity provision of the RJA Repeal violates double jeopardy protections and that, in any event, the State lacked the statutory authority to appeal that judgment. View "State v. Robinson" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming superior court judgments denying Defendant's Batson motion, holding that Defendant presented a sufficient record to permit meaningful appellate review of Defendant's Batson challenge and that Defendant established the existence of a prima facie case of discrimination necessary to require the performance of a complete Batson analysis.The trial court allowed Defendant to make a Batson motion but subsequently denied the motion, finding that there was no prima facie showing justifying the Batson challenge. The court of appeals also rejected Defendant's Batson claim, stating that, "[a]ssuming, arguendo, that defendant's argument is properly before us, we find no error in the ruling of the trial court and affirm." The Supreme Court reversed and remanded the case for further proceedings in the superior court, holding (1) the record was sufficient to permit appellate review of the merits of Defendant's Batson claim; and (2) the trial court erred in failing to find the existence of a prima facie showing of racial discrimination. View "State v. Bennett" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the order of the trial court denying Defendant's motion to suppress evidence seized during the execution of a search warrant, holding that the warrant supported by probable cause.Defendant pled guilty to the offense of trafficking in cocaine while preserving his right to appeal the denial of his motion to suppress. On appeal, Defendant argued that the trial court erred in denying his motion to suppress because the facts contained in the affidavit were insufficient to establish probable cause to search his residence. The court of appeals affirmed. The Supreme Court affirmed, holding that the affidavit contained facts that were sufficient to provide a nexus between the residence and suspected criminal activity, and therefore, the warrant was supported by probable cause. View "State v. Bailey" on Justia Law