Justia Civil Rights Opinion Summaries

Woodall pled guilty to capital murder, capital kidnapping, and first degree rape in connection with the 1997 murder of a 16-year-old girl. After a penalty trial, the trial court adopted the recommendation of the jury and sentenced Woodall to death on the murder conviction and life imprisonment for the remaining convictions. Woodall unsuccessfully appealed his sentence to the Kentucky Supreme Court and then filed a writ of habeas corpus in federal district court. The district court granted the petition because the trial court denied him his Fifth Amendment right against self-incrimination by refusing to give a requested “no adverse inference” instruction with respect to Woodall not testifying and made a constitutional error during jury selection in allowing the prosecution to use a peremptory challenge to strike an African-American member of the jury without holding a hearing pursuant to Batson. The Sixth Circuit affirmed.

In 1993, Lancaster, a former police officer with a long history of mental illness, shot his girlfriend and was charged by the state of Michigan with first-degree murder and with possession of a firearm in the commission of a felony. At his 1994 jury trial, he was convicted on both counts despite his asserted defenses of insanity and diminished capacity. The judgment was overturned, however, due to a Batson violation. When Lancaster was retried in 2005, he opted to be tried without a jury. Lancaster had planned to limit his defense to diminished capacity. But the trial court prohibited Lancaster from asserting the defense because, in the interim between his two trials, the Michigan Supreme Court had abolished the diminished-capacity defense (Carpenter decision). Lancaster was convicted and sentenced to life plus two years in prison. In his petition for a writ of habeas corpus, Lancaster claimed that his right to due process was violated by the state court’s retroactive application of Carpenter. The district court denied his petition. The Sixth Circuit reversed, granting the petition unless the state commences a new trial within 180 days in which Lancaster is permitted to assert the defense of diminished capacity.

Three petitioners received separate jury trials in Kent County, Michigan in 2001 or 2002. At jury selection, the petitioners did not object to racial composition of their respective venires; they were subsequently convicted. A few months later, the Grand Rapids Press published a story detailing how jury selection software had a computer glitch that had systematically excluded African-Americans from the jury pool. Petitioners each filed motions for post-conviction relief in state court. The state court found that the petitioners had waived these claims by failing to object to the racial composition of the jury venire during voir dire. A federal district court denied two habeas petitions, but another court granted the petition, holding that the petitioner could not have known of the computer glitch and presuming prejudice because the glitch caused a structural error. The Sixth Circuit remanded all three cases. Petitioners have shown cause to excuse their defaults, but federal-state comity requires that the district court find actual prejudice before granting relief.

Amos’s third wife died of a cocaine overdose while in a hotel room alone with Amos. He was convicted of first-degree premeditated murder and first-degree murder by poisoning and sentenced to two terms of life imprisonment without the possibility of parole. On remand, the judgment was amended to reflect only one conviction of first-degree murder under two theories. The Michigan Supreme Court denied leave to appeal. After state courts denied habeas relief, the district court found that three of the claims were procedurally defaulted and rejected remaining claims. The Sixth Circuit affirmed, finding no merit in claims of ineffective assistance of counsel and due process violations in the forms of prosecutorial misconduct and false testimony or withholding evidence with regard to the level of cocaine in the victim’s system.

Police received multiple 911 calls regarding Kevin’s threatening behavior. After verifying the threats, officers went to his father’s property, which was dark and surrounded by heavy woods. His father told officers that Kevin had been drinking, was possibly suicidal, and owned guns. Before officers could implement their plan, Kevin drove up, approaching the patrol cars. Officers activated lights and ordered Kevin to raise his hands and exit the vehicle. Kevin shifted into reverse and backed into the woods. During pursuit, Kevin’s truck became stuck in snow. Officers approached, ordering Kevin to show his hands. Kevin refused; an officer opened the truck door, yelled “Taser,” and deployed his taser. Kevin’s jacket prevented the taser from properly functioning. Kevin arose from the seat, yelled that he had a gun and turned toward the officers, his hands extended in a firing position. After shooting Kevin, officers began lifesaving procedures until an ambulance arrived. Kevin did not survive. Police found cell phone with the antenna extended on the front seat and a rifle in the snow, several car lengths away from Kevin’s truck. In a suit under 42 U.S.C. 1983, the Sixth Circuit affirmed summary judgment in favor of defendants on the basis of qualified immunity.

