Justia Civil Rights Opinion Summaries

In 1993, Lancaster, a former police officer with a long history of severe mental-health problems, killed his girlfriend. At his jury trial in Michigan state court, Lancaster asserted a defense of diminished capacity. Under then-prevailing Michigan Court of Appeals precedent, the diminished-capacity defense permitted a legally sane defendant to present evidence of mental illness to negate the specific intent required to commit a particular crime. The jury convicted him of first-degree murder. Lancaster later obtained federal habeas relief. By the time of Lancaster’s retrial, the Michigan Supreme Court had rejected the diminished-capacity defense in its 2001 decision, Carpenter. The judge at his second trial applied Carpenter and disallowed renewal of his diminished-capacity defense. Lancaster was again convicted. The Michigan Court of Appeals rejected Lancaster’s argument that retroactive application of Carpenter violated due process. Lancaster reasserted his due process claim in a federal habeas petition. The district court denied the petition, but the Sixth Circuit reversed. A unanimous Supreme Court reversed, holding that Lancaster is not entitled to federal habeas relief. The Michigan Court of Appeals’ rejection of Lancaster’s due process claim does not represent an unreasonable application of Supreme Court precedent, 28 U. S. C.2254(d)(1). In Carpenter, the Michigan Supreme Court rejected a diminished-capacity defense, reasonably finding the defense to have no origin in an on-point statute. The Supreme Court has never found a due process violation where a state supreme court, squarely addressing a particular issue for the first time, rejected a consistent line of lower court decisions based on the supreme court’s reasonable interpretation of a controlling statute. Fair-minded jurists could conclude that a state supreme court decision of that order is not “unexpected and indefensible by reference to [existing] law.” View "Metrish v. Lancaster" on Justia Law

McNeely, stopped for speeding and crossing the centerline, declined to take a breath test to measure his blood alcohol concentration (BAC). He was arrested and taken to a hospital. The officer never attempted to secure a search warrant. McNeely refused to consent, but the officer directed a lab technician to take a sample. McNeely’s BAC tested above the legal limit, and he was charged with driving while intoxicated. The trial court suppressed the test result, concluding that the exigency exception to the warrant requirement did not apply because, apart from the fact that McNeely’s blood alcohol was dissipating, no circumstances suggested that the officer faced an emergency. The Missouri Supreme Court and U.S. Supreme Court affirmed. The Court looked to the “totality of circumstances,” declining to announce a per se rule. When officers in drunk-driving investigations can reasonably obtain a warrant before having a blood sample drawn without significantly undermining the efficacy of the search, the Fourth Amendment mandates that they do so. Circumstances may make obtaining a warrant impractical such that dissipation will support an exigency, but that is a reason to decide each case on its facts. Blood testing is different in critical respects from other destruction-of-evidence cases; BAC evidence naturally dissipates in a gradual and relatively predictable manner. Because an officer must typically obtain a trained medical professional’s assistance before having a blood test conducted, some delay between the time of the arrest and time of the test is inevitable regardless of whether a warrant is obtained. View "Missouri v. McNeely" on Justia Law

Rodgers was charged with making criminal threats, assault with a firearm, and being a felon in possession of a firearm and ammunition. Before arraignment, he executed a valid waiver of his Sixth Amendment right to counsel, electing to represent himself. Before his preliminary hearing, Rodgers retained counsel. Two months later, he fired his lawyer and again waived counsel. Two months after that, Rodgers again changed his mind and asked the court to appoint an attorney. The court did so. Shortly before trial, he again surrendered his right to counsel. He proceeded to trial pro se. In June 2003, a California jury returned a verdict of guilty. After the verdict was read, Rodgers requested an attorney to help him move for a new trial. When offered a chance to supplement or explain his motion at a later hearing, Rodgers declined to do so. The trial court denied the request for counsel and the motion for a new trial. The California Court of Appeal affirmed the convictions and sentence. The federal district court denied habeas corpus. The Ninth Circuit reversed. The Supreme Court reversed, finding that, in light of the tension between the Sixth Amendment’s guarantee of “the right to counsel at all critical stages of the criminal process,” and its concurrent promise of “a constitutional right to proceed without counsel when [defendant] voluntarily and intelligently elects to do so,” it cannot be said that California’s approach was contrary to or an unreasonable application of the Court’s assistance-of-counsel cases. The Court expressed no view on the merits of the underlying Sixth Amendment principle. View "Marshall v. Rodgers" on Justia Law

