Justia Civil Rights Opinion Summaries

While on patrol, a police officer observed a pick-up truck parked in a shopping center lot. Because the truck's headlights were turned on, the officer stopped her patrol car directly behind the truck and activated her blue lights. The officer then approached the truck, observed a beer can in a cup holder inside, and found Defendant in the driver's seat with the keys in the ignition. Defendant was subsequently convicted for his fourth offense of driving under the influence. The court of criminal appeals reversed, holding (1) Defendant had been seized by the officer at the time the blue lights were activated; and (2) at the time of the seizure, the officer lacked either probable cause or reasonable suspicion to support an investigatory stop. The Supreme Court affirmed, holding (1) the activation of blue lights will not always qualify as a seizure; and (2) the totality of the circumstances in this instance established that the officer seized Defendant absent probable cause or reasonable suspicion and was not otherwise acting in a community caretaking role. View "State v. Moats" on Justia Law

After a jury trial, Petitioner was convicted of especially aggravated kidnapping, aggravated assault, especially aggravated robbery, and other robbery charges. The Supreme Court denied Petitioner's appeal, and the U.S. Supreme Court denied Petitioner's petition for writ of certiorari. Petitioner filed a petition for postconviction relief after the statutory deadline had passed because his former attorney provided him the wrong deadline date and failed to give Petitioner his legal files until after the actual deadline had passed. The criminal court dismissed the petition as untimely. The court of criminal appeals affirmed. The Supreme Court reversed and remanded the case to the trial court so Petitioner could pursue his petition for postconviction relief, holding (1) the facts of this case reflected that Petitioner was effectively abandoned by his appellate attorney after his petition for writ of certiorari was filed in the U.S. Supreme Court; (2) this abandonment impeded Petitioner's otherwise diligent efforts to file a timely postconviction petition; and (3) therefore, the statute of limitations should be tolled. View "Whitehead v. State" on Justia Law

Petitioner was convicted of premeditated first degree murder, especially aggravated robbery, and setting fire to person property. Petitioner subsequently filed a petition for post-conviction relief based partly on numerous instances of his trial counsel's ineffective assistance. The post-conviction court dismissed the petition. The court of criminal appeals, however, reversed Petitioner's convictions and remanded for a new trial, determining that Petitioner's trial counsel had been ineffective with regard to limitations placed on the ability of a defense expert to testify that Petitioner's mental condition rendered him unable to premeditate. The Supreme Court (1) reversed the judgment of the court of criminal appeals and affirmed the judgment of the post-conviction court on this issue, holding that Petitioner was not entitled to relief based on the manner in which his trial counsel dealt with the limitations placed of the defense's expert witness; and (2) reversed the judgment of the lower courts denying Defendant's claim relating to trial counsel's failure to object to the requirement that Petitioner wear a stun belt during the trial and remanded that issue for a new hearing, as the record did not permit the reviewing court to determine whether trial counsel was deficient with regard to this issue. View "Mobley v. State" on Justia Law

Defendant was convicted in three separate trials of three sets of execution-style murders, of seven persons total. Defendant faced seven death sentences. Defendant elected not to seek a new trial in any of these cases. Subsequently, Defendant's sister filed a "next friend" petition in each of the murder cases, requesting the courts to declare Defendant incompetent, thereby enabling her to pursue post-conviction relief on Defendant's behalf. Each court denied the petitions, and the court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) the trial courts employed the correct legal standard for determining whether Defendant possessed the mental capacity to rationally forego seeking post-conviction relief; (2) Defendant's sister failed to prove that Defendant lacked the capacity to make rational decisions regarding the pursuit of post-conviction relief; and (3) in all future cases, Tennessee's court should employ the mental competency standard of Tenn. Sup. Ct. R. 28, 11(B) to address the issue of a prisoner's competency to pursue post-conviction relief. View "Reid v. State" on Justia Law

Defendant was indicted on sixteen counts of animal cruelty for intentionally or knowingly failing to provide necessary food and care to horses on his farm. Defendant pleaded not guilty and filed an application for pretrial diversion, stating that he lacked a criminal history and claiming that the horses were sick when he received them. The assistant district attorney general denied the application, finding that the factors against granting pretrial diversion outweighed those in favor of granting pretrial diversion. Defendant filed a petition for writ of certiorari seeking judicial review. The trial court found no abuse of discretion, and the court of criminal appeals affirmed. The Supreme Court affirmed, holding that the assistant district attorney general did not abuse his discretion in denying Defendant pretrial diversion. View "Stanton v. State" on Justia Law

