Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the order of the district court granting Defendant's motion to suppress drugs and drug paraphernalia police discovered while searching her backpack, holding that the district court properly determined that the search of Defendant's backpack was beyond the scope of a permissible search incident to arrest.After officers arrested Defendant, they placed her inside a patrol car, placed her backpack in the trunk of the patrol car, and transported her to jail. Thereafter, the officers searched Defendant's backpack. On appeal, the State argued that the contraband was discovered in a lawful search incident to arrest or, alternatively, would have been inevitably discovered in a lawful inventory of the backpack's contents. The Supreme Court disagreed, holding (1) the search incident to arrest was invalid; and (2) because the evidence would not have been discovered through a lawful inventory search, the evidence was not admissible under the inevitable-discovery doctrine. View "State v. Nye" on Justia Law

The Supreme Court reversed Defendant's conviction, holding that, based on the record, it was more likely than not that the State used a peremptory challenge for impermissible reasons in violation of Batson v. Kentucky, 476 U.S. 79 (1986), necessitating a new trial.Defendant faced multiple charges related to a shooting. During jury selection, the State exercised one of its peremptory challenges to remove an African-American veniremember. Defendant made a Batson objection claiming that the peremptory challenge was based on the juror's race. The district court summarily overruled the objection without making any specific findings or explaining its reasoning. The Supreme Court reversed the judgment of conviction, holding (1) the record belied the State's nondemeanor explanations for using a peremptory challenge on the juror, indicating that the explanations were pretextual; and (2) because the district court did not fully engage in the inquiry and consideration required at step three in the Batson analysis, the court clearly erred in denying Defendant's Batson objection. View "Matthews v. State" on Justia Law

The Supreme Court reversed one of Defendant's convictions for robbery but affirmed the judgment of conviction in all other respects after adopting factors to guide the Court in deciding whether to consider an error's harmlessness despite the State's failure to argue it, holding that the district court's error in denying Defendant's motion to suppress was harmless.Defendant was found guilty of two counts of robbery with the use of a deadly weapon, murder with the use of a deadly weapon, and other crimes. The jury sentenced Defendant to death. On appeal, Defendant argued that the district court erred in denying his motion to suppress statements he made during an interview with detectives before his arrest. The Supreme Court concluded that the district court did err by denying Defendant's motion to suppress. The Court then adopted three factors to help determine whether the Court should consider an error's harmlessness when the State has not argued harmlessness in a death penalty case. After weighing those factors, the Court held (1) sua sponte harmless error review was appropriate in this matter, and the complained-of error was harmless; (2) one of the convictions for robbery was not supported by sufficient evidence; and (3) no other issue warranted relief. View "Belcher v. State" on Justia Law

The Supreme Court affirmed the district court's judgment of conviction and amended judgment of conviction convicting Defendant of first-degree murder and other crimes and denying Defendant's motion for a new trial, holding that any error was harmless.A jury found Defendant guilty of first-degree murder, sexual assault, and burglary and denied Defendant's motions for a new trial. The Supreme Court affirmed, holding that the district court (1) did not err in admitting evidence of other bad acts; (2) did not violate Defendant's rights under the Confrontation Clause; (3) did not violate Defendant's due process right to a fair trial by admitting autopsy photographs; (4) did not deny Defendant a fair trial by invoking Nevada hearsay rules to exclude certain testimony; (5) erred by not allowing Defendant to introduce certain evidence, but the error was harmless; and (6) did not tolerate prosecutorial misconduct. Further, the conviction was supported by sufficient evidence, and the district court did not err in denying Defendant's motion for a new trial on the basis of newly discovered evidence. View "Flowers v. State" on Justia Law

