State Supreme Court Data Tracker

Summary of Case Context & HoldingVolkswagen programmed their vehicles with "defeat device" software that would enable Volkswagen vehicles to perform better than they would otherwise on federal emissions tests. Volkswagen also recalled older vehicles to install updated software. The state of Ohio brought a claim against Volkswagen for its post-sale vehicle-emissions tampering under Ohio's Air Pollution Control Act. Volkswagen argued that the federal Clean Air Act preempts Ohio's Act. The Supreme Court disagreed and held that the Clean Air Act did not expressly preempt Ohio's Act because the Clean Air Act expressly preempts states from regulating emissions in "new motor vehicles" whereas Ohio's Act punished tampering with emission control systems "after sale."

Summary of Case Context & HoldingPlaintiffs, who were individuals who were taxpayers and registered voters in Wisconsin, brought action against the Wisconsin Elections Commission based on allegation that the Commission failed to comply with statute requiring that a voter's registration status be changed when officials receive reliable information that the voter has moved out of the municipality. The taxpayers argue that the Elections Commission is required to deactivate movers and to initiate contact with electors whose “record is deemed to be inaccurate or out-of-date.” The Supreme Court ruled that the Wisconsin Elections Commission has no mandatory duties under Wisconsin law that govern the Commission's affirmative responsibility to contact voters that may have relocated. Instead, the law creates a duty of municipal clerks and municipal Boards of Election Commissioners to do so.

Summary of Case Context & HoldingAn automobile insurer moved in two separate cases to vacate arbitration awards of no-fault benefits following judgments in negligence actions by insureds. In the first case, the district court granted the insurer's motion to vacate the insured's arbitration award, concluding that both the express public policy purpose of the Minnesota No-Fault Automobile Insurance Act (NFA), Minn. Stat. §§ 65B.41–.71, and collateral estoppel, bar an award of benefits in a no-fault arbitration based on the same medical expenses previously awarded as damages in a negligence action. Insured appealed. In the other case, the district court denied the insurer's motion, concluding that collateral estoppel did not preclude the insured from arbitrating her claim for no-fault benefits for medical expenses and wage loss that she had claimed but had not recovered in her negligence action. The cases were consolidated on appeal. The court of appeals affirmed in part and reversed in part, concluding that the NFA does not preclude an insured from obtaining no-fault benefits for the same economic loss for which damages were previously awarded in a negligence action. The court of appeals also concluded that collateral estoppel does not bar an insured who brings a negligence action from later seeking benefits for the same economic loss in no-fault arbitration. The Supreme Court affirmed, holding that: (1) the insured suffered a “loss” as she received bills despite recovery of past medical expenses in tort suit; (2) the NFA did not bar no-fault benefits for medical expenses recovered in prior negligence action; and (3) judgments in negligence actions did not collaterally estop insureds from seeking such benefits from insurer.

Summary of Case Context & HoldingIn 2008, five years after his juvenile adjudication, C.K., the Defendant, filed his first petition for post-conviction relief (PCR), seeking, among other things, a judicial declaration that the Megan's Law lifetime registration and notification requirements violated his constitutional rights. Even though the Defendant was a juvenile at the time of the offense, he was prevented from ever being removed from the registry due to the nature of his offense. Megan's Law mandates lifetime placement on the sex-offender registry for young people between the ages of 14 and 18 who commit certain sex offenses. The trial court denied the petition which was confirmed on appeal. The Supreme Court, however, held that the portion of Megan's Law that denies juvenile defendants the opportunity to be removed from the registry and relief from community notification requirements violated such defendants' substantive due process guarantee. The Court noted a number of arguments, including, among other things, that (i) juveniles' emotional, mental, and judgmental capacities are still developing and that their immaturity makes them more susceptible to act impulsively and rashly without consideration of the long-term consequences of their conduct; (ii) juveniles adjudicated delinquent of committing sex offenses, such as the Defendant, who have been offense-free for many years and assessed not likely to reoffend, pose little risk to the public; and (iii) categorical lifetime notification and registration requirements may impede a juvenile’s rehabilitative efforts and stunt a juvenile's ability to become a healthy and integrated adult member of society.

Summary of Case Context & HoldingA juvenile was charged with unlawful possession of a firearm, aggravated assault by pointing or displaying a firearm at law enforcement officers, and other crimes. The juvenile filed a motion to suppress the firearm evidence and the State filed a motion for waiver of jurisdiction from the Superior Court, Chancery Division, Family Part (a division of the New Jersey state court, which hears juvenile cases) and transfer of the case to Law Division, Criminal Part (a different division of the New Jersey state court, which hears adult criminal cases) for the juvenile to be tried as an adult. The superior court initially elected to hear the suppression motion first, but then, on reconsideration, ruled that the waiver motion should be heard first, based on an alleged general preference for waiver motions to be heard before other pending motions. The superior court then stayed its ruling pending a motion for leave to appeal the ruling regarding the order of the hearings, which was granted. The Appellate Division affirmed but ruled that the Family Part should apply the general preference to have the suppression hearing conducted first. The juvenile filed motion for leave to appeal to the New Jersey Supreme Court and the State filed a cross-motion for leave to appeal, both of which were granted. The issues presented to the New Jersey Supreme Court were (1) whether the Family Part should "apply a general preference" to hear suppression motions before deciding waiver motions; and (2) whether the trial court abused its discretion in this case by choosing to hear the state's waiver motion before the juvenile's suppression motion. The Court held that: (1) New Jersey did not apply a general preference for the Family Part's resolution of the juvenile's motion to suppress before consideration of the State's motion to waive the Family Part's jurisdiction; (2) it was within the Family Part's sound discretion to decide the order in which it heard the suppression and waiver motions; and (3) the Family Part did not abuse its discretion in deciding the State's waiver motion before juvenile's suppression motion. The Supreme Court reasoned that, considering the differences between juvenile court and criminal court, and the importance of a trial court's right to control its own calendar, the order of the waiver and suppression proceedings does not touch upon the juvenile's due process rights. The Court also accepted the lower court's reasoning that if probable cause were found for the juvenile to be tried as an adult, it would defeat the purpose of hearing the suppression motion first.

Summary of Case Context & HoldingAppellant Smart Growth filed a complaint challenging the City of Minneapolis's (City) 2040 Comprehensive Plan, alleging that adoption of the Plan violated the Minnesota Environmental Rights Act (MERA) because it was "likely to cause the pollution, impairment, or destruction of the air, water, land or other natural resources located within the state." The Court reversed the district court's dismissal of the claim, holding that (1) it was not barred by an administrative rule promulgated under the Minnesota Environmental Policy Act (MERA) that exempted the City from conducting an environmental review, and (2) the complaint adequately alleged a causal link between the City's adoption of its 2040 Comprehensive Plan and the purported materially adverse environmental effects.

Summary of Case Context & HoldingThe defendant, a 17-year old juvenile, was tried with multiple charges stemming from two separate shootings, including two counts of aggravated murder. On appeal, the defendant argued that the trial court's sentence was cruel and unusual punishment in violation of the Eighth Amendment because the trial court imposed a sentence of life imprisonment without parole without considering his youth as a mitigating factor. The Supreme Court held that the trial court was required to specifically consider a defendant's status as a juvenile offender as a mitigating factor before sentencing him to life imprisonment without the possibility of parole.