Hoover, a combat veteran who served in Iraq, alleged that police violated his rights by stopping his vehicle, prolonging the stop into an investigatory detention, transporting him to a police station and having him committed for psychiatric evaluation. He sued under 42 U.S.C. 1983, with state law claims for false arrest, false imprisonment, and assault and battery. The district court granted defendants summary judgment. The Sixth Circuit affirmed. Officers had reasonable cause for an investigatory stop after they observed a vehicle, filled to the brim with personal items, traveling at random, through a neighborhood known for theft and property crimes, at 1:20 a.m. Suspicions were further aroused when Hoover informed them that he intended to leave the state with his 18-month-old child and that he did not know where his wife was. They had probable cause to arrest Hoover before they asked him to exit his vehicle; 36 minutes after they initiated the stop, they learned that Hoover’s wife reported a domestic incident and that he was trying to escape with the child. Hoover’s wife confirmed that Hoover had experienced problems after returning from Iraq, had become increasingly violent, had destroyed property, and had held a knife to his neck while threatening to take his life.

Following a traffic stop for failing to dim her high beams in the face of oncoming traffic, Green was arrested for driving under the influence of drugs or alcohol, based on her responses to a series of field sobriety tests administered by a state trooper. A more definitive test, her urine sample, later came back clean; all charges were dropped. Green sued under 42 U.S.C. 1983, alleging that the trooper violated her Fourth Amendment rights by conducting field sobriety tests without having a reasonable suspicion that she was impaired and arresting her without probable cause. The district court dismissed. The Sixth Circuit reversed. A reasonable jury could find that Green's conduct did not create a reasonable suspicion that she was driving under the influence, that Green acted rationally throughout the stop, that her relatively minor traffic violations were not indicative of impairment, and that the officer fabricated the alleged constriction of her pupils to create an after-the-fact justification for the detention.

Nali and O'Brien started a 10-year sexual relationship in 1992. O’Brien was married. Nali videotaped their sexual encounters without consent. O'Brien attempted to end the relationship; Nali threatened to give the videotapes to her family and the media. After O’Brien divorced, she ended her relationship with Nali, who refused to leave her alone. After she reported harassment to police, her ex-husband intercepted a package addressed to their daughter, containing a videotape of sexual encounters between Nali and O'Brien. Her brothers received similar packages. Convicted of extortion, Nali was sentenced to 50 months to 20 years. Both his direct appeal to the Michigan Court of Appeal and a motion to remand for development of the record to support an ineffective assistance of counsel claim failed. The Supreme Court of Michigan denied review. The federal district court found the evidence insufficient to support conviction and granted an unconditional writ of habeas corpus, but concluded that Nali was not denied effective assistance of counsel; the court ordered immediate release. The Sixth Circuit reversed. The state court properly determined that a rational jury could find Nali guilty beyond a reasonable doubt and that he was not prejudiced by any failings of counsel.

Plaintiff was arrested after police officers found her intoxicated, sitting in the driver’s seat of her running, but legally parked, Hummer. She was charged with operating a vehicle while intoxicated, but the state trial court dismissed her case, finding that she was not "operating" her Hummer as that term is defined under Michigan law. Plaintiff sued her arresting officers, arguing, among other things, that they unconstitutionally detained her without reasonable suspicion and arrested her without probable cause. The district court held that the officers had qualified immunity. The Sixth Circuit affirmed. There was a reasonable basis to believe that plaintiff was operating her Hummer while intoxicated, and was therefore violating Michigan law.

In 1985, petitioner was convicted of distributing cocaine and sentenced to 15 years' imprisonment to be followed by a mandatory ten-year term of special parole, pursuant to 21 U.S.C. 841, repealed in 1984. In 2000, he was released on special parole. This began a cycle during which petitioner repeatedly violated the terms of his special parole, was incarcerated, and was re-released on special parole. By statute, each time he violated the terms of special parole, he forfeited credit for any time he spent in noncustodial supervision. As a result, the term of special parole is not set to expire until 2017. Petitioner filed a habeas petition challenging the re-imposition of special parole, and the district court denied relief. The Sixth Circuit affirmed, rejecting an argument that the regulation illegally circumvented statutorily required exercise of case-by-case discretion. Regardless of whether the Parole Commission has authority to reimpose a previously revoked term of special parole, petitioner still would have forfeited his time in non-custodial supervision under current parole regulations.