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The justice court properly denied Defendant’s motion to suppress evidence obtained during the interrogation of Defendant by Montana Fish, Wildlife, and Park (FWP) game wardens at a game check station. Defendant was charged with license, permit or tag offense; unlawful possession, transfer, or transport of game animal; and hunting or killing of a game animal over the legal limit. Defendant moved to suppress evidence gathered at the FWP check station, asserting that his incriminating statements were the fruits of an illegal interrogation. The justice court concluded that Defendant was not required to receive Miranda warnings because he was not subject to custodial interrogation at the check station. Defendant was then found guilty on all three counts. The district court affirmed. The Supreme Court affirmed, holding (1) Defendant was not taken into custody for purposes of Miranda, and therefore, the statements he made to FWP game wardens were admissible against him; and (2) under the totality of the circumstances, Defendant’s admissions and confession were voluntary. View "State v. Maile" on Justia Law

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Petitioner sought relief under 28 U.S.C. 2254 after the district court granted a certificate of appealability on the narrow procedural question of whether a habeas petitioner's claims raised for the first time in objections to a magistrate judge's proposed findings and recommendations must be heard by the district judge. The Fifth Circuit broadly answered in the affirmative, but found in this case that the district court did not commit reversible error. Accordingly, the court affirmed the judgment. View "Samples v. Ballard" on Justia Law

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The City of Houston, Alaska fired its police captain shortly before disbanding its police department. The captain claimed he was terminated in bad faith in order to stop ongoing investigations into city leaders. He challenged: (1) the superior court’s refusal to allow his claim under the Alaska Whistleblower Act; (2) a jury instruction stating that termination for personality conflicts did not constitute bad faith; and (3) an award of attorney’s fees and costs. The Alaska Supreme Court concluded that the court’s refusal to allow his claim under the Whistleblower Act, its decision to give the personality conflict instruction, and its award of attorney’s fees and costs were not erroneous and therefore affirmed. View "McNally v. Thompson" on Justia Law

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The Supreme Court vacated the judgments of conviction entered in the superior court following a jury trial convicting Defendant of three counts of assault with a dangerous weapon and one count of carrying a pistol without a license. The Supreme Court held (1) the superior court justice erred in denying Defendant’s motion to suppress evidence seized by police during a warrantless search of Defendant’s home because the state failed to overcome the presumption of unreasonableness that accompanies every warrantless entry into a home; and (2) the admission of the unlawfully seized evidence was not harmless beyond a reasonable doubt. View "State v. Terzian" on Justia Law

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The Supreme Court affirmed the judgment of the superior court following a jury verdict in favor of Plaintiff on a single claim of employment discrimination based on national origin. Both parties appealed the judgment. The Supreme Court denied and dismissed all appeals, holding that the superior court justice (1) did not err in instructing the jury on the law of evidentiary presumptions and its application to this discrimination claim; (2) properly weighed the evidence and did not invade the province of the jury; and (3) did not err when she vacated the jury’s finding that Plaintiff failed to mitigate his damages. Further, Plaintiff was not entitled to judgment as a matter of law on a separate count in the complaint that also alleged employment discrimination. View "Yangambi v. Providence School Board" on Justia Law

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Plaintiffs, the parents of six children, filed suit against the District, alleging that it was violating the "Child Find" requirement of the Individuals with Disabilities Education Act (IDEA) by failing to provide special education to their children and hundreds of other preschoolers with disabilities. The district court certified the suit as a class action and entered a comprehensive injunction designed to bring the District into compliance with the IDEA. The DC Circuit held that the case was not moot where it remains justiciable under United States Parole Commission v. Geraghty, 445 U.S. 388 (1980), and where the relation back doctrine applied in this case. The court also held that the district court did not abuse its discretion by certifying subclasses pursuant to Federal Rule of Civil Procedure 23(b)(2). Finally, the court rejected the District's challenges to the injunction, affirming the district court in all respects. View "DL v. District of Columbia" on Justia Law

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Petitioner, convicted of attempted criminal contempt in the second degree and harassment in the second degree, petitioned for habeas relief under 28 U.S.C. 2254. Petitioner was sentenced to a one-year conditional discharge, with the condition that she abide by a two-year order of protection. The Second Circuit affirmed the district court's dismissal of the petition, holding that the order of protection did not place her "in custody" for purposes of section 2254(a). View "Vega v. Schneiderman" on Justia Law

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In this employment discrimination case, prejudicial errors in four jury instructions required a new trial. Plaintiff filed claims against her former employer, alleging sexual harassment and retaliation under the Iowa Civil Rights Act (ICRA). The jury returned a verdict for Plaintiff on both counts and awarded damages in the amount of $1.4 million. Employer then filed a motion for new trial, which the district court denied. The Supreme Court reversed, holding (1) workers may bring a direct-liability negligence claim under the ICRA against an employer for supervisor harassment, but the plaintiff must prove that the employe knew or should have known of the harassment and failed to take prompt and appropriate remedial action to end it; (2) the district court did not abuse its discretion in admitting expert testimony on legal standards; but (3) the district court misinstructed the jury in four jury instructions, necessitating a new trial. View "Haskenhoff v. Homeland Energy Solutions, LLC" on Justia Law

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On September 26, 2014, plaintiff filed suit against the school district, alleging discrimination, hostile work environment, and retaliation claims (Welsh I). On December 16, 2014, the school district filed a plea to the jurisdiction in Welsh I, wherein the school district maintained, inter alia, that plaintiff's claims were barred by the statute of limitations because she filed her lawsuit more than two years after she filed her charge. The state district court granted the plea and dismissed the claims in Welsh I. On May 12, 2005, plaintiff filed this case against the school district (Welsh II), alleging claims for discrimination under Title VII and the Age Discrimination in Employment Act (ADEA), as well as retaliation claims. The Fifth Circuit held that the only claims in Welsh II that were barred under res judicata were those that were mature at the time that plaintiff filed her petition in Welsh I. The court vacated and remanded because the parties have not brief this issue under this framework and because at least some facts supporting plaintiff's alleged claims clearly were not extant at the time Welsh I was filed such that a claim could not have been mature based upon those facts. View "Welsh v. Fort Bend Independent School District" on Justia Law

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Halbach disappeared on Halloween 2005. Her family contacted police after she did not show up at the photography studio where she worked and her voice mailbox was full. Officers focused on the Avery Auto Salvage yard in Two Rivers, Wisconsin, the last place she was known to have gone. Avery, the son of the business owner, lived on the property. That day, Avery called Auto Trader magazine, for whom Halbach worked, to request that she photograph a minivan that he wished to sell. The police suspected that Avery’s 16‐year‐old nephew, Dassey, who also lived on the property, might have information about Halbach’s murder and called Dassey into the police station. After many hours of interrogation over several days, Dassey confessed that he, with Avery, had raped and murdered Halbach and burned her body. Before trial, Dassey recanted his confession. The state failed to find any physical evidence linking him to the crime. He was convicted and sentenced to life in prison. After unsuccessful state appeals and post‐conviction proceedings, Dassey sought federal habeas relief, claiming that he did not receive effective assistance of counsel and that his confession was not voluntary. The Seventh Circuit affirmed the district court in granting relief. The state court did not apply the proper standard; juvenile confessions require more care. “If a state court can evade all federal review by merely parroting the correct Supreme Court law, then the writ of habeas corpus is meaningless.” View "Dassey v. Dittmann" on Justia Law