Summary of Case Context & HoldingThe state of Ohio filed a complaint against the Defendant for aggravated robbery and a motion seeking to transfer the Defendant from juvenile court to adult court to be tried as an adult pursuant to Ohio laws that provide for the mandatory transfer if certain criteria are met. The Defendant argued that mandatory transfer laws in Ohio violates due process and equal protection rights as well as the prohibition against cruel and unusual punishment. The Supreme Court held that it was constitutional (not a due process violation) for 16 and 17 year old juvenile offenders accused of qualifying offenses to be tried as adults because an amenability hearing for juveniles is not a recognized substantive due process right and the transfer of certain juvenile offenders to the general division to be tried as an adulty does not violate "fundamental fairness" procedural due process because there was a proceeding in front of a juvenile division judge to determine whether there was probable cause prior to the case being transferred to the general division.

Summary of Case Context & HoldingA grand jury returned an indictment charging Defendant with murder and other crimes. The trial court entered an order suppressing the entirety of Defendant’s video-recorded statements with two sheriff deputies, finding that Defendant was in custody no later than the time when he was placed in an interrogation room and shackled to the floor because no reasonable person could believe that he was free to leave under these circumstances. The trial court excluded defendant’s pre-Miranda and post-Miranda statements as having resulted from an “[interrogate] first[,] warn later” procedure. The State appealed the suppression of the recorded statements. The Supreme Court held that the trial court did not address the existence, credibility, or weight of any such evidence, nor did the trial court make any findings or draw any conclusion as to whether the investigator’s two-step interrogation was a deliberate strategy, used in a calculated way to undermine the Miranda warning. The trial court’s judgment suppressing defendant’s post-Miranda statements was vacated, and the case remanded, so the trial court could make further findings of fact and apply the correct legal standard.

Summary of Case Context & HoldingDefendant is appealing his conviction in a criminal trial on the grounds of, among other things, ineffective assistance of counsel. Among one of the ineffective assistance claims raised was about the trial counsel's failure to object to the State's evidence of Defendant's homosexual relationship with his co-arrestee. The Supreme Court held that such an objection would have been without merit, as the State was entitled to establish the Defendant's relationship with his co-arrestee (a key witness as trial), the State did not belabor the point beyond that limited purpose, and trial counsel had sought through voir dire to eliminate jurors who may have had biases against homosexuality.

Summary of Case Context & HoldingAdair was placed on supervised probation for two felony convictions for solicitation to possess crack cocaine for sale. During his probation, an informant repeatedly told police that Adair was still selling crack cocaine. Based on the information from the informant, the probation department conducted a warrantless search of Adair’s residence with police and the officers found and seized crack cocaine, scales, packing materials, cash, a gun, and ammo. Adair was charged with felony possession of narcotic drugs for sale, possession of drug paraphernalia, and misconduct involving weapons. Prosecution moved to revoke his probation. Adair moved to suppress the items arguing it was a warrantless, pretextual search by police not by probation officers, as agreed under his probation agreement where he agreed to submit to search and seizure by probation without a warrant. The trial court rejected that argument but on a motion for reconsideration granted the motion to suppress because the probation officers lacked “reasonable suspicion” and did not have a sufficient legal basis. The court of appeals disagreed and vacated the order granting the motion to suppress. The Supreme Court addressed solely the issue of whether a warrantless probationary search may be carried out without a showing of probable cause or reasonable suspicion (a matter the Court noted had not yet been settled by the U.S. Supreme Court) and held that the search of Adair’s residence was lawful under the Fourth Amendment of the United States Constitution because the search was reasonable under the totality of the circumstances and therefore complied with the Fourth Amendment. The Court noted that the Supreme Court has not required reasonable suspicion as a threshold for warrantless probation searches and this Court would not do so either in part because probationary searches are materially different from other types of searches. The Court further explained that the Fourth Amendment does not categorically require reasonable suspicion for all warrantless searches of a probationer’s residence. Further, the Court rejected Adair’s argument that the privacy clause of the Arizona Constitution prohibited the search because a search pursuant to a valid probation condition is not without authority of law. The order granting the motion to suppress was reversed and the case was remanded to trial court.

Summary of Case Context & HoldingThe case involved the appeal of a judgment affirming an aggravated-murder conviction and death sentence. More than 20 years after the victim's death, DNA evidence revealed that the Defendant had likely raped the victim and murdered her after doing so. At the time of his arrest, the Defendant had been released on parole for three years for a prior rape conviction. A jury convicted the Defendant of aggravated murder in connection with the rape and murder of the victim and unanimously recommended the death penalty. The trial court accepted the recommendation and sentenced Defendant accordingly. The Seventh District Court of Appeals affirmed the conviction and sentence, and Defendant thereafter appealed to the Supreme Court. The Supreme Court held, among other things, that the Defendant's constitutional right to a speedy trial was not violated because such a right does not apply prior to arrest, indictment, or other official accusations, irrespective if the defendant is incarcerated for 22 years on different criminal offenses. Additionally, the Supreme Court held that a pre-indictment delay of approximately 22 years did not violate due process rights and that the trial court could provide a single omnibus capital specification (have them vote only for the death penalty overall, or not for the death penalty) without instructing jurors that they had to return a unanimous verdict as to each predicate felony in the specification for that felony to qualify as a supporting underlying offense for aggravated murder charge (a more granular vote for each component part that could contribute to a death penalty verdict), did not violate Defendant's constitutional right to unanimous jury.

Summary of Case Context & HoldingDefendant was found guilty of two counts of sexual conduct with a minor and three counts of child molestation. Defendant committed these acts from 2006 to 2008, when he was between the ages of ten and twelve, but was tried and convicted at 23 years old. Defendant appealed, arguing the court's decision was improper under Proposition 102. Proposition 102 amended the Arizona State Constitution in 1996 and provided that (1) the court’s jurisdiction and authority regarding juvenile proceedings would be determined by the legislature or people of Arizona (via referendum), rather than by the court itself; and (2) juveniles 15 years of age or older accused of violent felony offenses would be prosecuted as adults. Defendant argued that under Proposition 102, unlawful conduct committed by a juvenile younger than 14 years is only a delinquent act and not a criminal offense. He argued that delinquent acts may only be prosecuted in juvenile court, and thus, the State could not prosecute him for these offenses since he had reached adulthood. The Supreme Court rejected the argument, reasoning that Proposition 102 does not create a substantive difference between “delinquent acts” and criminal offenses. Instead, Proposition 102 merely clarifies that “delinquent acts” are juvenile criminal offenses that are governed by the juvenile code. Whether an offender is held accountable as a juvenile or as an adult depends entirely on the offense and the offender’s status at the time proceedings are initiated. The Court concluded that the State could prosecute Defendant for the offenses he committed as a child in adult court because he was an adult when proceedings began.