The Supreme Court vacated the judgment of conviction, pursuant to a jury verdict, of seven counts of robbery with the use of a deadly weapon and other offenses, holding that Defendant made specific factual allegations that could be sufficient to establish a prima facie violation of the requirement that a Defendant choose from a fair cross section of the community and those allegations were not disproved, and therefore, the district court abused its discretion by denying Defendant's request for an evidentiary hearing.At issue in this case was when an evidentiary hearing may be warranted on a fair-cross-section claim. The Supreme Court held (1) an evidentiary hearing is warranted on a fair-cross-section challenge when a defendant makes specific allegations that, if true, would be sufficient to establish a prima facie violation of the fair-cross-section requirement; (2) the district court abused its discretion in denying Defendant's request for an evidentiary hearing on his fair-cross-section challenge; and (3) none of Defendant's other arguments required a new trial. View "Valentine v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of multiple sex offenses against children and related offenses, holding that the trial judge's behavior and statements during voir dire constituted judicial misconduct and that the misconduct interfered with Defendant's right to an impartial jury.During the second day of voir dire in this case, a prospective juror stated that she did not think she could be unbiased toward Defendant. Thereafter, the trial judge threw a book against the wall, cursed, and berated, yelled at, and threatened that prospective juror. After a trial, the jury returned guilty verdicts on most of the counts with which Defendant was charged. On appeal, Defendant argued that the district court's misconduct during voir dire and the denial of his request for a new venire violated his right to a fair trial by an impartial jury. The Supreme Court agreed, holding that the judicial misconduct in this case deprived Defendant of his constitutional right to a fair trial before an impartial jury. View "Azucena v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court admitting certain out-of-court statements after finding that the witness was unavailable and that Defendant had intentionally deterred the witness from appearing at trial, holding that the record supported the court's conclusion that the State met its burden of proof in invoking the forfeiture by wrongdoing exception to the Confrontation Clause.Relying on the forfeiture by wrongdoing exception the trial court admitted the out-of-court statements despite Defendant's assertion of his right to confrontation. The Supreme Court affirmed, holding (1) the preponderance of the evidence standard is the appropriate burden of proof for purposes of the forfeiture by wrongdoing exception to the Confrontation Clause; and (2) the trial court did not err in its application of the forfeiture by wrongdoing exception to admit the witness's out-of-court statements. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Appellant of two counts of first-degree murder with a deadly weapon after adopting a framework for analyzing the appropriateness of juror anonymity, holding that the district court did not abuse its discretion when it empaneled an anonymous jury by withholding the jurors' names and addresses from counsel.Due to concerns about juror privacy, the district court decided to impanel an anonymous jury and redact the jurors' names and addresses from juror questionnaires. After a trial, the empaneled jury found Defendant guilty of two counts of murder and found that Defendant had used a deadly weapon in the commission of the crimes. The district court sentenced Defendant to life without parole on each count. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in empaneling an anonymous jury, and its use satisfied the rule adopted today; (2) a district court has no statutory obligation to instruct a jury about the consequences of a deadly weapon enhancement; and (3) the district court did not err when it admitted as consciousness-of-guilt evidence two recorded conversations during which Defendant asked his associates to threaten a key witness. View "Menendez-Cordero v. State" on Justia Law

The Supreme Court affirmed the district court’s order dismissing Plaintiff-inmate’s complaint to the extent Plaintiff asserted state tort claims under Nev. Rev. Stat. 41.031 and 41.0337 but reversed the district court’s dismissal as to Plaintiff’s claims made pursuant to 42 U.S.C. 1983, holding that, while a plaintiff must name the State as a party to any state tort claims to comply with sections 41.031 and 41.0337, this statutory requirement does not apply to section 1983 claims.At issue in this case was how sections 41.031 and 41.0337’s requirement that the State be named by a plaintiff as a party to invoke a waiver of Nevada’s sovereign immunity operates when a plaintiff brings an action against state employee pursuant to both those state statutes and 42 U.S.C. 1983. Plaintiff asserted both state tort claims and section 1983 claims against state employees but did not name the State as party to any claims. The district court dismissed the complaint. The Supreme Court reversed in part, holding that Nev. Rev. Stat. Chapter 41’s requirement that a plaintiff name the State as a party to any state tort claims does not apply to section 1983 claims, even when brought in the same complaint as a plaintiff’s state tort claims. View "Craig v. Donnelly" on Justia Law

The Supreme Court reversed and remanded this criminal case for a new trial, holding that the district court clearly erred when it found that Defendant had not made out a prima facie case of discrimination in challenging the State’s use of peremptory challenges to remove two African-American women during jury selection.Defendant was charged with child abuse, neglect, or endangerment and other offenses. Defendant objected to the State’s exercise of two of its peremptory challenges to remove two African-Americans from the jury. The district court denied Defendant’s Batson challenge. The Supreme Court reversed, holding that the district court clearly erred when it terminated the Batson analysis at step one of the three-step analysis and that the record did not clearly support the denial of Defendant’s objection. View "Cooper v. State" on Justia Law