Plaintiff was a tenured teacher who worked for Defendant, the Memphis City Schools Board of Education. After Plaintiff requested and was granted a substantial amount of sick leave but failed to return from that sick leave, Defendant dismissed Plaintiff without providing her with written charges or an opportunity for a hearing. Plaintiff filed a complaint alleging that her dismissal violated the Tennessee Teacher Tenure Act and her constitutional due process rights. The trial court granted Plaintiff's motion for partial summary judgment and awarded Plaintiff's reinstatement, back pay, compensatory damages for the actual harm she suffered, and attorney's fees. The court of appeals vacated the grant of summary judgment. The Supreme Court reversed the judgment of the court of appeals and reinstated the judgment of the trial court, holding (1) although a tenured teacher's failure to return from sick leave may constitute cause for termination, there is no statute authorizing a board of education to deem it a constructive resignation or a forfeiture of tenure; and (2) accordingly, Defendant violated Plaintiff's rights under the Tenure Act and her constitutional due process rights. View "Thompson v. Memphis City Schs. Bd. of Educ." on Justia Law

Petitioner was sentenced to death in 1991 after pleading guilty to murder and rape. In 2010, Petitioner filed a petition seeking to reopen his post-conviction proceeding on the ground that he possessed new scientific evidence of his actual innocence. His evidence consisted of a newly-obtained I.Q. test score purporting to show he could not be executed because he was intellectually disabled. The trial court denied the petition, determining, as a matter of law, that Petitioner's I.Q. test score was not new scientific evidence of his actual innocence. The court of criminal appeals affirmed because the I.Q. test score did not amount to scientific evidence of actual innocence for the purpose of Tenn. Code Ann. 40-30-117(a)(2) and because Coleman v. State did not announce a new rule of constitutional law under section 40-30-117(a)(1). The Supreme Court affirmed, holding (1) the General Assembly, when it enacted section 40-30-117(a)(2), did not intend for the phrase "actually innocent of the offense" to include ineligibility for the death penalty because of intellectual disability; and (2) Coleman v. State does not establish a new rule of constitutional law that must be applied retroactively under section 40-30-117(a)(1). View "Keen v. State" on Justia Law

In 2000, an affidavit of complaint was issued charging "John Doe" with an aggravated rape that occurred in 1994. The affidavit led to the issuance of an arrest warrant. In 2008, law enforcement officers discovered that fingerprints taken from the scene of the crime matched those of Defendant. Later, police determined that the DNA profile of "John Doe" contained in the affidavit was that of Defendant, and a superseding indictment was issued in his name. Defendant was subsequently convicted of attempted aggravated rape. Defendant appealed, arguing that the "John Doe" warrant with the DNA profile was insufficient to identify Defendant and commence prosecution within the applicable statute of limitations. The court of criminal appeals affirmed. The Supreme Court affirmed, holding (1) a criminal prosecution is commenced if, within the statute of limitations for a particular offense, a warrant is issued identifying the defendant by gender and his or her unique DNA profile; and (2) furthermore, a superseding indictment in the defendant's name provides the requisite notice of the charge. View "State v. Burdick" on Justia Law

Defendant pled guilty to reckless endangerment with a deadly weapon and theft of merchandise over five hundred dollars. The trial court sentenced Defendant as a Range II, multiple offender to three years on each count to be served concurrently. On appeal, Defendant argued that the trial court erred by failing to apply certain mitigating factors and by failing to grant probation or an alternative sentence. The court of criminal appeals, after declining to review the sentences because Defendant had failed to provide a transcript of the hearing on the guilty pleas, affirmed based upon a presumption that the evidence was sufficient to support the sentences. After granting an appeal because of conflicting opinions by the court of criminal appeals as to whether the absence of a transcript of a guilty plea submission hearing precludes appellate review on the merits, the Supreme Court ordered that the record be supplemented. The Court then affirmed the judgment of the trial court, holding that the record was adequate for a meaningful review of the sentences either with or without the transcript of the hearing on the guilty pleas, and Defendant was not entitled to relief. View "State v. Caudle" on Justia Law

After a jury trial, Defendant was convicted of especially aggravated robbery and felony murder. Defendant appealed, asserting that the evidence was insufficient to support his convictions. The court of criminal appeals found the evidence was insufficient to support the defendant's conviction of especially aggravated robbery and remanded to the trial court for re-sentencing on Defendant's conviction of second degree murder. The State appealed. The Supreme Court reversed the judgment of the court of criminal appeals and reinstated the judgment of the trial court, holding that the evidence was sufficient to support Defendant's convictions of especially aggravated robbery and felony murder. View "State v. Wagner" on Justia Law