Summary of Case Context & HoldingDefendant was convicted of sexual intercourse without consent. Defendant appealed the conviction on the grounds that the prosecutor committed plain error during his closing argument when he asserted that the jury could either believe the child victim or defendant and his friends, that the victim had “no motive” or “other reason” to lie and “was telling . . . the truth,” and that the defense witnesses “lied.” The Court held that while the comments were improper under the circumstances, they were not plain error given that defense counsel asked defense witnesses whether they “cook[ed] up a story” and would “lie for" their friend. Both closing arguments focused on why the jury should believe that party’s witnesses and not those of the other side. This case is frequently cited for the Court’s discussion of review of prosecutorial misconduct on appeal. Specifically, while the Court generally does not address on appeal claims of prosecutorial misconduct that are not objected to at trial, the Court may in its discretion review for plain error situations that "implicate a defendant's fundamental constitutional rights when failing to review the alleged error may result in a manifest miscarriage of justice, leave unsettled the question of the fundamental fairness of the proceedings, or compromise the integrity of the judicial process." In this case, the Court reasoned that having reviewed the trial transcript and considered the comments in the context of the entire argument and in light of the specific evidence presented by both sides, it did not conclude that failure to review Defendant's claims would result in a manifest miscarriage of justice, leave unsettled the fundamental fairness of his trial, or compromise the integrity of the judicial process. By failing contemporaneously to object to the prosecutor's comments concerning witness credibility, Defendant waived his right to do so on appeal. The Court affirmed the judgment.

Summary of Case Context & HoldingMark Fornaciari, and Defendant's then-boyfriend Philip Izzo worked as construction officials for Raritan Township. Defendant took Fornaciari's personnel file, which was related to an ongoing whistleblower investigation, from Izzo's truck. The personnel file was then mailed to the construction office. A detective made several attempts to contact Defendant, and ultimately pulled her over despite not seeing her commit a traffic violation. The detective approached and said he wanted to discuss the investigation. The detective told Defendant multiple times that she was free to leave. Defendant ultimately admitted during the traffic stop that she sent the file at the behest of Izzo in an attempt to get Fornaciari in trouble with the township, drafted the letter enclosed in the package, and intentionally listed the wrong return address. During a subsequent investigative interview with police in the presence of her attorney, Defendant asserted she had permission to enter the truck, that she accidentally grabbed the file, and decided to send it back to Fornaciari to spite Izzo and help with the whistleblower lawsuit. Defendant was arrested and charged with false reporting, hindering apprehension, and burglary. She moved to suppress her roadside statement based on a violation of the Fifth Amendment. The trial court denied her motion and admitted the statement. The Appellate Division reversed. The Supreme Court held, on the basis of both the United States and New Jersey constitutions, that law enforcement must have reasonable and articulable suspicion of a traffic violation, the commission of a crime, or unlawful activity before executing a traffic stop. Therefore, the Court held that Defendant's statement should have been excluded at trial, and the Court affirmed the Appellate Division's reversal of Defendant's convictions.

Summary of Case Context & HoldingAfter the jury was unable to reach a unanimous verdict on the charge of felony murder, that charge was mistried. Subsequently, the State failed to promptly retry the Defendant for felony murder and the case remained off the trial calendar for eight years. The Defendant was sentenced to a term of imprisonment for cruelty to a child and eventually was released from prison on parole. Years later, the prosecuting attorney realized that the Defendant was never retried for felony murder, and asked the trial court to put the case back on the trial calendar. The Defendant moved to dismiss the charge of felony murder, asserting that the delay in retrying him denied him his constitutional right to a speedy trial. The trial court balanced the four Barker-Doggett factors and granted the Defendant's motion. Barker v. Wingo, 407 U.S. 514 (1972), and Doggett v. United States, 505 U.S. 647 (1992) guide a court in its consideration of whether a delay in bringing an accused to trial amounts to a denial of his right to a speedy trial. The four factors are: (1) whether the delay before trial was uncommonly long; (2) whether the government or the criminal defendant is more to blame for that delay; (3) whether, in due course, the defendant asserted his right to a speedy trial; and (4) whether he suffered prejudice as the delay's result. The Supreme Court affirmed, and held that the nearly eight year passage of time before the case was restored to the trial calendar raised a presumption of prejudice. The trial court attributed more than six years of the delay to the negligent inaction of the State. Although Defendant did not assert his right to a speedy trial until his case was restored, his delay was mitigated by several circumstances, including that he was effectively without counsel after his motion for a new trial was denied, was incarcerated for a period of the time, and had a limited education. The trial court also found that the presumptive prejudice was substantial, since Defendant would be faced with allegations that were over nine years old, and that circumstance alone practically impaired putting on a defense.

Summary of Case Context & HoldingThe Supreme Court held that postconviction DNA testing is available to Defendants who pled guilty. The Court reached this conclusion by evaluating the text of a statute, N.C.G.S. § 15A-269, that governs when a convicted defendant is entitled to post-conviction DNA testing of evidence in North Carolina. The Supreme Court found that the statute did not explicitly exclude those who pled guilty from seeking postconviction DNA testing. The Supreme Court also considered the legislative purpose behind the statute and determined that because the statute was "remedial" it should be construed broadly to include defendants who pled guilty. Courts commonly do this with remedial statues. In this case, Defendant entered a guilty plea to second-degree murder. Two decades later, Defendant filed a postconviction motion for DNA testing of evidence found at the scene of the crime. The Supreme Court held that postconviction DNA testing can be available to defendants who pled guilty and showed materiality of the DNA evidence, but, in this case the Defendant did not show materiality of the DNA evidence. In cases where the defendant pled guilty, defendants show materiality by demonstrating a reasonable probability that the DNA testing would have produced a different outcome at trial. Because the Supreme Court determined that the DNA evidence would not be material, the Supreme Court affirmed the appellate court decision that the trial court did not err in denying Defendant's motion for DNA testing.

Summary of Case Context & HoldingThe juvenile Appellant was convicted of three counts of first-degree felony murder while committing or attempting to commit aggravated robbery, one count of first-degree premeditated murder, and two counts of second-degree murder, stemming from a January 2010 incident where Appellant entered a corner market and attempted (but botched) an armed robbery where the murder victims were the store owners and a customer. In September 2011, a jury found the Appellant guilty, and in October 2011 the district court sentenced Appellant to two consecutive sentences of life with the possibility of release after 30 years for the felony murders, and a mandatory life imprisonment without the possibility of release (LWOR) sentence for the first-degree premeditated murder of the customer. Appellant filed a direct appeal, which the Supreme Court of Minnesota stayed to allow postconviction proceedings to proceed. In a consolidated appeal to the Supreme Court of Minnesota, the Appellant was successful in arguing that per Miller v. Alabama, 567 U.S. 460 (2012) (holding that mandatory life-without parole sentences for juvenile homicide offenders are unconstitutional), the mandatory sentence of LWOR was unconstitutional, but was unsuccessful in arguing that the district court’s discretionary imposition of two consecutive sentences of life imprisonment with the possibility of release after 30 years for the felony murders also violated Miller. Ultimately the case was remanded for resentencing and the district court resentenced the Appellant's first-degree murder conviction to life with possibility of release after 30 years, and ordered that sentence run consecutively to the two consecutive sentences of life with possibility of release after 30 years for the second-degree murder charges. Appellant appealed, arguing that Miller (as clarified by Miller v. Alabama, 567 U.S. 460 (2012) (holding that Miller determined that life imprisonment without the possibility of parole is unconstitutional for all children except for the rare juvenile offender whose crime reflects irreparable corruption or permanent incorrigibility) should be extended to his case because (1) his three consecutive sentences are, in the aggregate, the ‘‘functional equivalent’’ of LWOR; (2) his consecutive sentences violate his right to equal protection under the Minnesota Constitution; and (3) the district court abused its discretion in sentencing him to consecutive sentences because the resulting aggregate sentence unfairly ‘‘exaggerates the criminality’’ of his conduct. The Supreme Court of Minnesota disagreed, holding that the Eighth Amendment prohibition against imposition of mandatory sentence of life without possibility of parole for murder committed by a juvenile under Miller did not apply to consecutive life sentences with possibility of release after 30 years on multiple counts of murder, even if such sentence, in the aggregate, was the functional equivalent of life without possibility of release. The Supreme Court further held that consecutive sentences of life with possibility of release after 30 years on multiple murder convictions committed when the juvenile was 16 years old did not constitute abuse of discretion. In dissent, Justice Chutich argued that to be consistent with Miller (as clarified by Montgomery), along with other U.S. Supreme Court precedent, the characteristics of youth and the prospects for rehabilitation must be evaluated before a juvenile offender is condemned to a lifetime in prison, no matter whether the juvenile committed one offense or multiple offenses.