The Federal Tort Claims Act (FTCA) waives the government’s sovereign immunity from tort suits, but excepts from that waiver certain intentional torts, 28 U. S. C. 2680(h). Section 2680(h) contains a proviso that extends the waiver of immunity to claims for six intentional torts, including assault and battery, that are based on the “acts or omissions” of an “investigative or law enforcement officer” “who is empowered by law to execute searches, to seize evidence, or to make arrests.” A federal prisoner, sued the United States under the FTCA, alleging assault and battery by correctional officers. The district court granted the government summary judgment; the Third Circuit affirmed, reasoning that the “law enforcement proviso” applies only to tortious conduct that occurs during the course of executing a search, seizing evidence, or making an arrest. The Supreme Court reversed. The law enforcement proviso extends to law enforcement officers’ acts or omissions that arise within the scope of employment, regardless of whether the officers are engaged in investigative or law enforcement activity, or are executing a search, seizing evidence, or making an arrest. Congress intended immunity determinations to depend on a federal officer’s legal authority, not on a particular exercise of that authority. Nor does the proviso indicate that a waiver of immunity requires the officer to be engaged in investigative or law enforcement activity. View "Millbrook v. United States" on Justia Law

Police took a drug-sniffing dog to Jardines’ front porch, where the dog gave a positive alert for narcotics. The officers then obtained a warrant for a search, which revealed marijuana plants. Jardines was charged with trafficking in cannabis. The Supreme Court of Florida approved the trial court’s suppression of the evidence. The U.S. Supreme Court affirmed. The investigation of Jardines' home was a search within the meaning of the Fourth Amendment. When the Government obtains information by physically intruding on persons, houses, papers, or effects, a search within the original meaning of the Fourth Amendment has "undoubtedly occurred." The right of a man to retreat into his own home and there be free from unreasonable governmental intrusion is the "very core” of the Fourth Amendment. The area immediately surrounding and associated with the home, the curtilage, is part of the home itself for Fourth Amendment purposes. The front porch is the classic exemplar of an area to which the activity of home life extends. The officers' entry was not explicitly or implicitly invited. Officers need not "shield their eyes" when passing a home on public thoroughfares but "no man can set his foot upon his neighbour's close without his leave." A police officer without a warrant may approach a home in hopes of speaking to occupants, because that is “no more than any private citizen might do” but the scope of a license is limited not only to a particular area but also to a specific purpose, and there is no customary invitation to enter the curtilage simply to conduct a search. View "Florida v. Jardines" on Justia Law

A California jury convicted Williams of murder. On direct appeal she claimed that questioning and dismissal of a juror during deliberations violated the Sixth Amendment and California law. Holding that the juror had been properly dismissed for bias, the California Court of Appeal quoted a Supreme Court definition of “impartiality,” but did not expressly acknowledge that it was deciding a Sixth Amendment issue. The state’s highest court remanded in light of its intervening decision that a trial court abused its discretion by dismissing, for failure to deliberate, a juror who appeared to disagree with the rest of the jury. Reaffirming its prior decision, the court of appeal discussed that decision and again failed to expressly acknowledge the federal claim. Williams ought federal habeas relief. The district court applied the deferential standard of review under the Antiterrorism and Effective Death Penalty Act for claims already “adjudicated on the merits in State court,” 28 U. S. C. 2254(d). The Ninth Circuit concluded that the state court had not considered Williams’ Sixth Amendment claim, reviewed that claim de novo, and found violation of the Sixth Amendment. The Supreme Court reversed. When a state court rules against a defendant in an opinion that rejects some of the defendant’s claims but does not expressly address a federal claim, a federal habeas court must presume, subject to rebuttal, that the federal claim was adjudicated on the merits for purposes of AEDPA. Applying that rebuttable presumption, the Ninth Circuit erred. Several facts indicate that the state court did consider the Sixth Amendment claim. View "Johnson v. Williams" on Justia Law

