Justia Civil Rights Opinion Summaries

Geoffrey Sanders was convicted by a jury of forcible sodomy, rape, object sexual penetration, and taking indecent liberties with a child. During the trial, the circuit court allowed the commonwealth's medical expert, a doctor, to rely on the results of a laboratory report as the basis of her opinion that the victim had a sexually transmitted infection. Sanders appealed, arguing that this portion of the expert's testimony violated his right to confront witnesses against him as guaranteed by the Confrontation Clause of the Sixth Amendment. The court of appeals found the laboratory report in this instance was not testimonial for purposes of Sixth Amendment confrontation. The Supreme Court affirmed, holding (1) the laboratory report was for medical treatment purposes as it was created to permit the doctor to medically diagnose and treat the victim for sexually transmitted infections and was thus non-testimonial; and (2) a laboratory technician under these circumstances would not have reason to believe the results of his or her testing would be used in later trial and thus the report and the expert's testimony as to its content were not subject to exclusion under Melendez-Diaz v. Massachusetts.

Police officers asked D'Angelo Brooks for permission to search his house for a weapon after someone reported shots fired. Brooks consented. During the search an officer opened a bag, in which he found cash and cocaine. The officer then asked Brooks if this was his cash and drugs, to which Brooks responded affirmatively. Prior to trial Brooks moved to suppress the cocaine as being beyond the scope of his consent to search and his statement as being fruit of the poisonous tree. The court denied the motion to suppress and found Brooks guilty of possession of cocaine. The court of appeals denied Brooks' petition for appeal. The Supreme Court held (1) the appellate court did not err when it upheld the denial of the motion to suppress the cocaine and Brooks' statement to the officer afterwards because the search of the bag was objectively reasonable and thus permissible under the Fourth Amendment; and (2) Brooks' statement was not obtained in violation of his Fifth and Sixth Amendment rights because a reasonable person in Brooks situation would not have believed he was in custody, and therefore no Miranda warning was needed.