Summary of Case Context & HoldingDefendant was arrested without a warrant for the death and abuse of her cousin. A jury convicted Defendant of first-degree felony murder, conspiracy to commit child abuse, and three counts of child abuse. The jury imposed the death sentence on the murder conviction and maximum and aggravated terms of imprisonment on the remaining counts. Defendant appealed both the judgments and the sentences, arguing that her trial was fundamentally flawed because the trial court erroneously admitted conversations between her and her husband while they were in police custody, violating her Fourth Amendment rights. The Supreme Court rejected this defense. The Court reasoned that the "legitimate security interest in monitoring and recording its interview rooms, along with the common knowledge that these rooms are being monitored, extinguished any already diminished expectation of privacy [Defendant] had while in custody." As for the non-capital counts against Defendant, to impose a maximum sentence, at least one aggravator must be found, Ariz. Rev. Stat. § 13-701(C), but to impose an aggravated sentence, at least two aggravating circumstances must be found for a first-time offender. The Supreme Court reviewed all 20 sex aggravating factors enumerated by statute, and only found that one applied. The Supreme Court held that (1) Defendant was not entitled to reversal of her convictions based on her allegations of error; and (2) as to count four, because only one aggravating factor was found, the aggravated sentence was not justified.

Summary of Case Context & HoldingThe Defendant was convicted of homicide by intoxicated use of an automobile. Defendant filed a post-conviction motion for a new sentencing hearing, contending that Wisconsin precedent prohibited the sentencing court in his case from considering that he had previously completed supervision in another case where the record of conviction had been expunged pursuant to Wis. Stat. § 973.015. The circuit court denied the motion. On appeal the Supreme Court affirmed the denial, holding that the sentencing court permissibly considered the Defendant’s expunged record for substantial battery in the other case because the sentencing court had not obtained that information from expunged court records, but rather from sources other than expunged court records. Accordingly, consideration of the facts underlying the crime itself was permitted.

Summary of Case Context & HoldingDefendant was charged with offenses related to the manufacture, possession, and sale of illegal drugs. During a traffic stop, an officer found marijuana and a large sum of cash in the Defendant's car. The officer then applied for a warrant to search the Defendant's home. The officer supported the warrant application with an affidavit discussing the traffic stop and stating that in the officer's experience drug dealers keep evidence of such activities in their homes. After getting the warrant, officers found digital scales, packaging materials, and other evidence in Defendant's home. At trial, the court granted Defendant's motion to suppress evidence seized during the search of Defendant's home on the grounds that the officer's affidavit did not show probable cause for the warrant and to conduct the search. The court of appeals affirmed the trial court's ruling on the lack of probable cause. The Supreme Court reversed and remanded, finding that the magistrate judge who originally issued the search warrant had a substantial basis to find the officer had probable cause. The Supreme Court held that the quantity of cash and marijuana found in the Defendant's car, as well as the officer's judgement based on experience, formed the substantial basis to find probable cause existed to issue the search warrant.

Summary of Case Context & HoldingPetitioner, Donald Marquice Anderson, was subject to a Terry stop and frisk by police officers while walking in the vicinity of a drug raid. See Terry v. Ohio, 392 U.S. 1 (1968) (holding that police officers may stop, briefly detain, and search an individual without probable cause if the police have reasonable suspicion based on articulable facts that the individual is involved in criminal activity). After searching Petitioner, the police found a bag of cocaine on him, arrested him, and he was later indicted for possession with intent to distribute. Petitioner moved to suppress the drugs, arguing that his detention and pat down were unlawful under the Fourth Amendment. The trial court denied his motion to suppress and found him guilty. The court of appeals affirmed. The Supreme Court reversed finding under the specific facts of Anderson’s search and seizure, the police lacked probable cause and even particularized suspicion as is minimally required to detain and search an individual. See United States v. Arvizu, 534 U.S. 266 (2002) (holding that in reviewing reasonable suspicion determinations, a court must look to the totality of the circumstance to determine whether a detaining officer has a particularized and objective basis for suspecting legal wrongdoing). Specifically, the police had obtained a warrant to search a house on Dobbs Street, and the warrant was based on surveillance by officers of drug activity in the home and surrounding area. The police mistakenly believed that the warrant covered the footpath area near the home, but it did not. Petitioner was walking on the footpath when confronted by police, tried to flee, and was ordered to stop before being detained and searched. Ultimately, the Court found a lack of evidence to support a Terry stop outside the bounds of the warrant the officer received, as Anderson’s conduct was not sufficiently dangerous and his search and detention could only be supported by his proximity to criminal activity or a high crime area.

Summary of Case Context & HoldingDefendant, a former county sheriff's officer, was indicted for second-degree official misconduct, third-degree hindering the apprehension or prosecution of another person, and fourth-degree obstructing the administration of the law or government function, arising out of his alleged efforts to help the target of a state narcotics investigation avoid criminal exposure. Leading up to his arrest, the State seized Defendant's iPhones pursuant to a search warrant. After state investigators were unable to access the information on Defendant's seized smartphones, the superior court granted the State's motion to compel Defendant to disclose the passcodes required to unlock the smartphones. In a case of first impression, the Supreme Court held that neither state nor federal protections shielded the Defendant's passcodes. More specifically, the Court found that: (1) Fifth Amendment privilege against self-incrimination did not protect Defendant from the compelled disclosure of the passcodes; (2) disclosure of passcodes was not an incriminating testimonial communication within the meaning of N.J.S.A. 2A:84A-19 and N.J.R.E. 503 and state law protections against compelled self-incrimination because actions that do not require an individual to disclose any knowledge he might have or to speak to his guilt are not testimonial and therefore not protected; (3) state common law privilege against self-incrimination was not violated by order compelling Defendant to disclose the passcodes; and (4) compelled production of the passcodes fell within the foregone conclusion exception because the State knew of the passcodes' existence, Defendant's possession of the cellphones, and the passcodes' self-authenticating nature render the issue one of surrender, not testimony. The Supreme Court found that because the State established the passcodes existed, were in Defendant's possession, and were self-authenticating in nature, the foregone conclusion exception to the Fifth Amendment privilege against self-incrimination applied, and the Fifth Amendment did not protect Defendant from compelled disclosure of the passcodes.