The district court increased the length of Henderson’s sentence so he could participate in a prison drug rehabilitation program. Henderson’s counsel did not object to the sentence, but, on appeal, Henderson claimed plain error. While appeal was pending, the Supreme Court decided, in Tapia v. United States, that it is error for a court to impose or lengthen a prison sentence to enable an offender to complete a treatment pro¬gram or otherwise to promote rehabilitation. The Fifth Circuit determined that Rule 52(b) did not give it authority to correct the error, reasoning that an error is “plain” only if it was clear under law at the time of trial. The Supreme Court reversed. Regardless of whether a legal question was settled or unsettled at the time of trial, an error is “plain” under Rule 52(b) if it was plain at the time of appellate review. If “plain error” covers trial court decisions that were plainly correct when made and those that were plainly incorrect when made, it should cover cases where the law was unsettled. A “time of review” interpretation furthers the basic principle that “an appellate court must apply the law in effect at the time it renders its decision,” works little harm upon the competing principle that insists that counsel call a potential error to the trial court’s attention, and is consistent with Rule 52(b)’s purpose of creating a fairness-based exception to the general requirement that an objection be made at trial to preserve a claim of error. View "Henderson v. United States" on Justia Law

After the State of Michigan rested its case at Evans’ arson trial, the court granted a directed verdict of acquittal, concluding that the state had failed to prove that the burned building was not a dwelling, a fact the court mistakenly believed was an “element” of the statutory offense. The court of appeals reversed and remanded for retrial. In affirming, the state’s highest court held that a directed verdict based on an error of law that did not resolve a factual element of the charged offense was not an acquittal for double jeopardy purposes. The Supreme Court reversed; the Double Jeopardy Clause bars retrial. An acquittal encompasses any ruling that the prosecution’s proof is insufficient to establish criminal liability for an offense. Unlike procedural rulings, which lead to dismissals or mistrials on a basis unrelated to factual guilt or innocence, acquittals are substantive rulings that conclude proceedings absolutely, and raise significant double jeopardy concerns. The trial court clearly evaluated the state’s evidence and determined that it was legally insufficient to sustain a conviction. The acquittal was the product of an erroneous interpretation of governing legal principles, but that error affects only the accuracy of the determination to acquit, not its essential character. View "Evans v. Michigan" on Justia Law

Immigration officials initiated removal proceedings against Chaidez in 2009 upon learning that she had pleaded guilty to mail fraud in 2004. To avoid removal, she sought to overturn that conviction by filing a petition for a writ of coram nobis, contending that her former attorney’s failure to advise her of the guilty plea’s immigration consequences constituted ineffective assistance of counsel. While her petition was pending, the Supreme Court held, in Padilla v. Kentucky, that the Sixth Amendment requires defense attorneys to inform non-citizen clients of the deportation risks of guilty pleas. The district court vacated Chaidez’s conviction. The Seventh Circuit reversed, holding that Padilla had declared a new rule and should not apply in a challenge to a final conviction. The Supreme Court affirmed. Padilla does not apply retroactively to cases already final on direct review. A case does not announce a new rule if it merely applies a principle that governed a prior decision to a different set of facts. Padilla’s ruling answered an open question about the Sixth Amendment’s reach, in a way that altered the law of most jurisdictions, breaking new ground and imposing a new obligation. View "Chaidez v. United States" on Justia Law

Officer Wheetley pulled Harris over for a routine traffic stop. Wheetley sought consent to search Harris’s truck, based on Harris’s nervousness and seeing an open beer can. When Harris refused, Wheetley executed a sniff test with his trained narcotics dog, Aldo, who alerted at the driver’s-side door, leading Wheetley to conclude that he had probable cause to search. The search turned up nothing Aldo was trained to detect, but did reveal ingredients for manufacturing methamphetamine. Harris was charged with illegal possession of those ingredients. In a subsequent stop while Harris was out on bail, Aldo again alerted on Harris’s truck but nothing of interest was found. The trial court denied a motion to suppress. The Florida Supreme Court reversed, holding that if an officer failed to keep records of field performance, including how many times a dog falsely alerted, he could never have probable cause to think the dog a reliable indicator of drugs. The Supreme Court reversed. Training and testing records supported Aldo’s reliability in detecting drugs and Harris failed to undermine that evidence, so Wheetley had probable cause to search. Whether an officer has probable cause depends on the totality of the circumstances, not rigid rules, bright-line tests, and mechanistic inquiries. Requiring the state to introduce comprehensive documentation of a dog’s prior hits and misses in the field is the antithesis of a totality-of-the-circumstances approach. Field records may sometimes be relevant, but the court should evaluate all the evidence, and should not prescribe an inflexible set of requirements. View "Florida v. Harris" on Justia Law