Justia Civil Rights Opinion Summaries

A jury found Defendant Nakia Nickerson guilty of felonious possession of stolen goods. Defendant appealed, arguing that the trial court erred by not instructing the jury on unauthorized use of a motor vehicle, contending that it was a lesser-included offense of the crime of possession of stolen goods. The court of appeals reversed, concluding (1) unauthorized use of a motor vehicle is a lesser-included offense of possession of stolen goods, and (2) the trial court erred when it failed to instruct the jury on the lesser-included offense. The Supreme Court reversed, holding (1) because the offense of unauthorized use of a motor vehicle requires proof of at least one essential element not required to prove possession of stolen goods, unauthorized use of a motor vehicle cannot be a lesser-included offense of possession of stolen goods; and (2) as such, Defendant was not entitled to an instruction on unauthorized use of a motor vehicle.

Defendant Eugene Hill was convicted of robbery with a dangerous weapon for taking $100 from the victim by means of threatening the use of a sharp object. Defendant appealed, arguing that the trial court erred by denying his motion to dismiss on the ground that the evidence was insufficient. The court of appeals affirmed. At issue on appeal was whether the State presented substantial evidence that (1) the victim's money was taken via the use or threatened use of a dnagerous weapon, and (2) the victim's life was endangered or threatened by Defendant's use of a dangerous weapon during the course of the robbery. The Supreme Court affirmed, holding that the State presented sufficient evidence to support Defendant's conviction.

Defendant Khuram Choudhry was convicted of first-degree murder and sentenced to life without parole. Defendant appealed, arguing that the trial court conducted an adequate inquiry pertaining to defense counsel's possible conflict of interest arising from counsel's prior representation of a State's witness. The court of appeals affirmed. The Supreme Court modified and affirmed the decision of the court of appeals, holding (1) although the trial court heard argument from the prosecutor and from defense counsel on this issue and made direct inquiry of Defendant after placing him under oath, under the facts of this case, the inquiry was insufficient to assure that Defendant knowingly, intelligently, and voluntarily made his decision regarding counsel's continued representation; but (2) Defendant failed to make a threshold showing that defense counsel's performance was adversely affected by the conflict, much less that Defendant was prejudiced by the representation.

A jury found defendant Mario Phillips guilty of four counts of first-degree murder. The jury also found defendant guilty of first-degree kidnapping, attempted first-degree murder, assault with a deadly weapon with intent to kill inflicting serious injury, robbery with a firearm, and first-degree arson. Following a capital sentencing hearing, the jury recommended a sentence of death for each murder conviction. Defendant appealed to the Supreme Court, arguing that (1) the trial court erred in regard to several pretrial matters such as denying defendant's motion to suppress and denying him effective assistance of counsel; (2) the trial court erred in regard to several matters during the trial such as admitting certain testimony and not intervening during the state's closing argument; (3) the trial court erred in regard to certain sentencing proceeding matters such as failing to intervene during the state's closing argument; and (4) the trial court erred in regard to several preservation issues. The Supreme Court overruled each assignment of error. The Court concluded that the defendant received a fair trial and capital sentencing proceeding and that the death sentence imposed by the trial court was not disproportionate to the penalty imposed in similar cases. No error.

Defendant Benzion Biber was indicted for felonious possession of cocaine. Prior to trial defendant filed a motion to suppress evidence. The trial court denied the motion. Defendant appealed, arguing that the trial court's ruling on his suppression motion was erroneous in that the officers lacked probable cause to arrest him for constructive possession of the powdery substance found in his motel room and thus evidence of the crack rocks for which defendant was convicted should be excluded as the fruit of an unlawful seizure. The court of appeals reversed. At issue was whether the trial court was correct in implicitly concluding that the officers had probable cause to arrest defendant for possession of a controlled substance. The Supreme Court reversed the judgment of the appellate court, holding (1) the trial court's findings of fact supported probable cause to arrest defendant for possession of a controlled substance, and (2) the appellate court majority utilized an incorrect evidentiary standard to determine probable cause.