Summary of Case Context & HoldingDefendant was convicted of driving under the influence of alcohol after he drove a vehicle off the road and into victim’s garage. Defendant was sentenced to a total of 12 months in jail with all but seven days suspended, along with certain fines. He was also ordered to pay restitution to victim for damages to her garage. Initially, victim prepared a loss statement showing damages of $3,270. Defendant informed the justice court that it was his understanding that his auto insurance had covered the damage. At a restitution hearing scheduled to resolve the discrepancy, victim’s loss statement was shown to include the costs associated with repainting victim’s entire house (rather than just the garage). Defendant’s insurance company also prepared a loss statement, which did not include repainting the entire house and estimated the costs at $1,910.86. The justice court ultimately ordered Defendant to pay the higher amount, and the district court affirmed. On appeal, the Court held that the justice court properly ordered restitution damages because the victim suffered a pecuniary loss which could otherwise have been recoverable in civil court. The Court then held that the district court’s imposition of the higher restitution award according to victim’s loss statement was clearly erroneous because it was not supported by substantial evidence since a reasonable mind could not conclude, solely from the two estimates, that one was more appropriate than the other.

Summary of Case Context & HoldingDefendant was arrested and charged with two counts of threatening or intimidating, in violation of Ariz. Rev. Stat. § 13-1202(B)(2). The trial court dismissed all threatening or intimidating charges, holding that the statute Defendant was charged under is unconstitutional because it violates due process by punishing a defendant for mere gang membership or association. The Supreme Court affirmed, holding that Ariz. Rev. Stat. § 13-1202(B)(2) violates due process because it enhances criminal penalties based solely on gang status without a sufficient nexus between gang membership and the underlying crime of threatening or intimidating.

Summary of Case Context & HoldingDefendant was charged with trafficking cocaine after a drug-sniffing dog made a positive indication for illegal drugs within the curtilage of his apartment. He filed a pretrial motion to suppress evidence obtained pursuant to the search warrant, arguing that the warrant was not supported by probable cause and thus was in violation of the Fourth Amendment. The trial court reserved ruling on the motion pretrial but later denied the motion after the jury was impaneled. Notably, after the State rested its case, the trial court—sua sponte—granted the motion to suppress and ordered a mistrial without prejudice. The State appealed and the court of appeals affirmed. The Supreme Court granted certiorari to hear the merits of the State’s appeal and decide whether the court of appeals erred in affirming the trial court’s ruling on the motion to suppress. Pursuant to O.C.G.A. § 5-7-1(a)(4), the State may appeal from certain orders “suppressing or excluding evidence illegally seized” in criminal cases, so long as certain elements are satisfied. To appeal an order, the motion had to have been made and ruled upon prior to the sooner of two events—the impaneling of the jury or the defendant being put in jeopardy. In Georgia, jeopardy attaches when the jury has been impaneled and sworn. As to the instant case, Defendant’s motion came before the impaneling of the jury and before Defendant was put in jeopardy. The trial court did not rule on the motion until thereafter. Since the applicable statute did not authorize the court of appeals to hear the State’s appeal, the Supreme Court vacated the judgment and remanded the case for further proceedings.

Summary of Case Context & HoldingThe Defendant was charged with attempting to possess a firearm while subject to a Domestic Violence Protection Order. The order prevented the Defendant from owning or using guns. The order was put in place to protect the Defendant's minor children, mother, and step-father. At trial, the Defendant had, at different times, three court appointed lawyers and two other lawyers who each were dismissed or withdrew. Three of these attorneys withdrew for unspecified reasons. Two others were dismissed upon motions by the Defendant who also filed waiver of counsel forms at the times of dismissal. Defendant proceeded pro se at trial because she was unable to afford an attorney and the judge denied her a fourth court appointed attorney. She was convicted. The court of appeals affirmed the conviction. The Supreme Court reversed the Court of Appeals' decision, finding that the Defendant had not waived the right to counsel. The Court reasoned that the Defendant had clearly expressed her desire to have counsel at the outset of trial, when she said "I would like to get another court appointed attorney." The Supreme Court also found that Defendant's behavior was not sufficiently egregious to warrant forfeiture of the right to counsel. The Supreme Court noted that "highly frustrating" conduct does not rise to the level of egregious conduct. Rather, egregious conduct might be aggressive, profane, threatening, or obstreperous behavior. Essentially, the defendant's actions must make representation impossible to involuntarily forfeit the right to counsel. But in this case the Supreme Court found that the Defendant was seeking to hire counsel earnestly. As such, the Defendant's right to counsel was not waived or forfeited.

Summary of Case Context & HoldingIn response to a call concerning suspicious activity, the police conducted a vehicle stop of an automobile driven by Defendant Atwood, in which Mizrahi (Co-Defendant) was a passenger. Police claimed that the front driver's side head light was out and the vehicle tried to quickly leave the area. Defendants, who were charged with possession of marijuana and cocaine, moved to suppress evidence seized from their vehicle, and disputed the basis for the stop, asserting that both headlights were operational and denied any evasive behavior. The appellate court granted the motion, and the State appealed. The Supreme Court ultimately ruled in favor of the Defendants holding: (i) the State has the burden of proving that reasonable and articulable suspicion supported the police officers' warrantless investigatory stop of Defendants' moving vehicle in suppression hearing, even though officers obtained warrant to search the vehicle after performing the investigatory stop; (ii) the State failed to demonstrate reasonable and articulable suspicion to support police officers' warrantless investigatory stop of Defendants' moving vehicle; and (iii) the officers' search of Defendants' vehicle for drugs pursuant to a search warrant was incident to the officers' prior unlawful investigatory stop of the vehicle, and thus, evidence obtained through that search was subject to suppression as fruit of the poisonous tree. The key reasoning for the Court was that there was no evidence that the Defendants' car would have been searched had it not been for the unsupported vehicle stop, and without such stop, the officers would not have smelled the marijuana.

Summary of Case Context & HoldingThe Defendant pleaded no contest to attempted murder after shooting a young man in the neck on a playground basketball court. Approximately 27 years later, the victim died, allegedly as a result of injuries from the shooting and the state reindicted the defendant charging him with aggravated murder. The Defendant argued that his earlier plea prevents the state from prosecuting him again. The Supreme Court held that the state and Defendant had not entered into a plea agreement when the Defendant pled no contest to attempted murder and felonies assault. A plea agreement would ordinarily bar further charges by the state. However, since there was no plea agreement, after the victim of the crime died several years later, the Supreme Court said the state had free reign to upgrade the charges from attempted murder to aggravated murder.

