Justia Civil Rights Opinion Summaries

After highway patrol troopers stopped a vehicle, in which Defendant was a passenger, for a traffic infraction, the trooper smelled marijuana on the driver and in the vehicle. Defendant then admitted to the presence of marijuana in the back of the vehicle. A trooper subsequently handcuffed Defendant, patted down his person, and found cocaine on Defendant’s person. Defendant was charged with possession of a controlled substance and possession of marijuana with intent to distribute. The circuit court suppressed the cocaine seized from Defendant’s person, concluding that the State failed to establish that the warrantless search of Defendant’s person was justified under any exception to the warrant requirement. The Supreme Court reversed, holding (1) the search of Defendant’s person did not fall within the search incident to arrest exception to the warrant requirement; but (2) the cocaine evidence was admissible under the inevitable discovery doctrine. View "State v. Smith" on Justia Law

After a jury trial, Appellant was convicted of the first-degree rape of a nine-year-old girl. Prior to trial, the State moved to partially close the courtroom during the victim’s testimony to everyone but the parties, the media, and the State’s victim-witness assistant. The trial court ordered disclosure, and defense counsel did not object. On appeal, Defendant challenged the courtroom closure, alleging, inter alia, that the closure violated his right to a public trial. The Supreme Court affirmed, holding (1) trial counsel, rather than a defendant personally, may waive a defendant’s right to a public trial; and (2) the trial court did not commit plain error by closing the courtroom to the general public during the victim’s testimony. View "State v. Bauer" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of first degree rape, sexual contact with a child under the age of sixteen, and aggravated incest based on allegations that Defendant had sexually abused his nine-year-old granddaughter. The Supreme Court affirmed the convictions, holding (1) the circuit court did not abuse its discretion by prohibiting testimony as to the victim’s brother’s statements; (2) the circuit court did not abuse its discretion by allowing Defendant to proceed pro se at sentencing; (3) Defendant’s sentence did not constitute cruel and unusual punishment; and (4) Defendant’s arguments that he received effective assistance of counsel at trial were not ripe for review on direct appeal. View "State v. Craig" on Justia Law

Joseph Burkett was arrested by Officer Justin Lux after the officer approached the Burkett’s vehicle, which was stopped in the middle of the road, and concluded that Burkett had been driving under the influence. A jury found Burkett guilty of DUI. Based on Burkett’s two prior DUI convictions within ten years of the current offense, Burkett was sentenced to a Class 6 felony. The Supreme Court affirmed, holding (1) the circuit court’s use of Burkett’s prior DUI convictions for sentencing enhancement purposes did not violate Burkett’s right to due process; (2) there was sufficient evidence to support the jury’s verdict; and (3) the circuit court did not err in denying Burkett’s motion to suppress based on Officer's Lux’s stop of Burkett, as the officer's decision to stop Burkett was reasonable. View "State v. Burkett" on Justia Law

After a jury trial, Defendant was found guilty of aggravated assault. On appeal, Defendant argued that the State’s peremptory strike of a Native American veniremember was racially motivated. The Supreme Court held that the circuit court had failed to address third step of the Batson v. Kentucky analysis and remanded with directions for the court to determine whether Defendant satisfied his burden to prove the State’s peremptory strike was racially motivated. On remand, the circuit court performed the third step and concluded that the State’s strike was not based on purposeful racial discrimination. The Supreme Court affirmed after a de novo review, holding that Defendant failed to carry his burden of proving purposeful racial discrimination. View "State v. Scott" on Justia Law

After a jury trial, Defendant was found guilty of three counts of distribution of a controlled drug or substance and three counts of possession of a controlled drug or substance. The Supreme Court affirmed the convictions, holding that the circuit court (1) did not violate Defendant’s due process rights in denying his motion to suppress an in-court identification stemming from an improper photo lineup; (2) did not err in refusing Defendant’s proposed jury instruction regarding cross-racial identification; and (3) did not err in denying Defendant’s motion for judgment of acquittal, as there was sufficient evidence to support the jury verdict. View "State v. Chuol" on Justia Law

Defendant, who was fifteen years old and a native Spanish speaker, was transported to the police department for questioning in connection with the death of Jasmine Guevara. During her questioning by police, Defendant confessed to the murder. Defendant moved to suppress her confession, arguing that she did not voluntarily, knowingly, and intelligently waive her Miranda rights. The juvenile court denied the motion. The case was then transferred to adult court in the First Judicial Circuit. The trial court reopened the motion to suppress and granted the motion, concluding that Defendant made her statements voluntarily but did not knowingly and intelligently waive her rights. The State appealed. The Supreme Court reversed, holding that the trial court erred in suppressing Defendant’s confession where the State met its burden to show more likely than not that Defendant’s waiver of her Miranda rights was “with a full awareness of both the nature of the right being abandoned and the consequences of the decision to abandon it.” View "State v. Diaz" on Justia Law

Defendant pleaded guilty to grand theft by insufficient funds check. Defendant was subsequently sentenced to eight years in the penitentiary. Defendant appealed, arguing that the trial judge failed properly to advise him of all of his constitutional and statutory rights at his plea hearing and that his sentence violated the Eighth Amendment. The Supreme Court affirmed, holding (1) Defendant knowingly and voluntarily entered his guilty plea; and (2) Defendant’s contention that his eight-year penitentiary sentence constituted cruel and unusual punishment was without merit. View "State v. King" on Justia Law

A federal court issued an arrest warrant for Christopher Yellow Eagle, whose warrant was referred to a task force that included federal and county law enforcement officers. The task force officers learned Yellow Eagle was living with Defendant, who had an outstanding warrant for her arrest. The task force arrested Defendant and Yellow Eagle at Defendant’s home after observing that Defendant and Yellow Eagle appeared to be under the influence of a controlled substance and had drugs on their persons. After a court trial, Defendant was convicted of possession of a controlled substance and sentenced to four years incarceration with four years suspended. Defendant appealed the circuit court’s denial of her motion to suppress, arguing (1) the task force officers who executed the arrest warrant were not authorized to enter her home to arrest her, and (2) because Yellow Eagle was a third party in her home, the officers were required to obtain a separate search warrant for the home. The Supreme Court affirmed, holding that the task force officers constitutionally entered Defendant’s home to arrest Defendant, or alternatively, Yellow Eagle. View "State v. Quevedo" on Justia Law

After a jury trial, Defendant was found guilty of eight counts of making false or fraudulent sales tax returns. On appeal, Defendant argued that the circuit court erred in (1) denying his Batson challenges to three peremptory strikes exercised by the State because the court’s Batson analysis was incomplete; and (2) denying his motion for judgment of acquittal. The Supreme Court (1) held that because the Court was unable to determine under the record the circuit court’s reason for denying the Batson challenges, limited remand was required to allow the circuit court to engage in the missing analysis; and (2) affirmed the denial of Defendant’s motion for judgment of acquittal, as the evidence was sufficient to sustain the convictions. View "State v. Guthmiller" on Justia Law