Summary of Case Context & HoldingThe New Jersey State Police investigated an alleged drug distribution network, identifying Defendant's husband and others as targets of the investigation. The Defendant, a police officer, was accused of using her username and password to access the secure records-management system containing police reports pertaining to the investigation and passing the information she found to her husband and his associates. Prior to trial, the Defendant moved to exclude text messages between herself and her husband, citing the marital communications privilege. The issue presented to the New Jersey Supreme Court was whether the crime-fraud exception to the marital communications privilege applied, given that the New Jersey legislature had not adopted the crime-fraud exception at the time the text messages were sent. The Supreme Court reasoned that there was no evidence in the legislative history to suggest that the legislature intended the exception to apply retroactively. The Supreme Court therefore held that: (1) the crime-fraud exception to the marital-communications privilege applies prospectively to marital communications that are made on or after the effective date of the amendment establishing the exception; and (2) the crime-fraud exception to the marital-communications privilege did not apply to text messages exchanged between Defendant and her husband. However, the Court found that the trial court's erroneous determination that the crime-fraud exception applied and its admission of text messages was harmless error because the State had presented extensive evidence in support of Defendant's official misconduct convictions.

Summary of Case Context & HoldingAppellant pled guilty in district court to seven counts of possession of child pornography, and was sentenced on all seven counts. Between November 2012 and June 2013, Appellant had downloaded, viewed, and saved to his computer's hard drive seven pornographic images of minors engaged in sexual conduct. Appellant downloaded and saved these photographs on different days, and each photograph depicted a different minor. Appellant appealed his conviction (which was affirmed by the court of appeals) arguing that he could only be convicted and sentenced for one count of possession because the "unit of possession" in the statute is possession of the computer, rather than the individual images stored on it, and his offenses were part of a single behavioral incident. The Supreme Court of Minnesota affirmed the conviction. While the Court acknowledged the dispositive question was what counts as the "unit of possession," it noted that violations of the same statutory provision may be charged multiple times in a single prosecution if the legislature ‘‘intended the facts underlying each count to make up a separate unit of prosecution.’’ The Supreme Court of Minnesota also held that the goal of statutory interpretation is to ascertain and effectuate the intent of the legislature. The Supreme Court of Minnesota concluded that the statute unambiguously criminalizes both the possession of a pornographic work itself and the possession of a computer storing a pornographic work. Accordingly, Appellant could be charged with all seven counts.

Summary of Case Context & HoldingResponding to a call about a house where the front door had remained wide open for some time, a police officer approached two individuals (including the Defendant) who exited a vehicle and “were walking straight towards” that house. In response to questioning, the individuals indicated that they were meeting people on the sidewalk, though the officer did not see any other people in the vicinity, and the individuals were travelling between two homes that would not normally take them past the vacant house. Based on their responses to questioning, the officer became suspicious that the Defendant and his companion were lying, and he asked each of them for their identification. The officer found a probation violation warrant and the Defendant was detained. While patting down the Defendant, the officer felt numerous unknown items in Defendant's pants pockets but because no items felt like a weapon, nothing was retrieved from the Defendant's pockets. After the Defendant was removed from the patrol vehicle the officer searched his patrol vehicle and found a small plastic bag containing methamphetamine. Defendant was charged and convicted of criminal possession of dangerous drugs. The issue on appeal was whether the district court correctly determined that the police officer had the requisite particularized suspicion to conduct an investigatory stop of the Defendant. A police officer has particularized suspicion to conduct an investigatory stop when the officer has “(1) objective data and articulable facts from which he or she can make certain reasonable inferences; and (2) a resulting suspicion that the person to be stopped has committed, is committing, or is about to commit an offense.” The Court held that based on the totality of the facts and circumstances of the case, both prongs of the analysis had been properly satisfied and the officer had a particularized suspicion that justified an investigatory stop of the Defendant.

Summary of Case Context & HoldingAfter Defendant's convictions for statutory rape of 15-year-old child and second-degree rape of mentally disabled person were affirmed on direct appeal, Defendant filed motion for appropriate relief to correct errors that occurred during the proceeding, based on claim that trial counsel was ineffective for failure to raise double jeopardy objection to separate punishments arising out of single act of sexual intercourse. The convictions arose from Defendant’s single act of vaginal intercourse with a juvenile who is mildly to moderately mentally disabled. The superior court denied the motion, and Defendant appealed. Defendant's petition for certiorari review was allowed, and the court of appeals reversed and remanded. The State petitioned for discretionary review. The Supreme Court reversed, holding that it was intended that Defendants be separately punished for a violation of the second-degree rape and statutory rape statutes arising from a single act of sexual intercourse, and therefore, Defendant was not prejudiced by counsel’s failure to raise the double jeopardy argument.

Summary of Case Context & HoldingDefendant Steven Louis Barnes sought to represent himself, but was denied the right to do so, in a trial where he was convicted of kidnapping and murder and sentenced to death. Defendant appealed and the Supreme Court reversed his conviction, allowing him to proceed with a new trial. In his new trial, Defendant sought representation from counsel, which the State argued amounted to a concession that the original conviction was constitutionally obtained and should be reinstated. The circuit court denied the State's argument at the trial level, and the Supreme Court granted a common law writ of certiorari to review the State's related circuit court motion. The Supreme Court disagreed with the State and held that Defendant’s exercise of his Sixth Amendment right to counsel, in a new trial, should neither be infringed by his initial request to waive such right in his original trial, nor does it concede the constitutionality of the original conviction. In assessing the State’s claim, the Court noted that no authority supports the State’s claim or otherwise “permits the remittitur to be recalled, not because of an error or inadvertence on the part of the Supreme Court, but rather because of post-remittitur conduct by a party.” Specifically, the State's argument would require the Supreme Court to recall its own order for the Defendant's trial to be re-heard at the circuit court level based on the Defendant's trial court argument, as opposed to the Supreme Court's finding of error in its own legal analysis or procedure. The Supreme Court found that there is no legal basis to recall the Defendant's case out of the circuit court, based solely on new arguments the Defendant raised at that level. Furthermore, the Court found the State’s argument to be contrary to constitutional and public policy, in that it sought to deprive a Defendant of his Sixth Amendment right to counsel in a new trial, based on the same Defendant’s exercise of their Sixth Amendment right to proceed without counsel in their original trial.

Summary of Case Context & HoldingPetitioner Walter Bash was indicted for trafficking in cocaine and cocaine base. Police, responding to an anonymous tip about drug activity, arrived to a home and parked their car next to a fence surrounding the home. There, officers observed Bash and others behind the house in a "grassy" area, and one of the men discarded what appeared to be cocaine. A subsequent search of Bash's vehicle led to the discovery of drugs. The Supreme Court reversed the court of appeals and reinstated the trial court's suppression of the evidence based on a determination that the police violated the Fourth Amendment by entering the curtilage of the home without a valid warrant to conduct the search. The Court found that the grassy area was part of the home's curtilage and that the officers conducted a search and not a permissible "knock and talk" as the purpose of the officers' actions was to search for drugs. As such, the officers' actions violated the Fourth Amendment by entering the curtilage of the home without a warrant, and thus, the evidence was improperly seized.

Summary of Case Context & HoldingFollowing a fifteen-day trial, Defendant was convicted of murder, attempted murder, and two weapons offenses and sentenced to a sixty-year sentence. Defendant appealed on numerous grounds, including (1) trial court barring Defendant's counsel from exploring a plea bargain with the State's lead witness on cross examination; and (2) trial court allowing expert witness to testify about the opinions expressed by another expert witness. The Supreme Court found that the trial court's handling of both issues amounted to violations of Defendant's confrontation right. The claimed bias of a witness is appropriate for cross-examination and a claim of bias is particularly compelling when the witness is also under investigation or where there are charges pending against the witness at the time of the witness's testimony. The Court found that the trial court erred when it barred Defendant's counsel from pursuing a line of questioning regarding the witness's plea bargain, and that such error was not harmless as the jury may have drawn an inference of bias. Next, the Court concluded that the expert report in question was "testimonial" for purposes of the Confrontation Clause under the "primary purpose" test, and a testimonial report that is not admitted into evidence can engender a violation of the Confrontation Clause if the report is "integral" to the testimony of a substitute witness. Finding that the witness simply parroted the other report, the Court found that the testimony did not conform to the Confrontation Clause and that the trial court committed error when it admitted that testimony.

Summary of Case Context & HoldingThe Defendant plead no contest for aggravated murder. The aggravated murder charge carried two death specifications: murder to escape detection and felony murder. Pursuant to Ohio law, if one plead no contest to aggravated murder, then the defendant waives his right to jury trial and the case is assigned to a three-judge panel because under Ohio's statutory scheme, when a capital defendant waives a jury and enters a no-contest plea, a three-judge panel determines both guilt and the appropriate sentence. The panel found the Defendant guilty and sentenced him to death. On appeal, the Defendant argued that, among other things, Ohio law is unconstitutional because it does not allow a defendant who plead no contest to a capital offense to have a jury determine his or her sentence in violation of the Sixth Amendment. The Defendant also argued that Ohio's lethal injection protocol violates the Eight Amendment guarantee against cruel and unusual punishment. The Supreme Court held, among other things, that a statutory scheme where defendants who plead no contest to a capital offense were referred to a three-judge panel did not implicate Defendant's right to jury trial; and that Defendant did not lack state court remedies to challenge the potential Eighth Amendment unconstitutionality of Ohio's lethal injection protocol.

Summary of Case Context & HoldingDefendant refused chemical testing to determine his blood alcohol content (BAC) during his arrest for operating a vehicle while intoxicated (OWI). The Defendant pled not guilty to the underlying OWI offense, but failed to request a "refusal hearing" to adjudicate his decision not to submit to the BAC test within the statutory ten-day time limit. The jury acquitted him of the OWI charge, and he moved to dismiss the charge of refusing the BAC test. The trial court granted his motion. The Supreme Court held that the trial court did not have discretion to dismiss the refusal charge because giving trial courts this discretion would "eliminate a great deal of the incentive to comply" with BAC testing.

Summary of Case Context & HoldingA jury convicted Defendant of burglary, a second degree felony and he was sentenced to 491-day judicial-sanction prison sentence for the postrelease-control violation and a prison term of 8 to 12 years to be served consecutively. On appeal, the Defendant argued that there was insufficient evidence to support his burglary conviction because the state had failed to prove that he used force, stealth, or deception as required under state law, but the appellate court rejected Defendant's argument, reasoning that the victim's testimony showed that Defendant's “attitude and demeanor” had deceived the victim into believing that the Defendant was not intending to trespass into the garage and steal the leaf blower. The Supreme Court, however, disagreed and reversed and remanded the case, holding that to prove that a defendant trespassed by stealth or deception in a burglary case, the state must prove that the defendant actively avoided discovery or used deceptive conduct to gain entry to the structure.

Summary of Case Context & HoldingDefendant pled guilty to bail jumping (failing to show up in court and then failing to surrender within a set time period) on April 19, 2012. His sentencing hearing was not scheduled until December 28, 2012, which set January 17, 2013 for the hearing. In light of this delay, Defendant filed a motion alleging he was denied a speedy trial because of the delay in his sentencing. Ultimately, due to further scheduling conflicts, he was not sentenced until June 27, 2013. The Court held that the constitutional right to a speedy trial does not apply to the sentencing period, instead holding that due process protects a defendant from unreasonable delay in sentencing. The Court also articulated a balancing test for due process violations in sentencing delays: "if a sentencing delay is purposeful and oppressive, then we must determine that there has been a constitutional due process violation. The determination of whether a delay is oppressive incorporates considerations of whether the defendant has suffered prejudice and the degree and nature of that prejudice." In this case, the Court noted that the delay of 14 months between conviction and sentencing was unacceptable, but most of the delay was institutional and was not a deliberate attempt by the State to delay for purposes of hampering the defense. The Court also noted that most of Defendant's claims of prejudice were speculative, such as anticipated benefits or participation in various Department of Corrections programs, anticipated dates for conditional discharge, and anticipated enrollment in rehabilitation services, all of which would have been further delayed anyway by a separate DUI matter that Defendant had in another county. The Court held that Defendant’s claims of prejudice did not warrant reversal because they were mostly speculative in nature.

Summary of Case Context & HoldingWhile on post release control for a prior felony conviction, the Defendant was indicted on one count of possession of heroin, a fifth-degree felony, and one count of possession of drug paraphernalia, a misdemeanor. At the plea hearing, the trial court did not inform the Defendant that once he pleaded guilty to the possession offense, the court would have the authority under R.C. 2929.141 to terminate the existing post release control and impose a prison term that he would serve consecutively to the term of imprisonment imposed for the possession offense. The trial court then sentenced the Defendant to serve a one-year prison sentence for the post release control consecutively to the sentence for the possession offense and the Defendant appealed, arguing that the had not knowingly, intelligently, and voluntarily pleaded guilty because he was not informed that his post release control can be terminated. The Supreme Court ruled that a trial court must inform a defendant who is on post release control and is pleading guilty to a new felony offense of the trial court's authority to revoke the defendant's post release control and impose a prison term consecutively to any term of imprisonment it imposes for that new felony offense.

Summary of Case Context & HoldingA jury convicted Ricky Lee Blackwell of kidnapping and killing eight-year-old Heather Brooke Center, the daughter of his ex-wife's boyfriend, and recommended a sentence of death. Following sentencing, Blackwell appealed to the South Carolina Supreme Court. In his appeal, Blackwell contended that the trial court erred in: (1) finding him eligible for the death penalty despite evidence of mental retardation; (2) failing to disqualify a juror for cause; (3) denying his Batson challenge. (A Batson challenge derives from Batson v. Kentucky, 476 U.S. 79 (1986) and is a legal objection raised during jury selection in a criminal or civil trial, claiming that the opposing party is using peremptory challenges (the right to exclude a potential juror without giving a reason) to remove jurors based solely on race, which violates the Equal Protection Clause of the Fourteenth Amendment); (4) prohibiting him from cross-examining a State witness using privileged statements the witness made to a mental health counselor and declining to accept the proffer of the mental health records as an exhibit; (5) declining to admit notes of two hospital chaplains as evidence that he was remorseful; and (6) failing to correctly instruct the jury regarding a finding of mental retardation during the penalty phase of the trial. The South Carolina Supreme Court held that (1) the trial court's pre-trial finding that Defendant was not mentally retarded, and thus not exempt from the death penalty, was supported by the evidence; (2) the juror's responses during voir dire did not demonstrate that she was unable to render a verdict according to the law; (3) Caucasian jurors that the prosecution did not strike were not similarly-situated to two African-American jurors who were stricken; (4) the court's error, in deciding not to review a witness's privileged mental health records in camera to determine whether disclosure of records was necessary under Confrontation Clause, was harmless; (5) notes from two hospital chaplains contained subjective opinions and judgments and any error in the court's exclusion of hospital chaplains' notes was harmless; and (6) the sentence of death was not the result of passion, prejudice, or any other arbitrary factor, and the jury's finding of two statutory aggravating circumstances for the murder was supported by the evidence.

Summary of Case Context & HoldingThe Defendant was charged with numerous felonies, a jury found him guilty, and he appealed arguing that he was denied effective assistance of counsel in his two cases in violation of the Sixth and Fourteenth Amendments. The Ohio Supreme Court upheld precedent in State v. Cole, 443 N.E.2d 169 (Ohio 1982) that if an ineffective assistance of counsel claim could have been determined based on the original trial-court record on direct appeal, that such an ineffective assistance claim can be barred by res judicata on postconviction review. However, this is significant because it is often impossible for a defendant to determine that their counsel is ineffective at the moment immediately following the trial court assistance.

Summary of Case Context & HoldingThe police received a tip that the Defendant was outside his residence engaged in an apparent drug transaction. The police did not have or attempt to obtain a warrant to detain the Defendant for the alleged drug transaction, but instead arrested him based upon an Automated Traffic System warrant issued for failure to respond to a summons charging him with driving with a suspended driver's license. The officers pursued the Defendant into a home and found a gun on him. The Defendant was charged with and found guilty of unlawful possession of the gun and argued on appeal that the officers' entry into the residence was not justified by the hot pursuit exception to the warrant requirement under the New Jersey Constitution and the Fourth Amendment of the U.S. Constitution. The issue presented to the New Jersey Supreme Court was whether the detectives had grounds to invoke the hot pursuit doctrine under the totality of the circumstances. The Court held that the officers' warrantless entry into a third party's residence was not justified under the hot pursuit doctrine, and thus violated the Fourth Amendment and New Jersey State Constitution. The Supreme Court reasoned that warrantless entries into a third party home are presumptively invalid unless the State can show that an exception to the warrant requirement applies. The exception under the hot pursuit doctrine did not apply because the warrant for the Defendant was for a minor traffic offense and the officers had no reason to suspect any risk of danger or destruction of evidence relevant to that warrant that would justify the hot pursuit.

Summary of Case Context & HoldingA Defendant was indicted for kidnapping, rape and attempted murder that occurred in 1993 and was cold until 2014 when DNA testing resulted in evidence against the Defendant. The Defendant moved to dismiss the indictment because it had been filed 26 years later and statute of limitations requires prosecutions of most felonies to be commenced within 6 years of the commission of the offense under O.R.C. 2901.13(A)(1)(a) (which establishes the statutes of limitations for criminal offenses). The state opposed the motion, asserting that there is no statute of limitations for attempted aggravated murder under O.R.C. § 2903.01, such that the statutes of limitations listed under O.R.C. 2901.13(A)(1)(a) do not apply. The Supreme Court concluded that the crimes of attempted aggravated murder and attempted murder are governed by the general six-year statute of limitations for felonies, reasoning that the state's provision did not apply because the Defendant was not prosecuted for the felony that had a longer statute of limitations.

Summary of Case Context & HoldingAndre Boston was sentenced to 14 consecutive life terms without the possibility of parole plus a term of 92 years in prison for various "horrific" crimes, including sexual assault, kidnapping, and other violent crimes, including against minors. Boston committed the crimes when he was 16 years old. Based on Graham v. Florida, 560 U.S. 48 (2010), which held that nonhomicide offenses committed by a juvenile could not be punished with a sentence of life without parole, Boston petitioned the court for post-conviction relief. The district court held that Graham's prohibition extended not just to an express life sentence, but also prohibited an aggregate sentence that is the functional equivalent of a life sentence (e.g., over 100 years). The district court vacated Boston's sentence and ordered a new hearing. The State appealed. On appeal, the Court agreed with the district court that Graham extends to prohibit aggregate sentences for nonhomicide offenses that are functionally equivalent to a life sentence. However, in light of Assembly Bill 267, 78th Leg. (Nev. 2015), which provided parole as the remedy for prisoners convicted as juveniles, the Court vacated the district court's resentencing order. Thus, Boston could seek parole, but release on parole was not guaranteed.

Summary of Case Context & HoldingThe Supreme Court held that a trial court violated Defendant's Sixth Amendment right to confront witnesses against him. The trial court had prevented the Defendant from cross examining the States' principal witness, who was in plea negotiations, about whether she would receive favorable treatment for her testimony against Defendant. The plea negotiations regarded charges for drug offenses, where the Defendant was on trial for murder, attempted armed robbery, and possession of a firearm by a felon. The plea negotiations were ongoing in the same jurisdiction as the other charges. The trial court reasoned that when a witness confronts charges in the same jurisdiction where they are testifying bias may be present. As a result, the Supreme Court of found that the Defendant's right to confront witnesses against him includes the right cross examine the witness regarding the charges which are a source of the potential bias. A new trial was ordered.

Summary of Case Context & HoldingBraden complained of inability to pay for basic necessities as an Ohio prisoner, due to civil debt the state administered by withdrawing, on a monthly basis, all money from his commissary account in excess of $25. Although the O.R.C. 2947.23(C) later allowed prisoners to pay civil debt more slowly over time, that statute was passed after Braden's sentencing. The issue before the court was whether a trial court has jurisdiction, pursuant to the current version of O.R.C. 2947.23(C), to waive, modify or suspend court costs for those cases in which the defendant's conviction and sentence became final prior to the enactment of O.R.C. 2947.23(C). The ACLU supported Braden's complaint that (a) state trial courts must consider ability to pay when hearing a criminal defendant's motion to modify court costs; and (b) that defendants may move to modify costs regardless of whether they were sentenced before or after the statute. The Supreme Court ruled that Ohio trial courts retain jurisdiction to modify court costs assessed against criminal defendants after sentencing under O.R.C. 2947.23(C), meaning that they may seek relief at any time based on inability to pay.

Summary of Case Context & HoldingPolice seized the Defendant’s vehicle with probable cause. They obtained a warrant and installed a GPS device to track the vehicle. Later, they followed the vehicle to the scene of a robbery. The police discovered the fruits of the robbery in the vehicle being driven by the Defendant. The Supreme Court held that the installation and use of the GPS device did not violate the fourth amendment because the warrant incorporated a detective's affidavit that described how GPS tracking devices work and gave express permission to install and maintain a GPS device.

Summary of Case Context & HoldingDefendant was stopped for speeding. He pulled into a legal parking spot while the police came to process the ticket. The police discovered he was also driving with a suspended license. The police told the Defendant they would impound the vehicle and began a warrantless inventory search, discovering a firearm, at which point the Defendant was arrested for illegal possession of firearm by a felon. The Defendant moved to suppress the firearm. The Supreme Court granted the motion, reasoning that since Defendant's girlfriend was on her way to retrieve the car, and it was parked legally, the inventory search violated the Fourth Amendment.